Corrective Action Plans

Create a detailed, step-by-step process for federal procurement to ensure compliance and awareness among all staff responsible for spending and reporting federal funds. Washington Local Schools - Federal Grants Management Process Require training for all staff involved in preparing, reviewing, or certifying federal grant reports, prior to beginning any work. Work with a Financial Program Manager at the Office of Budget and Management (Neal Bucklew was the district’s contact on this particular grant) to ensure that all activity reports are submitted correctly and received on time.

Management’s Action Plan: The Neighborhoods Department is committed to ensuring wage rate requirements for contractors and subcontractors are prioritized and internal controls are properly documented. In particular, evidence of approvals needed to ensure compliance with allowable costs, cost principles and period of performance requirements will be documented for all invoices and payroll allocations. Weekly payroll reports will be reviewed as part of the special tests and provisions needed to comply with wage rate requirements. A Labor Standards and Construction Manager has been hired to monitor all contracts with labor standard regulations, including wage rate requirements. This individual will be tasked with setting up tracking systems and monitoring compliance of the various City departments, as well as external subrecipients, to ensure all regulations and requirements for labor standards are followed. Currently, City Departments using federal funds through a MOU with the Neighborhoods Department can access funds and pay vendors without a review by the Housing & Community Development Division’s team. This has led to vendors being paid without submitting the proper wage rate requirement documentation. To mitigate this challenge, the Division has recommended that funds appropriated to other City departments be held by the Housing & Community Development Division, so that verification of wage rate requirements can occur prior to any payment for services. We will ensure that the written procedures for controls include the title of the positions responsible for each control (preparation, review, reconciliation, etc.) and require that the performance of the controls be documented in a clear, reperformable manner including the name of each responsible individual, the specific control they performed over compliance for the grant and the date(s) the controls were performed. Contact Names responsible for the plan – Travis Jeffrey Anticipated completion date of the plan – September 2025

Finding 2024-014 U.S. Department of Housing and Urban Development AL No. 14.241 Housing Opportunities for Persons with AIDS Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2023-011 Auditee’s Corrective Action Plan: Condition #1 Response MOHS acknowledges the finding that 2 out of 2subrecipient files did not have evidence that subrecipient was monitored. Corrective Action: MOHS will follow the City’s Grant Management office’s established process of establishing and maintaining a hardcopy audit file. This file will include: a. Federal System Registrations: SAM, Unique Entity Identification #s, Grants.gov information; b. Federal Financial Accountability and Transparency (FFATA) information; c. FFR Submissions (SF-425 Federal Financial Report); d. Grant Agreements; and, e. Prior Year Single Audits/Monitoring Reports. Condition #2 Response MOHS acknowledges the finding that 2 out of 2 selections did not have information related to the funding source and pass through entity on the notice of award. Corrective Action: MOHS will follow the City’s Grant Management office’s established process of establishing and maintaining a hardcopy audit file. This file will include: a. Federal System Registrations: SAM, Unique Entity Identification #s, Grants.gov information; b. Federal Financial Accountability and Transparency (FFATA) information; c. FFR Submissions (SF-425 Federal Financial Report); d. Grant Agreements; and, e. Prior Year Single Audits/Monitoring Reports. Contact Person: Lakeysha Williams, Director of Programs, Mayor’s Office of Homeless Services Completion Date: April 7, 2025

A new management team is in place for the referenced department and training will be provided to ensure that all staff understand the levels of approval needed before expending funds. The Grants Office, which is in development, will provide additional training and oversight to ensure that grant policies and procedures are being adhered to throughout the County. The Grants Office will be providing grants compliance oversight to ensure timely and accurate submission of all grant-related reports and billings. The County's new ERP system, which includes a grants management module, will allow grantees to more readily monitor, record and report on grant activity. Responsible for Corrective Action: Dorcas Young Griffin, Deputy Chief Administrative Officer and Danielle Schonbaum, Deputy Director, Finance and Administration Anticipated Completion Date: July, 2025

Concur. Due to key vacant positions and the inability to fill these positions, the required subrecipient monitoring activities were not completed during the fiscal year ending June 30, 2024. During the current fiscal year, the County has been successful in recruiting these positions and will ensure that the monitoring activities occur. In addition, policies and procedures will be documented on subrecipient monitoring activities to ensure that they are performed on a regular basis.

Statement of Concurrence or Nonconcurrence: CUAHSI agrees with the finding and recommendation. CUAHSI Corrective Action: Action by CUAHS! impacting audit year 2023: CUAHSI acknowledges that incomplete documentation was available to show subrecipient-monitoring procedures were followed for FY 2023 within the required timeframe. Corrective actions to processes and responsibilities impacting subsequent years: CUAHSI now follows a written Subrecipient Monitoring Policy that specifies the duties of the Director of Finance, Staff Accountant, and Principal Investigator. Monitoring of active subawards began in May 2023. The subaward monitoring process was updated on September 21 2023 and further refined in spring 2024. All subrecipients from FY 2020–2023 have been retroactively certified, and timely reviews were in place for awards from FY 2024 onward. Management performs a mid-year check to confirm that monitoring records are complete, adequate, and securely stored. Name of Contact Person: • Jordan S Read, Chief Executive Officer • Telephone: (339)933-4660 • Email: jread@cuahsi.org Projected Completion Date: NA; is complete

S. Department of Housing and Urban Development (HUD) AL No. 14.241 Housing Opportunities for Persons with AIDS Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes Auditee’s Corrective Action Plan: Condition #1 Response MOHS acknowledges the finding that 3 out of 3 subrecipient files did not disclose the federal award identification number of unique entity identifier on the sub award. Corrective Action: MOHS will follow the City’s Grant Management office’s established process of establishing and maintaining a hardcopy audit file. This file will include: a. Federal System Registrations: SAM; DUNS #s, Grants.gov information; b. Federal Financial Accountability and Transparency (FFATA) information; c. FFR Submissions (SF-425 Federal Financial Report); d. Grant Agreements; and, e. Prior Year Single Audits/Monitoring Reports Condition #1 Response MOHS acknowledges the finding that 3 out of 3 subrecipient files did not have evidence that prior year audit was verified. Corrective Action: MOHS will follow the City’s Grant Management office’s established process of establishing and maintaining a hardcopy audit file. This file will include: a. Federal System Registrations: SAM; DUNS #s, Grants.gov information; b. Federal Financial Accountability and Transparency (FFATA) information; c. FFR Submissions (SF-425 Federal Financial Report); d. Grant Agreements; and, e. Prior Year Single Audits/Monitoring Reports Contact Person: Lakeysha Williams – 410-396-4887 or Lakeysha.williams@baltimorecity.gov Completion Date: July 2024

Finding 2023-002 Program: AL No. 10.523 Centers of Excellence at 1890 Institutions Significant Deficiency and Noncompliance over Subrecipient Monitoring Corrective Action Plan for Significant Deficiency and Noncompliance over Reporting The Foundation developed a matrix for subrecipient monitoring and Single Audit reports/findings is a key attribute in our assessment of risk. Our subrecipient monitoring policy and procedure was completed on November 30, 2023. Additionally, we hired a Program Coordinator in June 2023. The Program Coordinator focuses on the interface work required by our organization to support our grants administration role including subrecipient monitoring The Foundation requires quarterly progress and financial reports from our subrecipients, and our current process is to increase scrutiny of reports and supporting documents, when risk is medium or high. The Foundation performed reviews of subrecipients in 2023, however, the time stamp was not effectively documented. The Foundation has implemented procedures to effectively time stamp the verification process using Sam.gov going forward. Contact Person: Calece Hilliard, CFAO 1890 Universities Foundation Completion Date: September 30, 2024

Item: 2023-002 Assistance Listing Number: 21.027 Programs: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds (SLFRF) Federal Agency: U.S. Department of Treasury Pass-Through Agencies: State of Arizona, Office of the Governor Pass-Through Grantor Identifying Number: EL9HZNBAN1B9 Award Year: July 1, 2022 – June 30, 2023 Compliance Requirement: Subrecipient Monitoring Criteria: In accordance with 2 CFR sections 200.330, .331, and .501(h), pass-through entities must (a) identify the award and applicable requirements, (b) evaluate the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CR section 200.332(b), (c) monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR section 200.332(d) through (f), and (d) ensure accountability for any for-profit subrecipients. Condition: In connection with our testing of Arizona Foundation for Human Service Providers (the Foundation) subrecipient monitoring, we noted that the Foundation did not timely or effectively monitor the activities of subrecipients to ensure that the subawards were used for authorized purposes and complied with the terms and conditions of the subaward. Name of Contact Person: Candy Espino, President & CEO Phone Number: (602) 252-9363 Anticipated Completion Date: September 30, 2024 Views of Responsible Officials and Corrective Actions: Arizona Foundation for Human Service Providers will enhance their existing policies and procedures to ensure sufficient controls are in place to properly monitor subrecipients. We will also include specific enhancements to the ongoing post-payment review of subawards and well as supervision and review controls to ensure the procedures are performed in a timely and thorough manner.

The County Grants Manager will ensure that all subrecipients receiving $750,000 in Federal Funds undergo a Single Audit as required by 2 CFR Part 200. The Grants Manager will review the SEFA and contact all necessary subrecipients for their audits. Name of Contact Person: Kristi D. Bosch, Grants Manager Anticipated Completion Date: 12/31/2024

The County will review the monitoring plan related to the program and will ensure these procedures are done timely and meet the federal requirements for monitoring subrecipients.

Action Plan: Upon learning of this finding during the FY2022 audit, we worked with the Neighborhoods Department to ensure wage rate requirement compliance was prioritized going forward. Considering this finding was presented near the completion of the FY2023 year, we expect this finding to be resolved in FY2024. We will continue to work with our departments to ensure that all controls for grants are documented with written procedures. The procedures will include the title of the positions responsible for each control (preparation, review, reconciliation, etc.) and will require that the performance of the controls be documented in a clear, reperformable manner including the name of each responsible individual, the specific control they performed over compliance for the grant and the date(s) the controls were performed. Contact Names responsible for the plan – Marcia Saulo Anticipated completion date of the plan – September 30, 2024

GRANT REPORTING Finding: The Audit Certification Memo for fiscal year 2022 (due June 30, 2023) and the Section 3 Summary Report (due July 31, 2023) were not filed with the DOC. Further the Contract and Subcontract Activity report (due on April 15, 2023) was not filed timely (filed September 7, 2023). With regards to the reimbursement request, the initial reporting was rejected due to noncompliance with procurement provision in the grant agreement. As a result, the DOC denied $74,813 of the City’s request as ineligible expenditures. Management’s Response: The city has filled a position focused mainly on projects & grants reporting. The employee will verify all grant requirements are fulfilled on time and according to the grant contract. Processes are being put in place that will include conversations with the project manager which will ensure they are notified of the necessary steps to fulfill the requirements, as well as final finance review to ensure compliance. Implementation Timeline: April 1, 2024 Responsible Party: Patrisha Draycott, Chief Financial Officer

Views of Responsible Officials and Planned Corrective Action: The Board agrees with this recommendation and will review monitoring procedures relating to subrecipients.

Finding Reference Number: MW2022-005 Statement of Concurrence or Nonconcurrence: CUAHSI agrees with the finding and recommendation. CUAHSI Corrective Action: Action by CUAHSI impacting audit year 2022: CUAHSI acknowledges that no documentation was available to show subrecipient-monitoring procedures were followed for FY 2022 within the required timeframe. In 2023, a targeted review of all active subawards 2022 was conducted. That effort was then expanded to include (i) written recipient self-certifications and (ii) a formal, documented risk-assessment workflow for CUAHSI management. Retroactive monitoring for every FY 2022 subaward was completed and filed under this enhanced process in spring 2024. Corrective actions to processes and responsibilities impacting subsequent years: CUAHSI now follows a written Subrecipient Monitoring Policy that specifies the duties of the Director of Finance, Staff Accountant, and Principal Investigator. Routine monitoring of active subawards began in May 2023; the process was updated on September 21 2023 and further strengthened in spring 2024. All subrecipients from FY 2020–2022 have been retroactively certified, and timely reviews were in place for FY 2023–2024 awards. Management performs a mid-year check to confirm that monitoring records are complete, adequate, and securely stored. Name of Contact Person: • Jordan S Read, Executive Director • Telephone: (339)933-4660 • Email: jread@cuahsi.org Projected Completion Date: NA; is complete

ORCCA plans to utilize grant tracker system with the ability to send reminders for important dates to avoid future delinquent reporting that was experienced during the audit period. The system will be utilized by the program directors as well as the finance team (Finance Director, Accounting Manager, Program Fiscal Compliance Coordinator) working with grant directors. Responsible party: Bonnie Foroudi, Finance Director Estimated completion date: December 31, 2025

2022-004 Subrecipient Monitoring U.S. Department of Treasury Recommendation: We recommend the County implement internal control(s) to ensure that required subrecipient monitoring through formal agreements is completed. Explanation of disagreement with audit finding: There are no disagreement with the audit finding. Action planned/taken in response to finding: The County will implement adequate controls designed to ensure that subrecipient monitoring requirements are being met. Name(s) of the contact person(s) responsible for corrective action: Debi Reynolds Planned completion date for corrective action plan: June 30, 2024

Finding 2022-002 Management plans to hire a new staff member who will be dedicated to ensure all activities related to subrecipient monitoring are in compliance with federal and program regulations. Responsible Official: Associate Vice Chancellor for Finance & Treasurer Implementation Date: May 2023

Views of Responsible Officials and Planned Corrective Actions: The County should review the monitoring plan related to the program to ensure these procedures are done timely and meet the federal requirements for monitoring subrecipients.

Finding 2022-002 Condition: Management did not verify that its subrecipient?s were not suspended or debarred or otherwise excluded from participating in the transactions. Foundation?s Response: The Foundation does not concur. 2 CFR Part 180 provides OMB guidance ?only to Federal agencies? (2CFR ? 180.5). As a pass-through entity, the Foundation falls under Uniform Guidance requirements at 2 CFR 200.332. Verification that subrecipients are not suspended, debarred or otherwise excluded is not a requirement of 200.332. However, the Foundation is committed to diligence in our stewardship of Federal funds, therefore we took the auditor?s comment into consideration, and incorporated an annual review of the Do Not Pay list into our subrecipient pre-award risk assessments.

Finding 2022-002 Management plans to hire a new staff member who will be dedicated to ensure all activities related to subrecipient monitoring are in compliance with federal and program regulations. Responsible Official: Associate Vice Chancellor for Finance & Treasurer Implementation Date: May 2023

Action Plan: We will work with our departments to ensure that controls for grants are documented with written procedures. These procedures will include the title of the positions responsible for each control (preparation, review, reconciliation, etc.) and will require that the performance of the controls be documented in a clear, re-performable manner with the name of the responsible individuals, the specific control(s) they performed over compliance for the grant, and the date(s) the controls were performed. Contact Names Responsible for the plan - Marcia Saulo Anticipated completion date of the plan - September 20, 2024

Action Plan: We will work with our departments to ensure that controls for grants are documented with written procedures. These procedures will include the title of the positions responsible for each control (preparation, review, reconciliation, etc.) and will require that the performance of the controls be documented in a clear, re-performable manner with the name of the responsible individuals, the specific control(s) they performed over compliance for the grant, and the date(s) the controls were performed. Contact Names Responsible for the plan - Marcia Saulo Anticipated completion date of the plan - September 20, 2024

Action Plan: We will work with our departments to ensure that controls for grants are documented with written procedures. These procedures will include the title of the positions responsible for each control (preparation, review, reconciliation, etc.) and will require that the performance of the controls be documented in a clear, re-performable manner with the name of the responsible individuals, the specific control(s) they performed over compliance for the grant, and the date(s) the controls were performed. Contact Names Responsible for the plan - Marcia Saulo Anticipated completion date of the plan - September 20, 2024

Action Plan: We will work with our departments to ensure that controls for grants are documented with written procedures. These procedures will include the title of the positions responsible for each control (preparation, review, reconciliation, etc.) and will require that the performance of the controls be documented in a clear, re-performable manner with the name of the responsible individuals, the specific control(s) they performed over compliance for the grant, and the date(s) the controls were performed. Contact Names Responsible for the plan - Marcia Saulo Anticipated completion date of the plan - September 20, 2024