Corrective Action Plans

Finding Summary - There were no formal agreements between the District and its subrecipients as required in 2 CFR 200.331 and no formal subrecipient monitoring procedures were being performed. Responsible Individual - Terry Baesler, Superintendent Corrective Action Plan - The District will maintain formal agreements with the subrecipient entities that include the Uniform Guidance language and implement formal monitoring procedures were being performed. Anticipated Completion Date - 6/30/2026

2025-002 – Lack of Written Policies and Procedures. Auditor Description of Condition and Effect. Although the Village has processes in place to cover these areas, and drafts of formal written policies covering the above items that address all of the area required by the Uniform Guidance have been developed, these policies have not yet been formally approved and adopted by the Village. As a result of this condition, the Village did not fully comply with the Uniform Guidance applicable to the above noted grants. Auditor Recommendation. We recommend that the Village review and approve the draft policies as soon as practical, but no later than the end of fiscal year 2026. Corrective Action. The Village has prepared a policies and procedures manual for the federal grant programs, which will be approved by the Village Council before the end of fiscal year 2026. Responsible Person. Vicki Burrell, Village Clerk. Anticipated Completion Date: February 2026.

2025-003 – Lack of Written Findings and Questioned Costs. Auditor Description of Condition and Effect. Although the Village has processes in place to cover these areas, and drafts of formal written policies covering the above items that address all of the area required by the Uniform Guidance have been developed, these policies have not yet been formally approved and adopted by the Village. As a result of this condition, the Village did not fully comply with the Uniform Guidance applicable to the above noted grants. Auditor Recommendation. We recommend that the Village review and approve the draft policies as soon as practical, but no later than the end of fiscal year 2026. Corrective Action. The Village has prepared a policies and procedures manual for the federal grant programs, which will be approved by the Village Council before the end of fiscal year 2026. Responsible Person. Ross Wilson, Village Clerk/Treasurer. Anticipated Completion Date: February 2026.

Finding #2024-002 – Lack of Subrecipient Monitoring Description of Finding: The Town passed through approximately $1,650,000 in federal funds to a local electric Co-op for broadband infrastructure installation. The Town did not perform subrecipient monitoring specific to this award by identifying applicable requirements for the award after the disbursement of these funds. Statement of Concurrence of Nonconcurrence: The Town concurs that applicable requirements for the award were not identified for the subrecipient, however the Town did monitor activities of the subrecipient. The Town monitored activities to ensure funds were used for allowable activities. Contact Person: Courtney Delaney, Town Administrator Planned Corrective Action: Establish and implement a formal subrecipient monitoring process for all federal funds passed through to other entities. Seek guidance from the awarding agency if responsibilities are unclear. Anticipated Completion Date: The Town has been in regular communication with the awarding agency and established clarity as to applicable terms and conditions as of this date. The Town is working to establish and implement a formal monitoring process and anticipates completion no later than December 31, 2025.

The County has created a filing system for recipients of SLFRF funds and a calendar set to send reminder notices to get receipts and other information from recipients. The reminders will be set in 3 month increments from the time funds are awarded to recipient. Implementation will begin January 1, 2026 with reminder notices set in calendar.

Views of Responsible Officials and Planned Corrective Actions: As Invisible Children continue to build longstanding partnerships with subrecipients, the organization will ensure proper documentation of risks on a regular basis, particularly at moments of award extension. Updated risk assessments will be filed at time of any new federal award even if continuing with existing partners. As part of the annual audit process, Invisible Children will receive formal attestations from all subrecipients regarding their Uniform Guidance audit requirements. Invisible Children has already begun to receive this documentation from active subrecipients ahead of the FY25 audit process.

COVID-19 Coronavirus State and Local Fiscal Recovery Funds (SLFRF) – Assistance Listing No. 21.027 Recommendation: CLA recommends that the County review its procedures for communicating information to subrecipients and implement the procedures necessary to ensure information is included in the subrecipient award documents at time of funding and that appropriate monitoring is performed for each subrecipient. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: For future awards the County will include compliance requirements to subrecipients in the award documents. For previously issued awards, the County will use appropriate subrecipient monitoring procedures to ensure compliance with the grants awarded throughout the remainder of the contract periods. Name of the contact person responsible for corrective action: Craig McBrain, Deputy Director of Budget and Finance Planned completion date for corrective action plan: December 1, 2025

Management Response/Corrective Action Plan: During the audit period, the City monitored subrecipient performance through the review of required supporting documentation submitted with each individual fund requisition and draw request. This process provided assurance that costs charged to the program were eligible and supported. The City also self identified one instance within this process where a consortium member subrecipient did not complete a Single Audit as required. City staff consulted with HUD on this matter and were advised by HUD staff to continue processing payments while HUD worked directly with the subrecipient to bring them back into compliance.

Isler recommended LCOG implement procedures to:  Formally document the determination of whether entities receiving federal funds are subrecipients or contractors prior to entering into agreements and preparing the SEFA, using the criteria in 2 CFR 200.331.  Develop and implement a risk-based monitoring plan for all identified subrecipients, ensuring that required monitoring activities (including review of reports and Single Audits, where applicable) are performed and documented throughout the period of performance.  Ensure the SEFA accurately reflects subrecipient relationships and amounts passed through.  This monitoring plan has already been implemented.

Finding 2024-003 – Lack of Determination Process for Subrecipients vs Contractors ● Issue: Lack of a formal process to distinguish contractors from subrecipients; risk of misclassification. ● Corrective Actions: 1. Adopt written procedures per 2 CFR §200.332 criteria. 2. Develop checklist for staff to use at award initiation. 3. Record contractors and subrecipients in separate GL accounts. ● Responsible Party: Outsourced Accounting Firm, Operations Manager, Executive Director ● Timeline:. Finalize procedure by September 2025; staff training by October 2026. Initiate determination review for transactions January 2025 - September 2025 and reclass accordingly.

The Fulton County Department of Behavioral Health and Developmental Disabilities (DBHDD) performs continuous monitoring activities with program subrecipients by conducting weekly meetings, reviewing monthly reports, invoices, and conducts quarterly performance reviews. DBHDD will strengthen its subrecipient monitoring internal controls by properly documenting these reviews in order to be incompliance with 2 CFR 200.331, and the County’s Subrecipient Monitoring Policy.

The Department of Senior Services follows the monitoring standards established by the pass-through entity and has implemented process improvements to ensure that all Program Year 2024-2025 compliance processes were met. The current period monitoring plan, risk assessments and monitoring have been completed. The Department will maintain an annual monitoring plan to ensure that all subrecipients are monitored in compliance with 2 CFR 200 requirements.

State of Missouri Single Audit Corrective Action Plan Year Ended June 30, 2024 State Agency: Office of Administration Audit Finding Number: 2024-007, SLFRF Program Subrecipient Monitoring Name of the contact person responsible for corrective action: Stacy Neal Anticipated completion date for corrective action: November 1, 2025 Recommendation A.: Develop policies and procedures to determine whether recipients of SLFRF program funds are subrecipients or contractors. Continue to work with the state agencies to ensure accurate and documented determinations are prepared for all recipients and modify subrecipient records as needed. OA partially agrees with the auditor’s finding. Corrective action planned is as follows: OA did complete a training for all agencies regarding subrecipient monitoring and the agencies responsibilities. OA also distributed a memo instructing agencies where to find information regarding subrecipient monitoring and instructing agencies to develop policies and procedures for their agency. To avoid confusion, OA will pursue Memorandums of Understandings (MOU) with agencies to ensure agencies understand their responsibilities for sub-recipient monitoring including sub-recipient specific risk assessments and monitoring. Finally, OA will implement random reviews of the sub-recipient monitoring compliance. Recommendation B.: The OA did not implement an effective subrecipient monitoring program to monitor the SLFRF subrecipients. As a result, some subrecipient monitoring procedures were not performed as required by the UG. OA agrees with the auditor’s finding. Corrective action planned is as follows: OA will pursue Memorandums of Understandings (MOU) with agencies to ensure agencies understand their responsibilities for sub-recipient monitoring including sub-recipient specific risk assessments and monitoring. Finally, OA will implement random reviews of the sub-recipient monitoring compliance.

The audit highlighted insufficient monitoring of subrecipients. To address this, a subrecipient monitoring policy has already been drafted and is being reviewed by the Executive Director. In addition to this, a subrecipient framework is being developed. This framework will standardize risk assessments, routine monitoring procedures and reporting requirements to ensure compliance with federal guidelines. Staff training on these monitoring practices will be completed prior to implementation.

Corrective Action Plan – Hamilton County Economic Development Corporation (dba Invest Hamilton County) Public Accounting Firm CliftonLarsonAllen LLP Audit Period Year ended December 31, 2024 The finding from the December 31, 2024 consolidated schedule of findings is discussed below. The findings is numbered consistently with the numbers assigned in the schedule. Section III 2024-001: Condition: The Organization did not clearly communicate the required federal award information and applicable requirements to the subrecipients. The Organization did not evaluate the risk of non-compliance of the subrecipients in order to identify the appropriate monitoring procedures. Statistical sampling was not used in making sample selections. Response: The response to this finding in 2023 was provided less than one month prior to the end of the grant activity period, and therefore adaptation to the management period was not feasible for this project. The Organizations’ Board and Chief Executive OMicer (CEO) and key HCEDC StaM recognize the need to further refine subrecipient monitoring. Subrecipients within the identified project are all school districts already under single audit with associated levels of financial controls and reporting. Participating districts, via their appropriate elected boards, were informed the conditions of the grant and individually voted to accept obligations and requirements. HCEDC management, in alignment with outsourced controller services via CliftonLarsonAllen LLP, have now further increased controls and monitoring activity. Through the onboarding of a new Grants Management System (GMS) in Fall 2024, subrecipient monitoring activity and profiles are now created for each eligible award. In 2024 and 2025, the HCEDC has also been much more active in communicating reporting and grants management requirements to subrecipients, including multiple amendments to the ESSER grant program. The new GMS system is built specifically to assist organizations with single audit compliance and has multiple features specific to subrecipient reporting and monitoring. If there are any questions regarding this plan, please contact the undersigned at 317-663-4457. Mike Thibideau PRESIDENT & CEO – INVEST HAMILTON COUNTY 37 East Main Street Carmel, IN 46032

2024-003 – Subrecipient Monitoring Auditor Description of Condition and Effect. We noted that the County did not compile any risk assessments or perform adequate subrecipient monitoring during the fiscal year. The lack of monitoring failed to provide reasonable assurance that the subrecipients complied with the provisions of the grant. Auditor Recommendation. We recommend that the County create a subrecipient policy to ensure that all subrecipient grant awards are monitored in compliance with the Uniform Guidance requirements. Corrective Action. The County will create a subrecipient monitoring policy to ensure that all subrecipient grant awards are monitored in compliance with the Uniform Guidance. Responsible Person. Eric Smith, Director of Finance & Budget Anticipated Completion Date. December 31, 2025

August 15, 2025 United States Department of Agriculture National Institute of Food and Agriculture Awards Management Division 805 Pennsylvania Ave Kansas City, MO 64105 Attention: Federal Audit Clearinghouse (FAC) Subject: Corrective Action Plan Submission – Finding #4 – Sovereign Equity Fund – Fiscal Year End 12/31/2024 To Whom It May Concern: Subrecipient Monitoring - Subrecipient agreements lacked required federal clauses and were not monitored according to risk assessments. Corrective Actions: • Develop a subrecipient monitoring policy aligned with 2 CFR §200.331-333. • Standardize agreement templates to include all required clauses for federal award subrecipient agreements (e.g., audit requirements, FFATA, termination provisions). • Implement a subrecipient risk assessment tool to determine monitoring frequency and risk level identification. • Assign staff for annual subrecipient desk reviews or site visits based on risk levels. Responsible Party: Executive Director / Legal & Compliance Team Target Completion Date: Risk assessment and financial monitoring tool in use and agreement templates updated within 45 days. Sincerely, Courtney Chavis Executive Director

Management agrees with the finding. The Center is currently in the process of updating its fiscal policies and procedures to align with the requirements of 2 CFR Part 200. The Finance Committee is leading this effort and is reviewing each policy area identified, including conflict of interest, allowable costs, subrecipient monitoring, and record retention. Updated policies and procedures will be finalized and presented for Board approval by August 30, 2025. Once approved, the Center will ensure implementation across all departments and provide internal guidance to promote consistent application. Anticipated Completion Date: August 30, 2025 Responsible Party: Finance Committee, with support from Executive Director, Nichole Henry.

Person responsible for corrective action: Nicole Meland, Vice President of Finance and Operations Responsible official’s response: Management is in agreement with this finding. Corrective action planned: The Chamber Foundation has subsequently requested all audit reports from all subrecipients. Additionally, the Chamber Foundation has changed subaward formatting to ensure that all required information is included within the award. Planned implementation date of corrective action: Ongoing

Recommendation: We recommend that the Parish establish and implement formal policies and procedures for subrecipient monitoring in accordance with 2 CFR § 200.331. This should include conducting and documenting pre-award risk assessments, developing a subrecipient monitoring plan (e.g., site visits, desk reviews), reviewing subrecipient performance and audit reports on a regular basis. Corrective Action: The Parish has established a subrecipient checklist to assess risk and compliance. The checklist will be completed as an additional measure to ensure the standards outlined in the “Grant Administration Policies & Procedure” are met.

THE ORGANIZATION WILL USE EXPENDITURE REPORTS BY CLASS TO SUPPORT BASE EXPENDITURES FOR THE PERIOD. WILL BE IN PLACE FOR THE 2025 SINGLE AUDIT AND BEGAN THIS PROCESS IN 2024. KAREN SHARPNACK, EXECUTIVE DIRECTOR KJS@IDAHOIMMUNE.ORG AND NEW CPA FIRM TO BE DETERMINED. THE ORGANIZATION THROUGH ITS BOARD OF DIRECTORS WILL CREATE A “FINANCIAL POLICY COMMITTEE” WHICH WILL BE RESPONSIBLE TO WORK WITH THE EXECUTIVE DIRECTOR, THE NEW CPA TO OUTLINE AND CREATE NEW POLICIES, PROCEDURES AND PROCESSES, ALONG WITH OVERSIGHT OF THE FINANCIAL WELL-BEING OF THE ORGANIZATION AND REPORT TO THE BOARD OF DIRECTORS. IMMEDIATELY, THE PROCESS WILL BEGIN TO RECRUIT THE COMMITTEE ON JUNE 25, 2025.

DMPSJ: While the Office of the Deputy Mayor for Public Safety and Justice (DMPSJ) doesn’t agree that it is out of compliance, DMPSJ will ensure documentation is maintained regarding its oversight of grant management. Nicole Peckumn, Chief of Staff, DMPSJ August 30, 2025 DMPSJ will ensure compliance with standard operation procedures to ensure monthly and performance reports are submitted, as well as ensure follow-up related to corrective action plans is documented. While DMPSJ doesn’t agree with the finding regarding the debarment check, DMPSJ will implement a practice of capturing a screenshot and maintaining a copy of the screenshot in the file for a grantee(s) receiving federal funding. ONSE: The Office of Neighborhood Safety and Engagement (ONSE) acknowledges and accepts the finding that the subrecipient failed to submit their monthly and performance reports. ONSE has created a monitoring team and plan to ensure that all subrecipients are in compliance with submissions of their financial and performance reports. Contact: Yasha Williams Robinson, Chief Operating Officer, ONSE Estimated Completion Date: September 30, 2025 See Corrective Action Plan for chart/table

Finding #2024-002 – Significant Deficiency and Other Noncompliance. Applicable federal program: U. S. Environmental Protection Agency, Assistance Listing #66.456, National Estuary program, Passed through Texas Commission on Environmental Quality: Contract period: 09/01/23 – 08/31/25, Contract number: 582-24-50165. Condition and context: We reviewed one of the two subrecipient awards for the required information described in the criteria above and noted such provisions were not included in the subrecipient agreement. Recommendation: Policies and procedures should be implemented to ensure all required information is included in the subrecipient agreement before issuance. Planned corrective action: Management agrees with the finding and would like to provide additional context to this situation. This agreement occurred during the early implementation phase of a multi-year grant in 2023, when the Foundation was still establishing internal processes for managing subawards under federal funding requirements. At the time of this transaction: The federal award had not yet been formally executed, though the federal agency provided authorization to begin incurring expenses. The subrecipient, a partner organization, drafted and issued the agreement using their standard contract template. Since that time, the Foundation has updated its procedures for subsequent subrecipient agreements to include the required Uniform Guidance information as outlined in 2 CFR §200.331(a). This was an isolated incident during a transitional period, and management is confident that current processes address this issue. To prevent recurrence, the Foundation will: Continue to follow updated subrecipient agreement templates, which include all required award and federal compliance language. Provide refresher training to staff involved in grant and contract administration on subrecipient vs. vendor classifications and associated federal requirements. Perform an annual compliance review of all subrecipient agreements to ensure ongoing adherence. Responsible officer: Dawn Asbury, Controller. Estimated completion date: July 31, 2025.

Finding 2024-003: SEFA Preparation – Subrecipient vs. Subcontractor Determinations Name of Responsible Official: Nikolos Oakley, CFAO Anticipated Completion Date: 09/30/2025 Condition: Subcontractor amounts were improperly included in the Amounts Provided to Subrecipients column on the Schedule of Expenditures of Federal Awards (SEFA). Context: Management made improper subrecipient vs. subcontractor determinations, resulting in inaccurate SEFA preparation. This resulted in $2.6 million being removed from the Amounts Provided to Subrecipients column in the original SEFA provided to the auditors by management. Views of Responsible Officials and Planned Corrective Action: IntraHealth acknowledges the finding regarding the improper inclusion of subcontractor amounts in the Amounts Provided to Subrecipients column on the Schedule of Expenditures of Federal Awards (SEFA). We will improve our reporting and review processes to ensure subcontractor amounts are not incorporated under Amounts Provided to Subrecipients column in SEFA. Corrective Action: • Implement a more rigorous review process to ensure that only true subrecipients are included in the Amounts Provided to Subrecipients column of the SEFA. Subcontractor amounts will be reported separately as required. We will also improve training for the finance and grants management teams to ensure they fully understand the regulations. IntraHealth is committed to ensuring the accuracy of future SEFA reports and will complete the corrective actions by 09/30/2025. We will also continue to monitor the effectiveness of these changes to prevent future misclassifications.

2024-006 Subrecipient Monitoring Compliance - CSBG Person responsible for corrective action - Andrea Olson, executive Director Responsible official's response - Management is in agreement with this finding. Responsible official's response - Management is in agreement with this finding. Corrective action planned - CAPND has changed subaward formatting to ensure that all required information is included within the award. Planned implementation date of corrective action - July 1, 2024