Corrective Action Plans

Finding 2025-010 U.S. Department of Housing and Urban Development (HUD) AL No. 14.241 Housing Opportunity for Persons with AIDS Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2024-014 Auditee’s Corrective Action Plan: MOHS will enhance and formalize subrecipient monitoring procedures to ensure full compliance with Uniform Guidance requirements. Subrecipient agreement templates will be revised to require inclusion of the subrecipient’s Unique Entity Identifier (UEI) and Federal Award Identification Number (FAIN) for all subawards, in accordance with 2 CFR §§25.300 and 200.332. MOHS has previously developed subrecipient risk assessment and monitoring tools for the Continuum of Care (CoC) program. These tools and procedures will be reviewed, updated as needed, and expanded to apply to all MOHS grants, including HOPWA. This includes documented risk assessments, monitoring plans, and verification that required Single Audit reports are obtained, reviewed, and retained when applicable. MOHS will maintain centralized subrecipient monitoring files containing executed agreements, audit reviews, monitoring documentation, and follow-up actions. Program and fiscal staff will receive training on updated subrecipient monitoring policies and documentation standards to ensure consistent implementation across all funding sources. MOHS will utilize the GMO’s subrecipient monitoring templates provided on their centralized SharePoint platform which include risk assessments, reporting forms, expenditure forms, and metrics forms to ensure all required subrecipient monitoring reporting is completed. Additionally, MOHS will require all grant staff to attend GMO monthly trainings and quarterly grant monitoring meetings to ensure subrecipient monitoring is being conducted and completed. MOHS will also require all grant staff to familiarize themselves with Administrative Manual policy 413-51 Subrecipient Monitoring and Management, which specifies all city-wide requirements for subrecipient monitoring. MOHS will maintain copies of all subrecipient monitoring documents in Workday, the City’s financial system. Contact Person: Sade Creighton-Wade, Chief of Fiscal Services Completion Date: September 30, 2026

Corrective Action Plan June 30, 2025 Finding: 2025-001 Name of Responsible Official: Angela Bass Anticipation Completion Date: December 31 , 2025 Mississippi First's Response: 1. Audit Finding Corrective Action Plan The auditor noted that Mississippi First did not submit a FFATA report for a subaward of $30,000 or more in a timely and accurate manner. 2. Root Cause The delay in submitting the FFATA report was due to a personnel transition during the reporting period. The outgoing Executive Director had been executing FFATA filings, and the incoming Executive Director and was not yet aware of this reporting requirement. Because the requirement was not captured in any written procedures or transition documents, the report was inadvertently missed. This was an isolated incident resulting from the timing of the leadership transition and a gap in knowledge transfer. 3. Corrective Action Taken / Planned A. Formal Policy Development - Mississippi First has drafted a comprehensive FFATA Compliance and Subaward Reporting Policy. B. Assignment of Responsibility - The Director of Operations is designated as the FFATA Reporting Officer. C. FFATA Reporting Checklist - A standardized checklist ensures accuracy for each submission. D. FSRS Standard Operating Procedure (SOP) - A detailed, step-by-step SOP has been developed. E. Deadline Tracking & Automated Reminders - FFATA deadlines will be integrated into the grants management calendar. F. Quarterly Internal Reviews - Quarterly internal audits will verify completeness, accuracy, and timeliness. G. Job Description Updates - Relevant staff job descriptions now include FFATA responsibilities. 4. Timeline for Implementation • Finalize and adopt FFATA Policy- by December 31, 2025 • Assign FFATA Reporting Officer role - Completed • Launch FFATA checklist and SOP - by December 31, 2025 • Implement automated reminders - by December 31, 2025 • Conduct first quarterly compliance review - by December 31, 2025 5. Preventive Measures Mississippi First will require FFATA training, include FFATA in onboarding, review the policy annually, and integrate FFATA compliance into grants management protocols.

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.

Planned Corrective Action: Illuminate Colorado has developed a new process for properly identifying subrecipients and ensuring all required federal award identification information is included in each subaward prior to issuance. This process includes the use of an updated subaward checklist and management review prior to execution of subaward agreements. This process will be documented through a Standard Operating Procedure to ensure consistent implementation of the expectations. Standard Operating Procedure will include: ● Identification of federal funds as a required step in the preparation of all vendor contracts ● Completion of an internal Subaward Checklist for contracts that include the use of federal funds prior to execution ● Use of a standardized subaward contract template including required Federal award identification information ● Enhanced and documented Executive Leadership review and approval of contracts before execution Name of Contact Person: Jillian Fabricius, Co-Executive Director (jfabricius@illuminatecolorado.org) Anne Auld, Co-Executive Director (aauld@illuminatecolorado.org) Linda Robinson, Director of Finance (lrobinson@illuminatecolorado.org) Cindy Rojas, Contracts & Compliance Manager (crojas@illuminatecolorado.org) Anticipated completion date: January 30, 2026

Prior to July 1, 2024, Jefferson County Community Action Commission (CAC) served as a subrecipient for WIOA programs (specifically as related to this finding for the Comprehensive Case Management and Employment program (CCMEP) funded by TANF) for which funding was received by the Harrison County Department of Job and Family Services (agency). As noted in the Audit Finding for 2023 (2023-002) Harrison County Department of Job and Family Services had not properly monitored the subrecipient. However, as of July 1, 2024, the CAC is no longer a subrecipient and serves as a contractor for the work experience youth element as part of the CCMEP program. Harrison County Department of Job and Family Services staff complete all eligibility for that program and referrals are made to the CAC only for youth for whom the work experience element is needed. The subrecipient monitoring issue was corrected in 2024 due to the agency reassuming responsibility for the programs and only contracting out specific youth elements in the CCMEP program.

Response to finding 2024-003 – Subrecipient Monitoring Views of Responsible Officials: CSforALL management agrees with the conditions identified by SAX Advisory Group, including the noted causes and resulting effects under 2024-003. Due to the organizational pause at the end of 2024 and the transition period throughout 2025, the Organization had limited capacity to maintain formalized subrecipient monitoring procedures aligned with 2 CFR 200.332. As CSforALL prepares for the 2026 rebuilding phase, management is establishing structured policies and procedures to ensure full compliance with federal subrecipient monitoring requirements. Corrective Action taken in 2025: During 2025, the Operations Manager ensured that all subrecipients associated with the current Alliance grant have signed or will sign formal Statements of Work with explicit deliverables and expectations required for payment. External parties without a Statement of Work are now required to submit proper documentation, invoicing, and proof of deliverables before any funds are released. No payments have been made to participants under the FY 2025 Alliance grant to date, as CSforALL is ensuring that all required policies and procedures are in place prior to both drawing down and paying out funds. Weekly and quarterly meetings have been established with external partners responsible for deliverables to confirm timelines, verify progress, and ensure alignment with payment expectations. Corrective Action Planned for 2026: Beginning in 2026, CSforALL will formalize subrecipient monitoring policies aligned with 2 CFR 200.332, including risk assessments for all subrecipients, review and documentation of Single Audit reports where applicable, issuance of management decisions, and structured ongoing monitoring activities. All monitoring documentation will be maintained in a centralized, accessible system to ensure consistent compliance throughout the 2026 operating year and beyond.

Assistance Listing 93.323 Epidemiology and Laboratory Capacity for Infectious Diseases Program Views of the Responsible Officials and Corrective Action Plan: The Philadelphia Department of Public Health (PDPH) acknowledges the Office of the City Controller’s finding. PDPH maintains a process to identify subrecipients during the contracting process. Contracts with subrecipients include federal compliance language. The three entities identified in this finding, including Concilio, Urban Affairs Coalition (UAC), and Public Health Management Corporation (PHMC), should have been classified as vendors and not subrecipients. These entities were not responsible for programmatic decision-making. This error has been corrected in subsequent contracts. Despite the misclassification, appropriate vendor monitoring was conducted, including supervision of staff hiring and monitoring and reconciliation of monthly invoice packages. Contact Person: Jessica Caum, Director, Department of Public Health, 215-685-6731 Naomi Mirowitz, Performance and Compliance Officer, Department of Public Health, 215-964-5050

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