Corrective Action Plans

Finding 2025-002 — Subrecipient Monitoring and Required Documentation Corrective Action Plan During fiscal year 2025, the Organization did not consistently obtain or retain: (i) written pre-award risk assessments for subrecipients; (ii) Single Audit reports for subrecipients expending $750,000 or more in federal awards; or (iii) Unique Entity Identifier (UEI) confirmations via SAM.gov, as required under 2 CFR §§200.331–200.333. The affected pass-through activity totaled approximately $542,500 across three major federal programs (CFDA 93.310, 93.137, and 93.185). Management will implement the following corrective actions: • Establish a centralized subrecipient monitoring file for each subaward relationship, organized by program and award year, and confirm each subrecipient’s active UEI registration in SAM.gov at the time of award and annually thereafter. • Conduct and document a formal pre-award risk assessment using the Subrecipient Risk Assessment Questionnaire, covering prior federal experience, financial stability, internal controls, audit history, and SAM.gov registration. Perform and document a written subrecipient-vs.-contractor determination consistent with 2 CFR §200.331 before entering into or renewing any agreement. • Ensure all subaward agreements include the required award information, compliance responsibilities, reporting requirements, record retention provisions, and audit access provisions under 2 CFR §200.332. • Use the Subrecipient Desk Review Checklist to document quarterly monitoring, including review of progress reports, invoices, deliverables, indirect cost calculations, and personnel timesheets. Require supporting documentation before approving payments. • Maintain an annual Single Audit tracking log to verify federal expenditure thresholds and document collection, review, and resolution of any subrecipient audit findings. • Train program managers and accounting personnel on Uniform Guidance subrecipient monitoring requirements and present updated procedures to the Board/Finance Committee for formal adoption. Responsible Party Executive Director; Accounting Manager; Program Managers; Treasurer/Finance Committee. Completion Date Management has already begun implementation. Full implementation of the monitoring checklist and centralized files expected by September 30, 2026. Review of open FY2025/FY2026 subrecipient files and documentation requests by September 30,2026.

Finding Number: 2025-001 Condition: Management concurs with the finding and has implemented a new grant governance committee and process for identifying grant components before entering into grant agreements. Management also created a new grant department with staff devoted to researching, applying for, monitoring, and reporting on all grants. The accounting function for grants will be done by this team as well but with continued oversight by the Executive Director, Accounting. Contact person responsible for corrective action: Stephanie Sessoms, Chief Financial Officer; Lynn Bailey, Executive Director, Accounting Anticipated Completion Date: 1/12/2026

Views of Responsible Officials: The Foundation will retroactively perform a risk assessment of all subrecipients for FY26. Going forward, a pre-award risk assessment will be performed prior to awarding a subrecipient and appropriate monitoring procedures over sub-recipients will be implemented.

2025-004: Subrecipient Monitoring - Contractor vs. Subrecipient Determination (Significant Deficiency in Internal Control) Statement of Condition/Criteria: 2 CFR §200.331 requires pass-through entities to evaluate each subaward to determine whether the recipient is a subrecipient or a contractor. This evaluation should be based on the characteristics outlined in 2 CFR §200.331(a) and (b) and documented to support proper classification. Effective internal control over federal awards also requires documentation of compliance-related judgments to ensure consistent application and oversight. During our testing of internal controls over compliance, we noted that the Organization does not maintain formal documentation supporting its evaluation of whether award recipients are classified as contractors or subrecipients in accordance with Uniform Guidance. Planned Corrective Action: The Council will work to implement requirements at the program level to evaluate and document all contracts to properly identify between contract and subaward. Contact person responsible for corrective action plan: Clayton Kincheloe, Executive Director Anticipated Completion Date: September 2026

Finding #2025-001: #84.048 -Career and Technical Education - Basic Grants to States Federal Grantor Agency: U.S. Department of Education Compliance Requirement: Subrecipient Monitoring Condition: During our audit procedures, we noted that the District does not have formal, written procedures governing subrecipient monitoring. Although the District reviews supporting documentation—such as invoices—submitted by subrecipient schools prior to submitting claims to the Department of Public Instruction (DPI), these practices are not documented in an established policy or procedure. Criteria: Uniform Guidance (2 CFR 200.331–200.332) requires pass-through entities to establish and implement written procedures for monitoring subrecipients to ensure compliance with federal program requirements and achievement of performance goals. Cause: The District has not developed or implemented formal written policies and procedures for subrecipient monitoring. Effect: In the absence of formalized procedures, the District’s monitoring practices may be applied inconsistently, increasing the risk of unallowable costs, noncompliance with federal requirements, or misunderstandings between the District and its subrecipients. This could lead to questioned costs or administrative issues during oversight by DPI or other regulatory bodies. Recommendation: We recommend that the District develop and adopt formal written procedures outlining its subrecipient monitoring activities. These procedures should clearly describe monitoring responsibilities, required documentation, review steps, communication expectations, and follow-up actions. Implementing a formalized process will help ensure consistent oversight and compliance with federal regulations. Grantee Response: The District will develop and implement written procedures that outline the required monitoring steps, documentation standards, communication protocols, and follow-up expectations for subrecipient oversight. These procedures will align with the requirements of Uniform Guidance and DPI expectations.

Program: Congressionally Recommended Awards / HOME Investment Partnerships Program / Homeland Security Grant Program / Epidemiology and Laboratory Capacity for Infectious Disease Federal Financial Assistance Listing Number: 16.753 / 14.239 / 97.067 / 93.323 Federal Grantor: U.S. Department of Justice / U.S. Department of Housing and Urban Development / U.S. Department of Homeland Security / U.S. Department of Health and Human Services Award No. and Year: Multiple Compliance Requirements: Other – Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) - Schedule of expenditures of Federal awards Type of Finding: Material Weakness in Internal Control Over Compliance Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) states that the auditee (the County) must prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the auditee’s financial statements, which must include the total federal awards expended as determined in accordance with §200.502. §200.331 of the Uniform Guidance states the County is responsible for making case-by-case determinations to determine whether the entity receiving the Federal funds is a subrecipient. In addition, §200.303 of the Uniform Guidance states that the County must establish and maintain effective internal control over the federal awards, including controls over the accuracy of program information and expenditure amounts. Condition: During our audit procedures performed over the SEFA we noted the following: • The Sheriff-Coroner Department did not properly identify the amount expended for the Congressionally Recommended Awards, AL No. 16.753. The expenditures reported by the Department were overstated by $2,638,516. • The Orange County Community Resources Department did not properly identify the amount of Federal funding passed through to subrecipients for the HOME Investment Partnerships Program, AL No. 14.239. The amount passed through to subrecipients reported by the Department was overstated by $4,500,624. • The Sheriff-Coroner Department did not properly identify the amounts expended for the Homeland Security Grant Program, AL No. 97.067. The expenditures reported by the Department were overstated by $715,489. • The Orange County Health Care Agency (HCA) did not properly identify the amount expended for the Epidemiology and Laboratory Capacity for Infectious Disease program, AL No. 93.323. The expenditures reported by the Agency were overstated by $486,000. Cause: As a result, the County lacked adequate internal controls to ensure the SEFA is completely and accurately stated. Specifically, the County’s processes for recording and tracking expenditures of Federal awards are not designed so that expenditures are identified when incurred. In addition, the County’s processes for identifying and reporting subrecipients are not designed to ensure appropriate reporting on the SEFA. Effect: Adjustments to the SEFA were required. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: No sampling was used. Program expenditures and amounts passed through to subrecipients were reconciled to the supporting records. Repeat Finding from Prior Years: No. Recommendation: The County, including all its reporting departments, should follow existing policies, procedures and internal controls to ensure all expenditures and amounts passed through to subrecipients are accurately tracked and reported on the SEFA. Personnel knowledgeable of federal expenditures should review amounts coded to federal programs for completeness and accuracy. The SEFA should be prepared and reviewed in a timely manner and reconciled to underlying records as well as the basic financial statements. Management Response and Corrective Action Plan: Health Care Agency: 1. Person Responsible: David Santalahti, HCA Claims & Financial Reporting Manager 2. Corrective action plan: HCA Accounting will review and enhance its procedures and training for analysis and tracking federal award expenditures to ensure expenditures are reported in the appropriate fiscal year period. 3. Anticipated Implementation date: June 30, 2026 Orange County Community Resources: 1. Person Responsible: Bill Malohn, OCCR Accounting Manager 2. Corrective action plan: Concur. OCCR has established policies and internal controls to ensure all expenditures and amounts passed through to subrecipients are accurately tracked and reported on the SEFA. Appropriate personnel review amounts coded to federal programs for completeness and accuracy. We prepare and review the SEFA in a timely manner and reconcile to underlying records as well as the basic financial statements. In this particular situation, we miscategorized one provider as a subrecipient and reported the related funding as such on the SEFA. This oversight had no impact on the total amount we reported on the SEFA. We will be sure to follow our policies and procedures to ensure accurate SEFA reporting. 3. Anticipated Implementation date: February 2, 2026 Sheriff-Coroner: 1. Person Responsible: Monique Vansuch, Fiscal Administrator 2. Corrective action plan: The Sheriff-Coroner Department acknowledges the finding and recognized federal grant expenditure incurred is defined as when expenditures are delivered and/or services are performed rather than when the expenditures are paid. We will strengthen the internal controls to ensure grant expenditures are reported per the Uniform Guidance. 3. Anticipated Implementation date: June 30, 2026

Finding 2025-006 Subrecipient Monitoring Federal Agency Name: Department of Health and Human Services Pass-Through En􀆟ty: Iowa Department of Health and Human Services Assistance Lis􀆟ng Number: 93.069 Program Name: Public Health Emergency Preparedness Finding Summary: The County did not formally communicate the required informa􀆟on to the subrecipient. No subrecipient agreement was executed. In addi􀆟on, no monitoring ac􀆟vi􀆟es were documented. Responsible Individuals: Amber Shepard, Budget Director Correc􀆟ve Ac􀆟on Plan: Clinton County is working with Genesis Health System on implemen􀆟ng a subrecipient agreement and will put a control process in place to monitor An􀆟cipated Comple􀆟on Date: June 30, 2026

Department will strengthen controls to ensure that the required award information is provided, once available. Certain information such as Federal Award Identification Number and Federal Transit Administration and National Highway Traffic Safety Administration award date are not available at the time of contracting CDOT is working on a process to provide this information, once it is available in a publicly available format on CDOT’s website or on a subrecipient facing grant management site. We will add a note to the contract explaining where the information will be posted on our site when it becomes available. The Department will also identify staff requiring additional training on classification and coding for contractors vs. subrecipients.

Views of Responsible Officials Management concurs with the finding. The Operation Stonegarden grants are managed by Broken Arrow Services, LLC, who is contracted with Otero County for this purpose. Broken Arrow Services, LLC has communicated to all sub-recipients the importance of submitting reports and invoices in a timely manner so that financial and performance reports can be completed and submitted to DHSEM by the required deadlines each quarter. All late submissions by sub-recipients will be tracked and follow-up efforts will be documented. Reimbursement to sub-recipients who are not in compliance will be withheld until all proper documentation and reporting has been submitted and reviewed for accuracy. Finding Resolutions Timeline: June 30, 2026 Designation Of Employee Position Responsible For Meeting This Deadline: Finance Director

RE: Finding 2025-003 Misreporting of Pass-Through Grant Expenditures in Compliance Report In conjunction with our FY25 annual audit, please see the City's corrective action plan below: The City of Sand Springs will strengthen internal controls over federal grant reporting to ensure proper distinction between direct federal awards and federal pass-through grants, in accordance with Uniform Guidance and SLFRF requirements. Specifically, the City will implement the following corrective actions: Separate Tracking of Direct vs. Pass-Through Funds o The Finance Department will revise grant accounting procedures to clearly segregate expenditures related to: Direct SLFRF (ARPA) awards administered by the City, and Federal pass-through grants administered by external entities, including OWRB. o Separate project codes and/or accounting identifiers will be maintained to prevent commingling of expenditures. Revision of SLFRF Reporting Procedures o Written procedures for preparation and review of the SLFRF Compliance Report will be updated to explicitly state that: Only expenditures related to direct federal awards are to be reported by the City, and Expenditures related to pass-through grants are excluded and reported by the pass-through entity. o A documented review step will be added to verify that reported expenditures align with the funding source prior to submission. Staff Training and Awareness o Finance staff involved in grant accounting and reporting will receive targeted training on: Uniform Guidance requirements (2 CFR 200), The distinction between direct federal awards and pass-through grants, and Proper SEFA and SLFRF reporting responsibilities. o Training will be documented and incorporated into onboarding materials for future staff. Coordination with Pass-Through Entity (OWRB) o The City will coordinate with OWRB to confirm: The sequence of fund utilization (pass-through vs. direct ARPA funds), and Roles and responsibilities for federal expenditure reporting. Expected completion date: Procedures will be implemented for the fiscal year ending June 30, 2026, and applied during interim processing and year-end close. Party Responsible: Finance Director and Finance Staff, in coordination with applicable Department Heads and Project Managers. Contact Information: Arlena Barnes 918-246-2646 arlena.barnes@sandspringsok.gov

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.

View of Responsible Officials and Corrective Action Plan The AAIHB acknowledges that its subrecipient related practices could be improved upon. The AAIHB will review and revise its internal processes and procedures and implement the auditor’s recommendations to ensure compliance with subrecipient requirements. Corrective Action Plan Timeline Prior to the audit finding, the AAIHB already had one meeting with key personnel involved in the administration and oversight of subawards to begin implementing improvements to our subrecipient monitoring practices. The AAIHB is actively working to update subrecipient monitoring practices and anticipates having policies and procedures in place by the beginning of the next fiscal year. In addition, the GHWIC program has found our internal administrative assistance portal that was developed to optimize admin workflow has been helpful because it has also optimized the processing of subaward invoices. Furthermore, the GHWIC program is in the process of developing a sub awardees data portal for invoicing and reporting purposes to streamline the subaward process and ensure payment in a timely manner. Designation of Employee Position Responsible for Meeting Deadline Executive Director, Finance, Program Managers/Directors/Coordinators, Grants & Contracts Specialist

2024-003 Program: WIOA Cluster Federal Financial Assistance Listing Number: 17.258, 17.259, 17.277, 17.278 Federal Grantor: U.S. Department of Labor Pass-Through: California Department of Employment Development Award No. and Year: AA011008 and 2019 Compliance Requirements: Subrecipient Monitoring Type of Finding: Material Weakness Management’s or Department’s Response: Imperial County Workforce Development Office (ICWDO) agrees with the finding. Views of Responsible Officials and Corrective Action Plan: The questions from finding 2021-008 relate to a formalization of the fiscal processes and protocols. ICWDO operates under WIOA guidelines and follows Imperial County’s fiscal policies. Internal policy will be formally updated to reflect compliance with WIOA regulations, as well as Imperial County policies. These policies will include formal controls and procedures to evaluate each subrecipient’s risk of noncompliance. Once the formal procedure is drafted, it will go through the ICWDO Policy Committee for comment and direction, and then finally reviewed and approved for implementation by the full Workforce Development Board. Additionally, for any future Memorandums of Understanding (MOUs) between this Imperial County department and any outside agency, there will be an additional step to include review by Imperial County Counsel to reflect that recital around the funding source will specify the following required information: • Federal Award Identification Number • Federal award date of award to recipient by the Federal agency • Name of Federal awarding agency • CFDA Number • Specific identification of whether the award is research and development ICWDO will develop internal policies for formalizing all subrecipient monitoring process. ICWDO operates under WIOA guidelines for monitoring; therefore a formal internal policy for future contracts will be developed and implemented using the usual review and approval procedures followed by the department. ICWDO will develop a formal internal documentation system, with appropriate checks and signatures, for the evaluation and assessment of each subrecipient’s risk of noncompliance. ICWDO will utilize this formal process to properly document the risk assessment of all subrecipients. ICWDO anticipates to implement the corrective action by December 31, 2025. Name of Responsible Person: Priscilla A Lopez, ICWDB Director Implementation Date: December 31, 2025

VIEWS OF RESPONSIBLE OFFICIALS ADSEF is committed to establishing a robust internal control framework specifically dedicated to FFATA compliance. We are developing comprehensive protocols that define clear roles, responsibilities, and standardized procedures to ensure all applicable subawards are identified, monitored, and reported to the FSRS in strict accordance with 2 CFR Part 170. Action Steps: 1. Protocol Development - Create a new "FFATA Compliance Protocol" that details the specific steps for subrecipient determination, data collection, and FSRS submission, while revising existing procurement SOPs to integrate these checks. 2. Roles & Responsibilities – Formalize the assignment of duties: (a) The Grants Management Officer will classify the entity as a subrecipient or contractor; (b) the Compliance Coordinator will extract the required data; and (c) the Finance Director will perform a final review before FSRS submission. 3. Subrecipient Determination Checklist – Implement a mandatory "Subrecipient Determination Checklist" based on 2 CFR §200.331 criteria, required for every new agreement exceeding $30,000. 4. Specialized Staff Training – Conduct mandatory training for procurement and grant personnel on FFATA regulations, the specific criteria for subrecipient classification, and the internal steps required for FSRS reporting IMPLEMENTATION DATE During Fiscal Year 2026-2027 RESPONSIBLE PERSON Eddie J. Burgos – Auxiliary Administrator for Finance and Budget Carlos Martinez Colón – Finance Director Vanessa Ayala Gerena – Director of Budget Gerhil Medina Baez – Auxiliary Administrator Operational Services Johana Hernandez Andaluz – TANF Program Director

Views of Responsible Officials and Planned Corrective Action While the Organization concurred with the prior year (2023-002) and current year renumbered recommendation (2024-002), the Organization notes the corrective actions that have been implemented, specifically, related to the subrecipient monitoring and management provision of 2 CFR§ 200.331 and 2 CFR §200.332 of the Uniform Guidance, that emphasizes accountability and compliance in managing federal funds and subrecipients, and that have been in practice, from the effective date(s) noted below, to the present period of the report dated June 17, 2026: A. Subrecipient Monitoring and Management. Implemented internal process changes, effective November 1, 2024, specifically, prospectively, and consistently the: 1. Use of a checklist, to comprehensively assess risk of determining subrecipient or contractor classification, before entering into any subrecipient agreement; 2. Provision of identification details such as CFDA number, amount of federal funds obligated, and the award period for determined subrecipient awards; 3. Submission of programmatic and financial reports as specified in the subrecipient agreement; 4. Review of a single audit in accordance with 2 CFR Part 200, Subpart F for subrecipients that expend $750,000 or more in federal funds during a fiscal year, if applicable; and 5. Review of their audit report(s) and addressing any finding(s) related to their federal award(s), including the related appropriate corrective actions, when applicable. B. Retroactive Subrecipient Portfolio Risk Assessment and Correction(s). The Organization performed a risk assessment of the existing subrecipient portfolio to identify risks, for the audit periods July 1, 2022 – June 30, 2023, and July 1, 2023 – June 30, 2024. The objective of this risk assessment was to identify, evaluate, and prioritize risks that could adversely impact the Organization’s ability to achieve its strategic, operational, compliance and quality assurance goals. The completion of the Organization’s portfolio risk assessment resulted in correction of identified non-compliant subrecipient agreement(s). C. Subrecipient Policies and Procedures. By December 31, 2024, the Organization updated and implemented financial policies and procedures aligned to the subrecipient monitoring and management provision of 2 CFR §200.331 and 2 CFR §200.332 of the Uniform Guidance, including checklists, flowcharts, samples, data sheets, data sharing agreements, etc.; and the current practices of the Organization to the present period of the report dated June 17, 2026, is consistent with such developed subrecipient policies and procedures.

Finding 2024-008 - Uniform Guidance Subrecipient Monitoring - Significant Deficiency/Noncompliance Condition/Context: As part of our follow-up on previous audit findings and based on our current year testing, it was noted that the County is not formally documenting its monitoring activities over its subrecipients in compliance with the Uniform Guidance. Corrective Action: The Office of Financial Management will implement a process to document all subrecipient activities in compliance with the Uniform Guidance. Responsible for Implementing Corrective Action: Office of Financial Management Anticipated Completion Date: We anticipate this to be completed in coordination with the 2026 audit.

Undocumented Subrecipient Monitoring Recommendation: We recommend that the Alliance establishes a formal policy for subrecipient monitoring in accordance with requirements outlined in 2 CFR §200.331 and 2 CFR §200.332 to ensure its sub-recipients are properly monitored. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Alliance did monitor the subrecipients, but the documentation was not properly saved. This policy has since been revised to save the monitoring documentation to the grant management software. Name of the contact person responsible for corrective action: Lisa Wolf Planned completion date for corrective action plan: July 1st 2026

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 Adminstration Policies & Procedures" are met.

Finding reference: 2024-007 - 93.137 – Community Programs to Improve Minority Health Grant Program Material Weakness and Noncompliance over Subrecipient Monitoring Recommendation: Program management should revise subaward agreements to specifically note the requirements and regulations of the Uniform Guidance, as noted in Section 200.331(a). Additionally, program management should develop standardized procedures for selecting and granting subawards. These procedures should be formalized and maintained for future reference. Brief minutes of progress meetings should be taken to show that monitoring is taking place. All reporting by the subrecipient should be reviewed by management of the program. Action taken: The HHS Department will outline the selection process within the Notice of Funding Availability. Furthermore, a monitoring schedule will be created and program staff are required to review all reports submitted by the subrecipient.

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.