Corrective Action Plans

Finding Number 2024-025 Subject Heading (Financial) or AL no. and program name (Federal) 93.658 – Foster Care Planned Corrective Action Oklahoma Human Services (OKDHS) concurs with the recommendation. OKDHS has been working to centralize and strengthen its contract and subrecipient monitoring processes to improve consistency in the identification, documentation, risk assessment, and monitoring of subrecipient relationships across the agency. As part of this effort, OKDHS is updating its procedures and standardized documentation to better ensure that subawards include required federal award information, program responsibilities and deliverables are sufficiently defined, required documentation is obtained and retained, and subrecipient risk assessments and monitoring activities are completed and documented consistently. OKDHS will implement updated, centralized contract and subrecipient monitoring procedures, including standardized tools and documentation requirements designed to address the conditions identified in the finding. The updated process will clarify responsibilities for documenting subrecipient risk assessments, required federal award information, contractual requirements, deliverables, and ongoing monitoring activities. Anticipated Completion Date 9/30/2026 Responsible Contact Person Kayla Urtz

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.

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