Corrective Action Plans

Circle Health acknowledges and agrees with this finding. We did have contracts in place with subrecipients, but they were outdated. Both program and finance staff work closely with subrecipients and ensure that they are aware of the grant requirements, reporting requirements, allowable costs, etc. Subrecipient monitoring is performed on a regular basis via review of submitted invoices, programmatic meetings and performance reviews. We will create new contracts and have all outstanding, unsigned agreements signed. We will maintain a checklist of due dates for all subrecipient agreements and review periodically throughout the year.

Management concurs with this finding. As noted in the response to Subrecipient Monitoring – Improper Communication to Subrecipient, Subrecipient vs. contractor differentiation has been an area of continued improvement. Management believes recent efforts to properly differentiate between subrecipients and contractors has resulted in accurate determinations. However, documentation, ongoing monitoring, and communication are areas for further improvement. To that end, Management has implemented a new subrecipient/contractor determination form that includes both documentation of the determination and a checklist for ongoing compliance and monitoring for both subrecipients and contractors. This form requires that a subrecipient monitoring plan be put in place which will address compliance with all applicable federal award conditions including Single Audits. Management believes implementation of this form/process will reduce the risk of further noncompliance.

As of January 2, 2024 CAL, hired a staff account (Melanie Richards) to ensure all expenses are recorded in compliance with performance periods. The Associate Director of Finance will review all postings monthly and consult with the Vice President of Finance on any corrections or recommendations.

Corrective Action Plan: Management will ensure controls are put in place to adequately monitor all subrecipient monitoring requirements. Anticipated Completion Date: Fiscal Year 2024.

Name of the Contact Person Responsible for the Corrective Action Plan: John Wiggins, Finance Director. Corrective Action Plan: The City of Forest Park will take necessary steps in the future to ensure that our subrecipient agreements include all of the required federal compliance language and we will ensure that risk assessments are performed for future subrecipients. Anticipated Completion Date: April 30, 2024

Federal Agency: U.S. Department of Transportation Program/Cluster: Highway Planning and Construction Federal Assistance Listing Number: 20.205 Pass‐through: California Department of Transportation Award No. and Year: 5923, 2022/2023 Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. All Public Works contracts receiving federal funding will be evaluated to determine if the vendor is a contractor or subrecipient going forward. This practice is already followed for the other divisions within the Department, and Public Works will now be included. Responsible Individual(s): James Bezek, Director of Resources Management Anticipated Completion Date: June 30, 2024

Federal Agency: U.S. Department of Housing and Urban Development Program/Cluster: Housing Voucher Cluster Federal Assistance Listing Number: 14.871, 14.879 Pass‐through: n/a – direct award Award No. and Year: CA131, 2022/2023 Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance Views of Responsible Officials and Corrective Action Plan: The subrecipient agreement was updated to include required federal award identification elements and was approved by the Board of Supervisors and executed on July 25, 2023. Discussion between the County and the City of Vacaville, including several meetings about the new contract took place throughout the audit period of July 1, 2022 and June 30, 2023. The risk assessment was completed in November 2022. The risk assessment will be updated on an annual basis going forward. A site visit was conducted in December 2022. Monitoring activities were occurring for this contract but were not formally documented. Documentation will be retained as support monitoring activities are occurring for this contract going forward. Responsible Individual(s): James Bezek, Director of Resources Management Anticipated Completion Date: June 30, 2024

Finding Number 2023-213: The Department erroneously determined that two recipients of Temporary Assistance for Needy Families (TANF) funding were contractors instead of subrecipients resulting in noncompliance with the subrecipient monitoring requirements. Federal Programs: 93.558 – Temporary Assistance for Needy Families Related to Prior Finding: N/A Agency’s view: The Department agrees with this finding. Corrective Action: The Department has revised our training of personnel involved in subrecipient and contractor determinations. These contract managers and monitors completed grant training on March 12th-13th, 2024 which included sections about subrecipient and contractor determinations, risk assessment and documentation. All newly hired employees will be trained beginning April 2024 with an on-line module. For the impacted vendor, an updated Risk Assessment was completed and submitted to LSO. Additionally, the Department has started the work to effectively change the designation of the vendor and ensure all required information is provided to this subrecipient. This process will be completed by April 30th, 2024. The Department will develop internal control procedures to ensure all required information is provided to the subrecipients at the time of the subawards. These updated internal control procedures will be completed by June 30th, 2024. Anticipated Corrective Action Date: June 30, 2024 Responsible for Corrective Action: Cameron Gilliland, Division Administrator Cameron.Gilliland@dhw.idaho.gov 208-334-0641 Kelly Combs, Bureau Chief, Compliance Kelly.Combs@dhw.idaho.gov 208-334-5814

CORRECTIVE ACTION PLAN March 26, 2024 City of Roanoke, Virginia respectfully submits the following corrective action plan for the year ended June 30, 2023. Name and address of independent public accounting firm: Brown, Edwards & Company, L.L.P. 3906 Electric Road Roanoke, VA 24018 Audit period: June 30, 2023 The findings from the June 30, 2023 Schedule of Findings and Questioned Costs (the "Schedule") are discussed below. The findings are numbered consistently with the number assigned in the Schedule. FINDINGS AND QUESTIONED COSTS - MAJOR FEDERAL AWARD PROGRAM AUDIT 2023-001: Workforce Investment Opportunity Cluster - Assistance Listing #17.258117.259 / 17.277 / 17.278, Subrecipient Monitoring Condition: During our review of subrecipient monitoring, we noted that the City's monitoring was not being performed according to the formal written policy. While monitoring was performed and documented during the second half of fiscal year 2023, there was a lack of evidence of testing and suggestions to the subrecipient during the first half of fiscal year 2023. Criteria: According to 2CFR 200.33l(a) of the 0MB Compliance Supplement, the City should make subrecipients aware of award information. According to the City's Program Participant Monitoring Plan, the City is supposed to conduct subrecipient monitoring on a semi-annual basis which should include desk reviews of payroll, disbursements, and other financial items. Cause: Staff turnover, particularly for the role of grant accountant, caused these procedures to be overlooked. Management prioritized core operating activities with staffing vacancies in lieu of monitoring activities. Management asserts staff went onsite to review key documents, as documented by email activities, but did not document specific items subject to review. Effect: Noncompliance with federal grant requirements with regard to subrecipient monitoring as well as an increased risk of subrecip1ent misusing funds. Questioned Cost Amount: Not applicable. Perspective Information: One out of two awards Recommendation: We recommend performing subrecipient monitoring in accordance with the City's guidelines and following the procedures laid out in the Program Participant Monitoring Plan. Corrective Action: Management concurs with the recommendation and will ensure that follow-up occurs regarding information provided by business owners. Loss of staff in this accountability area resulted in inquiry and reviews conducted by varying personnel the past few fiscal years. The Accounting Supervisor and the Accounts Payable coordinator, in the absence of a Grant Accountant, conducted the first semi-annual visit for fiscal year 2023. A grant accountant was hired in Spring 2023 along with an Accounting Manager, who were able to conduct the second visit in June 2023. Revisions to the policies and procedures were made following the June visit along with developing formalized documentation templates that show what was subject to monito ring. Fiscal year 2024 monitoring in January 2024 has been completed with follow-up to occur in June 2024. 2023-002: Coronavirus State and Local Fiscal Recovery Funds -Assistance Listing #21.027, Disbursements Condition: During our review of the locality's disbursements related to the program, it was noted that procurement policies were not being followed. In 3 of 25 instances, credit card purchases were not properly approved. Criteria: CSLFRF funds may be used for eligible expenses subject to restrictions set forth in Treasury's Interim Final Rule and Final Rule at 31 CFR Part 35. Also, 2 CFR Part 200 section 303 requires effective control over, and accountability for, all funds. According to the City's procurement policy, department managers and directors are supposed to review and approve credit card purchases on a monthly basis. Review includes ensuring appropriate supporting documentation is included. Documentation should support that transactions are for allowable expenses. Cause: Though the City has controls that push compliance, monitoring and enforcement by Finance is lacking. Additionally, the volume of transactions make monitoring challenging. Some transaction support and approval are routed electronically through US Bank for automation, but there are thousands of monthly transactions. Effect: Noncompliance with federal grant requirements with regard to disbursements. Questioned Costs: Not applicable. Perspective Information: Three out twenty-five transactions Recommendation: We recommend disbursing funds in accordance with the City's procurement policy including a process that requires approval of all credit card purchases. Corrective Action: Management concurs with the recommendation and will ensure that procurement policies including those over credit card purchases will be adhered to. Starting in fiscal year 2023 communication to department directors occurred reinforcing that reviewing and approving financial transactions is necessary under City policy. The City's Department of Finance on a monthly basis is monitoring P-Card compliance and has enhanced communication of internal deadline dates for coding and approving transactions. Follow-up is performed by the Accounts Payable coordinator to address issues with individual users and departments who have unapproved transactions. This practice will continue moving forward with issues of continued non-compliance by users and directors potentially resulting in revoking privileges of using city purchasing cards. 2023-003: Coronavirus State and Local Fiscal Recovery Funds -Assistance Listing #21.027, Disbursements Condition: During our review of the locality's revenue loss calculation, it was noted that one revenue figure was not supported by the City's transmittal form causing the lost revenue available for the City to claim to be understated by approximately $4.8 million. Criteria: Under the Final Rule, recipients can elect a one-time "standard allowance" of $10 million (not to exceed the recipient's award amount) to spend on the "provision of government services" during the period of performance. Alternatively, recipients can calculate lost revenue for the years 2020, 2021, 2022, and 2023 based on the formula provided in the Final Rule to determine the amount of SLFRF funds that can be used for the "provision of government services." According to the 0MB Compliance Supplement section 4-21.027 section III B, recipients can choose whether to use calendar or fiscal year dates but must be consistent through the period of the performance and must provide auditors with evidence supporting their revenue loss calculation. Cause: The calculation of revenue loss was performed by staff who was new to their role with the City. All figures agreed with the Auditor of Public Accounts (APA) transmittal except for one section. Supervisory review was performed but did not detect the inconsistency in the calculation with reported figures on the APA transmittal form. Effect: Noncompliance with federal grant requirements with regard to lost revenue, understating the available revenue loss the City can utilize. Questioned Cost Amount: Not applicable. Perspective Information: Three out of twenty-five transactions Recommendation: We recommend that a process be put in place that ties out all amounts used on the lost revenue calculation to amounts on the transmittal form. Corrective Action: Management concurs with the recommendation and will ensure that the APA transmittal is used for future calculations as necessary. The calculation will be subject to multiple reviews. A final ARPA revenue loss calculation is planned for the spring that will incorporate the updated revenue loss figures from fiscal year 2023 ACFR and update the reporting figures in the fiscal year 2022 ACFR. The City's plan for ARPA spending currently does not plan to utilize the entire revenue loss funds but instead seeks to spend on specific projects that are ARPA eligible. If the Federal Audit Clearinghouse has questions regarding this plan, please call Andrea Trent, Financial Management Consultant at 540-853-5224. Sincerely yours, Andrea F. Trent Financial Management Consultant

2023-001: 172.258, 17.259, 17.278 – WIOA Cluster • Recommendation 1: We recommend that the County prepare and maintain a written plan to ensure subrecipients are aware of the Uniform Guidance requirements. • Recommendation 2: We recommend the County performs the monitoring of the subrecipients and ensure the documentation is saved within the County. • Explanation of disagreement with audit finding: There is no disagreement and management agrees with the finding. • Corrective action taken in response to finding: The County Office of Finance will (1) develop a written plan to ensure that subrecipients are aware of all the Uniform Guidance requirements; (2) due to the pandemic and the recent retirement and resignation of the top two Grant department staff members, the monitoring was not conducted during the audit period. Management will make sure that the required monitoring will be conducted and ensure compliance and proper documentation is maintained onsite. • Name of the contact person responsible for corrective action: Kevin McMahon, Office of Finance and Charles Knapp, Anne Arundel Workforce Development Corporation. • Planned completion date for the corrective action plan: June 30, 2024.

Finding 2023-009 Lack of Subrecipient Monitoring Plan: The University of Illinois Springfield will review procedures to ensure subrecipient monitoring is conducted and documented for all subawards. Expected Implementation Date: April 2024 Contact: Charles Alsbury, Director Office of Research & Sponsored Programs, Post-Award University of Illinois Springfield Ralsb01s@uis.edu 217-206-7849

Department: Transportation Title: Internal control over DOT subrecipient and contractor determinations needs improvement Questioned Costs: None Status: Corrective action complete Corrective Action: The Department has reviewed the standards for categorizing vendors and subrecipients. The Department has amended the process to include a substantive review of the initial categorization by a Financial Analyst before the report is finalized and transmitted. Completion Date: February 21, 2024 Agency Contact: Kathleen Malcolm, Financial Processing Director, DOT, 207-624-3292

Statement of Concurrence or Non-concurrence: We agree with the auditor’s finding as far as not giving subrecipients the Assistance Listing Number (CFDA#) and the below actions will be taken to improve the situation. However, ICHC management questions the degree of the audit finding due to ICHC receiving the HEC funding from the State of Alaska as a pass-through and not directly from the Centers for Disease Control and Prevention. Corrective Action Plan Interior Community Health Center (ICHC) will read and ensure the requirements of 2 CFR 200.331 (a)(1) and the OMB Compliance Supplement May 2023 are understood and implemented for future subrecipient activity. ICHC will send out a letter to all agencies who received the HEC funds with the explanation that funds were federal funds and this required factors of 2 CFR 200.331(a)(1) of the OMB Compliance Supplement May 2023. ICHC will give the awardees the Assistance Listing Numbers of the HEC funds to ensure they properly reported funding on their FY23 SEFAs. ICHC will also send a notification to the State of Alaska notifying them that ICHC will be terminating the administration of HEC grant funding on May 31st, 2024. ICHC will tell the State that an error was made in providing the subrecipients the Assistance Listing Numbers of the HEC funding. ICHC will thank the State of Alaska for the opportunity to distribute the funding to the agencies in the Fairbanks North Star Borough that deal with the vulnerable people who are at a higher risk of COVID-19. Name of Contact Person: Traci Yeckley, Chief Financial Officer Contact Number: 907-455-4567. Email: traci.yeckley@inhc.org Projected Completion Date: The anticipated completed date is April 1st, 2024

Condition: Subaward agreements with subrecipients, including Assistance Listing Number (ALN) and title, subrecipient’s DUNS/UEI number, Federal Award Identification Number (FAIN), identification of whether the award is research and development, and indirect cost rate for federal award, were not included. Recommendation: We recommend that the agency 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. Views of responsible officials: There is no disagreement with the audit finding. Action taken in response to finding: KDEM is implementing a comprehensive compliance program. The program will oversee that appropriate communication is made to subrecipients as required to be in compliance with 2 CFR 200.331(a). Name(s) of the contact person(s) responsible for corrective action: Jennifer Deal Planned completion date for corrective action plan: July 1, 2024

Condition: During our testing, we noted subrecipients had required information omitted from the sub agreements to the subrecipients including Assistance Listing Number (ALN) and title, subrecipient’s DUNS/UEI number, Federal Award Identification Number (FAIN), identification of whether the award is R&D, and indirect cost rate for federal award. Recommendation: We recommend that the agency 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. Views of responsible officials: There is no disagreement with the audit finding. Action taken in response to finding: A cover sheet with the required information to be provided to the subrecipients has been created. Name(s) of the contact person(s) responsible for corrective action: Program personnel Planned completion date for corrective action plan: Implementation will begin immediately in March 2024.

Corrective action plan: To address the error, CMSM will add an additional layer of review for the Master Planning Summary (MPS) to be performed by the director of compliance subrecipient monitoring. In addition the MPS will be periodically provided to affected Program divisions for review. Implementation date: March 1, 2024 Responsible person: Earnest Hunt, Director of Compliance Subrecipient Monitoring

Program: AL 21.026 – COVID-19 Homeowner Assistance Fund – Subrecipient Monitoring Corrective Action Plan: The Military Department will continue to modify the Memorandum of Understanding between the parties to identify NIFA as a subrecipient and advise of them of any additional requirements. Contact: Erv Portis Anticipated Completion Date: ongoing

The newly hired CFO has Federal Grant Compliance experience and will implement a process for identification and oversight of subrecipients in line with Uniform Guidance 2 CFR § 200.331. The Organization will ensure there are written policies to comply with this provision and will monitor its subrecipients on a quarterly basis and will obtain written agreements by and between the Organization and its subrecipients.

The City agrees with the finding. The City's Grant Administrator will provide training to each City department which currently oversees subrecipients, ensuring that all department staff understand general and ARPA-specific subrecipient requirements. Additionally, the Grant Administrator will review City departments' subrecipient management checklists to ensure all required documentation is obtained from subrecipients and reviewed as required. This will be complete by June 30, 2024.

Views of Responsible Officials: We agree with the finding.

Significant Deficiency in Internal Control over Compliance and Other Matters 2023-003 (Previously 2022-002) Subrecipient Monitoring U.S. Department of Health and Human Services Maternal, Infant, Early Childhood Home visiting Assistance Listing Numbers: 93.870 Recommendation: We recommend the program create an agreement template that contains the required elements of a subaward to distribute to its subrecipients. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: ECECD takes this matter seriously. ECECD has taken immediate steps to resolve the omission of any required elements in our subrecipient agreements. ECECD wants to emphasize that other aspects of sub-recipient monitoring have been effectively corrected and performed. Additionally, the agreement template will be improved to include all required elements to ensure that they are contained within every subrecipient agreement going forward. To ensure a comprehensive resolution, the Chief Procurement Officer and the Chief Financial Officer (CFO) will develop and implement a subrecipient monitoring training for program staff to address and rectify this issue. Name(s) of the contact person(s) responsible for corrective action: Carmel Pacheco-Aragon, Chief Financial Officer; Marlene Acosta, Chief Procurement Officer. Planned completion date for corrective action plan: June 30, 2024

Views of Responsible Officials: In the past, WRC performed the risk assessments on the subrecipients by looking at information available on their website, reviewing the audited financial reports as well as performing elaborate Anti-Terrorism checks on the subrecipient, its management and financial institutions. The process was documented in WRC's Fiscal Policies and Procedures. However, the findings of these assessments were not formally documented. During the year, WRC updated it policies and procedures to establish a better way of performing and documenting the risk assessment of the subrecipients. In addition, we are currently in process of registering our subawards in FSRS. We expect the current subawards to be registered within two weeks. We will then look at the possibility of registering expired subawards in FSRS.

Finding No.: 2022-031 AL Program: 21.027 - Coronavirus State and Local Fiscal Recovery Funds Area: Subrecipient Monitoring Questioned Costs: $61,003,095 Contact Person(s): Tracy B. Norita, Secretary of Finance Corrective Action Plan: Condition 1-3: The Department of Finance agrees with this finding. The Department has recently adopted and approved (August 2025) a Subrecipient Monitoring Policy and Procedures which specifically focused on the implementation of 2 CFR 200.331. The Department will expand on this policy and procedure to include the development and implementation of a comprehensive subrecipient monitoring policies that clearly outline the process for identifying subawards, assessing the risk of noncompliance, and conducting monitoring activities based on those risks. These policies will be aligned with federal requirements and best practices to ensure consistency and accountability. Furthermore, due to internal scheduling constraints and the compressed timeline required to complete the FY22 audit, the requested documents were not submitted by the specified deadline, resulting in this finding. However, the Department maintains all relevant supporting documentation and is prepared to provide it upon request from the Grantor. Proposed Completion Date: Ongoing

Finding No.: 2022-027 AL Program: 21.026 - Homeowner Assistance Fund Program Area: Subrecipient Monitoring Questioned Costs: $4,157,924 Contact Person(s): Tracy B. Norita, Secretary of Finance Corrective Action Plan: Condition 1-4: The Department of Finance agrees with this finding. The Department has recently adopted and approved (August 2025) a Subrecipient Monitoring Policy and Procedures which specifically focused on the implementation of 2 CFR 200.331. The Department will expand on this policy and procedure to include the development and implementation of a comprehensive subrecipient monitoring policies that clearly outline the process for identifying subawards, assessing the risk of noncompliance, and conducting monitoring activities based on those risks. These policies will be aligned with federal requirements and best practices to ensure consistency and accountability. Proposed Completion Date: December 31, 2025

Finding No.: 2022-019 AL Program: 15.875 - Economic, Social, and Political Development of the Territories Area: Subrecipient Monitoring Questioned Costs: $549,849 Contact Person(s): Nerissa B. Karakaya, CIP COTR / Angelina Phillips, Office of Management and Budget (OMB) Corrective Action Plan: Condition 1 (N. Karakaya): CIP agrees with this finding. The address this finding, CIP will implement the following: 1. Establish Written Procedures: CNMI has developed and will initiate the implementation of formal written procedures requiring that all potential subrecipients be checked in SAM.gov prior to award and that verification is documented and retained in the official files. 2. Standardized Documentation: A standardized risk assessment checklist will be used for all subrecipients to confirm they are not suspended, debarred, or excluded under 2 CFR §180.300. 3. Staff Training: All staff responsible for subrecipient monitoring will receive training on federal requirements for exclusion checks and proper documentation procedures. 4. Monitoring and Review: CIP will conduct periodic reviews to ensure that SAM.gov checks are consistently performed and documented for all new and existing subrecipients. Condition 2 (N. Karakaya): CIP respectfully disagrees with this finding. The subrecipient was not required to submit the required project narrative report; instead, the report was prepared and submitted by the project manager responsible for managing the project as assigned by the Capital Improvement Program. In accordance with 2 CFR §200.328 – Monitoring and Reporting Program Performance, subrecipients are required to provide performance reports to the pass-through entity that document the status and progress of activities in accordance with the approved scope of work. To correct this issue, the subrecipient will implement a formal internal procedure designating the Program Coordinator as responsible for preparing, reviewing, and submitting all project narrative reports. Additionally, mandatory training will be conducted for all relevant subrecipient staff on federal reporting requirements and proper submission procedures, and all future narrative reports will include a certification by the authorized subrecipient representative confirming proper submission. The Capital Improvement Program will monitor submissions quarterly for the next 12 months to ensure full compliance. Corrective Actions: 1. Implement a formal internal reporting procedure requiring the subrecipient’s Program Coordinator to prepare, review, and submit all project narrative reports. 2. Conduct mandatory training for subrecipient staff on federal reporting requirements, documentation standards, and submission procedures. 3. Include a certification statement on all future narrative reports, signed by the subrecipient’s authorized representative, confirming proper submission. 4. Conduct quarterly monitoring of subrecipient submissions for the next 12 months to ensure compliance with reporting requirements. Proposed Completion Date: December 31, 2025 Condition 3 (N. Karakaya): We acknowledge the finding that documentation was not provided to verify whether eight subrecipients were subject to the audit requirements. The Capital Improvement Program will strengthen its subrecipient monitoring procedures to ensure compliance with 2 CFR 200.331(f) and related audit requirements. Corrective actions will include: 1. Policy Implementation: Adopt and disseminate the newly established Subrecipient Monitoring Policy and Procedures, which specify verification of subrecipients’ audit requirements. 2. Training: Provide training for program and grants management staff on the updated procedures and audit verification process. 3. Documentation: Maintain written evidence of audit requirement verifications for all subrecipients as part of the grant administration files. 4. Ongoing Monitoring: Incorporate periodic review of subrecipient audit status into the regular monitoring schedule to ensure continued compliance. These steps will be implemented immediately and will be applied to all current and future awards to prevent recurrence of this issue. Proposed Completion Date: December 31, 2025