Corrective Action Plans

Views of Responsible Officials and Planned Corrective Actions: The Center has already created a new risk assessment template to determine the level of risk associated with working with subrecipients. The Center will document the risk assessment findings and determine the necessary monitoring levels. Name and Title of Responsible Official(s): Vibha Bhatia, Vice President of Finance and Operations Anticipated Completion Date: October 31, 2024

Mayor’s Office of Housing (MOH) has implemented control procedures to ensure that each subrecipient is evaluated for risk of noncompliance to ensure appropriate subrecipient monitoring. Anticipated Completion Date: June 30, 2024 Responsible Contact Person: Colin Musto, Assistant City Auditor, Grants Monitoring Unit colin.musto@boston.gov

Finding 2023-003 Finding Subject: Covid-19 – Coronavirus State and Local Fiscal Recovery Funds – Subrecipient Monitoring Summary of Finding: The County did not include all required information in the subrecipient agreements during the audit period. Contact Person Responsible for Corrective Action: Debbie Morton-Crum, County Auditor Contact Phone Number: 765-482-2940 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The County Commissioners are responsible for the American Rescue Plan project list along with that responsibility is to have a sub-recipient agreement in place with those outside entities that received American Rescue Plan grant monies from the County. An Internal Control is now in place that requires a sub-recipient agreement in place before a warrant can be paid to those outside entities. We will put procedures in place to ensure that money disbursed to sub-recipient is monitored. Anticipated Completion Date: December 2024

Recommendation: It is recommended the County reviews their policies to ensure reporting requirements are met including a review of the subrecipient reports prior to submission. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The County will implement policies to ensure reporting processes include review by someone other than the preparer. Name of the contact person responsible for corrective action plan: Kathleen Ryan, Chief Financial Officer. Planned completion date for corrective plan: December 31, 2024

Auditor’s Recommendation: We recommend that management require all sub-awardees to have a subaward agreement or memorandum of understanding (MOU). Action Taken: • As a First Year Single Auditee, the management team will ensure that senior leadership team, finance and accounting team, as well as program manager/directors for federal awards receive some form of training and certify receipt of this training within six-months of these findings. • As a First Year Single Auditee, the management team will ensure that specific policies for sub-awards and sub-recipients will better ensure its internal practices are in alignment with Uniform Guidance standards for federal awards. • As a First Year Single Auditee, the management team will have an independent audit firm review these specific policies to ensure they are in alignment and conformance with Uniform Guidance standards.

2023-004 SUBRECIPIENT MONITORING Recommendations: The Council should review existing subrecipient agreements and amend any contracts that may be missing the required Uniform Guidance language. Management should ensure that future contracts use the template appropriate for the funding source (Federal, state or non-grant funded). To ensure compliance with the requirements for subrecipient monitoring, the Council should establish processes to (1) review and reports required by the subrecipient contract; (2) document the Council’s follow-up on action taken by the subrecipient on any deficiencies detected through audits, on-site reviews or other means; and (3) issue a management decision for audit findings pertaining to the Federal award provided to the subrecipient. Management’s Response: The timing of the federal award received from the EPA and the allocation of funds to certain projects approved in the workplan, resulted in several projects that had been completed and were originally funded through other revenue sources such as state license plate funds. The award time frame positioned these projects to be considered allowable pre-award expenses, however due to the timing of completion and award issuance, the agreements could not be amended to add the required federal subrecipient Uniform Guidance Language. The IRL Council will establish the following controls and implement actions to ensure subrecipient compliance: • Review all projects and activities currently allocated and funded by federal sources to insure the Uniform Guidance Language is in place with their respective agreements. For any agreement still in force, language will be amended immediately. For any agreement completed, the subrecipient shall be notified of the source of funds including the federal award identifier and amount of funding pertaining to that agreement to allow for subrecipient audit compliance. • All future subrecipient agreements funded by federal sources will not be executed until the respective federal award is in place and the Uniform Guidance Language is included. • All future and amended federally funded agreements will include language requesting audit reports and any finding with respect to the expenditure of federal funds. • The IRL Council will issue a written decision for audit findings pertaining to the Federal award provided to the subrecipient. Responsible Party: Daniel Kolodny, Chief Operating Officer Anticipated Completion Date: December 31, 2024.

Contact Person Responsible for Corrective Action: Abby Doyle, Chief Deputy Auditor Contact Phone Number: (574) 235-9668 ext.7201 Views of Responsible Official: We concur with the audit finding with respect to the monitoring of subrecipients for the American Rescue Plan funding. The County monitored the subrecipient agrees for the 50% matching requirement, and the subrecipient was paid properly. However, we did not obtain quarterly progress reports on the program. Description of Corrective Action Plan: On March 4, 2024, the County contacted each entity that signed a sub-recipient agreement for American Rescue Plan (ARP) funding and asked them to complete and sign the attached Proof of Project Efforts Schedule. The schedule provides the County with a description of the project and uses of ARP funds. In addition, the schedule provides a listing of project expenditures and paid invoices. The completed forms have been received and filed. Completion Date: March 29, 2024

In June 2023, following the completion of the 2022 Single Federal Audit, APS immediately implemented additional policies, procedures, and controls to ensure that all subrecipients submit programmatic and financial reports in a timely manner and that these reports are reviewed by the Principal Investigator/Program Manager and Grant Administrator through a new reporting form. This form logs electronic signatures from both the sub-awardee and APS staff. In addition, APS implemented a procedure to review the single federal audit of each sub-awardee annually. APS will review and monitor award amounts and for the required filings annually to ensure that the award amounts are accurate and updated timely to meet all reporting requirements set forth under the Transparency Act. APS implemented the corrective action plan on June 5, 2023. Management's contact responsible for the implementation of the Corrective Action Plan: Name: Jane Hopkins Gould Position: Chief Financial & Operating Officer Telephone number: 301-209-3276

EXECUTIVE OFFICE OF LABOR AND WORKFORCE DEVELOPMENT 2023-012 WIOA Cluster, Employment Service Cluster – Assistance Listing No. 17.258, 17.259, 17.278, 17.207, 17.801 Action taken in response to the finding: The corrective action plan (CAP) for this finding was implemented and completed in Fiscal Year 2023 with the addition of the FAIN numbers to the subawards and the completion of FY23 CommCorp monitoring. MDCS continues to include FAIN as part of the revised documented process and monitoring is current and timely performed. MDCS therefore considers this item to be completed and closed. Name of the contact person responsible for corrective action: Michael Williams, Director of Field management and Oversight Planned completion date for corrective action plan: December 31, 2022

2023-003 – Subrecipient Monitoring Compliance Person responsible for corrective action – Andrea Olson, Executive Director Responsible official’s response – Management is in agreement with this finding. Corrective action planned – CAPND has subsequently requested all audit reports from all subrecipients. Additionally, CAPND has changed subaward formatting to ensure that all required information is included within the award. Planned implementation date of corrective action – July 10, 2024

Views of Responsible Officials: The Organizations concur with the auditor's assessment and are in the process of implementing a pre-award risk assessment procedure.

Research and Development – Assistance Listing No. 10.216 Research and Development – Assistance Listing No. 43.008 Research and Development – Assistance Listing No. 93.433 Recommendation: We recommend the University review its procedures for the subrecipient monitoring process to ensure the reviews are completed timely and implement procedures necessary to ensure information is included in the subrecipient award documents at the time of funding. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Langston is strengthening processes to use and distribute disclosures to subrecipients and follow-up for incomplete/unsigned documents from subrecipients. Name(s) of the contact person(s) responsible for corrective action: Mr. Robert Dixon, Director, Grants and Contracts Fiscal Administration at Oklahoma State University. Planned completion date for corrective action plan: March 2024

The County Grants Manager will ensure that all subrecipients receiving $750,000 in Federal Funds undergo a Single Audit as required by 2 CFR Part 200. The Grants Manager will review the SEFA and contact all necessary subrecipients for their audits. Name of Contact Person: Kristi D. Bosch, Grants Manager Anticipated Completion Date: 12/31/2024

The County will review the monitoring plan related to the program and will ensure these procedures are done timely and meet the federal requirements for monitoring subrecipients.

The County will require departments receiving federal funding to complete a subrecipient and contractor relationship checklist based on the Uniform Guidance prior to entering into a contract with any vendor. This checklist will ensure proper identification of subrecipients and serve as documentation of this procedure. This checklist will be part of our Grants Acknowledge form implemented by our Grants department that recipient departments are required to complete at a grant’s inception. Completed checklists will be retained and reviewed by the Finance department prior to SEFA compilation to ensure subrecipient expenditures are being properly recorded on the SEFA. For awards identified as being passthroughs to subrecipients, the County has developed additional procedures to document this relationship. This includes a subrecipient package requiring signatures from the County and subrecipient to acknowledge the subrecipient relationship. This package will include relevant award identifiers such as award date, period of performance and Federal awarding agency and Assistance Listing Number and title. Recipient departments will also be required to perform monitoring procedures on identified subrecipients including assessing the subrecipient’s risk of noncompliance with Federal statutes, regulations and the terms and conditions of the subaward. The County has developed a questionnaire for biannual monitoring meetings with the subrecipient that is intended to further document the subrecipient is utilizing funds for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward, and that subaward performance goals are achieved. This questionnaire also requests obtaining copies of the subrecipients financial statements and single audit to verify the subrecipient is audited as required by Subpart F - Audit Requirement under the Uniform Guidance

SUBRECIPIENT MONITORING – COMMUNITY DEVELOPMENT BLOCK GRANTS Recommendation: It is recommended that the County reviews their policies to ensure they are monitoring subrecipients and retaining documentation as required by federal guidelines. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The County will implement policies to ensure all documentation is kept and subrecipient monitoring is in place. Name of the contact person responsible for corrective action plan: Nancy Malecha, Finance Director Planned completion date for corrective action plan: December 31, 2024

REPORTING – COMMUNITY DEVELOPMENT BLOCK GRANTS Recommendation: It is recommended that the County reviews their policies to ensure reporting requirements are met including a review of the subrecipient reports prior to submission. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The County will implement policies to ensure reporting processes include review by someone other than the preparer. Name of the contact person responsible for corrective action plan: Nancy Malecha, Finance Director Planned completion date for corrective action plan: December 31, 2024

The Department of Behavioral Health (DBH) agrees with the findings. Eligibility of Subrecipients: Training will take place for Fiscal Services Staff to ensure that screening for eligibility for the program takes place. The requirement for screening will be added as a required data element so screening can be monitored in the grants management system. Earmarking Requirements for Subrecipients: ICR will be set up based on allowable costs from the NOA in grants management system. Training will be conducted for Fiscal and Program Monitors so that they are aware of how ICR is determined and calculated. Monitoring of Subrecipients: DBH will conduct training to ensure that Fiscal and Program Monitors understand the requirements of on-going documentation to identify risk and compliance to the program. DBH will have the monitoring form created in the new grants management system so that failure to complete the documentation will trigger a system alert with an escalation process to ensure compliance. Contact - Eligibility of Subrecipients: Anthony Baffour, Director, Fiscal Services, Earmarking Requirements for Subrecipients: Sharon Hunt, State Opioid Treatment Authority and Anthony Baffour, Director, Fiscal Services, Monitoring of Subrecipients: Sharon Hunt, State Opioid Treatment Authority and Anthony Baffour, Director, Fiscal Services See Corrective Action Plan for chart/table Estimated Completion Date - Staffing Training: August 1, 2024, Grants Management System: January 1, 2025 See Corrective Action Plan for chart/table

The Department of Energy and Environment (DOEE), Office of Neighborhood Safety and Engagement (ONSE) and various other District agencies agree with the conditions and recommendations of this finding. DOEE: The agency will add a section regarding a subrecipient’s prior year audit report to the risk analysis conducted by program staff. For any prior year audit findings, the agency will request a copy of the subrecipient’s corrective action plan. ONSE: The agency will conduct and review, on a monthly and quarterly basis, site visits/reports and will follow up with subrecipients to submit reports on a timely basis. Various Other District Agencies: The agencies will review the details of subrecipients amount generated from the system and perform a vendor or subrecipient analysis to ensure accuracy of amounts to be reported in SEFA. Contact - Lisa Mae Crawford, Associate Director, Residential Services Division, DOEE, Yasha Williams, Chief Operating Officer, ONSE, Various District Cluster Controllers Estimated Completion Date - September 30, 2024; March 1, 2025 See Corrective Action Plan for chart/table

Views of Responsible Officials: While the Organization did evaluate sub-recipients prior to each sub-award, documentation of that evaluation was not retained as required. For any new subrecipients, the Organization will perform the required pre-award risk assessment and retain adequate documentation of the work performed and results.

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