Corrective Action Plans

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

The Government concurs with the auditor's findings and recommendations. The formal process for completing and retaining Subrecipient Agreements is now operational to ensure compliance with programmatic obligations. As the Recipient, it is the Territory's responsibility to notify the Subrecipient when the federal funds are obligated and provide them with a subrecipient agreement which outlines the terms and conditions of the program. The Disaster Program Financial Specialist is responsible for reconciling that the subrecipient agreement has been signed by the Applicant and Governor's Authorized Representative and provided to the Territorial Public Assistance Officer. As such, no funds will be disbursed until the Subrecipient signs and returns the subrecipient agreement. These agreements are saved in a centralized location for documentation and audit purposes.

The Government concurs with the auditor's findings and recommendations. VIDE acknowledges the need for strengthened controls to ensure subrecipient compliance with federal audit requirements, as specified in 2 CFR Part 200, Subpart F. VIDE is committed to implementing effective measures to ensure that all subrecipients adhere to federal regulations and that sufficient oversight is provided. VIDE will ensure all subrecipient agreements include explicit reporting requirements and compliance expectations under 2 CFR Part 200, Subpart F. In addition, training will be given to internal staff on subrecipient monitoring requirements and best practices to ensure consistent implementation.

The Government concurs with the auditor's findings and recommendations. OMB will identify and monitor the federal awarding agencies and will request single audit results for the applicable recipients beginning FY25 and include the results in the monitoring reviews. For revenue replacement projects, based on Treasury’s Final Rule FAQ (13.14), “Recipients’ use of revenue loss funds does not give rise to subrecipient relationships given that there is no federal program or purpose to carry out in the case of the revenue loss portion of the award.” As such, they are not subject to the Single Audit Act.

The Government concurs with the auditor's findings and recommendations. OMB will develop and enforce a robust framework that includes detailed monitoring procedures, regular compliance checks, and comprehensive oversight mechanisms. This framework will ensure that all subrecipients adhere to federal requirements, thereby promoting accountability and proper use of federal funds. These measures will help mitigate risks, enhance transparency, and ensure that subrecipients fulfill their obligations under federal statutes effectively.

Finding 2022-001 – Subrecipient Monitoring Corrective Action Planned: The Organization concurs with the finding. We recognize that our current subrecipient monitoring procedures did not adequately address compliance with payroll tax reporting and filing requirements for the Community Based Organizations that were the grant subrecipients. To strengthen our oversight, the Organization will take the following corrective actions: 1. Policy Update: Revise our subrecipient monitoring policy to explicitly require verification of payroll tax compliance, including review of IRS Form 941 filings and evidence of payroll tax payments. 2. Monitoring Procedures: Implement a standardized monitoring checklist that includes obtaining periodic compliance certifications from subrecipients and requiring submission of payroll-related documentation. 3. Staff Training: Provide training to staff responsible for subrecipient monitoring to ensure awareness of Federal compliance requirements, including payroll tax obligations. 4. Ongoing Oversight: Require annual subrecipient monitoring visits or desk reviews to evaluate compliance with financial and Federal reporting requirements. Anticipated Completion Date: December 31, 2025 Responsible Party for Implementation: Willa Lang, Executive Director (312-742-5105) Views of Responsible Official: The Organization agrees with the auditor’s finding and is committed to taking corrective actions to ensure full compliance with Federal requirements going forward.

THE ORGANIZATION WILL USE EXPENDITURE REPORTS BY CLASS TO SUPPORT BASE EXPENDITURES FOR THE PERIOD. WILL BE IN PLACE FOR THE 2025 SINGLE AUDIT AND BEGAN THIS PROCESS IN 2024. KAREN SHARPNACK, EXECUTIVE DIRECTOR KJS@IDAHOIMMUNE.ORG AND NEW CPA FIRM TO BE DETERMINED. THE ORGANIZATION THROUGH ITS BOARD OF DIRECTORS WILL CREATE A “FINANCIAL POLICY COMMITTEE” WHICH WILL BE RESPONSIBLE TO WORK WITH THE EXECUTIVE DIRECTOR, THE NEW CPA TO OUTLINE AND CREATE NEW POLICIES, PROCEDURES AND PROCESSES, ALONG WITH OVERSIGHT OF THE FINANCIAL WELL-BEING OF THE ORGANIZATION AND REPORT TO THE BOARD OF DIRECTORS. IMMEDIATELY, THE PROCESS WILL BEGIN TO RECRUIT THE COMMITTEE ON JUNE 25, 2025.

Finding 2022-006 – Subaward Monitoring In response to the finding, GEM enhances subaward monitoring by instituting the following. GEM will establish written documentation to ensure appropriate oversight of sub-awardee compliance with NSF program responsibilities. Anticipated date of completion: We received the "No cost extension" and this was completed by September 30, 2023. Written documentation instituted that outlines specific actions and timeline of deliverables expected of sub-awardee as well as corrective actions if sub-awardee is not in compliance with responsibilities. Responsible party: Dr. Marcus Huggans Principal Investigator

As part of our current policies and procedures review and revision process, we plan to incorporate the subrecipient monitoring and management provision of 2 CFR§ 200.331 and 2 CFR §200.332 of the Uniform Guidance to emphasize accountability and compliance in managing federal funds and subrecipients. Specifically and prospectively, effective November 1, 2024, the Organization’s practices will include: 1. Using a checklist for the determination of subrecipient or contractor classification as guidance; Perform a comprehensive risk assessment before entering into any subrecipient agreement. 2. Provide identification details such as CFDA number, amount of federal funds obligated, and the award period for determined subrecipient awards. 3. Require subrecipients to submit programmatic and financial reports as specified in the subrecipient agreement. 4. As part of the subrecipient process, ensure subrecipients that expend $750,000 or more in federal funds during a fiscal year undergo a single audit in accordance with 2 CFR Part 200, Subpart F. Review their audit reports and address any findings related to their federal awards, taking appropriate corrective actions Retroactively, for the audit periods July 1, 2022 – June 30, 2023 and July 1, 2023 – June 30, 2024, the Organization will perform a risk assessment of the existing subrecipient portfolio during this period to identify high-priority risks. The objective of this risk assessment review is to identify, evaluate, and prioritize risks that could adversely impact the organization’s ability to achieve its strategic, operational, and quality assurance goals, ensuring that all products, services, and processes align with established standards and fulfill processes. The above reflects the current planned practices of the Organization and the overall financial policies and procedures are in the process of being updated to align to the subrecipient monitoring and management provision of 2 CFR §200.331 and 2 CFR §200.332 of the Uniform Guidance. The Organization has prioritized the completion and distribution of the updated financial policies and procedures by December 31, 2024.

Finding 2022-006 – Subaward Monitoring In response to the finding, GEM enhances subaward monitoring by instituting the following. GEM will establish written documentation to ensure appropriate oversight of sub-awardee compliance with NSF program responsibilities. Anticipated date of completion: We received the "No cost extension" and this was completed by September 30, 2023. Written documentation instituted that outlines specific actions and timeline of deliverables expected of sub-awardee as well as corrective actions if sub-awardee is not in compliance with responsibilities. Responsible party: Dr. Marcus Huggans Principal Investigator

ACL Centers for Independent Living – Assistance Listing No. 93.435 Type of Finding: Subrecipient Monitoring/Procurement • Material Weakness in Internal Control over Compliance • Material Noncompliance (Modified Opinion) Criteria or specific requirement: Per 2 CFR Part 200.331, a pass-through entity must make case-by-case determinations whether each agreement it makes for the disbursement of Federal program funds casts the party receiving the funds in the role of a subrecipient or a subcontractor. If a subrecipient has been identified, per 2 CFR Part 200, Subpart F, pass through entities must notify subrecipients that they are receiving Federal funds as a subrecipient and must therefore comply with federal statutes, regulations, and the terms and conditions of the award. Additionally, pass through entities must keep documentation of monitoring the subaward. The pass-through entity must have a control process in place to ensure it is in compliance with federal requirements related to subrecipient monitoring. If a subcontractor has been identified (and payment is above the micro-purchase threshold), per 2 CFR Part 200, Subpart D, the entity must have and use documented procurement procedures such as drafting a procurement policy, obtaining qualified bids, performing cost analyses and justifying reason for final selection. Condition: While there existed sophisticated procedures for reviewing, approving and monitoring applicants, they did not meet all of the Federal requirements for either those of subrecipients or subcontractors. Questioned costs: $62,857 In known questioned costs. Context: Upon receipt of the Federal ACL CARES ACT grants, the instructions were to use and disseminate the funds within the community for the purposes of supporting individuals with disabilities who were impacted by COVID and creating professional relationships in further support of individuals with disabilities. DEC was not aware of the Federal Uniform Guidance guidelines requiring DEC to make the determination of whether the vendors meet the characteristics of a subrecipient or a subcontractor and therefore did not follow the required procedures. This is an isolated instance due to the specific nature of the CARES ACT funds as DEC is not able to engage in these activities with other Federal grants. Cause: DEC did not designate these vendors as either subrecipients or subcontractors and therefore did not follow the Federal Uniform Guidance guidelines. Effect: Pass-through entities, subcontractors and/or subrecipients could be out of compliance and misusing Federal funds. Repeat Finding: No Recommendation: CLA recommends DEC review the Uniform Guidance in relation to subrecipients and subcontractors, and for each vendor under contract, make a clear determination of which type of contract they fall under. Contracts should be drafted in conformity with either subrecipients or subcontracts (as directed by the Uniform Guidance). Views of responsible officials: There is no disagreement with the audit finding. Action taken in response to finding: DEC partnered with other organizations on shortterm projects to reach populations of individuals with disabilities who have intersecting identities. Due to vague instructions on using the funds, we were unaware of the need to define funding recipients as either subrecipients or subcontractors. DEC verified the recipient’s WA state business licenses and performed monitoring for each project. These projects were part of DEC’s plan to spend one-time CARES ACT grants. DEC is not authorized to perform activities of this type with any of our other Federal grants. Name(s) of the contact person(s) responsible for corrective action: Kimberly Meck, Executive Director Planned completion date for corrective action plan: If such an opportunity becomes available in the future, DEC will ensure it will follow appropriate Federal regulations for subrecipients and/or subcontractors as required.

2022-006 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, 2023. Name of Responsible Person: Priscilla A Lopez, ICWDB Director Implementation Date: December 31, 2023

Finding 2022-004 – Uniform Guidance Subrecipient Monitoring – Significant Deficiency/Non-Compliance Corrective Action: The County has met with Children & Youth to discuss in detail the process of monitoring Title IV-E activities. As a result of such, a formalized plan was implemented including a Sub-Recipient Monitoring Agreement for FY 2022-2023. Responsible for Implementing Corrective Action: Budget & Finance, Purchasing Joinder Board

Management is consiering its options for further appeals to the department of Labor for review. Management will work to ensure proper policies and procedures are established and followed by December 31, 2024