Corrective Action Plans

DRI – Agrees with the finding. • Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place: DRI will implement controls that require the documentation of risk assessment with respect to the subaward process. Depending on the results of the risk assessment, monitoring procedures will be designed to ensure compliance. With the current limited resources available in DRI’s Financial Services team, a position will be recruited as soon as possible with an anticipated start date in early spring 2025. It is expected that this position will support the full development and implementation of new procedures once on board. • How compliance and performance will be measured and documented for future audit, management and performance review: Documentation will be maintained in DRI’s pre-award system or in the accounting system, as appropriate to ensure compliance. • Who will be responsible and may be held accountable in the future if repeat or similar observations are noted: The Chief Financial Officer may be held accountable in the future if repeat or similar observations are noted. NSU – Agrees with the finding. • Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place: Nevada State University (NSU) has developed procedures to ensure the necessary reviews of all subrecipients’ transactions including risk assessment and determination, and financial statement review. Procedures will include the following: documentation of subrecipient risk assessment and risk-level determination and documentation of monitoring activities at regular intervals to ensure subrecipients are complying and making progress on performance objectives. NSU will proactively request subrecipients’ annual financial statements and audit reports. Upon review, NSU may modify monitoring as needed. • How compliance and performance will be measured and documented for future audit, management and performance review: NSU will perform risk assessment via a checklist prior to issuance of subaward. Subrecipient technical/progress reports will be requested periodically to monitor activities and progress. NSU will proactively request subrecipients’ annual financial statements and audit reports. Upon review, NSU will modify monitoring as may be needed. All reviews will be documented and maintained in the subrecipients’ files. • Who will be responsible and may be held accountable in the future if repeat or similar observations are noted: The Director of Grants Award Services will be responsible with additional oversight by the Associate Vice President of Fiscal Services. UNLV – Agrees with the finding. • Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place: The UNLV Office of Sponsored Programs will implement required controls for subrecipient risk assessment immediately. Additionally, UNLV OSP will enhance our current tools using the guidance of the Federal Demonstration Partnership for national standardized forms for subrecipient monitoring. Policies and procedures will be in place by the end of the calendar year 2024, and monitoring will be performed annually. • How compliance and performance will be measured and documented for future audit, management and performance review: Materials–to include the risk assessment, degree of sub monitoring required, and training for all OSP personnel–will be completed within 60 days. The risk assessment will be attached to each fully executed subrecipient agreement and, as applicable, annual risk assessments will be completed. Policies and procedures are being developed and are expected to be in place by the end of the calendar year 2024. • Who will be responsible and may be held accountable in the future if repeat or similar observations are noted: The UNLV Office of Sponsored Programs Executive Director is accountable for exercising oversight and responsibility. UNR – Agrees with the finding. • Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place: All required subaward documents will be retained in a centralized funding database for easy access and compliance tracking. Subaward specialists will review subrecipient audit reports at least once a year, rather than only when processing amendments. • How compliance and performance will be measured and documented for future audit, management and performance review: All required subaward documents, including subrecipient letters of certification, will be uploaded to Workday and maintained in a centralized funding database. • Who will be responsible and may be held accountable in the future if repeat or similar observations are noted: The Associate Director of PreAward is responsible for remediation of this finding. Name of contact person responsible for corrective action plan: Rhett R. Vertrees, Assistant Chief Financial Officer 2601 Enterprise Road, Reno NV 89512-1666 Phone: (775)784-3409, Fax: (775)784-1127 Email: rvertrees@nshe.nevada.edu

UNR – Agrees with the finding. • Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place: Assigned staff will document all advance payments in the Notes section of the Award in Workday. Federal funds reimbursed in advance will be separated into an interest-bearing account. Additionally, staff will compare subrecipient expenses with advance payments on a monthly basis and follow up with the subrecipient as needed to ensure timely use of the funds. • How compliance and performance will be measured and documented for future audit, management and performance review: Staff will document advance payments in Workday's Notes section. The use of an interest-bearing account for advance funds will also be tracked. • Who will be responsible and may be held accountable in the future if repeat or similar observations are noted: The Associate Director of Post Award is responsible for remediation of this finding. Name of contact person responsible for corrective action plan: Rhett R. Vertrees, Assistant Chief Financial Officer 2601 Enterprise Road, Reno NV 89512-1666 Phone: (775)784-3409, Fax: (775)784-1127 Email: rvertrees@nshe.nevada.edu

Name of Contact Person: Laura Leach, Director of Finance and Administration Corrective Action: The Commission will review all subawards for subrecipients and ensure that FFATA reporting is completed in a timely manner for subawards subject to the requirements. The Commission will add a clause in our Subawards stating this requirement. Proposed Completion Date: December 31, 2024

Response: Management agrees with the finding and will reevaluate internal processes and procedures. This error highlights the need for better oversight and timely communication between our organization and its subrecipients to ensure accurate reporting. The root cause of this issue was insufficient monitoring and communication between the subrecipient and our grants management team. To address this, we are implementing several corrective actions. These include establishing a stricter communication schedule with subrecipients to ensure timely submission of invoices and expense reports and strengthening our internal monitoring procedures by tracking submission deadlines more closely. Additionally, we will improve guidance and capacity-building efforts for subrecipients to ensure they understand reporting requirements, and we will conduct quarterly reviews of subrecipient expenses to proactively identify and mitigate reporting delays. Contact person responsible for corrective action: Lynne Duong, Post Award & Compliance Manager Anticipated completion date: December 31, 2024

Action taken in response to finding: We have 26 active awards that would be non-R&D. Grants and Contracts Accounting (GCA) is currently reviewing each to verify if all had check boxes checked as R&D on Attachment 2 of the Federal Awards Terms and Conditions template of the FDP Cost Reimbursement Subaward. Once we have the impacted population, GCA will issue a modification for those to draw attention to the error. In addition, GCA will ensure internal procedures are updated to review this field and verify proper identification prior to subaward execution. Anticipated Completion Date: September 30, 2024 Person Responsible: Tracy Walters, Director of Grants and Contracts Contact/Responsible Party: Tracy Walters, Director of Grants and Contracts Contact Information: trwalte@clemson.edu

Corrective Action Plan: Management will review the required procedures for pass-through entities as listed in 2 CFR 200.332 and implement the procedures accordingly. This will include documented risk assessment and monitoring procedures for all subrecipient of federal awards.

The County will implement a new policy to ensure all subrecipients that are given federal funds of $25,000 or more are properly monitored.

Views of Responsible Officials and Planned Corrective Action We will give instructions to the accounting staff in charge of the preparation of the quarterly progress reports of the Program, in order to comply with the FEMA reporting requirements. Responsible Official: Mrs. Irma M. Vargas Aguirre, Finance and Budget Director Implementation Date: December 31, 2025

Trailhead is establishing a new Contract and Compliance Coordinator role to oversee contract compliance processes and to ensure that Trailhead’s policy on subrecipient monitoring is followed. This role will be responsible for ensuring that compliance requirements are integrated at the outset of each grant. This role will be responsible for internal monitoring and auditing. This role will ensure that all grant kick-off meetings follow a standard procedure and include: 1) A clear understanding of federal requirements for all involved fiscal, program, and compliance staff 2) Delegated assignments to program staff for implementing and documenting: a) Suspension and debarment prior to contracting with subrecipients b) Subrecipient vs contractor determinations c) Evaluation of each subrecipient’s risk of noncompliance i) Establish the appropriate subrecipient monitoring level based on risk. This compliance role will have the authority to ensure the procedures are completed by the assigned staff. Evidence of the completed procedure must be documented and saved in a newly created contracts database. This database will be a centralized storage that will be reviewed during internal compliance checks to ensure all required steps have been completed and documented. These documents and associated grant and contract documents will be part of an official repository.

Finding Number 2023-006 Subject Heading (Financial) or AL no. and program name (Federal) 93.658 – Foster Care Planned Corrective Action The risk assessment cannot be completed until we have actual data and performance needed to make that assessment. Subrecipient risk assessments are completed at the beginning of the fiscal year based on prior year data and performance. The changes to all of the subrecipient agreements identified have been in process and were completed during State fiscal years 2024 and 2025. Additional findings are expected for the 2024 audit since the audit timing is currently almost two years in arrears. Anticipated Completion Date February 2025 Responsible Contact Person Kevin Haddock

Finding Number 2023-212 Subject Heading (Financial) or AL no. and program name (Federal) 93.323: Epidemiology and Laboratory Capacity for Infectious Diseases Planned Corrective Action The Oklahoma State Department of Education (OSDE) is committed to strengthening its subgrant management processes in response to the audit findings. To address the identified issues, OSDE will implement a more robust and clearly defined application procedure for Local Education Agencies (LEAs) applying for subgrants. This will include standardized guidance and documentation requirements to ensure consistency and transparency. In addition, OSDE will establish comprehensive procedures to conduct risk assessments of individual LEAs prior to awarding subgrants. These procedures will detail specific steps for identifying and addressing noncompliance, ensuring that higher-risk LEAs receive the appropriate level of oversight and support. To further improve the integrity of the reimbursement process, OSDE will provide regular training sessions and technical assistance to LEAs. These sessions will emphasize the importance of submitting complete and accurate documentation to support reimbursement claims. OSDE will also collaborate with our vendor, MTW, to ensure that LEAs can efficiently upload required documentation through the Grants Management System (GMS). Finally, OSDE will conduct targeted training for internal reviewers to ensure they are well-versed in identifying allowable versus unallowable expenditures and understand the documentation requirements associated with each type of expense. This will help promote consistency and compliance in the review and approval of claims. Anticipated Completion Date 6/30/2025 Responsible Contact Person Shawn Richmond, Comptroller

Finding Number 2023-053 Subject Heading (Financial) or AL no. and program name (Federal) TITLE I, PART A – GRANTS TO LOCAL EDUCATIONAL AGENCIES AL #84.010 Planned Corrective Action The Oklahoma State Department of Education (OSDE) will revise the risk assessment procedures to include a second review of data sourced for the risk assessment. Assigning a second reviewer will reduce the likelihood of errors and will confirm the risk assessment scoring is accurate. Anticipated Completion Date July-2025 Responsible Contact Person Tammy Smith

Finding Number 2023-046 Subject Heading (Financial) or AL no. and program name (Federal) AL #84.425 – EDUCATION STABILIZATION FUND (ESF - AL #84.425D; 84.425R; 84.425V) Planned Corrective Action OSDE does not agree with the finding regarding $802,414.82 of claims for a non-public school that used unallowable proportionality data in their ARP EANS application. The Office of Title Services (OTS) used the limited federal guidance available at the time to manage the Emergency Assistance to Nonpublic Schools (EANS) funds. Due to limited guidance from the US Department of Education (USDE), OSDE allocated ARP EANS funding consistent with CRRSA EANS. After funds were allocated, USDE provided guidance on the allocation of ARP EANS funding using actual low income poverty data. As a result, OSDE’s reviewed the allocation of ARP EANS funding and determine that certain expenditures totaling $802,414 were ineligible under ARP EANS but eligible under CRSA EANS. In the fall of 2024, the Office of Title Services (OTS) provided documentation and adjusting journal entries to reallocate ineligible funds from ARP EANS to unspent CRSA EANS. This adjustment transferred the unallowable expenditures originally charged to ARP EANS to unspent funds under CRRSA EANS. All funds were obligated during the applicable period of availability. The United States Department of Education accepted evidence of this corrective action in an email received by OTS staff on February 5, 2025. A copy of this email was sent to the Oklahoma State Auditor and Inspector’s Office on Monday, May 19th, 2025. As a result, these expenditures were allowable and did not result in questioned costs. OSDE agrees with that low-income data used for EANS allocation was different than the low-income data used for Title I allocations. OSDE used Low-income counts based upon data provided by nonpublic schools. The Office of Title Services (OTS) used the limited federal guidance available at the time to manage the Emergency Assistance to Nonpublic Schools (EANS) funds. OSDE is not aware of expenditures that lacked supporting documentation. OSDE agrees with the finding on a duplicate Payment. Duplicate payments were erroneously made to Complete Book and Media Supply LLC. OSDE is working to resolve this matter. EANS Proportionality In the fall of 2024, the Office of Title Services (OTS) provided documentation and adjusting journal entries to re-allocate ineligible funds from ARP EANS to unspent CRSA EANS. This adjustment transferred the unallowable expenditures originally charged to ARP EANS to unspent funds under CRRSA EANS. All funds were obligated during the applicable period of availability. The United States Department of Education accepted evidence of this corrective action in an email received by OTS staff on February 5, 2025. A copy of this email was sent to the Oklahoma State Auditor and Inspector’s Office on Monday, May 19th, 2025. As a result, these expenditures were allowable and did not result in questioned costs. EANS Low-Income If low-income data for nonpublic school participants is necessary to determine eligibility, then OTS will create a written procedure to collect and verify the data. EANS Procurement To avoid duplicate payments only the Senior Director of Federal Programs will have approval on any invoice submitted for payment. Invoices will be tracked and documented by the Office of Title Services. In the future should it be necessary to allocate to non-LEA entities, the Office of Title Services will create written procedures to ensure any necessary supporting documentation be submitted prior to approving payment on an invoice. Anticipated Completion Date Responsible Contact Person Tammy Smith

Finding Number 2023-014 Subject Heading (Financial) or AL no. and program name (Federal) ALN: 21.027 Federal Program name: Coronavirus State And Local Fiscal Recovery Funds (CSLFRF) Planned Corrective Action Management Response The Oklahoma Office of Management and Enterprise Services – Grants Management Office (OMES-GMO) partially agrees with the finding. OMES-GMO acknowledges the importance of robust subrecipient monitoring in accordance with 2 CFR § 200.332(d) and (f), which includes ensuring that all subrecipients expending $750,000 or more in federal funds obtain a Single Audit, as required by 2 CFR § 200.501. OMES-GMO concurs with the identified inconsistency with agencies notifying subrecipients of the single audit threshold amount, despite having deficient tracking of the total of federal expenditures across all federal programs that an entity was engaged in. OMES-GMO holds a good faith belief that this deficiency on behalf of the agencies was the result of a lack of clarity; and ergo, a misinterpretation between individual program thresholds and aggregate thresholds across all programs in a fiscal year. Error may further be attributed to the limitations in tracking mechanisms, rather than a lack of awareness or intent to comply. OMES-GMO has followed up with each of the agencies named in the finding and has verified that, although subrecipient monitoring was in place, additional controls are needed to ensure accurate tracking of total federal expenditures and timely collection of required audits. Listed below are the corrective actions that have or will be implemented. Corrective Actions • Standardized Monitoring Procedures: OMES-GMO will issue updated subrecipient monitoring guidance to all state agencies administering federal funds. This guidance will include clear expectations for tracking total federal expenditures, identifying subrecipients approaching the Single Audit threshold, and documenting audit compliance. • Improved Tracking Mechanisms: OMES-GMO will work with agencies to assess their internal systems for tracking cumulative federal expenditures across funding sources, ensuring timely identification of entities requiring a Single Audit. • Ongoing Support and Oversight: OMES-GMO will incorporate further Single Audit compliance into established review processes. Agency-Specific Actions • Agency 619: Single Audits through 2022 have been obtained and archived. Requests for FY2023 audits have been issued, and responses are currently being collected. FY2024 audits will be requested no later than September 30, 2025, to allow sufficient time for completion and submission. • Agency 340: The Finance Division will begin tracking all subrecipient expenditures, including secondary recipients. Verification of Single Audit compliance will be incorporated into the agency’s annual site visits. • Agency 830: A process is already in place through the Office of Inspector General (OIG) to identify subrecipients exceeding the $750,000 threshold. All subrecipient contracts include language requiring submission of a Single Audit if the threshold is met. These audits are collected, reviewed, and stored accordingly. These corrective actions reflect OMES-GMO’s and the respective agencies’ commitment to strengthening internal controls, ensuring proper oversight of federal funds, and maintaining compliance with all applicable federal requirements. Anticipated Completion Date 6/30/2025 Responsible Contact Person OMES: Parker Wise 619: Sara Librandi, Kami Fullingim 340: Diane Brown, Danielle Smith, Tracey Douglas 830: Jaretta Murphy, Lindsey Kanaly, Danielle Durkee, Katey Campbell

Finding Number 2023-026 Subject Heading (Financial) or AL no. and program name (Federal) ALN: 21.019 Federal Program name: Emergency Rental Assistance Program (ERA) Planned Corrective Action Oklahoma Office of Management and Enterprise Services (OMES) acknowledges the Oklahoma State Auditor and Inspector Office’s (SAI) findings that OMES did not implement the proper internal controls and oversight of the ERA Program during FY2023. However, OMES has taken steps to correct these findings and follow the recommendations set forth by SAI. Beginning with FY2025, OMES has taken the following measures: • Oversight and management of the ERA program has been transferred to the OMES Grant Management Office (OMES-GMO) which has staff with several years of grant experience. OMES-GMO has recently hired additional staff, and the two staff members dedicated to the management of the ERA program have 20+ years of combined federal grant specific experience. • To ensure that the subrecipient agreement includes all the required terms under the ERA Program and that the agreement does not expire, OMES-GMO and the Communities of Foundation of Oklahoma (CFO) have recently executed a Subrecipient Grant Agreement Amendment that details the responsibilities of OMES to monitor CFO and the duties and processes that CFO must follow in regard to ERA Program, including detailed cash management policies. See Attached – Grant Agreement Amendment. (See page 15 of attached Grant Agreement.) • OMES-GMO required the return of the remaining ERA2 Program funds from CFO to ensure proper oversight and review of ERA expenditures is performed. • OMES-GMO has a multi-level system of internal controls for grant management and oversight that includes routine monitoring, desk review, and site visits for all projects and associated project/administrative expenditures to ensure allowability, accuracy, and assist in the detection of fraud. For example, OMES-GMO’s process for disbursing funds to a subrecipient requires a written request from the subrecipient with supporting documentation, then OMES-GMO assigns a staff lead and secondary grant analyst to perform a primary and secondary review for compliance and to require additional supporting documentation if needed to approve the request. Once those reviews are completed and approved by the OMES-GMO staff, the Director of the OMESGMO must approve the request before it is sent to the OMES Finance Division, who will then verify the calculated amount(s) before completing the disbursement to the subrecipient. These internal controls and policies have been implemented for the management and oversight of the ERA Program and provide a multi-layer review that will prevent fraud and risk factors applicable to the ERA program. Additionally, the OMES- GMO staff assigned to the ERA program have the training and knowledge to ensure compliance with the Federal grant requirements. • Risk assessments have been obtained and are attached. • Depending on the level of risk, OMES-GMO conducts monthly, bi-weekly or weekly meetings with each subrecipient to monitor the progress of projects and address any issues or changes that might impact the project. For the ERA Program, OMES-GMO conducts biweekly monitoring meetings with CFO and is currently reviewing documentation provided by CFO to ensure all current ERA projects are eligible under the ERA guidelines and that CFO is exercising the proper oversight over their subrecipients. • OMES-GMO will continue with their current ERA monitoring steps and internal controls and will work with CFO to ensure ERA program funds are spent in accordance with ERA program guidelines and state and federal regulations. Anticipated Completion Date Ongoing throughout the life of the grant Responsible Contact Person Brandy Manek

Finding Number 2023-096 Subject Heading (Financial) or AL no. and program name (Federal) ALN: 21.019 Federal Program name: Coronavirus Relief Fund (CRF) Planned Corrective Action The State agrees with this finding. Within OMES, oversight and management of Federal grants has been transferred to the OMES Grant Management Office (OMES-GMO) which is staffed with individuals with several years of grant experience. OMES-GMO has a multi-level system of internal controls for grant management and oversight that includes routine monitoring, desk review, and site visits for all projects and associated project/administrative expenditures to ensure allowability, accuracy, and assist in the detection of fraud. Finally, OMES Finance has developed processes which provide for a more thorough coding of expenditures and proper review of expenditures when reporting on their GAAP Z. The State disagrees with the finding. The State had two Grant Award Notifications in place with the Boys and Girls Club which reflects the monies awarded to be used on the capital improvements and Club on the Go Mobile Clubhouses. This indicates the funds were obligated during the covered period. Per the email from the Keri for Jill Geiger Consulting, no signatures on the GANs were required and the Uniform Guidance does not require the GAN to be signed. Anticipated Completion Date September 2022 Responsible Contact Person Brandy Manek

Finding Number 2023-013 Subject Heading (Financial) or AL no. and program name (Federal) 20.509 - Formula Grants for Rural Areas Planned Corrective Action We concur with the auditor’s recommendation. OMPT—We will develop and implement risk assessments as part of our sub-recipient monitoring process and revise existing procedures related to single audits. Lastly, we will meet with Internal Audit, formerly CWO, to establish a process to ensure audit reviews are documented and received. Internal Audit - Unfortunately the issues that occurred in last year’s audit, also effected the transactions selected in this year’s audit. It should be noted that 6 of the 11 missing files were provided to SA&I, however most of those audits were not performed in a timely manner. After the finding last year many changes were implemented in the Audit Office, including a change in management of the Grants and Contract Auditing area. A Smartsheet application is in now in use that allows OMPT to check on the status of audits at any time. We also have done extensive cross training on these single audit reviews and we are currently performing these audits in a timely manner as they come in. Anticipated Completion Date 7/1/2025 Responsible Contact Person OMPT - Eric Rose/Bobby Parkinson Anne Antonelli, Internal Audit – Holly Lowe

Finding Number: 2023-045 Finding Name: Inadequate Monitoring of 21st Century Subrecipients Finding Condition(s): The Illinois State Board of Education (ISBE) did not adequately monitor and document program monitoring procedures performed over subrecipients of the 21st Century Community Learning Centers (21st Century) program. Additionally, ISBE did not follow its subrecipient monitoring procedures during the year ended June 30, 2023. Finally, ISBE’s controls for monitoring are not designed at an appropriate level of precision to ensure monitoring of subrecipients is completed as required. Name of Contact Person(s): Ryan Levin, Supervisor; 21st Century Community Learning Centers (CCLC) State Education Agency Coordinator – Illinois State Board of Education, Wellness and Student Care Management Department Corrective Action(s): To ensure that 21st Century Community Learning Centers (21st CCLC) subgrantees’ progress and performance are monitored in accordance with 2 CFR 200.331(d), 2 CFR 200.331(b) and 2 CFR 200.303, Wellness and Student Care Management Department and the 21st CCLC team will develop processes and structures to facilitate the procedures, protocols, and efficacy of subgrantee monitoring. Components of this work will include, but not be limited to: • Evaluating and revising the program’s subgrantee risk analysis procedures and tools to ensure that they are relevant and accurately reflect the items/actions that suggest higher levels of subgrantee risk (2 CFR 200.331(b)). • Reviewing and revising the procedures and/or documentation that is collected for all three tiers of subgrantee monitoring to ensure that all processes are relevant; are not simply perfunctory; ensure compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that the subaward performance goals are achieved (2 CFR 200.331(d)). • Establishing and implementing specific processes and protocols to ensure that all components of subgrantee monitoring are timely, that management reviews and provides approval for key components of the process, and that accurate and complete documentation is produced and maintained (2 CFR 200.303). Proposed Completion Date: December 31, 2025

Finding Number: 2023-035 Finding Name: Inadequate Fiscal Monitoring of Subrecipients Finding Condition(s): The Illinois Criminal Justice Information Authority (ICJIA) did not follow its established policies and procedures for monitoring subrecipients of the Crime Victim Assistance (CVA) program. Name of Contact Person(s): Hemant Modi, Chief Fiscal Officer – Illinois Criminal Justice Information Authority, Office of Fiscal Management Corrective Action(s): ICJIA will update its risk assessment policy to provide more clarity on the monitoring procedures, including the additional factors used to prioritize audits, performed to ensure proper fiscal oversight. Proposed Completion Date: June 30, 2025 – Completed

Finding Number: 2023-034 Finding Name: Inadequate Review of Subrecipient Single Audit Reports Finding Condition(s): The Illinois Criminal Justice Information Authority (ICJIA) did not adequately review single audit reports received from its subrecipients for the Crime Victim Assistance Program (CVA) program on a timely basis. Name of Contact Person(s): • Hemant Modi, Chief Fiscal Officer – Illinois Criminal Justice Information Authority, Office of Fiscal Management • Karen Crawford, Chief Grantee Auditor – Illinois Criminal Justice Information Authority, Office of Fiscal Management Corrective Action(s): By December 31, 2024, ICJIA hired and trained an individual to focus on the State’s Grant Accountability and Transparency Act (GATA) requirements over ICJIA’s reviews of its subrecipients’ single audit reports. Proposed Completion Date: December 31, 2024 – Completed

Finding Number: 2023-033 Finding Name: Failure to Adequately Monitor Subrecipients Finding Condition(s): The Illinois Criminal Justice Information Authority (ICJIA) did not follow its established program monitoring policies and procedures for subrecipients of the Crime Victim Assistance (CVA) program for fiscal year 2023. Name of Contact Person(s): Greg Stevens, Director – Illinois Criminal Justice Information Authority, Federal and State Grants Unit Corrective Action(s): ICJIA will increase its headcount with 20 additional staff members to expand ICJIA’s monitoring capabilities of the Federal and State Grants Unit. Proposed Completion Date: June 30, 2025 – Completed

Finding Number: 2023-030 Finding Name: Failure to Communicate Award Information to Subrecipients Finding Condition(s): The Illinois Department of Commerce and Economic Opportunity (DCEO) did not follow its established policies and procedures for monitoring subrecipients of the Low-Income Home Energy Assistance Program (LIHEAP). Name of Contact Person(s): Ben Moore, Fiscal Operations Manager – Illinois Department of Commerce and Economic Opportunity, Office of Community Assistance Corrective Action(s): There is currently a process in place to enter the correct Federal Award Identification Number (FAIN) from the federal award notice into the DCEO’s e-Grants system, which populates into all grant agreements created and issued for that grant series. To ensure the correct FAIN is entered, the Office of Community Assistance (OCA) added a step in its grant series establishment process to verify that the correct FAIN is entered into e-Grants prior to any grants being issued from that award. Proposed Completion Date: February 25, 2025 – Completed

Finding Number: 2023-018 Finding Name: Inadequate Monitoring of Subrecipients of the CSLFRF and ERA Programs Finding Condition(s): The Illinois Department of Human Services (IDHS) did not obtain and review periodic performance reports for subrecipients of the COVID-19 – Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) and the Emergency Rental Assistance (ERA) and programs. Name of Contact Person(s): Joseph Wellbaum, Chief Financial Officer – Illinois Department of Human Services Corrective Action(s): The IDHS will develop an organized process to ensure the availability of performance monitoring reports to comply with information requests. Proposed Completion Date: July 1, 2025 – Completed

Finding Number: 2023-015 Finding Name: Inadequate Review of Subrecipient Single Audit Reports Finding Condition(s): The Illinois Department of Human Services (IDHS) did not adequately review single audit reports received from its subrecipients for the Special Supplemental Nutrition Program for Women, Infants, and Children (WIC) programs, the Temporary Assistance for Needy Families Cluster (TANF), the CCDF Cluster (CCDF), the Social Services Block Grant (SSBG), and the Block Grants for Prevention and Treatment of Substance Abuse (SAPT) programs on a timely basis. Additionally, the IDHS has not established controls over subrecipient single audit report reviews at an adequate level of precision to ensure single audit reports are received and reviewed timely. Name of Contact Person(s): Brian Bond, Director – Illinois Department of Human Services, Office of Contract Administration Corrective Action(s): The IDHS’ Office of Contract Administration (OCA) staff will meet to coordinate and establish procedures to ensure subrecipient single audit reports are obtained and reviewed within established deadlines. On March 31, 2025, the OCA began to use its IDHS-OCA Procedures for Grantee Extensions of Audit Package Submissions. Proposed Completion Date: June 30, 2025 – Completed

Finding Number: 2023-010 Finding Name: Failure to Follow Established Program Subrecipient Monitoring Procedures Finding Condition(s): The Illinois Department of Human Services (IDHS) did not follow its established program monitoring policies and procedures for subrecipients of the Temporary Assistance for Needy Families (TANF) Cluster, the Childcare Cluster (CCDF), the Social Services Block Grant (SSBG), and the Block Grants for Prevention and Treatment of Substance Abuse (SAPT) programs. More specifically, the IDHS did not perform on-site monitoring reviews of subrecipients in fiscal year 2023 in accordance with IDHS’ planned monitoring schedule and/or could not provide support for the review, did not provide timely notification (within 60 days) of the results of the programmatic on-site reviews, did not complete its quality reviews on a timely basis (within 60 days), did not receive corrective action plans from subrecipients after findings were identified during the reviews, and was unable to provide documentation evidencing monitoring of the quarterly program reports. Name of Contact Person(s): • Elizabth Lusk, Social Service Program Planner – Illinois Department of Human Services, Division of Family and Community Services • Christina Miller, Fund Disbursement Manager – Illinois Department of Human Services, Division of Substance Use, Prevention, and Recovery Corrective Action(s): IDHS - Division of Family and Community Services (FCS) FCS Associate Directors, in conjunction with staff from the Director’s Office, met and reviewed exceptions noted in the fiscal year 2022 single audit to determine any need for updated documentation and communication regarding subrecipient programmatic monitoring. The FCS reviewed the FCS Programmatic Monitoring Guidance Document and made necessary updates. IDHS - Division of Substance Use Prevention and Recovery (SUPR) The SUPR will hire an administrative assistant to assist with compliance monitoring tracking activities to maintain communication about important deadlines. The SUPR will also hire compliance monitors to engage in conducting compliance reviews. Additionally, the SUPR will meet weekly to track monitoring activities to ensure deadlines are met. Finally, the SUPR will review its policy and procedures to assess timelines associated with the monitoring process. Proposed Completion Date: • July 29, 2024 – Completed (FCS) • December 31, 2025 (SUPR)