Corrective Action Plans

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)

Finding Number: 2023-004 Finding Name: Failure to Establish Subrecipient Monitoring Procedures Finding Condition(s): The Illinois Department of Human Services (IDHS) did not perform a risk assessment or subrecipient monitoring procedures for the subrecipient of the COVID-19 – Homeowner Assistance Fund (HAF) program. Name of Contact Person(s): Joseph Wellbaum, Chief Financial Officer – Illinois Department of Human Services Corrective Action(s): On September 10, 2024, the IDHS completed a fiscal and administrative review of the Illinois Housing Development Authority. Additionally, on March 5, 2024, the IDHS will complete a thorough programmatic review of the HAF program. Proposed Completion Date: September 10, 2024 – Completed

Finding Number: 2023-002 Finding Name: Inadequate Monitoring of Subrecipient Single Audit Reviews Finding Condition(s): The State of Illinois did not establish adequate controls to monitor the completion and documentation of the single audit reports reviews for its subrecipients of the Special Supplemental Nutrition Program for Women, Infants, and Children (WIC), Child and Adult Care Food Program (CACFP), Crime Victims Assistance Program (CVA), WIOA Cluster (WIOA), Highway and Planning Construction (Highway), Emergency Rental Assistance Program (ERAP), Homeowner Assistance Fund Program (HAF), Coronavirus State and Local Fiscal Recovery Funds (SLFRF), Twenty-First Century Community Learning Centers (Twenty-First), Title I Grants to Local Education Agencies (Title I), Supporting Effective Instruction State Grants (SEISG), Education Stabilization Funds (ESF), Epidemiology and Laboratory Capacity for Infectious Diseases (ELC), Temporary Assistance for Needy Families Cluster (TANF), Child Support Enforcement (CSE), Low-Income Home Energy Assistance Program (LIHEAP), CCDF Cluster (CCDF), Social Services Block Grant (SSBG), and Block Grants for Prevention and Treatment of Substance Abuse (SAPT) in the State's Grant Accountability and Transparency Act (GATA) Audit Report Review Management System (ARRMS). Name of Contact Person(s): Keyria Rodgers, Grant Accountability and Transparency Unit Director – Illinois Governor’s Office of Management and Budget Corrective Action(s): The Grant Accountability and Transparency Unit (GATU) provides a centralized, uniform process and a system which State grant-making agencies are required to adhere to throughout the life cycle of the grant. The Illinois Governor’s Office of Management and Budget (GOMB) will develop and implement monitoring procedures to ensure the system is updated by agencies and accurate as to the completeness of the agencies’ report reviews, letter issuances, and desk reviews. Proposed Completion Date: December 31, 2025

Finding 2023-041 Program Information Program Name: Child Support Enforcement CFDA Number: 93.563 Summary of Finding Subrecipient Monitoring Significant Deficiency in Internal Control over Compliance Agency Response Agency agrees with this finding. Corrective Action Plan DSS contracts staff will formally communicate to the Child Support Enforcement (CSEP) Chief the annual requirement to update the Subrecipient Federal Award Funding attachment with the current FAIN and Federal Grant Award date. A structured follow-up process will be implemented to confirm timely completion of the updated template and distribution to both the Subrecipient and DSS contracts staff for official records. These procedures will ensure that all subawards consistently include the required elements. Contact Person(s) Responsible Karen Stoycoff, Social Services Program Specialist Phone: 775-684-7436 Email: kstoycoff@dss.nv.gov Anticipated Completion Date September 30th, 2025.

Finding Number 2023-002 Contact Person(s): Brianna Mariani – BriannaMariani@housinghope.org Kathryn Opina - KathrynOpina@housinghope.org Explanation and specific reasons for disagreement with the audit finding or that corrective action is not required (if applicable): N/A Corrective action planned: This was the first and only grant Housing Hope has administered that required subrecipient monitoring. The grant has since ended and the organization does not anticipate entering any future agreements that would require subrecipient monitoring. To ensure compliance should such an agreement arise again, Housing Hope will adopt a Subrecipient Monitoring Policy. This policy will outline the criteria for identifying subrecipient relationships and establish a standardized process for monitoring subrecipients, if any are engaged in the future. Anticipated completion date: The Subrecipient Monitoring Policy will be adopted by October 2025 Board meeting.

2023-002 Compliance and Internal Controls over Subrecipient Fiscal Monitoring (Significant Deficiency) Corrective Action: In accordance with 2 CFR Section 200.332, The Resource Group as the pass-through entity will ensure subrecipient fiscal monitoring is completed in 2024 to ensure compliance with federal and state requirements. The Finance Director is responsible for oversight and administration of fiscal monitoring. Fiscal monitoring will be conducted at least annually in accordance with HRSA Monitoring Standards 45 CFR 74.51 and 45 CFR 75.352. As a pass-through entity, fiscal monitoring will include at minimum reviews of financial performance and compliance with federal and state statues, regulations and terms and conditions. The process will include desktop/remote verification of applicable financial policy and procedures and an onsite review. A standardized monitoring tool will be used to evaluate financial compliance. The fiscal monitoring observations will result in a monitoring report, disseminated to the subrecipient within 60 days of the onsite review. Progress to date: 1. To support the financial monitoring efforts, technical assistance was received on February 5-7, 2024, from the DSHS Fiscal Support and Oversight Department. The primary objective of the visit was to discuss financial monitoring requirements as it applies to state and federal regulations, statues and terms and conditions. The standardized monitoring tool was also evaluated for compliance. 2. The Finance Director developed and implemented a comprehensive fiscal monitoring schedule for calendar year 2024. In alignment with strengthened oversight practices, onsite fiscal reviews of subrecipients commenced in February 2024. As part of the enhanced monitoring approach, the testing period for subrecipient fiscal reviews was expanded beyond the standard scope to include transactions and activities from both Fiscal Year 2022 and Fiscal Year 2023. 3. As of September 2024, the Finance Director completed 100% of fiscal monitoring visits. a. Support Documentation: to establish additional guidelines for fiscal monitoring, the Fiscal Monitoring Policy was drafted and approved by the Board on November 18, 2024. 3 Responsible Party: Finance Director, Garland Thompson Date Complete: November 18, 2024

The Board of County Commissioners, with the cooperation and participation of all elected officials, reviews, develops and implements policies and procedures to create a strong internal control environment. The Board of County Commissioners will work with all elected officials, the third-party administrator, and federal, state and local partners to develop policies, procedures, and internal controls designed to accurately track grants, including the application process, verification, oversight, and reporting of grant requirements. To assist in this process, the Board of County Commissioners engaged a third-party administrator to oversee the grant process, including application, eligibility, review, requirements, contracting, recipient tracking and oversight, and documentation and reporting. The Board of County Commissioners will work with the third-party administrator to ensure proper grant administration.

Planned Corrective Action: Update Financial Policies and Procedures to reflect language surrounding areas of deficiency, specifically listed in 2 CFR 200.332(b). New subrecipients awards will include: subrecipient’s unique entity identifier, federal award identification number, federal award date, assistance listing title, assistance listing number, dollar amount available under each federal award and assistance listing number at the time of disbursement, and approved indirect cost rate. Planned Implementation Date of Corrective Action: 7/14/25, will be included in Financial Policies revisions in December 2025. Person Responsible for Corrective Action: Director of Finance

Corrective Action Plan FINDING 2023-002 - Subrecipient Monitoring (Partially Repeated from Prior Year Findings 22-002, 21-003, 20-004, 19-005, 18-004, and 17-003) CONDITION: The Regional Office of Education #47’s internal controls over subrecipient monitoring do not include timely and adequate risk assessment procedures. Furthermore, the Regional Office of Education #47 did not properly monitor subrecipients in accordance with the Uniform Guidance standards. During audit testing procedures it was determined that ROE #47: McKinney Education for Homeless Children – for three (3) of three (3) subrecipients tested, ROE #47: • Did not evaluate the risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward. • Did not conduct subrecipient monitoring procedures during the year ended June 30, 2023. • Did not determine whether the subrecipient met the 2 CFR 200 Subpart F Audit requirements criteria for a single audit. COVID-19 ARP - McKinney Education for Homeless Children – for three (3) of three (3) subrecipients tested, ROE #47: • Did not identify the subaward and applicable requirements in the agreements. • Did not evaluate the risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward. • Did not conduct subrecipient monitoring procedures during the year ended June 30, 2023. • Did not determine whether the subrecipient met the 2 CFR 200 Subpart F Audit requirements criteria for a single audit. PLAN: Moving forward, The Regional Office will formally identify the subaward and applicable requirements in our agreements. We will conduct subrecipient monitoring procedures. We will determine if the subrecipient met the requirement criteria of 2 CFR 200 Subpart F Audit requirements for a single audit. ANTICIPATED DATE OF COMPLETION: Fiscal Year 2025 CONTACT PERSON: Mr. Chris Tennyson, Regional Superintendent for Lee, Ogle, and Whiteside Counties.

VIEWS OF RESPONSIBLE OFFICIALS ADSEF will provide training to personnel on the requirements and regulations related to subrecipient monitoring. Recommendation to management will be implemented, internal controls and compliance measures that allow for the identification, reporting, and monitoring of subrecipient activities Prevention Activities/TANF. IMPLEMENTATION DATE During Fiscal Year 2025-2026. RESPONSIBLE PERSON Administration for Socioeconomic Development of the Family (ADSEF, by its Spanish Acronym)

Finding 2023-001 Information on the federal program: Federal Agency: Department of the Treasury Pass-Through Entity: N/A – Direct Grant Federal Program: Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) Assistance Listing Number: 21.027 Compliance Requirement: Subrecipient Monitoring Audit Findings: Material Weakness, Noncompliance Condition: The City of Bloomington was unable to identify subrecipients of CSLFRF funding for the purposes of financial reporting and compliance with requirements under 2 CFR 200.332. The City could not distinguish between a subrecipient and a general vendor. Management misreported subrecipient activity on the SEFA, failed to include required contractual language for subrecipient awards in executed agreements, and did not perform monitoring procedures over the subrecipients management identified during audit testing procedures. Context: The 10 subrecipients represent approximately 18%, $1,025,070, of the total award expenditures of $5,590,828, in 2023. The condition reported was prevalent for each subrecipient participating in the award. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and will draft a policy and develop an internal controls process regarding subawards and the monitoring of subrecipients to ensure the compliance requirements are met. Responsible party and timeline for completion: The City’s Controller will be responsible for overseeing the implementation of the corrective action plan, which will be implemented starting during calendar year 2025.