Corrective Action Plans

State of Missouri Single Audit Corrective Action Plan Year Ended June 30, 2023 State Agency: Office of Administration Audit Finding Number: 2023-010, SLFRF Program Subrecipient Monitoring Name of the contact person responsible for corrective action: Stacy Neal Anticipated completion date for corrective action: September 2024 Recommendation A.: Develop policies and procedures to determine whether recipients of SLFRF program funds are subrecipients or contractors. Work with the state agencies to ensure accurate and documented determinations are prepared for all recipients and modify subrecipient records as needed. OA partially agrees with the auditor’s finding. Corrective action planned is as follows: OA believes there are opportunities to improve the classification of subrecipient vs. contractor to ensure compliance with federal regulations. We concur that OA, as the responsible party, should modify a department determination of subrecipient when there is a conflict with the regulation. Finally, we agree that clear communication on roles and responsibilities of OA vs. departments related to compliance is essential and can be improved. Given this position, we disagree that OA needs to issue procedures that restate the rules the uniform guidance and SLFRF regulations already state. We will continue to have discussions with agencies and ensure compliance with federal regulations. Recommendation B.: Develop a subrecipient monitoring program in accordance with the Uniform Guidance, that including performing risk assessments for each subrecipient for the purposes of determining the appropriate subrecipient monitoring procedures; monitoring for compliance with federal requirements and subaward terms and conditions and ensuring subaward performance goals are achieved; and reviewing subrecipient single audit reports. Ensure tasks delegated to state agencies are adequately communicated and establish procedures to ensure those tasks are appropriately completed. OA agrees with the auditor’s finding. Corrective action planned is as follows: OA approached the SLFRF money to consider all spending (whether to subrecipients or any other payment) as high risk due to the large dollar amount of one-time funding that is subject to rules that have changed over time. We have continued to treat this unique and highly publicized funding as high risk for fraud and exercise due diligence to mitigate that risk. OA agrees however, that our universal determination related to the SLFRF does not meet the specific uniform guidance rules. OA agrees to provide additional communications to departments to ensure agencies understand their responsibilities for sub-recipient monitoring including sub-recipient specific risk assessments and monitoring. Finally, OA will implement random reviews of the sub-recipient monitoring compliance.

State of Missouri Single Audit Corrective Action Plan Year Ended June 30, 2023 State Agency: Department of Health and Senior Services Audit Finding Number: 2023-013 CACFP Subrecipient Monitoring Name of the contact person responsible for corrective action: Sarah Walker, Bureau Chief Anticipated completion date for corrective action: The agency does not agree with the audit findings or believes that corrective action is not required. Explanation and specific reasons are as follows: A- Risk Assessments DHSS disagrees with this recommendation because the risk assessment process performed by BCFNA is in compliance with the substance and spirit of federal regulations – both of the federal funding agency, USDA, and 2 CFR 200, Uniform Grant Guidance. BCFNA risk assessments consider relevant information and are used to determine the extent and timing of monitoring as set out in the Nutritionist Manual. The BCFNA risk-based monitoring approach already allows for monitoring subrecipients more frequently than required by USDA. 2 CFR 200.332 states pass-through entities are to evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (1) The subrecipient's prior experience with the same or similar subawards; (2) The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F of this part, and the extent to which the same or similar subaward has been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). The BCFNA formal risk assessment process takes into consideration the results of current and previous experience with the same subaward (item 1 in the suggested criteria) as well as whether the subrecipient has new personnel or new or substantially changed systems (item 3 in the suggested criteria). These observations are made when performing onsite monitoring by Nutritionists who are familiar with the program, its requirements and its participants, and are trained in recognizing significant issues. BCFNA also takes into consideration the results of the subrecipient’s prior experience with similar subawards in other programs such as SFSP, NSLP and Child Care Licensing Reviews (item 1 in the suggested criteria), audit results (item 2 in the suggested criteria) as well as the results of Technical Assistance Reviews offered to new subrecipients which could move up the planned monitoring schedule. B- Subrecipient Monitoring Procedures DHSS disagrees with this recommendation. The State Auditor’s Office (SAO) states in this finding, “While our review found the sample monitoring reviews were performed in accordance with the policies and procedures outlined in the Internal Nutritionist Manual we identified areas where these policies and procedures could be strengthened and improved...” The SAO has not noted any specific noncompliance with federal requirements regarding subrecipient monitoring. The SAO’s finding noted the DHSS could enhance or improve it’s process but not that it is out of compliance with federal requirements for subrecipient monitoring. The SAO is trying to hold DHSS to a higher standard than what is federally required. Throughout the SAO’s finding they repeatedly acknowledge that the BCFNA monitoring process is in compliance with Nutritionist Manual which is based on USDA requirements, but is somehow not in compliance with broader federal requirements. This is incongruent with the accepted hierarchy of federal compliance guidance which says that 2 CFR 200 Uniform Grant Guidance is broader and less specific than the higher-ranking requirements set forth by specific federal grant funders and awards. In addition, the DHSS has a strong system of internal controls documented in the Nutritionist Manual which is in compliance with federal regulations and is used as a best practice by the USDA for other states. The report from the most recent USDA Management Evaluation Report for Fiscal Year 2023 issued November 2023 stated “The FNS determined that the SA Monitoring of Sponsors and SA Oversight of Sponsor Monitoring’s has adequate management controls in place for administering the CACFP in accordance with Federal regulations. The FNS staff reviewed SA practices that included detailed SA review forms, spreadsheets that provided extra oversight, and written procedures detailing the monitoring process. The SA provides online CACFP trainings along with a handbook to institutions that detail policies and procedures governed by the SA. The SA developed an extensive tracking system in addition to a very thorough review tool that contains meal component and pattern calculation. The SA conducts oversight of the review process and tracks each step to confirm completion of any follow up required of institution. The SA CACFP training resources and online modules were reviewed and evaluated to ensure it contained the correct information and up to date policies and procedures. The FNS staff reviewed the SA policies and procedures and interviewed key SA staff regarding procedures for each respective area of this Section. All files reviewed are compliant with Program requirements. The FY 2023 CACFP ME review did not identify any significant reportable issues.” The DHSS through BCFNA has and will continue to review, strengthen and enforce subrecipient monitoring procedures in accordance with federal program requirements and management evaluation. BCFNA has and continues to exceed what is required by the federal awarding agency by implementing a risk-based monitoring plan that allows for more frequent onsite monitoring than required by the USDA. In addition, even though COVID waivers allowed for monitoring to be suspended during the COVID Public Health Emergency, the BCFNA continued to monitor through the use of desk reviews. BCFNA also returned to onsite monitoring months before it was required by the USDA. Furthermore, BCFNA has recently hired a financial manager to help identify red flags with new and returning sponsors and recently enhanced training and technical assistance opportunities based on issues found during monitoring. Corrective Action Plans Due to the size of the CACFP program it is imperative that a risk-based approach be used in performing monitoring and follow up activities. DHSS through BCFNA follows up and ensures that subrecipients take timely and appropriate action on all deficiencies detected through on-site reviews of the subrecipient using a risk-based approach approved by the USDA. Standard practices are in compliance with federal regulations. Physical verification or review of supporting documentation immediately at the time of submission to verify the CAP is not a federal requirement. Follow-up during the next scheduled review is in accordance with USDA regulations and BCFNA policy and procedure. BCFNA reviews Corrective Action Plans (CAPs) submitted by subrecipients to ensure they are acceptable and correct noted issues. Supporting documentation of CAP implementation may be reviewed by BCFNA’s trained Nutritionist performing the monitoring reviews prior to the next monitoring visit if deemed necessary, or during the next onsite monitoring visit. This follow up is timely and appropriate because the scheduling of the next monitoring visit is determined by the USDA-approved risk-based approach. For example, subrecipients that had significantly deficient issues in their monitoring will be reviewed onsite within 90 days to verify whether corrective actions have been taken and if not, move towards termination. The corrective action plans of other subrecipients that were deemed to not be as significant by the Nutritionist, such as using the wrong percent of milk, are verified at the next monitoring review which could range from 1 to 3 years. The criteria used by the SAO do not specify what is timely or appropriate and allows for BCFNA’s professional judgement and discretion of what is timely and appropriate. Claims testing BCFNA standard practice is test only the selected month(s) claim(s) per USDA requirements, although when warranted, additional reviews are conducted beyond the test month. Actual noncompliance has not been noted in regards to testing. The BCFNA Nutritionist Manual allows for expanded testing if needed and BCFNA does perform expanded testing if deemed necessary. However, the USDA risk-based monitoring approach implemented by BCFNA sets prompt follow-up standards for significant deficiencies to determine if addressed, and if not, move on to termination. Overclaim recoupment BCFNA standard practice is to pursue recoupment of overclaims of only the test month per USDA requirements, although when warranted, additional reviews are conducted beyond the test month. In addition, BCFNA officials pursue recoupment of overclaims for facilities/sponsors with terminated contracts on a case-by-case basis, taking into consideration various factors. BCFNA strives to maintain an appropriate balance between adequate monitoring and not creating barriers to program participation per USDA and the Paperwork Reduction Act. Starting the termination process is more effective than performing additional testing and pursuing historically unsuccessful recoupment of overclaims. CACFP is an important program that provides healthy meals to children and adults. The CACFP plays a vital role in improving the quality of day care and making it more affordable for many low-income families. This entitlement program provides reimbursements for nutritious meals and snacks to organizations that serve eligible children and adults who are enrolled for care at participating child care centers, day care homes, emergency shelters and adult day care centers. CACFP processes an average of 700 claims per month and provided healthy meals in Missouri to over 31 million children and adults in 2023. USDA prohibits creating barriers to program participation and provision of services. The steps over and above the USDA requirements suggested by the SAO would place significant barriers to participation in the CACFP program and in turn cause harm to needy children and adults. The USDA established an acceptable level of risk with respect to the CACFP program and provided approved risk management processes and requirements. DHSS disagrees with the methodology the SAO used in its calculations. Out of the SAO’s test sample of 60 monitoring reviews, only 9 of the overclaims were over the $600 threshold of acceptable risk set by the USDA. 7 CFR 226.8(f): In conducting management evaluations, reviews, or audits in a fiscal year, the State agency, FNS, or OIG may disregard an overpayment if the overpayment does not exceed $600. A State agency may establish, through State law, regulation or procedure, an alternate disregard threshold that does not exceed $600. The SAO left the inflated error percentage in the body of the finding despite repeated requests and only included the lower suggested rates in footnote 4. The SAO also did not explain how their test of monitoring reviews performed by BCFNA, instead of a sample of claims submitted, was representative of CACFP reimbursements that would lend to projecting to the total population. BCFNA monitors using a risk-based approach as required in response to known erroneous claims and to proactively address issues. A sample of monitoring reviews is proportionally more likely to include a higher number of claims with discrepancies.

2023-002: Fiscal Monitoring of Subrecipients – Weatherization for Low-Income Persons Name of Contact Person: Jamie Johnson, Senior Director of Operations Management’s Views and Corrective Action Plan: MaineHousing has developed and implemented a tracking tool to ensure each of the components of monitoring (fiscal, programmatic, technical) are conducted at the appropriate time and reports are issued within the required 30 days. Proposed Completion Date: Completed

The City of Scottsboro will adopt and implement policies in regards to federal award compliance, including subrecipient monitoring compliance.

Recommendation: We recommend the Society to establish an official written policy for subrecipient monitoring that is in line with the requirements of the Uniform Guidance. The policy should contain components for compliance with and references to Federal requirements, such as review of reports requested from the subrecipient regarding project status, reviewing invoices to ensure spending is limited to expenses involving approved projects, and proper approval procedures key personnel perform to ensure these invoices are valid. Management Response and Corrective Action Plan Management's Response: We appreciate the auditor's thorough review and recommendations regarding our subrecipient monitoring processes. Legal Aid Society of San Bernardino is committed to maintaining the highest standards of compliance with federal regulations and ensuring proper oversight of subawards. We acknowledge the importance of having a comprehensive written policy that aligns with the requirements set forth in 2 CFR part 200, Appendix XI, Compliance Supplement May 2023, sections 3-M-1 and 3-M-2. Corrective Action Plan: 1. Formalize written policy: We will document our existing subrecipient monitoring practices into a comprehensive written policy that fully aligns with 2 CFR part 200, Appendix XI, Compliance Supplement May 2023, sections 3-M-1 and 3-M-2. This policy will include: a. Detailed procedures for reviewing financial and programmatic reports from subrecipients b. Guidelines for following up on and addressing any identified deficiencies c. Clear references to relevant Federal requirements 2. Standardize subaward agreements: We will develop a standardized subaward agreement template that incorporates all required elements as specified in the Uniform Guidance. This will ensure consistency and compliance across all subawards. 3. Enhance approval protocols: We will fortify our existing two-party approval system and bill.com submission process for payments. This reinforced procedure will ensure rigorous oversight and thorough validation of all subrecipient expenses, maintaining a robust checks and balances system that aligns with federal compliance requirements. 4. Implement regular reporting: We will continue our practice of requesting 6-month and end-of-year reports from subrecipients. This will help us monitor processes, identify any budget or client service deviations, and ensure ongoing compliance with subrecipient monitoring requirements. 5. Establish policy review process: We will implement an annual review of our subrecipient monitoring policies to ensure they remain current with any changes in Federal regulations. Planned Implementation Date: November 30, 2024 Responsible Person: Pablo Ramirez, Executive Director

Finding 2023‐003 Condition Both of the two subawards selected for testing did not contain the required elements found in 2 CFR Part 200.332(a). The sample selected was not statistically valid. Corrective Action Plan Corrective Action Planned: The County will create Subrecipient Agreements for all providers that are identified as pass‐through entities and amend their contracts to add the agreement to existing contracts. Name(s) of Contact Person(s) Responsible for Corrective Action: Jillian Stacey, Housing Program Specialist, and Dylan Seitz, Accountant Anticipated Completion Date: September 30, 2024.

Finding ref number: 2023-001 Finding caption: The Agency did not have adequate internal controls for ensuring compliance with federal subrecipient monitoring requirements Name, address, and telephone of Agency contact person: Corena Stern 2200 W Sims Way Unit 100 Port Townsend, WA 98368 (360) 379-5064 Corrective action the auditee plans to take in response to the finding: The Agency takes seriously their responsibility for managing Federal Grant Funds and accordingly will make sure that in the future subrecipient contracts will have the specific elements required by Federal Uniform Guidance in their subcontracts. The agency will institute a Contract Review Checklist and approval process that includes the 14 required elements in the Federal guidance CFR 200.332 in order to clearly identify the source of federal funds in each subaward agreement. The checklist elements will include: • Federal Award Identification Number (FAIN) • Federal Award Date • Subaward budget period start and end date • Assistance Listing Number and Program Title The completed checklist will be reviewed and approved by the Administrative Director or Contracts Director before finalizing the subrecipient agreement. In addition, the Olympic Area Agency on Aging will require contracts and program staff managing federal grants to attend Federal Uniform Guidance Grants Training. Anticipated date to complete the corrective action: December 31, 2024

Action Taken: 1.) Subrecipient funding agreements have been updated to include the following information: federal award identification information, requirements imposed by pass-through entity, information on the indirect cost rate and requirements to permit access to subrecipients records and statements. 2.) Agency will verify subaward applicants are not suspended or debarred from receiving federal funding prior to approval of funding application. Agency will maintain documentation of such verification with subaward application materials. 3.) Agency has developed a risk-based fiscal monitoring program for all federal award subrecipients. Detailed monitoring requirements are included in subrecipient funding agreements.

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

Subrecipient Monitoring The county will review and update our internal processes and procedures and provide additional training and education to all departments to ensure the minimum requirements of 2 CFR 200 and the subrecipient monitoring policies established by the Oconto County Board are being followed. Planned completion date for corrective action: December 31, 2024

The City will establish an official written policy for subrecipient monitoring that is in line with the requirements of the Uniform Guidance.

Corrective Action Plan - Finding 2023-001 Subrecipient Monitoring Department of Treasury COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - ALN #21.027.The County will implement procedures to formally document and complete a risk assessment of subrecipients and for the development of monitoring procedures to address the risks. This corrective action plan calls for the County to annually prepare a risk assessment for each subrecipient and provider documented monitoring to address the risk. The County Budget Director will collect the audits for the respective subrecipient by June 30th. For those that have not completed their audit by June 30th, a follow up reminder will be sent each month inquiring as to the status for date of completion until which time the audit is received.The County Budget Director has developed a tracking spreadsheet to include receipt date of audit, review date of audit, risk assessment level and comments regarding audit. Any subrecipient receiving over $500,000 will automatically be considered a higher risk. In addition, any subrecipient that has findings or comments within their audit will also be considered a higher risk Currently, all expenditure requests must include copies of invoices and canceled checks to ensure that payment has been made prior to reimbursement. Quarterly reports are submitted and reviewed to update the County on progress of the projects. For those subrecipients that are documented as higher risk, additional monitoring procedures will occur. These procedures may include meeting with the subrecipient to discuss other funding sources to fund the project or follow up to any corrective action plans put in place to address the audit findings or comments. Anticipated Completion Date: September 30, 2024.Person Responsible for Corrective Action: Ann Brown Budget Director County of Butler PO Box 1208 Butler, PA 16003-1208 724-284-5105 abrown@co.butler.pa.us

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

Status: Completed Corrective Action: The City agrees with the finding. After receiving 2022-007, DDPHE has consulted with the City’s Federal Grants Manager, other agencies that typically have subrecipients for Federal awards, and the City Attorney’s Office to review the current standard contract provisions to ensure they cover all required provisions and has modified those provisions accordingly. DDPHE has a new template for Scope of Work that includes the missing information that was identified by BDO. DDPHE also included a step to verify the recording of the SAM.gov in the scope of work. This will be implemented in any Federally funded contracts going forward and we will be trained on this during Contracts & Grants training on a regular basis. Person(s) Responsible for Implementing: DDPHE – Paige Cheney Implementation Date: October 2023

Finding 2023-001 – Subrecipient Monitoring Cluster: Research and Development Agency: Department of Health and Human Services Award Names: Safety and Health Risks in Energy Transition for the Commercial Fishing Industry Award Numbers: U01OH012502 Assistance Listing Title: Center for Disease Control and Prevention (CDC) Assistance Listing Number: 93.262 Award Year: FY 2023 To ensure compliance with 2 CFR 200.332 (d), ABS will extend its current policy to review agencies’ annual audited financial statements when Uniform Guidance reports are not available. ABS will appoint a finance team member to review the Uniform Guidance report or financial statements and will offer the project management team feedback toward ensuring necessary monitoring actions are taken. ABS understands the associated funding risks and will begin implementing these processes while we draft and submit our policy update into our Quality Management system. We expect this to be corrected and implemented by December 31, 2024.

ALN: 84.010, 84.365, 84.367, 84.424, Corrective Action Plan: Inadequate Support for Federal Reimbursement - Title I-IV - OPI - The Internal Control Auditor of the Montana Office of Public Instruction will perform quarterly sampling reviews to determine which receipts and additional data should be requested to ensure the agency's compliance. Person(s) Responsible for Corrective Measures: April Grady, Chief Financial Officer, Montana Office of Public Instruction, Target Date: 12/31/2024

ALN: 84.010, Corrective Action Plan: Inadequate Subrecipient Monitoring - Title I - OPI - The Montana Office of Public Instruction Program Supervisor and Federal Grants Coordinator will create a new process to track and monitor Local Educational Entity (LEA) reviews, monitor findings, corrective actions identified, and whether corrective actions were completed and submitted within 90 days. Person(s) Responsible for Corrective Measures: April Grady, Chief Financial Officer, Montana Office of Public Instruction, Target Date: 09/30/2024

ALN: 20.509, Corrective Action Plan: Noncompliance with Subrecipient Monitoring Requirements - MDT - The Montana Department of Transportation has enhanced internal controls and subrecipient risk assessments, and provided training to staff to ensure departmental and federal compliance. It has also ensured all required elements are included in rolling-stock subaward agreements. Additionally, the department has hired new Transit Section leadership, who are actively working with the Federal Transit Administration (FTA) and the subrecipients to formalize procedures, document oversight measures, and correct these deficiencies. The department will create a tracking sheet with supervisor review and approval to ensure all subrecipient risk assessments have been performed and documented. MDT will also develop procedures for enhanced monitoring in response to higher assessed subrecipient risk levels and document the additional monitoring work performed. Person(s) Responsible for Corrective Measures: Rob Stapley, Administrator, Montana Department of Transportation, Target Date: 12/31/2024

ALN: 20.509, Corrective Action Plan: Noncompliance with Federal Procurement Requirements - MDT - The Montana Department of Transportation has hired new leadership for the Transit Section, who are actively working with the Federal Transit Administration (FTA) and the subrecipients to formalize procedures, document oversight measures, and correct the deficiencies. Person(s) Responsible for Corrective Measures: Rob Stapley, Administrator, Montana Department of Transportation, Target Date: 06/30/2025

ALN: 84.425, 84.425D, 84.425U, Corrective Action Plan: Inadequate Support for Federal Reimbursement - ESSER - OPI - The Internal Control Auditor of the Montana Office of Public Instruction will review cash requests and determine if the subrecipient grant expenditures comply with the Elementary and Secondary School Emergency Relief Fund (ESSER) requirements and ensure costs are related to the pandemic, reasonable and necessary. Additional documentation will be requested of the subrecipient as needed. The Internal Control Auditor will also monitor subrecipient compliance with construction and capital expenditures including wage certifications for construction projects. Person(s) Responsible for Corrective Measures: April Grady, Chief Financial Officer, Montana Office of Public Instruction, Target Date: 09/30/2024

ALN: 97.036, Corrective Action Plan: Inadequate Subrecipient Communications and Controls - DMA - The Montana Department of Military Affairs, Disaster and Emergency Services Division, will update the applicant awarding documentation to include the Federal Agency Listing Number (ALN) in compliance with 2 CFR 200.332(a)(1) and review of subrecipient audit reports as part of the initial risk assessments. Person(s) Responsible for Corrective Measures: Delila Bruno, Administrator, Montana Department of Military Affairs, Target Date: 12/31/2024

ALN: 21.027, Corrective Action Plan: Inadequate Subrecipient Monitoring - ARPA - DNRC - The Montana Department of Natural Resources and Conservation partially concurs with finding 2023-015 because it disagrees with the interpretation that subrecipient monitoring must occur within a specified time period and believes controls were in place during the audit period. Additionally, because the department's policy is to assign every subrecipient the same risk level until an assessment is completed, it believes it is following subrecipient monitoring requirements. As such, the department will continue to evaluate risk through a subrecipient survey and designate any subrecipient as medium risk if a survey is not completed and returned. The department has enhanced related internal controls by noting in its Risk Assessment and Subrecipient Monitoring Guidance that the agency may withhold reimbursement payments if a subrecipient fails to complete a risk survey. Additionally, the DNRC continues to perform subrecipient monitoring requirements, including verifying compliance with the Single Audit Act.  The agency has enhanced related internal controls by adding a process to review the Montana Department of Administration’s Local Government Audit Findings Report and requesting corrective actions from noncompliant subrecipients. Person(s) Responsible for Corrective Measures: Meaghan Bjerke, Chief Financial Officer, Montana Department of Natural Resources and Conservation, Target Date: Completed

ALN: 84.371, Corrective Action Plan: Inadequate Subrecipient Monitoring - Literacy - OPI - The Internal Control Auditor of the Montana Office of Public Instruction will review cash requests and determine if the subrecipient grant expenditures comply with federal program requirements. Additional documentation will be requested of the subrecipients as needed. Person(s) Responsible for Corrective Measures: April Grady, Chief Financial Officer, Montana Office of Public Instruction, Target Date: 09/30/2024

ALN: 84.371, Corrective Action Plan: Inadequate Support for Federal Reimbursement - Literacy - OPI - The Internal Control Auditor of the Montana Office of Public Instruction will review cash requests and determine if the subrecipient grant expenditures comply with federal program requirements. Additional documentation will be requested of the subrecipient as needed. Person(s) Responsible for Corrective Measures: April Grady, Chief Financial Officer, Montana Office of Public Instruction, Target Date: 09/30/2024

ALN: 93.575, 93.596, Corrective Action Plan: Inadequate Subrecipient Monitoring - CCDF - DPHHS - The Montana Department of Public Health and Human Services, Child Care and Development Fund programs have updated their 2023 contracts to include required disclosures. Risk assessments were completed annually, as required. However, the 2022 risk assessments were accidently copied over when completing the 2023 risk assessments. Controls have been updated to ensure copies of each risk assessment are now saved with procurement files to ensure files are not accidentally replaced. Person(s) Responsible for Corrective Measures: Tracy Moseman, Administrator, Montana Department of Public Health and Human Services, Target Date: Completed