Corrective Action Plans

The Grant Accounting Analyst and Director of Operations will ensure that every subaward agreement is clearly identified to the subrecipient and the following information will be included in our subaward agreements. • Federal Award Identification • Name of the Federal and awarding agency and contact information. • Subrecipient Name (which must match the name associated with its unique entity identifier). • Subrecipient's Unique Identifier • Federal Award Identification Number • Federal Award Date • Subaward Period of Performance • Subaward Budget Start and End Date • Amount of Federal funds obligated by this action by the Vail Health to the subrecipient. • Total amount of Federal funds obligated to the subrecipient by the Vail Health.The Grant Accounting Analyst and Director of Operations will monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statues, regulations and the terms and conditions of the subaward and that the subaward performance goals are achieved. Vail Health's monitoring of the subrecipient will include: 1. Reviewing financial and program performance reports of the subrecipient. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on any deficiencies pertaining to the subaward agreement. 3. An audit certification letter will be sent out to sub•recipients confirming their eligibility for Single Audit. Sub recipients will certify if they are eligible or not. Single Audits reports will be requested from sub-recipients receiving over $750,000 in federal funds. 4. If a sub-recipient has an audit finding, a copy of their corrective action plan will be requested by Vail Health. The Grant Accounting Analyst will complete an evaluation for risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring. This evaluation will include. • Assessing subrecipient's prior experience with Federal awards or subawards • The results of previous audits including whether the subrecipient receives a single audit in accordance with the Federal regulations. • Whether the subrecipient has new personnel or new or substantially changed systems. • The number and dollar amount of Federal awards received by the subrecipient. Depending upon assessment of risk posed by the subrecipient, the following monitoring tools will be used to ensure proper accountability and compliance with the program requirements and achievement of performance goals. • Providing subrecipients with training and technical assistance on program- related matters Performing on-site reviews of the program operations The Grant Accounting Analyst will take attend grant compliance training to acquire more knowledge on Uniform Guidance. Vail Health Sub-Recipient Monitoring policies will be updated accordingly.

The County concurs with this finding and will be working to enhance internal controls over the adherence to our policies and procedures in accordance with 2 CFR 200.332 to ensure compliance with subrecipient monitoring requirements.

Item: 2023-002 Assistance Listing Number: 21.027 Programs: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds (SLFRF) Federal Agency: U.S. Department of Treasury Pass-Through Agencies: State of Arizona, Office of the Governor Pass-Through Grantor Identifying Number: EL9HZNBAN1B9 Award Year: July 1, 2022 – June 30, 2023 Compliance Requirement: Subrecipient Monitoring Criteria: In accordance with 2 CFR sections 200.330, .331, and .501(h), pass-through entities must (a) identify the award and applicable requirements, (b) evaluate the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CR section 200.332(b), (c) monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR section 200.332(d) through (f), and (d) ensure accountability for any for-profit subrecipients. Condition: In connection with our testing of Arizona Foundation for Human Service Providers (the Foundation) subrecipient monitoring, we noted that the Foundation did not timely or effectively monitor the activities of subrecipients to ensure that the subawards were used for authorized purposes and complied with the terms and conditions of the subaward. Name of Contact Person: Candy Espino, President & CEO Phone Number: (602) 252-9363 Anticipated Completion Date: September 30, 2024 Views of Responsible Officials and Corrective Actions: Arizona Foundation for Human Service Providers will enhance their existing policies and procedures to ensure sufficient controls are in place to properly monitor subrecipients. We will also include specific enhancements to the ongoing post-payment review of subawards and well as supervision and review controls to ensure the procedures are performed in a timely and thorough manner.

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

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

HSEM concurs with the finding. Condition A: NH HSEM Mitigation and Recovery leadership has updated the award letter templates to ensure the necessary information is included as outlined in the condition. Conditions B – D: NH HSEM Mitigation and Recovery leadership updated the Risk Assessment Quick Reference Guide (QRG) and Subrecipient monitoring QRG. A two hour in-person training was conducted on January 31, 2024, to Mitigation and Recovery staff which focused on conducting risk assessments and subrecipient monitoring. This will be reviewed with staff again during an upcoming Section meeting in March 2024.

Condition A: DHHS partially concurs. The review of expenditure details is an integral part of DHHS’ Subrecipient Monitoring and standard language is included in the templates for legal agreements. These five subrecipients were deemed low or no risk, examination of expenditure detail is considered sufficient monitoring. All five of these subrecipients had the inclusion of the monthly detail requirement in the contracts and this was performed prior to the invoice being submitted to AP for payment. DHHS will re-evaluate current practices to ensure that the documentation is sufficient for the current subrecipient monitoring process. Regarding the two selections identified as having risk assessments which did not specify recommended monitoring procedures: The Risk Assessment Tool for one subrecipient was performed after the subaward award. However, as indicated on the Tool, programmatic monitoring activities were included in the contract. DHHS reviewed the monthly back-up documentation provided with the submitted invoices prior to sending them to AP for payment. The risk assessment tool for the second selection was performed after the subaward award. However, as indicated on the tool, programmatic monitoring activities were included in the contract. We reviewed the monthly back-up documentation provided with the submitted invoices prior to sending them to AP for payment. Condition B: DHHS partially concurs. The review of expenditure details is an integral part of DHHS’ Subrecipient Monitoring and standard language is included in the templates for legal agreements. The subrecipients were deemed low or no risk, therefore, examination of expenditure detail is considered sufficient fiscal monitoring. DHHS employs the review of expenditure details, as allowed under 200.332 (d)(1), as an integral part of the Departments Subrecipient Monitoring. A review of the expenditures provides monitoring for the following concerns: • The familiarity a subrecipient has utilizing Federal funds • The subrecipient management teams’ familiarity with Federal funding • Single Audit findings • Any prior return of funding due to non-compliance • The subrecipient’s compliance with the requirements of 200.300 and 302 • Whether the subrecipient has a new financial system DHHS will re-evaluate the risk response parameters to determine that the level of documentation is sufficient to ensure that the procedures performed would be able to identify noncompliance at the subrecipient level. Condition C: DHHS concurs. DHHS will be updating procedures to include contacting vendors to remind them of the deadline regarding the submission of their single audit in the Federal Audit Clearinghouse.

The Department Concurs with paragraph A – Since this same finding was reported in March of 2023 for FY22, items a, c, and d are now included on all federal subaward contracts and policies have been updated to reflect this. The Department will ensure b is also included going forward. The Department concurs with paragraph B - The finding was a result of personnel turnover and medical issues. The Department has hired and trained additional program staff and updated policies to ensure programmatic monitoring and subsequent reports are done in a timely manner. The Department partially concurs with paragraph C. Fiscal monitoring was done for all 3 subrecipients during the federal program year. However, 1 subrecipient monitoring fell outside the state fiscal year so was not covered during the audit period. The Department has changed the wording on its risk assessment procedures to ensure no misinterpretation of the timeframe each subrecipient will be monitored in accordance with its risk assessment. The Department has also changed the requirements of the frequency of fiscal monitoring in each of the risk assessment categories. The Department Concurs with paragraph D – The Department is reviewing policies and procedures and will update them to ensure compliance with 2 CFR section 200.332(a), 2 CFR section 200.332(b) and 2 CFR section 200.521. The Department also created a tracking mechanism to ensure we receive, review, and issue management decisions (if required) in a timely manner. The Department concurs with Paragraph E - The Department is reviewing policies and procedures for both reporting and subrecipient monitoring to ensure data is tested and verified. The Department has already gained increased access to data in current software and is in the process of selecting a vendor for new software that will provide more testing and enhanced internal controls.

Condition A: DHHS concurs. Pursuant to the Subrecipient Monitoring Policy, the risk assessment and determination of subrecipient monitoring activities is performed during the procurement process with the Grants Administrator and the Program Lead. It is the responsibility of Program to perform the requested subrecipient monitoring. The Department provides annual training on the Subrecipient Monitoring Policy. We will reinforce the requirements of the Policy and the ramifications for the Department for the non-compliance in this year’s annual training. Regarding the incomplete Risk Assessment Tool, we will update the Subrecipient Monitoring Policy to include a secondary review of the Tool prior to implementation, as part of our internal controls. Condition B: DHHS does not concur. The Department employs the review of expenditure details, as allowed under 200.332 (d)(1), as an integral part of the Departments Subrecipient Monitoring. The Department’s review of the expenditures provides monitoring for the following concerns: • The familiarity a subrecipient has utilizing Federal funds • The subrecipient management teams’ familiarity with Federal funding • Single Audit findings • Any prior return of funding due to non-compliance • The subrecipient’s compliance with the requirements of 200.300 and 302 • Whether the subrecipient has a new financial system Standard language for the submission of expenditure detail is included in all templates for legal agreements. These subrecipients were deemed low or no risk, therefore, examination of expenditure detail is considered sufficient monitoring. Subrecipient monitoring activities are memorialized in the legal agreements. The Risk Assessment Tool provides a space for the monitoring activities to be selected, however, the Subrecipient Monitoring Policy does require the memorialization of the activities on the Tool for compliance, only to be memorialized in the legal agreement. Condition C DHHS partially concurs. As the subrecipient’s audit report had no findings, we are not required to issue a management decision letter. However, we will be updating our procedures to include contacting the vendors to remind them of the deadline regarding the submission of their single audit in the Federal Audit Clearinghouse.

Corrective Action Planned (Condition A): The DAS analyzed the six items erroneously reported as subawards and noted the errors were isolated to two specific agencies, the Department of Health and Human Services and the Department of Environmental Services. In response to the prior year finding 2022-002, the DAS had strengthened internal controls related to the review and validation of amounts reported by individual state agencies as pass through expenditures. This included an additional control specifically verifying SLFRF pass through expenditures reported by each agency. The DAS will offer additional training relative to identification and reporting of subaward expenditures in its annual statewide Single Audit training and re-evaluate the precision of execution of controls over the validation of pass through reporting in assembling the SEFA for fiscal year 2024. Corrective Action Planned (Conditions B through E): The State largely concurs with the findings and recommendations and has implemented procedures to address the identified conditions already or will do so. With regards to condition B, The State will work with the individual agencies to ensure that individual agencies entering into such agreements clearly indicate the terms required by Uniform Guidance, including permitted indirect cost rates and whether the award is for R&D. The State has already begun this corrective action plan with the agencies. With regards to condition C, for a. and b. for payments by agencies, there are standard procedures for review and authorization of invoices and payments and those payments are documented. For c. The State has already implemented an agency wide framework for subrecipient monitoring. The State will provide re-training for those agencies that had not properly documented monitoring as outlined by the subrecipient risk assessments and ensure monitoring reports are documented. With regards to condition D, The State has already implemented an agency wide framework to help ensure policies and procedures are in place concerning Uniform Guidance Reports. We will work those agencies that had not documented the date received and the review of the Uniform Guidance Reports to ensure written documentation occurs. Where findings have been reported in the Uniform Guidance Report, ensure timely Management Letters are documented and provided with the summary review of Uniform Guidance Report.

FISCAL YEAR OF FINDING: 2023 AUDITOR FINDING: 1. At the time of the award – County did not make subrecipients aware of Federal Assistance Listing Number or title. 2. Risk Assessment could not be provided for 2022 or 2023 to support the level of monitoring. 3. Audited financials for family tree for 2022 or 2023 were not obtained by the County. 4. Family Tree did not have any case review monitoring performed during 2023 – October 15, 2022. Criteria: Condition: During testing, we noted the following: - The Assistance Listings number and Title were not provided to the County's two subrecipients in accordance with 2 CFR Part 200.332(a) - The County did not have a formal documented risk assessment completed for either of the County's two subrecipients in accordance with 2 CFR Part 200.332(b) - The County did not obtain or review one of the subrecipients single audit reports in accordance with 2 CFR Part 200.332(f) Effect: The subrecipient may be unaware whether the funds are federal or what compliance requirements they are responsible for. In addition, The County may not perform the adequate level of monitoring as formal risk assessments were not completed. Finaly, the County did not review the single audit report and while any finding would not directly be related to the subaward program, failure to review such reports and take appropriate action could result in non-compliance by the subrecipient continuing for an inappropriate length of time. Cause: The County does not have adequate internal controls over subrecipient monitoring to ensure that the County is in compliance with subrecipient monitoring requirements. Recommendation: We recommend that the County develop a risk assessment template or form to be completed over each federal subrecipient. The County should provide training to those administering grants over the development risk assessment template or form and the associated monitoring to be performed based on each assessed risk. In addition, the County should develop a subrecipient grant template to help ensure all required information is included within each award. Finally, the County should establish a policy or procedure over obtaining and reviewing audits completed over each of their subrecipients. CLIENT PLANNED ACTION: 1. On 4/8/24, Jefferson County sent the two ERA subrecipients the Federal Assistance Listing Number. The County policy is to include the Subaward Data Form, which includes the Federal Assistance Listing Number (see attached), as an Exhibit in all subrecipient contracts. This was inadvertently not included in the ERA contract. 2. On 4/8/24, Jefferson County completed a formal Risk Assessments for both The Action Center and Family Tree and placed in the files. The two subrecipients are long-time partners and federal fund recipients and have undergone continuous scrutiny through regular monitoring, and a rigorous draw reimbursement process. Due to this history and knowledge, both partners were determined to be very low risk at the time of ERA awards. Moving forward, the County will complete a formal Risk Assessment for the records prior to the execution of a contract or within 6 months of execution of a contract. 3. The County has now collected the audited financial statements for the two subrecipients and retained them in the files. Subrecipient audits are regularly reviewed as part of the monitoring process to assess for any findings or concerns. Moving forward, the County will obtain the most recent audit reports and place them in the files prior to the execution of a contract or within 6 months of execution of a contract. 4. The County performed a monitoring including the scrutiny of 20% of all case files during the 2022 ERA Program and there were no findings. The County had plans to monitor the ERA2 Program at the time of this audit, after the program was running at full capacity. The County has now moved up this time frame according to the above feedback and is currently undergoing a monitoring of the 2023 cases from the two subrecipients. This process aligns with the previous year, as the program has more time during the early spring months when cases are slower. Monitoring of subrecipients began the week of April 8th. CLIENT RESPONSIBLE PARTY: Kat Douglas, Community and Workforce Development Director COMPLETION DATE: 6/25/24

Sandra Dalida, CFO September 30, 2024 AL# 2 1.027 - Coronavirus State and Local Recovery Funds; 2023 Pursuant to CFR Section 200.332(b), pass-through ent1t1es must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the tenns and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring. The Unity Council did not perform a risk assessment of subrecipients. Management is in agreement with the finding and is in the process of developing and documenting a risk assessment process. Chief Financial Officer, Sandra Dalida Chief Operating Officer Chief Program Officer September 30, 2024

Views of Responsible Officials and Planned Corrective Actions: AL has a long-standing preassessment Questionnaire (sample attached) that we require each potential subgrantee to complete before they can receive any financial remuneration from us. In response to this finding, we will require all subgrantees to complete this questionnaire on an annual basis. In addition we have included the following questions to the questionnaire:  Does the organization perform an annual audit of financial statements?  Annual amount of US Government Funds received?  Is the organization subject to a US compliance audit under 2 CFR 200 Subpart F?  If the organization is subject to a compliance audit under 2 CFR 200 Subpart F, please provide a copy of your most recent 2 CFR 200 Subpart F audit report. Anticipated Completion Date: We will submit the questionnaire to all subgrantees during the month of June 2024 and then perform it annually. Responsible Officials: Chief Innovation and Operations Officer and Finance Manager.

EXECUTIVE OFFICE OF HOUSING AND LIVABLE COMMUNITIES 2023-028 Low-Income Home Energy Assistance, COVID-19 – Low-Income Home Energy Assistance - Assistance Listing No. 93.568 Action taken in response to the finding: The Executive Office of Housing and Livable Communities (EOHLC), which was formerly the Department of Housing and Community Development (DHCD or Department), has implemented the recommended measures and will continue them going forward. EOHLC has reviewed their internal controls and procedures and is committed to making any enhancements that are necessary to ensure that required information is included in its subawards. EOHLC notes that the Federal Award Identification Number (FAIN) and the Federal Award Date are included in the HHS award notices and other HHS guidance, which EOHLC incorporates by reference into its LIHEAP subaward contracts with its subrecipients. In an effort to ensure compliance with these requirements going forward, EOHLC will include a direct reference to the FAIN and the Federal Award Date in its LIHEAP subaward contracts with its subrecipients beginning with its FFY 2025 LIHEAP contracts. Name of the contact person responsible for corrective action: Edward Kiely Planned completion date for corrective action plan: October 1, 2024

DEPARTMENT OF PUBLIC HEALTH 2023-025 Refugee and Entrant Assistance State Administered Programs (Refugee), Opioid-STR Block Grants for Prevention and Treatment of Substance Abuse, COVID-19 - Block Grants for Prevention and Treatment of Substance Abuse (SABG) - Assistance Listing No. 93.566, 93.788, 93.959 Action taken in response to the finding: DPH will continue to automatically generate a subrecipient notification whenever federal funding amounts change. However, because FAIN# and grant award date information is not currently available through our automated systems, we will require bureaus to include a contract attachment that includes this information. The state’s current accounting system is being replaced by a new system, with improved grant functionalities. If the FAIN# and grant award information is available through this system, DPH will be able to add these data to our automatically generated subrecipient notification in the future. Name of the contact person responsible for corrective action: Sharon Dyer, Director Purchase of Service Office Planned completion date for corrective action plan: September 30, 2024

OFFICE FOR REFUGEES AND IMMIGRANTS 2023-024 Refugee and Entrant Assistance State Administered Programs - Assistance Listing No. 93.566 Action taken in response to the finding: ORI will provide the Federal Award Identification Number (FAIN) to the subrecipient in the contract document. ORI will update internal controls and procedures to confirm FAIN number is included in contract documents going forward. Name of the contact person responsible for corrective action: Kelvin Pham Planned completion date for corrective action plan: July 1, 2024

EXECUTIVE OFFICE OF ELDER AFAIRS 2023-022 COVID-19 – Aging Cluster - Assistance Listing No. 93.044, 93.045, 93.053 Action taken in response to the finding: EOEA will review internal processes to ensure that all required information is included in all subaward agreements, including reviewing FFY25 and subsequent Title III subaward agreements to ensure that the required federal award information is present. Name of the contact person responsible for corrective action: Sheila Tunney, EOEA CFO Planned completion date for corrective action plan: EOEA will complete this corrective action plan for the re-issuance of FFY24 subawards following receipt of additional federal awards, anticipated for June/July 2024.

MASSACHUSETTS EXECTIVE OFFICE OF EDUCATION 2023-019 COVID-19 – Governor’s Emergency Education Relief (GEER) Fund - Assistance Listing No. 84.425C Action taken in response to the finding: EOE will review and enhance internal controls and procedures to ensure that all required information is included in all subawards including: RFQ postings and contracts. This documentation will be included in our updated internal control process which is underway as required by the Comptroller’s Office. Name of the contact person responsible for corrective action: Joanne Puopolo Planned completion date for corrective action plan: July 1, 2024

EXECUTIVE OFFICE OF HOUSING AND LIVABLE COMMUNITIES 2023-015 COVID-19 – Emergency Rental Assistance Program – Assistance Listing No. 21.023 Action taken in response to the finding: The Emergency Rental Assistance Program (ERA or ERAP) was a temporary program relating to the COVID-19 emergency which was administered by the Executive Office of Housing and Livable Communities (EOHLC), formerly the Department of Housing and Community Development (DHCD or Department). Most of the ERA contracts that are still in place will be ending as of 6/30/2024. In the event that EOHLC’s ERA contracts are extended or renewed before the performance period ends, EOHLC will amend the contracts to include a reference to the required information. EOHLC is committed to reviewing internal controls and procedures and making the enhancements that are necessary to ensure that required information is included in its subawards going forward. Name of the contact person responsible for corrective action: Henok Teffera Planned completion date for corrective action plan: July 1, 2024

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

DEPARTMENT OF ELEMENTARY AND SECONDARY EDUCATION 2023-005 Child and Adult Care Food Program – Assistance Listing No. 10.558 Action taken in response to the finding: The Office for Food and Nutrition Programs (FNP) has moved from a paper based permanent agreement to a web form that exists on the DESE Security Portal. All existing and new Child Nutrition Sponsors will continue to sign off on the document via the web-based portal allowing for a more efficient collection and document retention process. A change will be made in the portal to automatically apply a DESE signature upon submission of the permanent agreement to avoid a late DESE signature. Name of the contact person responsible for corrective action: Rob Leshin, Director of FNP Planned completion date for corrective action plan: July 1, 2024

DEPARTMENT OF ELEMENTARY PUBLIC HEALTH 2023-004 WIC Special Supplemental Nutrition Program for Women, Infants, and Children – Assistance Listing No. 10.557 Action taken in response to the finding: DPH will continue to automatically generate a subrecipient notification whenever federal funding amounts change. However, because FAIN# and grant award date information is not currently available through our automated systems, we will require bureaus to include a contract attachment that includes this information. The state’s current accounting system is being replaced by a new system, with improved grant functionalities. If the FAIN# and grant award information is available through this system, DPH will be able to add these data to our automatically generated subrecipient notification in the future. Name of the contact person responsible for corrective action: Sharon Dyer, Director Purchase of Service Office Planned completion date for corrective action plan: September 30, 2024

FINDING 2023-002 Individuals Responsible for Corrective Action Plan: Romero Brown/Alliance staff Corrective Action: The Organization will properly monitor the subaward disbursed to provide reasonable assurance the subrecipient used the subaward for authorized purposes. Anticipated Completion Date: December 31, 2024

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

Views of Responsible Officials: Management is aligned with these observations and notes that a Subaward Manual was finalized for use by the Prime (JGI-Tanzania) as of February 2024. The Manual addresses the auditor’s findings around subaward selection and monitoring policies. Preaward procedures were performed that signaled that the subrecipients were low risk. The Prime will retroactively document the pre-award risk assessment for the two subawards in 2023 and any future subaward. The Prime will perform monitoring procedures according to the assessed level of risk. Additionally, subawards will be assigned a Federal Assistance Listing Number as required by §200.332.