Corrective Action Plans

Contact Person: Iftin Hagimohamed; Chief Financial Officer Stephanie Sosa: Finance Manager Corrective Action Plan For the Year Ended 2023 Explanation and specific reasons for disagreement with the audit finding or that corrective action is not required (if applicable): Management concurs with the finding. Subaward agreements did not consistently include all required elements under 2 CFR §200.332. Status: Corrective Action Taken Corrective action planned: Management has revised its internal policies and procedures regarding subrecipient monitoring to follow 2 CFR 200.332. Ensure that subward are clearly identified and included in subrecipient agreement. • Develop and adopt a standardized subaward agreement template including Assistance Listing Number, federal award name, award ID, performance period, and required compliance provisions. • Implement a documented subrecipient risk assessment process. • Establish a subrecipient monitoring checklist for invoice review and compliance tracking. • Amend active subaward agreements where required. Anticipated completion date: April 30,2026

We will implement the required procedures surrounding the subrecipient monitoring process and follow them consistently.

Views of Responsible Officials and Planned Corrective Action While the Organization concurred with the prior year (2022-002) and current year renumbered recommendation (2023-002), the Organization notes the corrective actions that have been implemented, specifically, related to the subrecipient monitoring and management provision of 2 CFR§ 200.331 and 2 CFR §200.332 of the Uniform Guidance, that emphasizes accountability and compliance in managing federal funds and subrecipients, and that have been in practice, from the effective date(s) noted below, to the present period of the report dated March 2, 2026: A. Subrecipient Monitoring and Management. Implemented internal process changes, effective November 1, 2024, specifically, prospectively, and consistently the: 1. Use of a checklist, to comprehensively assess risk of determining subrecipient or contractor classification, before entering into any subrecipient agreement; 2. Provision of identification details such as CFDA number, amount of federal funds obligated, and the award period for determined subrecipient awards; 3. Submission of programmatic and financial reports as specified in the subrecipient agreement; 4. Review of a single audit in accordance with 2 CFR Part 200, Subpart F for subrecipients that expend $750,000 or more in federal funds during a fiscal year, if applicable; and 5. Review of their audit report(s) and addressing any finding(s) related to their federal award(s), including the related appropriate corrective actions, when applicable. B. Retroactive Subrecipient Portfolio Risk Assessment and Correction(s). The Organization performed a risk assessment of the existing subrecipient portfolio to identify risks, for the audit periods July 1, 2022 – June 30, 2023, and July 1, 2023 – June 30, 2024. The objective of this risk assessment was to identify, evaluate, and prioritize risks that could adversely impact the Organization’s ability to achieve its strategic, operational, compliance and quality assurance goals. The completion of the Organization’s portfolio risk assessment resulted in correction of identified non-compliant subrecipient agreement(s). C. Subrecipient Policies and Procedures. By December 31, 2024, the Organization updated and implemented financial policies and procedures aligned to the subrecipient monitoring and management provision of 2 CFR §200.331 and 2 CFR §200.332 of the Uniform Guidance, including checklists, flowcharts, samples, data sheets, data sharing agreements, etc.; and the current practices of the Organization to the present period of the report dated March 2, 2026, is consistent with such developed subrecipient policies and procedures.

The MOF requires that all necessary documents, including expenditure and financial reports, be submitted prior to the release of subsequent funding. These reports are reviewed and processed by the Compliance Unit once complete. Additionally, the Sub-Grants Monitoring Procedures Manual has been updated to require management, through the Chief of Internal Audit, to prepare a management decision letter. Furthermore, a proposed adjusting entry will be made to recognize a receivable for the overpayment, which will be discussed with the grantor.

Chairman of the Board of County Commissioners: This issue originated under the prior County Clerk’s administration where key reporting processes were not followed. The Board of County Commissioners and the other elected officials have made correcting this a top priority. Together, we are: • developing a comprehensive SOP to ensure accurate and timely tracking and reporting of Federal funds, • improving communication and oversight between all county offices to ensure consistent reporting standards, • and ensuring annual compliance with federal reporting requirements. Our collective goal is to implement the policies and structures that will keep Osage County operating with the highest standard of accountability and excellence County Clerk: I was not the County Clerk in office at this time. To correct this issue, the County plans to develop a SOP to timely and accurately track and report on Grants and Awards. The SOP will be reviewed, adopted, and monitored by the Board of County Commissioners.

The formal process for completing and retaining Subrecipient Agreements is now operational to ensure compliance with programmatic obligations. As the recipient, it is the territory's responsibility to notify the Subrecipient when the federal funds are obligated and provide them with a subrecipient agreement which outlines the terms and conditions of the program. The Disaster Program Financial Specialist is responsible for obtaining the subrecipient agreement and ensure it has been signed by the Applicant/Subrecipient and Governor's Authorized Rep and later provided to the Territorial Public Assistance Officer (TPAO). As such, no funds will be disbursed until the Subrecipient signs and returns the agreement. These agreements are saved in a centralized location for documentation and audit purposes. In accordance with the 2CFR #200 Subpart F, all Subrecipients must comply with applicable audit requirements because the applicant is in the receipt of federal funding. Under 2CFR #200.500 Subpart F applies to any non-federal entity that expends $750,000 or more in federal awards during a fiscal year. Subrecipients meeting this threshold are required to undergo a single audit or a program specific audit for that fiscal year. The TPAO will review audit requirements during the applicant's briefing and will incorporate these requirements into the Subrecipient Agreement.

VIDE, through the Office of Federal Grants (OFG), acknowledges the finding and concurs with the need to strengthen internal controls related to subrecipient identification, monitoring, and compliance with federal audit requirements, as outlined in 2 CFR Part 200, Subpart F. During the period under review, gaps in documentation and monitoring were impacted by staff turnover, leadership transitions, and programmatic shifts, which limited the consistency and precision of subrecipient oversight across programs. In response, OFG has taken steps to reinforce its role as the pass-through entity and to formalize monitoring expectations and processes. OFG is committed to ensuring that all subrecipient agreements clearly identify the federal award and applicable requirements, including reporting, audit, and compliance obligations under 2 CFR Part 200, Subpart F, in accordance with 2 CFR §§ 200.331 and 200.332. Subrecipient agreements will explicitly outline financial, programmatic, and reporting expectations necessary for VIDE to meet its own federal responsibilities. In addition, OFG is strengthening risk-based subrecipient monitoring practices, including evaluating prior audit results, changes in personnel or systems, and the complexity of subawards to determine the appropriate level of oversight. Monitoring activities will include documented reviews of financial and programmatic reports and follow-up on identified deficiencies, as required. Through these actions, OFG is working to ensure that subrecipients are properly identified, monitored, and supported, and that federal funds are expended in accordance with all applicable statutes, regulations, and award terms.

The Government concurs with the auditor’s findings and recommendations. Starting FY25, OMB will identify and monitor federal awarding agencies, requesting single audit results for applicable recipients and including them in monitoring reviews. For revenue replacement projects, Treasury's Final Rule FAQ (13.14) states that these funds do not create subrecipient relationships, thus exempting them from the Single Audit Act due to the absence of a federal program or purpose.

The Government concurs with the auditor’s findings and recommendations. The GVI is currently in the process of developing a comprehensive Grants Management Overarching Standard Operating Policies and Procedures (SOPP) to establish uniform guidance for all grant-related processes, including drawdowns, documentation retention, subrecipient and compliance monitoring. Training will be provided to all staff on the SOPPs.

Recommendation: We recommended the City enhance its subrecipient monitoring activities and establish a formal record-keeping policy to ensure complete and timely documentation of expenses. Views of Responsible Officials: Management concurs with the finding. The City of Adelanto experienced higher than expected staff turnover in the finance department during the timeframe noted in this audit, which caused a backlog in audit preparation and submission, along with certain financial controls implementation interruption. At the time of this audit publishing, Management believes that implementation of such procedures is in compliance with the noted recommendation. Persons Responsible for Corrective Action: City Finance Staff (various) City Department Heads applying for grant funding (various) Anticipated Completion Date for Corrective Action: Corrective action has been immediately implemented in response to the auditors’ recommendation. As financial reporting is still in the process of becoming current, the City anticipates finding to be removed in future fiscal years.

The County Child and Youth Services department started requiring a corrective action plan for all subrecipients with findings as a result of their on-site monitoring in 2023 that include the entity’s plan to correct the errors noted, individual responsible and timeline for corrections to be implemented. Finding noted are for monitoring completed in January and March 2023, prior to the requirement of written corrective action plans being implemented.

Response to finding 2023-004 – Subrecipient Monitoring Views of Responsible Officials: CSforALL management agrees with the conditions identified by SAX Advisory Group, including the noted causes and resulting effects under 2023-004. Due to the organizational pause at the end of 2024 and the transition period throughout 2025, the Organization had limited capacity to maintain formalized subrecipient monitoring procedures aligned with 2 CFR 200.332. As CSforALL prepares for the 2026 rebuilding phase, management is establishing structured policies and procedures to ensure full compliance with federal subrecipient monitoring requirements. Corrective Action taken in 2025: During 2025, the Operations Manager ensured that all subrecipients associated with the current Alliance grant have signed or will sign formal Statements of Work with explicit deliverables and expectations required for payment. External parties without a Statement of Work are now required to submit proper documentation, invoicing, and proof of deliverables before any funds are released. No payments have been made to participants under the FY 2025 Alliance grant to date, as CSforALL is ensuring that all required policies and procedures are in place prior to both drawing down and paying out funds. Weekly and quarterly meetings have been established with external partners responsible for deliverables to confirm timelines, verify progress, and ensure alignment with payment expectations. Corrective Action Planned for 2026: Beginning in 2026, CSforALL will formalize subrecipient monitoring policies aligned with 2 CFR 200.332, including risk assessments for all subrecipients, review and documentation of Single Audit reports where applicable, issuance of management decisions, and structured ongoing monitoring activities. All monitoring documentation will be maintained in a centralized, accessible system to ensure consistent compliance throughout the 2026 operating year and beyond.

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

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

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

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

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

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

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

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

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

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

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

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

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