Corrective Action Plans

Finding 2023-009 Lack of Subrecipient Monitoring Plan: The University of Illinois Springfield will review procedures to ensure subrecipient monitoring is conducted and documented for all subawards. Expected Implementation Date: April 2024 Contact: Charles Alsbury, Director Office of Research & Sponsored Programs, Post-Award University of Illinois Springfield Ralsb01s@uis.edu 217-206-7849

Department: Health and Human Services Title: Internal control over TANF subrecipient risk evaluation procedures needs improvement Questioned Costs: None Status: Management’s opinion is that corrective action is not required Corrective Action: The Department disagrees with this finding. The Department has subrecipient monitoring procedures for all of its subrecipients whether they were competitively bid or not. The first assessment of risk, as noted in the finding, is when a subaward is competitively bid. Secondly, another risk assessment built into the Maine Uniform Accounting and Auditing Practices for Community Agencies (MAAP), requires higher risk subrecipients to undergo a higher level of testing. Additionally, there are audit and review requirements at a much lower threshold than that of the Uniform Guidance (UG). Finally, the Social Service Unit of the Division of Audit performs a risk assessment and tests transactions for those subrecipients that have been determined to be higher risk. The Department's subrecipient monitoring procedures ensures that we comply with the UG 200.332(d) Pass-through entity (PTE) monitoring of the subrecipient must include: 1) Review of financial and performance reports. 2) Following-up and ensuring that subrecipients take timely and appropriate action on all deficiencies. 3) Issues management decisions. 4) PTE is responsible for resolving audit findings specifically related to the subaward. Based on the Department's MAAP rules we ensure we comply with UG 200.332(e) Depending on the PTE's assessment of risk, the following tools may be useful: 1) Training and technical assistance. 2) On-site reviews. 3) Arranging for agreed upon procedures. The Department covers #3 by ensuring that all of our subrecipients have a requirement to submit to the Department a/an Audit, Review or Schedule of Expenditures of Department Awards (SEDA). Completion Date: N/A Agency Contact: Jim Lopatosky, Director, Division of Contract Management, DHHS, 207-287-5075

Department: Health and Human Services Title: Internal control over ICA program subrecipient monitoring procedures needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The Department will establish a plan to ensure that a final review of contracts is completed to confirm that accurate Federal award identification information is included and documented prior to being sent to the provider for signing. The Department will begin using the established plan to ensure that a final review of contracts is completed to confirm that accurate Federal award identification information is included and documented prior to being sent to the provider for signing. The Department will re-evaluate the risk of current providers to determine the appropriate monitoring activities. The Department team will establish a plan to ensure that they receive, review, and approve all financial and performance reports within 10 business days of receipt. The Department will begin using the established plan to receive, review, and approve all financial and performance reports within 10 business days of receipt. Completion Date: April 30, 2024 (first item), May 31, 2024 (second, third and fourth items) and June 30, 2024 (fifth item) Agency Contact: Eden Silverthorne, Associate Director, Office of Population Health Equity (CDC OPHE PSM II), 207-441-1090

Department: Education Title: Internal control over ESF subrecipient monitoring procedures needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: During the review of ESF applications, the Office of Federal Emergency Relief Programs (OFERP) team will confirm that equipment purchases are denoted in the equipment budget category of the application. Equipment inventories and real property lists will be collected during the subrecipient monitoring process from school administrative units (SAUs) and reviewed for compliance by the OFERP team. Completion Date: Ongoing and July 1, 2024 respectively Agency Contact: Shelly Chasse-Johndro, Director of OFERP, DOE, 207-458-3180

Department: Education Title: Internal control over Special Education subrecipient audit procedures needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The Department will review the current procedure regarding the notification of management decisions related to audit findings and corrective action, to strengthen the areas where prior notifications were missed. Completion Date: April 30, 2024 Agency Contact: Nicole Denis, Director of Finance, DOE, 207-530-2161

Department: Administrative and Financial Services Title: Internal control over CSLFRF reporting needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The Department will review contracts with the agencies to verify the classifications. Completion Date: June 30, 2024 Agency Contact: Marilyn Leimbach, Director, Security and Employment Service Center, DFPS, DAFS, 207-248-2556

Department: Labor Title: Internal control over CSLFRF subrecipient risk evaluation procedures needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The Department will further develop and refine the sub-recipient monitoring procedure and implement the revised process. Completion Date: June 30, 2024 Agency Contact: Samantha Dina, Associate Commissioner, DOL, 207-816-1714

Department: Economic and Community Development Title: Internal control over CSLFRF subrecipient audit procedures needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The Department engaged with their contractor to review single audits for all subrecipients receiving more than $750,000 in aggregate federal funding. The contractor will raise any findings to the attention of DECD staff who will then issue a management decision letter in keeping with federal regulations. The Department will continue its own review in conjunction with that of the contractor and address findings or concerns with subrecipients to ensure that findings are addressed and that chances of recurrence are mitigated. Completion Date: February 21, 2024 and ongoing respectively Agency Contact: Denise Garland, Deputy Commissioner, DECD, 207-624-7496

Department: Economic and Community Development Title: Internal control over ERA Program subrecipient monitoring needs improvement Questioned Costs: None Status: Corrective action complete Corrective Action: The Department has contracted with a vendor to conduct all subrecipient monitoring of all federal ARPA funding. The Department has required detailed documentation in support of subrecipient reimbursement of all federal ARPA funding. Completion Date: June 30, 2023 Agency Contact: Deborah Johnson, Director, Office of Community Development, DECD, 207-624-9817

Department: Education Title: Internal control over CACFP subrecipient monitoring procedures needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The Department will update the newly established risk evaluation tool, with new auditor suggestions. The Department will enhance the policies and procedures to ensure that the audit reports for all subrecipients receiving over $750,000 in Federal Awards requiring audits are properly tracked, received, and reviewed. The Department will enhance documentation to support the reasons for late or missing audit reports. The Department will implement a process to ensure that all reviews are fully completed within the allotted timeframe. Completion Date: April 1, 2024 (first item), May 1, 2024 (second item) and June 1, 2024 (third and fourth items) Agency Contact: Jane McLucas, Director of Child Nutrition, DOE, 207-624-6880

Department: Education Title: Internal control over CNC subrecipient monitoring procedures needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The Child Nutrition supervisor will review details of the findings from the state auditors to assess where errors occurred in both administrative review completion and tracking. Clear separation of duties will be created between administrative staff responsibilities for review tracking and reviewer staff responsibilities. Staff will be trained on review tracking spreadsheet responsibilities. Staff will be trained on administrative review tool completion. Training will highlight areas where data was missing, more information was needed or errors were made. This will occur at monthly staff meetings. Special Provision 2 base year review staff will be trained on the need to ensure SFAs revise claims as required due to base year review findings. It will be recommended that a tracking document be created to validate that claim adjustments have been made. If the adjustment is over the 60 day late claim window, the financial specialist will track the reason for the claim exception. Completion Date: March 15, 2024 (first, second and third items), June 10, 2024 (fourth item) and March 14, 2024 (sixth item) Agency Contact: Adriane Ackroyd, Assistant Director Child Nutrition, DOE, 207-592-1722

Finding No. 2023-001 Subrecipient Monitoring Cluster: Research and Development Cluster Grantor: Department of Health and Human Services and National Aeronautics and Space Administration Award Names: Biomedical Research and Research Training and Science Award Year: July 1, 2022 – June 30, 2023 Award Number: 5R01GM140457-03 and 80NSSC21K0753 Assistance Listing Numbers: 93.859 and 43.001 Pass-through entity: Not applicable The College agrees with the finding noting that a business control process was in place for the regular monitoring of subrecipients, however, the College did not retain certain documentation evidencing this review. The ongoing risk inherent with subrecipient scenarios is taken seriously by the College, but the reviews have been informally performed and without standard documentation. The College has recently added a full time equivalent to the Controller’s Office for grant administration purposes, such as this control. Through the assistance of this new employee, the College will develop a formal subrecipient process and move forward with its implementation. We anticipate certain steps in place by June 30, 2024. Stephen Nigro, Controller is responsible for implementing this corrective action plan. Contact Person: Stephen Nigro, Controller (413) 542-2101

The organization has assigned a full-time employee with prior experience in subrecipient monitoring to own this process and will make additional resources available as necessary. Organizational leadership has reviewed the subrecipient monitoring policy to verify the proper steps and processes are in place to ensure compliance.

Community Partners acknowledges that while subrecipient monitoring was performed for federal subrecipients by hiring third party CPAs, the monitoring was based on randomly selected samples and a risk assessment was not included in the monitoring plan. Current leadership has enhanced the subrecipient monitoring plan by ensuring that risk assessments are incorporated into any future subrecipient monitoring. The person responsible for the corrective action detailed above will be Joyce Williams, Chief Financial and Operations Officer, (213) 346‐3202. We anticipate corrective action will be completed by June 30, 2024.

Community Partners acknowledges that while subrecipient monitoring was performed for federal subrecipients by hiring third party CPAs, the monitoring was based on randomly selected samples and a risk assessment was not included in the monitoring plan. Current leadership has enhanced the subrecipient monitoring plan by ensuring that risk assessments are incorporated into any future subrecipient monitoring. The person responsible for the corrective action detailed above will be Joyce Williams, Chief Financial and Operations Officer, (213) 346‐3202. We anticipate corrective action will be completed by June 30, 2024.

2023-005 Subrecipient Monitoring U.S. Department of Labor Assistance Listing Number 17.258/17.259/17.278 Recommendation: We recommend that the Board review its policies and procedures for sufficiency and commit the appropriate personnel to subrecipient monitoring to ensure that the Board is in compliance with all federal requirements. Action Taken: With the assistance of Workforce WV, the Board met with a private company representative (via Zoom) who made recommendations to the Board for fiscal monitoring of the Board’s subrecipient. A plan is in the process of accomplishing this action for both 21-22 and 22-23 Fiscal Years. The Board is planning on submitting a monitoring report within the next week. This process will be developed, and a six-month monitoring period is being developed to enter into the Board’s policies and procedures as a normal course of action.

2023-003 HOME Investment Partnership Program – Assistance Listing Number 14.239 Recommendation: We recommend procedures be strengthened to fully document subrecipient monitoring for all subrecipients. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We are in the process of strengthening our subrecipient monitoring procedures and tracking process now that new staff have come on board in the last year. Name(s) of the contact person(s) responsible for corrective action: Allison McIntyre, Housing Development Planner; Shaylyn Davis-Iannaco, Housing Program Manager; Lara Kritzer, Director of Housing and Community Development. Planned completion date for corrective action plan: July 2024

To improve the communication of the nature of the federal funding and associated requirements, C/CAG will ensure that future federal pass-through grant agreements include the following information and language: (1) The specific portion of funding that is federal funds, the Federal Awarding Agency, full funding amount and applicable Federal Project Number, listing number and title. (2) A portion of the funds included are federal funds, and the recipient is responsible for compliance with all relevant Federal requirements, including, but not limited to § 200.501 Audit requirements and 2 CFR § 200.332 Requirements for pass-through entities.

COMMONWEALTH OF PUERTO RICO MUNICIPALITY OF COAMO Corrective Action Plan For the Fiscal Year Ended June 30, 2023 _____________________________________________________________________________________________________________________ Audit Report: Reports on Compliance and Internal Control in Accordance with Government Auditing Standards and OMB Super Circular Uniform Guidance Audit Period: July 1, 2022 – June 30, 2023 Fiscal Year: 2022-2023 Principal Executive: Hon. Juan C. García Padilla, Mayor Contact Person: Mrs. Miraisa David Esparra, Finance and Budget Director Phone: (787) 825-1150 Original Finding Number: 2023-004 Statement of Concurrence or Non concurrence: We concur with the finding. Corrective Action: The Program Director is aware about the compliance requirement. We gave instructions to the Program Director to maintain a dateline control sheet to ascertain that required reports were submitted within the due date. Implementation Date: March 21, 2024 Responsible Person: Mr. Héctor R. Sanjurjo Rodríguez Federal Programs Director

Views of Responsible Officials: AHCMC acknowledges that it does not have a formal documented subrecipient policy that complies with all requirements of the Uniform Guidance. AHCMC will correct this deficiency by ensuring that every subaward is clearly identified to the subrecipient as a Federal pass-through subaward and that the agreement includes the Assistance Listing Number. AHCMC will also assign a risk level to each subrecipient and use monitoring tools to ensure that subrecipients are spending the funds appropriately. AHCMC will also ensure that subrecipients have a single audit if required.

Views of Responsible Officials and Planned Corrective Action: ASBO has developed a Notice of Subgrant Award Information Form providing required information to each subrecipient. We have already sent this form out for CPF grants as an amendment to the current grant award. This form will be part of the subawards that will be issued for the upcoming BEAD subgrants. We are currently developing this form for all SLFRF grants to be sent out as an amendment. It is currently being reviewed for changes. Our goal is to have this form out as an amendment to all SLFRF subgrantees by June 1, 2024. Anticipated Completion Date: June 1, 2024 Contact Person: Name: Glen Howie Title: Director Agency: Department of Commerce, Arkansas State Broadband Office Address: 1 Commerce Way, Suite 601 City, State, Zip: Little Rock, AR 72202 Phone Number: 501-682-1123 Email Address: Glen.howie@arkansasEDC.com

The County is aware of the above finding and has adjusted our procedures related to disbursing federal funds to subrecipients. We have changed to a cost reimbursement basis for disbursing the federal funds to subrecipients. We currently receive supporting documentation prior to payment.

Finding Number: 2023-001 Condition: The College does not have a subrecipient monitoring policy and did not perform risk assessment procedures before selecting the subrecipient for the grant. Planned Corrective Action: The College will work to develop a subrecipient monitoring policy and subrecipient monitoring procedures, which would include the performing of a risk assessment, to ensure the policies and procedures are in alignment with other College policies while also adhering to federal regulations and best practices in grant management. Contact person responsible for corrective action: Vice President for Finance & Business Anticipated Completion Date: 06/30/2024

Commodity Supplemental Food Program (CSFP) and The Emergency Food Assistance Program (TEFAP) have developed a tentative 2024 agency review schedule to ensure continued compliance with the annual USDA Food and Nutrition Services (FNS) requirements. The schedule was submitted to FNS as part of the state’s FFY 2022 Management Evaluation (ME) findings response. The State received notification from FNS on January 26, 2024, noting the successful completion and close-out of the FFY 2022 Management Evaluation and its findings.

UEI Missing - This issue was mainly caused by a mid-year change by our federal partners when they moved from the DUNS number to the UEI numbers. Our GMS system adjusted for the change but some of our grant awards did not include UEI numbers at that time. We will raise this issue with our Vendor to ensure the UEI shows on all awards going forward. We will also make sure the UEI is reviewed during our grant review process. Obligation by this action- This is an issue with how our GMS processes grant amendments, on amendments beyond the first amendment the GMS shows the total change vs the change for this action. AOE will raise this issue with our vendor and will try to get it corrected prior to when FY25 grant amendments are processed. This will be a critical request to our Vendor. Position Responsible for Implementation of Corrective Action Name: Sean Cousino Position: Deputy CFO Email: sean.couisno@vermont.gov Phone Number: 802 595-3693 Date of Implementation of Corrective Action: 10/01/2024