Corrective Action Plans

Planned Corrective Action: The DCF Bureau of Finance will update current subrecipient contracts containing Social Services Block Grant (SSBG) funds to include information required under 2 CFR section 200.332. The bureau will incorporate the SSBG fund source into existing procedures which identify the federal assistance listing numbers for subrecipient contracts. Anticipated Completion Date: The bureau will complete this work by June 30, 2024. Person responsible for corrective action: Rachelle Armstrong, Director Bureau of Finance Rachelle.Armstrong@wisconsin.gov

Finding 2023-201: Refugee and Entrant Assistance State / Replacement Designee Administered Programs – Subrecipient Monitoring Planned Corrective Action: The DCF Bureau of Finance currently performs risk assessments for subrecipients meeting either the state single audit threshold or federal single audit threshold. The bureau will review and update subrecipient risk evaluation procedures to ensure all subrecipients receive a risk assessment, even in cases of lower dollar amount subawards. The DCF Bureau of Refugee Programs (BRP) monitors all subrecipients for compliance with state and federal requirements pertaining to the grants they receive. In certain cases during State Fiscal Year 2023, BRP made decisions to differentiate monitoring activities of certain partners according to bureau established priorities, which included but were not limited to programs related to refugee employment, distribution of benefits, and reduction of refugees’ use of public benefits. These programs received BRP’s highest degree of formal monitoring (on- site case file reviews), while other programs were monitored through program desk reviews of subrecipient reports and direct communication with subrecipients in accordance with the results of those reviews. During SFY 2023 and the beginning of SFY2024, BRP piloted and then implemented a new comprehensive program desk monitoring plan and annual monitoring schedule. BRP will continue to review these tools to ensure that all subrecipients are appropriately monitored and that all monitoring activities are appropriately documented. In addition, BRP will review existing subrecipient contracts to ensure appropriate monitoring plans are in-place and customized as needed according to subrecipient risk assessments, administered as planned, and that ongoing monitoring activities are adequately documented.Anticipated Completion Date: The bureaus will complete this work by June 30, 2024. Persons responsible for corrective action: Rachelle Armstrong, Director Bureau of Finance Rachelle.Armstrong@wisconsin.gov Bojana Zoric Martinez, Director Bureau of Refugee Programs Bojana.ZoricMartinez@wisconsin.gov

Department staff has reviewed the Legislative Audit Bureau’s (LAB) interim audit memo for Finding 2023-305: Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises – Subrecipient Monitoring. This is the department’s response.  Recommendation (2023-305): Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises – Subrecipient Monitoring We recommend the Wisconsin Department of Health Services: • Develop a written monitoring plan for the Health Disparities program that includes a description of the subrecipient monitoring expected for low-, moderate-, and high-risk subrecipients; procedures for completing and documenting desk reviews of subrecipient invoices; procedures for assessing and documenting the reliance that can be placed on review of subrecipient single audit reports; and procedures for documenting management oversight of the monitoring plan. Wisconsin Department of Health Services Planned Corrective Action: The Department of Health Services (DHS), Division of Public Health (DPH) Grant Managers and their designees are responsible for subrecipient monitoring. As part of the ongoing monitoring, DHS DPH recognized opportunities for improvement of this process and began developing a new Internal Controls Checklist during FY 2022-23. On February 15, 2024, DHS DPH Bureau of Operations provided training to DHS DPH staff who regularly work on financial, granting, and/or contracting items on a new Internal Controls Checklist for Federal Funding. This checklist provides DHS DPH federal Grant Managers and their designees a best practice tool for reviewing how their grant activities are carried out and to ensure their consistency with the terms and conditions of the federal award and with federal and state policies. The Internal Controls Checklist guides DHS DPH federal Grant Managers and their designees through a series of questions that, among other things, direct them to have knowledge of, follow, and maintain written policies for administering federal grant programs; document procedures for verifying invoices; archive relevant documentation; ensure financial reports are submitted timely; monitor subgrantees for fiscal and program requirements; document procurement authority; and monitor expenses against waiver and contract limits. The Internal Controls Checklist is to be signed by the Grant Managers or their designees in the last quarter of the grant. The policy states the Section Manager is accountable to make sure the Checklist is completed accurately. Using the Internal Controls Checklist will formalize management oversight as it will be signed by the Section Manager overseeing the grant. The Internal Controls Checklist will be updated to identify the need for subrecipient monitoring to be attributed to the risk levels of subrecipients. Also, it will include direction to document procedures for completing and documenting desk reviews of subrecipient invoices and procedures for assessing and documenting the reliance that can be placed on review of a subrecipient’s single audit report. Grant Managers and their designees are encouraged to use the Internal Controls Checklist as a monitoring plan by evaluating each item in the checklist and saving the procedures, documents, and emails associated with those steps in a folder, in addition to the program’s usual record keeping practice, to enhance the effectiveness of the information. Grant Managers and their designees may also produce a separate monitoring plan instead of using the Internal Controls Checklist, and if a separate document is produced, management oversight will be documented within the plan. We recommend the Wisconsin Department of Health Services: • Develop a central location to maintain documentation related to the subrecipient monitoring, including email correspondence. Wisconsin Department of Health Services Planned Corrective Action: Grant Managers and their designees maintain documentation related to subrecipient monitoring in various ways, and to provide better consistency, the newly created Internal Controls Checklist provides some recommendations. The Internal Controls Checklist recommends Grant Managers, and their designees develop plans for archiving relevant documents for program administration and maintain information to support subgrantee monitoring, including risk analyses and reporting. Individual units in DHS DPH will develop a central location to maintain documentation related to the subrecipient monitoring, including email correspondence. We recommend the Wisconsin Department of Health Services: • Provide sufficient training to the Department of Health Services staff administering the Health Disparities program to ensure all subrecipient monitoring responsibilities are completed consistently and are based on the risk assessment level determined. Wisconsin Department of Health Services Planned Corrective Action Current Grant Managers and their designees in DHS DPH who oversee federally awarded programs will be informed of the federal requirements as they relate to 2 CRF s. 200.331, through specific subrecipient monitoring training. DHS DPH will administer annual trainings to Grant Administrators and their designees on subrecipient monitoring requirements and policies for conducting risk assessments. Anticipated Completion Date: June 30, 2024 Person responsible for corrective action: Christina Isenring, Director Bureau of Operations, Division of Public Health christinam.isenring@dhs.wisconsin.gov

Department staff has reviewed the Legislative Audit Bureau’s (LAB) interim audit memo for Finding 2023-306: Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response – Subrecipient Monitoring. This is the department’s response.  Recommendation (2023-306): Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response – Subrecipient Monitoring We recommend the Wisconsin Department of Health Services: • Review the tracking spreadsheets completed in fiscal year 2022-23, and complete the assessment of the progress and fiscal reports and consideration of potential unallowable costs, document the conclusions, and return funding to the federal government if costs were determined to be unallowable; Wisconsin Department of Health Services Planned Corrective Action: Emergency Health Care (OPEHC) will create a workgroup that includes subject matter expert staff from all impacted areas that will be tasked with reviewing all the tracking spreadsheets for fiscal year 2022-2023. Staff will conduct the recommended assessment on all progress and fiscal reporting to determine any possible unallowable costs under the parameters of the cooperative agreement. The workgroup will coordinate efforts, as needed, with impacted health departments and workers. The workgroup will document all conclusions and, in coordination with leadership, will work with the correct federal agency to discuss and complete any necessary next steps. We recommend the Wisconsin Department of Health Services: • Develop a written monitoring plan for the Cooperative Agreements program that includes a description of the subrecipient monitoring expected for low-moderate-, and high-risk subrecipients; procedures for completing and documenting review of the progress and fiscal reports; procedures for completing and documenting desk reviews or on-site visits; procedures for assessing and documenting the reliance that can be placed on review of a subrecipient’s single audit report; and procedures for documenting management oversight of the monitoring plan. Wisconsin Department of Health Services Planned Corrective Action: The Department of Health Services (DHS), Division of Public Health (DPH) Grant Managers and their designees are responsible for subrecipient monitoring. As part of the ongoing monitoring, DHS DPH recognized opportunities for improvement of this process and began developing a new Internal Controls Checklist during FY 2022-23. On February 15, 2024, DHS DPH Bureau of Operations provided training to DHS DPH staff who regularly work on financial, granting, and/or contracting items on a new Internal Controls Checklist for Federal Funding. This checklist provides DHS DPH federal Grant Managers and their designees a best practice tool for reviewing how their grant activities are carried out and to ensure their consistency with the terms and conditions of the federal award and with federal and state policies. The Internal Controls Checklist guides DHS DPH federal Grant Managers and their designees through a series of questions that, among other things, direct them to have knowledge of, follow, and maintain written policies for administering federal grant programs; document procedures for verifying invoices; archive relevant documentation; ensure financial reports are submitted timely; monitor subgrantees for fiscal and program requirements; document procurement authority; and monitor expenses against waiver and contract limits. The Internal Controls Checklist is to be signed by the Grant Managers or their designees in the last quarter of the grant. The policy states the Section Manager is accountable to make sure the Checklist is completed accurately. Using the Internal Controls Checklist will formalize management oversight as it will be signed by the Section Manager overseeing the grant. The Internal Controls Checklist will be updated to identify the need for subrecipient monitoring to be attributed to the risk levels of subrecipients. Also, it will include direction to document procedures for completing and documenting review of the progress and fiscal reports, procedures for completing and documenting desk reviews or on-site visits, and for procedures for assessing and documenting the reliance that can be placed on review of a subrecipient’s single audit report. Grant Managers and their designees are encouraged to use the Internal Controls Checklist as a monitoring plan by evaluating each item in the checklist and saving the procedures, documents, and emails associated with those steps in a folder, in addition to the program’s usual record keeping practice, to enhance the effectiveness of the information. Grant Managers and their designees may also produce a separate monitoring plan instead of using the Internal Controls Checklist, and if a separate document is produced, management oversight will be documented within the plan. We recommend the Wisconsin Department of Health Services: • Develop a central location to maintain documentation related to the subrecipient monitoring, including email correspondence. Wisconsin Department of Health Services Planned Corrective Action: Grant Managers and their designees maintain documentation related to subrecipient monitoring in various ways, and to provide better consistency, the newly created Internal Controls Checklist provides some recommendations. The Internal Controls Checklist recommends Grant Managers and their designees develop plans for archiving relevant documents for program administration and to maintain information to support subgrantee monitoring, including risk analyses and reporting. Individual units in DHS DPH will develop a central location to maintain documentation related to the subrecipient monitoring, including email correspondence. We recommend the Wisconsin Department of Health Services: • Provide sufficient training to the Department of Health Services staff administering the Health Disparities program to ensure all subrecipient monitoring responsibilities are completed consistently and are based on the risk assessment level determined. Wisconsin Department of Health Services Planned Corrective Action: Current Grant Managers and their designees in DHS DPH who oversee federally awarded programs will be informed of the federal requirements as they relate to 2 CRF s. 200.331, though specific subrecipient monitoring. DHS DPH will administer annual trainings to Grant Administrators and their designees on subrecipient monitoring requirements and policies for conducting risk assessments. Anticipated Completion Date: June 30, 2025 Person responsible for corrective action: Natalie Easterday, Director Office of Preparedness & Emergency Health Care, Division of Public Health natalie.easterday@dhs.wisconsin.gov

Department staff has reviewed the Legislative Audit Bureau’s (LAB) interim audit memo for Finding 2023-308: Aging Cluster – Subrecipient Monitoring. This is the department’s response. Recommendation (2023-308): Aging Cluster – Subrecipient Monitoring We recommend the Wisconsin Department of Health Services: • Create a centralized tracking process to monitor the receipt of the quarterly financial reports and semiannual financial reports from each Area Agency on Aging, including follow-up procedures when reports are not provided. Wisconsin Department of Health Services Planned Corrective Action: We will create a centralized tracking process that documents receipt of quarterly reports from each of the three Area Agencies on Aging, which we require to provide the basis for our annual federal reports. This tracking tool will also document any follow up measures taken if reports are late or not submitted. We recommend the Wisconsin Department of Health Services: • Implement procedures to document the review and approval of the quarterly financial reports and semiannual financial reports, including related follow-up and resolution. Wisconsin Department of Health Services Planned Corrective Action: The centralized tracking process will include documentation of the review and approval of the reports, including any follow up to address and resolve problems with the submissions. We recommend the Wisconsin Department of Health Services • Develop and maintain in a central location documentation related to the monitoring procedures performed, including email correspondence or documentation of oversight meetings such as agendas and significant discussion topics. Wisconsin Department of Health Services Planned Corrective Action: We will create and deploy standard agenda templates for our oversight meetings with Area Agency on Aging program management and fiscal management and will record minutes of these meetings including documenting attendance, topics address, and decisions requiring follow-up actions. The new tracking tools and the meeting agendas and minutes will be maintained in shared document storage space for ready access by all management and fiscal team members and will be monitored by leadership for completion. Anticipated Completion Date: June 1, 2024 Person responsible for corrective action: Cynthia Ofstead, Director Office on Aging, Bureau of Aging and Disability, Division of Public Health cynthia.ofstead@dhs.wisconsin.gov

Finding 2023-800: Geographic Programs -Great Lakes Restoration Initiative— Subrecipient Monitoring Planned Corrective Action: DNR will develop a written plan for monitoring subrecipients for the Geographic Programs-Great Lakes Restoration initiative program. This plan will include completing a documented risk assessment for each subrecipient and specific steps for monitoring subrecipients based on the assessed level of risk. In addition,DNR will develop a process to ensure that subrecipient audit reports are received, the review is documented and will follow-up with subrecipients to ensure all audit reports are received. Anticipated Completion Date:11/1/24 Name, Title: Wade Strickland, Director Office: Office of Great Waters Email address: wade.strickland@wisconsin.gov Person responsible for corrective action: Name, Title:Karen Van Schoonhoven,Finance Director Division or Unit (if applicable): Internal Services Division Email address: karena.vanschoonhoven@wisconsin.gov

Finding 2023-103: Emergency Rental Assistance Program—Subrecipient Monitoring Auditor Recommendation: Review its existing monitoring procedures and ensure adequate management oversight procedures are established, documented, and followed. Planned Corrective Action: The Wisconsin Department of Administration (Department) has reviewed its existing monitoring procedures, designed to ensure that subrecipients use the subaward for authorized purposes, take timely and appropriate action on all deficiencies detected through monitoring, and comply with the terms and conditions of the subaward, as required by 2 CFR s. 200.332 (d) through (f), and its own policies and procedures. The Department will improve the completeness and effectiveness of its monitoring program by ensuring that management oversight procedures are appropriately established, documented, and followed. Auditor Recommendation: Complete review and follow-up with the community action agencies or Energy Services, Inc. (ESI) identified by its existing monitoring procedures. Planned Corrective Action: The Department will complete review and follow-up with the community action agencies or Energy Services, Inc. (ESI) in accordance with its existing monitoring procedures.Auditor Recommendation: Consider if additional monitoring should be completed for the community action agencies or ESI for the months during FY 2022-23 when the Department of Administration paused monitoring for the Emergency Rental Assistance Program. Planned Corrective Action: To maintain the integrity of its Emergency Rental Assistance monitoring program, the Department will complete additional monitoring of the community action agencies and ESI during FY 2022-23, including during the period acceptance of new program applications was temporarily paused. Anticipated Completion Date: June 30, 2024. Persons responsible for corrective action: David Pawlisch, Administrator Division of Energy, Housing and Community Resources david.pawlisch@wisconsin.gov

CORRECTIVE ACTION PLAN February 15, 2024 The Tor Project, Inc. (the Organization) respectfully submits the following corrective action plan for the year ended June 30, 2023. Name and address of independent accounting firm: CohnReznick LLP 350 Granite Street, Suite 1200 Braintree, MA 02184 Audit period: July 1, 2022 – June 30, 2023 The findings from the June 30, 2023 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Federal Award Findings and Questioned Costs Significant Deficiency Item #2023-001 - Subrecipient Monitoring International Programs to Support Democracy Human Rights and Labor – 19.345 Issue: The Organization did not fully monitor the subrecipients to ensure the subaward was used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Recommendation: Management should monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved per 2 CFR 200.332. Action Taken: Subsequent to fiscal year end, the Agency implemented additional internal controls over subrecipient monitoring and retroactively performed these compliance procedures. The Tor Project, Inc. sampled monthly invoice periods for each active sub-recipient, per grant, in the period of the FY23 annual external audit. The Tor Project reviewed all supporting documentation for the cost reimbursements of the sample to ensure accuracy and completeness of all reimbursed costs. For all sub-recipients, The Tor Project performed the internal audit procedure selecting a sample of monthly invoices at random per sub-recipient, per grant, per year to verify the completeness and accuracy of all reimbursed costs. If there are any questions regarding this plan, please call Susan Abt at 781-307-8651.

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE – U.S. DEPARTMENT OF EDUCATION, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, CAREER AND TECHNICAL EDUCATION – BASIC GRANTS TO STATES – FEDERAL ALN 84.048 2023-001 Internal Control Over Compliance With Subrecipient Monitoring Requirements Finding Summary 2 CFR § 200.332 requires Intermediate District No. 287 (the District) as a pass-through entity, to have written subrecipient monitoring policies and procedures that include a written risk assessment of each subrecipient and documentation of the District’s monitoring of the subrecipient. Additionally, as a pass-through entity, the District is required to verify that every subrecipient is audited as required by 2 CFR § 200 Subpart F when it is expected that the subrecipient’s federal awards expended during the respective fiscal year equaled or exceeded the threshold for a federal Single Audit. During our audit, we noted that the District did have documented written controls to ensure compliance with the U.S. Office of Management and Budget’s Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) subrecipient monitoring requirements. The District did not maintain documentation of its evaluation of each subrecipient’s risk of noncompliance with federal statutes, regulations, and the terms and conditions of the subaward, nor did the District maintain documentation of the results of the subrecipients’ Single Audit, if any, for purposes of determining the appropriate subrecipient monitoring. Corrective Action Plan Actions Planned – The District will review its policies and procedures relating to subrecipient monitoring for its federal programs to ensure compliance with the Uniform Guidance in the future. Official Responsible – The District’s Executive Director of Business Services, Brian Schultz. Planned Completion Date – June 30, 2024. Disagreement With or Explanation of Finding – The District agrees with the finding. Plan to Monitor – The District’s Executive Director of Business Services, Brian Schultz, will assure appropriate internal controls and procedures are updated and in place to ensure compliance with subrecipient monitoring requirements.

Contact Person Debby Marshall Planned Corrective Action The Cooperative will ensure proper subrecipient monitoring is implemented. Planned Completion Date June 30, 2024.

2023‐013 – Subrecipient Monitoring (Material Weakness) State Department of Labor and Industrial Relations AL Numbers and Program Title: 17.258 – WIOA Adult Program 17.259 – WIOA Youth Activities 17.278 – WIOA Dislocated Worker Formula Grant (WIOA Cluster) Condition No evidence of evaluation of the subrecipients’ risk of noncompliance at the time of the subawards, and no evidence of on‐site monitoring procedures of the subrecipients. Current Status of Corrective Action Plan Concur. -The ASO will come up with a checklist of pertinent reports that are due for WIOA programs including but not limited to Risk Assessment Report to include the following information: - Subrecipient’s prior experience with the same or similar subawards. - Results of previous Single Audit of the same or similar program that has been audited as major program. - New and Departing Personnel Record. - Systems Changes/Update. - Completion of Subrecipient Monitoring Report. - A formal analysis of each subrecipient’s risk of noncompliance with each of the respective subaward requirements shall be performed at the time of the subaward. - In‐person, onsite monitoring of the activities of the subrecipient shall take place annually to ensure that the subaward is used for authorized purposes, in accordance with federal statute and regulations. Person Responsible Ferdinand Casabay, Accountant VI Anticipated Date of Completion May 31, 2024

Finding No. 2023‐008 – Subrecipient Monitoring (Significant Deficiency) State Department of Land and Natural Resources AL Number: 15.634 Program Title: State Wildlife Grants (R&D Cluster) Condition The auditing firm examined a non‐statistical sample of two subawards and noted the following instances of noncompliance: -Subaward agreements did not include certain required federal award information. -No evidence of pass‐through entity verifying that subrecipients are audited as required by 2 CFR Section 200, Subpart F. Current Status of Corrective Action Plan Concur. DLNR DOFAW does provide subaward information to subrecipients and will ensure to include all required federal award information. DLNR DOFAW will ensure that documentation is retained when performing verification that subrecipients are audited as required by 2 CFR Section 200, Subpart F. Person Responsible Cynthia C. Gomez, Fiscal Management Officer David Smith, DOFAW Administrator Anticipated Date of Completion Completed.

1. Person responsible: Division Chief, Auditor-Controller Accounting Division 2. Corrective action plan: The County agrees with the finding and recommendation. In September 2022, the County issued the Notice of Federal Subaward Information template, which contains the 14 reporting elements required by 2 CFR §200.332(a) that must be provided to subrecipients at the time of the subaward. The County will issue written correspondence reminding departments to complete the Notice of Federal Subaward Information template and provide a completed copy to the subrecipient at the time of the subaward. The County will also remind departments to provide all the required elements from 2 CFR §200.332(a) via letter or amended agreement to existing subrecipients that were not initially provided all the requirements. In the same correspondence, the County will remind departments to monitor their Coronavirus State and Local Fiscal Recovery Fund (CSLFRF) subrecipients, maintain sufficient records of the monitoring, and utilize the Subrecipient Monitoring Guide issued in June 2023. 3. Anticipated implementation date: June 28, 2024

2023-003: 21.027 – COVID-19 – American rescue Plan Act Funds (US Treasury ARPA) • Recommendation: We recommend that the County prepare and maintain a written plan to ensure subrecipients are aware of the Uniform Guidance requirements. • Explanation of disagreement with audit finding: There is no disagreement and management agrees with the finding. • Corrective action taken in response to finding: The County Office of Finance will create a written plan to ensure that subrecipients are aware of all the needed Uniform Guidance requirements. • Name of the contact person responsible for corrective action: Kevin McMahon, Office of Finance. • Planned completion date for the corrective action plan: June 30, 2024.

2023-001: 172.258, 17.259, 17.278 – WIOA Cluster • Recommendation 1: We recommend that the County prepare and maintain a written plan to ensure subrecipients are aware of the Uniform Guidance requirements. • Recommendation 2: We recommend the County performs the monitoring of the subrecipients and ensure the documentation is saved within the County. • Explanation of disagreement with audit finding: There is no disagreement and management agrees with the finding. • Corrective action taken in response to finding: The County Office of Finance will (1) develop a written plan to ensure that subrecipients are aware of all the Uniform Guidance requirements; (2) due to the pandemic and the recent retirement and resignation of the top two Grant department staff members, the monitoring was not conducted during the audit period. Management will make sure that the required monitoring will be conducted and ensure compliance and proper documentation is maintained onsite. • Name of the contact person responsible for corrective action: Kevin McMahon, Office of Finance and Charles Knapp, Anne Arundel Workforce Development Corporation. • Planned completion date for the corrective action plan: June 30, 2024.

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