Corrective Action Plans

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.cousino@vermont.gov Phone Number: 802 595-3693 Date of Implementation of Corrective Action: 10/01/2024

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

FAIN (Federal Award Identification Number) and Federal Award Date: The following action has been implemented to include the FAIN & Award date on all awards for ALN 20.509: All awards executed for Public Transit will include a “Grant Insert Sheet”. The Grant Insert Sheet will be identified on the Part 1 Grant award detail document. Box “36” titled FAIN, will include text that reads “See attachment B”. The Grant Insert Sheet is a document that is completed by the Public Transit Unit and is provided to the Grants Unit for award execution. This sheet includes detailed information related to the award. To address the deficiency, The Grant Insert sheet has been updated to include FAIN Numbers and the Federal Award Date. To ensure the Agency of Transportation meets this compliance requirement, the Grants Unit will verify this information is included prior to award execution. Anticipated completion date: This action went into effect as of January 12, 2024. Person Responsible for Corrective Action: Ross MacDonald, Public Transit Program Manager ross.macdonald@vermont.gov Tricia Scribner, Grants Unit Manager tricia.scribner@vermont.gov Management Review Schedules In the past, The Public Transit Program has used the State Fiscal year for the timing/scheduling of the 3-year Management Reviews. For example, if the completion of the last Management Review occurred in FY 2020, then we would ensure a new Management Review began at any time during FY2023. We understand this could lead to more than exactly 3 years between these reviews. Due to this finding, we will now establish a starting month/date for each provider, with 3-year intervals between the start of each Management Review. We have attached the updated schedule and will adhere to this from this day forward. Anticipated completion date: As of December 27, 2023, the updated Management Review Schedule is in effect. Person Responsible for Corrective Action: Ross MacDonald, Public Transit Program Manager ross.macdonald@vermont.gov

The Agency had last year recognized a need to provide training and technical assistance to State Agencies and Departments. The Agency provided Uniform Guidance training in February and March of 2023. The Agency developed and delivered a subrecipient monitoring framework which included tools to facilitate subrecipient risk assessments, subrecipient monitoring plans based on the initial risk assessments, testing of transaction records, desk reviews of subrecipients, and corrective action plans. The Agency performed desk reviews for agencies and departments in the first six months of Fiscal Year 2024. As part of the desk review process, preliminary reports are issued, mitigation opportunities are presented, mitigation opportunities are implemented as appropriate, and final reports are shared across staff and management. The Agency will continue to provide oversight and monitoring for agency adherence to subrecipient monitoring procedures, informed by our ongoing agency and program-level compliance risk assessments, which include factors such as program complexity and history of audit findings. Scheduled Completion Date of Corrective Action Plan: Completed: July, 2023: Subrecipient Monitoring Framework Provided to Agencies & Departments Completed: December, 2023: Sampling completed by Agency Expected: April, 2024: Post-Sampling Follow-up with Agencies and Departments Expected: June, 2024: Continuing Monitoring and Technical Assistance Processes Expected: June, 2024: Additional Training for Agencies and Departments Contacts for Corrective Action Plan: Douglas Farnham Chief Recovery Officer, Vermont State Recovery Office Douglas.Farnham@vermont.gov (802) 585-8119 Ethan Hurley Director of Finance & Operations, Vermont State Recovery Office Ethan.Hurley@vermont.gov (802) 461-5317

Finding: The Foundation is not in compliance with recordkeeping for program monitoring and evaluation, as the Foundation does not have comprehensive sponsor/subrecipient monitoring policies and procedures. Corrective Action Taken or Planned: The Foundation has updated its Quality Management Plan to include comprehensive subrecipient monitoring policies. The Foundation’s Quality Management team is working with all programming to implement a robust monitoring process, including risk assessments, adherent to grantor regulations, service delivery, and program outcomes. Anticipated Date of Completion: June 30, 2024 Name of Contact Person: Laurie Wettstead, Chief Finance Officer

Management Response and Corrective Action Plan We agree with this finding and will have the Corrective Action Plan completed and implemented no later than February 29, 2024. Views of Responsible Officials and Corrective Actions Management of Family Service Agency of Santa Barbara County agrees with the findings noted above, and will implement proper internal controls to correct the issues noted. Contact Information for Responsible Officials Lisa Brabo, Chief Executive Officer, 805-965-1001 ex. 1240 Jaime Kuczkowski, CFO/Director of Finance, 805-618-3125 Cynthia MacDuff, FSS Program Director – North County, 805-588-1407

Management Response and Corrective Action Plan We agree with this finding and will have the Corrective Action Plan completed and implemented no later than February 29, 2024. Views of Responsible Officials and Corrective Actions Management of Family Service Agency of Santa Barbara County agrees with the findings noted above, and will implement proper internal controls to correct the issues noted. Contact Information for Responsible Officials Lisa Brabo, Chief Executive Officer, 805-965-1001 ex. 1240 Jaime Kuczkowski, CFO/Director of Finance, 805-618-3125 Paul Katan, Director of Grants and Partnerships, 805-965-1001 ext. 1255 Arcelia Sencion, Chief Strategy and North County Programs Officer, 805-433-5921

Management Response and Corrective Action Plan We agree with this finding and will have the Corrective Action Plan completed and implemented no later than February 29, 2024. Views of Responsible Officials and Corrective Actions Management of Family Service Agency of Santa Barbara County agrees with the findings noted above, and will implement proper internal controls to correct the issues noted. Contact Information for Responsible Officials Lisa Brabo, Chief Executive Officer, 805-965-1001 ex. 1240 Jaime Kuczkowski, CFO/Director of Finance, 805-618-3125 Cynthia MacDuff, FSS Program Director – North County, 805-588-1407

Management Response and Corrective Action Plan We agree with this finding and will have the Corrective Action Plan completed and implemented no later than February 29, 2024. Views of Responsible Officials and Corrective Actions Management of Family Service Agency of Santa Barbara County agrees with the findings noted above, and will implement proper internal controls to correct the issues noted. Contact Information for Responsible Officials Lisa Brabo, Chief Executive Officer, 805-965-1001 ex. 1240 Jaime Kuczkowski, CFO/Director of Finance, 805-618-3125 Paul Katan, Director of Grants and Partnerships, 805-965-1001 ext. 1255 Arcelia Sencion, Chief Strategy and North County Programs Officer, 805-433-5921

2023-017. Failure to Implement SLFRF Subrecipient Monitoring Requirements State Agency: Governor’s Office of Planning and Budget Federal Agency: Department of the Treasury While this corrective action plan was already implemented, GOPB will continue to carry forward the implemented corrective action plan. Specifically, GOPB will review project budgets and categories with state agencies administering ARPA SLFRF funds to ensure that all agencies administering projects are aware of subrecipient monitoring requirements. GOPB will collaborate with the Division of Finance to examine FAQ 13.15 and summarize which requirements do and do not apply to revenue replacement projects in order to guide agency compliance activities. GOPB has scheduled a dedicated training session during April 2024 with all finance directors involved in administering ARPA SLFRF fund. This session will focus on providing compliance training on subrecipient requirements, including internal controls, monitoring procedures, and compliance standards. GOPB will continue to conduct regular agency trainings, reviews, and site visits as part of our ongoing efforts to monitor compliance and strengthen internal controls. In cases where agencies have been discovered to not fully comply with internal control and subrecipient monitoring requirements, GOPB will work with them to identify and implement improvements. Contact Person: Darcy Jaimez, Fiscal Grant Manager, 385-377-3373 Anticipated Correction Date: April 30, 2024

Corrective action plan: TANF – While Intellectual and Developmental Disabilities (IDD) Services & Preadmission Screening & Resident Review (PASRR) no longer operates contracts with Temporary Assistance for Needy Families, Social Services Block Grant, or Block Grants for Community Mental Health Services funding, IDD Services & PASRR’s IDD Contract Management Unit will incorporate the following items into its performance contracts and record the requirement in its procedure defining required data fields for contracts that include federal funding:  UEI  FAIN  Federal award date  Assistance listings numbers and title  Indirect cost rate (including if the de minimis rate is charged) For indirect cost rates, the Federal Funds Office Indirect Cost Rate Group continues to accept, negotiate, and acknowledge Indirect Cost Rates for the Health and Human Services system. Once a rate is established, the contracting area incorporates the rate into appropriate contracts. The IDD Contract Management Unit will incorporate approved indirect cost rates into contracts that include federal awards. SSBG/MHBG – Behavioral Health Services’ pass-through agreements effective September 1, 2023 include 2 CFR §200.332 requirements. Implementation dates: TANF – August 31, 2025 SSBG/MHBG – September 1, 2023 Responsible persons: TANF – Chad Pomerleau, Director, IDD Services & PASRR Contract Management Unit SSBG/MHBG – Roderick Swan, Associate Commissioner, Behavioral Health Contract Operations

Corrective action plan: SRM has added all AEL subrecipients to its Monitoring Year 2024 mid-year risk assessment. They will be included in the Monitoring Year 2025 risk assessment and all annual and mid-year risk assessments going forward. Implementation date: January 23, 2024 Responsible persons: Mary Millan, Deputy Director, SRM, Division of Fraud Deterrence and Compliance Monitoring.

Corrective action plan: To address the error, CMSM will add an additional layer of review for the Master Planning Summary (MPS) to be performed by the director of compliance subrecipient monitoring. In addition the MPS will be periodically provided to affected Program divisions for review. Implementation date: March 1, 2024 Responsible person: Earnest Hunt, Director of Compliance Subrecipient Monitoring

The Management Council will implement the following corrective actions: • Procedures will be put in place to analyze federal awards to properly determine whether expected disbursements should be categorized as subawards. • Policies and procedures will be put in place to properly administer the subawards and monitor the subrecipients activity to ensure that grant requirements are being met.

New Directions, Cash Grants The Office of Income Maintenance (OIM) is determining how it can incorporate onsite financial monitoring into the monitoring that is currently being conducted. This includes consideration of the specific areas the financial monitoring should cover and the scope of the monitoring. After OIM develops the monitoring procedures, OIM will start the onsite monitoring. Anticipated Completion Date: 12/31/2024 Contact Name: Joel O’Donnell, Dir., Bureau of Program Support, OIM Real Alternatives Despite repeated attempts and efforts by the Office of Policy Development (OPD) to engage Real Alternatives in ongoing monitoring activities, as well as monitoring after the end of the grant for previous years, the grantee was uncooperative and unresponsive to our requests and therefore regular monitoring was not completed. Effective December 31, 2023, the Department of Human Services’ grant agreement with Real Alternatives ended and was not renewed. Anticipated Completion Date: Completed Contact Name: Jessica Schneider, Executive Policy Specialist I, Grants, OPD

On March 2, 2021, AMLR program representatives attended a Department of Interior, Office of Surface Mining Reclamation and Enforcement online training covering 2 CFR 200 and contractor or subrecipient determinations. DEP ceased issuing AMLR grants under Management Directive 305.20, Grant Administration. DEP management has determined the recipients with existing agreements are subrecipients and DEP will follow this determination consistently with future agreements and accounting. DEP has developed written policies and procedures for subrecipient monitoring and has notified grantees to implement the policies and procedures immediately to ensure timely subrecipient compliance with federal regulations. On July 28, 2023, an audit resolution letter was issued by the Department of Interior, Office of Surface Mining Reclamation and Enforcement. To further address deficiencies, training for DEP Grant Managers was held on January 24, 2024, and January 31, 2024, to provide details and instruction on reporting requirements and proper documentation to ensure subrecipient compliance with federal regulations and DEP’s role in this compliance. Anticipated Completion Date: Completed Contact Names: Patrick Webb, Director, Bureau of Abandoned Mine Reclamation; Tim Golding, Exec. Assist., Office of Admin. and Management

PDA: For federal programs within the Food Distribution Cluster (ALNs 10.565, 10.568, and 10.569), PDA will put the following steps in place for (1) identifying the federal award information and applicable requirements and (2) evaluating each subrecipient’s risk of noncompliance as Required by the Uniform Grant Guidance. 1) PDA will ensure that FAIN numbers are now included in all new subaward agreements. (For currently existing agreements, PDA will send letters by June 30 to provide the FAIN and reiterate Single Audit requirements.) 2) For those subaward agreements that are permanent and/or cover multiple funding years, PDA will develop procedures to ensure that annual notices are sent to each subrecipient notifying them of the updated FAIN for their agreement and reminding them of the Single Audit requirements that are laid out in the terms of their initial signed agreement. 3) PDA will develop a process to evaluate each subrecipient’s risk of noncompliance with federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring. The evaluation will be based on Key Performance Indicators, such as leadership tenure; prior incidents of food spoilage; or qualitative feedback from clients served. If the evaluation determines that additional monitoring tools beyond the routine performance of on-site reviews of the subrecipient's program operations are necessary, such conditions will be laid out in a separate letter communication to the sub-awardee. Anticipated Completion Date: 06/30/2024 Contact Name: Caryn Long Earl, Director, Bureau of Food Assistance PDOA: PDOA will implement the following steps to evaluate each subrecipient’s risk of noncompliance as required by the uniform grant guidance. 1. Evaluation is ongoing for the impacted Aging Cluster programs. 2. A risk assessment is being developed to evaluate each subrecipient’s risk of noncompliance to proactively address any weaknesses in internal controls over federal programs. - Pointed questions regarding the Organization included to gauge management’s ability to follow all terms and conditions of the contract. - General Policies will be reviewed for adherence to all federal and state regulations and competence of personnel administering the programs. - Since multiple federal funding streams are involved, a fiscal component will also be administered to review internal controls for financial issues. 3. Performance check-ins are launching in April of 2024 as part of a statewide comprehensive monitoring as a new form of regulatory measure. 4. Follow-Up procedures resulting from this finding will be reviewed and adjusted as needed to deliver optimal outcomes. Preliminary procedures will be directed to the agency’s audit review committee for resolution of completeness. 5. In the event the audit review committee determines additional steps beyond the monitoring efforts outlined above are insufficient, additional efforts will be communicated to the AAA network. Anticipated Completion Date: 06/30/2024 Contact Name: Jennifer Cave, Fiscal Management Specialist, PDOA Audit Liaison DOH: DOH plans to develop and implement a robust subrecipient monitoring program which includes establishing a new section within the Budget Office pending enacted budget funds and complement to support the creation of the section. Initiative goals/milestones include: 1. Educate Department: Budget Office is developing a bulletin that will outline the subrecipient monitoring requirements with links to state and federal sources. The bulletin will be shared with all program office staff. The Budget Office will develop the following templates and provide to all program offices: - Determination of vendor status: Subrecipient or Contractor - Risk Assessment Form - Internal Control Self-Assessment for Subrecipient Template - Subrecipient Monitoring Template 2. Implementation of full compliance initiative: Recommendations provided in the assessment will be used to develop and implement comprehensive policies and procedures lead by a new section in the Budget Office. Anticipated Completion Dates: 1 - 03/31/2024; 2 - 03/31/2025 Contact Name: Andrea Race, CFO DHS: Foster Care 1. For the portion of the audit finding that indicates State Agencies Did Not Identify the Federal Award Information and Applicable Requirements at the Time of the Subaward. Beginning state fiscal year 2024-2025, OCYF will begin sending out the required information to the Foster Care non-profit contractor. 2. Separately, OCYF will be developing a risk assessment process for the Foster Care non-profit contractor in state fiscal year 2024-2025. Anticipated Completion Dates: 1 - 06/30/2024; 2 - 06/30/2025 Contact Name: Melissa Erazo, Director, Bureau of Budget and Fiscal Support TANF and SSBG Effective December 31, 2023, DHS’ grant contract with Real Alternatives ended. We have no contract for services with them going forward. Despite repeated attempts and efforts to engage this grantee in ongoing monitoring activities, as well as monitoring after the end of the grant for previous years, they were uncooperative and unresponsive to our requests and therefore regular monitoring was not completed. Due to the Covid-19 global pandemic as well as staff turnover and vacancies in the Office of Policy Development, regular monitoring of SSBG grant recipients was not performed on schedule. However, with the hiring of a full complement of staff for the DHS Policy Office, including a Grant Administrator, we are in the process of creating and implementing a robust monitoring plan for all 19 of our grantees for calendar year 2024, including risk assessments, in person monitoring, desk monitoring, data collection and analysis. Anticipated Completion Date: 12/31/2024 Contact Name: Jessica Schneider, Executive Policy Specialist I, Grants

PDA: PDA will be hiring a complement position to develop and maintain an audit tracking report to ensure that all single audits are properly logged and processed. In addition, this position will review the financial information in each audit report to determine if all pass-through funding is properly included and subject to audit. This position will coordinate with the bureaus within PDA to ensure all required follow-up is completed in a timely manner. Anticipated Completion Date: 06/30/2024 Contact Name: Tracee Gotwalt, Audit Coordinator PDOA: The PDOA is looking to improve management decision communications in addition to more thorough evaluations as a new Comprehensive Monitoring Process pilot is starting in April 2024 to address the noncompliance of subrecipient monitoring. This has resulted in management designing control activities to achieve timely submissions in the future by initiating the following: 1. An audit tracking log has been established to track report submissions, document when they were received, initiated, findings requiring follow-up, and subsequent steps to finalize the audit. 2. A separate tracking mechanism is in place to ensure the monitoring of subrecipient activities for compliance with federal statutes, regulations, and the terms and conditions of the Agreement for the 52 Area Agency on Aging subrecipients. 3. PDOA is looking to fill a vacant position with a focus of tracking subrecipient expenditures in the aggregate and tracks Single Audit submissions on a Commonwealth wide basis since the Aging Cluster is material and has material sub-granted expenditures. 4. Since receiving the finding, PDOA has reached out to the resource account where Subrecipient Single Audit reports are received by the Federal Audit Clearinghouse (FAC) to verify all outstanding audit items for PDOA, as action is required within six months of receipt. 5. It is PDOAs impression that having increased oversight of the Schedule of Expenditures of Federal Awards (SEFA) will allow for timely dissemination of Management Decision Letters (MDL) in the six-month timeframe for making a management decision for federal award findings. 6. Additionally, PDOA will confirm a closure letter was sent to the Philadelphia Corporation for Aging documenting PDOA’s management decision regarding federal award findings, as included in their FYE 06/30/2021 Single Audit report. 7. Follow-Up procedures resulting from this finding will be reviewed and adjusted as needed to deliver optimal outcomes. Preliminary procedures will be directed to the agency’s audit review committee for resolution of completeness. 8. In the event the audit review committee determines additional steps beyond the monitoring efforts outlined above are insufficient, additional efforts will be communicated to the AAA network. Anticipated Completion Date: 06/30/2024 Contact Name: Jennifer Cave, Fiscal Management Specialist, PDOA Audit Liaison DOH: DOH’s subrecipient single audit tracking report now includes a mechanism to monitor management decision deadlines related to each entity’s FAC submission date. The process for tracking subrecipient audit reports with findings has been updated to include and highlight subrecipients’ audit reports where DOH is the lead agency for finding resolution or the report contains findings that relate to the Department. Anticipated Completion Date: 03/31/2024 Contact Name: Steven Marsden, Chief, Audit Resolution Section PDE: PDE has implemented weekly, monthly and quarterly checks to ensure that all single audits are properly logged and processed. The clerk typist will conduct a weekly review and provide confirmation to the audit coordinator by signature. Bi-weekly, the clerk typist will follow up on any single audits that remain open. Anticipated Completion Date: Completed Contact Names: Clayton Carroll, Audit Coordinator, Bureau of Budget & Fiscal Management; Jessica Sites, Director, Bureau of Budget & Fiscal Management

Program: AL 21.027 – COVID-19 – Coronavirus State and Local Fiscal Recovery Funds – Allowability & Subrecipient Monitoring Corrective Action Plan: Payments to Developmental Disability Providers, Assisted-Living Facilities, and Nursing Facilities for Employee Retention and Recruitment: DHHS is in the process of obtaining affidavits from all Developmental Disability Providers, Assisted-Living Facilities, and Nursing Facilities who received payments under LB1014 stating that funds were used for allowable purposes. Premium Pay: We do not believe any corrective action is warranted as our files were corrected with the Auditor’s guidance and assistance in accordance with all CSLFRF eligibility requirements. Assistance to Nonprofits: For Shovel-Ready awards that have already been granted, DED will confirm prior to close-out of the grant that there is sufficient supporting documentation showing the awardee suffered a harm related and reasonably proportional to the award. Sufficient supporting documents must prove that the nonprofits suffered an economic harm, such as a decrease in revenue or an increase in expenses due to COVID-19. The evidence may include but is not limited to: • Profit and loss statements showing a decrease in revenue or an increase in expenses • Audited financial statements showing a decrease in review or an increase in expenses • Change in a line of credit • Increase in costs for projects related to COVID-19, such as construction cost data, • Decrease in written pledges related to COVID-19 • Decrease in donations related to COVID-19 • Historical fundraising comparisons University of Nebraska: The University project is ongoing. In the next six months, Military/NEMA will initiate monitoring activities to include the review and validation of expenditures for allowability as required under 2 C.F.R. part 200. Nursing Scholarships: DHHS’ current internal controls for the Nursing Scholarship program have minimized the risk of fraud as they correctly identified this case of fraud and have identified others prior to any payment being made. DHHS will continue to review payments for the Nursing Scholarship program, which uncovered the $5,000 identified in the finding. Contact: Payments to Developmental Disability Providers, Assisted-Living Facilities, and Nursing Facilities for Employee Retention and Recruitment: Heather Arnold, CPA, CFE DHHS Deputy Director of Financial Services Premium Pay: Nicole Zimmerman, Finance Director Assistance to Nonprofits: Audrey Sautter, DED Compliance Team Manager University of Nebraska: Erv Portis, Assistant Director-Nebraska Emergency Management Agency (NEMA) Nursing Scholarships: Heather Arnold, CPA, CFE DHHS Deputy Director of Financial Services Anticipated Completion Date: Payments to Developmental Disability Providers, Assisted-Living Facilities, and Nursing Facilities for Employee Retention and Recruitment: June 2025 Premium Pay: N/A Assistance to Nonprofits: DED will draft a policy to place the above into effect within the next 7 days. University of Nebraska: July 2024 Nursing Scholarships: June 2025

Program: AL 20.509 – Formula Grants for Rural Areas – Subrecipient Monitoring Corrective Action Plan: NDOT updated the supplemental agreement template to include the Federal Award Identification information, including Federal award date and subaward period of performance start and end dates. A draft template has been provided to the APA. Current 5311 agreements are effective July 1, 2024 to June 30, 2025, when additional supplemental agreements are needed, the updated template which includes FAIN information will be provided to the subrecipients. Contact: Jodi Gibson Anticipated Completion Date: Complete

Program: AL 20.509 – Formula Grants for Rural Areas – Allowability & Subrecipient Monitoring Corrective Action Plan: NDOT recently updated the Invoicing Reimbursement Acceptable Documentation Requirement Guidelines. These guidelines offer comprehensive instruction, best practices, and a clearer definition of allowable expenses for subrecipients. The updated guide was distributed to subrecipients in February 2024. Over the next six months, NDOT plans to conduct additional training sessions through opportunities such as the monthly Transit Manager meetings, on-site visits, or webinars with subrecipients. The objective is to ensure a thorough understanding of required documentation and the identification of eligible federal reimbursement expenses. To assist with transit subrecipient monitoring, NDOT management has designated an internal auditor within the Transit Section. The auditor’s focus will be assessing reimbursement documentation, reviewing time studies, evaluating cost allocation plans, developing risk assessment, and helping to intensify monitoring efforts over all subrecipients. NDOT is also in the process of improving and updating the invoice review process to provide consistency for reviewing and approving invoices to enhance accuracy within the Transit Section. Additionally, NDOT has established a dedicated unit “Financial Oversight” within the Transit Section solely focusing on Subrecipient reimbursements. The four staff members in this unit will report directly to Financial Aid Administrator III, this oversight will enhance the quality checks and consistency among subrecipient reimbursements. The Financial Oversight unit will continue to evaluate and refine the operations to ensure federal regulation and required documentation is in place prior to any subrecipient reimbursement. Contact: Jodi Gibson Anticipated Completion Date: On-going

Program: AL 97.036 – Disaster Grants - Public Assistance (Presidentially Declared Disasters) – Subrecipient Monitoring Corrective Action Plan: The Agency’s top priority is to respond to its vacancy needs by continuing working with department Human Resources to find, hire, and train viable candidates who can perform these important functions. Contact: Erv Portis Anticipated Completion Date: Ongoing

Program: AL 84.287 – Twenty-First Century Community Learning Centers – Subrecipient Monitoring Corrective Action Plan: The NDE was provided written guidance from the U.S. Department of Education (USED) regarding source documentation required for the NDE’s review of preliminary documentation required to make payment whereas this effort is not associated with the NDE’s Grant Compliance Section performing the fiscal monitoring activities applying the required pass-through activities contained within 2 CFR 200.332. To make payment, the USED guidance states, “Uniform Guidance does not require the NDE to obtain specific source documentation from its subrecipient prior to making payments and the NDE’s Grant Guidance states that for certain reimbursement requests, such as credit card purchases, travel expenses, and personal reimbursements, subrecipient are always required to submit supporting documentation. For other expenditures, including personnel costs, and time and effort certification, supporting documents need to be retained by the subrecipient for at least three years and must be available for auditing and monitoring purposes”. For the reimbursement request tested to make payment, additional source documentation was acquired from the subrecipient upon the APA’s request and submitted for review on March 1, 2024. Contact: Jen Utemark, Administrator, Office of Budget & Grants Management Anticipated Completion Date: March 1, 2024

Program: Various, including AL 84.027 – Special Education Grants to States; AL 84.173 – COVID-19 Special Education Preschool Grants; AL 84.425D – COVID-19 Education Stabilization Fund – Elementary and Secondary School Emergency Relief Fund (ESSER I and ESSER II); AL 84.425U – COVID-19 Education Stabilization Fund – American Rescue Plan – Elementary and Secondary School Emergency Relief Fund (ARP ESSER) – Subrecipient Monitoring Corrective Action Plan: First SPED subrecipient – As education subrecipients have had a significant influx of subawards to mitigate post-COVID supports for Nebraska education with limited staff capacity, the Department has remained mindful of these conditions and is on schedule to complete its annual fiscal monitoring efforts within the normal timelines afforded each year. Second SPED subrecipient – Because the UNL utilizes PVS as allowed by 2 CFR 200.430 in regard to salary and wage benefit costs for employees working on a project under a contractual grant agreement, the NDE going forward will require PVS supporting documentation be submitted as a minimum semi-annually for each contract to verify the salary and benefit costs being requested for reimbursement as recommended by the U.S. Department of Education beginning with any payments occurring after March 1, 2023. Third SPED subrecipient – The documentation to support the review of purchased services and supplies during fiscal monitoring was provided to the APA on March 4, 2024. Single Audits – The Director of Grants Management and Director of Grants Compliance will work collaboratively to ensure all subrecipient audits are reviewed and applicable management decision letters are issued within the requested timeframe. Contact: Jen Utemark, Administrator, Office of Budget & Grants Management Anticipated Completion Date: July 1, 2024

2023-001 Program: Foster Care Federal Financial Assistance Listing Number: 93.658 Federal Grantor: U.S. Department of Health and Human Services Pass-Through: California Department of Social Services Award No. and Year: 2301CAFOST and 2023, 2201CAFOST and 2022 Compliance Requirements: Subrecipient Monitoring Type of Finding: Material Weakness in Internal Control over Compliance and Material Instance of Noncompliance Criteria: In accordance with Title 2 U.S. Code of Federal Regulations (CFR) 200.332, pass-through entities must comply with the following: • 2 CFR Part 200.332(a), Requirements for Pass-Through Entities, states that all pass- through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes certain information as well as all the requirements imposed by the pass-through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award. • 2 CFR 200.332(b) – Evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors listed in 2 CFR 200.332(b)(1) through (4). • 2 CFR 200.332(d) – 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. Pass-through entity monitoring of the subrecipient must include the information at 2 CFR 200.332(d)(1) through (4). • 2 CFR 200.332(f) – Verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipient’s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 200.501. The California Department of Social Services further clarifies in its County Fiscal Letter No. 22/23- 91 that Foster Family Agency (FFA), Group Home, and Short Term Residential Therapeutic Programs (STRTP) are “considered subrecipients and subject to the same audit requirements and require the same degree of oversight as other subrecipients”. Further, while there are some licensing and oversight functions performed by the state over FFAs, group homes, and STRTPs, “counties are still ultimately responsible for review of these audits and their findings, any follow- up to ensure compliance, and any other form of monitoring and oversight required by federal and state laws and regulations.” 2 CFR Section 180.300a, Responsibilities of Participants Regarding Doing Business with Other Persons (and repeated in the California Department of Social Services - County Fiscal Letter No. 21/22 – 115) counties are required to verify that recipients or contracts have not been suspended or debarred by using the federal SAM (Systems for Award Management). Condition: The Social Services Agency (SSA) did not have any formal controls in place for evaluating each subrecipient’s risk of noncompliance or the purpose of determining the appropriate subrecipient monitoring or for subrecipient monitoring for the Foster Care program. Additionally, the following information was not provided at the time of the subaward for ten (10) of fourteen (14) subawards selected for testing from the SSA’s for the Foster Care program: • Subrecipient’s unique entity identifier • Federal award identification number • Federal award date of award to recipient by the Federal agency • Subaward period of performance • Amount of federal funds obligated to the subrecipient • Amount of federal funds committed to the subrecipient • Federal award project description • Name of federal awarding agency • CFDA/Assistance Listing number • Identification of whether the award is research and development • Indirect cost rate During our testing, we noted for four (4) of fourteen (14) subrecipients selected, SSA did not have documentation that the SAM clearance was performed prior to entering the contract with the subrecipient. The County’s policy was to verify the subrecipient was not suspended or debarred prior to entering the contract, but the County did not retain evidence of this check prior to entering the contract. Cause: The SSA’s procedures did not consistently ensure that the required award information and applicable requires were communicated to the subrecipients. The SSA did not follow their procedures to evaluate the risk of noncompliance or monitor the activities of each subrecipient, and the SSA did not maintain documentation of their verification that every subrecipient is audited, as required. Additionally, the SSA department did not follow their policy to retain documentation of the verification of the information prior to entering the contract. Effect: The County’s control policies were not consistently followed which require compliance with the Subrecipient Monitoring requirements in 2 CFR 200.332 and did not comply with subrecipient monitoring requirements related to the program. Additionally, the County’s control policies were not consistently followed, which required documentation of the verification prior to entering the contract. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of fourteen (14) out of seventy (70) subrecipients were sampled, which included seven (7) FFA, and seven (7) STRTP types. The condition noted above was identified during our procedures related to subrecipient monitoring and was pervasive to the program. Repeat Findings from Prior Years: Yes, Finding 2022-002,2022-005 and 2022-006. Recommendation: We recommend that the County adhere to their policies and procedures in accordance with 2 CFR 200.332 to ensure compliance with subrecipient monitoring requirements. We recommend that the County adhere to their procedures requiring documentation of the SAM clearance prior to entering the contract. Management Response and Corrective Action: Social Services Agency: 1. Person Responsible: Kristi Fiskum, Human Services Deputy Director and Karen Vu, Procurement Contract Manager, Senior 2. Corrective Action Plan: SSA has revised its Subrecipient Monitoring Policy in accordance with 2 CFR 200.332 to ensure compliance with subrecipient monitoring requirements and the updated policy was implemented in September 2023. A check list has been developed to track monitoring requirements and was also implemented in September 2023. 3. Anticipated Implementation Date: Fully implemented as of September 2023