Corrective Action Plans

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

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