Corrective Action Plans

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

The newly hired CFO has Federal Grant Compliance experience and will implement a process for identification and oversight of subrecipients in line with Uniform Guidance 2 CFR § 200.331. The Organization will ensure there are written policies to comply with this provision and will monitor its subrecipients on a quarterly basis and will obtain written agreements by and between the Organization and its subrecipients.

FINDING 2023-002 Finding Subject: COVID-19 – Education Stabilization Fund – Subrecipient Monitoring Summary of Finding: The School Corporation received and passed through to subrecipients $495,386 of ESF funds. The School Corporation is to clearly identify the award and applicable requirements to the subrecipients, evaluate the risk of noncompliance related to the subrecipients to determine appropriate monitoring of the subaward, and monitor the activities of the subrecipients to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. Contact Person Responsible for Corrective Action: Dr. Judi Hendrix, Director of WVEC and Michelle Cronk, CFO of West Lafayette Schools Contact Phone Number and Email Address: Dr. Judi Hendrix Michelle Cronk 765-894-0333 765-746-1602 judi.hendrix@esc5.k12.in.us cronkm@wl.k12.in.us Views of Responsible Officials: We concur with the finding regarding the informing and monitoring of subrecipients for federal grants. Description of Corrective Action Plan: We concur with the findings from the State Audit regarding the 3E grants funds; 2023-002. Our Corrective Action Plan would consist of the following:  Before ESF funds are dispersed to school districts (subrecipients), the WVEC Grant Director will ask districts for proper documentation such as receipts, college entrance letters, staff documented timesheets to support their request for funding.  The WVEC Grant Director will monitor the activities of the subrecipients to ensure that the financial subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals of the grant.  Once the school district’s information and documentation is received and approved, grant funding will be dispersed. Both the Service Center Executive Director and WVEC Grant Manager will approve and sign off on any payment made to a subrecipient.  On a biannual basis (periods ending June 30 and December 31), West Lafayette School Corporation will request the monitoring documentation from WVEC to ensure that proper monitoring is taking place. The WVEC Grant Director will create a sub-grantee reporting procedure:  Monthly spreadsheet with district allowable expense and sign off by Grant Manager, WVEC Executive Director and WVEC Treasurer approval.  This will take place every pay period to monitor the disbursement of any federal funds and to ensure that they are used for allowable expenditures under the grant.  This monitoring will begin in the month of March 2024 and continue until the end of the grant or Final Report, December 31, 2024. This procedure will also be used for other federal grants received.  On a biannual basis (periods ending June 30 and December 31), West Lafayette School Corporation will request the monitoring documentation from WVEC to ensure that proper monitoring is taking place. Anticipated Completion Date: Monthly monitoring will begin promptly (March 2024) and end with the final report of 3E grant activities on December 31, 2024.

Responsible Contact Person(s): Diana Clark, Associate Director Senior Corrective Action Planned: A spreadsheet to track monitoring activities by the BP SRM Coordinator was developed and implemented to ensure that Program Consultants adhere to the developed schedule. The BP SRM Coordinator reviews the completed audit documents to ensure that all required audit documents are uploaded to the system timely and that reviews are conducted in accordance with the SRM Plan. A SRM monitoring desk tool will be created for Practice Consultants as a quick reference to the SRM Plan. Training for all Program Consultants conducting SRM will be provided on the new updated monitoring plan as well as ongoing training for newly hired Program Consultants. Estimated Completion Date: 8/1/2023

Responsible Contact Person(s): Diana Clark, Associate Director Senior Corrective Action Planned: SRM for the TANF Federal grant program will be included in the SFY2024 SRM Plan. Inclusion of Risk Assessment criteria have been made and are being incorporated into the Monitoring Plan. Estimated Completion Date: 8/1/2023

Responsible Contact Person(s): Diana Clark, Associate Director Senior Corrective Action Planned: A risk assessment tool was developed as part of the State Fiscal Year 2024 SRM Plan and will be implemented with the new plan. Estimated Completion Date: 8/1/2023

Responsible Contact Person(s): Ross McDonald, Director of Compliance Ousman Kah, Subrecipient Monitoring Coordinator Corrective Action Planned: The final version of the agency's Monitoring Plan was completed. Estimated Completion Date: 8/1/2023

Responsible Contact Person(s): Ross McDonald, Director of Compliance Ousman Kah, Subrecipient Monitoring Coordinator Kevin Platea, Chief Information Officer Corrective Action Planned: A Grants Management solution is being pursued by DSS in anticipation that it can be deployed with Subrecipient Monitoring capabilities needed to comply with these requirements. A new budget request has been submitted for funding of a contingent Subrecipient Monitoring System solution. This will help bridge the deficiencies noted until an integrated permanent solution is implemented. Additionally, an interim solution is being considered where these subrecipients will be reviewed and tracked through a manual system. Estimated Completion Date: 3/31/2025

Responsible Contact Person(s): Ross McDonald, Director of Compliance Ousman Kah, Subrecipient Monitoring Coordinator Corrective Action Planned: A Grants Management solution is being pursued by DSS in anticipation that it can be deployed with Subrecipient Monitoring capabilities needed to comply with these requirements. A new budget request has been submitted for funding of a contingent Subrecipient Monitoring System solution. This will help bridge the deficiencies noted until an integrated permanent solution is implemented. Estimated Completion Date: 3/31/2025

Condition: The College did not have a control system in place to monitor performance measures as outlined in the subrecipient and grant agreements. The College was also not completing any site visits of the subrecipients or requiring annual financial reporting be submitted. Planned Corrective Action: Below are three items implemented to address the subrecipient monitoring requirement: 1. To address the finding of noncompliant subrecipient agreements, Grand Rapids Community College has implemented a new Grants Administration Guide. This guide can be found on the Grand Rapids Community College website. 2. To address the finding of lack of progress monitoring, subrecipient partners have been given monthly metric reports which include planned vs actual outcomes as a means of outlining their progress. The reports also include historical data for each category. This information is broken down by month and to be reviewed with subrecipients on a bi-weekly basis. This bi-weekly monitoring will provide oversight and help manage performance. Each grant partner will submit quarterly outreach plans that will be balanced against planned vs actual outcomes. These outreach plans will consist of detailed information highlighting the purpose of the event, target audiences, and updates from previous events. 3. To address the finding of lack of subrecipient monitoring, Grand Rapids Community College has scheduled formal site visits with subrecipients. Within the meetings they will discuss the following topics: Narrative Visit Overview, Financial Status Discussions, Metrics Verification, Narrative Overview, Participant Records and Revenue and Evaluation. Contact person responsible for corrective action: C. Dennis Triggs II- Program. Manager – One Workforce Grant. Anticipated Completion Date: 7/31/2023

FINDING 2023-001 Finding Subject: Research and Development Cluster – Subrecipient Monitoring Summary of Finding: Audit Finding 2023-001 states that Indiana State University did not have an effective internal control system in place in order to ensure that subrecipient Federal Audit Clearinghouse reports are reviewed in a timely manner for the Research & Development Cluster. Contact Person Responsible for Corrective Action: Hope Waldbieser, Executive Director of Finance Contact Phone Number and Email Address: 812-237-3524 - hope.waldbieser@indstate.edu Views of Responsible Officials: We concur with the finding that Indiana State University should have completed the Federal Audit Clearinghouse review in a more timely manner. Indiana State University conducted the required review, but it was completed later than allowed by the excerpt of 2 CFR 200.521(d) below. 2 CFR 200.521(d) states in part: “The federal awarding agency or pass-through entity responsible for issuing a management decision must do so within six months of acceptance of the audit report by the FAC. . . . “ Indiana State University did have other aspects of subrecipient monitoring in place related to the review of financial and programmatic reports for the subrecipients. Explanation and Reasons for Disagreement: Description of Corrective Action Plan: Effective January 2024, Indiana State University will update its Subrecipient Monitoring procedures in the following ways to ensure the Federal Audit Clearinghouse is reviewed in a timely manner and that appropriate documentation is maintained. 1. Subrecipient Federal Audit Clearinghouse reviews for prior fiscal year audits will be completed quarterly (July, October, January & April) during each fiscal year. The final Subrecipient Federal Audit Clearinghouse review for prior fiscal year audits will be completed in July after all current fiscal year payments have been made. 2. In order to ensure there is a segregation of duties the Office of Contracts & Grants Director will provide the Executive Director of Finance a report of the completed review each quarter including INDIANA STATE BOARD OF ACCOUNTS 20 the final review in July for their review and approval. The Executive Director of Finance will confirm the following: a. There is adequate documentation to support each quarterly review. b. Any deficiencies pertaining to the subrecipients Federal Audit Clearinghouse findings related to an award from Indiana State University are addressed in a timely manner. 3. Any identified issues during these reviews will be appropriately addressed by management as required by 2 CFR 200.332 and 2 CFR 200.521(d). Anticipated Completion Date: Indiana State University will ensure that the revised timeline for these procedures is in place during January 2024.