Corrective Action Plans

Finding Number 2023-096 Subject Heading (Financial) or AL no. and program name (Federal) ALN: 21.019 Federal Program name: Coronavirus Relief Fund (CRF) Planned Corrective Action The State agrees with this finding. Within OMES, oversight and management of Federal grants has been transferred to the OMES Grant Management Office (OMES-GMO) which is staffed with individuals with several years of grant experience. OMES-GMO has a multi-level system of internal controls for grant management and oversight that includes routine monitoring, desk review, and site visits for all projects and associated project/administrative expenditures to ensure allowability, accuracy, and assist in the detection of fraud. Finally, OMES Finance has developed processes which provide for a more thorough coding of expenditures and proper review of expenditures when reporting on their GAAP Z. The State disagrees with the finding. The State had two Grant Award Notifications in place with the Boys and Girls Club which reflects the monies awarded to be used on the capital improvements and Club on the Go Mobile Clubhouses. This indicates the funds were obligated during the covered period. Per the email from the Keri for Jill Geiger Consulting, no signatures on the GANs were required and the Uniform Guidance does not require the GAN to be signed. Anticipated Completion Date September 2022 Responsible Contact Person Brandy Manek

Finding Number 2023-013 Subject Heading (Financial) or AL no. and program name (Federal) 20.509 - Formula Grants for Rural Areas Planned Corrective Action We concur with the auditor’s recommendation. OMPT—We will develop and implement risk assessments as part of our sub-recipient monitoring process and revise existing procedures related to single audits. Lastly, we will meet with Internal Audit, formerly CWO, to establish a process to ensure audit reviews are documented and received. Internal Audit - Unfortunately the issues that occurred in last year’s audit, also effected the transactions selected in this year’s audit. It should be noted that 6 of the 11 missing files were provided to SA&I, however most of those audits were not performed in a timely manner. After the finding last year many changes were implemented in the Audit Office, including a change in management of the Grants and Contract Auditing area. A Smartsheet application is in now in use that allows OMPT to check on the status of audits at any time. We also have done extensive cross training on these single audit reviews and we are currently performing these audits in a timely manner as they come in. Anticipated Completion Date 7/1/2025 Responsible Contact Person OMPT - Eric Rose/Bobby Parkinson Anne Antonelli, Internal Audit – Holly Lowe

Finding Number: 2023-045 Finding Name: Inadequate Monitoring of 21st Century Subrecipients Finding Condition(s): The Illinois State Board of Education (ISBE) did not adequately monitor and document program monitoring procedures performed over subrecipients of the 21st Century Community Learning Centers (21st Century) program. Additionally, ISBE did not follow its subrecipient monitoring procedures during the year ended June 30, 2023. Finally, ISBE’s controls for monitoring are not designed at an appropriate level of precision to ensure monitoring of subrecipients is completed as required. Name of Contact Person(s): Ryan Levin, Supervisor; 21st Century Community Learning Centers (CCLC) State Education Agency Coordinator – Illinois State Board of Education, Wellness and Student Care Management Department Corrective Action(s): To ensure that 21st Century Community Learning Centers (21st CCLC) subgrantees’ progress and performance are monitored in accordance with 2 CFR 200.331(d), 2 CFR 200.331(b) and 2 CFR 200.303, Wellness and Student Care Management Department and the 21st CCLC team will develop processes and structures to facilitate the procedures, protocols, and efficacy of subgrantee monitoring. Components of this work will include, but not be limited to: • Evaluating and revising the program’s subgrantee risk analysis procedures and tools to ensure that they are relevant and accurately reflect the items/actions that suggest higher levels of subgrantee risk (2 CFR 200.331(b)). • Reviewing and revising the procedures and/or documentation that is collected for all three tiers of subgrantee monitoring to ensure that all processes are relevant; are not simply perfunctory; ensure compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that the subaward performance goals are achieved (2 CFR 200.331(d)). • Establishing and implementing specific processes and protocols to ensure that all components of subgrantee monitoring are timely, that management reviews and provides approval for key components of the process, and that accurate and complete documentation is produced and maintained (2 CFR 200.303). Proposed Completion Date: December 31, 2025

Finding Number: 2023-035 Finding Name: Inadequate Fiscal Monitoring of Subrecipients Finding Condition(s): The Illinois Criminal Justice Information Authority (ICJIA) did not follow its established policies and procedures for monitoring subrecipients of the Crime Victim Assistance (CVA) program. Name of Contact Person(s): Hemant Modi, Chief Fiscal Officer – Illinois Criminal Justice Information Authority, Office of Fiscal Management Corrective Action(s): ICJIA will update its risk assessment policy to provide more clarity on the monitoring procedures, including the additional factors used to prioritize audits, performed to ensure proper fiscal oversight. Proposed Completion Date: June 30, 2025 – Completed

Finding Number: 2023-034 Finding Name: Inadequate Review of Subrecipient Single Audit Reports Finding Condition(s): The Illinois Criminal Justice Information Authority (ICJIA) did not adequately review single audit reports received from its subrecipients for the Crime Victim Assistance Program (CVA) program on a timely basis. Name of Contact Person(s): • Hemant Modi, Chief Fiscal Officer – Illinois Criminal Justice Information Authority, Office of Fiscal Management • Karen Crawford, Chief Grantee Auditor – Illinois Criminal Justice Information Authority, Office of Fiscal Management Corrective Action(s): By December 31, 2024, ICJIA hired and trained an individual to focus on the State’s Grant Accountability and Transparency Act (GATA) requirements over ICJIA’s reviews of its subrecipients’ single audit reports. Proposed Completion Date: December 31, 2024 – Completed

Finding Number: 2023-033 Finding Name: Failure to Adequately Monitor Subrecipients Finding Condition(s): The Illinois Criminal Justice Information Authority (ICJIA) did not follow its established program monitoring policies and procedures for subrecipients of the Crime Victim Assistance (CVA) program for fiscal year 2023. Name of Contact Person(s): Greg Stevens, Director – Illinois Criminal Justice Information Authority, Federal and State Grants Unit Corrective Action(s): ICJIA will increase its headcount with 20 additional staff members to expand ICJIA’s monitoring capabilities of the Federal and State Grants Unit. Proposed Completion Date: June 30, 2025 – Completed

Finding Number: 2023-030 Finding Name: Failure to Communicate Award Information to Subrecipients Finding Condition(s): The Illinois Department of Commerce and Economic Opportunity (DCEO) did not follow its established policies and procedures for monitoring subrecipients of the Low-Income Home Energy Assistance Program (LIHEAP). Name of Contact Person(s): Ben Moore, Fiscal Operations Manager – Illinois Department of Commerce and Economic Opportunity, Office of Community Assistance Corrective Action(s): There is currently a process in place to enter the correct Federal Award Identification Number (FAIN) from the federal award notice into the DCEO’s e-Grants system, which populates into all grant agreements created and issued for that grant series. To ensure the correct FAIN is entered, the Office of Community Assistance (OCA) added a step in its grant series establishment process to verify that the correct FAIN is entered into e-Grants prior to any grants being issued from that award. Proposed Completion Date: February 25, 2025 – Completed

Finding Number: 2023-018 Finding Name: Inadequate Monitoring of Subrecipients of the CSLFRF and ERA Programs Finding Condition(s): The Illinois Department of Human Services (IDHS) did not obtain and review periodic performance reports for subrecipients of the COVID-19 – Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) and the Emergency Rental Assistance (ERA) and programs. Name of Contact Person(s): Joseph Wellbaum, Chief Financial Officer – Illinois Department of Human Services Corrective Action(s): The IDHS will develop an organized process to ensure the availability of performance monitoring reports to comply with information requests. Proposed Completion Date: July 1, 2025 – Completed

Finding Number: 2023-015 Finding Name: Inadequate Review of Subrecipient Single Audit Reports Finding Condition(s): The Illinois Department of Human Services (IDHS) did not adequately review single audit reports received from its subrecipients for the Special Supplemental Nutrition Program for Women, Infants, and Children (WIC) programs, the Temporary Assistance for Needy Families Cluster (TANF), the CCDF Cluster (CCDF), the Social Services Block Grant (SSBG), and the Block Grants for Prevention and Treatment of Substance Abuse (SAPT) programs on a timely basis. Additionally, the IDHS has not established controls over subrecipient single audit report reviews at an adequate level of precision to ensure single audit reports are received and reviewed timely. Name of Contact Person(s): Brian Bond, Director – Illinois Department of Human Services, Office of Contract Administration Corrective Action(s): The IDHS’ Office of Contract Administration (OCA) staff will meet to coordinate and establish procedures to ensure subrecipient single audit reports are obtained and reviewed within established deadlines. On March 31, 2025, the OCA began to use its IDHS-OCA Procedures for Grantee Extensions of Audit Package Submissions. Proposed Completion Date: June 30, 2025 – Completed

Finding Number: 2023-010 Finding Name: Failure to Follow Established Program Subrecipient Monitoring Procedures Finding Condition(s): The Illinois Department of Human Services (IDHS) did not follow its established program monitoring policies and procedures for subrecipients of the Temporary Assistance for Needy Families (TANF) Cluster, the Childcare Cluster (CCDF), the Social Services Block Grant (SSBG), and the Block Grants for Prevention and Treatment of Substance Abuse (SAPT) programs. More specifically, the IDHS did not perform on-site monitoring reviews of subrecipients in fiscal year 2023 in accordance with IDHS’ planned monitoring schedule and/or could not provide support for the review, did not provide timely notification (within 60 days) of the results of the programmatic on-site reviews, did not complete its quality reviews on a timely basis (within 60 days), did not receive corrective action plans from subrecipients after findings were identified during the reviews, and was unable to provide documentation evidencing monitoring of the quarterly program reports. Name of Contact Person(s): • Elizabth Lusk, Social Service Program Planner – Illinois Department of Human Services, Division of Family and Community Services • Christina Miller, Fund Disbursement Manager – Illinois Department of Human Services, Division of Substance Use, Prevention, and Recovery Corrective Action(s): IDHS - Division of Family and Community Services (FCS) FCS Associate Directors, in conjunction with staff from the Director’s Office, met and reviewed exceptions noted in the fiscal year 2022 single audit to determine any need for updated documentation and communication regarding subrecipient programmatic monitoring. The FCS reviewed the FCS Programmatic Monitoring Guidance Document and made necessary updates. IDHS - Division of Substance Use Prevention and Recovery (SUPR) The SUPR will hire an administrative assistant to assist with compliance monitoring tracking activities to maintain communication about important deadlines. The SUPR will also hire compliance monitors to engage in conducting compliance reviews. Additionally, the SUPR will meet weekly to track monitoring activities to ensure deadlines are met. Finally, the SUPR will review its policy and procedures to assess timelines associated with the monitoring process. Proposed Completion Date: • July 29, 2024 – Completed (FCS) • December 31, 2025 (SUPR)

Finding Number: 2023-004 Finding Name: Failure to Establish Subrecipient Monitoring Procedures Finding Condition(s): The Illinois Department of Human Services (IDHS) did not perform a risk assessment or subrecipient monitoring procedures for the subrecipient of the COVID-19 – Homeowner Assistance Fund (HAF) program. Name of Contact Person(s): Joseph Wellbaum, Chief Financial Officer – Illinois Department of Human Services Corrective Action(s): On September 10, 2024, the IDHS completed a fiscal and administrative review of the Illinois Housing Development Authority. Additionally, on March 5, 2024, the IDHS will complete a thorough programmatic review of the HAF program. Proposed Completion Date: September 10, 2024 – Completed

Finding Number: 2023-002 Finding Name: Inadequate Monitoring of Subrecipient Single Audit Reviews Finding Condition(s): The State of Illinois did not establish adequate controls to monitor the completion and documentation of the single audit reports reviews for its subrecipients of the Special Supplemental Nutrition Program for Women, Infants, and Children (WIC), Child and Adult Care Food Program (CACFP), Crime Victims Assistance Program (CVA), WIOA Cluster (WIOA), Highway and Planning Construction (Highway), Emergency Rental Assistance Program (ERAP), Homeowner Assistance Fund Program (HAF), Coronavirus State and Local Fiscal Recovery Funds (SLFRF), Twenty-First Century Community Learning Centers (Twenty-First), Title I Grants to Local Education Agencies (Title I), Supporting Effective Instruction State Grants (SEISG), Education Stabilization Funds (ESF), Epidemiology and Laboratory Capacity for Infectious Diseases (ELC), Temporary Assistance for Needy Families Cluster (TANF), Child Support Enforcement (CSE), Low-Income Home Energy Assistance Program (LIHEAP), CCDF Cluster (CCDF), Social Services Block Grant (SSBG), and Block Grants for Prevention and Treatment of Substance Abuse (SAPT) in the State's Grant Accountability and Transparency Act (GATA) Audit Report Review Management System (ARRMS). Name of Contact Person(s): Keyria Rodgers, Grant Accountability and Transparency Unit Director – Illinois Governor’s Office of Management and Budget Corrective Action(s): The Grant Accountability and Transparency Unit (GATU) provides a centralized, uniform process and a system which State grant-making agencies are required to adhere to throughout the life cycle of the grant. The Illinois Governor’s Office of Management and Budget (GOMB) will develop and implement monitoring procedures to ensure the system is updated by agencies and accurate as to the completeness of the agencies’ report reviews, letter issuances, and desk reviews. Proposed Completion Date: December 31, 2025

Finding 2023-041 Program Information Program Name: Child Support Enforcement CFDA Number: 93.563 Summary of Finding Subrecipient Monitoring Significant Deficiency in Internal Control over Compliance Agency Response Agency agrees with this finding. Corrective Action Plan DSS contracts staff will formally communicate to the Child Support Enforcement (CSEP) Chief the annual requirement to update the Subrecipient Federal Award Funding attachment with the current FAIN and Federal Grant Award date. A structured follow-up process will be implemented to confirm timely completion of the updated template and distribution to both the Subrecipient and DSS contracts staff for official records. These procedures will ensure that all subawards consistently include the required elements. Contact Person(s) Responsible Karen Stoycoff, Social Services Program Specialist Phone: 775-684-7436 Email: kstoycoff@dss.nv.gov Anticipated Completion Date September 30th, 2025.

Finding Number 2023-002 Contact Person(s): Brianna Mariani – BriannaMariani@housinghope.org Kathryn Opina - KathrynOpina@housinghope.org Explanation and specific reasons for disagreement with the audit finding or that corrective action is not required (if applicable): N/A Corrective action planned: This was the first and only grant Housing Hope has administered that required subrecipient monitoring. The grant has since ended and the organization does not anticipate entering any future agreements that would require subrecipient monitoring. To ensure compliance should such an agreement arise again, Housing Hope will adopt a Subrecipient Monitoring Policy. This policy will outline the criteria for identifying subrecipient relationships and establish a standardized process for monitoring subrecipients, if any are engaged in the future. Anticipated completion date: The Subrecipient Monitoring Policy will be adopted by October 2025 Board meeting.

2023-002 Compliance and Internal Controls over Subrecipient Fiscal Monitoring (Significant Deficiency) Corrective Action: In accordance with 2 CFR Section 200.332, The Resource Group as the pass-through entity will ensure subrecipient fiscal monitoring is completed in 2024 to ensure compliance with federal and state requirements. The Finance Director is responsible for oversight and administration of fiscal monitoring. Fiscal monitoring will be conducted at least annually in accordance with HRSA Monitoring Standards 45 CFR 74.51 and 45 CFR 75.352. As a pass-through entity, fiscal monitoring will include at minimum reviews of financial performance and compliance with federal and state statues, regulations and terms and conditions. The process will include desktop/remote verification of applicable financial policy and procedures and an onsite review. A standardized monitoring tool will be used to evaluate financial compliance. The fiscal monitoring observations will result in a monitoring report, disseminated to the subrecipient within 60 days of the onsite review. Progress to date: 1. To support the financial monitoring efforts, technical assistance was received on February 5-7, 2024, from the DSHS Fiscal Support and Oversight Department. The primary objective of the visit was to discuss financial monitoring requirements as it applies to state and federal regulations, statues and terms and conditions. The standardized monitoring tool was also evaluated for compliance. 2. The Finance Director developed and implemented a comprehensive fiscal monitoring schedule for calendar year 2024. In alignment with strengthened oversight practices, onsite fiscal reviews of subrecipients commenced in February 2024. As part of the enhanced monitoring approach, the testing period for subrecipient fiscal reviews was expanded beyond the standard scope to include transactions and activities from both Fiscal Year 2022 and Fiscal Year 2023. 3. As of September 2024, the Finance Director completed 100% of fiscal monitoring visits. a. Support Documentation: to establish additional guidelines for fiscal monitoring, the Fiscal Monitoring Policy was drafted and approved by the Board on November 18, 2024. 3 Responsible Party: Finance Director, Garland Thompson Date Complete: November 18, 2024

The Board of County Commissioners, with the cooperation and participation of all elected officials, reviews, develops and implements policies and procedures to create a strong internal control environment. The Board of County Commissioners will work with all elected officials, the third-party administrator, and federal, state and local partners to develop policies, procedures, and internal controls designed to accurately track grants, including the application process, verification, oversight, and reporting of grant requirements. To assist in this process, the Board of County Commissioners engaged a third-party administrator to oversee the grant process, including application, eligibility, review, requirements, contracting, recipient tracking and oversight, and documentation and reporting. The Board of County Commissioners will work with the third-party administrator to ensure proper grant administration.

Planned Corrective Action: Update Financial Policies and Procedures to reflect language surrounding areas of deficiency, specifically listed in 2 CFR 200.332(b). New subrecipients awards will include: subrecipient’s unique entity identifier, federal award identification number, federal award date, assistance listing title, assistance listing number, dollar amount available under each federal award and assistance listing number at the time of disbursement, and approved indirect cost rate. Planned Implementation Date of Corrective Action: 7/14/25, will be included in Financial Policies revisions in December 2025. Person Responsible for Corrective Action: Director of Finance

Corrective Action Plan FINDING 2023-002 - Subrecipient Monitoring (Partially Repeated from Prior Year Findings 22-002, 21-003, 20-004, 19-005, 18-004, and 17-003) CONDITION: The Regional Office of Education #47’s internal controls over subrecipient monitoring do not include timely and adequate risk assessment procedures. Furthermore, the Regional Office of Education #47 did not properly monitor subrecipients in accordance with the Uniform Guidance standards. During audit testing procedures it was determined that ROE #47: McKinney Education for Homeless Children – for three (3) of three (3) subrecipients tested, ROE #47: • Did not evaluate the risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward. • Did not conduct subrecipient monitoring procedures during the year ended June 30, 2023. • Did not determine whether the subrecipient met the 2 CFR 200 Subpart F Audit requirements criteria for a single audit. COVID-19 ARP - McKinney Education for Homeless Children – for three (3) of three (3) subrecipients tested, ROE #47: • Did not identify the subaward and applicable requirements in the agreements. • Did not evaluate the risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward. • Did not conduct subrecipient monitoring procedures during the year ended June 30, 2023. • Did not determine whether the subrecipient met the 2 CFR 200 Subpart F Audit requirements criteria for a single audit. PLAN: Moving forward, The Regional Office will formally identify the subaward and applicable requirements in our agreements. We will conduct subrecipient monitoring procedures. We will determine if the subrecipient met the requirement criteria of 2 CFR 200 Subpart F Audit requirements for a single audit. ANTICIPATED DATE OF COMPLETION: Fiscal Year 2025 CONTACT PERSON: Mr. Chris Tennyson, Regional Superintendent for Lee, Ogle, and Whiteside Counties.

VIEWS OF RESPONSIBLE OFFICIALS ADSEF will provide training to personnel on the requirements and regulations related to subrecipient monitoring. Recommendation to management will be implemented, internal controls and compliance measures that allow for the identification, reporting, and monitoring of subrecipient activities Prevention Activities/TANF. IMPLEMENTATION DATE During Fiscal Year 2025-2026. RESPONSIBLE PERSON Administration for Socioeconomic Development of the Family (ADSEF, by its Spanish Acronym)

Finding 2023-001 Information on the federal program: Federal Agency: Department of the Treasury Pass-Through Entity: N/A – Direct Grant Federal Program: Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) Assistance Listing Number: 21.027 Compliance Requirement: Subrecipient Monitoring Audit Findings: Material Weakness, Noncompliance Condition: The City of Bloomington was unable to identify subrecipients of CSLFRF funding for the purposes of financial reporting and compliance with requirements under 2 CFR 200.332. The City could not distinguish between a subrecipient and a general vendor. Management misreported subrecipient activity on the SEFA, failed to include required contractual language for subrecipient awards in executed agreements, and did not perform monitoring procedures over the subrecipients management identified during audit testing procedures. Context: The 10 subrecipients represent approximately 18%, $1,025,070, of the total award expenditures of $5,590,828, in 2023. The condition reported was prevalent for each subrecipient participating in the award. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and will draft a policy and develop an internal controls process regarding subawards and the monitoring of subrecipients to ensure the compliance requirements are met. Responsible party and timeline for completion: The City’s Controller will be responsible for overseeing the implementation of the corrective action plan, which will be implemented starting during calendar year 2025.

Chairman of the Board of County Commissioners: Oklahoma County will comply with federal laws and regulations and grant agreements by creating award agreements that are designed and implemented to ensure Subrecipient Monitoring is performed. Anticipated Completion Date: 6/30/2025 Responsible Contact Person: Myles Davidson, BOCC Chairman

Statement of Condition: Compliance over subrecipient monitoring. Entity did identify the award and applicable requirements, however entity did not evaluate each subrecipient’s risk of noncompliance nor did it monitor subrecipient activities as listed in the contracts “Subaward Performance Reporting” and monitoring procedures per 2 CFR Sections 200.332 (b) and (d) through (f). Criteria: National Association of Wetland Managers’ internal control policies and procedures, and the Uniform Guidance 2 CFR Sections 200.332 (b) and (d)-(f). Cause: Management’s lack of understanding of criteria. Corrective Action Plan: Contact person: Marla Stelk, Executive Director Corrective action to be taken: NAWM will finalize and implement our subrecipient policies and procedures for current subawards, including documentation of how NAWM evaluated each subrecipient’s risk of noncompliance. NAWM will continue to monitor subrecipient activities through the grant period for each subaward as applicable. For future subawards, NAWM will evaluate and document each subrecipient’s risk of noncompliance and will monitor subrecipient activities as stated in our subrecipient policies and procedures. Anticipated completion date: End of current fiscal year (December 31, 2025)

Recommendation: We recommend the Center establish a formal monitoring process to review the activities on each of its recipients. This should include site visits, review of annual external audits when applicable and training when deemed necessary. Action Taken: Tri-County OIC has developed and begun implementing a comprehensive Sub recipient Monitoring Plan to ensure compliance and accountability. Actions taken include: Development of Sub recipient Monitoring Policies and Procedures, which outline expectations, responsibilities, and steps for oversight. Creation of a Sub recipient Risk Assessment Tool to categorize sub recipients based on risk level and determines appropriate monitoring frequency. Scheduling of Annual On-Site or Virtual Monitoring Visits, including programmatic and fiscal reviews. Formal Collection and Review of Annual External Audits or Financial Statements from sub recipients, as applicabie. Documentation Protocols to maintain records of all monitoring activities, communications, findings, and corrective actions. Anticipated Completion Date: May 31, 2025 Contact Person Responsible: Christina Johnson, Executive Director

Recommendation: We recommend the Center review its contracts against the criteria set forth in the Uniform Guidance to ensure that all sub-awards in the future contain the required information for subrecipients. Action Taken: Tri-County 010 has taken the following corrective steps: Reviewed and Updated the Subrecipient Contract Template to include all required elements as outlined in Pennsylvania Department of Education. Implemented a Pro-Award Contract Review Checklist to ensure each contract is verified for compliance prior to execution. Established a Documentation Process for storing all subrecipient agreements and related compliance materials in a centralized location. Anticipated Completion Date: March 31, 2025 Contact Person Responsible: Christina Johnson, Executive Director

Recommendation: CLA recommends adding a review and approval process for all the reimbursement requests and obtaining the support for the payments made in advance for the subawards and review whether subrecipient used the subaward for authorized purposes in compliance with federal statutes, regulations, and the terms and conditions of the subaward. Additionally, CLA recommends modifying the subaward agreements to include the award information required by CFR 200.332 (b). There is no disagreement with the audit finding. Action taken in response to finding: ICEDC appreciates the identification of a gap in subrecipient monitoring. In response, we are strengthening our monitoring procedures by implementing a formal subrecipient monitoring program. ICEDC will implement a formal review and approval process for all reimbursement requests and will enhance monitoring procedures to better assess utilization of the subaward funds for their intended, authorized purposes. This will include regular reviews of subrecipient activities and financial reports to ensure compliance with federal statutes, regulations, and the terms of the subaward. ICEDC will ensure subaward agreements include all necessary award information as required by CFR 200.332 (b). Name(s) of the contact person(s) responsible for corrective action: Kristina Hines Planned completion date for corrective action plan: 8/31/2025