Corrective Action Plans

Landesa will revise its internal controls on subrecipient financial and programmatic monitoring by clarifying required documentation and recordkeeping procedures for all subrecipients on federal awards and the supervisory review process on compliance with subrecipient reporting requirements in the Subrecipient Monitoring Policy and the Engaging Third Parties guidance. Landesa will also clarify the procedures and appropriate timelines for resolving instances of significant non-compliance with the terms and conditions of a subaward by a subrecipient on federal awards. In the event a subrecipient does not comply with programmatic and financial reporting requirements, Landesa will seek resolution in a timely manner to either correct instances of non-compliance of subrecipient or terminate subaward if there is a failure to correct on part of the subrecipient. Landesa will provide training on revisions to the policy to all relevant staff by March 2024. The Director of Program Effectiveness will monitor staff implementation of the revised policy and procedures to ensure compliance with the revised policy. Director, Program Effectiveness and Anticipated completion date: March 2024

Applicable federal program: U. S. Department of Health and Human Services, Family Planning Services (Title X), Assistance Listing #93.217, Contract Number: FPHPA006521-01-00, Contract Year: 04/01/22 – 03/31/23 Condition and context: Of the four subrecipients tested, we found that WHFPT did not obtain and review the Single Audit reports for one subrecipient. Recommendation: Implement policies to obtain the single audit reports for all subrecipients to ensure compliance with federal requirements and, where findings are reported, ensure that the subrecipient has taken appropriate actions to remedy the finding. Planned corrective action plan: The Finance Compliance Department will request the single audit for each subrecipient in January of each calendar year for the purpose of identifying any single audit findings that required monitoring of federal grant monies. Any identified items from a single audit will be added to the Finance Compliance Department’s monitoring activities for the year. If a subrecipient fails to submit their single audit report within 30 days of the request, the Finance Compliance Department will retrieve the single audit report from the Federal Clearinghouse. Responsible officer: Danielle Owens; Chief Executive Officer Estimated completion date: January 31, 2024

Finding 2023-002 Federal Agency Name: US Department of Health & Human Services, California Department of Social Services Program Name: Child Care and Development Fund Cluster CFDA #93.575 Finding Summary: Material Weakness in internal Control and Material Instance of Non-Compliance Responsible Individuals: Debora Dickerson-Sims, Chief Financial Officer and Scott McGrath, Deputy Director Corrective Action Plan: The Commission plans to fully implement the current policies and procedures to ensure the following align with the Subrecipient Monitoring requirements in 2 CFR 200.332. 1) every subaward is clearly identified to the subrecipient as a subaward and includes the information at 2 CFR 200.332(a)(1) through (6) at the time of the subaward, 2) monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, 3) verify that every subrecipient is audited as required by Subpart F of this part. Anticipated Completion Date: June 30, 2024

2023-001 Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2023 Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Management acknowledges that certain subrecipient Uniform Guidance reports were not reviewed within a twelve-month period. Additionally, typos were included in risk assessment documentation for 4 of the 25 selections tested indicating a prior fiscal year Uniform Guidance report was reviewed. Following the identification of subrecipient Uniform Guidance findings where no follow-up was documented, the University communicated with the respective entities and determined that there was no impact to the University’s awards. By June 30, 2024, and on an annual basis, the University’s Post-Award office will review all subrecipient Uniform Guidance reports, consistently document report information, findings noted, and follow-up performed with the subrecipient, if necessary. The consolidated analysis will be reviewed by the Director of Post-Award Research Administration and the University Controller.

City of Charlotte Material Weakness Finding 2023-001 Corrective Action Plan: Because of the material weakness finding, the following actions have/will be taken: • The Finance Department will propose amendments to the Subrecipient Management policy, consistent with the external auditor’s recommendation. Amendments will include requirements for written monitoring plans to be maintained by departments. • Finance will work with departments with subrecipient arrangements to ensure understanding of the federal requirements, as well as to promote policy compliance. • Housing and Neighborhood Services will develop and implement a plan to perform an annual risk assessment to ensure compliance with the subrecipient management policy. • Any department that currently does not have a written monitoring plans will be required to develop and implement those plans. Each action stated in the corrective action plan will be completed during and by the end of fiscal year 2024. Responsible Parties: Rebecca Hefner, Acting Director Housing and Neighborhood Services Teresa Smith, Chief Financial Officer Finance Department October 31, 2023

Finding No.: 2022-044 AL Program: 97.036 - Disaster Grants - Public Assistance (Presidentially Declared Disasters) Area: Subrecipient Monitoring Questioned Costs: $1,540,330 Contact Person(s): Patrick Guerrero, Governor’s Authorized Rep., PAO Corrective Action Plan: Condition 1: The Public Assistance Office agrees with this finding and acknowledges that, as the pass-through entity, we are responsible for monitoring subrecipients. The Public Assistance Office will strengthen monitoring procedures to ensure compliance with 2 CFR 200.332(e). Beginning September 2025, PAO has begun conducting biannual risk assessments. The PAO will also strengthen documentation and audit trails by maintaining monitoring checklists, review notes, and communications in subrecipient files. Proposed Completion Date: Ongoing Condition 2: The Public Assistance Office agrees with this finding and acknowledges that, as the pass-through entity, we are responsible for monitoring subrecipients. The Public Assistance Office will strengthen monitoring procedures to ensure compliance with 2 CFR 200.332(g). Beginning September 2025, PAO has begun conducting biannual risk assessments. Proposed Completion Date: Ongoing

Finding No.: 2022-031 AL Program: 21.027 - Coronavirus State and Local Fiscal Recovery Funds Area: Subrecipient Monitoring Questioned Costs: $61,003,095 Contact Person(s): Tracy B. Norita, Secretary of Finance Corrective Action Plan: Condition 1-3: The Department of Finance agrees with this finding. The Department has recently adopted and approved (August 2025) a Subrecipient Monitoring Policy and Procedures which specifically focused on the implementation of 2 CFR 200.331. The Department will expand on this policy and procedure to include the development and implementation of a comprehensive subrecipient monitoring policies that clearly outline the process for identifying subawards, assessing the risk of noncompliance, and conducting monitoring activities based on those risks. These policies will be aligned with federal requirements and best practices to ensure consistency and accountability. Furthermore, due to internal scheduling constraints and the compressed timeline required to complete the FY22 audit, the requested documents were not submitted by the specified deadline, resulting in this finding. However, the Department maintains all relevant supporting documentation and is prepared to provide it upon request from the Grantor. Proposed Completion Date: Ongoing

Finding No.: 2022-027 AL Program: 21.026 - Homeowner Assistance Fund Program Area: Subrecipient Monitoring Questioned Costs: $4,157,924 Contact Person(s): Tracy B. Norita, Secretary of Finance Corrective Action Plan: Condition 1-4: The Department of Finance agrees with this finding. The Department has recently adopted and approved (August 2025) a Subrecipient Monitoring Policy and Procedures which specifically focused on the implementation of 2 CFR 200.331. The Department will expand on this policy and procedure to include the development and implementation of a comprehensive subrecipient monitoring policies that clearly outline the process for identifying subawards, assessing the risk of noncompliance, and conducting monitoring activities based on those risks. These policies will be aligned with federal requirements and best practices to ensure consistency and accountability. Proposed Completion Date: December 31, 2025

Finding No.: 2022-019 AL Program: 15.875 - Economic, Social, and Political Development of the Territories Area: Subrecipient Monitoring Questioned Costs: $549,849 Contact Person(s): Nerissa B. Karakaya, CIP COTR / Angelina Phillips, Office of Management and Budget (OMB) Corrective Action Plan: Condition 1 (N. Karakaya): CIP agrees with this finding. The address this finding, CIP will implement the following: 1. Establish Written Procedures: CNMI has developed and will initiate the implementation of formal written procedures requiring that all potential subrecipients be checked in SAM.gov prior to award and that verification is documented and retained in the official files. 2. Standardized Documentation: A standardized risk assessment checklist will be used for all subrecipients to confirm they are not suspended, debarred, or excluded under 2 CFR §180.300. 3. Staff Training: All staff responsible for subrecipient monitoring will receive training on federal requirements for exclusion checks and proper documentation procedures. 4. Monitoring and Review: CIP will conduct periodic reviews to ensure that SAM.gov checks are consistently performed and documented for all new and existing subrecipients. Condition 2 (N. Karakaya): CIP respectfully disagrees with this finding. The subrecipient was not required to submit the required project narrative report; instead, the report was prepared and submitted by the project manager responsible for managing the project as assigned by the Capital Improvement Program. In accordance with 2 CFR §200.328 – Monitoring and Reporting Program Performance, subrecipients are required to provide performance reports to the pass-through entity that document the status and progress of activities in accordance with the approved scope of work. To correct this issue, the subrecipient will implement a formal internal procedure designating the Program Coordinator as responsible for preparing, reviewing, and submitting all project narrative reports. Additionally, mandatory training will be conducted for all relevant subrecipient staff on federal reporting requirements and proper submission procedures, and all future narrative reports will include a certification by the authorized subrecipient representative confirming proper submission. The Capital Improvement Program will monitor submissions quarterly for the next 12 months to ensure full compliance. Corrective Actions: 1. Implement a formal internal reporting procedure requiring the subrecipient’s Program Coordinator to prepare, review, and submit all project narrative reports. 2. Conduct mandatory training for subrecipient staff on federal reporting requirements, documentation standards, and submission procedures. 3. Include a certification statement on all future narrative reports, signed by the subrecipient’s authorized representative, confirming proper submission. 4. Conduct quarterly monitoring of subrecipient submissions for the next 12 months to ensure compliance with reporting requirements. Proposed Completion Date: December 31, 2025 Condition 3 (N. Karakaya): We acknowledge the finding that documentation was not provided to verify whether eight subrecipients were subject to the audit requirements. The Capital Improvement Program will strengthen its subrecipient monitoring procedures to ensure compliance with 2 CFR 200.331(f) and related audit requirements. Corrective actions will include: 1. Policy Implementation: Adopt and disseminate the newly established Subrecipient Monitoring Policy and Procedures, which specify verification of subrecipients’ audit requirements. 2. Training: Provide training for program and grants management staff on the updated procedures and audit verification process. 3. Documentation: Maintain written evidence of audit requirement verifications for all subrecipients as part of the grant administration files. 4. Ongoing Monitoring: Incorporate periodic review of subrecipient audit status into the regular monitoring schedule to ensure continued compliance. These steps will be implemented immediately and will be applied to all current and future awards to prevent recurrence of this issue. Proposed Completion Date: December 31, 2025

We concur with the finding. The Republic has executed a signed subrecipient subaward agreement to formalize the relationship and ensure compliance with applicable requirements. Applicable laws and regulations include the COMPACT Fiscal Procedures for Palau, which take precedence as special terms and conditions where both these procedures and 2 CFR 200 address the same matter. The Ministry of Finance has implemented internal control policies and procedures to identify and document subrecipient relationships at the time of award, monitor subrecipient activities through periodic reporting, and verify compliance with federal and local requirements prior to processing drawdown requests. We further confirm that the program audit requirement for this subrecipient has been met through the separate single audit.

The Government concurs with the auditor's findings and recommendations. The formal process for completing and retaining Subrecipient Agreements is now operational to ensure compliance with programmatic obligations. As the Recipient, it is the Territory's responsibility to notify the Subrecipient when the federal funds are obligated and provide them with a subrecipient agreement which outlines the terms and conditions of the program. The Disaster Program Financial Specialist is responsible for reconciling that the subrecipient agreement has been signed by the Applicant and Governor's Authorized Representative and provided to the Territorial Public Assistance Officer. As such, no funds will be disbursed until the Subrecipient signs and returns the subrecipient agreement. These agreements are saved in a centralized location for documentation and audit purposes.

The Government concurs with the auditor's findings and recommendations. VIDE acknowledges the need for strengthened controls to ensure subrecipient compliance with federal audit requirements, as specified in 2 CFR Part 200, Subpart F. VIDE is committed to implementing effective measures to ensure that all subrecipients adhere to federal regulations and that sufficient oversight is provided. VIDE will ensure all subrecipient agreements include explicit reporting requirements and compliance expectations under 2 CFR Part 200, Subpart F. In addition, training will be given to internal staff on subrecipient monitoring requirements and best practices to ensure consistent implementation.

The Government concurs with the auditor's findings and recommendations. OMB will identify and monitor the federal awarding agencies and will request single audit results for the applicable recipients beginning FY25 and include the results in the monitoring reviews. For revenue replacement projects, based on Treasury’s Final Rule FAQ (13.14), “Recipients’ use of revenue loss funds does not give rise to subrecipient relationships given that there is no federal program or purpose to carry out in the case of the revenue loss portion of the award.” As such, they are not subject to the Single Audit Act.

The Government concurs with the auditor's findings and recommendations. OMB will develop and enforce a robust framework that includes detailed monitoring procedures, regular compliance checks, and comprehensive oversight mechanisms. This framework will ensure that all subrecipients adhere to federal requirements, thereby promoting accountability and proper use of federal funds. These measures will help mitigate risks, enhance transparency, and ensure that subrecipients fulfill their obligations under federal statutes effectively.

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.

We agree with this finding and will include the relevant information in our subawards in the future.

Management agrees with the finding and is implementing the accompanying corrective action plan. Views of Responsible Officials: Jacy Hyde, Executive Director Joel Rusco, Chief Financial and Administrative Officer Jessica Martinez, Deputy Director Contact Person: Jessica Martinez, Deputy Director Joel Rusco, Chief Financial and Administrative Officer Corrective Action Plan: In response to FY21 Corrective Action Plan, CFSC implemented an updated Subrecipient Monitoring Policy in June 2024 to ensure compliance with Uniform Guidance, including subrecipient risk assessment and audit review requirements. To further strengthen compliance and eliminate inconsistencies in subrecipient risk assessments, CFSC will implement the following corrective actions: 1.Mandatory Pre-Award Risk Assessment & Documentation: a.The Grants Manager will have the responsibility to ensure that a Subrecipient Risk Assessment Form is completed and documented for all subawards before execution. b.Risk assessment findings will be stored in the subrecipients grant file and reviewed during routine monitoring. c.Any subrecipients classified as high risk will be subject to enhanced monitoring procedures to be carried out by the assigned Grant Specialist, which may include additional financial oversight and/or more frequent reporting. 2.Systematic Audit review & compliance tracking: a.The Grants Manager will be responsible for ensuring timely collection and review of subrecipient audit reports. 3.Quarterly Compliance Audits of Risks Assessments & Audit Reviews: The Grants Manager will conduct quarterly internal audits to confirm: a.All subrecipients have undergone documented risk assessments before receiving funds. b.All subrecipient audits have been collected, reviewed, and properly documented. c.Any identified audit findings have been addressed with documented corrective actions. Anticipated Completion Date: These corrective actions will be fully implemented by the end of Quarter 2 of FY25.

Consortium shall implement procedures to ensure quarterly reports are filed no later than the tenth calendar day of the second month following the quarter the report represents. In addition, all data reported thru these quarterly reports should be supported by the accounting system of the Fiscal Agent and County Financial Information System (CFIS). This practice was put into place on April 10, 2024.

As part of our current policies and procedures review and revision process, we plan to incorporate the subrecipient monitoring and management provision of 2 CFR§ 200.331 and 2 CFR §200.332 of the Uniform Guidance to emphasize accountability and compliance in managing federal funds and subrecipients. Specifically and prospectively, effective November 1, 2024, the Organization’s practices will include: 1. Using a checklist for the determination of subrecipient or contractor classification as guidance; Perform a comprehensive risk assessment before entering into any subrecipient agreement. 2. Provide identification details such as CFDA number, amount of federal funds obligated, and the award period for determined subrecipient awards. 3. Require subrecipients to submit programmatic and financial reports as specified in the subrecipient agreement. 4. As part of the subrecipient process, ensure subrecipients that expend $750,000 or more in federal funds during a fiscal year undergo a single audit in accordance with 2 CFR Part 200, Subpart F. Review their audit reports and address any findings related to their federal awards, taking appropriate corrective actions Retroactively, for the audit periods July 1, 2022 – June 30, 2023 and July 1, 2023 – June 30, 2024, the Organization will perform a risk assessment of the existing subrecipient portfolio during this period to identify high-priority risks. The objective of this risk assessment review is to identify, evaluate, and prioritize risks that could adversely impact the organization’s ability to achieve its strategic, operational, and quality assurance goals, ensuring that all products, services, and processes align with established standards and fulfill processes. The above reflects the current planned practices of the Organization and the overall financial policies and procedures are in the process of being updated to align to the subrecipient monitoring and management provision of 2 CFR §200.331 and 2 CFR §200.332 of the Uniform Guidance. The Organization has prioritized the completion and distribution of the updated financial policies and procedures by December 31, 2024.

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: 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. 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 that were identified during testing procedures. Context: The 10 subrecipients represent approximately 38%, $1,935,000, of the total award expenditures of $4,999,384. 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.

ALN 21.023 – Lack of Internal Controls and Noncompliance with Subrecipient Monitoring – Emergency Rental Assistance Program (Repeat Finding 2021-013) Cleveland County takes the auditor's findings seriously and has already implemented several improvements in documentation, monitoring, and reporting practices. Cleveland County is working toward improvements for Fiscal Year 2025 and has reconciled billing to align with the contract scope of work. However, we recognize the need for documented internal controls and are committed to addressing all recommendations to ensure compliance and transparency in future programs. The County appreciates the constructive feedback and will continue to refine its processes to better serve its citizens.

The County will implement a new policy to ensure all subrecipients that are given federal funds of $25,000 or more are properly monitored.

Finding 2022-008 U.S. Department of Health and Human Services, passed through Kansas Department of Aging Aging Cluster – ALN 93.044 - Special Programs for the Aging_Title III, Part B_Grants for Supportive Services and Senior Centers - 2201KSOASS and 2201KSOACM ALN 93.045 – Speicl Programs for the Aging_Title III, Part C_Nutrition Services – 2201KSOCAHC Management’s Response: Management concurs. Risk assessments are an important component of award management. We have developed a risk assessment tool for use by department personnel in risk assessments for sub recipients. Views of Responsible Officials and Corrective Action: Department grant management personnel will receive training around risk assessments and provided our monitoring tool for their assessments. Management will ensure this is addressed by December 31, 2024. Responsible Official: Dr. Shelley Kneuvean Chief Financial Officer Unified Government of Wyandotte County & Kansas City KS

Panthera has now adopted the implementation of the Federal Assistance Listing Numbers on each agreement with subrecipients, and will ensure a formal approval is issued on all expenditure reports.

2022-006 Program: WIOA Cluster Federal Financial Assistance Listing Number: 17.258, 17.259, 17.277, 17.278 Federal Grantor: U.S. Department of Labor Pass-Through: California Department of Employment Development Award No. and Year: AA011008 and 2019 Compliance Requirements: Subrecipient Monitoring Type of Finding: Material Weakness Management’s or Department’s Response: Imperial County Workforce Development Office (ICWDO) agrees with the finding. Views of Responsible Officials and Corrective Action Plan: The questions from finding 2021-008 relate to a formalization of the fiscal processes and protocols. ICWDO operates under WIOA guidelines and follows Imperial County’s fiscal policies. Internal policy will be formally updated to reflect compliance with WIOA regulations, as well as Imperial County policies. These policies will include formal controls and procedures to evaluate each subrecipient’s risk of noncompliance. Once the formal procedure is drafted, it will go through the ICWDO Policy Committee for comment and direction, and then finally reviewed and approved for implementation by the full Workforce Development Board. Additionally, for any future Memorandums of Understanding (MOUs) between this Imperial County department and any outside agency, there will be an additional step to include review by Imperial County Counsel to reflect that recital around the funding source will specify the following required information: • Federal Award Identification Number • Federal award date of award to recipient by the Federal agency • Name of Federal awarding agency • CFDA Number • Specific identification of whether the award is research and development ICWDO will develop internal policies for formalizing all subrecipient monitoring process. ICWDO operates under WIOA guidelines for monitoring; therefore a formal internal policy for future contracts will be developed and implemented using the usual review and approval procedures followed by the department. ICWDO will develop a formal internal documentation system, with appropriate checks and signatures, for the evaluation and assessment of each subrecipient’s risk of noncompliance. ICWDO will utilize this formal process to properly document the risk assessment of all subrecipients. ICWDO anticipates to implement the corrective action by December 31, 2023. Name of Responsible Person: Priscilla A Lopez, ICWDB Director Implementation Date: December 31, 2023