Corrective Action Plans

The City agrees with the finding. The City's Grant Administrator will provide training to each City department which currently oversees subrecipients, ensuring that all department staff understand general and ARPA-specific subrecipient requirements. Additionally, the Grant Administrator will review City departments' subrecipient management checklists to ensure all required documentation is obtained from subrecipients and reviewed as required. This will be complete by June 30, 2024.

SUBRECIPIENT MONITORING School Building Authority (SBA) Assistance Listing Number 97.036, COVID-19 97.036 The SBA will ensure and review audits of all subrecipients yearly effective February 2024. The SBA will implement policies and procedures to monitor all subrecipients to ensure compliance with federal requirements. This will include, but is not limited to, performing a yearly risk assessment as required by 2 CFR 200.303. This assessment will take into consideration results from the yearly audit of each subrecipient as well as other criteria listed in 2CFR 200.303 paragraphs (b), (d) & (e).

SUBRECIPIENT MONITORING West Virginia Community Advancement and Development (WV CAD) Assistance Listing Number 93.568, COVID-19 93.568 Between the years 2022 and 2023, the Weatherization Assistance Program (WAP) experienced a significant turnover in its staff. As a result of this turnover, the proper adherence to the requirement of 2 CFR 200.332(f) for verifying subrecipients was not followed during the auditing process. To ensure that this requirement is met in the future, WV CAD has taken measures to document the policies and procedures related to the financial audit requirements of 2 CFR 200.332(f) in the current WAP State Plan. A designated team member has been assigned the responsibility of maintaining a comprehensive tracking list, which includes the due dates of audits, their review dates, any necessary subrecipient corrective action plans, the dates of letter correspondence, and the uploading of all relevant documents into the divisions Shared Drive. Additionally, this team member is also responsible for downloading the audits from the Federal Audit Clearinghouse and submitting the information to the Fiscal Monitor for a thorough accounting review. These measures aim to ensure proper compliance and accountability within the Weatherization Assistance Program. This action will be implemented in February 2024.

SUBRECIPIENT MONITORING Department of Education (DOE) Assistance Listing Number 93.558, COVID-19 93.558 Program management will implement policies and procedures to ensure that the subrecipient monitoring is updated to “ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the passthrough entity must provide the best information available to describe the federal award and subaward.” The timeline for the development and initiation of the process is tentatively set for February 1, 2024.

SUBRECIPIENT MONITORING Department of Environmental Protection (DEP) Assistance Listing Number 15.252 Effective April 2024, DEP will prepare and implement a written risk assessment policy containing monitoring and compliance review standards. DEP will also prepare and implement written standard operating procedures to assist in measuring subrecipient risk.

Pacific University acknowledges the importance of an effective control environment and closely monitors activities of subrecipients under federal awards. Pacific was able to demonstrate that the selected subrecipients had appropriate audits under Subpart F (or were not subject to such audits). However, the University will enhance controls related to tracking such compliance

Recommendation We recommend updating internal policy over subrecipient monitoring and recommend implementation of effective internal controls and procedures over subrecipient monitoring and tracking that allow for compliance with all applicable federal laws, regulations, and compliance requirements of various federal grants. It seems likely that additional monitoring activities are being performed that are not currently being documented in a central location, and therefore we recommend standardizing the documentation of such activities. Management Response Corrective Action: We concur with this finding and the auditor’s recommendation. The Department is in the process of implementing policies and procedures to ensure proper monitoring of subrecipients. This will also include training for both the financial and the grants departments. Subrecipient monitoring tools, such as excel worksheets and checklists are being reviewed and modified to fit the Department’s needs. The complete implementation of the subrecipient policies and processes is expected to be completed June 2024. Due Date of Completion: June 30, 2024 Responsible Person(s): Chief Financial Officer, Grants Unit Manager

CORRECTIVE ACTION PLAN (Concerning Finding 2023-001) December 21, 2023 Finding: 2023-001 Subrecipient Monitoring Federal Program Information: U.S. Department of Education Passed through the State of Vermont Agency of Education ALN: 84.425 - Education Stabilization Fund Contact Person Responsible for Corrective Action: Cheryl Hammond, Business Manager Corrective Action: The Two Rivers Supervisory Union will take the following actions to address finding 2023-001:  Review 2 CFR 200.332(a)  Create a temple subreceipient form  Complete the form annually and create a new form with any chance to the sub granted amount  Begin this process immediately Anticipated Completion Date: December 21, 2023

2023-002 - Noncompliance and Significant Deficiency in Internal Controls over Compliance for Subrecipient Monitoring Corrective Action Plan: Wellbeing Initiative has reviewed subrecipient monitoring criteria and updated the Internal Controls Policy and Procedure Manual to include the following policy. The appropriate measures have been taken to ensure these requirements are met in the coming years. Item 10.8.b.i-xv. Subrecipient monitoring requirements for pass-through entities, include the requirement that pass-through entities ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward. Required information includes but is not limited to: i. Subrecipient name (which must match the name associated with its unique entity identifier); ii. Subrecipient's unique entity identifier; iii. Federal Award Identification Number (FAIN); iv. Subaward Period of Performance Start and End Date; v. Subaward Budget Period Start and End Date; vi. Total Amount of Federal Funds Obligated to the subrecipient by the pass-through entity including the current financial obligation; vii. Total Amount of the Federal Award committed to the subrecipient by the pass-through entity; viii. Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA); ix. Name of Federal awarding agency, pass-through entity, and contact information for awarding official of the Pass-through entity; x. Assistance Listings number and Title; the pass-through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at time of disbursement; xi. Indirect cost rate for the Federal award (including if the de minimis rate is charged) per § 200.414. xii. All 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 Federal award; xiii. Any additional requirements that the pass-through entity imposes on the subrecipient in order for the pass-through entity to meet its own responsibility to the Federal awarding agency including identification of any required financial and performance reports; xiv. A requirement that the subrecipient permit the pass-through entity and auditors to have access to the subrecipient's records and financial statements as necessary for the pass-through entity to meet the requirements of this part; and xv. Appropriate terms and conditions concerning closeout of the subaward Anticipated Completion Date: Completed 11/16/2023 Responsible: Chief Executive Team: Danielle Smith and Sadie Thompson

Federal Program Name: • Coronavirus State and Local Fiscal Recovery Funds – ALN 21.027 Recommendation: The Organization created a Subrecipient Monitoring Policy in fiscal year 2023 to include performing subrecipient risk assessments on all subrecipient relationships entered into by the Organization. As part of the Organization’s subrecipient monitoring process it received an incomplete audit report from a subrecipient and as a result the Organization was not aware of the audit findings the subrecipient had received. Our auditor’s recommended the Organization utilize the federal audit clearinghouse to verify the audit reports the subrecipients are providing. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Management’s response: Management concurs with the audit finding. Subrecipient monitoring was performed per the existing policy but the subrecipient provided inaccurate information on the monitoring questionnaire and incomplete audit information. The information provided by the subrecipient was not verified against the Federal Audit Clearinghouse. The risk assessment policy will be updated to ensure that information provided by subrecipients is verified against the Federal Audit Clearinghouse to ensure a complete risk assessment is performed. Planned completion date for corrective action plan: Will implement in fiscal year 2024. If the U.S. Department of Health and Human Services has questions regarding this plan, please call Brent Amfahr, CFO at 303-443-8500

Management Views and Corrective Action Plan: Management agrees with the finding and recommendation. Name and Title of Responsible Official: Rouba Anka, Chief Financial Officer Planned Completion Date: Immediately

University’s Response/Corrective Action Plan: Upon becoming aware of the issue, the University issued a Stop Work Order to the identified subrecipient to cease all work on the award until such time their invoicing and documentation complies with the terms and conditions of the subrecipient agreement. Since this issue was contained to a single award and a single department the University completed these steps: 1. Performed an audit of the subrecipients on the award to ensure all were following the requirements of the subrecipient award agreement. The audit was complete on October 13, 2023. 2. The Office of Research & Sponsored Programs (ORSP) and Grants Accounting (GA) completed a subrecipient monitoring training for the department to ensure that they were familiar with the requirements of the agreement and revised their processes for appropriate monitoring of subrecipients. This training was completed on November 7, 2023. This training will be made available to all OHIO principal investigators (PI) via the subrecipient webpage on the Office of Research & Sponsored Programs website by November 30, 2023. 3. ORSP and GA worked closely to develop a new checklist that was shared with all PIs on Tuesday, October 24, 2023, that outlines the PI responsibilities for monitoring subrecipients and reviewing any invoices before payment from the subrecipient to ensure that it complies with the subrecipient agreement terms and conditions. This checklist will also be added as resource for PIs as an additional tool for subrecipient monitoring by November 30, 2023. 4. Developed a subrecipient invoice template that includes all required information to comply with the subrecipient agreement. This invoice template will be sent to all subrecipients when the purchase order is issued to the subrecipient. This practice started on October 23, 2023. 5. Responsible Parties: Heidi Whitney, Director of Grants Accounting and Susan Robb, Assistant Vice President for Research & Sponsored Programs

Management’s Views and Corrective Action Plan 2023-001 – Subrecipient Information and Monitoring Grantor: Centers for Disease Control and Prevention (CDC) Passthrough Agency: Massachusetts Department of Public Health Program Name: Massachusetts Community Health Worker for Resilience Award Name: Community Health Workers for Public Health Response and Resilient Award Year: Various Award Number: INTF4207M03225031012 Assistance Listing Number: 93.495 The Alliance has implemented a template effective December 1, 2023 to be utilized for the communication of the subaward information as well as an initial risk assessment and a continuing reassessment template. Additionally, the Alliance will be developing formalized procedures to communicate with subrecipients. The Alliance will be using a checklist to formally review the initial and continuing agreements and will include high and low risk determinations. These will be implemented in February 2024 and be reviewed on an annual basis for any continued funding. Jill Batty Chief Financial Officer Cambridge Health Alliance 350 Main Street Malden, MA 02148

Failure to Properly Track Grant Expenditures Recommendation: We recommend that the Clinic maintains an effort to track federal and state funding and expenditures separate from regular program expenditures, inquiring of granting agencies if needed. Action Taken: Management is now properly tracking grant expenditures and can accurately state quantities of grant expenditures.

2023-003 Material Weakness over Subrecipient Monitoring; Emergency Rental Assistance Program (ERAP), Assistance Listing Number 21.023, U.S. Department of Treasury Recommendation: We recommend that the County create a subrecipient monitoring policy to monitor federal awards in accordance with the contract and Uniform grant guidance. The subrecipient monitoring policy should include performing a risk assessment to determine the level of subrecipient monitoring required. Additionally, we recommend the County conduct site visits and/or perform a random sampling of charges based on the results of the risk assessment. Corrective Action: An organization-wide documented policy is being developed by the newly established Grants Management program officers. The new policy will meet current Federal guidance on subrecipient monitoring and will include resources and recommendations for County Departments to perform a risk assessment, internal control assessment, onsite visits, and desk reviews as applicable. Proposed Completion Date: Upon completion and approval of the new subrecipient monitoring policy the County will implement the procedures within 180 days. Name of Contact Person: Patrick Flanary, Chief Financial Officer

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.