Corrective Action Plans

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

FINDING NO: 2022-002 - Subrecipient Monitoring (Repeated from Prior Year Findings 21-003, 20-004, 19-005, 18-004, and 17-003) CONDITION: Audit procedures revealed that ROE #47 was not properly monitoring subrecipients in accordance with the Uniform Guidance standards as follows: 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 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 two (2) of two (2) 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. • 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.

Responsible: Denice Hairston, Chief Quality, Compliance and Accountability Officer Corrective Actions: Update subrecipient award agreements to ensure the final approved scope of work or project description is specified. Completion Date: March 29, 2023 Explanation: Policies and procedures were updated in 2023 in response to an OJJDP/OCFO recommendation to ensure subaward files contain the requisite components for the award agreement. In addition to these updates, which include a master file checklist, National CASA/GAL has updated the subrecipient Terms & Conditions agreement to include CFR requirements as recommended.

Finding 2022-009 Subrecipient Monitoring – Material Noncompliance and Material Weakness in Internal Controls Over Compliance Corrective Action Plan: Management concurs with the finding and will adhere to the corrective action plan included in this report. Management plans to revise policies and procedures related to subrecipient monitoring. Anticipated Completion Date: December 31, 2024

Finding 2022-004 – Subrecipient Monitoring – U.S. Department of Homeland Security Montana Department of Disaster and Emergency Services BRIC: Building Resilient Infrastructure and Communities – ALN 97.047 The county has established a Core grants team consisting of members of Finance, Auditors Office, and our Grants Department. This team will work closely with all county grant managers. Specifically looking at sub recipient awards, the Core Grants Team will implement the following; Review and update polices related to subrecipient grant management. Polices will be updated to clearly outline roles and responsibilities, and expectations concerning monitoring of Subrecipient grant awards. Develop and implement a training program for all grant managers and staff involved with subrecipient grants. Follow up to ensure staff understand their roles with monitoring subrecipient activities and compliance with terms of the grant. Establish a monitoring framework to include regular checkpoints and reporting mechanisms. Implement standardized reporting for monitoring activities. Implement regular reviews of subrecipient financial reports and compliance documentation. Clearly communicate expectations as often as possible and encourage open communication. Contact Person Responsible for the Corrective Action: David Wall, County Auditor Anticipated Completion Date of the Corrective Action: June 30, 2024

21.023 - Lack of Internal Controls and Noncompliance with Subrecipient Monitoring Requirement – Emergency Rental Assistance Program (Repeat Finding – 2021-002) 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: 6/21/2023 Responsible Contact Person: Brian Maughan, BOCC Chairman

21.019 - Lack of Internal Controls and Noncompliance with Subrecipient Monitoring Requirement – Coronavirus Relief Fund (Repeat Finding - 2021-001) 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: 6/30/2024 Responsible Contact Person: Brian Maughan, BOCC Chairman

FINDING # 2022-010No finding in prior yearAs recommended, the DCA will review current procedures to ensure that all subaward information required by the federal Uniform Guidance is included in all subaward contracts and grant agreements. The DCA has also reviewed its current subrecipient monitoring procedures for standard subawards made by the agency and has determined that no internal control enhancements are required. The HAF award was a unique grant relationship for DCA in that the entire award was passed through to another New Jersey State government agency that is a direct affiliate of the Department. Monitoring procedures were determined based on the close working relationship with our affiliate organization and the fact that less than 1 percent of the grant award was expended through June 30, 2022. Current procedures included a risk assessment of the subrecipient and performance of the single audit desk review of the independent audit report. In addition, the Director of Audit, and the Executive Director of the subgrantee affiliate participate in weekly meetings where updates on the program status can be determined. DCA?s subrecipient monitoring plan also includes the hiring of an Integrity Monitor to oversee and monitor the use of the HAF funds as well as compliance with all HAF program reporting requirements. As program disbursement activity is continuing to increase with the HAF program(s) created more fully up and running, DCA is currently targeting the Integrity Monitor hire to take place sometime within the next three to six months.COMPLETION DATE/CONTACT PERSON Fiscal Years 2023 and 2024John Alexy(609) 913.4385John.Alexy@dca.nj.gov

Subrecipients Not Tracked for Monitoring of Single Audit ReportsState Agency: Department of Workforce ServicesFederal Program: Child Care and Development Block GrantWe have verified that the four omitted subrecipients have been audited as required. Three of the four received a single audit and had no findings related to subawards provided by DWS. The remaining subrecipient was not required to have a single audit. Queries designed to identify subrecipients have been updated and reviewed to ensure that they include all subrecipients. FINET coding has been created to more specifically identify payments to subrecipients. This coding has simplified the query, which will minimize the risk of errors in the future.Contact Person: Van Christensen, Internal Audit Director, 801-808-0698Anticipated Correction Date: June 30, 2022

CRF Subrecipient Single Audit Report Reviews Not OccurringState Agency: Governor?s Office of Planning and BudgetFederal Program: Coronavirus Relief FundGOPB has updated its policies and procedures to ensure notification is given to all awarded subrecipients to be compliant with 2 CFR 200.332(d) and the $750,000 annual spending threshold. GOPB will annually perform a review of subrecipients and verify that entities likely exceeding the federal funds expenditure threshold have completed and submitted a single audit report published on the Federal Audit Clearinghouse website. Any entity needing a single audit that can not be located on the website will be notified of their lack of compliance. Additionally, each year a sample of CRF subrecipients single audits will be reviewed for noncompliance.Contact Person: Duncan Evans, Senior Managing Director of Budget and Operations, 801-538-1592Anticipated Correction Date: April 30, 2023

Go Utah Did Not Implement Internal Controls for Subrecipient Monitoring RequirementsState Agency: Go UtahFederal Program: Coronavirus State and Local Fiscal Recovery Fundsa. ?Gain an understanding of subrecipient requirements and establish internal controls to ensure compliance with these requirements;?In order to achieve a sufficient internal control environment, additional controls are needed at both the agency and state levels. Therefore, the Economic Opportunity Office will work with the Governor?s Office of Planning and Budget to create internal controls that, in addition to the ones already in place, create an environment that ensures compliance with federal requirements.b. ?Communicate all required federal award information to sub-recipients.?The Economic Opportunity Office will work with the Attorney General?s Office to include all required federal award information with the sub-recipient?s granting contracts.Contact Person: Kamron Dalton, Managing Director of Operations (COO), 801-538-8677Anticipated Correction Date: July 1, 2023