Corrective Action Plans

Program: AL 20.205 ? Highway Planning & Construction ? Subrecipient Monitoring Corrective Action Plan: NDOT will review all current active subaward agreements and verify federal subaward identification information is included. If information was not previously included in the original agreement or a supplement agreement, NDOT will provide a supplemental award notice to notify the subrecipient of the subaward identification information as required by 2 CFR ? 200.332. Contact: Khalil Jaber Anticipated Completion Date: September 2023

Program: AL 84.010 ? Title I Grants to Local Educational Agencies ? Allowability and Subrecipient Monitoring Corrective Action Plan: The Department will contact the two subrecipients noted to provide one-on-one technical assistance and will also provide additional technical assistance regarding proper time and effort documentation to all subrecipients. Additionally, time and effort guidance is available to all subrecipients on the Department?s website, will be discussed at upcoming subrecipient training opportunities and supported by a dedicated Grants Management Training Specialist. The Department will ensure the identified written deficiencies noted in the subrecipient fiscal monitoring exit letter clearly identifies a finding vs. technical assistance needed; whereas a finding is supported by follow-up in accordance with federal UGG regulations and technical assistance provides knowledge of the Department?s training and resources available. Contact: Jen Utemark, Budget and Grants Management Anticipated Completion Date: December 31, 2023

Finding: 2022-001 ? Material Weakness, Compliance and Internal Control over Compliance, Subrecipient Monitoring ? ALN 21.027 Coronavirus State and Local Fiscal Recovery Funds Personnel Responsible for Corrective Action: Pam Noonan, Mesa County Finance Director Anticipated Completion Date: 12/31/2023 Cause: Mesa County embarked on the usual funding methodology of capitalizing on private investments in our low-income community, whereby a much-needed training facility and daycare is nonexistent, by utilizing New Market Tax Credits. Due to the complexity of the arrangement and the lack of adequate information provided by consultants, determinations and documentation of the subrecipient did not occur prior to granting funds to the recipient organization. View of Responsible Officials: Mesa County agrees with the finding and has put together a corrective action plan for the finding. Planned Corrective Action: Mesa County will develop procedures and educate County departments in order to ensure compliance with the grant management policy and subrecipient language included therein. Mesa County will formally communicate with the subrecipient organization the necessary Federal award identifiers and expected continued compliance and required documentation during the performance period.

View of Responsible Officials NHED concurs with the finding identified in section A. This was an oversight on the part of NHED, and a process has been implemented to ensure that when the GAN template is generated, there is a review by 2 separate staff members to ensure all required elements on the GAN are complete. NHED concurs with the finding identified in Section B. The previous Division Director of Learner Support, without understanding the unintended consequences, required that the IDEA allocations be uploaded in separate installments instead of including the full year award amount. This led to a GAN generation that included only the first installment. This procedure has since been corrected and NHED is now uploading the full year allocation amount in GMS, this will then generate a GAN that reflects the full year grant amount. If a reallocation does occur, there is a review by 2 separate staff members to ensure that the amount is verified and that a new GAN is manually generated to include that verified amount, and then the GAN is reissued to the recipient. Anticipated Completion Date: Already completed Contact Person: Lindsey Labonville

View of Responsible Officials The Department acknowledges the misinterpretation of the agreement as a subaward has led to a failure to comply with 2 CFR section 200.332(a). Underlying this misinterpretation was the Department?s failure to differentiate between entering into agreements with other state agencies and entities recognized as component units of state government such as the NH Business Finance Authority; noting agreements between state agencies would not require such compliance. Accordingly, the Department will review existing policies and procedures related to subawarding and subrecipient monitoring to ensure agreements with component units of state government are properly considered. Additionally, the Department will amend the existing agreement to ensure required award information is communicated and ensure all other subrecipient monitoring protocols are applied to the subaward. Anticipated Completion Date: June 30, 2023 Contact Person: Taylor Caswell

View of Responsible Officials The State largely concurs with the findings and recommendations and has either implemented procedures to address the identified conditions already or will do so. With regard to condition A(a) and (b), although the State illustrated that it includes clauses related to allowed costs in its subawards, including direct and indirect costs, it will work to ensure that agencies entering into such agreements clearly indicate the terms required by Uniform Guidance, including permitted indirect cost rates and whether the award is for R&D. With regard to condition B, the State agrees that risk assessments should have been completed and has since implemented a framework to help ensure that agencies are more consistently conducting and documenting subrecipient risk assessments. With regard to condition C, the State concurs and has already implemented an agency-wide framework to help ensure procedures and policies are in place concerning Uniform Guidance Report review and the issuance of any necessary management decision letters, to the extent required. It is worth noting that the State in most cases has timely conducted risk assessments of subrecipients and reviewed relevant Uniform Guidance Reports, but its corrective actions will result in better documentation and more consistent and timelier follow through. Anticipated Completion Date: The corrective actions indicated above relative to conditions B and C have already been implemented as of the date of this response. The State will work to address Condition A before the end of the current Fiscal Year. Contact Person: Chase Hagaman and Steve Giovinelli

View of Responsible Officials The State concurs in part with the findings and recommended action. The State?s HAF program fully launched in March 2022 of the Fiscal Year under review, which ended June 30, 2022. On the whole, a more robust subrecipient monitoring framework and process is being implemented during the current Fiscal Year for this program. However, the State has engaged in thorough monitoring of its subrecipient, receiving and reviewing recurring biweekly and quarterly reports. As noted, discussion of those reports takes place during weekly conversations with the subrecipient. However, the State has acknowledged that it needs to more formally memorialize the substance of such conversations to demonstrate such review. This change in protocol and procedure has already been implemented during this Fiscal Year. The State has also engaged in a subrecipient risk assessment and review of audited financials for the purposes of uniform guidance report review. However, its process and protocols will be revised to better demonstrate when such reviews/assessments take place moving forward. Moreover, the State relies on its subrecipient to facilitate the State?s HAF program, which includes collecting and processing data, as outlined in the program?s policy guide manual. A key feature of that process is a detailed quality control protocol. Additionally, during this Fiscal Year, the State engaged in a robust, on-site review of the subrecipient?s quality control protocols and methods, including applicant file review, and found them satisfactory and reliable. The State also works closely with its subrecipient during the quarterly and annual U.S. Treasury reporting processes, which involves reviewing and analyzing data provided by the subrecipient for reporting purposes. This review and the resulting communications can result in corrections to data prior to submission to U.S. Treasury. Corrective Action and Anticipated Completion Date: As of this response, the State has already implemented several corrective actions that align with the recommendations above, including documentation of report review during weekly calls with the subrecipient, timestamping procedures for uniform guidance report review, and on site, detailed review of quality control protocols that involved applicant file review. The State will further ensure that such updated protocols and procedures are memorialized in the Programs? transaction processing memo during its Q1 2023 update, including any protocols necessary to ensure timely issuance of any required management decisions relative to the subrecipient. Contact Person: Chase Hagaman, Lisa Cota-Robles, and Michele Zangri-Crean

View of Responsible Officials The State concurs in part with the findings and concurs in part with the recommendations. Given that CARES Act CRF is a funding source that is no longer eligible for use because program obligations were required to be entered into by December 31, 2021, and program expenditures complete by September 30, 2022, there are no ongoing CRF funded projects or programs. As a result, any corrective actions would relate to ensuring any other federal funding sources are achieving compliance requirements. With regard to condition A, the State partially concurs. Federal guidance concerning CARES Act CRF did not allow for charging indirect costs. That guidance indicated ?Payments from the Fund are not administered as part of a traditional grant program and the provisions of the Uniform Guidance, 2 CFR part 200, that are applicable to indirect costs do not apply. Recipients may not apply their indirect costs rates to payments received from the Fund.? Thus, awardees and recipients of funds were not permitted to charge indirect costs against CARES Act CRF. However, the state acknowledges inclusion of language specifically acknowledging the disallowance of indirect costs could have been included in the agreements. With regard to condition B, the State concurs. The four identified subrecipients were awardees of a program that was facilitated at the very end of CARES Act CRF eligibility for the period of performance. This program was run due to updated guidance by U.S. Treasury on December 14, 2021, that extended the deadline for expenditure of funds so long as obligations were entered into by December 31, 2021. That program largely resulted in direct beneficiary awards, but due to the nature of some expenditures awarded some entities received a subaward. Those subawards identified a brief timeline for project completion, between December 2021 and September 2022. Most projects were completed in February and March, with two of the subrecipients finalizing projects in September. Given the nature and timing of the program, those subawardees were closely monitored and regularly interacted with the State in order to receive reimbursement for eligible expenses and complete projects. The State can provide documentation of that monitoring and expense review. However, formal risk assessments were not initially done for those entities. Since then, the State has implemented policies and procedures that help ensure risk assessments are completed for all subrecipients, regardless of the nature of the program. With regard to condition C, the State concurs and has already implemented corrective actions to ensure procedures and policies are in place concerning Uniform Guidance Report review and the issuance of any necessary management decision letters to the extent required and where this deficiency could impact any other sources of federal funding. It is worth noting that the State in most cases has timely conducted risk assessments of subrecipients and reviewed relevant Uniform Guidance Reports, but its corrective action will result in better documentation of that process and protocol. Anticipated Completion Date: The corrective actions indicated above have already been implemented as of the date of this response. Contact Person: Steve Giovinelli and Chase Hagaman

U.S. Department of the Treasury 2022-007 Covid-19 Coronavirus State and Local Fiscal Recovery Funds - Assistance Listing No. 21.027 Recommendation: We recommend an amended subrecipient contract that complies with all guidelines under 2 CFR section 200.332(a) be put into place between Polk County and the identified subrecipient. In addition, we recommend a risk assessment of this subrecipient be performed and depending on the results of the assessment, determine a planned schedule of monitoring that matches frequency and intensity that aligns with the risk assessment. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The County is implementing training and procedures to properly identify and classify subrecipients on the Schedule of Expenditures of Federal Awards and State Financial Assistance, and to ensure that all required subrecipient monitoring is properly performed. Additionally, the contract for a subrecipient identified during the audit is being amended to comply with all applicable requirements. Name(s) of the contact person(s) responsible for corrective action: Christia Johnson Planned completion date for corrective action plan: June 15, 2023. Approval of amended contract expected in August 2023.

State of Missouri Single Audit Corrective Action Plan Year Ended June 30, 2022 State Agency: Department of Health and Senior Services (DHSS) Audit Finding Number: 2022-008 ELC Program Subrecipient Monitoring Name of the contact person responsible for corrective action: Jennifer Harrison, Senior Program Specialist Anticipated completion date for corrective action: March 2024 Corrective action planned is as follows: DHSS through DCPH will continue to perform monitoring reviews in accordance with the ELC program monitoring plan.

Condition: For all four subawards selected for testing, the identification of the award being Research and Development (R&D) was not noted. Further, for two of the four subawards selected for testing, there was missing information from the subaward including (1) Recipient DUNS number (2) Unique Federal Award Identification Number (FAIN) (3) Assistance Listing number (4) Indirect Cost Rate. Lastly, one subaward did not include the following information: (a) Period of Performance of subaward (b) Amount of federal funds obligated and awarded (c) General terms and conditions of subaward (d) Federal award project description (e) Name of Federal awarding agency. Corrective Action Plan: EA recognizes that this required information must be provided to subrecipients. To prevent this error in the future, EA will design a cover page template including all required information. EA will confirm with Sikich that the form covers all requirements. EA will use this template for all subawards related to our grants. Responsible Person for Corrective Action Plan: Betsy Spore, Director of Finance and Accounting Implementation Date for Corrective Action Plan: 09/01/2023

FINDING 2022-003 (Auditor Assigned Reference Number) Contact Person Responsible for Corrective Action: Jamie Arce, Controller Contact Phone Number: 574-322-4863 Views of Responsible Official: Management agrees with the finding. Description of Corrective Action Plan: The City will review its existing policies and procedures surrounding adequate supporting documentation and will update policy as required. Training on this requirement will be provided to all City Staff involved in procurement. Anticipated Completion Date: October 31, 2023

Reference Number: 2022-029 Prior Year Finding: 2021-027 Federal Agency: U.S. Department Homeland Security State Department Name: Department of Safety and Homeland Security, Federal Emergency Management Agency (FEMA) State Division Name: Delaware Emergency Management Agency (DEMA) Federal Program: Disaster Grants - Public Assistance (Presidentially Declared Disasters), COVID-19 ? Disaster Grants ? Public Assistance (Presidentially Declared Disasters) Assistance Listing Number: 97.036 Award Number and Year: 4526-DR-DE (2022), 4566-DR-DE (2022), 4627-DR-DE (2022) Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness in Internal Control Over Compliance, Material Noncompliance Recommendation: DEMA should review and enhance internal controls and procedures to ensure that all required information is included in all subawards, that subrecipients are properly monitored, and that evaluation of independent audits is performed. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: A contractor has been assigned to develop and implement internal controls to ensure all required information is included in all subawards, that subrecipients are properly monitored, and that evaluation of independent audits is performed. Subaward letters were updated in September 2022 and a monitoring protocol implemented to begin monitoring all subrecipients to date to include an evaluation of independent audits that is documented as part of the monitoring visit. Name(s) of the contact person(s) responsible for corrective action: Tramaine Childs Disaster Recovery Specialist Innovative Emergency Management Inc. 318.278.2813 (Mobile) Tramaine.Childs@iem.com Planned completion date for corrective action plan: September 26, 2022

Reference Number: 2022-024 Prior Year Finding: 2021-024 Federal Agency: U.S. Department of Health and Human Services State Department Name: Department of Health and Social Services State Division Name: Division of Substance Abuse and Mental Health Federal Program: Block Grants for Prevention and Treatment of Substance Abuse, COVID-10 - Block Grants for Prevention and Treatment of Substance Abuse Assistance Listing Number: 93.959 Award Number and Year: B08TI083060 (10/1/2019 ? 9/30/2021), B08TI083488 (10/1/2020 ? 9/30/2022) Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness in Internal Control Over Compliance, Material Noncompliance Recommendation: The Division should review and enhance internal controls and procedures to ensure that all required information is included in all subawards and provided to the subrecipients, that proper subrecipient monitoring is conducted, and that evaluation of independent audits is performed. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Division has been working to implement corrective action. DSAMH continues to update and enhance policies and procedures to ensure that proper subrecipient monitoring is conducted in accordance with Federal regulations. Name(s) of the contact person(s) responsible for corrective action: Mequoria Bowden, Chief of Administration Office of the Secretary Administration Planned completion date for corrective action plan: October 31, 2023

Reference Number: 2022-023 Prior Year Finding: 2021-018 Federal Agency: U.S. Department of Health and Human Services State Department Name: Department of Health and Social Services State Division Name: Division of Substance Abuse and Mental Health Federal Program: Opioid STR Assistance Listing Number: 93.788 Award Number and Year: H79TI083305 (9/30/2020 ? 9/29/2022) Compliance Requirement: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Recommendation: The Division should review and enhance internal controls and procedures to ensure that proper subrecipient monitoring is conducted in accordance with Federal regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Division has been working to implement corrective action. DSAMH continues to update and enhance policies and procedures to ensure that proper subrecipient monitoring is conducted in accordance with Federal regulations. Name(s) of the contact person(s) responsible for corrective action: Mequoria Bowden, Chief of Administration, Office of the Secretary Administration Planned completion date for corrective action plan: October 31, 2023

Finding # 2022-007 Title of Finding Subrecipient Monitoring Contact Person Brook Hinzman Anticipated Completion Date June 2023 Corrective Action planned to be taken: Will comply and monitor subrecipient spending going forward.

Policies, procedures and controls have been reviewed and revised to ensure all sub-awards are monitored consistently and that reports are filed regularly with APS. A new reporting form has been created that will log electronic signatures from both the sub-awardee and APS staff. In addition, APS will request a copy of the single federal audit of each sub-awardee annually. And, APS will monitor award amounts and then make the required filings, to meet all reporting requirements set forth under the Transparency Act. APS begin implementing these procedures in Q2 2023, upon discovery of these deficiencies. APS implemented the corrective action plan on June 5th, 2023. Management's contact responsible for the implementation of the Corrective Action Plan: Name: Jane Hopkins Gould Position: Chief Financial & Operating Officer Telephone number: 301-209-3276

CORRECTIVE ACTION PLAN (Concerning Finding 2022-001) Contact Person Responsible for Corrective Action: Beth Drew, Business Administrator Corrective Action: The Essex North Supervisory Union will take the following actions to address finding are subrecipient award letters will be awarded to Canaan School District for the following grants: IDEA ? B IDEA-Pre-K Title I-A Title II-A Title IV-A Schoolwide Best Act 230 ARP IDEA Basic ARP IDEA Pre-K Tobacco ESSER 2021 ESSER II ? 2021 ARP ESSER -2021 Anticipated Completion Date: April 2023

Name of Contact Person: Niki Easley, Director HIV/AIDS Initiative Management Response:The subrecipient in question has been rendering services under the HIV Care Formula Grant for a span of over 20 years. Throughout this period, UWGN has experienced no performance or fiscal-related concerns with this subrecipient. Unfortunately, the subrecipient suffered catastrophic damage due to a natural disaster at their office space. Consequently, this has caused delays in obtaining the required audit due to the process of document recovery and relocation of office space. Given the circumstances faced by the subrecipient and their historical performance under the grant, UWGN made a decision to consider the Federal Form 990 as sufficient information temporarily. This measure was taken to prevent any additional negative impacts on the subrecipient?s operations until the completion of their audited financials. Corrective Action: The subrecipient is expected to receive their audited financials for 2021 and 2022 by Fall of 2023. UWGN will thoroughly review their audited report to identify any potential issues concerning the HIV Care Formula Grant, and if deemed necessary, appropriate actions will be taken. As of October 2022, UWGN has implemented a policy requiring an annual agency eligibility review process for all funded agencies, including subrecipients receiving fund through government grant from UWGN. This process ensures ongoing compliance and accountability for all parties involved. Proposed Completion Date: September 30, 2023

The Authority agrees with the finding and has implemented several new policies and procedures to strengthen controls surrounding the sub monitoring process. All staff are scheduled to complete a full monitoring cycle and have been scheduled for additional trainings. Additionally, weekly team meetings are conducted, and the Authority has updated its written procedures to address the sub monitoring deficiencies. Management and Supervisors will be responsible for weekly quality control tasks that include, reviewing system reports, weekly one on one meetings with the Assistant Director and any staff. The quality control and one on one meetings will be used to reduce and eliminate delayed submissions, closeouts, and notification letters. The Supervisors will run internal reports weekly to identify what inspections are due and ensure they are submitted timely.

Rural Health Care Services Outreach, Rural health Network Development and Small Health Care Provider Quality Improvement ? AL No. 93.912 Recommendation: Our auditors recommended that the Organization create 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. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Management?s response: The ROAMS grant did not clarify with the Network partners that receive $20,000 yearly stipends whether they were subrecipients or contractors, but instead assumed everyone was a contractor. We agree to this as a finding. We have since followed up with the stipend partners and all but one has declared their stipends as contracts. ROAMS agrees with the classification of three as contractors and one as a subrecipient which is described below: ? Union County General Hospital (UCGH): Both ROAMS and UCGH see this relationship as a contractor. The stipend pays for a Tele-OB room in their facility and the budget even lists rent as part of the reason for the stipend. The stipend per the MoU also supports their participation in the monthly Governing Council meetings, data collection, IT support for the program implementation and decision making. ? Questa Health Center/Presbyterian Medical Services (Questa): Both ROAMS and Questa see this relationship as a contractor. The stipend pays for an OB room in their facility and is even listed as rent in the stipend budget. The stipend per the MoU also supports their participation in the monthly Governing Council and decision making. ? UNM Envision (UNM): UNM declared a portion of their stipend over the three-year period they received as subrecipient. They declared $39,635 as subrecipient and they received a total of $68,000 from ROAMS. ROAMS always saw the relationship as a contractor and not a subrecipient and we do not understand why they have declared a portion of their stipend as subrecipient. UNM was not an essential grant partner, joined in year two to assist with data review, participated in the Governing Council, and ROAMS has a data evaluation agreement with UNM that we understood as a contract. This different understanding of the relationships highlights the audit finding that the type of relationship should be agreed upon upfront. ? Miners Colfax Medical Center (MCMC): sees themselves as a subrecipient and we agree. They are a state hospital and the other Labor and Delivery hospital in the ROAMS grant, and like Holy Cross Medical Center have a very high data reporting burden and serve as the home for the patients. The Memorandum of Agreement signed by all Network partners outlines their obligations in section IV Provision of Services and VI Records and Information (a. b. and c.). As we have investigated the monitoring of subrecipients verses a contractor, we have found that the same follow up is necessary, as long as the subrecipient receives less than $750,000 in federal funds in a year, which is the case for MCMC. Rural Health Care Services Outreach, Rural health Network Development and Small Health Care Provider Quality Improvement ? AL No. 93.912 (Continued) Our procedures for paying the stipend for both the contractors and one subrecipient (MCMC), have been attendance at the monthly Governing Council meetings, and deliverables from data collection, to IT support and meetings, workflow meetings, and clinical meetings. Reminders of deliverables that are pending are in the monthly Governing Council notes as is the attendance. ROAMS and the network partners were very clear in written documents and practice that the quarterly stipend payment was linked to participation and deliverables. We can provide you with monthly Governing Council notes to show this. A draft policy is in the works that will have the network partners formally declare their relationship as contractor or subrecipient and outline the monitoring of subrecipients. From our research we do not see the subrecipient monitoring being significantly different from a contractor unless the $750,000 threshold is met. The ROAMS grant did not clarify with the Network partners that receive $20,000 yearly stipends whether they were subrecipients or contractors, but instead assumed everyone was a contractor. We agree to this as a finding. We have followed up with the stipend partners and all but one has declared their stipends as contracts. ROAMS agrees with the classification of three as contractors. The ROAMS Director will request from the entities the audits for the CFO review to review for deficiencies on an annual basis. Name(s) of the contact person(s) responsible for corrective action: Connie Prewitt, Interim CFO Planned completion date for corrective action plan: Will implement in fiscal year 2023

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE ? U.S. DEPARTMENT OF THE TREASURY, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS ? FEDERAL ALN 21.027 2022-003 Internal Controls Over Compliance With Subrecipient Monitoring Requirements Finding Summary 2 CFR ? 200.332 requires the District as a pass-through entity, to have written subrecipient monitoring policies and procedures that include a written risk assessment of each subrecipient and documentation of the District?s monitoring of the subrecipient. Additionally, as a pass-through entity, the District is required to verify that every subrecipient is audited as required by 2 CFR ? 200 Subpart F when it is expected that the subrecipient?s federal awards expended during the respective fiscal year equaled or exceeded the threshold for a federal single audit. During our audit, we noted that the District did not have documented written controls to ensure compliance with the U.S. Office of Management and Budget?s Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) subrecipient monitoring requirements. The District did not maintain documentation of their evaluation of each subrecipient?s risk of noncompliance with federal statutes, regulations, and the terms and conditions of the sub-award, nor did the District maintain documentation of the results of the subrecipients? single audit, if any, for purposes of determining the appropriate subrecipient monitoring. Corrective Action Plan Actions Planned ? The District is in the process of reviewing and updating its written policies and procedures relating to subrecipient monitoring for its federal programs to ensure compliance with the Uniform Guidance in the future. Official Responsible ? The District?s Finance Supervisor, Janet Doman. Planned Completion Date ? June 30, 2023. Disagreement With or Explanation of Finding ? The District agrees with this finding. Plan to Monitor ? The District?s Finance Supervisor, Janet Doman, will assure appropriate internal controls and procedures are updated and in place to ensure compliance with subrecipient monitoring requirements.

The management team agrees with the auditor?s recommendation and has already implemented additional controls to address the stated concerns. Effective July 1, 2022, the City created a separate Grants division to centralize the application, compliance and administration of federal grants. This department is responsible for creating a City-wide Grants Policy and Procedures Manual related to grants including but not limited to: acceptance of an award, managing an award, initiating and monitoring subawards, programmatic and financial reporting and closeout of awards. The Grants Director is responsible for the corrective action as it relates to this finding.

2022 ? 007 (Previously 2021-003) Subrecipient Monitoring (Significant Deficiency and Noncompliance) Management?s Progress for Repeat Findings: The City Controller reviewed the listing of subrecipient risk assessments for 2022 and the listing was determined to be complete. The City will update the subrecipient monitoring policies and procedures ad provide training to the departments. Management Response: Management agrees with the finding. The City will develop standard City-wide subrecipient management policies and procedures including risk assessment and monitoring tools. Additionally, any federal program with two or more City departments managing subrecipients will use the same subrecipient tools to ensure consistency. Timeline and Responsible Position: June 2023 ? City Controller/DFAS Deputy Director

Cluster: Research and Development Federal Agency: All awards with subrecipients on the SEFA Award Names: All awards with subrecipients on the SEFA Award Numbers: All awards with subrecipients on the SEFA Assistance Listing Title: All awards with subrecipients on the SEFA Assistance Listing Number: All awards with subrecipients on the SEFA Award Year: 2021 - 2022 Pass-through entity: All pass-through entities noted on the SEFA Management agrees with the finding related to the Subrecipient Risk Assessments. To address these deficiencies Research Operations will update its subrecipient monitoring policy to explicitly state the ongoing monitoring activities that must be conducted and the frequency of required monitoring. Additionally, training will be provided to the staff who perform the risk assessment to ensure they are documenting the details of the review including the date and results of the subrecipient audit report review. Furthermore, updates will be made to the risk assessment procedure to ensure subrecipient annual audits are reviewed and the results of the review and follow-up are sufficiently documented. To ensure compliance, internal monitoring will be performed. Leadership Responsible: Barbara A. Vance, PhD, CRA, Vice President, Research Operations Anticipated Completion Date: 12/31/2023; Monitoring of compliance will continue throughout FY24