Corrective Action Plans

(A) CDOT will work with various divisions to devise a plan that will comply with this finding and the recommendations noted within. This plan shall include identifying a centralized location for all policies and procedures related to subrecipient monitoring. We will look at all policies and procedures to ensure they clearly identify responsibilities and requirements for non-compliance. (B) CDOT will work with various divisions to devise a plan that will comply with this finding and the recommendations noted within. This plan shall include establishing a process by which an analysis of contracted entities will be performed to identify and properly record entities as a vendor or subrecipient.

(A) The Department will update the policy to clarify the frequency in which the risk assessment is required to be completed or updated as applicable for contracts that span multiple fiscal years, as well as identifying exceptions, outlining when it is acceptable to forgo risk assessments. The Department will also update the policy to address the nature in which the subrecipient programmatic and financial reports are reviewed. The updates will be completed by November 2023. (B) The Department will provide training on the subrecipient monitoring policy manual to outline roles, responsibilities and the frequency of risk assessments that span over multiple fiscal years. The training will also provide guidance on the programmatic and financial information review process.

The Department of the Treasury (Treasury) strengthened its internal controls with DOLA?s agreement to disseminate the necessary information to the subrecipients in compliance with federal requirements for subrecipient monitoring and reporting for the Minerals Leasing Act program (Program) at the earliest possible opportunity following receipt of the recommendation in the previous FYE?s report as the monitoring and reporting for the Program could only be performed following the annual distribution of such funds which took place subsequent to FYE 2022. The Department will formalize an Interagency Agreement with DOLA and any other relevant parties, incorporating additional corrective action before the stated date above (June 30, 2023).

Assistance Listings Number: Program Name: 97.024 Emergency Food and Shelter National Board Program Name of contact person: Regina Kelly, Director, Grants Management & Innovation Anticipated completion date: June 2024 Response: Pima County agrees with the finding. Pima County's federal award expenditures have more than quadrupled since 2018, dramatically increasing the volume of subrecipients and the need for monitoring. The County recognized this challenge and procured services from a third-party entity to conduct subrecipient monitoring in the short term and assist in the development of a robust and effective subrecipient monitoring program to effectively address the rapid growth of subrecipient monitoring needs.

Federal Program Name: ? Block Grants for Community Mental Health Services ? ALN 93.243 ? Section 223 Demonstration Programs to Improve Community Mental Health Services ? ALN 93.958 Recommendation: Our auditors recommended the Organization revise their Subrecipient Monitoring Policy to include performing subrecipient risk assessments on all subrecipient relationships that the Organization enters into. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Management?s response: Management concurs with the finding. While the Subrecipient Monitoring Policy was updated, Mental Health Partners did not have procedures in place to ensure risk assessments were performed on all subrecipients for each grant period. The Controller, Grants Manager, and Contracts Manager are currently updating the internal controls and procedures to ensure that risk assessments are performed for each subrecipient for each grant period in compliance with 2 CFR 200.332(b). Planned completion date for corrective action plan: Will implement in fiscal year 2023.

Wabanaki Public Health and Wellness received our FY21 audit in April 2023, which did not allow for the changes to be made in time for FY22. The corrective action plan from FY21 continues to be our course of action and will be fully implementing the following to ensure compliance in FY23. Wabanaki Public Health & Wellness followed sections of the subrecipient monitoring for requirements of documentation and follow through, however there were areas in which the audit team brough forth to light that needed some enhancing for procedures. WPHW will follow through with full review of the OMB standards for the subrecipient monitoring and build a check list to determine that each required section/item is followed throughout the period of award. The WPHW team, which includes, the Director of Finance, Financial Quality and Compliance Manager, and the Contract Specialist will be working together to build the required list and procedure and reviewing the checklist for when the award is first presented to allow both parties, (sub awardee and WPHW) to understand the requirements for the award. Throughout the award period WPHW will maintain required documentation following the CFR 200.332 guidelines. The Financial Quality and Compliance Manager will review processes through the periodic review of all awards to verify that monitoring has been completed at the deemed timeframe and all parties involved are maintaining the set forth requirements of the award. Person(s) Responsible: Beth McLean Timing for Implementation: Summer 2023

View of Responsible Officials The Department of Energy recognizes the need to include all required information to be communicated to sub-recipients, and that all sub-recipients? risk assessments are thoroughly completed. In addition, uniform guidance reports need to be collected and reviewed to ensure that management letters be issued within the required timeframe. Anticipated Completion Date: Ongoing Contact Person Eileen Smiglowski, NH LIHEAP Administrator

agreement. View of Responsible Officials A. We concur with this finding. The Department utilized an internally available copy of the Management Log, which lists vendor?s determinations. This is a copy of the log, not the original, official copy. There is a delay in updating this copy from the original, and incorrect information had been initially entered. The Department is moving this log to software which allows all Department employees to view the same log, while limiting the number of individuals who have access to make changes. Implementation has been completed as of March 2023. B. We concur with this finding. However, we believe this was an isolated incident as the TANF CFDA number (93.558) used was very similar to correct CFDA number (93.778) that should have been documented. C. 200.332 requirements a. We do not concur with this finding. The contract for Mt Prospect became effective 8/4/21, prior to the 4/22 inception of the UEI. The DUNS number, as in effect at that time, is noticed in Exhibit J of the contract. b. We concur with three of the four findings. Two of the four contracts pre-date the template update requiring the notice an indirect cost rate. Indirect cost rate for federal awards (including if the de minimis rate is charged per 2 CFR section 200.414) were added to Exhibit C of the Department?s contracts in April 2020. One of the contracts did not indicate an indirect cost rate as required. One of the contracts notes the indirect cost rate in the Notes of their financial details. c. One of the two contracts pre-dates the template update requiring the notice the identification of R&D. R&D identifications for federal awards were added to Exhibit C of the Department?s contracts in April 2020 One of the two contracts did not identify whether the contract was R&D as required. D. Subrecipient Risk Assessment ? We concur with the finding. We consider the finding to be fully resolved through Department policy Department policy and Department wide implementation. However, it should be noted full compliance will not be achieved for one to two contact cycles due to timing. The Department began addressing the issue of Subrecipient Monitoring issue in June 2017 when the first Grants Administrator was hired. The Department finalized the Subrecipient Monitoring Policy, which encompasses the financial and programmatic risk assessments as well as the subrecipient monitoring, on June 1, 2018. The Department provided user training on the subject in February and September 2018, training over one hundred forty-six staff. However, only brand new procurements utilized this policy during the initial roll out of this policy. The Department hired a new Grants Administrator in May 2019. The full Subrecipient Monitoring policy rolled out to all procurements, including sole source, amendments, and renewals, effective August 1, 2020. The Contracts Unit received specialized subrecipient monitoring training on May 13 and October 28, 2020. Department wide training to all staff occurred weekly between September 8 and November 3, 2020. The Grants Office provided additional targeted training to Program staff through team meetings. Over one hundred fifty Program and Finance staff received training. Annual training will be held in September each year. Refresher training or training for new staff is available upon request from the Grants Office. The Grants Office website offers Program, Finance, and Contracts Bureau staff access to the subrecipient monitoring policy, as well as training modules, slides, and tools. The training has also been recorded and is available on this site. The Subrecipient Monitoring Policy requires Program to determine whether any vendor which receives funds in exchange for goods or services is a Contractor or Subrecipient. Determined subrecipients receive a Management Questionnaire, which includes a ten question questionnaire and requirements for submitting financial data. This information is used to populate the Risk Assessment Tool, which shows any risks pertinent to a subrecipient and the subaward. Based on the risks shown, Program chooses monitoring activities to mitigate the risks and the Contracts Bureau memorializes these choices in the contract. The Grants Office continues to work closely with the Contracts Bureau to ensure compliance with the Subrecipient Monitoring policy. C. and D. It is also important to note that between April 2020 and June 2022 the Department was involved in the State?s strategic response to the COVID-19 pandemic. During this time, New Hampshire was under a state of emergency (Executive Order 2020-04), processes were rapidly converted to fully digital overnight, the State?s standard approval processes were suspended and non-standard templates, which did not include the required notifications under 200.332, were utilized to respond to the COVID-19 pandemic. The Department worked with other State Departments and the National Guard to create a record number of amendments, contracts, and other agreements (approximately 200% more than standard). The Department is in the process of instituting a new contract life cycle management solution that will utilize conditional logic to include the required notifications for agreements involving federal funds in order to ensure compliance. Implementation is anticipated to be complete in July 2023. As the COVID-19 pandemic strategic response has wound down, the Department has not suspended its regular standard approval or subrecipient risk assessment and monitoring processes and has not used non-standard templates to award federal funding. E. We concur there was no formal documentation of any monitoring activity. Due to staff turnover a new administrator has been hired and unable to furnish the monitoring that took place during FY22. However, a program site review during FY23 was performed and financial monitoring of invoices has also taken place. Anticipated Completion Date: July, 2023 Contact Person: Melissa Kelleher, Administrator Rejoinder As documented above in Bullet B of the condition found, the Department did not properly communicate all required award information to the subrecipient. Once aware of the noncompliance, the Department should have timely communicated this information to its subrecipients.

View of Responsible Officials The Department will review its Sub-recipient Monitoring Policy and assess compliance across the Department. It is important to note that between April 2020 and June 2022 the Department was involved in the State?s strategic response to the COVID-19 pandemic. During this time, New Hampshire was under a state of emergency (Executive Order 2020-04), processes were rapidly converted to fully digital overnight, the State?s standard approval processes were suspended and non-standard templates were utilized to respond to the COVID-19 pandemic. The Department worked with other State Departments and the National Guard to create a record number of amendments, contracts, and other agreements (approximately 200% more than standard). The Department is in the process of instituting a new contract life cycle management solution that will utilize conditional logic to include the required notifications for agreements involving federal funds in order to ensure compliance. Implementation is anticipated to be complete in July 2023. As the COVID-19 pandemic strategic response has wound down, the Department has not suspended its regular standard approval or subrecipient risk assessment and monitoring processes and has not used non-standard templates to award federal funding. The Financial Compliance Unit (FCU) will continue to work with the Business System Analyst of the Cost Allocation Unit in determining the amount of Federal payments made to the vendors. The FCU receives a vendor payment list on a quarterly basis that includes the total amount of Federal funds that were paid to all contracted agencies. We will continue to closely monitor the FAC to obtain all copies of the Single Audits pertaining to the DHHS agencies. In addition, we will devise a spreadsheet that will list all contracts that have been awarded Federal funds and cross check these agencies to vendor payment list. The DHHS updated the policy on risk assessment on November 16, 2020 to ensure that all contracts have a risk assessment performed regardless of funding source. We also have added verbiage in the contracts effective for contracts that begin after November 2021. It states any Contractor that receives an amount equal to or greater than $250,000 from the Department during a single fiscal year, regardless of the funding source, may be required, at a minimum, to submit annual financial audits performed by an independent CPA if the Department?s risk assessment determination indicates the Contractor is high-risk. Finally, effective for any new procurement subsequent to March 2022, all back-up documentation must accompany the invoices and be submitted on a monthly basis. Anticipated Completion Date: July 2023 Contact Person: Melissa Kelleher, Grants Administrator, Ann Driscoll, Financial Compliance Unit

Program: Homeland Security Grant Program Federal Financial Assistance Listing Number: 97.067 Federal Grantor: U.S. Department of Homeland Security Passed-Through: California Office of Emergency Services Award No. and Year: 2019-0035 and 2020; 2020-0095 and 2021 Compliance Requirements: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control and Instance of Noncompliance Criteria: 2 CFR section 200.332(b), Requirements for Pass-Through Entities, states that all pass-through entities must evaluate each subrecipient?s risk of noncompliance with Federal statues, regulations and the terms and conditions of the subaward for purpose of determining the appropriate subrecipient monitoring. Condition: During our testing of Homeland Security Grant Program (HSGP) of the Sheriff-Coroner department?s provisions for evaluating subrecipient?s risk of noncompliance with Federal statutes, regulations and the terms and conditions of the subaward, we noted for two (2) of two (2) subrecipients selected, the required evaluation of the subrecipient?s risk of noncompliance was not documented. Further, onsite reviews were not performed. Cause: The Sheriff-Coroner department did not adhere to established policies and procedures relating to documentation of the risk assessment when a subrecipient contract is awarded. With respect to onsite reviews, these were not performed due to COVID restrictions. Effect: There is an increased risk that the monitoring procedures performed may not address the subrecipient?s risk of noncompliance. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: The entire population of two (2) subrecipients were selected for subrecipient monitoring testing from the Sheriff-Coroner department for the Homeland Security Grant Program. Repeat Finding from Prior Years: No. Recommendation: We recommend that the Sheriff-Coroner department follow the implemented policies and procedures to ensure that the required evaluation of the subrecipient?s risk of noncompliance be documented in accordance with 2 CFR section 200.332(b). Management Response and Corrective Action: Sheriff-Coroner?s Department: 1. Person Responsible: Yumi Leung, Supervising Grants Manager 2. Corrective action plan: The Sheriff-Coroner Department will complete a pre-award risk assessment form at the time the subrecipient is notified of a subaward. The Sheriff-Coroner Department resumed subrecipient monitoring visits starting January 2023. Going forward, if on-site visits are not possible, virtual meetings with subrecipients will be conducted. 3. Anticipated Implementation date: June 2023

Program: Foster Care Federal Financial Assistance Listing Number: 93.658 Federal Grantor: U.S. Department of Health and Human Services Pass-Through: California Department of Social Services Award No. and Year: 2201CAFOST and 2022, 2101CAFOST and 2021 Compliance Requirements: Subrecipient Monitoring Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria: In accordance with Title 2 U.S. Code of Federal Regulations (CFR) 200.332, pass-through entities must comply with the following: ? 2 CFR 200.332(d) ? Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include the information at 2 CFR 200.332(d)(1) through (4). ? 2 CFR 200.332(f) ? Verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 200.501. The California Department of Social Services further clarifies in its County Fiscal Letter No. 21/22 ? 115 that Foster Family Agency (FFA), Group Home, and Short Term Residential Therapeutic Programs (STRTP) are ?considered subrecipients and subject to the same audit requirements and require the same degree of oversight as other subrecipients?. Further, while there are some licensing and oversight functions performed by the state over FFAs, group homes, and STRTPs, ?counties are still ultimately responsible for review of these audits and their findings, any follow- up to ensure compliance, and any other form of monitoring and oversight required by federal and state laws and regulations.? Condition: The County did not have any formal controls or procedures in place for subrecipient monitoring for the Foster Care program. Cause: The County did not maintain procedures to monitor the activities of each subrecipient, or verify that every subrecipient is audited, as required. Effect: The County did not maintain policies and procedures to align with the Subrecipient Monitoring requirements in 2 CFR 200.332 and did not comply with subrecipient monitoring requirements related to the program. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of eight (8) out of 53 subrecipients were sampled, which included six (6) FFA, and two (2) STRTP types. The condition noted above was identified during our procedures related to subrecipient monitoring, and was pervasive to the program. Repeat Findings from Prior Years: No. Recommendation: We recommend that the County implement policies and procedures in accordance with 2 CFR 200.332 to ensure compliance with subrecipient monitoring requirements. Management Response and Corrective Action: Social Services Agency: 1. Person Responsible: Kristi Fiskum, Deputy Division Director, Family Assessment & Shelter Services and Karen Vu, Administrative Manager II, Contracts Services 2. Corrective action plan: SSA will revise its current Subrecipient Monitoring Policy in accordance with 2 CFR 200.332 to ensure compliance with subrecipient monitoring requirements. SSA will include procedures for verifying that every subrecipient is audited and a monitoring checklist will be developed to track activities. 3. Anticipated Implementation date: July 1, 2023

Finding Number: 2022-012 Federal Program, Assistance Listing Number and Name: ALN 21.027, Department of Treasury, COVID-19 Coronavirus State and Local Fiscal Recovery Fund (CSLFRF) Condition: Original Finding Description: The CSLFRF subrecipient agreements did not include the CSLFRF assistance Listing Number (ALN) as required per 2 CFR 200.332 (a)(1)(xii). Contact Person Responsible for Corrective Action: Sandra Yu Stahl and Terri Daniels Anticipated completion date: July 2023 Planned Corrective Action: The City has implemented a process to ensure that all subrecipient agreements contain the Federal ALN as required by 2 CFR 200.332. All subrecipient agreements will include a new exhibit as an attachment in the agreement that will include the ALN and any other required grant elements.

Views of Responsible Officials and Planned Corrective Actions: The County should review the monitoring plan related to the program to ensure these procedures are done timely and meet the federal requirements for monitoring subrecipients.

Program: AL 21.026 ? COVID-19 Homeowner Assistance Fund ? Subrecipient Monitoring Corrective Action Plan: N/A Contact: Major General Daryl Bohac Anticipated Completion Date: N/A

Program: AL 20.509 ? Formula Grants for Rural Areas ? Allowability & Subrecipient Monitoring Corrective Action Plan: The Controller Division, Audit Section, will provide support through continued engagement and work collaboratively as an additional resource to the NDOT Transit staff and transit recipients. NDOT Transit staff in collaboration with the Controller Division will be improving the standard operating Procedures which will be utilized for the in-depth review of monthly invoices moving forward. Contact: Khalil Jaber Anticipated Completion Date: Ongoing

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.