Corrective Action Plans

Temporary Assistance for Needy Families (TANF) ? Assistance Listing No. 93.558 Recommendation: We recommend the County determine whether an entity receiving payment under TANF is a subrecipient or a contractor prior to entering into an agreement with the entity and to include all guidance under 2 CFR 200.331 when making this determination. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Prior to the finding we have been working to properly classify entities that receive TANF fund as subrecipients versus contractors. We will continue to implement a process to analyze the entities that are receiving payments through TANF and make sure that we properly determine them as a subrecipient or a contractor. Once the determination is made, we will work with Legal and enter into the correct agreement with the entity. We will also perform the required monitoring for the TANF subrecipients. Name of the contact persons responsible for corrective action: Eddie Valdez ? Deputy Director, Candace Cadena ? Executive Strategist, Nick Beston ? Accounting Manager. Planned completion date for corrective action plan: July 1, 2024

DPH agrees with the finding and recommendations. DPH will notify its subrecipients about their subawards and include any changes in subsequent subaward modifications. DHSP will strengthen its review processes to complete and include the Notice of Federal Subaward Information form as part of the contract copy at the time of the contract execution.

Corrective Action Plan: The Agency has recognized a need to provide training and technical assistance to State Agencies and Departments. The Agency has created Uniform Guidance trainings that began in February 2023 and continue in March. These trainings include reference materials such as desk references, job aids, etc. As a follow-up to the training, we will be developing and delivering a subrecipient monitoring framework which includes tools to facilitate subrecipient risk assessments, subrecipient monitoring plans based on the initial risk assessment, testing of transaction records, desk reviews of low-risk subrecipients, and corrective action plans. Finally, we will be working to provide oversight and monitoring for agency adherence to subrecipient monitoring procedures, informed by program-level compliance risk assessment. Scheduled Completion Date of Corrective Action Plan: Completed: February 16, 2023: Uniform Guidance Training (Part 1) Expected: March, 2023: Uniform Guidance Training (Part 2) Expected: July, 2023: Subrecipient Monitoring Framework Provided to Agencies & Departments Expected: December, 2023: Sampling completed by Agency Expected: February, 2024: Post-Sampling Follow-up with Agencies and Departments Contacts for Corrective Action Plan: Doug Farnham Deputy Secretary, Agency of Administration Douglas.Farnham@vermont.gov (802) 585-8119 Holly S. Anderson Chief Financial Officer, Agency of Administration ? Financial Services Division Holly.S.Anderson@vermont.gov (802) 505-1177

The Supervisor and Director of the CDBG program are now meeting weekly with the staff person assigned for review the Single Audits to understand the workload and assist in ensuring the backlog and the current audits are all reviewed in a timely manner. Additionally, going forward, the Agency is working to fund an agency-wide compliance officer to ensure impartial oversight of the agencies programs with regard to federal requirements (including single audit review), as well as avoiding taking the time of the CDBG program staff away from their duties. Scheduled Completion Date for Corrective Action Plan: Completed: Reviewed audits selected for testing September 30, 2023: Supervisor and Director have assisted in reviewing to ensure backlog brought current August 30, 2023: new position for Agency-wide compliance officer funded and position-filled Point of Contact: Ann Karlene Kroll, Federal Programs Director annkarlene.kroll@vermont.gov; (802) 828-5225.

Recommendation: Providers that receive findings as a result of their on-site monitoring should submit a corrective action plan to the County. Action Taken: The County Child and Youth Services department will require a corrective action plan for all subrecipients with findings as a result of their on-site monitoring in 2023, and thereafter, that will include the entity?s plan to correct the errors noted, individual responsible and timeline for corrections to be implemented. Responsible Individual for Corrective Action: Angelique Hiers, County of Delaware Department of Human Services Director Completion Date: March 1, 2023

Recommendation: We recommend the Authority design controls to ensure subrecipients are responding to and addressing questions and findings within its monitoring reports. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Views of responsible officials and planned corrective actions: MF A uses the Tracker database to track monitoring deadlines electronically. The Tracker automatically sends reminders to all staff in the department every two weeks to follow up with pending and outstanding monitoring issues. However, some staff were not using the Tracker as intended. The Director will enforce and monitor the use of the Tracker and ensure staff follow up on the monitorings by the required deadlines. Name of the person responsible for corrective action: Chief Housing Officer Planned completion date for corrective action plan: November 30, 2022

Recommendation: We recommend the Authority design controls to ensure subrecipients are responding to and addressing questions and findings within its monitoring reports. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Views of responsible officials and planned corrective actions: MF A uses the Tracker database to track monitoring deadlines electronically. The Tracker automatically sends reminders to all staff in the department every two weeks to follow up with pending and outstanding monitoring issues. However, some staff were not using the Tracker as intended. The Director will enforce and monitor the use of the Tracker and ensure staff follow up on the monitorings by the required deadlines. Name of the person responsible for corrective action: Chief Housing Officer Planned completion date for corrective action plan: November 30, 2022

2022-010 Improve Controls over Subrecipient Monitoring Federal Agency: U.S. Department of Education State Entity: Department of Education (GaDOE) Corrective Action Plans: We have transitioned the subrecipient audit monitoring process to the Financial Review team within GaDOE which currently performs local educational agency (LEA) audit monitoring. The controls already in place for the Financial Review team?s LEA audit monitoring will be duplicated for nonprofit audit monitoring to ensure all required procedures are complete and timely. Additionally, we will review the Division of Federal Programs Handbook, the 21st Century Community Learning Centers (CCLC) Subgrantee Manual, and the 21st CCLC Internal Operations manual to ensure compliance to the Uniform Grants Guidance for subrecipient monitoring. Where needed, language will be added to each manual to clarify and emphasize that subrecipient monitoring includes application review, budget review, drawdown approval, completion report review in addition to virtual or onsite monitoring of specific program indicators. The 21st CCLC documents will be updated to ensure a clear subrecipient monitoring process is established for the final year of a cohort. This process will clarify that subrecipient monitoring during the last funded year will include application review, budget review, drawdown approval, and completion report review. Additionally, LEAs identified as ?high-risk? will have an onsite or virtual monitoring on specific 21st CCLC indicators. Estimated Completion Date: June 30, 2023 Contact Person: Metsehet Ketsela, Assistant Director Telephone: 678-472-7898; E-mail: metsehet.ketsela@doe.k12.ga.us

Department of Health and Human Services 2022-003 Immunization Research, Demonstration, Public Information and Education, Training and Clinical Skills Improvement Projects - Assistance Listing No. 93.185 Recommendation: We recommend the Foundation attend training, review federal requirements, and fully understand the requirements over indirect costs Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: CFGF will engage with external firm to assist with fully understanding requirements related to indirect costs and federal requirements. CFGF will also work with external firm to assist in the identification and selection of additional training opportunities for staff who work on federal programs. Name(s) of the contact person(s) responsible for corrective action: Brett Hunkins Planned completion date for corrective action plan: December 31, 2023 If the Department of Health and Human Services has questions regarding this plan, please call Brett Hunkins at 810-767-8270.

The County agrees with the finding and recommendation. On September 12, 2022, the County issued the ?Notice of Federal Subaward Information Template and Subrecipient Monitoring? memo, which provided departments with a template to communicate the 14 subrecipient reporting requirements from 2 CFR ?200.332(a) to their subrecipients at the time of the subaward. The memo also reminded departments to provide all the required elements from 2 CFR ?200.332(a) to existing CRF subrecipients that were not initially provided all the requirements. In addition, the memo reminded departments that subrecipient agreements must include detailed expectations for periodic reporting and timing of reporting submission. On January 12, 2023, the County issued the ?CARES and ARP Act Funds Subrecipient Monitoring? memo, which reminded departments that subrecipient agreements must include data encryption requirements. The memo also reminded departments that existing subrecipient agreements without data encryption requirements will need to be amended by departments. In May 2023, during the Single Audit Kick-off annual meeting, the County will include the issued ?Notice of Federal Subaward Information Template? on the presentation slides and remind departments that the template should be used to communicate the 14 subrecipient reporting requirements. The County will also reiterate that departments need to maintain documentation that the template was provided to subrecipients at the time of the subaward and existing subrecipients that were not initially provided all the subaward requirements.

Views of Responsible Officials and Planned Corrective Action The HPU Office of Sponsored Projects will work collaboratively with the Principal Investigators together to ensure that the required procedure for subrecipient monitoring is conducted and evidence of such procedure is maintained. The OSP staff will strengthen its policies and procedures so that the required subrecipient single audit report is obtained and reviewed periodically to confirm that the recipient is in compliance with all the applicable federal regulations. Person Responsible: Principal Investigator, Assistant VP of Office of Sponsored Projects and Manager of Office of Sponsored Projects, Grant and Contracts Specialist. Targeted Correction Date: June 30, 2023.

Corrective Action Plan - Finding 2022-001 The County will implement procedures to formally document and complete a risk assessment of sub-recipients (provider), and for the development of monitoring procedures to address the risks. This corrective action plan calls for the County's Human Services department to annually prepare a risk assessment for each provider for the fiscal period, and submit it along with the funding awards, if available, to the Butler County Controller office, by August 31st of each year. The County Controllers office will then by documenting that the amount of the awards, if available, agree to the County's general ledger. Additionally, the Controller's office will document whether or not a risk assessment has been performed for the provider. The funding award, along with the risk assessment shall serve as the basis from which the Controller's office will review the provider's audits and deficiencies. Provider audits for years-ending on December 31st are due within 180 days, or June 30th each year. Similarly, provider audits for year-ending June 30th are due within 180 days, or December 31st of each year. If an audit report is not received within six month, and an extension for time has not be granted, a delinquent letter will be issued by the Human Services department to the provider, not more than thirty (30) days after the deadline. For providers with a 12/31 year-end, the Controller's office will notify the Human Services department by September 30th each year, issuing a documentation that lists the provider that failed to submit an acceptable audit report; and further action will be documented by the Human Services department. Likewise, for providers with a 06/30 year-end, the Controller's office will notify the Human Services department by March 31st each year, issuing documentation that lists the providers that failed to submit an acceptable audit report; and further action will be taken and noted by the Human Services department. Audit opinions, findings, or deficiencies that indicate concern will be communicated by the Controller's office, to the Human Services department in a timely manner, but no less than ninety (90) days after the report was received by the Controller's office. In the event that a sub-recipient is issued a finding in their Single Audit, the County, either through the Board of Commissioners or the Human Services Department, shall furnish a written management decision to the Auditee, within six months of the audit being received by the Federal Audit Clearinghouse. The risk assessments and subsequent monitoring procedures, including review of the provider audits for the previous fiscal contract period, will be presented formally to the Board of County Commissioners, County Controller, and Director of Human Services by April 30th of the following year.

Responsible Contact Person(s): Ross McDonald, Director of Compliance Ousman Kah, Subrecipient Monitoring Coordinator Corrective Action Planned: The final version of the agency's Monitoring Plan will be completed by 6/30/2023. Estimated Completion Date: 6/30/2023

Responsible Contact Person(s): Ross McDonald, Director of Compliance Ousman Kah, Subrecipient Monitoring Coordinator Corrective Action Planned: A Grants Management solution is being pursued by DSS in anticipation that it can be deployed with Subrecipient Monitoring capabilities needed to comply with these requirements. Estimated Completion Date: 6/30/2024

Responsible Contact Person(s): Jennifer Cooper, Associate Director Senior Diana Clark, Compliance Coordinator Corrective Action Planned: SRM for the TANF Federal grant program will be included in the SFY2024 SRM Plan. Estimated Completion Date: 6/30/2023

Responsible Contact Person(s): Ross McDonald, Director of Compliance Ousman Kah, Subrecipient Monitoring Coordinator Kevin Platea, Deputy Chief Information Officer Corrective Action Planned: A Grants Management solution is being pursued by DSS in anticipation that it can be deployed with Subrecipient Monitoring capabilities needed to comply with these requirements. Estimated Completion Date: 6/30/2024

Responsible Contact Person(s): Danielle Robertson, Fiscal Officer Corrective Action Planned: The Emergency Rental Assistance program sub awarded funds to DHCD partner Virginia Housing Development Authority (VHDA). VHDA has been notified of the upcoming monitoring which has a planned completion date of on or prior to March 31, 2023. Estimated Completion Date: 3/31/2023

Responsible Contact Person(s): Jennifer Cooper, Associate Director Senior Diana Clark, Compliance Coordinator Corrective Action Planned: A risk assessment tool was developed as part of the SFY2024 SRM Plan and will be implemented with the new plan. Estimated Completion Date: 6/30/2023

Responsible Contact Person(s): Jennifer Cooper, Associate Director Senior Diana Clark, Compliance Coordinator Corrective Action Planned: Coordinator reviews the completed audit documents to ensure that all required audit documents are uploaded to the website based collaboration system timely and that reviews are conducted in accordance with the SRM Plan. A SRM monitoring desk tool will be created for Practice Consultants as a quick reference to the SRM Plan. Training for all Program Consultants conducting SRM will be provided on the new updated monitoring plan as well as ongoing training for newly hired Program Consultants. Estimated Completion Date: 6/30/2023

2022-002 STRIVING READERS COMPREHENSIVE LITERACY/COMPREHENSIVE LITERACY STATE DEVELOPMENT ? SUBRECIPIENT MONITORING ? NONCOMPLIANCE WITH SUBRECIPIENT GRANT AGREEMENT REQUIREMENTS ? ALN 84.371 ? MATERIAL WEAKNESS AND MATERIAL NONCOMPLIANCE Condition: Devils Lake Public School District did not prepare subrecipient grant agreements that included the elements as outlined in 2 CFR 200.332(a) for the Striving Readers Comprehensive Literacy/Comprehensive Literacy State Development programs. In addition, Devils Lake Public School District did not have procedures in place to ensure subrecipient grant agreements were prepared for all subrecipients and included all the required elements. Corrective Action Plan: We agree, Devils Lake Public School will make sure to sit down with any subrecipients and review all the requirements of the grant for their particular allocation. Anticipated Completion Date: We will start implementation on 7/1/2023 and continue with this moving forward.

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.

Finding Reference Number: SA2022-006 - Subrecipient Monitoring Assistance Listing Number: 21.027 Assistance Listing Title: COVID-19 ? Coronavirus State and Local Fiscal Recovery Funds Name of Federal Agency: Department of the Treasury Federal Award Identification Number: EES4XJFTXC28 ? Name(s) of the contact person: Karen Chang, Finance Director ? Corrective Action Plan: City will incorporate this information in our grant policy to ensure the program staff is aware of this requirement. ? Anticipated Completion Date: July 1, 2023

EXECUTIVE OFFICE OF LABOR AND WORKFORCE DEVELOPMENT 2022-013 WIOA Cluster ? Assistance Listing No. 17.258, 17.259, 17.278 Action taken in response to the finding: Beginning with fiscal year 2023, MHDCS has revised all Financial/Fiscal related documentation (i.e., Budget Sheets, Contracts) for sub- awardees to include the FAIN identifier as recommended through this finding. Further, MDCS has revised and enhanced its internal controls processes for scheduling, notification, and reporting of subrecipient monitoring by including an additional senior level signoff to confirm that all related documentation, required information including annual reviews, has been stored in a designated backup SharePoint data file beginning with Fiscal year 2023. Name of the contact person responsible for corrective action: Michael Williams, Director of Monitoring and Oversight, MHDCS Planned completion date for corrective action plan: December 2022

Office of State Treasurer Finding: 2022-036 Office of State Treasurer Response/Corrective Action Plan: The Office of State Treasurer does agree with finding that we were not in compliance with federal regulations related to providing required information to subrecipients of Coronavirus Relief Funds (CRF). Corrective action planned: 1. The Office of State Treasurer will work with ND Office of Management and Budget (OMB) to communicate to subrecipients timely and create a template for future use that includes the required information that was missed as detailed on the schedule of federal findings and questions costs. 2. The Office of State Treasurer has discussed with OMB that the information will not be recommunicated to the subrecipients as OMB has been in contact with subrecipients in guiding them to necessary information and assisting with any needs. It has been determined that communicating the information retroactively would cause more confusion and issues among the subrecipients. Contact Person: Nicole Krivoruchka Director of Finance Anticipated Completion Date September 3, 2023

Ref. No. Internal Control Findings 2022-001 Improve Controls over Recording of Non-routine Transactions - Material Weakness Recommendation County management should ensure that estimates are developed more timely to ensure proper recording in the County?s financial statements. View of Responsible Officials and Planned Corrective Action Management concurs with this audit finding. The Department of Finance will develop specific processes to ensure necessary estimates are developed and corresponding entries are booked in a timely manner for new occurrences (transient accommodations tax) or unusual events (bargaining unit grievances due to COVID-19). Additionally, the Department of Finance will work with the Department of Corporation Counsel to ensure that any potential liabilities regarding personnel matters are monitored and tracked on an ongoing basis. End Date: Ongoing Responding Person(s): Marci Sato, Accounting System Administrator Department of Finance Phone No. (808) 270-7503