Corrective Action Plans

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

2022-032 Oregon Housing and Community Services Ensure subrecipient risk assessments and fiscal monitoring are performed and required grant information is communicated timely to subrecipients Federal Awarding Agency: U.S. Department of Health and Human Services, Administration for Children and Families Assistance Listing Number and Name: 93.568 Low-Income Home Energy Assistance Program 93.568 Low-Income Home Energy Assistance Program (COVID-19) Federal Award Numbers and Years: 2001ORE5C3, 2020 (COVID-19); 2102ORLIEA, 2021; 2102ORE5C6 , 2021 (COVID-19); 2202ORLIEA, 2022 Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness; Material Noncompliance Prior Year Finding: N/A Questioned Costs: N/A Criteria: 2 CFR ? 200.332(a) ? (h) Federal regulations require that pass-through entities evaluate each subrecipient?s risk of noncompliance with federal statutes, regulations, and the terms and conditions of the subaward to determine the extent and scope of subrecipient monitoring activities. Monitoring activities should be based on the results of a given subrecipient?s determined risk. Pass-through entities must also communicate certain award information to subrecipients as the time of the subaward. The department, as the pass-through entity, has long-established subrecipient monitoring procedures broken into two categories: program and fiscal monitoring. Program monitoring is performed by program-specific staff and focuses on requirements related to certain aspects of Activities Allowed and Client Eligibility. During FY2022, the department performed program monitoring activities as planned. Fiscal monitoring reviews compliance requirements related to Allowable Costs, Activities Allowed, and Earmarking. However, fiscal monitoring activities were limited due to staff turnover. As a result, limited fiscal monitoring procedures were performed for 5 of 17 subrecipients, and fiscal monitoring risk assessments were not performed for any of the 17 subrecipients. Without the performance of subrecipient risk assessments and adequate fiscal monitoring, the department risks distributing program funds to subrecipients out of compliance with federal program requirements. Additionally, we reviewed 5 randomly selected subrecipients to determine whether all required grant award information was communicated at the time of the subaward. For all of the 5 subrecipients reviewed, only some of the required information was communicated at the time of the award. The required information missing in the original grant agreements was communicated via agreement amendments several months later. Without timely communication of required grant information, subrecipients may not have all the information they need for the subaward they received. We recommend department management ensure subrecipient risk assessments are performed for all subrecipients and ensure required fiscal monitoring activities are performed based on the results of the risk assessments. We also recommend department management ensure all required award information is communicated to subrecipients at the time of the subawards. MANAGEMENT RESPONSE: We agree with this recommendation. OHCS lost critical fiscal monitoring staff and was unable to complete all risk assessments and fiscal monitoring due to this. OHCS is on track to complete fiscal monitoring and risk assessments for all subrecipients of LIHEAP in FY23. Additionally, OHCS has established vendor relationships to perform fiscal monitoring as a backup for when staff vacancies exist. Anticipated Completion Date: June 30, 2023 Contact: Dean Criscola, Controller or Michelle Cole, Assistant Director of Energy Services

2022-016 ? Subrecipient Monitoring (Significant Deficiency) Department of Defense AL Number: 97.036 Program Title: Disaster Grants ? Public Assistance Direct Award from: Federal Emergency Management Agency (FEMA) Condition The requirement to evaluate each subrecipients? risk of noncompliance was not being conducted during the audit timeframe of the awards that were audited. There was internal miscommunication as to who in the Hawaii Emergency Management Agency (HIEMA) is responsible for performing the risk assessments. Current Status of Corrective Action Plan Concur. HIEMA has implemented a Risk Assessment Policy to ensure the assessments are completed at the beginning of the grant process and conducted annually to ensure continued compliance with all grant requirements. Resilience and the Grants teams will continue to work together to ensure this process is adhered to. Person Responsible Brian Fisher ? Hawaii Emergency Management Agency ? Disaster Assistance Project Manager Lauren Mark ? Hawaii Emergency Management Agency ? Grants Program Manager Anticipated Date of Completion The Risk Assessment Policy was implemented on February 8, 2023 and outlines steps to be taken by all Grants Team members and Resilience Branch Point of Contacts to ensure compliance.

2022-014 ? Subrecipient Monitoring (Material Weakness) Governor?s Office care of State Department of Budget and Finance AL Number: 84.425C Program Title: COVID 19 ? Education Stabilization Fund Direct Award from: U.S. Department of Education Condition 2 CFR Section 200.332(a) requires a pass-through entity to ensure that every subaward is clearly identified to the subrecipient as a subaward and provide specific Federal award information to subrecipients at the time of the subaward. 2 CFR Section 200.332(b) requires a pass-through entity to evaluate each subrecipient?s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. Due to the improper determination of the Research Corporation of the University of Hawai`i as a subrecipient rather than a grants contractor, State program management did not ensure Federal award information was included in the subawards to the entities ultimately determined to be first tier subrecipients. Current Status of Corrective Action Plan Concur. B&F will ensure that program personnel are familiar with all grant requirements including compliance with 2 CFR Section 200.332 (a) and (b) which requires the reporting of specific Federal award information to subrecipients and performing an evaluation of each subrecipient?s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward. Person Responsible Mark K. Anderson, Office of Federal Awards Management, Administrator Anticipated Date of Completion July 1, 2023

CORRECTIVE ACTION PLAN September 28, 2023 Crawford County Human Services respectfully submits the following corrective action plan for calendar year ended December 31, 2022. Name and address of independent public accounting firm: Maher Duessel, CPA?s 503 Martindale Street, Suite 600 Pittsburgh, PA 15212 Audit period: January 1, 2022 ? December 31, 2022 The finding from the December 31,2022 schedule of findings is discussed below: FINDING?SUBRECIPIENT MONITORING Dept. of Health and Human Services Passed through PA Dept. of Human Services Foster Care ? Title IV-E ? ALN 93.658 Finding 2002-002 Recommendation: We recommend that the County ensure adherence to the monitoring policy related to subrecipients and that these subrecipients be monitored on an annual basis in accordance with the policy. Action taken: Crawford County Human Services has created a Fiscal Technician position to aid in the monitoring process. The Fiscal Technician position has been approved by the County Commissioners and State Civil Service. Crawford County Human Services is activity recruiting for the position. The monitoring policy will be updated to insure inclusion of IV-E providers and will outline a set of criteria to determine the frequency of monitoring. Sincerely yours, Roberta Clark Fiscal Operations Officers Crawford County Human Services

Concur. The Highway Safety Section will abide by its written procedures policy which states that the Safety Section is responsible for issuing a management decision for audit findings that relate to Federal awards it makes to subrecipients and must do so within six months of acceptance of the audit report by the Federal Audit Clearinghouse. The Highway Safety Section shall ensure that subrecipients take appropriate and timely corrective action in addressing audit findings. In cases of continued inability or unwillingness to have an audit conducted as required, the Highway Safety Section shall take appropriate action using sanctions such as: (a) withholding a percentage of Federal awards until the audit is completed satisfactorily; (b) withholding or disallowing overhead costs; (c) suspending Federal awards until the audit is conducted; or (d) terminating the Federal award. Person Responsible: Lianne Yamamoto, Highway Safety Specialist Karen Kahikina, Highway Safety Specialist Christy Cowser, Highway Safety Specialist Kari Benes, Highway Safety Manager Anticipated Completion Date: December 31, 2023

MANAGEMENT VIEWS AND CORRECTIVE ACTION PLAN REPORT ON FEDERAL AWARDS IN ACCORDANCE WITH THE OMB UNIFORM GUIDANCE SEPTEMBER 30, 2022 Finding 2022-001 Subrecipient Monitoring To ensure Auburn University is in compliance with 2 CFR 200.332(b), 2 CFR200.332 (d), 2CFR 200.332 (e), and 2CFR (f). Auburn University will implement the following corrective action plan: The Office of Sponsored Programs will verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. The Office of Sponsored Programs has begun addressing this issue by enhancing the existing Subagreement Checklist utilized at the beginning of the subaward set-up. The new checklist provides a place for documenting the judgment around whether a new risk assessment should be performed, the results of the audit review, and the results of any necessary risk assessments. It also provides an opportunity for the administrator to detail the reasons for the risk assessment results. These documents will be monitored by the lead subaward administrator before the subaward is fully executed. Once reviewed, the lead subaward administrator will date and sign the checklist as verification that all applicable monitoring has been performed and gone through a two-step review process. The results will then be added to a master list that will be utilized when pulling the audit reports on a yearly basis for review. The checklist will be accompanied by a guide to completing the form and the regulatory backup for each applicable step. The Office of Sponsored Programs will evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. These procedures include (among other items) obtaining a certification letter or current audit from the subrecipient and performing an annual risk assessment on all subrecipients. Auburn University has also engaged in the implementation of an electronic research administration (eRA) solution that will include a subaward module. We expect the eRA system to be fully operational during the first quarter of fiscal year 2025. Additionally, the Office of Sponsored Programs is currently reviewing the required staffing levels to ensure the timely implementation and operation of the above-referenced procedures. Contact: Tony Ventimiglia Asst. VP for Research Administration, Office of the Senior VP for Research & Economic Development Amy Douglas Assoc. VP Financial Services/Controller Anticipated Completion Date: July 31, 2023

Name of the Contact Person Responsible for the Corrective Action Plan: Jeremi Patterson, Deputy Finance Director. Corrective Action Plan: The City of Forest Park will take necessary steps in the future to ensure that our subrecipient agreements include all of the required federal compliance language and we will ensure that risk assessments are performed for future subrecipients. Anticipated Completion Date: December 31, 2023

The City has implemented steps to be more proactive in subrecipient monitoring and will perform additional testing to meets these requirements.

SUBRECIPIENT MONITORING Recommendation: We recognize the agency has established a policy over sub-grant recipient files effective June 29, 2017. We recommend the policy begin to be enforced in fiscal year 2023. Also, we recommend any updating to the policy for implementation of effective internal controls and procedures over subrecipient monitoring and tracking that allow for compliance with all applicable federal laws, regulations, and compliance requirements of various federal grants. Corrective Action: The Department understands this issue. Administrative Services Bureau does complete subrecipient monitoring via desktop review and uses a monitoring checklist housed in the subgrant files. The Department has onboarded a Grants Unit Manager to include oversight of the subrecipient monitoring process. The process is currently being reviewed, modified, and implemented. Now that COVID restrictions have been lifted significantly, the Sub Grant Analysts will include physical monitoring visits as well as desk monitoring reviews as part of their job duties in FY23. Due Date of Completion: June 30, 2023 Responsible Person(s): Chief Financial Officer, Grants Unit Manager

SUBRECIPIENT MONITORING Division of Emergency Management (DEM) Assistance Listing Number 97.036, COVID-19 97.036 A new grant monitor has been hired for the recovery grants managed by DEM. The monitor has reviewed and updated the agency policies related to subrecipient monitoring and is conducting training with other program staff to ensure understanding. The Public Assistance (PA) Program in DEM has completed the Risk Assessment for 2022 using the risk assessment tool and identified the highest risk project worksheets. DEM is reviewing the municipal audits conducted by the State Auditor?s office for PA sub-recipients. DEM has developed a Monitoring Plan for the coming year and completed a calendar of upcoming monitoring visits. DEM is using the FEMA approved monitoring protocol and the subrecipient monitoring standards outlined in 2 CFR 200.303, and it is our belief that we are complying with all applicable regulations and requirements.