Corrective Action Plans

Finding 2024-001: Subrecipient Monitoring Federal Agency: U.S. Department of Housing and Urban Development Frogram Name: COVID 19 — HOME Investment Partnerships Program and HOME Investment Partnerships Program (HOME) - ALN 14.239; Award Identification Number: MC420501 Criteria of Specific Requirement: Per 2 CFR 200.332, a pass-through entity must monitor the activities of subrecipients 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. Condition: During our testing of subrecipient monitoring, we noted that the City did not perform required monitoring procedures during the year. Questioned Costs: Unknown Cause: The City did not have adequate internal controls in place to ensure compliance with subrecipient monitoring requirements, and staffing turnover contributed to the lack of oversight. Effect: The City was not in compliance with subrecipient monitoring requirements. Identification as a Repeat Finding: This is not a repeat finding from the prior audit. Recommendation: We recommend the City implement controls to ensure compliance with subrecipient monitoring, documenting monitoring activities performed and following up on any identified deficiencies in a timely manner. Views of Responsible Officials and Planned Corrective Actions: Management agrees; see corrective action plan below. History The City initiated monitoring of the HOME program in March 2023, and the local office of the Department of Housing and Urban Development (HUD) initiated its own monitoring in June 2023. To avoid duplicative work, the City shifted its approach and reviewed closed programs while HUD monitored open programs. These monitoring efforts resulted in significant updates to program policies and procedures. The City's monitoring was completed in October 2023 and HUD's monitoring was finalized in October 2024. Correction Action Plan Since October 2024, the City has collaborated with its subrecipient, the Urban Redevelopment Authority (URA), to implement a streamlined, informal quarterly review process. While formal HOME monitoring has not occurred since the end of the HUD monitoring, the City will initiate a review before the end of 2025 to return to compliance. Monitoring will occur annually moving forward.

Management agrees with the finding. Management has downloaded 2 CFP Part 200 for review and to familiarize. Assistance has been requested to develop additional policies in accordance with the Uniform Guidance. Policies will be reviewed and approved by the Board regularly. Contact Person: Renee LaFleur, Executive Director Anticipated Date of Completion: December 31, 2025

August 15, 2025 United States Department of Agriculture National Institute of Food and Agriculture Awards Management Division 805 Pennsylvania Ave Kansas City, MO 64105 Attention: Federal Audit Clearinghouse (FAC) Subject: Corrective Action Plan Submission – Finding #4 – Sovereign Equity Fund – Fiscal Year End 12/31/2024 To Whom It May Concern: Subrecipient Monitoring - Subrecipient agreements lacked required federal clauses and were not monitored according to risk assessments. Corrective Actions: • Develop a subrecipient monitoring policy aligned with 2 CFR §200.331-333. • Standardize agreement templates to include all required clauses for federal award subrecipient agreements (e.g., audit requirements, FFATA, termination provisions). • Implement a subrecipient risk assessment tool to determine monitoring frequency and risk level identification. • Assign staff for annual subrecipient desk reviews or site visits based on risk levels. Responsible Party: Executive Director / Legal & Compliance Team Target Completion Date: Risk assessment and financial monitoring tool in use and agreement templates updated within 45 days. Sincerely, Courtney Chavis Executive Director

FINDING 2024-003 Finding Subject: COVID 19 Coronavirus State and Local Fiscal Recovery - Subrecipient Monitoring Contact Person Responsible for Corrective Action: Gretchen Parker Contact Phone Number and Email Address: 765-648-6113 gparker@cityofanderson.com Views of Responsible Officials: "We concur with the finding." Description of Corrective Action Plan: The city has several individuals involved in the monitoring of activities related to the COVID 19 Coronavirus State and Local Fiscal Recovery federal award. The city has implemented procedures to ensure oversight and review of subrecipient reports is properly documented. Anticipated Completion Date: September 1, 2025

To address this finding, AACC will adhere to the financial policies and procedures properly documenting the fraud risk assessments to determine the level of risk (Low, Medium, High), and will properly document all necessary monitoring procedures (Financial Policies and Procedures, pages 45-53). Additionally, AACC has developed a risk assessment policy that will accompany AACC’s Subrecipient Award and Monitoring Policy developed in 2021. The appropriate signatures and corrective action plans and follow up with be managed in a timely manner.

Finding 2024-004: Subrecipient Monitoring U.S. Department of Commerce, Economic Development Cluster- Assistance Listing Number 11.307 Questioned Costs: Unknown Condition: The Organization does not have formal subrecipient monitoring policies and procedures in place to document the assessment of risk for subrecipients. Specifically, there is no documented review of subrecipient financial or performance reports, no formal risk assessments conducted prior to disbursement of funds, and no site visits or other monitoring activities to ensure compliance with award terms and federal regulations. In addition, the Organization does not have procedures in place to adequately review the subrecipient audits received, ensure that audit requirement language is included in each contract, or notify the subrecipient of the subaward ALN and amount that was paid during the year. Action: InnovatePGH will implement monitoring procedures for subrecipients, including risk assessment, site visits as deemed appropriate, and review of reporting and audits.

FINDING – FINANCIAL STATEMENT 2024-001 Financial Statement Recommendation: We recommend that the Organization implement the necessary internal controls to ensure that accruals are properly recorded and the associated expenses and revenues are recorded in the proper period. Explanation of disagreement with audit findings: Management concurs with the finding and will implement effective internal controls to ensure that financial information is reported in accordance with GAAP. Action Plan: The Finance & Administration Director has updated the Accounting protocol guide and Grants Internal Control guide instructing staff how to identify accrual expense invoices. These policies establish procedures for recording accrual expense invoices to ensure that all expenses are properly recognized in the correct accounting period in accordance with Generally Accepted Accounting Principles (GAAP). This policy applies to all accounting and grant management staff responsible for processing and recording expense transactions, including accounts payable, month-end closing and journal entries, and other financial reporting activities. In addition, on Sept. 11, 2025, a training program was developed and administered to accounting staff to ensure they understand this policy. The Finance & Administration Director will conduct quarterly internal reconciliations and reviews to audit compliance and identify areas of error. This process is tracked in the Asana project management tool. The Finance Director will review all invoices for appropriate invoice dates so that accrued expenses will be posted to the correct period. And lastly, the Grants Finance Manager and Finance & Administration Director will review journal entries, financial statements, and key estimates (such as allowances for doubtful accounts or depreciation methods) further ensure accuracy. Name(s) of the contact people responsible for correction action: Renee Kempka, Finance & Administration Director U.S. Department of Agriculture 2024-002 Assistance Lising #10.163 – Market Protection Program Recommendation: The Organization should establish written policies and procedures regarding the contracting and monitoring of subrecipients that are in line with Uniform Guidance requirements, as well as establish organizational controls to ensure that such policies and procedures are being followed. Explanation of disagreement with audit findings: Management concurs with the finding and will implement effective internal controls to ensure that subrecipient monitoring is properly done and documented appropriately. Action taken in response to finding: Upon discovery of the initial audit finding, an accrual journal entry was created to correct the subrecipient invoicing between 2025 and 2024. The adjusting journal entries and updated financial statements were submitted to Kern & Thompson, who we engaged to conduct the financial audits. This altered previous financial statements for 2024 and 2025, and the SEFA. Action Plan: The late reporting was primarily due to delays in receiving invoices from the subrecipient after the fiscal year end closing. The Education and Advocacy Director will send out quarterly reminders to partners informing them of the invoice due dates. Subrecipient partners will be expected to submit the invoice within the allotted time of 30 days after the closing of the reporting period. The Grant Finance Manger will conduct a review of all active subrecipient partners to ensure invoices have been received and recorded in the corresponding fiscal period for which the activity was conducted. If the invoice is not received, a courtesy reminder email and/or phone call will be sent to let the partner know that if the invoice is received outside of the 30 days, it will no longer be allowable. 21 days after the close of a quarter, the Finance Director and the Grants Finance Manager will meet and audit the sub-recipient budget against what has been submitted for payables. A list of partners who have not submitted invoices will be created with subsequent intent to contact the organization. This task will be tracked for completion according to timelines in the Grant Internal Control Asana project. Name(s) of the contact people responsible for correction action: Abigail Soto, Grants Finance Manager, Ben Bowell, Education & Advocacy Director and Renee Kempka, Finance & Administration Director Plan completion date for corrective action plan: 09/11/25

FFT will monitor its subcontractor for compliance in the future.

Finding Number 2024-001 Contact Person(s): Kim Goodman, Finance Director Corrective action planned: The Association acknowledges the audit findings and recognizes the importance of strengthing internal control processes to ensure staff understand the nature of a subrecipient vs a contractor, and that they ensure that this determination is being reviewed, and clearly communicated in underlying agreements, as part of their internal control processes. The following corrective actions have been taken: • All 23-25 AJA Grantees will be provided agreements with the correct designation of "sub recipient." • All 25-27 AJA and MHFR Grantees will have the designation of "sub recipient." Anticipated completion date: Completed June 30, 2025

System of Internal Controls Over Compliance: Subrecipient Monitoring; U.S. Department of Treasury, Assistance Listing #21.027, Coronavirus State and Local Fiscal Recovery Funds, Passed Through State of Nevada Criteria: In accordance with 2 CFR 200.332, the auditee must maintain a system of internal control over compliance to ensure they provide each subrecipient within the required appropriate document the performance of internal controls over the compliance for subrecipient monitoring. Condition: The Organization did not appropriately implement internal controls necessary to ensure appropriate documentation was available to support the performance of controls in compliance with 2 CFR 200.332. Context: The Organization did not identify funds being passed through from one subsidiary of the Organization to a second subsidiary in a timely manner and based on this timing did not appropriately document the performance of internal controls over the compliance of subrecipient monitoring. Cause: The Organization did not identify its only subrecipient for this award in a timely manner. Effect: The Organization was not able to properly document its performance of internal controls over most of the requirements outlined in 2 CFR 200.332 for the award based on untimely identification of its subrecipient. Recommendation: We recommend management design and implement a system of internal controls over compliance where consideration of possible subrecipients is considered when the award is being applied for and that well documented and supportable internal controls over subrecipient monitoring are implemented when there are subrecipients identified under an award. Views of Responsible Officials and Planned Corrective Actions: SJRC NV Region is addressing its missing controls related to the requirements of 2 CFR 200.332. We acknowledge that SJRC must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the information required under 2 CFR 200.332 at the time of the subaward all requirements. This includes that every subaward is clearly identified to the subrecipient as a subaward and includes at the time of the subaward and if any data elements change, that there must be an approved subaward modification. We will also ensure we meet the requirements under 2 CFR 200.332 to include our obligations to risk assess and monitor any subrecipients. The timeframe for correction is immediate and full accounting system control improvements will be implemented as part of our 2025 fiscal year-end close. Submitted by: Dr. Christina Vela, DPP Chief Executive Officer St. Jude's Ranch for Children, Inc. and its subsidiaries cvela@stjudesranch.org

The County concurs with this finding and will be working to enhance internal controls over the adherence to our policies and procedures in accordance with 2 CFR 200.332 to ensure compliance with subrecipient monitoring requirements.

New policy was to be implemented by August 31, 2025 that will include written agreements with subaward programs and the Grants Manager will monitor the plan, with additional monitoring to be completed by the Exective Director periodically.

Management agrees with the finding and is implementing the accompanying corrective action plan. Views of Responsible Officials: Jacy Hyde, Executive Director Joel Rusco, Chief Financial and Administrative Officer Jessica Martinez, Deputy Director Contact Person: Joel Rusco, Chief Financial and Administrative Officer Jessica Martinez, Deputy Director Corrective Action Plan: In response to FY21 Corrective Action Plan, CFSC implemented an updated Subrecipient Monitoring Policy in June 2024 to ensure compliance with Uniform Guidance, including subrecipient risk assessment and audit review requirements. To further strengthen compliance and eliminate inconsistencies in subrecipient risk assessments, CFSC will implement the following corrective actions: 1. Mandatory Pre‐Award Risk Assessment & Documentation: a. The Grants Manager will ensure that a Subrecipient Risk Assessment Form is completed and documented for all subawards before execution. b. Risk assessment findings will be stored in the subrecipients grant file and reviewed during routine monitoring. c. Any subrecipients classified as high risk will be subject to enhanced monitoring procedures to be carried out by the assigned Grant Specialist, which may include additional financial oversight and/or more frequent reporting. 2. Systematic Audit review & compliance tracking: a. The Grants Manager will be responsible for ensuring timely collection and review of subrecipient audit reports. 3. Quarterly Compliance Audits of Risks Assessments & Audit Reviews: a. The Grants Manager will conduct quarterly internal audits to confirm: i. All subrecipients have undergone documented risk assessments before receiving funds. ii. All subrecipient audits have been collected, reviewed, and properly documented. iii. Any identified audit findings have been addressed with documented corrective actions. Anticipated Completion Date: Corrective actions regarding mandatory pre‐award risk assessment & documentation (item 1) and systematic audit review &compliance tracking (item 2) have been fully implemented as of quarter 2 of FY25. CFSC has begun to implement the quarterly compliance audits (item 3) and will have this fully implemented by the end of FY25.

2024-001: Internal Control Over Compliance with Subrecipient Monitoring and Noncompliance with Subrecipient Monitoring U.S. Department of Health and Human Services; Passed through the State of Tennessee Department of Health: ALN #93.558 Temporary Assistance for Needy Families Management’s Response: We concur. View of Responsible Officials and Corrective Action: United Way has an Agency Eligibility Review (AER) to ensure an organization is financially sound prior to awarding funding. As part of this process, subrecipients are required to provide their most recent From 990, as well as audited or reviewed financial statements, based on their gross revenue. United Way utilizes the AER as part of subrecipient application process government grants awarded to United Way. Historically, the majority of the government grants awarded to United Way have been for a 12-month period. However, the Temporary Assistance for Needy Families grant represents the first multi-year grant received by United Way from the State. Due to the multi-year nature of this award, United Way initially obtained financial records only after subrecipients entered the program. Going forward, we will review our processes to ensure financial records are collected and reviewed in a timely manner for all multi-year grants. The Senior Director of Innovation & Strategy and the Senior Director of Finance will obtain and review the most recent audited financial statements for the subrecipients. Supporting documentation will be maintained with the grant activity to ensure proper compliance documentation is kept. Name(s) of the Contact Person(s) Responsible for Corrective Action: Rod DeVore and Matt Lim Anticipated Completion Date: September 30, 2025

The Board of County Commissioners, with the cooperation and participation of all elected officials, reviews, develops and implements policies and procedures to create a strong internal control environment. The Board of County Commissioners will work with all elected officials, the third-party administrator, and federal, state and local partners to develop policies, procedures, and internal controls designed to accurately track grants, including the application process, verification, oversight, and reporting of grant requirements. To assist in this process, the Board of County Commissioners engaged a third-party administrator to oversee the grant process, including application, eligibility, review, requirements, contracting, recipient tracking and oversight, and documentation and reporting. The Board of County Commissioners will work with the third-party administrator to ensure proper grant administration.

Corrective Action: 1. Develop a policy for subrecipient monitoring, and implement procedures to oversee the programmatic and financial activities of subrecipients and ensure compliance with regulations. 2. Develop a standardized checklist to guide the monitoring of subrecipients. 3. Provide training to relevant staff on the new procedures for subrecipient monitoring and the importance of compliance with federal regulations.

Identifying Number: 2024-002 Subrecipient Monitoring Controls Finding: Weaknesses were found in federal subrecipient controls and monitoring during 2024. Corrective Actions Taken or Planned: Name of Responsible Official: John Passauer, Vice President of Finance Anticipated Completion Date: December 31, 2025 Views of Responsible Officials and Planned Corrective Action: 1. Review and refine current grant policies to more clearly outline the roles and responsibilities with respect to subrecipient monitoring 2. Provide training on the new policy for all Country Directors, grant program managers and Finance Directors. 3. Monitor ongoing compliance with the new policy on a quarterly basis.

Finding Number: 2024-002 Recommendation: Inform subrecipients of the required federal award info outlined in § 200.332 Requirements for pass-through entities. Action Taken: 1. AANA has posted on its MAST website and application that: “The MAST program is funded by the United States Federal Government and is subject to all applicable federal statutes, regulations, and requirements. The receiving entity is not debarred, suspended, or otherwise excluded from using federal funds.” 2. AANA will include the following as a footnote on any MAST manuscripts and printed text: “Supported by a grant administered by The Arthroscopy Association of North America (AANA), with funding provided by the Military Advanced Surgical Treatment (MAST) Program.” 3. Request and/or ensure the following information through the contracting process with any MAST Subrecipient: a. Subrecipient's name (must match the name associated with its unique entity identifier) b. Subrecipient's unique entity identifier c. Subaward Period of Performance Start and End Date d. Subaward Budget Period Start and End Date e. Amount of Federal Funds Obligated in the subaward f. Total Amount of Federal Funds Obligated to the subrecipient by the pass-through entity, including the current financial obligation g. Total Amount of the Federal Award committed to the subrecipient by the pass-through entity h. Federal award project description, as required by the Federal Funding Accountability and Transparency Act (FFATA) i. Identification of whether the Federal award is for research and development j. Indirect cost rate for the Federal award (including if the de minimis rate is used in accordance with § 200.414) i. An approved indirect cost rate negotiated between the subrecipient and the Federal Government. If no approved rate exists, a pass-through entity must determine the appropriate rate in collaboration with the subrecipient. The indirect cost rate may be either: 1. An indirect cost rate negotiated between the pass-through entity and the subrecipient. These rates may be based on a prior negotiated rate between a different pass-through entity and the subrecipient, in which case the passthrough entity is not required to collect information justifying the rate but may elect to do so; or 2. The de minimis indirect cost rate. k. A requirement that the subrecipient permit the pass-through entity and auditors to access the subrecipient's records and financial statements for the pass-through entity to fulfill its monitoring requirements l. Verify that a subrecipient is audited as required Responsible Contact Person for Planned Corrective Action: Dennis Siena Anticipated Completion Date: September 30, 2025

The County’s Corrective Action Plan to address the condition is to put controls in place to ensure subaward agreements are current and include all required information, required information is provided to the subrecipient at the time of award issuance, subrecipients have a UEI, monitoring activities are conducted in accordance with the subaward agreement, and subrecipient risk assessment and audit verification is documented.In addition, finance personnel will be provided with the proper education and training to ensure proper monitoring procedures are being followed.The County is in the process of finalizing an updated subaward agreement that includes all required information. The subrecipient has obtained the proper UEI.The County Auditor, Michelle Samford, will be responsible for ensuring that the Corrective Action Plan is implemented. The anticipated completion date is December 31, 2025.

FINDING 2024-001 Finding Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Contact Person Responsible for Corrective Action: Debra Carnes Contact Phone Number and Email Address: 317.477.1105 Views of Responsible Officials: We concur with the audit finding and will enhance our internal controls and procedures for subrecipient monitoring. Specifically, we will: Corrective Action Plan for Finding 2024-001 l. Include the Assistance Listing Number (ALN) and Federal Award Identification Number (FAIN) in subaward agreements. 2. Verify that subrecipients have been audited as required. Implementation Timeline We will update our written internal controls by August 29, 2025, to reflect these enhancements. Current Status We have already verified that our subrecipient has been audited, and to the best of our knowledge, there are no findings related to ARPA funding. Sincerely, Debra A. Carnes Hancock Co. Auditor

Corrective Action Plan for Finding 2024-004 Contact person Responsible for Corrective Action: Karen Hennessy Contact Phone Number: 815 774-6359 Views of Responsible Official: We concur with the finding and offer the following context and corrective action plan: Condition: During our audit of the County’s administration of federal funds under the CSLFRF program, we noted that the County did not have a documented process in place to track and maintain copies of Single Audit reports for subrecipients to whom it awarded federal funds. Specifically, the County was unable to provide evidence that it had obtained and reviewed Single Audit reports for any of its subrecipients during the audit period. Description of Corrective Action Plan: The county will create a tracking document that provides the following: -All CSLFRF (ARPA) subrecipients -Amounts and types of all CSLFRF allocations to the subrecipient -The fiscal cycle of the subrecipient -The date the annual financial statement was received -The person receiving the file -The file name and location -An indication if the subrecipient meets the threshold to have a single audit (not based on the amount allocated by the county) -If a single audit is required a copy will be requested from the subrecipient or from the Federal Clearing House -The date the Single Audit report was received -The name of the person receiving the file -The file name and location -The name of the person completing the review of the Single Audit report to identify any findings related to CSLFRF -Notes regarding follow up due to findings related to CSLFRF Anticipated Completion Date: August 31, 2025

Corrective Action Plan for Finding 2024-003 Contact person Responsible for Corrective Action: Karen Hennessy Contact Phone Number: 815 774-6359 Views of Responsible Official: We concur with finding 2024-003 and offer the following context and corrective action plan: Condition: During our audit of the County’s administration of federal funds under the CSLFRF program, we noted the County failed to provide a subrecipient agreement to two subrecipient entities that would have included appropriate information related to federal award identification. Description of Corrective Action Plan: The County had all CSLFRF projects reviewed to confirm that the correct agreement type had been issued. The review found that 6 of the 56 projects had been issued a Beneficiary Agreement instead of a Subrecipient Agreement. Each of the 6 subrecipients has been contacted and provided with a Subrecipient Agreement. This corrects the finding. Completion Date: June 30, 2025

Corrective Action Plan for Finding 2024-004 Contact person Responsible for Corrective Action: Karen Hennessy Contact Phone Number: 815 774-6359 Views of Responsible Official: We concur with the finding and offer the following context and corrective action plan: Condition: During our audit of the County’s administration of federal funds under the CSLFRF program, we noted that the County did not have a documented process in place to track and maintain copies of Single Audit reports for subrecipients to whom it awarded federal funds. Specifically, the County was unable to provide evidence that it had obtained and reviewed Single Audit reports for any of its subrecipients during the audit period. Description of Corrective Action Plan: The county will create a tracking document that provides the following: -All CSLFRF (ARPA) subrecipients -Amounts and types of all CSLFRF allocations to the subrecipient -The fiscal cycle of the subrecipient -The date the annual financial statement was received -The person receiving the file -The file name and location -An indication if the subrecipient meets the threshold to have a single audit (not based on the amount allocated by the county) -If a single audit is required a copy will be requested from the subrecipient or from the Federal Clearing House -The date the Single Audit report was received -The name of the person receiving the file -The file name and location -The name of the person completing the review of the Single Audit report to identify any findings related to CSLFRF -Notes regarding follow up due to findings related to CSLFRF Anticipated Completion Date: August 31, 2025

Corrective Action Plan for Finding 2024-003 Contact person Responsible for Corrective Action: Karen Hennessy Contact Phone Number: 815 774-6359 Views of Responsible Official: We concur with finding 2024-003 and offer the following context and corrective action plan: Condition: During our audit of the County’s administration of federal funds under the CSLFRF program, we noted the County failed to provide a subrecipient agreement to two subrecipient entities that would have included appropriate information related to federal award identification. Description of Corrective Action Plan: The County had all CSLFRF projects reviewed to confirm that the correct agreement type had been issued. The review found that 6 of the 56 projects had been issued a Beneficiary Agreement instead of a Subrecipient Agreement. Each of the 6 subrecipients has been contacted and provided with a Subrecipient Agreement. This corrects the finding. Completion Date: June 30, 2025

The City of Athens has reviewed the findings of ODOD and has modified subrecipient monitoring procedures to detect these types of issues in the future.