Corrective Action Plans

Force Detroit will monitor compliance through: ● Vendors/grantees must submit regular financial and programmatic reports, including expenditures, progress toward goals, and any issues encountered. ● Reports will be reviewed for accuracy, completeness, and alignment with the approved budget and program plan. ● Site visits to verify program activities, financial management practices, and overall compliance. Findings will be documented, and any deficiencies will trigger the Corrective Action Plan. ● Review of financial and programmatic documentation ● Verification of debarment and good standing with regulatory bodies ○ Vendors/grantees must provide confirmation that they are not debarred, suspended, or otherwise restricted from receiving federal funds.

COVID-19 Coronavirus State and Local Fiscal Recovery Funds (SLFRF) – Assistance Listing No. 21.027 Recommendation: CLA recommends that the County review its procedures for communicating information to subrecipients and implement the procedures necessary to ensure information is included in the subrecipient award documents at time of funding and that appropriate monitoring is performed for each subrecipient. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: For future awards the County will include compliance requirements to subrecipients in the award documents. For previously issued awards, the County will use appropriate subrecipient monitoring procedures to ensure compliance with the grants awarded throughout the remainder of the contract periods. Name of the contact person responsible for corrective action: Craig McBrain, Deputy Director of Budget and Finance Planned completion date for corrective action plan: December 1, 2025

Management Response/Corrective Action Plan: During the audit period, the City monitored subrecipient performance through the review of required supporting documentation submitted with each individual fund requisition and draw request. This process provided assurance that costs charged to the program were eligible and supported. The City also self identified one instance within this process where a consortium member subrecipient did not complete a Single Audit as required. City staff consulted with HUD on this matter and were advised by HUD staff to continue processing payments while HUD worked directly with the subrecipient to bring them back into compliance.

Update Financial Policies and Procedures to reflect language surrounding areas of deficiency, specifically listed in 2 CFR 200.332(b). New subrecipients awards will include: subrecipient’s unique entity identifier, federal award identification number, federal award date, assistance listing title, assistance listing number, dollar amount available under each federal award and assistance listing number at the time of disbursement, and approved indirect cost rate. This was found during the 2023 single-audit, with the corrective action implemented for contracts starting after 7/14/25. Planned Implementation Date of Corrective Action: 7/14/25, will be included in Financial Policies revisions in December 2025. Person Responsible for Corrective Action: Director of Finance

● The Organization will develop a policy and procedures that require documentation of subrecipient monitoring for each subrecipient. ● The Organization will redesign the subrecipient contract template to include the federal award identification number and amount of federal funds awarded to each subrecipient. ● The Finance Director will distribute the policies and procedures along with the new contract template to all staff that manage grants. ● The Finance Director will train the staff on the new policies and procedures.

TCA acknowledges that during the fiscal year 2024, that the agency did not conduct onsite fiscal monitoring of the delegate agencies, due to several personnel and medical challenges and absences within the accounting and fiscal unit. In accordance with policy and procedures stated in the TCA Accounting and Financial Procedures, the TCA fiscal and programmatic team, under the joint supervision of the Chief Financial Officer and Compliance Officer, have updated the procedures and documents to support our full compliance for fiscal year 2025.

Isler recommended LCOG implement procedures to:  Formally document the determination of whether entities receiving federal funds are subrecipients or contractors prior to entering into agreements and preparing the SEFA, using the criteria in 2 CFR 200.331.  Develop and implement a risk-based monitoring plan for all identified subrecipients, ensuring that required monitoring activities (including review of reports and Single Audits, where applicable) are performed and documented throughout the period of performance.  Ensure the SEFA accurately reflects subrecipient relationships and amounts passed through.  This monitoring plan has already been implemented.

2024-004 - Subrecipient Monitoring Activities Auditor Description of Condition and Effect: During subrecipient monitoring testing, the ALN number and award number were not included in the four subrecipient agreements subjected to testing. Additionally, the Organization does not have a policies/procedure in place to evaluate and address subrecipient's fraud risk and risk of noncompliance. Auditor Recommendation: We recommend that the Organization adopt additional policies and procedures related to subrecipient monitoring to ensure compliance with Uniform Guidance. Corrective Action: The Organization will implement stronger control in place to ensure that subrecipient disclosure requirements are included in the subrecipient agreements. In addition, the Organization will put in place a formal policy to address subrecipient fraud risk and risk of noncompliance. Responsible Person: Dora Gonzales Anticipated Completion Date: December 2025

Finding 2024-005 – Subrecipient Monitoring ● Issue: Missing elements in agreements; incomplete audit follow-up; insufficient documentation. (Repeat finding from 2023). ● Corrective Actions: 1. Implement standardized subaward and contractor agreement template with all required elements (Assistance Listing number, R&D designation, closeout terms, indirect cost rate). 2. Update written monitoring procedures to include audit report review, recurring 3. Maintain monitoring files with risk assessments, audit follow-ups, and site visit notes. ● Responsible Party: Operations Manager, Executive Director ● Timeline: Template finalized November 2025; procedures updated and training held Dec 2025.

Finding 2024-003 – Lack of Determination Process for Subrecipients vs Contractors ● Issue: Lack of a formal process to distinguish contractors from subrecipients; risk of misclassification. ● Corrective Actions: 1. Adopt written procedures per 2 CFR §200.332 criteria. 2. Develop checklist for staff to use at award initiation. 3. Record contractors and subrecipients in separate GL accounts. ● Responsible Party: Outsourced Accounting Firm, Operations Manager, Executive Director ● Timeline:. Finalize procedure by September 2025; staff training by October 2026. Initiate determination review for transactions January 2025 - September 2025 and reclass accordingly.

Views of Responsible Officials and Planned Corrective Action Management agrees with the recommendation. Quivira Coalition will: Action Step Detail Date Responsible Party Update its subrecipient and contractor agreement templates to include information outlined in 2 CFR § 200.332, including more specific federal award identification. 10/31/25 Operations Director Add a clause to the subrecipient and contractor agreement templates to include a requirement to report any significant developments to Quivira Coalition. 10/31/25 Operations Director Build a procedure for evaluating a subrecipient’s fraud risk and risk of non-compliance with the federal awards (as outlined in 2 CFR § 200.332 (c)) during the grant application phase or before engaging in agreements & work with subrecipient. It will continue to follow-up annually with the recipients on fraud risk and risk of non-compliance until the end of the federal award period. 10/31/25 Operations Director; CRI Director & Grants Manager Monitor sub-recipients as required by 2 CFR 200.332(e) 1/31/2026 Operations Director If a subrecipient has significant development during the course of monitoring, institute a tailored monitoring plan as outlined in 2 CFR § 200.332 (e) & (f) and resolve any findings listed as its responsibility under 2 CFR § 200.332 (e). 10/31/25 Operations Director; CRI Director & Grants Manager

Ref. No. 2024-001: Missing Signatures Recommendation: The Company should consider reevaluating their established procedures and controls currently in place to ensure full compliance with regard to eligibility and proper maintenance of tenant information, including policies for handling missing files during management transitions to ensure compliance with HUD requirements. Action Taken: The Company will start randomly testing a small sample of tenant files, as part of our quarterly site inspection. Additionally, Kay-Kay Realty, a third-party vendor is already engaged to review tenant move-in and recertification files, but the prior resident manager was selecting the files to review. We will now ask Kay-Kay Realty to randomly select tenant files for their review process. Contact person: Patrick Delaney; (808) 523-5681, ext. 693 Anticipated Completion Date: October 1, 2025

Corrective Action: The risk assessment template and list of subaward terms to be downloaded. A new subaward agreement template to be developed which encompasses all aspects of 200.332(b). Contact Persons: Laurie Olson, Controller and Kevin Osborn, Interim Executive Director Implementation Timeline: The risk assessment template and subaward terms were downloaded and distributed to key stakeholders on Friday, September 19, 2025. A new subaward agreement template will be created in a multi-department collaboration and is due to be completed by December 31, 2025.

The Organization recognizes that subrecipient agreements must include all elements required by 2 CFR 200.332(b)(1). To address this, management will update the standard subrecipient agreement template to incorporate each required element and will adopt a checklist to be used during the agreement drafting and review process to ensure completeness. Staff responsible for preparing and executing subrecipient agreements will receive training on Uniform Guidance requirements. These steps will ensure that all subrecipient agreements fully comply with Federal regulations going forward.

Finding number 2024-005, material weakness in internal controls over compliance – subrecipient monitoring. Recommendation: We recommend that management implement procedures to ensure that all subrecipient agreements include the information required by 2 CFR 200.322. This should include a standardized checklist or template for subaward agreements and periodic reviews to verify compliance. We further recommend the entity implement and document procedures to (1) perform and retain evidence of subrecipient risk assessments, and (2) verify and document whether sub-recipients are subject to the Since Audit and, if so, obtain and review the audit reports for findings related to the federal program. Explanation of Disagreement with Audit Finding: There is no disagreement with the audit finding. Action planned in response to the finding: KRJC will develop a standardized checklist for all subaward agreements and will conduct semi-annual reviews to verify compliance with that checklist. As part of this updated review, KRJC will perform updated risk assessments with all sub-awardees and will retain evidence of those risk assessments in sub-awardee files. KRJC will also verify and document whether sub-recipients are subject to the single audit, and, if so, obtain and review the audit reports for findings related to the federal program. KRJC will ensure that any existing sub-awardees are reviewed for compliance no later than November 1, 2025. Planned completion date for corrective action plan: November 1, 2025.

Management agrees with the finding. The Organization hired a new Executive Director in the fall of 2024 and has discussed the matter with the Department of Agriculture and legal counsel to ensure compliance requirements are followed.

Finding 2024-001 Audit Finding: In accordance with 2 CFR § 200.332(a) of the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), pass-through entities are required to “clearly identify to the subrecipient” certain information and requirements at the time of subaward, including the Federal award identification, all compliance requirements, and any additional terms and conditions imposed by the pass-through entity. The Town did not execute a formal subrecipient agreement with Fishers Island Ferry District, to whom federal funds were passed through during the audit period. Specifically, no written agreement was in place outlining the subrecipient’s responsibilities, applicable compliance requirements, or the terms and conditions of the award. Recommendation: We recommend that the Town develop and implement procedures to ensure that formal written subrecipient agreements are executed prior to the disbursement of federal funds. These agreements should contain all elements required by 2 CFR § 200.332(a), including the identification of the federal award, applicable compliance requirements, and any additional terms and conditions. Corrective Action Plan: In coordination with the Supervisor’s office, Town Attorney’s office, and Comptroller’s office, formal subrecipient agreements will be prepared and executed, with adoption of Town Board resolutions, between the Town of Southold and pass-through entities concurrently as Federal grant contracts are awarded, as applicable. Responsible Individual: Albert J. Krupski Jr., Town Supervisor Paul DeChance, Town Attorney Michelle Nickonovitz, Town Comptroller Planned Date of Implementation: Corrective action plan procedures have already been communicated and implemented to ensure that formal written subrecipient agreements with pass-through entities are executed prior to the disbursement of federal funds.

Finding 2024-003 - Subrecipient Monitoring Contact Person Responsible for Corrective Action: Danny Yost Contact Phone Number: 812-285-6221 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The County will obtain all subrecipient audit reports and formally document their review of each subrecipient's audit report. Anticipated Completion Date: October 2025

Finding summary: an internal control deficiency affecting the accuracy of the Schedule of Expenditures of Federal Awards (SEFA) Responsible department: Finance and PPACG Contact person: Finance Corrective action plan: As of 2025 SEFA internally will be prepared by Grant coordinator and review by Finance. Envida will ensure that all appropriate ALNs and Federal identifications and amounts are included on the contracts. Envida will implement a process for all appropriate department directors, including CEO to sign off on each grant received. Timeline for completion: Dec 31 2025 Monitoring plan: Monthly Review with Grant coordinator Anticipated outcome: SEFA will reflect accurate federal expenditures.

FINDING 2024-002 Massachusetts Individual Responsible for Corrective Action Plan: Alliance Director Jenn Aldworth Corrective Action: The Organization is refining subaward agreements for future awards and will ensure federal provisions required to be communicated by the grant and also 2 CFR § 200.332 are incorporated consistently for all subrecipients. Anticipated Completion Date: December 31, 2025

State of Missouri Single Audit Corrective Action Plan Year Ended June 30, 2024 State Agency: State Emergency Management Agency Audit Finding Number: 2024-012 - SEMA Subrecipient Monitoring Name of the contact person responsible for corrective action: Nikol Enyart Anticipated completion date for corrective action: Implemented Corrective action planned is as follows: Since the discovery of the shortfall in the monitoring of subrecipients, SEMA has taken action to get the program back on track. SEMA has maintained forward momentum on completing the risk assessments during the time dictated by the policy. SEMA has also completed 46 out of 107 desk monitoring reports for the medium risk subrecipients, and SEMA has completed 17 out of 83 site visits for high risk subrecipients. SEMA has also cross trained multiple employees in the steps and processes to achieve high outputs for this process. SEMA has created a separate tracker to focus directly on the desk monitoring and site visits that have been completed or still need to be completed. This tracker is monitored by the Deputy Recovery Division Manager. SEMA also generates reports on the 15th and 30th of each month outlining any progress made during those two weeks, and those reports are submitted to the Recovery Division Manager. This report was first created and submitted on January 31, 2025. In relation to the A-133 audits, SEMA has implemented cross training for staff that will ensure should one employee leave, the task will continue without disruption. Two staff are now trained and will submit a report each quarter to the Deputy Fiscal Manager to ensure compliance with the A-133 requirements.

State of Missouri Single Audit Corrective Action Plan Year Ended June 30, 2024 State Agency: Office of Administration Audit Finding Number: 2024-007, SLFRF Program Subrecipient Monitoring Name of the contact person responsible for corrective action: Stacy Neal Anticipated completion date for corrective action: November 1, 2025 Recommendation A.: Develop policies and procedures to determine whether recipients of SLFRF program funds are subrecipients or contractors. Continue to work with the state agencies to ensure accurate and documented determinations are prepared for all recipients and modify subrecipient records as needed. OA partially agrees with the auditor’s finding. Corrective action planned is as follows: OA did complete a training for all agencies regarding subrecipient monitoring and the agencies responsibilities. OA also distributed a memo instructing agencies where to find information regarding subrecipient monitoring and instructing agencies to develop policies and procedures for their agency. To avoid confusion, OA will pursue Memorandums of Understandings (MOU) with agencies to ensure agencies understand their responsibilities for sub-recipient monitoring including sub-recipient specific risk assessments and monitoring. Finally, OA will implement random reviews of the sub-recipient monitoring compliance. Recommendation B.: The OA did not implement an effective subrecipient monitoring program to monitor the SLFRF subrecipients. As a result, some subrecipient monitoring procedures were not performed as required by the UG. OA agrees with the auditor’s finding. Corrective action planned is as follows: OA will pursue Memorandums of Understandings (MOU) with agencies to ensure agencies understand their responsibilities for sub-recipient monitoring including sub-recipient specific risk assessments and monitoring. Finally, OA will implement random reviews of the sub-recipient monitoring compliance.

State of Missouri Single Audit Corrective Action Plan Year Ended June 30, 2024 State Agency: Department of Health and Senior Services (DHSS) Audit Finding Number: 2024-009 - CACFP Subrecipient Monitoring Name of the contact person responsible for corrective action: Sarah Walker, Bureau Chief Anticipated completion date for corrective action: Corrective action planned is as follows: The agency does not agree with the audit findings and therefore no corrective action is required. Explanation and specific reasons are as follows: DHSS disagrees with this finding. While the USDA partially sustained the previous finding in the FY2023 SWSA, the corrective action plan and supporting documentation submitted by DHSS was accepted by USDA and deemed adequate. On April 17, 2025, the USDA recommended final action to close the FY2023 audit finding.

WFA Management’s Corrective Action Plan for Year Ended 12/31/2024 Finding number: 2024-002 Finding relates to subrecipient monitoring and management under 2 CFR Part 200. Corrective Action Plan The Women’s Foundation of Alabama is committed to ensuring clarity, accountability, and compliance in our grants management. To address the findings, we will: 􀁸 Implement the Subrecipient vs. Contractor Determination Form as a standard requirement for all agreements. For all agreements determined to be with subrecipients, a standardized agreement process to ensure that all required information is communicated and documented upfront. This includes clearly stating: o The federal award name and Assistance Listing Number (ALN). o A list of all applicable federal regulations. o Financial and performance reporting requirements and deadlines. Responsible Parties 􀁸 Chief Operating Officer – overall accountability for corrective action 􀁸 Director of Strategic Operations – coordination of implementation and recordkeeping 􀁸 Accounting Team (Mauldin & Jenkins): Technical assistance on compliance and reconciliation Anticipated Timeline 􀁸 Form and process adopted by [October 2025]

Action taken in response to finding: The County will review the subrecipient monitoring requirements and work with the County Auditor to develop a formal policy that includes internal controls, monitoring procedures, and documentation requirements.