Corrective Action Plans

Finding 2022-005 Contact Person Responsible for Corrective Action: Debbie Morton-Crum, County Auditor Contact Phone Number: 765-482-2940 View of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The County Commissioners are responsible for the American Rescue Plan project list along with that responsibility is to have a sub-recipient agreement in place with those outside entities that received American Rescue Plan grant monies from the County. An Internal Control is now in place that requires a sub-recipient agreement in place before a warrant can be paid to those outside entities. We will put procedures in place to ensure that money disbursed to sub-recipient is monitored. Anticipated Completion Date: October 1, 2023

June 14, 2023 Roslund, Prestage & Company, P.C. 525 West Warwick Drive Suite Alma, MI 48801 Finding: 2022-001 Federal Program: ALN 93.959 Block Grants for Prevention and Treatment of Substance Abuse (Prevention, COVID-19 Prevention II, and COVID-19 ARPA Prevention) Condition: During testing of contracts with subrecipients it was noted that these contracts did not include portions of required disclosures. Corrective Action Plan: The NMRE will include the information in contracts with subrecipients that are required in 2 CFR 200.332. Responsible Party: Chris VanWagoner, Provider Network Manager Date of anticipated implementation: FY23 going forward Thank you Regards, Deanna Yockey, CFO Northern Michigan Regional Entity 1999 Walden Drive Gaylord, MI 49770 231-383-6438

Assistance Listings number: 17.258 WIOA Adult Program; Assistance Listings number: 17.259 WIOA Youth Activities; and Assistance Listings number: 17.258 WIOA Dislocated Worker Formula Grants Contact Person(s): Jeremy Flowers, WIOA Executive Director and Lisa Grannis, WIOA Board Clerk and Compliance Specialist Anticipated completion date: June 30, 2023 Concur. The nonprofit organization was created in part to serve as the administrative arm of the Local Board and to provide a location for a resource center where WIOA services would be provided. The County did not distinguish fiscal responsibilities between parties and therefore assumed that certain expenditures of the Local Board and nonprofit would be allowable and could be paid directly by the County. The County considered the expenditures of the nonprofit to be program related, even though they were not directly incurred by the County. The County will improve its accounts payable policies and procedures for processing invoices using established process within the Finance Department, including ensuring all invoices are addressed to the County prior to payment. In addition, the County will establish clear contractual agreements that establish fiscal responsibilities that follow the program?s requirements. Finally, the County will coordinate with the pass-through grantor for the repayment of the unallowable costs identified in the finding.

Finding 2022-001 Condition Out of the three executed subrecipient agreements selected for testing, none of them included the subaward information required by the Uniform Guidance. Corrective Action Plan Corrective Action Planned: Lake County acknowledges that subaward information required by the Uniform Guidance was not provided to subrecipients in a separate notice. The County had previously incorporated the information in various clauses of the contracts/agreements with each subrecipient. The County has since developed a single notification form with the required subaward information which it includes with the initial contract and upon any modifications or change orders. Name(s) of Contact Person(s) Responsible for Corrective Action: Melissa Gallagher, Deputy Finance Director Anticipated Completion Date: August 31, 2023

Finding Number: 2022-001 Condition: It was noted through testing that there were multiple agencies where a monitoring visit had not taken place within the last two years per the Food Bank's subrecipient monitoring policy. Planned Corrective Action: The Director, Compliance Manager, and three (3) Area Leaders of the Agency Team maintain a schedule of due site monitors. During COVID there were extensive site closings and reduced hours thus impeding the ability to maintain the schedule. In order to maintain a safe work environment, it was necessary to reduce visits during peak periods of the pandemic. This was a unique and short-term issue. Each team member has a goal of conducting weekly monitors in order to complete the overdue monitor site visits by June 30, 2023. Monitors will be prioritized of oldest to newest until caught up with the schedule. Area Leaders will continue conducting site monitors with agencies prior to their upcoming due dates. Contact person responsible for corrective action: Persons responsible for enacting this corrective action plan include Director of Agency Relations Jacqui Hebein, contact jhebein@northernilfoodbank.org, or Compliance and Member Insights Manager Mackenzie Peshek, contact mpeshek@northernilfoodbank.org, (630) 443-6910 ext. 278. Anticipated Completion Date: 06/30/2023

City of Warren, Michigan June 30, 2022 Corrective Action Plan Finding Number: 2022-001 Condition: The City did not perform a risk assessment of the subrecipient during the year, and did not maintain documentation of subrecipient monitoring, as evidence to support subrecipient monitoring performed. Planned Corrective Action: The City agrees with the finding and will put procedures in place to ensure appropriate documentation is retained related to subrecipient monitoring and comply with the relevant internal policies. Contact person responsible for corrective action: Controller Anticipated Completion Date: 06/30/2023

Department: Health and Human Services Title: Internal control over TANF subrecipient audit procedures needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The Department will revise the standard operating procedures to include a search for out of state subrecipients. Completion Date: April 30, 2023 Agency Contact: Herb Downs, Director, Division of Audit, DHHS, 207-287-2778

Department: Health and Human Services Title: Internal control over TANF subrecipient risk evaluation procedures needs improvement Questioned Costs: None Status: Management?s opinion is that corrective action is not required Corrective Action: The Department disagrees with the finding. The Department has subrecipient monitoring procedures for all of its subrecipients whether they were competitively bid or not. The first assessment of risk, as noted in the finding, is when a subaward is competitively bid. Secondly, another risk assessment built into the Maine Uniform Accounting and Auditing Practices for Community Agencies (MAAP) in which requires higher risk subrecipients to undergo a higher level of testing. Additionally, there are audit and review requirements at a much lower threshold than that of the Uniform Guidance (UG). Finally, the Social Service Unit of the Division of Audit performs a risk assessment and tests transactions for those subrecipients that have been determined to be higher risk. The Department's subrecipient monitoring procedures ensures that we comply with the UG 200.332(d) Pass-through entity (PTE) monitoring of the subrecipient must include: 1) Review of financial and performance reports. 2) Following-up and ensuring that subrecipients take timely and appropriate action on all deficiencies. 3) Issues management decisions. 4) PTE is responsible for resolving audit findings specifically related to the subaward. Based on the Department's MAAP rules we ensure we comply with UG 200.332(e) Depending on the PTE's assessment of risk, the following tools may be useful: 1) Training and technical assistance. 2) On-site reviews. 3) Arranging for agreed upon procedures. The Department covers #3 by ensuring that all of our subrecipients have a requirement to submit to the Department a/an Audit, Review or Schedule of Expenditures of Department Awards (SEDA). Completion Date: N/A Agency Contact: Jim Lopatosky, Director, Division of Contract Management, DHHS, 207-287-5075

Department: Health and Human Services Title: Internal control over ICA program subrecipient monitoring procedures needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The Department will update subrecipient monitoring policies and procedures for all OPHE subawards based on this finding and recommendations. The Department will develop a subaward tracking tool for each agreement. The Department will transfer all subaward monitoring records to a centralized location within OPHE that can be accessed by the entire team, including approval records and copies of reports submitted by each subaward recipient. The Department will conduct subaward risk assessments for SFY23 contracts. The Department will complete subaward monitoring processes for SFY23 contracts following the updated monitoring policies and procedures and ensure all documentation (including approvals) is saved in the centralized location. Completion Date: March 30, 2023, April 15, 2023, April 30, 2023 and June 30, 2023 respectively Agency Contact: Ian Yaffe, Director, Office of Population Health Equity, DHHS, 207- 592-1481

Department: Education Title: Internal control over ESF subrecipient monitoring procedures needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: During the review of ESF applications, the Office of Federal Emergency Relief Programs (OFERP) team will confirm that equipment purchases are denoted in the equipment budget category of the application. Equipment inventories and real property lists will be collected during the subrecipient monitoring process from school administrative units (SAUs) and reviewed for compliance by the OFERP team. Completion Date: December 31, 2023 Agency Contact: Shelly Chasse-Johndro, Director of OFERP, DOE, 207-458-3180

Department: Economic and Community Development Title: Internal control over ERA Program subrecipient monitoring needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The Department will contract with a consultant to conduct close out procedures that will ensure these subrecipient funds were used for authorized purposes and in compliance with Federal regulations. The Department will ensure that the review of subrecipient audit reports are sufficiently documented. Completion Date: June 30, 2023 Agency Contact: Deborah Johnson, Director, Office of Community Development, DECD, 207-624-9817

Department: Education Title: Internal control over CACFP subrecipient risk evaluation procedures needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The CACFP team will create a risk assessment tool to use in scheduling subrecipient reviews. Completion Date: June 30, 2023 Agency Contact: Jane McLucas, Director of Child Nutrition, DOE, 207-624-6880

Department: Education Title: Internal control over CACFP subrecipient audit procedures needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The Department will implement policies and procedures for the tracking, receipt, and review of audits for subrecipients that expend over $750,000, in accordance with Federal regulations. Completion Date: June 30, 2023 Agency Contact: Jane McLucas, Director of Child Nutrition, DOE, 207-624-6880

Department: Education Title: Internal control over CNC subrecipient audit procedures needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The Department will create policies and procedures to collect, track, and review single audits for private schools receiving over $750,000 in Federal awards. Completion Date: September 1, 2023 Agency Contact: Jane McLucas, Director of Child Nutrition, DOE, 207-624-6880

Action Plan: We will work with our departments to ensure that controls for grants are documented with written procedures. These procedures will include the title of the positions responsible for each control (preparation, review, reconciliation, etc.) and will require that the performance of the controls be documented in a clear, re-performable manner with the name of the responsible individuals, the specific control(s) they performed over compliance for the grant, and the date(s) the controls were performed. Contact Names Responsible for the plan - Marcia Saulo Anticipated completion date of the plan - September 20, 2024

Action Plan: We will work with our departments to ensure that controls for grants are documented with written procedures. These procedures will include the title of the positions responsible for each control (preparation, review, reconciliation, etc.) and will require that the performance of the controls be documented in a clear, re-performable manner with the name of the responsible individuals, the specific control(s) they performed over compliance for the grant, and the date(s) the controls were performed. Contact Names Responsible for the plan - Marcia Saulo Anticipated completion date of the plan - September 20, 2024

FINDING 2022-004 The 2022 97.024 Emergency Food and Shelter National Board Program grant funding was received during a crisis resulting in a unique situation for the City of Chicago. The funding was provided before the federal government set up an award identifier (i.e., ALN/CFDA, CSFA), resulting in the Delegate Agency contract with the Department of Family Support Services (DFSS) containing only the name of the Grant. To address and prevent such issues in the future, the City's Office of Budget and Management (OBM) will run a Comprehensive Report quarterly to identify any placeholder award identifiers during funding setup. The Grants Management Unit within OBM will collaborate closely with the Department of Finance (DOF) to ensure the federal award identifiers are promptly updated in the financial system. Moreover, to ensure accuracy and compliance, the Grants Management Unit will work with the relevant contracting Department to update contracts with Delegate Agencies. This measure will guarantee that all necessary award identifiers are included, streamlining the funding process and ensuring proper tracking and reporting of federal grants. Assistant Budget Director Belczak at the Office of Budget and Management will be responsible for ensuring that this corrective action plan is implemented by the beginning of the fourth quarter in October 2023.

Finding 2022-061 Disaster Grants - Public Assistance (Presidentially Declared Disasters), ALN 97.036 - Subrecipient Audits Management Views MSP agrees with the finding. Planned Corrective Action MSP will improve monitoring by reconciling expenditures by program to ensure that all subrecipients are included on the single audit tracking sheet for review. In addition, MSP will transition to each division having the responsibility for the completion of their own single audit reviews beginning October 1, 2023. Anticipated Completion Date MSP will reconcile expenditures by program by October 1, 2023, and each division will have their single audit reviews completed by September 30, 2024. Responsible Individual(s) Matt Opsommer, MSP

Finding No. 2022-005 Department(s) New York City Department of Health and Mental Hygiene Program(s) Assistance Listing Numbers 93.940, HIV Prevention Activities ? Health Department Based Corrective Action(s) We agree with the recommendation provided above and have been working on an internal control structure to address the compliance requirements. Subsequently, we have created a site visit schedule with PHS this fiscal year and revised the site visit tool. The current site visit for this portfolio is scheduled for 4/1/23. Moving forward, we will continue work on a yearly site visit schedule with PHS in a timely manner. Anticipated Completion Date April 2023 Person(s) Responsible for Implementation Jenny Fernandez Director of Administration, BHHS (347) 396-4258 Jennifer Sorel Deputy Director of Business Systems, BHHS (347) 396-7407

Finding No. 2022-016 Department(s) New York City Department for the Aging Program(s) Assistance Listing Numbers 93.044, 93.045, & 93.053, Aging Cluster Corrective Action(s) NYC Aging agrees with the recommendation and will be amending all appropriate contracts to provide subrecipient award notices with the information required by the Uniform Guidance. The award notice will also reference the audit instructions, which will further provide subrecipients with guidelines on how to report their federal expenditures and comply with their Single Audit requirements. Anticipated Completion Date September 2023 Person(s) Responsible for Implementation Jose Mercado Chief Financial Officer (212) 602-4471

Finding 2022-042 Education Stabilization Fund, ALN 84.425 - During-the-Award Monitoring Procedures Management Views For part a., MDE partially agrees with the finding. MDE acknowledges that it did not complete any reviews of the FERs submitted during fiscal year 2022. However, the Uniform Guidance does not specify a timeframe for the review of FERs for the Education Stabilization Funds (ESF) and the ESF program is inherently more flexible than other federal programs in this regard. Although GANs originally required ESF subrecipients to submit a FER by August 29, 2022, MDE communicated to ESF subrecipients after the initial GANs that the August 29, 2022 due date was subject to change due to the continuously changing rules and requirements around this funding, including extension possibilities such as late liquidation. ESF FERs were due either within 60 days of full draw of the funds or within 60 days of the end of the award period, which could have been during the State?s fiscal year 2022 or well after September 30, 2022. For this reason, under Uniform Guidance, MDE had the authority to delay the review of FERs until closer to the end date of the award. In the case of late liquidation, the U.S. Department of Education provided notification that extended the award period as far as 14 months beyond the original end date of the award. For part b., MDE partially agrees with the finding. MDE acknowledges that subrecipient desk reviews were not finalized; however, the majority of the subrecipient monitoring was complete. The Uniform Guidance does not specify a timeframe for ESF subrecipient monitoring to occur and no requirement or expectation was made that monitoring would be finalized by MDE management by September 30, 2022. While the MDE contractor was not tracking completion against the date of September 30, 2022, documentation was and is still available, upon request from the OAG, to demonstrate the substantial ongoing monitoring activities, such as desk reviews and review of amendments, as of the end of the State?s fiscal year 2022. The Compliance Team was in regular contact with MDE throughout the monitoring process. The Compliance Team provided regular updates leading up to September 30, 2022 and shared comprehensive preliminary results with the department soon after September 30, 2022. Planned Corrective Action For part a., MDE will evaluate the process for reviewing FERs to determine the appropriate timeframe for FER review of these ESF funds in light of federal liquidation extensions. MDE and subrecipients were notified of a one-time, Coronavirus Aid, Relief, and Economic Security Act reopening drawdown opportunity during the spring of 2023, which again reopened the possibility for subrecipients to submit FERs. MDE will begin interim reviews of a sample of submitted FERs by September 30, 2023. For part b., MDE?s contractor provided MDE with the final results of its school year 2021 monitoring that was finalized during the summer of 2022 on January 5, 2023. MDE and its contractor have since followed up with subrecipients to recommend necessary or reasonable corrective action in March 2023. School year 2022 monitoring is ongoing and anticipated to be completed by September 30, 2023. Anticipated Completion Date September 30, 2023 Responsible Individual(s) Spencer Simmons, MDE

Finding 2022-018 MDE - Subaward Information Management Views MDE agrees with the finding. For part a., MEGS+ automatically generates Grant Award Notifications (GAN) upon approval of the application. At the time the applications were originally approved, a complete GAN would have been available for the subrecipient that included all subaward information as required by the Uniform Guidance. However, an error occurred when MDE updated the letterhead template in the MEGS+ system, disrupting the appropriate generation of the GANs for those applications that included multiple funding sources. For part b., prior to fiscal year 2022, the Great Start Readiness Program (GSRP) appropriation was composed of State funding only. Program office oversight of the GSRP grant includes a complex grant application reliant on multiple data points connected to budget submissions. As such, the grant management system could not be restructured to accommodate federal funding for GSRP including systematic issuance of GANs within a reasonable timeframe for fiscal year 2022. This necessitated GANs be created and issued via a manual process. The MDE program office was unable to determine the federal award identification number (FAIN) or closeout terms and conditions prior to issuance. Planned Corrective Action For part a., MDE corrected the error that caused GANs to generate without all required subaward information in MEGS+ on April 28, 2023. All GANs are available in MEGS+ and can be generated when requested in the system. For part b., MDE fully corrected this issue for fiscal year 2023. MDE now has the appropriate details and beginning in fiscal year 2023, GANs are issued systemically with all required FAIN or closeout terms and conditions via the new grant management system. All federal funding GANs for fiscal year 2023 were issued upon approval of grantee budgets beginning January 30, 2023, with the final approval and GAN issued May 18, 2023. Anticipated Completion Date Completed Responsible Individual(s) Spencer Simmons, MDE Richard Lower, MDE

Finding 2022-040 Formula Grants for Rural Areas and Tribal Transit Program, ALN 20.509 - Subrecipient Audits Management Views MDOT agrees with the finding. Planned Corrective Action MDOT will update and implement its procedures to include management decision letter timelines that are consistent with the Uniform Guidance related to subrecipient report review. Anticipated Completion Date September 30, 2023 Responsible Individual(s) Adam Feldpausch, MDOT Dave Wearsch, MDOT

Finding 2022-037 Crime Victim Assistance, ALN 16.575 - Risk Assessment and During-the-Award Monitoring Management Views MDHHS agrees with the finding. Planned Corrective Action For part a., MDHHS included the grant agreement identified in the fiscal year 2023 monitoring plan. MDHHS will evaluate current monitoring procedures and make updates, if necessary, to improve documentation of monitoring activity. For the grantees identified that only receive an administrative portion of VOCA funds, MDHHS has initiated the process to provide the grantees with access to the U.S. Department of Justice (DOJ) Office for Victims of Crime (OVC) reporting website. MDHHS is working with DOJ OVC to determine reporting elements for the administrative awards and will work with grantees to implement the required reporting elements. For part b., MDHHS will revise risk assessment and monitoring plan procedures to include all awards issued during the fiscal year. Anticipated Completion Date a. December 30, 2023 b. October 1, 2023 Responsible Individual(s) a. Twanisha Glass and Patsy Baker, MDHHS b. Tonya Avery, MDHHS

The Department finance office will work with the charter office to update its policies, procedures, and internal controls for review of charter schools with charter management organizations (CMO) to ensure proper risk assessment for conflicts of interest, related party transactions, and segregation of duties between the CMO and the charter school. Anticipated Completion Date: December 31, 2023 Contact Person: Mark Dunham, Director, Finance Office Department of Elementary and Secondary Education mark.dunham@ride.ri.gov