Corrective Action Plans

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Panthera has now adopted the implementation of the Federal Assistance Listing Numbers on each agreement with subrecipients, and will ensure a formal approval is issued on all expenditure reports.

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

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

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

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

Finding 2022-001 ? Subrecipient Monitoring Cluster: Research and Development Agency: Department of Commerce and Department of Health and Human Services Award Names: Standards/Guidance for Rapid Qualification of Metal-Based Additive Manufacturing and Development and Testing a Field-based Hazard/Near-Miss Sharing System for Commercial Fishing Vessels Award Numbers: 70NANB21H038 and U01OH012288 Assistance Listing Title: Measurement and Engineering Research and Standards and Occupational Safety and Health Program Assistance Listing Number: 11.609 and 93.262 Award Year: FY 2022 To ensure American Bureau of Shipping (ABS) is in compliance with 2 CFR 200.332(d) and 2 CFR 200.332(f), ABS will obtain and review annual Uniform Guidance reports or annual audited financial statements (if the entity was not subject to a Uniform Guidance audit) of all subrecipients. ABS has revised its Contracted Research and Development Process Instruction for subrecipient monitoring. The process instruction is supplemented by a subrecipient monitoring form and check sheet. The annual subrecipient monitoring form and check sheet outline the necessary steps to document and interpret the review of Uniform Guidance reports or financial reports. The annual review will be completed within two months of the grant date anniversary. The contracts administrator and project manager will provide two-step verification by reviewing, dating, and signing both the subrecipient monitoring form and check sheet to document their understanding of the type of opinion(s) expressed, findings associated with their awards, document their review, and assess whether there is any change in the initial risk assessment and subsequent monitoring need of each subrecipient. The annual reviews commenced in July 2023.

DEPARTMENT OF ELEMENTARY AND SECONDARY EDUCATION 2022-004 Child and Adult Care Food Program ? Assistance Listing No. 10.558 Action taken in response to the finding: The Office for Food and Nutrition Programs (FNP) has moved from a paper based permanent agreement to a web form that exists on the DESE Security Portal. All existing and new Child Nutrition Sponsors will continue to sign off on the document via the web-based portal allowing for a more efficient collection and document retention process. The identified sponsors with missing permanent agreements for the time period selected now have signed permanent agreements via the web-based form. FNP will add the applicable FAIN numbers to the Financial Management portion of FNP?s public website. FNP will review and update these numbers annually as applicable. FNP, in conjunction with DESE?s Federal Accounting Unit, have embarked on a process to provide all Child Nutrition sponsors instructions and collect information related to UEIs. FNP will continue the process and outreach until all UEIs have been collected. Name of the contact person responsible for corrective action: Robert Leshin, Director of Nutrition, Jeffrey Benbenek, Director of Audit & Compliance Planned completion date for corrective action plan: July 1, 2023

Children First Fund: The Chicago Public Schools Foundation State Single Audit Corrective Action Plan For the Fiscal Year Ended 2022 AUDIT FINDINGS Finding Reference Number: 2022-001 Description of Finding: CFF did not communicate the required information to subrecipients noted in the criteria including the communication of what funding represented federal funding and was subject to the related grant requirements. Statement of Concurrence or Nonconcurrence: The organization agrees with the finding and will implement corrective action when applicable. Corrective Action: The Chicago Connected initiative was supported by various external partners, including government and philanthropic funders. As the fiscal sponsor, the Children First Fund executed service agreements with each participating community-based organization (CBO), that noted the amount they were awarded. As deliverables were met, CFF made payments based on when the funds came in since they were not designated to a particular CBO by funder. As a result, CFF did not notify CBOs which payments came from federal vs philanthropic funding. Understanding that this is required when it comes to distributing federal funds to subrecipients, CFF will ensure that it's internal controls are updated to include this moving forward. Name of Contact Person: Yemisi Odedina, Managing Director of Finance & Operations E: yodedina@childrenfirstfund.org P: (312) 883-4977 Projected Completion Date: By the end of the calendar year of 2023, the organization will ensure that it?s internal controls are updated to include the federal uniform guidance standards that applies to federal awards to ensure future awards are managed per those guidelines.

Significant deficiency in internal controls over compliance and instances of noncompliance related to subrecipient monitoring. Contact Person(s): Beth Mizushima, Chief Operating Officer, mizushimab@crhn.org; and Connie Sowa, Compliance, Governance and Contracts Officer, sowac@crhn.org. Explanation and specific reasons for disagreement with the audit finding or that corrective action is not required (if applicable): Not applicable. Corrective action planned: In FY23 we have established a Compliance, Governance and Contracts Officer staff position (1.0 FTE) that provides compliance support. We have also developed and implemented training around our Ethics and Compliance Manual, which includes 14 new policies and procedures related to ensuring subrecipient compliance standards are met for all grant awards. Since July 1, 2023, we have completed assessments for the risk of noncompliance with all partner agencies before executing contracts. In FY23 we have also amended contracts to be on a reimbursement for allowable expenditures structure rather than fixed amount. We believe that the former leadership team who established the fixed fee award may have misinterpreted the guidance around providing flexibility to reduce burden for financial assistance during COVID response. Furthermore, it is our belief that the former program officer and staff discussed the details of their work and contracts, but we cannot find documentation of receiving prior approval. To address this issue, we have amended contracts in FY23 to include specific contract wording requiring prior approval to implement a fixed fee contract. Additionally, we are in the process of implementing a contract and portal partners management platform. The new contract management system and the improvements in compliance process will ensure that we adhere to the provisions as outlined in 2 CFR200.332. Anticipated completed process September 30, 2023