Corrective Action Plans

The Department will continue to monitor Title I supplement/supplant methodologies for subrecipients through its subrecipient monitoring/risk assessment survey. The Department will require Title I subrecipients to submit supplement/supplant policies, procedures, and methodologies as a requirement to complete the survey. Anticipated Completion Date: December 31, 2023 Contact Person: Mark Dunham, Director, Finance Office Department of Elementary and Secondary Education mark.dunham@ride.ri.gov

The implementation of the Grants Management System has increased controls, standardized business practices, and implemented policy and regulation subrecipients addressing this finding in full. Anticipated Completion Date: System completed December 2022; Regulation completed April 2023 Contact Person: Steve Thompson, Chief of Strategic Planning, Monitoring and Evaluation Department of Administration, Office of Management & Budget, Grants Management Office steve.thompson@omb.ri.gov

Finance and the Office of Highway Safety will work together to create policies and procedures to ensure compliance with subrecipient monitoring. Anticipated Completion Date: September 30, 2023 Contact Person: Loren Doyle, Acting Chief Operating Officer / Chief Financial Officer Department of Transportation loren.doyle@dot.ri.gov

Finding Reference Number: 2022-002 Federal Agency: U.S. Department of Health and Senior Services Program Name: Temporary Assistance for Needy Families Assistance Listing Number: 93.558 Responsible Official: Megan Bania, Executive Director Views of Responsible Individuals: The loss of the executive director in January 2022 and the poor handoff to the interim executive director Brian Valentine, and his resignation in March 2023, left SkillUp program manager with insufficient oversight and management support. The failure of the Director of Finance to assist with creating updated financial monitoring protocols and lingering concerns about traveling during COVID resulted in the failure to perform financial monitoring. The former program manager did follow spending and provided programmatic monitoring and support to subrecipients. She resigned from MCAN in July 2022. Megan Bania is the new executive director and has worked with the new program manager and the accounting team to create in person/onsite financial monitoring protocols and will ensure that financial monitoring is conducted in FY 2023.

84.027 Special Education - Grants to States (IDEA, Part B) 84.173 Special Education - Preschool Grants (IDEA, Preschool) Subrecipient Monitoring 2022-029 Strengthen Controls to Ensure Compliance with On-Site Subrecipient Monitoring Requirements for Special Education Cluster Programs. Response The MDE Office of Special Education (OSE) acknowledges the findings identified by the Office of the State Auditor's as described above. MDE OSE has maintained the review of the Single Audits and provided follow-up on corrections needed by LEAs with funding under IDEA programs. In addition, MDE OSE provides technical assistance to LEAs regarding such. Further, MDE OSE utilizes the District Determinations (SPP/APR) data to provide proactive technical assistance to LEAs. During the 2020-2021 school year, MDE OSE conducted cyclical monitoring to the best of its ability given school closures related to the COVID-19 pandemic. During SY 20-21, the existing procedure required onsite visits for every monitoring activity. However, during that time, and under the guidance of the National Center for Systemic Improvement (NCSI) , MDE OSE monitored LEAs via Special Education Determination Reports, Mississippi Comprehensive Automated Performance-based System (MCAPS) funding application review, and Formal State Complaints using previous procedures while MDE OSE developed new procedures and risk assessments. Additionally, with the onset of COVID-19, the districts and state agencies faced challenges in meeting monitoring requirements and timelines during the first six months of the 2020-2021 school year due to health and safety restrictions. In its implementation of new procedures and risk assessments, MDE OSE has incorporated broad revisions to the agency's subrecipient monitoring procedures and made a significant investment in building the capacity of new OSE management team members to monitor subrecipient compliance and ensure that subawards are used for authorized purposes. Those newly developed procedures were piloted during the 2021-2022 school year, finalized in May 2022, and fully implemented for school year 2022-2023. It should be noted that in June 2023, the MDE OSE received a program determination letter (PDL) from the U.S. Department of Education (US DOE), Office of Special Education and Rehabilitative Services (OSERS) that resolved a similar finding 2021-037 from Audit 04-21-39984 conducted by the State of Mississippi, Office of the State Auditor. The corrective actions included in finding 2021-037 are the same as those seen below. The PDL indicated that the MDE OSE produced evidence of revised systems to ensure compliance with the agency?s requirements for subrecipient monitoring. Corrective Action Plan: A. The MDE OSE will continue the programmatic and cyclical monitoring of LEAs that began as a pilot in the spring of 2020. The newly implemented procedures will be utilized fully in the 2022-2023 school year. B. The MDE OSE will continue to complete the risk-based assessment, that includes the SPP/APR data, each year as universal monitoring of all LEAs to identify those in need of intensive intervention and support. C. The MDE OSE will continue to review, approve and monitor budgets and expenditures through the Mississippi Comprehensive Automated Performance-based System (MCAPS) to oversee the use of IDEA grant funds to subrecipients. D. The MDE OSE has established a procedure of virtual self-assessment via desk audits if the process is once again interrupted due to health and safety concerns.

ALN Number 17.258, 17.259, 17.278 ? Workforce Innovation and Opportunity Act 2022-023 ? Strengthen Controls to Ensure Compliance with Subrecipient Monitoring Requirements. Cat ? M, Finding Type, A, C1 (MW, MNC) MDES Response: The Mississippi Department of Employment Security concurs in principle with the three conditions noted in the finding. During and prior to this audit, MDES enacted new procedures to address the concerns noted in this finding. MDES renewed its commitment to ensuring that subrecipients are qualified to receive funds. MDES contracted with Booth Management Consultants and more recently Trace Advisory Group to ensure compliance with all DOL monitoring requirements, including on-site monitoring and through other modes. Also, we started implementing a risk-based assessment tool to ensure the performance of a thorough qualification assessment on all grantees. Corrective Action Plan: A. The Offices of Grant Management and Business Management will develop a plan to document our assessment of the subrecipients? awareness of audit requirements at 2 CFR 200.332(f). MDES will start implementing the plan detailed below on or before October 31, 2023. This plan involves the following: 1) Perform a pre-award risk assessment to determine risk for awarding grant and the level of monitoring required during program; 2) Issue a standardized audit requirement letter or agreed upon procedures to all subgrantees to remind them of grant requirements; 3) Receipt of required federal single audit from subgrantees expending more than $750,000 in federal funds from all sources OR receipt of a statement that the entity did not meet this threshold; 4) Document the review and assessment of the audits received for findings or questioned costs using tools, such as the templates found in the DOL Core Monitoring Guide; and 5) Document all required agency action necessary to mitigate the risks identified in the audits. B. COVID-19 caused extensive travel and in-person meeting restrictions nationwide. MDES did not restrict travel or virtual meetings. As contact guidelines fluctuated, the on-site monitoring team had discretion regarding the method to conduct this process. Also during this time, DOL staff observed similar contact restrictions, which limited federal monitoring of MDES. Such challenges and restrictions no longer exist. MDES will perform on-site and remote monitoring, as required. Where possible, MDES intends to conduct future monitoring on-site. MDES management will also hold regular meetings with the subrecipients to monitor progress and to ensure questions related to grant expenditures receive timely responses. C. Although the agency did not perform a risk-based assessment in the year reviewed by the auditors (PY21), MDES did incorporate the Risk Assessment Tool, Tool S from the U. S. Department of Labor?s Core Monitoring Guide, into its review of subgrantees for PY 2022. MDES will continue to ensure the performance of a thorough risk-based assessment on all grantees.

Finding 2022-001 Federal Agency: Various Program Name: Research and Development Cluster Assistance Listing Number: Various Federal Award Year: Programs active between July 1, 2021 ? June 30, 2022 Compliance requirement: Subrecipient Monitoring Finding Type: Significant Deficiency The Office of Research and Sponsored Programs lost both its primary and secondary resources responsible for subrecipient monitoring in July 2020 and June 2021. The University could not replace them immediately due to a hiring freeze during the Covid pandemic. A full time Subaward Coordinator was hired in December 2021. The Subaward Coordinator has operationalized all tasks associated with Subrecipient Monitoring as identified in the Uniform Guidance as well as in accordance with Lehigh policies, procedures and internal controls. The review of current active subawards has been completed, including all single audits for fiscal year 2022, with no findings for any of Lehigh?s subawards. The Subaward Coordinator continues to monitor for the posting of these remaining reports on a weekly basis in order to complete the review of subrecipient single audit reports on a timely basis. We are confident with the full-time focus of the Subaward Coordinator and the enhancements to our subrecipient monitoring processes and controls that this finding is fully remediated. Name of contact person: Cynthia Kane, Assistant Vice Provost, Office of Research and Sponsored Programs. Completion date: May 31, 2022

FINDING 2022-004 Contact Person Responsible for Corrective Action: Chad Shireman Contact Phone Number: 812-738-8241 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The county will be retaining and periodically reviewing the grant application and award to stay current on applicable requirements of the subrecipient in order to ensure compliance. Lines of communication with the subrecipient will be established and maintained to better monitor activities, ensuring that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward and achieves performance goals. Policies and procedures will be adopted and implemented to allow the county to evaluate the subrecipient?s risk of noncompliance. The county will request supporting documentation from the subrecipient when reimbursement requests are made, and this process will be documented in order to provide evidence that it is taking place. Anticipated Completion Date: The anticipated completion date will be December 31, 2023. This will allow the county and the subrecipient to work together to create the necessary policies and procedures. Once created, the remainder of the year will be used to implement them, allowing the county to evaluate all activities for the entire 2023 audit period that will be under review by SBOA in 2024.

The City has established an Audit Review Certification form that will be completed by employees to formally document the review of subrecipient agencies? audit reports.

The City has established an Audit Review Certification form that will be completed by employees to formally document review of subrecipient agencies? audit reports.

Corrective Action Plan: Carle to proceed with publishing and implementing its Sub-Recipient Monitoring Policy. The Grants Administration Office has already created Sub-Recipient Orientation training session for Carle departments and prospective subrecipients and will work with Compliance to actively train stakeholders. Contact Person(s): Kathy Dams, Director, Grants Administration and Research Operations Anticipated Completion: 12/31/2023

Finding: The Washington State Department of Transportation did not have adequate controls over and did not comply with requirements to perform risk assessments for subrecipients of the Formula Grants for Rural Areas program. Questioned Costs: Assistance Listing # 20.509 20.509 COVID-19 Amount $0 Status: Corrective action in progress Corrective Action: The Washington State Department of Transportation (WSDOT) concurs with the finding and is in the process of implementing the audit recommendations. Specifically, the Department?s Public Transportation Division will ensure it performs risk assessments for all subrecipients receiving federal subawards regardless of when WSDOT executes the related contract. As of February 2023, the Public Transportation Division updated its risk assessment process and plans to complete all risk assessments by July 1, 2023. Completion Date: Estimated July 2023 Agency Contact: Jesse Daniels External Audit Liaison PO Box 47320 Olympia, WA 98504-7320 (360) 705-7035 danielje@wsdot.wa.gov

Finding: The Health Care Authority did not have adequate internal controls over and did not comply with federal requirements to ensure subrecipients of the Block Grants for Community Mental Health Services program and the Block Grants for Prevention and Treatment of Substance Abuse program received required single audits, and that it appropriately followed up on findings and issued management decisions. Questioned Costs: Assistance Listing # 93.958 93.958 COVID-19 93.959 93.959 COVID-19 Amount $0 Status: Corrective action in progress Corrective Action: The Authority concurs with the finding. The Authority will: ? Follow established procedures related to the agency-wide monitoring of subrecipients? single audits. ? Issue management decision letters for findings subrecipients received related to programs that are funded by the Authority?s pass-through federal funding. ? Evaluate corrective actions to ensure subrecipients adequately address audit recommendations. Completion Date: Estimated July 2023 Agency Contact: William Sogge, CPA External Audit Liaison PO Box 45502 Olympia, WA 98504-5502 (360) 725-5110 william.sogge@hca.wa.gov

Finding: The Department of Commerce did not have adequate internal controls over and did not comply with requirements to issue management decisions for audit findings to subrecipients of the Low-Income Home Energy Assistance Program. Questioned Costs: Assistance Listing # 93.568 93.568 COVID-19 Status: Corrective action complete Corrective Action: The Department?s internal control officer is responsible for completing the monitoring of federal reporting and issuing management decisions for subrecipients who receive federal audit findings for programs funded with the Department?s federal pass-through funding. Beginning in December 2021, the internal control officer documented all findings, corrective action plans, and communication with subrecipients in a monitoring spreadsheet. This enabled the Department to ensure all efforts in monitoring subrecipients were taken. In May 2022, all management decisions were added to the monitoring spreadsheet which documented the Department?s management decisions. To ensure compliance with federal requirements for subrecipient monitoring, the Department has implemented the following process: ? Review all audit findings issued to Department subrecipients. ? Review each subrecipient?s corrective action plan. ? Review and discuss all findings and corrective action plans with subrecipients to identify and understand the basis for the deficiency and planned corrections. ? Create a management decision for each subrecipient finding, receive leadership approval, and formally communicate the decision to our subrecipient. ? All management decisions will be formally communicated to our pass-through subrecipients within the six-month federal deadline. Completion Date: September 2022 Agency Contact: Gena Allen Internal Control Officer PO Box 42525 Olympia, WA 98504-2525 (360) 480-5149 Gena.Allen@Commerce.wa.gov

Finding: The University of Washington did not have adequate internal controls over and did not comply with federal requirements to ensure subrecipients of the Global AIDS program received required single or program-specific audits, and that it followed up on findings and issued management decisions. Questioned Costs: Assistance Listing # 93.067 93.067 COVID-19 Amount $0 Status: Corrective action in progress Corrective Action: The University maintains that there are adequate internal controls to ensure the Global AIDS program complies with the requirements for pass-through entities as outlined in Uniform Guidance 2 CFR ? 200.332 and the university policy incorporated in Grants Information Memorandum 8. As noted in the finding, the University uses a certification process to obtain information and documentation needed, such as audited financial statements, from each subrecipient and perform a risk assessment using standard risk criteria. For the one exception identified by the auditors, the University misinterpreted the response provided by the subrecipient regarding whether it expended $750,000 or more in federal awards during the fiscal year. Although the single or program specific audit report was not obtained and reviewed, a risk assessment was performed on the subrecipient. With a medium risk rating, the subrecipient was subject to monitoring at the program level throughout the project during the period in question, in accordance with University policy. The University will: ? Update the certification process with all subrecipients to confirm if federal expenditures during a fiscal year exceed the $750,000 threshold to require a single or program-specific audit. ? Issue written management decisions for all applicable audit findings. ? Ensure subrecipients develop and perform acceptable corrective actions to address all audit recommendations, if applicable. Completion Date: Estimated September 2023 Agency Contact: Erick Winger Controller 4300 Roosevelt Way NE Seattle, WA 98195 (206) 543-5322 erickw@uw.edu

2022-007 Finding: Subrecipient Monitoring - ALN 93.391 ? Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises / Department of Health and Human Services / Award Number: ENVHL-202159027 / Award Year: 2021 Status: Corrective action in progress Corrective Action: The City agrees with the finding. DDPHE will consult with the City?s Federal Grants Manager, other agencies that typically have subrecipients for federal awards, and the City Attorney?s Office to review the current standard contract provisions to ensure they cover all required provisions and will modify those provisions accordingly. Person(s) Responsible for Implementing: DDPHE ? Paige Cheney Implementation Date: October 2023

Bonneville Power Administration: Columbia Survival Study (CSS), Streamnet, and Smolt Monitoring by Non-Federal Entities Programs ? Assistance Listing No. 81.999 Recommendation: CLA recommends the Commission follow its internal controls and procedures over subrecipient monitoring to ensure subrecipient audits are received, reviewed, and followed up on and that documentation of those procedures is maintained. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Commission will conduct a comprehensive update on subrecipient surveys for fiscal year 2023. In addition, folders and documentation for the annual review of subrecipients? financial statements will be made available for the auditors in the upcoming fiscal year 2023 audit. Name(s) of the contact person(s) responsible for corrective action: Pam Kahut Planned completion date for corrective action plan: June 30, 2023

Reference Number: 2022-001 Assistance Listing Number: 84.425 Federal Program Title: Education Stabilization Fund Awarding Agency / Pass-Through Entity: U.S. Department of Education, Colorado Department of Education Compliance Requirement: Subrecipient Monitoring Criteria: None for ECSD Corrective Action: The District agrees with the finding and has adopted Policy Regulations: DD-R, Project Partnerships, Sub-Award Grants, Sub-Contracts Pursuant to Grants, and Third-Party Grants Involving District Personnel, Programs or Facilities and; DD-R2, Grants to District Personnel Personnel Responsible: Sandra Farrell, COO and Chelsey Gerard, Director of Finance Completion Date: October 31, 2022

Finding Number: 2022-002 ? Subrecipient Monitoring Name of Contact Person: Tamara Colden, Assistant Director Housing and Community Services Department Corrective Action: The Subrecipient Monitoring policy and procedures were updated in August 2022 to include the procedures for evaluating risk for subrecipients and revise monitoring procedures. These procedures will be updated to include checking the Federal Awards clearinghouse annually to assess audit requirements for all subrecipients and ensure the monitoring policy includes procedures when those audits result in any concerns or findings for subrecipients. A revised risk assessment will be conducted for each subrecipient. Proposed Completion Date: 06/30/2023

The DCEO filled the position responsible for issuing MDLs in June 2023.

Aging will hire and train staff; this is already in process.

The IDPH’s fiscal staff were notified in November 2021 to add the ALN to the warrant description for each subrecipient disbursement made.

IDHS - Division of Family and Community Services (FCS) The IDHS-FCS’ Bureau of Contract Support and Payment administration staff has reviewed the exceptions and worked to create a process to ensure the proper notification of the ALN at time of disbursement. A plan of action was created whereby in each fiscal year the IDHS’ Bureau of Program Support and Fiscal Management staff will communicate the appropriate ALN to be utilized. IDHS - Division of Substance Use, Prevention, and Recovery (SUPR) The IDHS-SUPR staff will ensure that all monthly expenditure vouchers have the ALNs listed and will work with IDHS’ fiscal staff to ensure that the ALNs are listed in the notes field for all vouchers processed for payments. Finally, the IDHS-SUPR staff will ensure that the ALNs are listed on all grants and contracts.

IDHS - Division of Family and Community Services (FCS) The IDHS-FCS staff will meet to determine the need for updated documentation and communication regarding subrecipient programmatic monitoring. IDHS - Division of Substance Use, Prevention, and Recovery (SUPR) The IDHS-SUPR staff will track the completion of compliance and monitoring activities and update the Virtual Compliance Review (VCR) Tracking spreadsheet to track additional monitoring activities to ensure compliance processes are achieved in a timely manner. The IDHS will send reminders and conduct follow- up activities with compliance monitors to ensure compliance and monitoring activities are moving forward as planned. Finally, IDHS will update procedures and provide training to compliance monitors to ensure consistent follow-up is conducted when organizations do not meet established deadlines.

The IDHS will implement fiscal and administrative reviews of IHDA and program monitoring procedures.