Corrective Action Plans

Views of Responsible Official: We concur with the audit finding with respect to the monitoring of subrecipients for the American Rescue Plan funding. The County monitored the subrecipient agreement for the 50% matching requirement, and the subrecipient was paid properly. However, we did not obtain quarterly progress reports on the program. Description of Corrective Action Plan: Effective January 1st, 2024, the County will obtain progress reports on a quarterly basis for all active subrecipient agreements. Completion date: December 20, 2023.

CONDITION: The ROE did not have adequate controls over subrecipient monitoring in compliance with the Code. PLAN: The ROE retroactively conducted monitoring of the subrecipients of the ARP - Social Emotional Learning grant passed through the ISBE. The subrecipients of this grant were all other ROEs in the Area IV hub (ROEs 9, 17, 32, and 54) with funds going out for administration costs. Since it is common knowledge that each ROE is audited annually by the Illinois Auditor General, further audit consideration was unnecessary. The ROE will draft subrecipient monitoring policies and procedures to align with standards. Future monitoring will be scheduled in December 2023. ANTICIPATED DATE OF COMPLETION: New policy and procedures implemented partially in FY23 and fully for FY24. CONTACT PERSON: Ms. Jill Reedy, Regional Superintendent

2022-001 – Communications with Subrecipients Finding Type: Significant Deficiency in internal control over compliance Program: ALN 93.959 – SAPT COVID Supplement ALN 93.959 – Prevention, Women’s Specialty Services, Administration ALN 93.959 – Treatment/AMS Criteria: As required by 2 CFR 200.332, the pass-through entity must communicate specific information to subrecipients, as applicable. Condition: Contracts with subrecipients did not include portions of required disclosures. Cause/Effect: Inadequate internal controls over compliance. Select contracts were not in compliance with 2 CFR 200.332. Questioned Cost: None. Recommendation: We recommend that the Entity update all contracts with subrecipients to include required language. View of Responsible Official: Management is in agreement with this recommendation. Planned corrective action: FY2023 contracts with subrecipients have been partially updated with the required language and all required language will be included in the FY2024 contracts with subrecipients. Responsible party: Chief Financial Officer Anticipated completion date: September 30, 2024

Assistance listing number and program name: 93.558 Temporary Assistance for Needy Families 93.558 COVID-19 Temporary Assistance for Needy Families Agency: Department of Economic Security Name of contact person and title: Molly Bright, DCAD Assistant Director Anticipated completion date: June 30, 2024 Agency’s Response: Concur The Department will stop the reimbursement of costs to all nonprofit and contracted subrecipients for items that are disallowed and/or restricted by the regulations provided within the provisions of the federal Temporary Assistance for Needy Families (TANF) grant received by the Department. Additionally, the Department will obtain all supporting documentation needed to ensure compliance with these regulations prior to disbursing any TANF funding to any subrecipient for the purpose of reimbursement or programmatic funding. The Department will also update its policies and procedures for subrecipient monitoring. Furthermore, detailed training for the Department personnel responsible for reviewing and approving subrecipient reimbursement requests will be provided to ensure personnel are capable of identifying costs that are unallowable under federal regulations. The Department will assess the risk of noncompliance violations for each subrecipient and establish a plan of action to address noncompliance. The plan of action will include an array of training and educational processes to ensure applicable personnel are knowledgeable of TANF compliance requirements and Department contracts. The Department will also monitor subrecipients per updated policies and procedures. The Department will continue to resolve the unallowable costs reimbursed to subrecipients as deemed appropriate by the United States Department of Health and Human Services.

Assistance listing number and program name: 84.425C COVID-19 Education Stabilization Fund – Governor’s Emergency Education Relief (GEER) Fund Agency: Arizona Governor’s Office of Strategic Planning and Budgeting (Office) Name of contact person and title: Sarah Brown, Director Governor’s Office of Strategic Planning & Budgeting Completion date: July 31, 2024 Agency’s Response: Concur During fiscal year 2023, the Office took significant corrective action to improve subrecipient monitoring, including assessing each subrecipient’s risk of noncompliance, collecting single audits (as applicable) or certified financial statements from new awardees, and requesting and reviewing additional information from grantees related to uses of awarded funds. Moving forward, the Office proposes the following: 1. The Office will annually require grantees to complete a questionnaire to attest whether the entity will be required to obtain a single audit. The Office will collect single audits (as applicable) or certified financial statements in order to review and follow-up on corrective action items related to the grants administered. The Office will conduct grantee training regarding subrecipient monitoring and the requirements for grantees accepting Federal grant awards. 2. The Office staff have attended various training opportunities to improve their understanding of and tools available to them to perform subrecipient monitoring procedures, as required. The Office has also conducted a staffing assessment and has added staff to perform subrecipient monitoring activities.

Assistance listing number and program name: 21.027 Coronavirus State and Local Fiscal Recovery Funds Agency: Arizona Governor’s Office of Strategic Planning and Budgeting (Office) Arizona Office of Tourism Arizona Supreme Court Name of contact person and title: Sarah Brown, Director Governor’s Office of Strategic Planning & Budgeting Lena Allen, Director of Outdoor Recreation & Sustainability Alyce Agostino, Financial Analyst, Grant Compliance Agency’s Response: Concur Anticipated Completion date: see below Office Completion date: July 31, 2024 During fiscal year 2023, the Office took significant corrective action to improve subrecipient monitoring, including assessing each subrecipient’s risk of noncompliance, collecting single audits (as applicable) or certified financial statements from new awardees, and requesting and reviewing additional information from grantees related to uses of awarded funds: 1. The Office will annually require grantees to complete a questionnaire to attest whether the entity will be required to obtain a single audit. The Office will collect single audits (as applicable) or certified financial statements in order to review and follow-up on corrective action items related to the grants administered. The Office will conduct grantee training regarding subrecipient monitoring and the requirements for grantees accepting Federal grant awards. 2. The Office staff have attended various training opportunities to improve their understanding of and tools available to them to perform subrecipient monitoring procedures, as required. The Office has also conducted a staffing assessment and has added staff to perform subrecipient monitoring activities. Arizona Office of Tourism Anticipated Completion date: January 31, 2024 • Risk Assessment aspect of finding: The Arizona Office of Tourism (AOT) is now aware and will comply with these requirements. In order to comply, AOT will update processes and procedures to include risk assessments of subrecipients. This process will include both an outline for analysis along with the proper documentation and all necessary actions. • Subrecipient Single Audit aspect of finding: Per 2 CFR 200.332(f) AOT had a process in place for any subrecipient that was awarded through the Visit Arizona Initiative Grant Program over $750,000. As outlined by the audit, 2 CFR 200.332(f) applies for any organization that receives over $750,000 in federal funds even outside of the VAI grant program. To align with this requirement, AOT will create a process for identifying, requesting and reviewing Single Audits. Arizona Supreme Court – Administration Office of the Courts Anticipated Completion date: February 28, 2024 The Judicial Branch, Arizona Supreme Court, has drafted a Risk-Assessment Questionnaire for all Grants in which the Supreme Court is a pass-through grantee, to collect all essential information that is needed to reasonably assess the risk probability of possible subrecipients going forward in accordance with 2 CFR §200.332[b] and [d-e].

Assistance listing number and program name: 21.019 COVID-19 Coronavirus Relief Fund Agency: Arizona Governor’s Office of Strategic Planning and Budgeting Name of contact person and title: Sarah Brown, Director Governor’s Office of Strategic Planning & Budgeting Anticipated completion date: July 31, 2024 Agency’s response: Concur During fiscal year 2023, the Office took significant corrective action to improve subrecipient monitoring, including assessing each subrecipient’s risk of noncompliance, collecting single audits (as applicable) or certified financial statements from new awardees, and requesting and reviewing additional information from grantees related to uses of awarded funds. Additionally, Office staff have attended trainings to improve their understanding of and tools available to them to perform subrecipient monitoring procedures, as required. The Office has also conducted a staffing assessment and is adding resources to perform subrecipient monitoring.

Assistance listing number and program name: 14.231 Emergency Solutions Grant Program 14.231 COVID-19- Emergency Solutions Grant Program 14.267 Continuum of Care Program Agency: Department of Housing Name of contact person and title: Keon Montgomery, Assistant Deputy Director of Programs Molly Bright, DCAD Assistant Director (DES) Anticipated completion date: April 30, 2024 Agency’s Response: Concur Department of Housing response: The Department is no longer reimbursing the subrecipient for unsupported or ineligible costs and is working to resolve the issue. The HUD Field Office is aware of the findings and the Department is working toward resolution. Written policies for reviewing and approving subrecipient reimbursements, as well as, risk assessment will be reviewed and updated. Contract specialists in the Special Needs Division have begun training and the Department will continue to leverage Federal educational resources centered on Grants and Agreements, 2 CFR 200 cost principles and award requirements. Department of Economic Security response: Agency: Department of Economic Security Name of contact person and title: Molly Bright, DCAD Assistant Director Anticipated completion date: June 30, 2024 Agency’s Response: Concur The Department will stop the reimbursement of costs to all nonprofit and contracted subrecipients for all items that are disallowed and/or restricted by the regulations provided for within the provisions of the federal Emergency Solutions Grant Program (ESG), including payments that violate the conflict-of-interest disclosure requirements. Additionally, the Department will revise its cost monitoring policy to ensure compliance with these regulations prior to disbursing any ESG funding to any subrecipient for any purpose. The Department will also update its policies and procedures for subrecipient monitoring. The Department will assess the risk of noncompliance violations for each subrecipient and establish a plan of action to address noncompliance. The plan of action will include an array of training and educational processes to ensure applicable personnel are knowledgeable of ESG compliance requirements and Department contracts. The Department will also monitor subrecipients per updated policies and procedures. The Department will continue to resolve the unallowable costs reimbursed to subrecipients as deemed appropriate by the United States Department of Housing and Urban Development.

Assistance Listing 93.558 Temporary Assistance for Needy Families Assistance Listing 93.658 Foster Care – Title IV-E Act 148 Pennsylvania Department of Human Services Views of the Responsible Officials and Corrective Action Plan: Effective 10/13/23, DHS has been preparing FY24 funding allocation letters that will be sent to provider agencies immediately. Going forward, the funding allocation letters will go out at the beginning of the contract fiscal year. Contact Person: Landuleni Shipanga, Controller, Department of Human Services, 215-683-6366.

Assistance Listing 93.558 Temporary Assistance for Needy Families Views of the Responsible Officials and Corrective Action Plan: Management agrees with the finding and recommendation. Starting from FY2024, MOCEO will include a Notice of Award document for all subrecipients contracts. This document will contain the necessary OMB required information to clearly identify award details for the subrecipient. Contact Person: Allison Elliott, Director of Finance, Mayor’s Office of Community Empowerment and Opportunity, 215-685-3626

Finding No.: 2021-033 AL Program: 21.027 - Coronavirus State and Local Fiscal Recovery Funds Area: Subrecipient Monitoring Questioned Costs: $0 Contact Peron(s): Thomasa DLG. Naraja, Senior Financial Analyst, SOF Corrective Action Plan: The Department of Finance agrees with this finding. To address the findings identified, the Department of Finance (DOF) will conduct a thorough review of policies and procedures governing subrecipient monitoring. This review aims to identify any gaps or ambiguities that may have contributed to the audit findings. The DOF is committed to updating these policies and procedures promptly to clarify requirements and strengthen controls over compliance. Proposed Completion Date: Ongoing

Finding No.: 2021-028 AL Program: 21.019 - Coronavirus Relief Fund Area: Subrecipient Monitoring Questioned Costs: $59,158 Contact Person(s): Ryan Camacho, Sr. Financial Analyst / Pam Marigmen, Sr. Financial Analyst, SOF Office Corrective Action Plan: The Department of Finance agrees with this finding under ALN# 21.019. We have completed our review and proposed adjustments to accurately reflect expenditures in compliance with grant policies and requirements. Moving forward, we have implemented policies and procedures to ensure that all documentation is uploaded to the new financial system, and proper review and documentation are included to verify the allowability of expenditures within grant policies and requirements. Proposed Completion Date: Completed

Finding No.: 2021-022 AL Program: 15.875 - Economic, Social, and Political Development of the Territories Area: Subrecipient Monitoring Questioned Costs: $0 Contact Person(s): Nerissa B. Karakaya, CIP COTR Corrective Action Plan: Conditions 1 - 4: The CIP Office agrees with this finding. Capital Improvement Program updated the Subrecipient Monitoring Agreement to reflect the additional grant information required. A copy of the updated agreement is attached for your reference. We agree that personnel should obtain training specifically in subrecipient monitoring. A request for best practices was made to the Senior Financial Analyst at the Department of Finance responsible for audits. In response, a sample copy of the sub-recipient agreement, grant monitoring checklist, and subgrantee risk-based assessment was shared. A revised version of the agreement, monitoring checklist, and risk-based assessment will be developed and implemented. - Identify and enroll key personnel in comprehensive training programs focused on subrecipient monitoring requirements and best practices. Budget allocation for training programs, and identification of credible training providers. - Develop and implement detailed policies and procedures for subrecipient monitoring that comply with federal and state regulations. Consultation with compliance experts, review of regulatory guidelines. - Establish a regular schedule for monitoring subrecipients, including periodic reviews and audits to ensure adherence to compliance requirements. Development of monitoring tools and checklists, allocation of staff time for periodic reviews. - Implement a system for documenting subrecipient monitoring activities, findings and preparing regular reports for internal review and oversight. Proposed Completion Date: Ongoing

FINDING 2021-003 – Subrecipients Monitoring (Repeated from Prior Year Findings 20-004, 19-005, 18-004, and 17-003) CONDITION: The ROE does not have effective internal controls over subrecipient monitoring. Furthermore, ROE #47 was not properly monitoring subrecipients in accordance with the Uniform Guidance standards. During audit testing procedures it was determined that ROE #47: Number of Subrecipients a. Did not evaluate the risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward. 2 of 2 b. Did not conduct subrecipient monitoring procedures 2 of 2 c. Did not determine whether the subrecipient met the 2 CFR 200 Subpart F Audit Requirements criteria for a single audit. 2 of 2 PLAN: Regional Office of Education will implement the following internal controls over Federal awards to ensure subrecipients are properly monitored as required by 2 CFR 200.332. This includes: a. Evaluating the risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward; b. Conducting subrecipient monitoring procedures; and c. Determining whether the subrecipient met the requirement criteria of 2 CFR 200 Subpart F Audit requirements for a single audit. ANTICIPATED DATE OF COMPLETION: Fiscal Year 2021 CONTACT PERSON: Mr. Chris Tennyson, Regional Superintendent for Lee, Ogle, and Whiteside Counties.

Public Health agrees with the recommendation. We will establish formal procedures for conducting risk assessments of our subrecipients. Public Health will also develop and implement specific subrecipient monitoring procedures and establish a process for obtaining single audit reports from out subrecipients. Finally, we will develop a monitoring mechanism to track subrecipients' compliance with the single audit mandate. Estimated Implementation Date: December 2024 Contact: Melissa Relles, Assistant Deputy Director Division of Operations Center for Preparedness and Response California Department of Public Health

California Business, Consumer Services and Housing Agency (BCSH) The California Interagency Council on Homelessness (Cal ICH), an entity under the BCSH, would like to acknowledge a finding from the fiscal year 2020-21 Statewide Federal Compliance Audit of the State of California. This audit finding identifies lack of communication of required subaward information to Cal ICH subrecipients of the Coronavirus Relief Fund (CRF) program at the time of the subaward, or when the State became aware of changes in subaward information, including identification that the subaward funds represented federal funding. Cal ICH agrees with this finding and the recommendation to review all subawards provided which were funded using CRF program funds and determine whether the subrecipients properly reported their CRF awards and related expenditures in their respective schedule of expenditures of federal awards pursuant to Title 2 Code of the Federal Regulations 200.502. Additionally, while formal communication identifying that the subaward fund represented federal funding was not provided, many informal conversations were had with CRF grantees. These conversations were held during bi-weekly online Office Hours and through one-on-one calls with individual subrecipients and discussions of the substitution of federal awards with grantees originally provided with State funds could have occurred. Cal ICH will conduct review of the CRF subawards during mandatory desk reviews to verify that subrecipients properly reported their CRF awards and that expenditures of the federal awards were made pursuant to Title 2 Code of Federal Regulations 200.502. Additionally, Cal ICH has developed an improved communication system between leadership and program staff that will ensure changes are clearly communicated. This will also ensure the Council’s subrecipients are notified in a timely manner upon any changes in subaward information, such as identifying if subaward funds represent federal funding so that expenditures are spent in accordance with Federal statutes, regulations, and the terms and conditions of federal awards. Additionally, if in the future funding is changed, CDE will provide updated information to all recipients; this will ensure that expenditures are in line with the terms and conditions of the grant and/or funding source. Estimated Implementation Date: May 2023 Contact: Ellen Meuchel, Monitoring Unit Cal ICH Grant Operations and Suppor California Department of Education Concur. Education will review the relevant subawards funded under the CRF program and determine whether the subrecipients properly reported their CRF awards pursuant to 2 CFR 200.501. Estimated Implementation Date: July 31, 2023 Contact: Kelly Levario, External Audits Coordinator Audits and Investigations Division California Department of Social Services The California Department of Social Services (CDSS) acknowledges the Single Audit finding regarding the delayed communication of subaward information to the Department’s subrecipients of the Coronavirus Relief Fund (CRF) program. On December 21, 2022, CDSS released County Fiscal Letter 22/23-31 on the subject of “Federal Coronavirus Relief Funds That Replaced General Fund for COVID-19 Related Activities for Fiscal Years 2019-20 and 2020-21” to County Welfare Departments (CWDs) and federally recognized Tribal governments in California. This letter served as a formal documentation of the portion of expenditures that were funded with federal CRF. Additionally, although formal notice was not provided until December 21, 2022, informal notices and conversations took place between CDSS and the County Welfare Directors Association, as well as with CWDs, regarding possible situations in which the substitution of federal awards with grants originally provided with State funds could occur. On September 21, 2021, CDSS sent a notice to subrecipients requesting for their Data Universal Number System for the purpose of CRF federal subawards; thereby, communicating the use of CRF on the subrecipients’ behalf. CDSS will conduct a review of the CRF subawards during on-site fiscal monitoring reviews to verify that subrecipients properly reported their CRF awards and that expenditures of the federal awards were made pursuant to Title 2 Code of Federal Regulations 200.502. Moreover, CDSS will ensure that the Department’s subrecipients are notified in a timely manner upon any changes in subaward information, such as identifying if subaward funds represent federal funding so that expenditures are spent in accordance with Federal statutes, regulations, and the terms and conditions of federal awards. Estimated Implementation Date: April 2023 through June 2024 Contact: Elisa Tsujihara, Chief Fiscal Policy and Analysis Bureau

Finding 2021-009 Management agrees with the finding and is implementing the accompanying corrective action plan. Views of Responsible Officials: Jessica Martinez, Program Director Joel Rusco, Chief Financial and Administrative Officer Jacy Hyde, Executive Director Contact Person: Jessica Martinez, Program Director Corrective Action Plan: • CFSC has retained Clark Nuber to assist in updating its policies and procedures to include a risk assessment for all subrecipients. The updated procedure includes a review of the subrecipients’ past audits and the development of a thorough monitoring plan based on an assessment of risk and/or audit findings pertaining to federal awards. • CFSC will update its policies and procedures to require subrecipients to report matching funds on a quarterly basis to ensure the matching requirement is met by the end of the grant period. Anticipated Completion Date: CFSC will implement these corrective actions by the end of Quarter 2 of 2024.

2021-013 Lack of Internal Controls and Noncompliance with Subrecipient Monitoring - Emergency Rental Assistance Program The County has met with the Oklahoma State Auditor & Inspector's office m reference to Finding 2021-013 lack of internal controls and noncompliance with sub-recipient monitoring requirements for the Emergency Rental Assistance Program. We agree with the auditor's recommendation and will take the following corrective actions: I . Design and implement internal controls to ensure compliance with all applicable federal laws, regulations, and grant requirements for current and future ERA grants. This will include: a) Amend written policies and procedures to better included sub-recipient monitoring, including requirements for sub-recipients to provide supporting documents for actual administrative expenditures incurred rather than receiving advance payments. b) Providing annual training to staff on the new sub-recipient monitoring policies and procedures. c) Implementing a documentation and review process to ensure sub-recipients are properly informed of federal requirements related to allowable cots and that expenditures are supported before payment. 2. Strengthen sub-recipient agreements to include clear requirements around supporting documents for administrative costs. 3. Increase monitoring of sub-recipients through periodic desk audits and site visits to review expenditures and supporting documentation. The County takes these findings seriously and will implement robust internal controls and subrecipient monitoring procedures to ensure full compliance with federal grant requirements and prevent any future noncompliance or questioned costs. We appreciate the auditor identifying these issues so they can be properly addressed and corrected. Please let us know if any additional information or documentation is needed regarding the corrective actions. Anticipated Completion Date: November 27,2023 Responsible Contact Person: Rod Cleveland,Chairman BOCC

Finding 2021‐009 Monitoring Activities – Subrecipient Monitoring – Material Noncompliance and Material Weakness in Internal Control over Compliance Corrective Action Plan Management will revise the policies and procedures related to subrecipient monitoring and will ensure that policies are established to ensure subawards contain the required federal award information. Expected Completion Date Fiscal Year 2025.

Finding 2021‐008 Subrecipient Agreements – Subrecipient Monitoring – Material Noncompliance and Material Weakness in Internal Control over Compliance Corrective Action Plan Management will revise the policies and procedures related to subrecipient monitoring and will ensure that policies are established to ensure subawards contain the required federal award information. Expected Completion Date Fiscal Year 2025.

Planned Corrective Action: The Consortium will implement procedures to ensure quarterly reports are filed no later than the tenth calendar day of the second month following the quarter the report represents. In addition, all data reported thru these quarterly reports will be supported by the accounting system of the Fiscal Agent and County Financial Information System (CFIS). Anticipated Completion Date: March 31, 2024 Responsible Contact Person: Crystal Keaton

The Authority contracted with the Berks Coalition to End Homelessness (BCEH) to undertake various aspects of the Emergency Rental Assistance Program. In the late fall of 2021, the Authority began monitoring the work of BCEH and reviewing all case documentation provided by BCEH.

Contact person(s) responsible: Executive Director Vanessa Timmons, Associate Director Keri Moran-Kuhn Corrective Action planned: OCADSV will ensure that all future federal subawards will contain the information required by CFR §200.332. All contracts, sub-grantees, and MOU’s, will include information required. Anticipated completion date: Effective 6-1-2023 and ongoing

Corrective Action Plan: The Program has designed and implemented policies and procedures that enable the Compliance division to use the risk assessment results as a work plan for performing the site visits and monitoring of subrecipients on an annual basis. COR3 will continue to follow its policy for the management and monitoring of its subrecipients to ensure their compliance in managing federal funds. Contact Person: Alejandro Nieto, Compliance Director Anticipated Completion Date: No later than December 31, 2023

Planned Corrective Action: The Consortium will implement procedures to ensure quarterly reports are filed no later than the tenth calendar day of the second month following the quarter the report represents. In addition, all data reported thru these quarterly reports will be supported by the accounting system of the Fiscal Agent and County Financial Information System (CFIS). Anticipated Completion Date: March 31, 2024 Responsible Contact Person: Crystal Keaton