Corrective Action Plans

Finding 2023-800: Geographic Programs -Great Lakes Restoration Initiative— Subrecipient Monitoring Planned Corrective Action: DNR will develop a written plan for monitoring subrecipients for the Geographic Programs-Great Lakes Restoration initiative program. This plan will include completing a documented risk assessment for each subrecipient and specific steps for monitoring subrecipients based on the assessed level of risk. In addition,DNR will develop a process to ensure that subrecipient audit reports are received, the review is documented and will follow-up with subrecipients to ensure all audit reports are received. Anticipated Completion Date:11/1/24 Name, Title: Wade Strickland, Director Office: Office of Great Waters Email address: wade.strickland@wisconsin.gov Person responsible for corrective action: Name, Title:Karen Van Schoonhoven,Finance Director Division or Unit (if applicable): Internal Services Division Email address: karena.vanschoonhoven@wisconsin.gov

Finding 2023-103: Emergency Rental Assistance Program—Subrecipient Monitoring Auditor Recommendation: Review its existing monitoring procedures and ensure adequate management oversight procedures are established, documented, and followed. Planned Corrective Action: The Wisconsin Department of Administration (Department) has reviewed its existing monitoring procedures, designed to ensure that subrecipients use the subaward for authorized purposes, take timely and appropriate action on all deficiencies detected through monitoring, and comply with the terms and conditions of the subaward, as required by 2 CFR s. 200.332 (d) through (f), and its own policies and procedures. The Department will improve the completeness and effectiveness of its monitoring program by ensuring that management oversight procedures are appropriately established, documented, and followed. Auditor Recommendation: Complete review and follow-up with the community action agencies or Energy Services, Inc. (ESI) identified by its existing monitoring procedures. Planned Corrective Action: The Department will complete review and follow-up with the community action agencies or Energy Services, Inc. (ESI) in accordance with its existing monitoring procedures.Auditor Recommendation: Consider if additional monitoring should be completed for the community action agencies or ESI for the months during FY 2022-23 when the Department of Administration paused monitoring for the Emergency Rental Assistance Program. Planned Corrective Action: To maintain the integrity of its Emergency Rental Assistance monitoring program, the Department will complete additional monitoring of the community action agencies and ESI during FY 2022-23, including during the period acceptance of new program applications was temporarily paused. Anticipated Completion Date: June 30, 2024. Persons responsible for corrective action: David Pawlisch, Administrator Division of Energy, Housing and Community Resources david.pawlisch@wisconsin.gov

CORRECTIVE ACTION PLAN February 15, 2024 The Tor Project, Inc. (the Organization) respectfully submits the following corrective action plan for the year ended June 30, 2023. Name and address of independent accounting firm: CohnReznick LLP 350 Granite Street, Suite 1200 Braintree, MA 02184 Audit period: July 1, 2022 – June 30, 2023 The findings from the June 30, 2023 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Federal Award Findings and Questioned Costs Significant Deficiency Item #2023-001 - Subrecipient Monitoring International Programs to Support Democracy Human Rights and Labor – 19.345 Issue: The Organization did not fully monitor the subrecipients to ensure the subaward was used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Recommendation: Management should monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved per 2 CFR 200.332. Action Taken: Subsequent to fiscal year end, the Agency implemented additional internal controls over subrecipient monitoring and retroactively performed these compliance procedures. The Tor Project, Inc. sampled monthly invoice periods for each active sub-recipient, per grant, in the period of the FY23 annual external audit. The Tor Project reviewed all supporting documentation for the cost reimbursements of the sample to ensure accuracy and completeness of all reimbursed costs. For all sub-recipients, The Tor Project performed the internal audit procedure selecting a sample of monthly invoices at random per sub-recipient, per grant, per year to verify the completeness and accuracy of all reimbursed costs. If there are any questions regarding this plan, please call Susan Abt at 781-307-8651.

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE – U.S. DEPARTMENT OF EDUCATION, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, CAREER AND TECHNICAL EDUCATION – BASIC GRANTS TO STATES – FEDERAL ALN 84.048 2023-001 Internal Control Over Compliance With Subrecipient Monitoring Requirements Finding Summary 2 CFR § 200.332 requires Intermediate District No. 287 (the District) as a pass-through entity, to have written subrecipient monitoring policies and procedures that include a written risk assessment of each subrecipient and documentation of the District’s monitoring of the subrecipient. Additionally, as a pass-through entity, the District is required to verify that every subrecipient is audited as required by 2 CFR § 200 Subpart F when it is expected that the subrecipient’s federal awards expended during the respective fiscal year equaled or exceeded the threshold for a federal Single Audit. During our audit, we noted that the District did have documented written controls to ensure compliance with the U.S. Office of Management and Budget’s Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) subrecipient monitoring requirements. The District did not maintain documentation of its evaluation of each subrecipient’s risk of noncompliance with federal statutes, regulations, and the terms and conditions of the subaward, nor did the District maintain documentation of the results of the subrecipients’ Single Audit, if any, for purposes of determining the appropriate subrecipient monitoring. Corrective Action Plan Actions Planned – The District will review its policies and procedures relating to subrecipient monitoring for its federal programs to ensure compliance with the Uniform Guidance in the future. Official Responsible – The District’s Executive Director of Business Services, Brian Schultz. Planned Completion Date – June 30, 2024. Disagreement With or Explanation of Finding – The District agrees with the finding. Plan to Monitor – The District’s Executive Director of Business Services, Brian Schultz, will assure appropriate internal controls and procedures are updated and in place to ensure compliance with subrecipient monitoring requirements.

Contact Person Debby Marshall Planned Corrective Action The Cooperative will ensure proper subrecipient monitoring is implemented. Planned Completion Date June 30, 2024.

2023‐013 – Subrecipient Monitoring (Material Weakness) State Department of Labor and Industrial Relations AL Numbers and Program Title: 17.258 – WIOA Adult Program 17.259 – WIOA Youth Activities 17.278 – WIOA Dislocated Worker Formula Grant (WIOA Cluster) Condition No evidence of evaluation of the subrecipients’ risk of noncompliance at the time of the subawards, and no evidence of on‐site monitoring procedures of the subrecipients. Current Status of Corrective Action Plan Concur. -The ASO will come up with a checklist of pertinent reports that are due for WIOA programs including but not limited to Risk Assessment Report to include the following information: - Subrecipient’s prior experience with the same or similar subawards. - Results of previous Single Audit of the same or similar program that has been audited as major program. - New and Departing Personnel Record. - Systems Changes/Update. - Completion of Subrecipient Monitoring Report. - A formal analysis of each subrecipient’s risk of noncompliance with each of the respective subaward requirements shall be performed at the time of the subaward. - In‐person, onsite monitoring of the activities of the subrecipient shall take place annually to ensure that the subaward is used for authorized purposes, in accordance with federal statute and regulations. Person Responsible Ferdinand Casabay, Accountant VI Anticipated Date of Completion May 31, 2024

Finding No. 2023‐008 – Subrecipient Monitoring (Significant Deficiency) State Department of Land and Natural Resources AL Number: 15.634 Program Title: State Wildlife Grants (R&D Cluster) Condition The auditing firm examined a non‐statistical sample of two subawards and noted the following instances of noncompliance: -Subaward agreements did not include certain required federal award information. -No evidence of pass‐through entity verifying that subrecipients are audited as required by 2 CFR Section 200, Subpart F. Current Status of Corrective Action Plan Concur. DLNR DOFAW does provide subaward information to subrecipients and will ensure to include all required federal award information. DLNR DOFAW will ensure that documentation is retained when performing verification that subrecipients are audited as required by 2 CFR Section 200, Subpart F. Person Responsible Cynthia C. Gomez, Fiscal Management Officer David Smith, DOFAW Administrator Anticipated Date of Completion Completed.

1. Person responsible: Division Chief, Auditor-Controller Accounting Division 2. Corrective action plan: The County agrees with the finding and recommendation. In September 2022, the County issued the Notice of Federal Subaward Information template, which contains the 14 reporting elements required by 2 CFR §200.332(a) that must be provided to subrecipients at the time of the subaward. The County will issue written correspondence reminding departments to complete the Notice of Federal Subaward Information template and provide a completed copy to the subrecipient at the time of the subaward. The County will also remind departments to provide all the required elements from 2 CFR §200.332(a) via letter or amended agreement to existing subrecipients that were not initially provided all the requirements. In the same correspondence, the County will remind departments to monitor their Coronavirus State and Local Fiscal Recovery Fund (CSLFRF) subrecipients, maintain sufficient records of the monitoring, and utilize the Subrecipient Monitoring Guide issued in June 2023. 3. Anticipated implementation date: June 28, 2024

2023-003: 21.027 – COVID-19 – American rescue Plan Act Funds (US Treasury ARPA) • Recommendation: We recommend that the County prepare and maintain a written plan to ensure subrecipients are aware of the Uniform Guidance requirements. • Explanation of disagreement with audit finding: There is no disagreement and management agrees with the finding. • Corrective action taken in response to finding: The County Office of Finance will create a written plan to ensure that subrecipients are aware of all the needed Uniform Guidance requirements. • Name of the contact person responsible for corrective action: Kevin McMahon, Office of Finance. • Planned completion date for the corrective action plan: June 30, 2024.

2023-001: 172.258, 17.259, 17.278 – WIOA Cluster • Recommendation 1: We recommend that the County prepare and maintain a written plan to ensure subrecipients are aware of the Uniform Guidance requirements. • Recommendation 2: We recommend the County performs the monitoring of the subrecipients and ensure the documentation is saved within the County. • Explanation of disagreement with audit finding: There is no disagreement and management agrees with the finding. • Corrective action taken in response to finding: The County Office of Finance will (1) develop a written plan to ensure that subrecipients are aware of all the Uniform Guidance requirements; (2) due to the pandemic and the recent retirement and resignation of the top two Grant department staff members, the monitoring was not conducted during the audit period. Management will make sure that the required monitoring will be conducted and ensure compliance and proper documentation is maintained onsite. • Name of the contact person responsible for corrective action: Kevin McMahon, Office of Finance and Charles Knapp, Anne Arundel Workforce Development Corporation. • Planned completion date for the corrective action plan: June 30, 2024.

Finding 2023-009 Lack of Subrecipient Monitoring Plan: The University of Illinois Springfield will review procedures to ensure subrecipient monitoring is conducted and documented for all subawards. Expected Implementation Date: April 2024 Contact: Charles Alsbury, Director Office of Research & Sponsored Programs, Post-Award University of Illinois Springfield Ralsb01s@uis.edu 217-206-7849

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 this 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), 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 establish a plan to ensure that a final review of contracts is completed to confirm that accurate Federal award identification information is included and documented prior to being sent to the provider for signing. The Department will begin using the established plan to ensure that a final review of contracts is completed to confirm that accurate Federal award identification information is included and documented prior to being sent to the provider for signing. The Department will re-evaluate the risk of current providers to determine the appropriate monitoring activities. The Department team will establish a plan to ensure that they receive, review, and approve all financial and performance reports within 10 business days of receipt. The Department will begin using the established plan to receive, review, and approve all financial and performance reports within 10 business days of receipt. Completion Date: April 30, 2024 (first item), May 31, 2024 (second, third and fourth items) and June 30, 2024 (fifth item) Agency Contact: Eden Silverthorne, Associate Director, Office of Population Health Equity (CDC OPHE PSM II), 207-441-1090

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: Ongoing and July 1, 2024 respectively Agency Contact: Shelly Chasse-Johndro, Director of OFERP, DOE, 207-458-3180

Department: Education Title: Internal control over Special Education subrecipient audit procedures needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The Department will review the current procedure regarding the notification of management decisions related to audit findings and corrective action, to strengthen the areas where prior notifications were missed. Completion Date: April 30, 2024 Agency Contact: Nicole Denis, Director of Finance, DOE, 207-530-2161

Department: Administrative and Financial Services Title: Internal control over CSLFRF reporting needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The Department will review contracts with the agencies to verify the classifications. Completion Date: June 30, 2024 Agency Contact: Marilyn Leimbach, Director, Security and Employment Service Center, DFPS, DAFS, 207-248-2556

Department: Labor Title: Internal control over CSLFRF subrecipient risk evaluation procedures needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The Department will further develop and refine the sub-recipient monitoring procedure and implement the revised process. Completion Date: June 30, 2024 Agency Contact: Samantha Dina, Associate Commissioner, DOL, 207-816-1714

Department: Economic and Community Development Title: Internal control over CSLFRF subrecipient audit procedures needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The Department engaged with their contractor to review single audits for all subrecipients receiving more than $750,000 in aggregate federal funding. The contractor will raise any findings to the attention of DECD staff who will then issue a management decision letter in keeping with federal regulations. The Department will continue its own review in conjunction with that of the contractor and address findings or concerns with subrecipients to ensure that findings are addressed and that chances of recurrence are mitigated. Completion Date: February 21, 2024 and ongoing respectively Agency Contact: Denise Garland, Deputy Commissioner, DECD, 207-624-7496

Department: Economic and Community Development Title: Internal control over ERA Program subrecipient monitoring needs improvement Questioned Costs: None Status: Corrective action complete Corrective Action: The Department has contracted with a vendor to conduct all subrecipient monitoring of all federal ARPA funding. The Department has required detailed documentation in support of subrecipient reimbursement of all federal ARPA funding. 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 monitoring procedures needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The Department will update the newly established risk evaluation tool, with new auditor suggestions. The Department will enhance the policies and procedures to ensure that the audit reports for all subrecipients receiving over $750,000 in Federal Awards requiring audits are properly tracked, received, and reviewed. The Department will enhance documentation to support the reasons for late or missing audit reports. The Department will implement a process to ensure that all reviews are fully completed within the allotted timeframe. Completion Date: April 1, 2024 (first item), May 1, 2024 (second item) and June 1, 2024 (third and fourth items) Agency Contact: Jane McLucas, Director of Child Nutrition, DOE, 207-624-6880

Department: Education Title: Internal control over CNC subrecipient monitoring procedures needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The Child Nutrition supervisor will review details of the findings from the state auditors to assess where errors occurred in both administrative review completion and tracking. Clear separation of duties will be created between administrative staff responsibilities for review tracking and reviewer staff responsibilities. Staff will be trained on review tracking spreadsheet responsibilities. Staff will be trained on administrative review tool completion. Training will highlight areas where data was missing, more information was needed or errors were made. This will occur at monthly staff meetings. Special Provision 2 base year review staff will be trained on the need to ensure SFAs revise claims as required due to base year review findings. It will be recommended that a tracking document be created to validate that claim adjustments have been made. If the adjustment is over the 60 day late claim window, the financial specialist will track the reason for the claim exception. Completion Date: March 15, 2024 (first, second and third items), June 10, 2024 (fourth item) and March 14, 2024 (sixth item) Agency Contact: Adriane Ackroyd, Assistant Director Child Nutrition, DOE, 207-592-1722

Finding No. 2023-001 Subrecipient Monitoring Cluster: Research and Development Cluster Grantor: Department of Health and Human Services and National Aeronautics and Space Administration Award Names: Biomedical Research and Research Training and Science Award Year: July 1, 2022 – June 30, 2023 Award Number: 5R01GM140457-03 and 80NSSC21K0753 Assistance Listing Numbers: 93.859 and 43.001 Pass-through entity: Not applicable The College agrees with the finding noting that a business control process was in place for the regular monitoring of subrecipients, however, the College did not retain certain documentation evidencing this review. The ongoing risk inherent with subrecipient scenarios is taken seriously by the College, but the reviews have been informally performed and without standard documentation. The College has recently added a full time equivalent to the Controller’s Office for grant administration purposes, such as this control. Through the assistance of this new employee, the College will develop a formal subrecipient process and move forward with its implementation. We anticipate certain steps in place by June 30, 2024. Stephen Nigro, Controller is responsible for implementing this corrective action plan. Contact Person: Stephen Nigro, Controller (413) 542-2101

The organization has assigned a full-time employee with prior experience in subrecipient monitoring to own this process and will make additional resources available as necessary. Organizational leadership has reviewed the subrecipient monitoring policy to verify the proper steps and processes are in place to ensure compliance.

Community Partners acknowledges that while subrecipient monitoring was performed for federal subrecipients by hiring third party CPAs, the monitoring was based on randomly selected samples and a risk assessment was not included in the monitoring plan. Current leadership has enhanced the subrecipient monitoring plan by ensuring that risk assessments are incorporated into any future subrecipient monitoring. The person responsible for the corrective action detailed above will be Joyce Williams, Chief Financial and Operations Officer, (213) 346‐3202. We anticipate corrective action will be completed by June 30, 2024.

Community Partners acknowledges that while subrecipient monitoring was performed for federal subrecipients by hiring third party CPAs, the monitoring was based on randomly selected samples and a risk assessment was not included in the monitoring plan. Current leadership has enhanced the subrecipient monitoring plan by ensuring that risk assessments are incorporated into any future subrecipient monitoring. The person responsible for the corrective action detailed above will be Joyce Williams, Chief Financial and Operations Officer, (213) 346‐3202. We anticipate corrective action will be completed by June 30, 2024.