Corrective Action Plans

FINDING 2022-003 Individuals Responsible for Corrective Action Plan: Kristine Steinmann, Director, Georgia Alliance of Boys & Girls Clubs Corrective Action: Management will update subrecipient monitoring procedures to ensure compliance with subrecipient monitoring requirements and will continue to follow these enhanced policies to properly detect and prevent unallowable charges to the grant. Management will implement monitoring processes to ensure subrecipients submit sufficient documentation prior to disbursing funds. Anticipated Completion Date: October 1, 2023

Finding 2022-001 ? M. Subrecipient Monitoring Information on the federal program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No. / FAIN: 93.847 / R24DK106743 Views of responsible officials and planned corrective actions: During 2022, management has implemented a policy which addresses the 2 CFR section 200.332(b) requirements, including evaluating the results of previous audits obtained by its subrecipients including whether or not the subrecipient receives a single audit in accordance and the extent to which the same or similar subaward has been audited as a major program. Name of responsible official: Name ? Betty-Jane Sloan Title ? Clinical Research Manager Phone: 646-317-0701 Email: bjsloan@nyp.org Projected completion date: June 10, 2022

2022-012 ? Subrecipient Monitoring (Significant Deficiency) Governor?s Office care of State Department of Budget and Finance AL Number: 21.027 Program Title: Coronavirus State and Local Fiscal Recovery Fund Direct Award from: U.S. Department of Treasury Condition 2 CFR Section 200.332(b) requires a pass-through entity to evaluate each subrecipient?s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. The auditing firm selected a sample of 7 subawards active in FY 2022. The auditing firm noted that program management did not evaluate the subrecipient?s risk of noncompliance at the time of the subaward for one of the subawards tested. Current Status of Corrective Action Plan Concur. B&F will ensure that program personnel are familiar with federal program requirements, including compliance with 2 CFR Section 200.332(b) which requires an evaluation of each subrecipient?s risk of noncompliance with federal statutes, regulations, and the terms and conditions of the subaward. Person Responsible Mark K. Anderson, Office of Federal Awards Management, Administrator Anticipated Date of Completion July 1, 2023

2022-010 ? Subrecipient Monitoring (Significant Deficiency) Governor?s Office care of State Department of Budget and Finance AL Number: 21.026 Program Title: Homeowner Assistance Fund Direct Award from: U.S. Department of Treasury Condition 2 CFR Section 200.332(b) requires a pass-through entity to evaluate each subrecipient?s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring for the subaward. The auditing firm selected a sample of two subawards that were executed in FY 2022. The auditing firm noted that program management did not evaluate the subrecipient?s risk of noncompliance prior to the execution of the subawards. Current Status of Corrective Action Plan Concur. B&F will ensure that program personnel are familiar with Federal program requirements, including compliance with 2 CFR Section 200.332(b) which requires an evaluation of each subrecipient?s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward. Person Responsible Mark K. Anderson, Office of Federal Awards Management, Administrator Anticipated Date of Completion July 1, 2023

Finding No. 2022-007 ? Subrecipient Monitoring (Significant Deficiency) Governor?s Office care of State Department of Budget and Finance AL Number: 21.023 Program Title: Emergency Rental Assistance Program Direct Award from: U.S. Department of Treasury Condition 2 CFR Section 200.332(b) requires a pass-through entity to evaluate each subrecipient?s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. The auditing firm selected three subawards and noted untimely evaluation of the subrecipients? risk of noncompliance for two subawards. The auditing firm noted that one assessment was performed 2 days after a subaward was made, and for the second subaward, an assessment was performed 172 days after the subaward was made. Current Status of Corrective Action Plan Concur. B&F will ensure that program personnel are familiar with federal program requirements, including compliance with 2 CFR Section 200.331(b) which requires an evaluation of each subrecipient?s risk of noncompliance with federal statutes, regulations, and the terms and conditions of the subaward. Person Responsible Mark K. Anderson, Office of Federal Awards Management, Administrator Anticipated Date of Completion July 1, 2023

Recommendation: We recommend that the County review its procedures for communicating information to subrecipients and implement the procedures necessary to ensure information is included in the subrecipient award documents at time of funding and that appropriate monitoring is performed for each subrecipient. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The County will ensure that all subrecipients of American Rescue Plan (APRA) funds are monitored by using appropriate subrecipient monitoring procedures to ensure compliance with the grant awarded throughout the contract period. Name(s) of the contact person(s) responsible for corrective action: Sherri Crow, Interim Director of Budget and Finance Planned completion date for corrective action plan: January 1, 2024

Finding #2022-009: regarding subrecipient monitoring were not performed on the Health Equity Grant, Award# 11442, CFDA # 93.391 as required by CCH Policy and Federal Regulations. Cause: The cause of this finding resulted from subrecipients being identified as vendors in the Grant application. The Program Lead informed Finance late which did not allow sufficient time to mobilize CCH staff and/or external consultant to perform subrecipient monitoring. Correction Action: The CCH Director of Grant Accounting will engage an outside consultant to conduct subrecipient monitoring for the grant and collaboratively work to modify the established policy. Anticipated completion of the corrective action will be December 31, 2023.

Temporary Assistance for Needy Families (TANF) ? Assistance Listing No. 93.558 Recommendation: We recommend the County determine whether an entity receiving payment under TANF is a subrecipient or a contractor prior to entering into an agreement with the entity and to include all guidance under 2 CFR 200.331 when making this determination. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Prior to the finding we have been working to properly classify entities that receive TANF fund as subrecipients versus contractors. We will continue to implement a process to analyze the entities that are receiving payments through TANF and make sure that we properly determine them as a subrecipient or a contractor. Once the determination is made, we will work with Legal and enter into the correct agreement with the entity. We will also perform the required monitoring for the TANF subrecipients. Name of the contact persons responsible for corrective action: Eddie Valdez ? Deputy Director, Candace Cadena ? Executive Strategist, Nick Beston ? Accounting Manager. Planned completion date for corrective action plan: July 1, 2024

DPH agrees with the finding and recommendations. DPH will notify its subrecipients about their subawards and include any changes in subsequent subaward modifications. DHSP will strengthen its review processes to complete and include the Notice of Federal Subaward Information form as part of the contract copy at the time of the contract execution.

Corrective Action Plan: The Agency has recognized a need to provide training and technical assistance to State Agencies and Departments. The Agency has created Uniform Guidance trainings that began in February 2023 and continue in March. These trainings include reference materials such as desk references, job aids, etc. As a follow-up to the training, we will be developing and delivering a subrecipient monitoring framework which includes tools to facilitate subrecipient risk assessments, subrecipient monitoring plans based on the initial risk assessment, testing of transaction records, desk reviews of low-risk subrecipients, and corrective action plans. Finally, we will be working to provide oversight and monitoring for agency adherence to subrecipient monitoring procedures, informed by program-level compliance risk assessment. Scheduled Completion Date of Corrective Action Plan: Completed: February 16, 2023: Uniform Guidance Training (Part 1) Expected: March, 2023: Uniform Guidance Training (Part 2) Expected: July, 2023: Subrecipient Monitoring Framework Provided to Agencies & Departments Expected: December, 2023: Sampling completed by Agency Expected: February, 2024: Post-Sampling Follow-up with Agencies and Departments Contacts for Corrective Action Plan: Doug Farnham Deputy Secretary, Agency of Administration Douglas.Farnham@vermont.gov (802) 585-8119 Holly S. Anderson Chief Financial Officer, Agency of Administration ? Financial Services Division Holly.S.Anderson@vermont.gov (802) 505-1177

The Supervisor and Director of the CDBG program are now meeting weekly with the staff person assigned for review the Single Audits to understand the workload and assist in ensuring the backlog and the current audits are all reviewed in a timely manner. Additionally, going forward, the Agency is working to fund an agency-wide compliance officer to ensure impartial oversight of the agencies programs with regard to federal requirements (including single audit review), as well as avoiding taking the time of the CDBG program staff away from their duties. Scheduled Completion Date for Corrective Action Plan: Completed: Reviewed audits selected for testing September 30, 2023: Supervisor and Director have assisted in reviewing to ensure backlog brought current August 30, 2023: new position for Agency-wide compliance officer funded and position-filled Point of Contact: Ann Karlene Kroll, Federal Programs Director annkarlene.kroll@vermont.gov; (802) 828-5225.

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