Corrective Action Plans

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

Finding No.: 2019-012 Federal Agency: U.S. Department of Health and Human Services CFDA Program: 93.243 Substance Abuse and Mental Health Services Projects of Regional and National Significance Award Number: 5U79SP020710-04 Area: Subrecipient Monitoring Questioned Costs: $468,864 Contact Persons: Perlie Santos, Chief Financial Officer; Reyna Saures, CGC Director; Vincent Camacho, Grants Administrator. Corrective Action: Condition 1 CHCC does not concur with the findings and the $353,864 questioned costs. Pursuant to the terms and conditions of the sub-award agreement, before any subsequent disbursements to the Subgrantee, invoices and receipt and progress reports from the prior disbursements were submitted to the Project Director for review and approval. No subsequent disbursements were issued without compliance to these requirements Condition 2 CHCC does not concur with the findings and the $115,000 questioned costs. The Announcement for the funding availability was published in the local newspaper. 2019-012 Condition 2.pdf Condition 3 CHCC does not concur with the findings and the $25,000 questioned costs. The selected transaction was voided (document type PE); hence no supporting documents were provided. Finding No.: 2019-012, Continued This 2nd disbursement was subsequently processed on July 29, 2019 (PV1456803), when all the required documentation pursuant to the sub-award agreement were complied with. Proposed Completion Date: Not applicable as CHCC does not concur with the findings.

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