Corrective Action Plans

Action taken in response to finding: The County will review the subrecipient monitoring requirements and work with the County Auditor to develop a formal policy that includes internal controls, monitoring procedures, and documentation requirements.

USAID Foreign Assistance for Programs Overseas – Assistance Listing No. 98.001 Recommendation: CLA recommends amending existing subaward agreements to include the award information required by CFR 200.332(b) and to verify all future subawards agreements include all necessary information prior to issuance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: SFP will revise its subaward agreement template to include all necessary award information as required by CFR 200.332(b). Name(s) of the contact person(s) responsible for corrective action: Annie Haylon Planned completion date for corrective action plan: October 31, 2025

The subgrantees in question were Boys & Girls Clubs of America, National Youth Service League, Young Men’s Service League, and Boise State. 9/11 Day researched all subgrantees, required each to provide MOUs, program details, and budgets, and verified organizational status using resources such as Candid and Charity Navigator. Financial statements were also reviewed, but documentation of these reviews and verifications was not consistently retained, and certain federal requirements were not fully incorporated into the process. 9/11 Day has now adopted a written policy that ensures that, in its role as a pass-through entity, all subgrants will be made in full compliance with the minimum required elements found under 2 CFR 200.332(b). This shall include implementing a comprehensive tracking and monitoring system for all subgrantees, regardless of funding level, with enhanced verification requirements for those receiving over $30,000. All subaward agreements will be updated to include the minimum required elements under 2 CFR 200.332(b), and the evaluation of subgrantee risk will incorporate all suggested elements under 2 CFR 200.332(c), including consideration of fraud risk and risk of noncompliance. The system will record the time and date of all eligibility verifications and retain supporting documentation, including MOUs, SAM.gov confirmation of suspension and debarment status, IRS Form 990s, financial statements, and audit confirmations. In compliance with 2 CFR 200.332(e)(1), subgrantees will now be required to submit both performance and financial reports, which will be reviewed and compared against project budgets. In addition, 9/11 Day will evaluate subgrantees’ Single Audits, if filed, in accordance with 2 CFR 200.332(e)(2)–(4) and will review any reported deficiencies. All monitoring activities will be documented and logged throughout the life of each project to ensure stronger oversight, complete documentation, and compliance with federal requirements.

Corrective Action Plan – Hamilton County Economic Development Corporation (dba Invest Hamilton County) Public Accounting Firm CliftonLarsonAllen LLP Audit Period Year ended December 31, 2024 The finding from the December 31, 2024 consolidated schedule of findings is discussed below. The findings is numbered consistently with the numbers assigned in the schedule. Section III 2024-001: Condition: The Organization did not clearly communicate the required federal award information and applicable requirements to the subrecipients. The Organization did not evaluate the risk of non-compliance of the subrecipients in order to identify the appropriate monitoring procedures. Statistical sampling was not used in making sample selections. Response: The response to this finding in 2023 was provided less than one month prior to the end of the grant activity period, and therefore adaptation to the management period was not feasible for this project. The Organizations’ Board and Chief Executive OMicer (CEO) and key HCEDC StaM recognize the need to further refine subrecipient monitoring. Subrecipients within the identified project are all school districts already under single audit with associated levels of financial controls and reporting. Participating districts, via their appropriate elected boards, were informed the conditions of the grant and individually voted to accept obligations and requirements. HCEDC management, in alignment with outsourced controller services via CliftonLarsonAllen LLP, have now further increased controls and monitoring activity. Through the onboarding of a new Grants Management System (GMS) in Fall 2024, subrecipient monitoring activity and profiles are now created for each eligible award. In 2024 and 2025, the HCEDC has also been much more active in communicating reporting and grants management requirements to subrecipients, including multiple amendments to the ESSER grant program. The new GMS system is built specifically to assist organizations with single audit compliance and has multiple features specific to subrecipient reporting and monitoring. If there are any questions regarding this plan, please contact the undersigned at 317-663-4457. Mike Thibideau PRESIDENT & CEO – INVEST HAMILTON COUNTY 37 East Main Street Carmel, IN 46032

WRTP has reviewed the organization’s fiscal policy manual including all subsections regarding monitoring responsibilities. Additional training has been provided and completed by management and staff. Management has reviewed all monitoring with the subrecipient in good faith efforts.

B. Corrective action steps taken and/or planned: ACHD will maintain lists of subrecipients used and checklists to help ensure that monitoring activities are performed for each. Also working on establishing a process to incorporate language into our contracts. In addition, ACHD will complete and file out of compliance sub recipient forms per the timetable noted in Section D below. C. Timetable of dates for performance of planned corrective action steps including completion date: Slated to begin new process August 1, 2025 for new contracts and/or contract renewals. Once process has been finalized, ACHD Fiscal will also review past agreements that are still in effect. D. Description of monitoring to be performed to ensure corrective action steps are taken: ACHD Financial Manager and Grants Manager will ensure lists and monitoring activities are maintained.

ACHD will maintain lists of subrecipients used and checklists to help ensure that monitoring activities are performed for each. Also working on establishing a process to incorporate language into our contracts. In addition, ACHD will complete and file out of compliance sub recipient forms per the timetable noted in Section D below. D. Description of monitoring to be performed to ensure corrective action steps are taken: ACHD Financial Manager and Grants Manager will ensure lists and monitoring activities are maintained.

Management will develop and implement formal procedures for subrecipient monitoring that include retention of single audit and compliance audit reports of subrecipients and regular communications to monitor progress and compliance with program objectives.

2024-002 Conservation Research and Development Program – Assistance Listing #81.086 Recommendation: The Organization should establish written policies and procedures regarding the contracting and monitoring of subrecipients that are in line with Uniform Guidance requirements, as well as establish organizational controls to ensure that such policies and procedures are being followed. Explanation of disagreement with audit findings: There is no disagreement with the audit findings. Action Plan: Effective October 31, 2024, we established procedures for monitoring subrecipients, which include obtaining and reviewing their annual audits. This procedure, implemented late in 2024, remains in practice to date. In 2025, we will strengthen these procedures by: ● Establishing a monitoring plan for each subrecipient based on their assessed level of risk. ● Instituting procedures for formally documenting all monitoring activities. ● Completing risk assessments for past subrecipients to ensure comprehensive oversight. Name(s) of the contact people responsible for correction action: Gina Avalos-Limardo, Director of Finance & Operations and Cho Heide, Contracts & Compliance Manager Plan completion date for corrective action plan: November 30, 2025

Finding 2024-0002 Subrecipient Monitoring CDOT Subrecipient Monitoring was lacking documentation. Corrective Action: ECCOG Executive Director and/or Senior & Transit Services Director will implement a formal monitoring protocol for future contracts as there are no subrecipient contracts at this time. The former subrecipients now have their own CDOT contract for funding. The protocol/procedures may be added to the Grant Management Policy using the CDOT guidance received. Person Responsible for Implementation: Executive Director Implementation Date: Sept 18, 2025. Corrective Action Plan approved by ECCOG’s Board of Directors September 18, 2025

2024-001: Subrecipient Monitoring – Low Income Energy Assistance Program Name of Contact Person: Bobbie Crooker, Director of Energy and Housing Management’s Views and Corrective Action Plan: The Department of Energy and Housing Services (EHS) at MaineHousing agrees that not all subrecipients had the required annual quality assurance reviews performed within the specified timeframe. Additionally, it agrees that all monitoring reviews were not formally documented. This issue occurred due to staff turnover within the LIHEAP Team, within the Fiscal Team, and within the EHS Department overall, as well as due to an insufficient monitoring process. EHS is in the process of developing and implementing a department wide Monitoring group with representation from all Teams in the department. As part of this, the Monitoring group is developing a regular schedule to visit the Community Action Agencies (CAAs) each year based on the established schedule. At the conclusion of each review, a consolidated report with an overall summary will be completed for each CAA. This new process will ensure that all CAAs are monitored by all program teams as well as the fiscal team each year and that all monitoring visits are documented appropriately. In addition to this, EHS has hired a Quality Control Specialist to review all monitoring reports, and program processes to ensure that each Team is monitoring to the applicable programmatic requirements annually. The monitoring group will be fully implemented by January 2026. Proposed Completion Date: January 2026

Finding 2024-001: Subrecipient Monitoring Federal Agency: U.S. Department of Housing and Urban Development Frogram Name: COVID 19 — HOME Investment Partnerships Program and HOME Investment Partnerships Program (HOME) - ALN 14.239; Award Identification Number: MC420501 Criteria of Specific Requirement: Per 2 CFR 200.332, a pass-through entity must monitor the activities of subrecipients 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. Condition: During our testing of subrecipient monitoring, we noted that the City did not perform required monitoring procedures during the year. Questioned Costs: Unknown Cause: The City did not have adequate internal controls in place to ensure compliance with subrecipient monitoring requirements, and staffing turnover contributed to the lack of oversight. Effect: The City was not in compliance with subrecipient monitoring requirements. Identification as a Repeat Finding: This is not a repeat finding from the prior audit. Recommendation: We recommend the City implement controls to ensure compliance with subrecipient monitoring, documenting monitoring activities performed and following up on any identified deficiencies in a timely manner. Views of Responsible Officials and Planned Corrective Actions: Management agrees; see corrective action plan below. History The City initiated monitoring of the HOME program in March 2023, and the local office of the Department of Housing and Urban Development (HUD) initiated its own monitoring in June 2023. To avoid duplicative work, the City shifted its approach and reviewed closed programs while HUD monitored open programs. These monitoring efforts resulted in significant updates to program policies and procedures. The City's monitoring was completed in October 2023 and HUD's monitoring was finalized in October 2024. Correction Action Plan Since October 2024, the City has collaborated with its subrecipient, the Urban Redevelopment Authority (URA), to implement a streamlined, informal quarterly review process. While formal HOME monitoring has not occurred since the end of the HUD monitoring, the City will initiate a review before the end of 2025 to return to compliance. Monitoring will occur annually moving forward.

Management agrees with the finding. Management has downloaded 2 CFP Part 200 for review and to familiarize. Assistance has been requested to develop additional policies in accordance with the Uniform Guidance. Policies will be reviewed and approved by the Board regularly. Contact Person: Renee LaFleur, Executive Director Anticipated Date of Completion: December 31, 2025

August 15, 2025 United States Department of Agriculture National Institute of Food and Agriculture Awards Management Division 805 Pennsylvania Ave Kansas City, MO 64105 Attention: Federal Audit Clearinghouse (FAC) Subject: Corrective Action Plan Submission – Finding #4 – Sovereign Equity Fund – Fiscal Year End 12/31/2024 To Whom It May Concern: Subrecipient Monitoring - Subrecipient agreements lacked required federal clauses and were not monitored according to risk assessments. Corrective Actions: • Develop a subrecipient monitoring policy aligned with 2 CFR §200.331-333. • Standardize agreement templates to include all required clauses for federal award subrecipient agreements (e.g., audit requirements, FFATA, termination provisions). • Implement a subrecipient risk assessment tool to determine monitoring frequency and risk level identification. • Assign staff for annual subrecipient desk reviews or site visits based on risk levels. Responsible Party: Executive Director / Legal & Compliance Team Target Completion Date: Risk assessment and financial monitoring tool in use and agreement templates updated within 45 days. Sincerely, Courtney Chavis Executive Director

FINDING 2024-003 Finding Subject: COVID 19 Coronavirus State and Local Fiscal Recovery - Subrecipient Monitoring Contact Person Responsible for Corrective Action: Gretchen Parker Contact Phone Number and Email Address: 765-648-6113 gparker@cityofanderson.com Views of Responsible Officials: "We concur with the finding." Description of Corrective Action Plan: The city has several individuals involved in the monitoring of activities related to the COVID 19 Coronavirus State and Local Fiscal Recovery federal award. The city has implemented procedures to ensure oversight and review of subrecipient reports is properly documented. Anticipated Completion Date: September 1, 2025

To address this finding, AACC will adhere to the financial policies and procedures properly documenting the fraud risk assessments to determine the level of risk (Low, Medium, High), and will properly document all necessary monitoring procedures (Financial Policies and Procedures, pages 45-53). Additionally, AACC has developed a risk assessment policy that will accompany AACC’s Subrecipient Award and Monitoring Policy developed in 2021. The appropriate signatures and corrective action plans and follow up with be managed in a timely manner.

Finding 2024-004: Subrecipient Monitoring U.S. Department of Commerce, Economic Development Cluster- Assistance Listing Number 11.307 Questioned Costs: Unknown Condition: The Organization does not have formal subrecipient monitoring policies and procedures in place to document the assessment of risk for subrecipients. Specifically, there is no documented review of subrecipient financial or performance reports, no formal risk assessments conducted prior to disbursement of funds, and no site visits or other monitoring activities to ensure compliance with award terms and federal regulations. In addition, the Organization does not have procedures in place to adequately review the subrecipient audits received, ensure that audit requirement language is included in each contract, or notify the subrecipient of the subaward ALN and amount that was paid during the year. Action: InnovatePGH will implement monitoring procedures for subrecipients, including risk assessment, site visits as deemed appropriate, and review of reporting and audits.

FINDING – FINANCIAL STATEMENT 2024-001 Financial Statement Recommendation: We recommend that the Organization implement the necessary internal controls to ensure that accruals are properly recorded and the associated expenses and revenues are recorded in the proper period. Explanation of disagreement with audit findings: Management concurs with the finding and will implement effective internal controls to ensure that financial information is reported in accordance with GAAP. Action Plan: The Finance & Administration Director has updated the Accounting protocol guide and Grants Internal Control guide instructing staff how to identify accrual expense invoices. These policies establish procedures for recording accrual expense invoices to ensure that all expenses are properly recognized in the correct accounting period in accordance with Generally Accepted Accounting Principles (GAAP). This policy applies to all accounting and grant management staff responsible for processing and recording expense transactions, including accounts payable, month-end closing and journal entries, and other financial reporting activities. In addition, on Sept. 11, 2025, a training program was developed and administered to accounting staff to ensure they understand this policy. The Finance & Administration Director will conduct quarterly internal reconciliations and reviews to audit compliance and identify areas of error. This process is tracked in the Asana project management tool. The Finance Director will review all invoices for appropriate invoice dates so that accrued expenses will be posted to the correct period. And lastly, the Grants Finance Manager and Finance & Administration Director will review journal entries, financial statements, and key estimates (such as allowances for doubtful accounts or depreciation methods) further ensure accuracy. Name(s) of the contact people responsible for correction action: Renee Kempka, Finance & Administration Director U.S. Department of Agriculture 2024-002 Assistance Lising #10.163 – Market Protection Program Recommendation: The Organization should establish written policies and procedures regarding the contracting and monitoring of subrecipients that are in line with Uniform Guidance requirements, as well as establish organizational controls to ensure that such policies and procedures are being followed. Explanation of disagreement with audit findings: Management concurs with the finding and will implement effective internal controls to ensure that subrecipient monitoring is properly done and documented appropriately. Action taken in response to finding: Upon discovery of the initial audit finding, an accrual journal entry was created to correct the subrecipient invoicing between 2025 and 2024. The adjusting journal entries and updated financial statements were submitted to Kern & Thompson, who we engaged to conduct the financial audits. This altered previous financial statements for 2024 and 2025, and the SEFA. Action Plan: The late reporting was primarily due to delays in receiving invoices from the subrecipient after the fiscal year end closing. The Education and Advocacy Director will send out quarterly reminders to partners informing them of the invoice due dates. Subrecipient partners will be expected to submit the invoice within the allotted time of 30 days after the closing of the reporting period. The Grant Finance Manger will conduct a review of all active subrecipient partners to ensure invoices have been received and recorded in the corresponding fiscal period for which the activity was conducted. If the invoice is not received, a courtesy reminder email and/or phone call will be sent to let the partner know that if the invoice is received outside of the 30 days, it will no longer be allowable. 21 days after the close of a quarter, the Finance Director and the Grants Finance Manager will meet and audit the sub-recipient budget against what has been submitted for payables. A list of partners who have not submitted invoices will be created with subsequent intent to contact the organization. This task will be tracked for completion according to timelines in the Grant Internal Control Asana project. Name(s) of the contact people responsible for correction action: Abigail Soto, Grants Finance Manager, Ben Bowell, Education & Advocacy Director and Renee Kempka, Finance & Administration Director Plan completion date for corrective action plan: 09/11/25

FFT will monitor its subcontractor for compliance in the future.

Finding Number 2024-001 Contact Person(s): Kim Goodman, Finance Director Corrective action planned: The Association acknowledges the audit findings and recognizes the importance of strengthing internal control processes to ensure staff understand the nature of a subrecipient vs a contractor, and that they ensure that this determination is being reviewed, and clearly communicated in underlying agreements, as part of their internal control processes. The following corrective actions have been taken: • All 23-25 AJA Grantees will be provided agreements with the correct designation of "sub recipient." • All 25-27 AJA and MHFR Grantees will have the designation of "sub recipient." Anticipated completion date: Completed June 30, 2025

System of Internal Controls Over Compliance: Subrecipient Monitoring; U.S. Department of Treasury, Assistance Listing #21.027, Coronavirus State and Local Fiscal Recovery Funds, Passed Through State of Nevada Criteria: In accordance with 2 CFR 200.332, the auditee must maintain a system of internal control over compliance to ensure they provide each subrecipient within the required appropriate document the performance of internal controls over the compliance for subrecipient monitoring. Condition: The Organization did not appropriately implement internal controls necessary to ensure appropriate documentation was available to support the performance of controls in compliance with 2 CFR 200.332. Context: The Organization did not identify funds being passed through from one subsidiary of the Organization to a second subsidiary in a timely manner and based on this timing did not appropriately document the performance of internal controls over the compliance of subrecipient monitoring. Cause: The Organization did not identify its only subrecipient for this award in a timely manner. Effect: The Organization was not able to properly document its performance of internal controls over most of the requirements outlined in 2 CFR 200.332 for the award based on untimely identification of its subrecipient. Recommendation: We recommend management design and implement a system of internal controls over compliance where consideration of possible subrecipients is considered when the award is being applied for and that well documented and supportable internal controls over subrecipient monitoring are implemented when there are subrecipients identified under an award. Views of Responsible Officials and Planned Corrective Actions: SJRC NV Region is addressing its missing controls related to the requirements of 2 CFR 200.332. We acknowledge that SJRC must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the information required under 2 CFR 200.332 at the time of the subaward all requirements. This includes that every subaward is clearly identified to the subrecipient as a subaward and includes at the time of the subaward and if any data elements change, that there must be an approved subaward modification. We will also ensure we meet the requirements under 2 CFR 200.332 to include our obligations to risk assess and monitor any subrecipients. The timeframe for correction is immediate and full accounting system control improvements will be implemented as part of our 2025 fiscal year-end close. Submitted by: Dr. Christina Vela, DPP Chief Executive Officer St. Jude's Ranch for Children, Inc. and its subsidiaries cvela@stjudesranch.org

The County concurs with this finding and will be working to enhance internal controls over the adherence to our policies and procedures in accordance with 2 CFR 200.332 to ensure compliance with subrecipient monitoring requirements.

New policy was to be implemented by August 31, 2025 that will include written agreements with subaward programs and the Grants Manager will monitor the plan, with additional monitoring to be completed by the Exective Director periodically.

Management agrees with the finding and is implementing the accompanying corrective action plan. Views of Responsible Officials: Jacy Hyde, Executive Director Joel Rusco, Chief Financial and Administrative Officer Jessica Martinez, Deputy Director Contact Person: Joel Rusco, Chief Financial and Administrative Officer Jessica Martinez, Deputy Director Corrective Action Plan: In response to FY21 Corrective Action Plan, CFSC implemented an updated Subrecipient Monitoring Policy in June 2024 to ensure compliance with Uniform Guidance, including subrecipient risk assessment and audit review requirements. To further strengthen compliance and eliminate inconsistencies in subrecipient risk assessments, CFSC will implement the following corrective actions: 1. Mandatory Pre‐Award Risk Assessment & Documentation: a. The Grants Manager will ensure that a Subrecipient Risk Assessment Form is completed and documented for all subawards before execution. b. Risk assessment findings will be stored in the subrecipients grant file and reviewed during routine monitoring. c. Any subrecipients classified as high risk will be subject to enhanced monitoring procedures to be carried out by the assigned Grant Specialist, which may include additional financial oversight and/or more frequent reporting. 2. Systematic Audit review & compliance tracking: a. The Grants Manager will be responsible for ensuring timely collection and review of subrecipient audit reports. 3. Quarterly Compliance Audits of Risks Assessments & Audit Reviews: a. The Grants Manager will conduct quarterly internal audits to confirm: i. All subrecipients have undergone documented risk assessments before receiving funds. ii. All subrecipient audits have been collected, reviewed, and properly documented. iii. Any identified audit findings have been addressed with documented corrective actions. Anticipated Completion Date: Corrective actions regarding mandatory pre‐award risk assessment & documentation (item 1) and systematic audit review &compliance tracking (item 2) have been fully implemented as of quarter 2 of FY25. CFSC has begun to implement the quarterly compliance audits (item 3) and will have this fully implemented by the end of FY25.

2024-001: Internal Control Over Compliance with Subrecipient Monitoring and Noncompliance with Subrecipient Monitoring U.S. Department of Health and Human Services; Passed through the State of Tennessee Department of Health: ALN #93.558 Temporary Assistance for Needy Families Management’s Response: We concur. View of Responsible Officials and Corrective Action: United Way has an Agency Eligibility Review (AER) to ensure an organization is financially sound prior to awarding funding. As part of this process, subrecipients are required to provide their most recent From 990, as well as audited or reviewed financial statements, based on their gross revenue. United Way utilizes the AER as part of subrecipient application process government grants awarded to United Way. Historically, the majority of the government grants awarded to United Way have been for a 12-month period. However, the Temporary Assistance for Needy Families grant represents the first multi-year grant received by United Way from the State. Due to the multi-year nature of this award, United Way initially obtained financial records only after subrecipients entered the program. Going forward, we will review our processes to ensure financial records are collected and reviewed in a timely manner for all multi-year grants. The Senior Director of Innovation & Strategy and the Senior Director of Finance will obtain and review the most recent audited financial statements for the subrecipients. Supporting documentation will be maintained with the grant activity to ensure proper compliance documentation is kept. Name(s) of the Contact Person(s) Responsible for Corrective Action: Rod DeVore and Matt Lim Anticipated Completion Date: September 30, 2025