Corrective Action Plans

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

Responsible Contact Person(s): Jennifer Cooper, Associate Director Senior Diana Clark, Compliance Coordinator Corrective Action Planned: Coordinator reviews the completed audit documents to ensure that all required audit documents are uploaded to the website based collaboration system timely and that reviews are conducted in accordance with the SRM Plan. A SRM monitoring desk tool will be created for Practice Consultants as a quick reference to the SRM Plan. Training for all Program Consultants conducting SRM will be provided on the new updated monitoring plan as well as ongoing training for newly hired Program Consultants. Estimated Completion Date: 6/30/2023

2022-002 STRIVING READERS COMPREHENSIVE LITERACY/COMPREHENSIVE LITERACY STATE DEVELOPMENT ? SUBRECIPIENT MONITORING ? NONCOMPLIANCE WITH SUBRECIPIENT GRANT AGREEMENT REQUIREMENTS ? ALN 84.371 ? MATERIAL WEAKNESS AND MATERIAL NONCOMPLIANCE Condition: Devils Lake Public School District did not prepare subrecipient grant agreements that included the elements as outlined in 2 CFR 200.332(a) for the Striving Readers Comprehensive Literacy/Comprehensive Literacy State Development programs. In addition, Devils Lake Public School District did not have procedures in place to ensure subrecipient grant agreements were prepared for all subrecipients and included all the required elements. Corrective Action Plan: We agree, Devils Lake Public School will make sure to sit down with any subrecipients and review all the requirements of the grant for their particular allocation. Anticipated Completion Date: We will start implementation on 7/1/2023 and continue with this moving forward.

Panthera has now adopted the implementation of the Federal Assistance Listing Numbers on each agreement with subrecipients, and will ensure a formal approval is issued on all expenditure reports.

Finding Reference Number: SA2022-006 - Subrecipient Monitoring Assistance Listing Number: 21.027 Assistance Listing Title: COVID-19 ? Coronavirus State and Local Fiscal Recovery Funds Name of Federal Agency: Department of the Treasury Federal Award Identification Number: EES4XJFTXC28 ? Name(s) of the contact person: Karen Chang, Finance Director ? Corrective Action Plan: City will incorporate this information in our grant policy to ensure the program staff is aware of this requirement. ? Anticipated Completion Date: July 1, 2023

EXECUTIVE OFFICE OF LABOR AND WORKFORCE DEVELOPMENT 2022-013 WIOA Cluster ? Assistance Listing No. 17.258, 17.259, 17.278 Action taken in response to the finding: Beginning with fiscal year 2023, MHDCS has revised all Financial/Fiscal related documentation (i.e., Budget Sheets, Contracts) for sub- awardees to include the FAIN identifier as recommended through this finding. Further, MDCS has revised and enhanced its internal controls processes for scheduling, notification, and reporting of subrecipient monitoring by including an additional senior level signoff to confirm that all related documentation, required information including annual reviews, has been stored in a designated backup SharePoint data file beginning with Fiscal year 2023. Name of the contact person responsible for corrective action: Michael Williams, Director of Monitoring and Oversight, MHDCS Planned completion date for corrective action plan: December 2022

Office of State Treasurer Finding: 2022-036 Office of State Treasurer Response/Corrective Action Plan: The Office of State Treasurer does agree with finding that we were not in compliance with federal regulations related to providing required information to subrecipients of Coronavirus Relief Funds (CRF). Corrective action planned: 1. The Office of State Treasurer will work with ND Office of Management and Budget (OMB) to communicate to subrecipients timely and create a template for future use that includes the required information that was missed as detailed on the schedule of federal findings and questions costs. 2. The Office of State Treasurer has discussed with OMB that the information will not be recommunicated to the subrecipients as OMB has been in contact with subrecipients in guiding them to necessary information and assisting with any needs. It has been determined that communicating the information retroactively would cause more confusion and issues among the subrecipients. Contact Person: Nicole Krivoruchka Director of Finance Anticipated Completion Date September 3, 2023

Ref. No. Internal Control Findings 2022-001 Improve Controls over Recording of Non-routine Transactions - Material Weakness Recommendation County management should ensure that estimates are developed more timely to ensure proper recording in the County?s financial statements. View of Responsible Officials and Planned Corrective Action Management concurs with this audit finding. The Department of Finance will develop specific processes to ensure necessary estimates are developed and corresponding entries are booked in a timely manner for new occurrences (transient accommodations tax) or unusual events (bargaining unit grievances due to COVID-19). Additionally, the Department of Finance will work with the Department of Corporation Counsel to ensure that any potential liabilities regarding personnel matters are monitored and tracked on an ongoing basis. End Date: Ongoing Responding Person(s): Marci Sato, Accounting System Administrator Department of Finance Phone No. (808) 270-7503

Finding 2022-001 ? Subrecipient Monitoring Cluster: Research and Development Agency: Department of Commerce and Department of Health and Human Services Award Names: Standards/Guidance for Rapid Qualification of Metal-Based Additive Manufacturing and Development and Testing a Field-based Hazard/Near-Miss Sharing System for Commercial Fishing Vessels Award Numbers: 70NANB21H038 and U01OH012288 Assistance Listing Title: Measurement and Engineering Research and Standards and Occupational Safety and Health Program Assistance Listing Number: 11.609 and 93.262 Award Year: FY 2022 To ensure American Bureau of Shipping (ABS) is in compliance with 2 CFR 200.332(d) and 2 CFR 200.332(f), ABS will obtain and review annual Uniform Guidance reports or annual audited financial statements (if the entity was not subject to a Uniform Guidance audit) of all subrecipients. ABS has revised its Contracted Research and Development Process Instruction for subrecipient monitoring. The process instruction is supplemented by a subrecipient monitoring form and check sheet. The annual subrecipient monitoring form and check sheet outline the necessary steps to document and interpret the review of Uniform Guidance reports or financial reports. The annual review will be completed within two months of the grant date anniversary. The contracts administrator and project manager will provide two-step verification by reviewing, dating, and signing both the subrecipient monitoring form and check sheet to document their understanding of the type of opinion(s) expressed, findings associated with their awards, document their review, and assess whether there is any change in the initial risk assessment and subsequent monitoring need of each subrecipient. The annual reviews commenced in July 2023.

DEPARTMENT OF ELEMENTARY AND SECONDARY EDUCATION 2022-004 Child and Adult Care Food Program ? Assistance Listing No. 10.558 Action taken in response to the finding: The Office for Food and Nutrition Programs (FNP) has moved from a paper based permanent agreement to a web form that exists on the DESE Security Portal. All existing and new Child Nutrition Sponsors will continue to sign off on the document via the web-based portal allowing for a more efficient collection and document retention process. The identified sponsors with missing permanent agreements for the time period selected now have signed permanent agreements via the web-based form. FNP will add the applicable FAIN numbers to the Financial Management portion of FNP?s public website. FNP will review and update these numbers annually as applicable. FNP, in conjunction with DESE?s Federal Accounting Unit, have embarked on a process to provide all Child Nutrition sponsors instructions and collect information related to UEIs. FNP will continue the process and outreach until all UEIs have been collected. Name of the contact person responsible for corrective action: Robert Leshin, Director of Nutrition, Jeffrey Benbenek, Director of Audit & Compliance Planned completion date for corrective action plan: July 1, 2023

Children First Fund: The Chicago Public Schools Foundation State Single Audit Corrective Action Plan For the Fiscal Year Ended 2022 AUDIT FINDINGS Finding Reference Number: 2022-001 Description of Finding: CFF did not communicate the required information to subrecipients noted in the criteria including the communication of what funding represented federal funding and was subject to the related grant requirements. Statement of Concurrence or Nonconcurrence: The organization agrees with the finding and will implement corrective action when applicable. Corrective Action: The Chicago Connected initiative was supported by various external partners, including government and philanthropic funders. As the fiscal sponsor, the Children First Fund executed service agreements with each participating community-based organization (CBO), that noted the amount they were awarded. As deliverables were met, CFF made payments based on when the funds came in since they were not designated to a particular CBO by funder. As a result, CFF did not notify CBOs which payments came from federal vs philanthropic funding. Understanding that this is required when it comes to distributing federal funds to subrecipients, CFF will ensure that it's internal controls are updated to include this moving forward. Name of Contact Person: Yemisi Odedina, Managing Director of Finance & Operations E: yodedina@childrenfirstfund.org P: (312) 883-4977 Projected Completion Date: By the end of the calendar year of 2023, the organization will ensure that it?s internal controls are updated to include the federal uniform guidance standards that applies to federal awards to ensure future awards are managed per those guidelines.

Significant deficiency in internal controls over compliance and instances of noncompliance related to subrecipient monitoring. Contact Person(s): Beth Mizushima, Chief Operating Officer, mizushimab@crhn.org; and Connie Sowa, Compliance, Governance and Contracts Officer, sowac@crhn.org. Explanation and specific reasons for disagreement with the audit finding or that corrective action is not required (if applicable): Not applicable. Corrective action planned: In FY23 we have established a Compliance, Governance and Contracts Officer staff position (1.0 FTE) that provides compliance support. We have also developed and implemented training around our Ethics and Compliance Manual, which includes 14 new policies and procedures related to ensuring subrecipient compliance standards are met for all grant awards. Since July 1, 2023, we have completed assessments for the risk of noncompliance with all partner agencies before executing contracts. In FY23 we have also amended contracts to be on a reimbursement for allowable expenditures structure rather than fixed amount. We believe that the former leadership team who established the fixed fee award may have misinterpreted the guidance around providing flexibility to reduce burden for financial assistance during COVID response. Furthermore, it is our belief that the former program officer and staff discussed the details of their work and contracts, but we cannot find documentation of receiving prior approval. To address this issue, we have amended contracts in FY23 to include specific contract wording requiring prior approval to implement a fixed fee contract. Additionally, we are in the process of implementing a contract and portal partners management platform. The new contract management system and the improvements in compliance process will ensure that we adhere to the provisions as outlined in 2 CFR200.332. Anticipated completed process September 30, 2023

The South Carolina Department of Social Services respectfully submits the following corrective action plan for the year ended June 30, 2022. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS?FEDERAL AWARD PROGRAM AUDIT U. S. Department of Agriculture 2022-013 Child and Adult Care Food Program ? Assistance Listing: 10.558 Recommendation: We recommend that the Department follow its established policies and procedures for the program to ensure compliance with federal subrecipient monitoring requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The three-year time frame in which these monitoring reviews were to have occurred included the peak months of the Coronavirus pandemic, when Department staff were working remotely for an extended period and many provider facilities were closed or operating sporadically due to staffing shortages. A significant number of program staff also left the agency during that time. These factors made timely monitoring much more difficult and extended the time required to complete it. The program maintains a worksheet designed to track compliance with this monitoring requirement and reviews, updates and acts upon it monthly. All monitoring reviews are now being conducted within the required time-frame. DSS also has an active project in progress to automate its compliance monitoring processes, and management plans to include a dashboard that displays the detailed status of each provider?s review, from start to completion. It will also report statistics showing the progress toward meeting the required yearly reviews. Management expects to have these system controls in place by December 2023. In the meantime, program staff will maintain the manual monitoring controls now in place to assure compliance. Name(s) of the contact person(s) responsible for corrective action: Mary Abney-Young, Early Care and Education Program Manager Planned completion date for corrective action plan: December 31, 2023

2022-004 - Sub-recipient Agreements: Non-Compliance Auditor Recommendation: Recommend that the City review 2 CFR Part 200 to ensure information required in sub-recipient agreements is properly included. Management's Response: Agree with the finding. Corrective Action Taken: The City will review 2 CFR Part 200 to ensure the assistance listing number of the grant funding being passed through, and the indication that the sub-recipient would be subject to single audit requirements set forth in 2 CFR Part 200, Sub-part F (Uniform Guidance). This Corrective Action will be completed no later than the subsequent quarterly report due date of April 30, 2023.

2022-003 - Sub-recipient Agreements: Significant Deficiency Auditor Recommendation: Recommend that the City review 2 ? CFR Part 200 to ensure information required in sub-recipient agreements is properly included. Management's Response: Agree with the finding. Corrective Action Taken: The City will review 2 CFR Part 200 to ensure the assistance listing number of the grant funding being passed through, and the indication that the sub-recipient would be subject to single audit requirements set forth in 2 CFR Part 200, Sub-part F (Uniform Guidance). This Corrective Action will be completed no later than the subsequent quarterly report due date of April 30, 2023.

New Directions DHS is exploring different possibilities to satisfy the audit finding to include the contracting of a certified public accounting firm to assist in conducting the financial portion of our subrecipient monitoring. Alternatives to Abortion Office of Policy Development (OPD) initiated numerous conversations with the Alternatives to Abortion grantee regarding receiving the requested documentation for monitoring (communication occurred regularly from April 2021 through January 2023). The grantee disagrees that the disclosure of this information is a requirement of the grant agreement and as such has not provided the documentation needed to complete the monitoring. On October 27, 2022, DHS sent a letter to the grantee outlining specific action steps to establish compliance with their grant agreement. The grantee responded on November 28, 2022, disputing the claims of DHS and asserting that they are not out of compliance with their grant agreement. OPD will be scheduling time to visit the grantee to review documents required by the terms of their grant agreement in order to complete the monitoring. Monitoring will occur by June 30, 2023. Anticipated Completion Date: New Directions- 03/01/2024; Alternatives to Abortion- 06/30/2023 Contact Person and Title: New Directions- Joel O?Donnell, Director, Bureau of Program Support, OIM; Alternatives to Abortion- Ana Arcs, Acting Policy Director, OPD

DHS: The Office of Children, Youth, and Families (OCYF) is sending out a Restrictions and Requirements document with each tentative and final allocation letter. This document lists all OCYF?s grants, the federal agency granting the fund and where to find the rules and regulations guiding the usage of the funds. For the State fiscal year 2021-2022, Tentative Allocation Letters were sent out on April 1, 2021, with Federal Award Identification Numbers (FAIN) and funding amounts. Final Allocation Letters were sent out August 12, 2021, with the Amount, FAIN and Name. OCYF has a risk assessment process in place for Title IV-E and TANF awards. During the Quality Assurance reviews, which occur twice a year at a minimum, OCYF reviews a sample of Title IV-E eligible foster care cases, Title IV-E ineligible foster care cases, Title IV-E eligible adoption assistance cases, and TANF eligible cases. Depending on the number of eligibility and claiming errors identified during the review, OCYF schedules more frequent visits as the risk of repeated and continued errors in these County Children and Youth Agencies (CCYAs) is higher. Inaccurate eligibility determinations lead to inaccurate federal claiming, so basing the review schedule on a CCYA?s eligibility review outcome allows OCYF to target those CCYAs where inaccurate claiming is a higher risk. However, to further address this finding, the risk assessment now includes documentation. Anticipated Completion Date: Completed Contact Person and Title: TinaMarie Petrovitz, Director of County Support DOH: The Department plans to develop and implement a robust subrecipient monitoring program which includes establishing a new section within the Budget Office pending enacted budget funds and complement to support the creation of the section. Initiative goals/milestones include: - Assessment: Comprehensive assessment of all current federal grants and subawards and their processes. This assessment will document best practices and identify gaps within the agency?s processes. It will also provide an evaluation of current operational and technological resources that can be leveraged to facilitate compliance. Target start date: February 27, 2023. Target completion date: June 30, 2023. - Educate Department: Budget Office is developing a bulletin that will outline the subrecipient monitoring requirements with links to State and Federal Sources. The bulletin will be shared with all program office staff. The Budget Office will develop the following templates and provide to all program offices: - Determination of vendor status: Subrecipient or Contractor - Risk Assessment Form - Internal Control Self-Assessment for Subrecipient Template - Subrecipient Monitoring Template All materials will be updated with any additional information gained during the assessment. Start date: February 3, 2023. Target Completion Date: June 30, 2023 - Implementation of full compliance initiative: Recommendations provided in the assessment will be used to develop and implement comprehensive policies and procedures led by a new section in the Budget Office. Target start date July 1, 2023. Target fully operational date: June 30, 2024. Anticipated Completion Date: 06/30/2024 Contact Person and Title: Andrea Race, CFO

AMLR program representatives attended Department of Interior, Office of Surface Mining Reclamation and Enforcement online training covering 2 CFR 200 and contractor or subrecipient determinations. DEP ceased issuing AMLR grants under Management Directive 305.20, Grant Administration. DEP management has determined the recipients with existing agreements are subrecipients and DEP will follow this determination consistently with future agreements and accounting. DEP has developed written policies and procedures for subrecipient monitoring and has notified grantees to implement the policies and procedures immediately to ensure timely subrecipient compliance with federal regulations. Anticipated Completion Date: Completed Contact Person and Title: Patrick Webb, Acting Dir., Bureau of AMLR; Tim Golding, Executive Assistant, Office of Admin. and Management