Corrective Action Plans

Department: Economic and Community Development Title: Internal control over ERA Program subrecipient monitoring needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The Department will contract with a consultant to conduct close out procedures that will ensure these subrecipient funds were used for authorized purposes and in compliance with Federal regulations. The Department will ensure that the review of subrecipient audit reports are sufficiently documented. 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 risk evaluation procedures needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The CACFP team will create a risk assessment tool to use in scheduling subrecipient reviews. Completion Date: June 30, 2023 Agency Contact: Jane McLucas, Director of Child Nutrition, DOE, 207-624-6880

Department: Education Title: Internal control over CACFP subrecipient audit procedures needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The Department will implement policies and procedures for the tracking, receipt, and review of audits for subrecipients that expend over $750,000, in accordance with Federal regulations. Completion Date: June 30, 2023 Agency Contact: Jane McLucas, Director of Child Nutrition, DOE, 207-624-6880

Department: Education Title: Internal control over CNC subrecipient audit procedures needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The Department will create policies and procedures to collect, track, and review single audits for private schools receiving over $750,000 in Federal awards. Completion Date: September 1, 2023 Agency Contact: Jane McLucas, Director of Child Nutrition, DOE, 207-624-6880

Action Plan: We will work with our departments to ensure that controls for grants are documented with written procedures. These procedures will include the title of the positions responsible for each control (preparation, review, reconciliation, etc.) and will require that the performance of the controls be documented in a clear, re-performable manner with the name of the responsible individuals, the specific control(s) they performed over compliance for the grant, and the date(s) the controls were performed. Contact Names Responsible for the plan - Marcia Saulo Anticipated completion date of the plan - September 20, 2024

Action Plan: We will work with our departments to ensure that controls for grants are documented with written procedures. These procedures will include the title of the positions responsible for each control (preparation, review, reconciliation, etc.) and will require that the performance of the controls be documented in a clear, re-performable manner with the name of the responsible individuals, the specific control(s) they performed over compliance for the grant, and the date(s) the controls were performed. Contact Names Responsible for the plan - Marcia Saulo Anticipated completion date of the plan - September 20, 2024

FINDING 2022-004 The 2022 97.024 Emergency Food and Shelter National Board Program grant funding was received during a crisis resulting in a unique situation for the City of Chicago. The funding was provided before the federal government set up an award identifier (i.e., ALN/CFDA, CSFA), resulting in the Delegate Agency contract with the Department of Family Support Services (DFSS) containing only the name of the Grant. To address and prevent such issues in the future, the City's Office of Budget and Management (OBM) will run a Comprehensive Report quarterly to identify any placeholder award identifiers during funding setup. The Grants Management Unit within OBM will collaborate closely with the Department of Finance (DOF) to ensure the federal award identifiers are promptly updated in the financial system. Moreover, to ensure accuracy and compliance, the Grants Management Unit will work with the relevant contracting Department to update contracts with Delegate Agencies. This measure will guarantee that all necessary award identifiers are included, streamlining the funding process and ensuring proper tracking and reporting of federal grants. Assistant Budget Director Belczak at the Office of Budget and Management will be responsible for ensuring that this corrective action plan is implemented by the beginning of the fourth quarter in October 2023.

Finding 2022-061 Disaster Grants - Public Assistance (Presidentially Declared Disasters), ALN 97.036 - Subrecipient Audits Management Views MSP agrees with the finding. Planned Corrective Action MSP will improve monitoring by reconciling expenditures by program to ensure that all subrecipients are included on the single audit tracking sheet for review. In addition, MSP will transition to each division having the responsibility for the completion of their own single audit reviews beginning October 1, 2023. Anticipated Completion Date MSP will reconcile expenditures by program by October 1, 2023, and each division will have their single audit reviews completed by September 30, 2024. Responsible Individual(s) Matt Opsommer, MSP

Finding No. 2022-005 Department(s) New York City Department of Health and Mental Hygiene Program(s) Assistance Listing Numbers 93.940, HIV Prevention Activities ? Health Department Based Corrective Action(s) We agree with the recommendation provided above and have been working on an internal control structure to address the compliance requirements. Subsequently, we have created a site visit schedule with PHS this fiscal year and revised the site visit tool. The current site visit for this portfolio is scheduled for 4/1/23. Moving forward, we will continue work on a yearly site visit schedule with PHS in a timely manner. Anticipated Completion Date April 2023 Person(s) Responsible for Implementation Jenny Fernandez Director of Administration, BHHS (347) 396-4258 Jennifer Sorel Deputy Director of Business Systems, BHHS (347) 396-7407

Finding No. 2022-016 Department(s) New York City Department for the Aging Program(s) Assistance Listing Numbers 93.044, 93.045, & 93.053, Aging Cluster Corrective Action(s) NYC Aging agrees with the recommendation and will be amending all appropriate contracts to provide subrecipient award notices with the information required by the Uniform Guidance. The award notice will also reference the audit instructions, which will further provide subrecipients with guidelines on how to report their federal expenditures and comply with their Single Audit requirements. Anticipated Completion Date September 2023 Person(s) Responsible for Implementation Jose Mercado Chief Financial Officer (212) 602-4471

Finding 2022-042 Education Stabilization Fund, ALN 84.425 - During-the-Award Monitoring Procedures Management Views For part a., MDE partially agrees with the finding. MDE acknowledges that it did not complete any reviews of the FERs submitted during fiscal year 2022. However, the Uniform Guidance does not specify a timeframe for the review of FERs for the Education Stabilization Funds (ESF) and the ESF program is inherently more flexible than other federal programs in this regard. Although GANs originally required ESF subrecipients to submit a FER by August 29, 2022, MDE communicated to ESF subrecipients after the initial GANs that the August 29, 2022 due date was subject to change due to the continuously changing rules and requirements around this funding, including extension possibilities such as late liquidation. ESF FERs were due either within 60 days of full draw of the funds or within 60 days of the end of the award period, which could have been during the State?s fiscal year 2022 or well after September 30, 2022. For this reason, under Uniform Guidance, MDE had the authority to delay the review of FERs until closer to the end date of the award. In the case of late liquidation, the U.S. Department of Education provided notification that extended the award period as far as 14 months beyond the original end date of the award. For part b., MDE partially agrees with the finding. MDE acknowledges that subrecipient desk reviews were not finalized; however, the majority of the subrecipient monitoring was complete. The Uniform Guidance does not specify a timeframe for ESF subrecipient monitoring to occur and no requirement or expectation was made that monitoring would be finalized by MDE management by September 30, 2022. While the MDE contractor was not tracking completion against the date of September 30, 2022, documentation was and is still available, upon request from the OAG, to demonstrate the substantial ongoing monitoring activities, such as desk reviews and review of amendments, as of the end of the State?s fiscal year 2022. The Compliance Team was in regular contact with MDE throughout the monitoring process. The Compliance Team provided regular updates leading up to September 30, 2022 and shared comprehensive preliminary results with the department soon after September 30, 2022. Planned Corrective Action For part a., MDE will evaluate the process for reviewing FERs to determine the appropriate timeframe for FER review of these ESF funds in light of federal liquidation extensions. MDE and subrecipients were notified of a one-time, Coronavirus Aid, Relief, and Economic Security Act reopening drawdown opportunity during the spring of 2023, which again reopened the possibility for subrecipients to submit FERs. MDE will begin interim reviews of a sample of submitted FERs by September 30, 2023. For part b., MDE?s contractor provided MDE with the final results of its school year 2021 monitoring that was finalized during the summer of 2022 on January 5, 2023. MDE and its contractor have since followed up with subrecipients to recommend necessary or reasonable corrective action in March 2023. School year 2022 monitoring is ongoing and anticipated to be completed by September 30, 2023. Anticipated Completion Date September 30, 2023 Responsible Individual(s) Spencer Simmons, MDE

Finding 2022-018 MDE - Subaward Information Management Views MDE agrees with the finding. For part a., MEGS+ automatically generates Grant Award Notifications (GAN) upon approval of the application. At the time the applications were originally approved, a complete GAN would have been available for the subrecipient that included all subaward information as required by the Uniform Guidance. However, an error occurred when MDE updated the letterhead template in the MEGS+ system, disrupting the appropriate generation of the GANs for those applications that included multiple funding sources. For part b., prior to fiscal year 2022, the Great Start Readiness Program (GSRP) appropriation was composed of State funding only. Program office oversight of the GSRP grant includes a complex grant application reliant on multiple data points connected to budget submissions. As such, the grant management system could not be restructured to accommodate federal funding for GSRP including systematic issuance of GANs within a reasonable timeframe for fiscal year 2022. This necessitated GANs be created and issued via a manual process. The MDE program office was unable to determine the federal award identification number (FAIN) or closeout terms and conditions prior to issuance. Planned Corrective Action For part a., MDE corrected the error that caused GANs to generate without all required subaward information in MEGS+ on April 28, 2023. All GANs are available in MEGS+ and can be generated when requested in the system. For part b., MDE fully corrected this issue for fiscal year 2023. MDE now has the appropriate details and beginning in fiscal year 2023, GANs are issued systemically with all required FAIN or closeout terms and conditions via the new grant management system. All federal funding GANs for fiscal year 2023 were issued upon approval of grantee budgets beginning January 30, 2023, with the final approval and GAN issued May 18, 2023. Anticipated Completion Date Completed Responsible Individual(s) Spencer Simmons, MDE Richard Lower, MDE

Finding 2022-040 Formula Grants for Rural Areas and Tribal Transit Program, ALN 20.509 - Subrecipient Audits Management Views MDOT agrees with the finding. Planned Corrective Action MDOT will update and implement its procedures to include management decision letter timelines that are consistent with the Uniform Guidance related to subrecipient report review. Anticipated Completion Date September 30, 2023 Responsible Individual(s) Adam Feldpausch, MDOT Dave Wearsch, MDOT

Finding 2022-037 Crime Victim Assistance, ALN 16.575 - Risk Assessment and During-the-Award Monitoring Management Views MDHHS agrees with the finding. Planned Corrective Action For part a., MDHHS included the grant agreement identified in the fiscal year 2023 monitoring plan. MDHHS will evaluate current monitoring procedures and make updates, if necessary, to improve documentation of monitoring activity. For the grantees identified that only receive an administrative portion of VOCA funds, MDHHS has initiated the process to provide the grantees with access to the U.S. Department of Justice (DOJ) Office for Victims of Crime (OVC) reporting website. MDHHS is working with DOJ OVC to determine reporting elements for the administrative awards and will work with grantees to implement the required reporting elements. For part b., MDHHS will revise risk assessment and monitoring plan procedures to include all awards issued during the fiscal year. Anticipated Completion Date a. December 30, 2023 b. October 1, 2023 Responsible Individual(s) a. Twanisha Glass and Patsy Baker, MDHHS b. Tonya Avery, MDHHS

The Department finance office will work with the charter office to update its policies, procedures, and internal controls for review of charter schools with charter management organizations (CMO) to ensure proper risk assessment for conflicts of interest, related party transactions, and segregation of duties between the CMO and the charter school. Anticipated Completion Date: December 31, 2023 Contact Person: Mark Dunham, Director, Finance Office Department of Elementary and Secondary Education mark.dunham@ride.ri.gov

The Department will continue to monitor Title I supplement/supplant methodologies for subrecipients through its subrecipient monitoring/risk assessment survey. The Department will require Title I subrecipients to submit supplement/supplant policies, procedures, and methodologies as a requirement to complete the survey. Anticipated Completion Date: December 31, 2023 Contact Person: Mark Dunham, Director, Finance Office Department of Elementary and Secondary Education mark.dunham@ride.ri.gov

The implementation of the Grants Management System has increased controls, standardized business practices, and implemented policy and regulation subrecipients addressing this finding in full. Anticipated Completion Date: System completed December 2022; Regulation completed April 2023 Contact Person: Steve Thompson, Chief of Strategic Planning, Monitoring and Evaluation Department of Administration, Office of Management & Budget, Grants Management Office steve.thompson@omb.ri.gov

Finance and the Office of Highway Safety will work together to create policies and procedures to ensure compliance with subrecipient monitoring. Anticipated Completion Date: September 30, 2023 Contact Person: Loren Doyle, Acting Chief Operating Officer / Chief Financial Officer Department of Transportation loren.doyle@dot.ri.gov

Finding Reference Number: 2022-002 Federal Agency: U.S. Department of Health and Senior Services Program Name: Temporary Assistance for Needy Families Assistance Listing Number: 93.558 Responsible Official: Megan Bania, Executive Director Views of Responsible Individuals: The loss of the executive director in January 2022 and the poor handoff to the interim executive director Brian Valentine, and his resignation in March 2023, left SkillUp program manager with insufficient oversight and management support. The failure of the Director of Finance to assist with creating updated financial monitoring protocols and lingering concerns about traveling during COVID resulted in the failure to perform financial monitoring. The former program manager did follow spending and provided programmatic monitoring and support to subrecipients. She resigned from MCAN in July 2022. Megan Bania is the new executive director and has worked with the new program manager and the accounting team to create in person/onsite financial monitoring protocols and will ensure that financial monitoring is conducted in FY 2023.

84.027 Special Education - Grants to States (IDEA, Part B) 84.173 Special Education - Preschool Grants (IDEA, Preschool) Subrecipient Monitoring 2022-029 Strengthen Controls to Ensure Compliance with On-Site Subrecipient Monitoring Requirements for Special Education Cluster Programs. Response The MDE Office of Special Education (OSE) acknowledges the findings identified by the Office of the State Auditor's as described above. MDE OSE has maintained the review of the Single Audits and provided follow-up on corrections needed by LEAs with funding under IDEA programs. In addition, MDE OSE provides technical assistance to LEAs regarding such. Further, MDE OSE utilizes the District Determinations (SPP/APR) data to provide proactive technical assistance to LEAs. During the 2020-2021 school year, MDE OSE conducted cyclical monitoring to the best of its ability given school closures related to the COVID-19 pandemic. During SY 20-21, the existing procedure required onsite visits for every monitoring activity. However, during that time, and under the guidance of the National Center for Systemic Improvement (NCSI) , MDE OSE monitored LEAs via Special Education Determination Reports, Mississippi Comprehensive Automated Performance-based System (MCAPS) funding application review, and Formal State Complaints using previous procedures while MDE OSE developed new procedures and risk assessments. Additionally, with the onset of COVID-19, the districts and state agencies faced challenges in meeting monitoring requirements and timelines during the first six months of the 2020-2021 school year due to health and safety restrictions. In its implementation of new procedures and risk assessments, MDE OSE has incorporated broad revisions to the agency's subrecipient monitoring procedures and made a significant investment in building the capacity of new OSE management team members to monitor subrecipient compliance and ensure that subawards are used for authorized purposes. Those newly developed procedures were piloted during the 2021-2022 school year, finalized in May 2022, and fully implemented for school year 2022-2023. It should be noted that in June 2023, the MDE OSE received a program determination letter (PDL) from the U.S. Department of Education (US DOE), Office of Special Education and Rehabilitative Services (OSERS) that resolved a similar finding 2021-037 from Audit 04-21-39984 conducted by the State of Mississippi, Office of the State Auditor. The corrective actions included in finding 2021-037 are the same as those seen below. The PDL indicated that the MDE OSE produced evidence of revised systems to ensure compliance with the agency?s requirements for subrecipient monitoring. Corrective Action Plan: A. The MDE OSE will continue the programmatic and cyclical monitoring of LEAs that began as a pilot in the spring of 2020. The newly implemented procedures will be utilized fully in the 2022-2023 school year. B. The MDE OSE will continue to complete the risk-based assessment, that includes the SPP/APR data, each year as universal monitoring of all LEAs to identify those in need of intensive intervention and support. C. The MDE OSE will continue to review, approve and monitor budgets and expenditures through the Mississippi Comprehensive Automated Performance-based System (MCAPS) to oversee the use of IDEA grant funds to subrecipients. D. The MDE OSE has established a procedure of virtual self-assessment via desk audits if the process is once again interrupted due to health and safety concerns.

ALN Number 17.258, 17.259, 17.278 ? Workforce Innovation and Opportunity Act 2022-023 ? Strengthen Controls to Ensure Compliance with Subrecipient Monitoring Requirements. Cat ? M, Finding Type, A, C1 (MW, MNC) MDES Response: The Mississippi Department of Employment Security concurs in principle with the three conditions noted in the finding. During and prior to this audit, MDES enacted new procedures to address the concerns noted in this finding. MDES renewed its commitment to ensuring that subrecipients are qualified to receive funds. MDES contracted with Booth Management Consultants and more recently Trace Advisory Group to ensure compliance with all DOL monitoring requirements, including on-site monitoring and through other modes. Also, we started implementing a risk-based assessment tool to ensure the performance of a thorough qualification assessment on all grantees. Corrective Action Plan: A. The Offices of Grant Management and Business Management will develop a plan to document our assessment of the subrecipients? awareness of audit requirements at 2 CFR 200.332(f). MDES will start implementing the plan detailed below on or before October 31, 2023. This plan involves the following: 1) Perform a pre-award risk assessment to determine risk for awarding grant and the level of monitoring required during program; 2) Issue a standardized audit requirement letter or agreed upon procedures to all subgrantees to remind them of grant requirements; 3) Receipt of required federal single audit from subgrantees expending more than $750,000 in federal funds from all sources OR receipt of a statement that the entity did not meet this threshold; 4) Document the review and assessment of the audits received for findings or questioned costs using tools, such as the templates found in the DOL Core Monitoring Guide; and 5) Document all required agency action necessary to mitigate the risks identified in the audits. B. COVID-19 caused extensive travel and in-person meeting restrictions nationwide. MDES did not restrict travel or virtual meetings. As contact guidelines fluctuated, the on-site monitoring team had discretion regarding the method to conduct this process. Also during this time, DOL staff observed similar contact restrictions, which limited federal monitoring of MDES. Such challenges and restrictions no longer exist. MDES will perform on-site and remote monitoring, as required. Where possible, MDES intends to conduct future monitoring on-site. MDES management will also hold regular meetings with the subrecipients to monitor progress and to ensure questions related to grant expenditures receive timely responses. C. Although the agency did not perform a risk-based assessment in the year reviewed by the auditors (PY21), MDES did incorporate the Risk Assessment Tool, Tool S from the U. S. Department of Labor?s Core Monitoring Guide, into its review of subgrantees for PY 2022. MDES will continue to ensure the performance of a thorough risk-based assessment on all grantees.

Finding 2022-001 Federal Agency: Various Program Name: Research and Development Cluster Assistance Listing Number: Various Federal Award Year: Programs active between July 1, 2021 ? June 30, 2022 Compliance requirement: Subrecipient Monitoring Finding Type: Significant Deficiency The Office of Research and Sponsored Programs lost both its primary and secondary resources responsible for subrecipient monitoring in July 2020 and June 2021. The University could not replace them immediately due to a hiring freeze during the Covid pandemic. A full time Subaward Coordinator was hired in December 2021. The Subaward Coordinator has operationalized all tasks associated with Subrecipient Monitoring as identified in the Uniform Guidance as well as in accordance with Lehigh policies, procedures and internal controls. The review of current active subawards has been completed, including all single audits for fiscal year 2022, with no findings for any of Lehigh?s subawards. The Subaward Coordinator continues to monitor for the posting of these remaining reports on a weekly basis in order to complete the review of subrecipient single audit reports on a timely basis. We are confident with the full-time focus of the Subaward Coordinator and the enhancements to our subrecipient monitoring processes and controls that this finding is fully remediated. Name of contact person: Cynthia Kane, Assistant Vice Provost, Office of Research and Sponsored Programs. Completion date: May 31, 2022

FINDING 2022-004 Contact Person Responsible for Corrective Action: Chad Shireman Contact Phone Number: 812-738-8241 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The county will be retaining and periodically reviewing the grant application and award to stay current on applicable requirements of the subrecipient in order to ensure compliance. Lines of communication with the subrecipient will be established and maintained to better monitor activities, ensuring that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward and achieves performance goals. Policies and procedures will be adopted and implemented to allow the county to evaluate the subrecipient?s risk of noncompliance. The county will request supporting documentation from the subrecipient when reimbursement requests are made, and this process will be documented in order to provide evidence that it is taking place. Anticipated Completion Date: The anticipated completion date will be December 31, 2023. This will allow the county and the subrecipient to work together to create the necessary policies and procedures. Once created, the remainder of the year will be used to implement them, allowing the county to evaluate all activities for the entire 2023 audit period that will be under review by SBOA in 2024.

The City has established an Audit Review Certification form that will be completed by employees to formally document the review of subrecipient agencies? audit reports.

The City has established an Audit Review Certification form that will be completed by employees to formally document review of subrecipient agencies? audit reports.