Corrective Action Plans

Corrective Action Plan: Carle to proceed with publishing and implementing its Sub-Recipient Monitoring Policy. The Grants Administration Office has already created Sub-Recipient Orientation training session for Carle departments and prospective subrecipients and will work with Compliance to actively train stakeholders. Contact Person(s): Kathy Dams, Director, Grants Administration and Research Operations Anticipated Completion: 12/31/2023

Finding: The Washington State Department of Transportation did not have adequate controls over and did not comply with requirements to perform risk assessments for subrecipients of the Formula Grants for Rural Areas program. Questioned Costs: Assistance Listing # 20.509 20.509 COVID-19 Amount $0 Status: Corrective action in progress Corrective Action: The Washington State Department of Transportation (WSDOT) concurs with the finding and is in the process of implementing the audit recommendations. Specifically, the Department?s Public Transportation Division will ensure it performs risk assessments for all subrecipients receiving federal subawards regardless of when WSDOT executes the related contract. As of February 2023, the Public Transportation Division updated its risk assessment process and plans to complete all risk assessments by July 1, 2023. Completion Date: Estimated July 2023 Agency Contact: Jesse Daniels External Audit Liaison PO Box 47320 Olympia, WA 98504-7320 (360) 705-7035 danielje@wsdot.wa.gov

Finding: The Health Care Authority did not have adequate internal controls over and did not comply with federal requirements to ensure subrecipients of the Block Grants for Community Mental Health Services program and the Block Grants for Prevention and Treatment of Substance Abuse program received required single audits, and that it appropriately followed up on findings and issued management decisions. Questioned Costs: Assistance Listing # 93.958 93.958 COVID-19 93.959 93.959 COVID-19 Amount $0 Status: Corrective action in progress Corrective Action: The Authority concurs with the finding. The Authority will: ? Follow established procedures related to the agency-wide monitoring of subrecipients? single audits. ? Issue management decision letters for findings subrecipients received related to programs that are funded by the Authority?s pass-through federal funding. ? Evaluate corrective actions to ensure subrecipients adequately address audit recommendations. Completion Date: Estimated July 2023 Agency Contact: William Sogge, CPA External Audit Liaison PO Box 45502 Olympia, WA 98504-5502 (360) 725-5110 william.sogge@hca.wa.gov

Finding: The Department of Commerce did not have adequate internal controls over and did not comply with requirements to issue management decisions for audit findings to subrecipients of the Low-Income Home Energy Assistance Program. Questioned Costs: Assistance Listing # 93.568 93.568 COVID-19 Status: Corrective action complete Corrective Action: The Department?s internal control officer is responsible for completing the monitoring of federal reporting and issuing management decisions for subrecipients who receive federal audit findings for programs funded with the Department?s federal pass-through funding. Beginning in December 2021, the internal control officer documented all findings, corrective action plans, and communication with subrecipients in a monitoring spreadsheet. This enabled the Department to ensure all efforts in monitoring subrecipients were taken. In May 2022, all management decisions were added to the monitoring spreadsheet which documented the Department?s management decisions. To ensure compliance with federal requirements for subrecipient monitoring, the Department has implemented the following process: ? Review all audit findings issued to Department subrecipients. ? Review each subrecipient?s corrective action plan. ? Review and discuss all findings and corrective action plans with subrecipients to identify and understand the basis for the deficiency and planned corrections. ? Create a management decision for each subrecipient finding, receive leadership approval, and formally communicate the decision to our subrecipient. ? All management decisions will be formally communicated to our pass-through subrecipients within the six-month federal deadline. Completion Date: September 2022 Agency Contact: Gena Allen Internal Control Officer PO Box 42525 Olympia, WA 98504-2525 (360) 480-5149 Gena.Allen@Commerce.wa.gov

Finding: The University of Washington did not have adequate internal controls over and did not comply with federal requirements to ensure subrecipients of the Global AIDS program received required single or program-specific audits, and that it followed up on findings and issued management decisions. Questioned Costs: Assistance Listing # 93.067 93.067 COVID-19 Amount $0 Status: Corrective action in progress Corrective Action: The University maintains that there are adequate internal controls to ensure the Global AIDS program complies with the requirements for pass-through entities as outlined in Uniform Guidance 2 CFR ? 200.332 and the university policy incorporated in Grants Information Memorandum 8. As noted in the finding, the University uses a certification process to obtain information and documentation needed, such as audited financial statements, from each subrecipient and perform a risk assessment using standard risk criteria. For the one exception identified by the auditors, the University misinterpreted the response provided by the subrecipient regarding whether it expended $750,000 or more in federal awards during the fiscal year. Although the single or program specific audit report was not obtained and reviewed, a risk assessment was performed on the subrecipient. With a medium risk rating, the subrecipient was subject to monitoring at the program level throughout the project during the period in question, in accordance with University policy. The University will: ? Update the certification process with all subrecipients to confirm if federal expenditures during a fiscal year exceed the $750,000 threshold to require a single or program-specific audit. ? Issue written management decisions for all applicable audit findings. ? Ensure subrecipients develop and perform acceptable corrective actions to address all audit recommendations, if applicable. Completion Date: Estimated September 2023 Agency Contact: Erick Winger Controller 4300 Roosevelt Way NE Seattle, WA 98195 (206) 543-5322 erickw@uw.edu

2022-007 Finding: Subrecipient Monitoring - ALN 93.391 ? Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises / Department of Health and Human Services / Award Number: ENVHL-202159027 / Award Year: 2021 Status: Corrective action in progress Corrective Action: The City agrees with the finding. DDPHE will consult with the City?s Federal Grants Manager, other agencies that typically have subrecipients for federal awards, and the City Attorney?s Office to review the current standard contract provisions to ensure they cover all required provisions and will modify those provisions accordingly. Person(s) Responsible for Implementing: DDPHE ? Paige Cheney Implementation Date: October 2023

Bonneville Power Administration: Columbia Survival Study (CSS), Streamnet, and Smolt Monitoring by Non-Federal Entities Programs ? Assistance Listing No. 81.999 Recommendation: CLA recommends the Commission follow its internal controls and procedures over subrecipient monitoring to ensure subrecipient audits are received, reviewed, and followed up on and that documentation of those procedures is maintained. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Commission will conduct a comprehensive update on subrecipient surveys for fiscal year 2023. In addition, folders and documentation for the annual review of subrecipients? financial statements will be made available for the auditors in the upcoming fiscal year 2023 audit. Name(s) of the contact person(s) responsible for corrective action: Pam Kahut Planned completion date for corrective action plan: June 30, 2023

Reference Number: 2022-001 Assistance Listing Number: 84.425 Federal Program Title: Education Stabilization Fund Awarding Agency / Pass-Through Entity: U.S. Department of Education, Colorado Department of Education Compliance Requirement: Subrecipient Monitoring Criteria: None for ECSD Corrective Action: The District agrees with the finding and has adopted Policy Regulations: DD-R, Project Partnerships, Sub-Award Grants, Sub-Contracts Pursuant to Grants, and Third-Party Grants Involving District Personnel, Programs or Facilities and; DD-R2, Grants to District Personnel Personnel Responsible: Sandra Farrell, COO and Chelsey Gerard, Director of Finance Completion Date: October 31, 2022

Finding Number: 2022-002 ? Subrecipient Monitoring Name of Contact Person: Tamara Colden, Assistant Director Housing and Community Services Department Corrective Action: The Subrecipient Monitoring policy and procedures were updated in August 2022 to include the procedures for evaluating risk for subrecipients and revise monitoring procedures. These procedures will be updated to include checking the Federal Awards clearinghouse annually to assess audit requirements for all subrecipients and ensure the monitoring policy includes procedures when those audits result in any concerns or findings for subrecipients. A revised risk assessment will be conducted for each subrecipient. Proposed Completion Date: 06/30/2023

The DCEO filled the position responsible for issuing MDLs in June 2023.

Aging will hire and train staff; this is already in process.

The IDPH’s fiscal staff were notified in November 2021 to add the ALN to the warrant description for each subrecipient disbursement made.

IDHS - Division of Family and Community Services (FCS) The IDHS-FCS’ Bureau of Contract Support and Payment administration staff has reviewed the exceptions and worked to create a process to ensure the proper notification of the ALN at time of disbursement. A plan of action was created whereby in each fiscal year the IDHS’ Bureau of Program Support and Fiscal Management staff will communicate the appropriate ALN to be utilized. IDHS - Division of Substance Use, Prevention, and Recovery (SUPR) The IDHS-SUPR staff will ensure that all monthly expenditure vouchers have the ALNs listed and will work with IDHS’ fiscal staff to ensure that the ALNs are listed in the notes field for all vouchers processed for payments. Finally, the IDHS-SUPR staff will ensure that the ALNs are listed on all grants and contracts.

IDHS - Division of Family and Community Services (FCS) The IDHS-FCS staff will meet to determine the need for updated documentation and communication regarding subrecipient programmatic monitoring. IDHS - Division of Substance Use, Prevention, and Recovery (SUPR) The IDHS-SUPR staff will track the completion of compliance and monitoring activities and update the Virtual Compliance Review (VCR) Tracking spreadsheet to track additional monitoring activities to ensure compliance processes are achieved in a timely manner. The IDHS will send reminders and conduct follow- up activities with compliance monitors to ensure compliance and monitoring activities are moving forward as planned. Finally, IDHS will update procedures and provide training to compliance monitors to ensure consistent follow-up is conducted when organizations do not meet established deadlines.

The IDHS will implement fiscal and administrative reviews of IHDA and program monitoring procedures.

Views of Responsible Official: We concur with the audit finding with respect to the monitoring of subrecipients for the American Rescue Plan funding. The County monitored the subrecipient agreement for the 50% matching requirement, and the subrecipient was paid properly. However, we did not obtain quarterly progress reports on the program. Description of Corrective Action Plan: Effective January 1st, 2024, the County will obtain progress reports on a quarterly basis for all active subrecipient agreements. Completion date: December 20, 2023.

CONDITION: The ROE did not have adequate controls over subrecipient monitoring in compliance with the Code. PLAN: The ROE retroactively conducted monitoring of the subrecipients of the ARP - Social Emotional Learning grant passed through the ISBE. The subrecipients of this grant were all other ROEs in the Area IV hub (ROEs 9, 17, 32, and 54) with funds going out for administration costs. Since it is common knowledge that each ROE is audited annually by the Illinois Auditor General, further audit consideration was unnecessary. The ROE will draft subrecipient monitoring policies and procedures to align with standards. Future monitoring will be scheduled in December 2023. ANTICIPATED DATE OF COMPLETION: New policy and procedures implemented partially in FY23 and fully for FY24. CONTACT PERSON: Ms. Jill Reedy, Regional Superintendent

2022-001 – Communications with Subrecipients Finding Type: Significant Deficiency in internal control over compliance Program: ALN 93.959 – SAPT COVID Supplement ALN 93.959 – Prevention, Women’s Specialty Services, Administration ALN 93.959 – Treatment/AMS Criteria: As required by 2 CFR 200.332, the pass-through entity must communicate specific information to subrecipients, as applicable. Condition: Contracts with subrecipients did not include portions of required disclosures. Cause/Effect: Inadequate internal controls over compliance. Select contracts were not in compliance with 2 CFR 200.332. Questioned Cost: None. Recommendation: We recommend that the Entity update all contracts with subrecipients to include required language. View of Responsible Official: Management is in agreement with this recommendation. Planned corrective action: FY2023 contracts with subrecipients have been partially updated with the required language and all required language will be included in the FY2024 contracts with subrecipients. Responsible party: Chief Financial Officer Anticipated completion date: September 30, 2024

Assistance listing number and program name: 93.558 Temporary Assistance for Needy Families 93.558 COVID-19 Temporary Assistance for Needy Families Agency: Department of Economic Security Name of contact person and title: Molly Bright, DCAD Assistant Director Anticipated completion date: June 30, 2024 Agency’s Response: Concur The Department will stop the reimbursement of costs to all nonprofit and contracted subrecipients for items that are disallowed and/or restricted by the regulations provided within the provisions of the federal Temporary Assistance for Needy Families (TANF) grant received by the Department. Additionally, the Department will obtain all supporting documentation needed to ensure compliance with these regulations prior to disbursing any TANF funding to any subrecipient for the purpose of reimbursement or programmatic funding. The Department will also update its policies and procedures for subrecipient monitoring. Furthermore, detailed training for the Department personnel responsible for reviewing and approving subrecipient reimbursement requests will be provided to ensure personnel are capable of identifying costs that are unallowable under federal regulations. The Department will assess the risk of noncompliance violations for each subrecipient and establish a plan of action to address noncompliance. The plan of action will include an array of training and educational processes to ensure applicable personnel are knowledgeable of TANF compliance requirements and Department contracts. The Department will also monitor subrecipients per updated policies and procedures. The Department will continue to resolve the unallowable costs reimbursed to subrecipients as deemed appropriate by the United States Department of Health and Human Services.

Assistance listing number and program name: 84.425C COVID-19 Education Stabilization Fund – Governor’s Emergency Education Relief (GEER) Fund Agency: Arizona Governor’s Office of Strategic Planning and Budgeting (Office) Name of contact person and title: Sarah Brown, Director Governor’s Office of Strategic Planning & Budgeting Completion date: July 31, 2024 Agency’s Response: Concur During fiscal year 2023, the Office took significant corrective action to improve subrecipient monitoring, including assessing each subrecipient’s risk of noncompliance, collecting single audits (as applicable) or certified financial statements from new awardees, and requesting and reviewing additional information from grantees related to uses of awarded funds. Moving forward, the Office proposes the following: 1. The Office will annually require grantees to complete a questionnaire to attest whether the entity will be required to obtain a single audit. The Office will collect single audits (as applicable) or certified financial statements in order to review and follow-up on corrective action items related to the grants administered. The Office will conduct grantee training regarding subrecipient monitoring and the requirements for grantees accepting Federal grant awards. 2. The Office staff have attended various training opportunities to improve their understanding of and tools available to them to perform subrecipient monitoring procedures, as required. The Office has also conducted a staffing assessment and has added staff to perform subrecipient monitoring activities.

Assistance listing number and program name: 21.027 Coronavirus State and Local Fiscal Recovery Funds Agency: Arizona Governor’s Office of Strategic Planning and Budgeting (Office) Arizona Office of Tourism Arizona Supreme Court Name of contact person and title: Sarah Brown, Director Governor’s Office of Strategic Planning & Budgeting Lena Allen, Director of Outdoor Recreation & Sustainability Alyce Agostino, Financial Analyst, Grant Compliance Agency’s Response: Concur Anticipated Completion date: see below Office Completion date: July 31, 2024 During fiscal year 2023, the Office took significant corrective action to improve subrecipient monitoring, including assessing each subrecipient’s risk of noncompliance, collecting single audits (as applicable) or certified financial statements from new awardees, and requesting and reviewing additional information from grantees related to uses of awarded funds: 1. The Office will annually require grantees to complete a questionnaire to attest whether the entity will be required to obtain a single audit. The Office will collect single audits (as applicable) or certified financial statements in order to review and follow-up on corrective action items related to the grants administered. The Office will conduct grantee training regarding subrecipient monitoring and the requirements for grantees accepting Federal grant awards. 2. The Office staff have attended various training opportunities to improve their understanding of and tools available to them to perform subrecipient monitoring procedures, as required. The Office has also conducted a staffing assessment and has added staff to perform subrecipient monitoring activities. Arizona Office of Tourism Anticipated Completion date: January 31, 2024 • Risk Assessment aspect of finding: The Arizona Office of Tourism (AOT) is now aware and will comply with these requirements. In order to comply, AOT will update processes and procedures to include risk assessments of subrecipients. This process will include both an outline for analysis along with the proper documentation and all necessary actions. • Subrecipient Single Audit aspect of finding: Per 2 CFR 200.332(f) AOT had a process in place for any subrecipient that was awarded through the Visit Arizona Initiative Grant Program over $750,000. As outlined by the audit, 2 CFR 200.332(f) applies for any organization that receives over $750,000 in federal funds even outside of the VAI grant program. To align with this requirement, AOT will create a process for identifying, requesting and reviewing Single Audits. Arizona Supreme Court – Administration Office of the Courts Anticipated Completion date: February 28, 2024 The Judicial Branch, Arizona Supreme Court, has drafted a Risk-Assessment Questionnaire for all Grants in which the Supreme Court is a pass-through grantee, to collect all essential information that is needed to reasonably assess the risk probability of possible subrecipients going forward in accordance with 2 CFR §200.332[b] and [d-e].

Assistance listing number and program name: 21.019 COVID-19 Coronavirus Relief Fund Agency: Arizona Governor’s Office of Strategic Planning and Budgeting Name of contact person and title: Sarah Brown, Director Governor’s Office of Strategic Planning & Budgeting Anticipated completion date: July 31, 2024 Agency’s response: Concur During fiscal year 2023, the Office took significant corrective action to improve subrecipient monitoring, including assessing each subrecipient’s risk of noncompliance, collecting single audits (as applicable) or certified financial statements from new awardees, and requesting and reviewing additional information from grantees related to uses of awarded funds. Additionally, Office staff have attended trainings to improve their understanding of and tools available to them to perform subrecipient monitoring procedures, as required. The Office has also conducted a staffing assessment and is adding resources to perform subrecipient monitoring.

Assistance listing number and program name: 14.231 Emergency Solutions Grant Program 14.231 COVID-19- Emergency Solutions Grant Program 14.267 Continuum of Care Program Agency: Department of Housing Name of contact person and title: Keon Montgomery, Assistant Deputy Director of Programs Molly Bright, DCAD Assistant Director (DES) Anticipated completion date: April 30, 2024 Agency’s Response: Concur Department of Housing response: The Department is no longer reimbursing the subrecipient for unsupported or ineligible costs and is working to resolve the issue. The HUD Field Office is aware of the findings and the Department is working toward resolution. Written policies for reviewing and approving subrecipient reimbursements, as well as, risk assessment will be reviewed and updated. Contract specialists in the Special Needs Division have begun training and the Department will continue to leverage Federal educational resources centered on Grants and Agreements, 2 CFR 200 cost principles and award requirements. Department of Economic Security response: Agency: Department of Economic Security Name of contact person and title: Molly Bright, DCAD Assistant Director Anticipated completion date: June 30, 2024 Agency’s Response: Concur The Department will stop the reimbursement of costs to all nonprofit and contracted subrecipients for all items that are disallowed and/or restricted by the regulations provided for within the provisions of the federal Emergency Solutions Grant Program (ESG), including payments that violate the conflict-of-interest disclosure requirements. Additionally, the Department will revise its cost monitoring policy to ensure compliance with these regulations prior to disbursing any ESG funding to any subrecipient for any purpose. The Department will also update its policies and procedures for subrecipient monitoring. The Department will assess the risk of noncompliance violations for each subrecipient and establish a plan of action to address noncompliance. The plan of action will include an array of training and educational processes to ensure applicable personnel are knowledgeable of ESG compliance requirements and Department contracts. The Department will also monitor subrecipients per updated policies and procedures. The Department will continue to resolve the unallowable costs reimbursed to subrecipients as deemed appropriate by the United States Department of Housing and Urban Development.

Assistance Listing 93.558 Temporary Assistance for Needy Families Assistance Listing 93.658 Foster Care – Title IV-E Act 148 Pennsylvania Department of Human Services Views of the Responsible Officials and Corrective Action Plan: Effective 10/13/23, DHS has been preparing FY24 funding allocation letters that will be sent to provider agencies immediately. Going forward, the funding allocation letters will go out at the beginning of the contract fiscal year. Contact Person: Landuleni Shipanga, Controller, Department of Human Services, 215-683-6366.

Assistance Listing 93.558 Temporary Assistance for Needy Families Views of the Responsible Officials and Corrective Action Plan: Management agrees with the finding and recommendation. Starting from FY2024, MOCEO will include a Notice of Award document for all subrecipients contracts. This document will contain the necessary OMB required information to clearly identify award details for the subrecipient. Contact Person: Allison Elliott, Director of Finance, Mayor’s Office of Community Empowerment and Opportunity, 215-685-3626