Corrective Action Plans

To prevent recurrence and ensure timeliness, the following corrective actions have been implemented as of May 29, 2025. Revised Internal Deadlines: Internal monthly reporting deadlines are now set five business days before the funder’s due date to allow for review and contingency time. Party(ies) responsible for overseeing the corrective action plan for the grant program: Wynetta L. Scales, Associate Director, Financial Planning & Analysis Juandalynn Johnson, Associate Director, Grants Management The Justice Advisory Council completed the above corrective action on May 29, 2025.

To address this issue, the department will be taking the following corrective actions: 1. Training: Staff responsible for sub-recipient monitoring will complete updated training focused on federal Uniform Guidance requirements, as well as best practices for oversight and documentation. 2. Policy Review and Clarification: The department will review and revise its internal policies and procedures to align more closely with federal guidelines and institutional expectations. Clear protocols for sub-recipient monitoring activities will be disseminated to relevant personnel. 3. Ongoing Oversight: Upon implementation, the Department will conduct periodic reviews of sub-recipient monitoring activities to ensure compliance and for purposes of identifying any areas requiring further improvement. These actions are intended to strengthen compliance efforts and prevent similar issues in the future. Party(ies) responsible for overseeing the corrective action plan for the grant programs: - Nader Abusumayah, Chief Accountant, nader.abusumayah2@cookcountysao.org, 312.603.1840 - Nicole Kramer, Director of Programs and Development, nicole.kramer@cookcountysao.org, 312.603.1879 The department plans on completing the above corrective action on 8/30/2025

2024-001 Research and Development Cluster – Education Innovation and Research (formerly Investing in Innovation (i3) Fund – Validation Grants) Assistance Listing No. 84.411A Condition: For both subawards selected for testing, the identification of the contact information for the awarding agency was incorrect. The contact information was Education Analytics, Inc., the Organization’s grantor, but should have been Future Forward, Inc. Further, one of the two subawards selected for testing had information missing from the subaward including all requirements for the award to be used in accordance with Federal statutes, regulations and terms and conditions of the Federal award. We consider this condition to be an instance of noncompliance relating to the Subrecipient Monitoring compliance requirement. Statistical sampling was not used in making sample selections. Corrective Action Plan: Future Forward will re-issue contracts/MOUs for its two subawards with the correct awarding agency listed (Future Forward instead of Education Analytics). In addition, Future Forward will include requirements for the award to be used in accordance with Federal statutes, regulations and terms and conditions of the Federal award in the revised contracts/MOUs. Responsible Person for Corrective Action Plan: Kate Bauer-Jones, Executive Director Implementation Date for Corrective Action Plan: May 15, 2025

Lack of Subrecipient Monitoring Auditor Description of Criteria, Condition, and Effect: Under 2 CFR Part 200.332(e), the pass through-entity must monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. The County performed financial monitoring procedures during the year and obtained and reviewed subrecipient single audit reports from those subrecipients who were required to have single audits performed under 2 CFR 200 Subpart F. However, the County could not provide evidence that programmatic or performance monitoring to ensure that the stated goals and objectives of the subaward program were achieved during the year, and as such did not comply with all necessary subrecipient monitoring requirements during the year as required in 2 CFR Part 200.332(e). The County did not follow all federal requirements for subrecipient monitoring and as a result has not completed all monitoring requirements for pass-through entities. Auditor Recommendation: We recommend that the County review its procedures for subrecipient monitoring to ensure compliance with Uniform Guidance. In the past, the County has had established procedures which included desk reviews and documented program monitoring of subrecipient programs, and it appears that not all of those procedures have remained in place due to staff turnover. The County should review, update, and implement procedures to ensure that those required elements of internal control are carried out by the responsible County department. Corrective Action: The Office of Community and Economic Development will implement a subrecipient monitoring policy specific to grants and operations including a schedule of monitoring and risk assessment. OCED program and finance staff will undergo training specific to subrecipient monitoring to ensure alignment in policies across programs. The OCED Finance and Operations Division Administrator will lead subrecipient monitoring activities and will coordinate as necessary with other OCED department division administrators to develop a monitoring schedule and communication plan for subrecipients. Washtenaw County Finance will assist in developing this subrecipient monitoring policy and will perform an overall review of all subrecipient monitoring to ensure compliance and consistency across departments and programs. Responsible Person: Chief Financial Officer Anticipated Completion Date: December 2025

The District will thoroughly examine all grant disclosures and requirements, follow guidance provided, and maintain records related to all reporting. Treasurer has communicated that all district expenditure data reporting be completed by Treasurer/CFO in the future.

MANAGEMENT VIEWS AND CORRECTIVE ACTION PLAN REPORT ON FEDERAL AWARDS IN ACCORDANCE WITH THE OMB UNIFORM GUIDANCE SEPTEMBER 30, 2024 Finding 2024-002 Subrecipient Monitoring- Lack of evidence of subrecipient Uniform Guidance report reviews Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Enabling Low Temperature Plasma (LTP) Ignition Technologies for Multi- Mode Engines Through the Development of a Validated High Fidelity LTP Model for Predictive Simulation Tools, Greater Alabama Black Belt Region (GABBR) LSAMP, and Reimagining controlled environment agriculture in a low carbon world Award Numbers: 211809, 200634, and 205280 Assistance Listing Title: Conservation Research and Development, STEM Education (formerly Education and Human Resources), Agriculture and Food Research Initiative (AFRI) Assistance Listing Number: 81.086, 47.076, and 10.310 Award Year: 2023 - 2024 Pass-through entity: University of Texas Dallas, Association of Public & Land Grant Universities, Tuskegee University, and Clemson University To ensure Auburn University is in compliance with 2CFR 200.332(f), Auburn University has implemented the following corrective action plan: Since the audit period, the University has started a comprehensive review of its subrecipient monitoring framework and has been working to distribute workload more effectively with the goal of building consistency in subrecipient monitoring procedures. This includes efforts to clarify ownership of monitoring tasks, implementing a more centralized and standardized approach to documentation, and balancing the day-to-day operational duties across the subaward team to allow for appropriate focus on Uniform Guidance compliance. Brief internal training sessions or check-ins will be conducted to reinforce expectations and ensure that all staff are aligned with the updated documentation practices. Current procedures will be revised to address risk assessments and annual monitoring. These improvements are designed to ensure consistency, accountability, and compliance with Uniform Guidance expectations moving forward. We will document when all reviews of sub-recipients’ financial statements/Uniform Guidance reports occur and who completed the reviews. These reviews will be entity-specific and conducted annually. The corrective actions noted herein are in process and implementation is expected before the end of the current fiscal year to allow adequate time for review, development, and benchmarking. Contact: Tony Ventimiglia Asst. VP Research Administration Office of the Senior VP for Research & Economic Development Amy Douglas Associate VP Financial Services/Controller Anticipated Completion Date: October 1, 2025

Finding 2024-015 U.S. Department of Treasury AL No. 21.027 American Rescue Plan Act (ARPA) Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: No Auditee’s Corrective Action Plan: Comments on Finding Prior to executing subgrant agreements, in accordance with 2 CFR 200, the Mayor’s Office of Recovery Programs (Recovery Office) confirms that subrecipients have a Unique Entity Identifier (UEI) through SAM.gov. The Recovery Office is responsible for ensuring that UEI information is correctly entered into subgrant agreements that are between the Recovery Office and a subrecipient. Additionally, the Recovery Office shared the UEI requirement with City agencies and developed template ARPA subgrant agreements that City agencies must use with their subrecipients. These templates include a specific field in which to enter the UEI. City agencies are responsible for ensuring that this information is correctly entered into the subgrant agreement. Whether the subgrant agreement is executed by the Recovery Office or another City agency, the Recovery Office collects and retains the SAM.gov record for each subrecipient on the City’s secure network and records the UEI number in a spreadsheet. UEIs are also included in all statutorily required quarterly and annual reporting to the U.S. Department of Treasury. This information has consistently and accurately been reported to the Treasury. However, though required reports to Treasury are accurate, the Recovery Office acknowledges that the UEI was missing or incorrect for some subgrant agreements. This is due to the following: • Clerical errors in the preparation of draft agreements; and • An early version of a funding exhibit in ARPA template subgrant agreements that did not include a specific field in which to enter the UEI (this funding exhibit has since been corrected). CAP for Agreements Executed by the Mayor’s Office of Recovery Programs Subgrant Agreement Review • The Recovery Office will complete a review of all executed subgrant agreements to confirm that the correct Unique Entity Identifier (UEI) appears in the agreement. o This review will exclude Interagency Agreements with City agencies since they are not considered subrecipients, but as the prime recipient, the City of Baltimore. o This review will also exclude any agreements related to projects classified under Expenditure Category 6.1 in ARPA SLFRF guidance. According to Frequently Asked Questions (FAQs) issued by the Treasury, this EC does not give rise to subrecipient relationships, therefore UEI information is not required1. Resolution of Identified UEI Errors in Subgrant Agreements • For any subgrant agreements with an incorrect or missing UEI, the Recovery Office will submit a single memorandum that presents correct UEIs to the Board of Estimates (BOE) to ensure that the official record has correct UEI information. New Subgrant Agreements • The Recovery Office will implement a revised business process for the review of subgrant agreements. All ARPA funding was obligated as of December 31, 2024. According to Treasury guidance, there are very limited circumstances in which a jurisdiction may enter new subgrant agreements after the statutory obligation deadline. If the Recovery Office does execute a new subgrant agreement, the Recovery Office Project Manager must include the following two items in their request for the Chief Recovery Officer’s signature on the document: o a copy of the subrecipient’s SAM.gov record; and o written confirmation that the UEI number presented in the agreement matches the subrecipient’s SAM.gov record. CAP for Agreements Signed by Other City of Baltimore Agencies Subgrant Agreement Review • The Recovery Office will distribute a list to City agencies with all subgrants funded by ARPA. The list will include the subgrant agreement amount, subgrantee name, Workday identifiers (e.g., Purchase Order or Supplier Contract numbers), and the UEI number on file. o This review will also exclude any agreements related to projects classified under Expenditure Category 6.1 in ARPA SLFRF guidance. According to Treasury FAQs, this EC does not give rise to subrecipient relationships2. o City agencies must complete a review of all ARPA-funded subgrant agreements included on the list and confirm that the UEIs are accurate. Resolution of Identified UEI Errors in Subgrant Agreements • For any subgrant agreements with an incorrect or missing UEI, the Recovery Office will require each City agency to submit a single memorandum that presents correct UEIs to the Board of Estimates (BOE) to ensure that the official record has correct UEI information. • Using the list distributed by the Recovery Office, City agencies will confirm that the correction memo has been submitted and approved by the BOE. New Subgrant Agreements • The Recovery Office will implement a revised business process for the review of subgrant agreements in Workday. Though the Recovery Office does not execute ARPA-funded agreements initiated by other City agencies, executed agreements are routed in Workday for Recovery Office approval. The Recovery Office Project Manager will review the UEI presented in the agreement and confirm its accuracy. If it is missing or inaccurate, the Project Manager will notify the agency and instruct them to submit a memorandum to the BOE with the correct UEI information. 1 According to FAQ 13.14 Treasury is not collecting subaward data for projects categorized under Expenditure Category Group 6 “Revenue Replacement.” Treasury has determined that there are no subawards under this eligible use category. U.S. Department of the Treasury. (2021). Final Rule Frequently Asked Questions (FAQ). Retrieved from https://home.treasury.gov/system/files/136/SLFRF-Final-Rule-FAQ.pdf. 2 According to FAQ 13.14 Treasury is not collecting subaward data for projects categorized under Expenditure Category Group 6 “Revenue Replacement.” Treasury has determined that there are no subawards under this eligible use category. U.S. Department of the Treasury. (2021). Final Rule Frequently Asked Questions (FAQ). Retrieved from https://home.treasury.gov/system/files/136/SLFRF-Final-Rule-FAQ.pdf. Contact Person: Elizabeth Tatum, Deputy Director, Mayor’s Office of Recovery Programs Completion Date: June 30, 2025

Finding 2024-028 U.S. Department of Health and Human Services AL No. 93.940 HIV Prevention Activities Health Department Based Programs Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2023-024 Auditee’s Corrective Action Plan: BCHD has developed a subrecipient monitoring policy currently routing internally for approval that addresses the assessment, monitoring and documentation portions of subrecipient monitoring as well as other key elements to ensure adherence to 2CFR 200. The following tools have been created and implemented or in progress to use during monitoring: A. Subrecipient vs. Contractor Determination Checklist that must be completed by staff when submitting contract request to the contract unit to ensure subrecipients are properly identified and to develop a comprehensive monitoring schedule for the agency. B. Comprehensive risk assessment tool to determine monitoring plan for subrecipient. C. Both programmatic and fiscal baseline monitoring tools. Programmatic tools are at the beginning stages of implementation and continue to be customized for specific grant award requirements when necessary. D. Updated expense tracker for the accountants to utilize for review of subrecipient invoices. E. Updated monitoring and risk assessment tools to include requesting and documenting both single audit reports and SAMS.gov status. F. Subrecipient contract agreement templates are being updated to ensure subaward is clearly identified and includes the Federal Award Identification Number, subrecipient’s UEI, along with clear monitoring expectations. Contact Person: Unyime Ekpa, Chief Financial Officer, Baltimore City Health Department Completion Date: June 30, 2025

Finding 2024-025 U.S. Department of Health and Human Services AL No. 93.914 HIV Emergency Relief Project Grants Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2023-021 Auditee’s Corrective Action Plan: BCHD has developed a subrecipient monitoring policy currently routing internally for approval that addresses the assessment, monitoring and documentation portions of subrecipient monitoring as well as other key elements to ensure adherence to 2CFR 200. The following tools have been created and implemented or in progress to use during monitoring: A. Subrecipient vs. Contractor Determination Checklist that must be completed by staff when submitting contract request to the contract unit to ensure subrecipients are properly identified and to develop a comprehensive monitoring schedule for the agency. B. Comprehensive risk assessment tool to determine monitoring plan for subrecipient. C. Both programmatic and fiscal baseline monitoring tools. Programmatic tools are at the beginning stages of implementation and continue to be customized for specific grant award requirements when necessary. D. Updated expense tracker for the accountants to utilize for review of subrecipient invoices. Updated monitoring and risk assessment tools to include requesting and documenting both single audit reports and SAMS.gov status. E. Update subrecipient contract agreement templates ensure subawards are clearly identified and include the Federal Award Identification Number, subrecipient’s UEI, along with clear monitoring expectations. Contact Person: Unyime Ekpa, Chief Financial Officer, Baltimore City Health Department Completion Date: June 30, 2025

Finding 2023-022 U.S. Department of Health and Human Services AL No. 93.686 Ending the HIV Epidemic: A Plan for America Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2023-017 BCHD has developed a subrecipient monitoring policy currently routed internally for approval that addresses the assessment, monitoring and documentation portions of subrecipient monitoring as well as other key elements to ensure adherence to 2 CFR 200. The following tools have been created and implemented or in progress to use during monitoring: A. Subrecipient vs. Contractor Determination Checklist that must be completed by staff when submitting contract request to the contract unit to ensure subrecipients are properly identified and to develop a comprehensive monitoring schedule for the agency. B. Comprehensive risk assessment tool to determine monitoring plan for subrecipient. C. Both programmatic and fiscal baseline monitoring tools. Programmatic tools are at the beginning stages of implementation and continue to be customized for specific grant award requirements when necessary. D. Updated expense tracker for the accountants to utilize for review of subrecipient invoices. E. Updated monitoring and risk assessment tools to include requesting and documenting both single audit reports and SAMS.gov status. E. Update subrecipient contract agreement templates ensure subawards are clearly identified and include the Federal Award Identification Number, subrecipient’s UEI, along with clear monitoring expectations. Contact Person: Unyime Ekpa, Chief Financial Officer, Baltimore City Health Department Completion Date: June 30, 2025

Finding 2024-018 U.S. Department of Health and Human Services AL No. 93.600 Head Start Significant Deficiency in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: No Auditee’s Corrective Action Plan: While the FAIN was included in the package approved by BOE and sent to the subrecipient and the budget and the Federal award also included in the package showed that only direct costs would be reimbursed, the City’s Law Department will revise Exhibit G Funding Source in Subrecipient contracts to include the FAIN, the subrecipient’s UEI and a statement regarding indirect costs. Consequently, the information noted as missing will be specifically referenced/included in contracts signed by the subrecipients moving forward. Contact Person: Shannon Burroughs-Campbell, Executive Director of Baltimore City Head Start Lisa Dooley, Head Start Accountant Completion Date: June 30, 2025

Finding 2024-016 U.S. Department of Health and Human Services AL No. 93.391 Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: No Auditee’s Corrective Action Plan: BCHD has developed a subrecipient monitoring policy currently routed internally for approval that addresses the assessment, monitoring and documentation portions of subrecipient monitoring as well as other key elements to ensure adherence to 2CFR 200. The following tools have been created and implemented or in progress to use during monitoring: A. Subrecipient vs. Contractor Determination Checklist that must be completed by staff when submitting contract request to the contract unit. B. Comprehensive risk assessment tool to determine monitoring plan for subrecipient. C. Both programmatic and fiscal baseline monitoring tools. Programmatic tools are at the beginning stages of implementation and continue to be customized for specific grant award requirements when necessary. D. Updated expense tracker for the accountants to utilize for review of subrecipient invoices. E. Both monitoring and risk assessment tools were created to request and document single audit and SAMS.gov status. Contact Person: Nkenge Williams, Director of Audits, Baltimore City Health Department Completion Date: June 30, 2025

Finding 2024-014 U.S. Department of Housing and Urban Development AL No. 14.241 Housing Opportunities for Persons with AIDS Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2023-011 Auditee’s Corrective Action Plan: Condition #1 Response MOHS acknowledges the finding that 2 out of 2subrecipient files did not have evidence that subrecipient was monitored. Corrective Action: MOHS will follow the City’s Grant Management office’s established process of establishing and maintaining a hardcopy audit file. This file will include: a. Federal System Registrations: SAM, Unique Entity Identification #s, Grants.gov information; b. Federal Financial Accountability and Transparency (FFATA) information; c. FFR Submissions (SF-425 Federal Financial Report); d. Grant Agreements; and, e. Prior Year Single Audits/Monitoring Reports. Condition #2 Response MOHS acknowledges the finding that 2 out of 2 selections did not have information related to the funding source and pass through entity on the notice of award. Corrective Action: MOHS will follow the City’s Grant Management office’s established process of establishing and maintaining a hardcopy audit file. This file will include: a. Federal System Registrations: SAM, Unique Entity Identification #s, Grants.gov information; b. Federal Financial Accountability and Transparency (FFATA) information; c. FFR Submissions (SF-425 Federal Financial Report); d. Grant Agreements; and, e. Prior Year Single Audits/Monitoring Reports. Contact Person: Lakeysha Williams, Director of Programs, Mayor’s Office of Homeless Services Completion Date: April 7, 2025

SD 2024‐003 SUBRECIPIENT MONITORING Recommendations: If the most recent subrecipient audit report is not yet available, management should request the prior fiscal year if not already obtained. Management’s Response: The IRL Council put controls in place to be more effective at subrecipient monitoring following the FY 2023 finding which included the following actions: The IRL Council reviewed all projects and activities currently allocated and funded by federal sources to ensure the Uniform Guidance was in place within their respective agreements, and they were amended as needed. All new subrecipient agreements funded by federal sources were not executed until the respective federal award was in place and the Uniform Guidance language was included. The IRL Council did request audit reports from subrecipients and made statements on them, however for the ones who had not completed their FY 2024 audit, a prior year audit report was not immediately requested and statements for those subrecipients had not yet been made. The IRL Council will implement a control to request prior year Financial Statements/audit reports from subrecipients who have not yet completed their report for the year being requested during the Council’s monitoring. Responsible Party: Daniel Kolodny, COO Anticipated Completion Date: June 1, 2025.

All new contracts and subawards will contain a suspension and debarment clause or condition. For existing contracts and subawards, SAWC will amend with this clause where possible or otherwise verify that the contractor/subrecipient is not suspended or debarred and retain documentation of this verification in our records.

Views of Responsible Officials: Over the past three (3) years, the organization has increased the skill set and capacity among teams for risk assessment and awards management. Subaward policies have been reviewed and all subaward recipients are required to complete pre-award surveys (which include the risk assessment unless the subrecipients are pre-approved by USAID and exempted from such policies). The Associate Director of Grants and Compliance continues to work with members of the Program team to monitor all subrecipient awards for full compliance with 2 CFR 200.516(a). After the FY2022 findings, Astraea sought documentation from federal agencies where risk assessment exemptions applied. The inception of some of these subawards predated FY2022. While we had intended to perform new retroactive risk assessments, the suspension of the federal awards as of January 24, 11:59PM and subsequent termination of the awards had clear instructions to stop work, and therefore made such requests impossible.

Corrective Action Plan Single Audit FY24 May 5, 2025 In regards to finding # 2024-001, contracts with subrecipients did not include portions of required disclosures; the Chief Financial Officer will work directly with Chief Operating Officer and Contracts Department to identify any subrecipients during the budget process and throughout the fiscal year. Contracts department will then issue a contract in compliance with 2 CFR 200.332. The Chief Operating Officer will oversee and monitor compliance with 2 CFR 200.332 prior to the close of the next fiscal year (September 30, 2025). They will then be responsible for reviewing and issuing appropriate contracts to subrecipients going forward. Taylor J. Good Chief Financial Officer

Assistance Listings numbers and names: 17.258 WIOA Adult Program 17.259 WIOA Youth Activities 17.278 WIOA Dislocated Worker Formula Grants 21.027 Coronavirus State and Local Fiscal Recovery Funds 97.024 Emergency Food and Shelter National Board Program 97.141 Shelter and Services Program Name of contact person: Ken Walker, Director (Interim), Grants Management & Innovation Anticipated completion date: June 30, 2026 Response: Concur. The Pima County Department of Grants Management & Innovation (GMI) has re-organized its structure to include a division called Monitoring, Analysis, and Performance (MAP), which is now the lead on monitoring of all County sub-recipients and has begun the process of improving its sub-recipient monitoring processes and practices. The new process combines a more robust analysis of each subrecipient’s required core documents including the entity’s most recent financial audits as well as relevant policies and procedures with an updated fiscal and programmatic compliance review protocol that is aligned with specific award terms and with federal regulations. For example, 1. GMI has institutionalized the use of standardized written communication and timelines regarding monitoring all sub-recipients - e.g., entrance letters, corrective action requests, and exit letters. 2. GMI is currently piloting a new risk assessment methodology. Once it is finalized the County will communicate the new methodology to all subrecipient entities with an explanation of the revised system elements. The new methodology includes first-hand scoring of the degree to which the materials provided by each entity align with grantor and federal requirements. 3. GMI is developing a standardized method for initiating special terms and conditions with out-of-compliance sub-recipients. Corrective action steps will be incremental and may include increased meeting or reporting frequencies, technical assistance, and/or required training completion to help the entity attain regulatory compliance. Serious, on-going issues or refusal to correct may result in suspending payment until the items are corrected and contract termination as a last resort. 4. MAP will work with its Grants Data Management division colleagues to integrate monitoring scheduling and activities, results, and documents into Amplifund, the County’s new grants management plug-in to its new ERP, Workday. Additionally, to address the ongoing challenge of geometric growth in subrecipients over the last several fiscal years without added personnel capacity, GMI is working to achieve efficiency through the County’s new grants management database, AmpliFund, as the centralized data repository for all subrecipient related reporting. Since go-live of the County’s new ERP in July 2024, GMI has been providing training to all County subrecipients regarding how to interact with AmpliFund to be responsive to GMI monitoring and federal compliance. The County continues to work on the implementation of the full functionality of the new ERP software and its ancillary systems. Full functionality will allow real time updates to track subrecipient monitoring activities with visibility for both County departments and subrecipient entities.

Teenage Pregnancy Prevention Program – Assistance Listing No. 93.297 Recommendation: We recommend the Organization enhance its policies and procedures to ensure adequate oversight and monitoring of subrecipients throughout the subaward period, including reviewing audit reports on a timely basis, actively following up with subrecipients on any audit findings to verify corrective action is being taken, and clearly documenting an annual desk review. Additionally, the Organization should ensure it provides subrecipients with clear information on the federal award, including the federal assistance listing number, as well as the federal requirements applicable under the agreement. This information should be written into the subaward agreement and signed by both parties. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: PPNCS has been made aware of performing annual subrecipient audits and has begun this process. Name of the contact person responsible for corrective action: Randy Drager, CFO Planned completion date for corrective action plan: May 1, 2025

Finding: The Office of Superintendent of Public Instruction did not have adequate internal controls over and did not comply with federal activities allowed and subrecipient monitoring requirements for the Education Stabilization Fund program. Questioned Costs: Assistance Listing # 84.425R 84.425V Amount $47,322,280 Status: Corrective action complete Corrective Action: The Office distributed the remaining unobligated funds from the program to Local Education Agencies (LEAs) through the apportionment process to meet the legislative intent. Due to the nature of how the payments were calculated, the Office’s grants system could not be used for the distribution. When a grant is awarded through our grants system, an email notification is sent to the organization that contains the federal elements required in 2 CFR 200.332. Although the Office concurs that we did not provide a formal subaward document that included all of the elements since the funds were not distributed through our grants system, the LEA’s received other formal communication through a Gov Delivery email and the School District Accounting Manual that included most of these federal elements. Going forward, if the Office uses the apportionment process to distribute funds to LEAs, all the required federal elements in 2 CFR 200.332 will be included in a separate subaward. The Office’s communication to LEAs also included the allowable use of these funds. Therefore, the Office does not concur that the funds should be questioned as not being allowable or properly supported. Completion Date: February 2025 Agency Contact: TJ Kelly Chief Financial Officer P.O. Box 47200 Olympia, WA 98504-7200 (360) 725-6301 Thomas.Kelly@k12.wa.us

The RIEMA Recovery staff will revise the Federal Audit Clearinghouse tracking form to include the recommended items. We will not only include findings directly related to our program, FEMA 97.036, but all FEMA findings. We will also add any findings that were noted on any program on the tracking form. We are also creating an additional form, Verification of Compliance – FAC.Gov, which will be submitted to the RIEMA fiscal department. This form identifies any findings and requests their recommendation on proceeding with reimbursement to the sub-recipient in our payment package. Also, we will be incorporating our review of the Single Audit Report in both the tracking form and the verification form. Anticipated Completion Date: RIEMA is implementing this for all project reviews. Contact Person: Lawrence Macedo, Recovery Branch Chief, Rhode Island Emergency Management Agency lawrence.macedo@ema.ri.gov

RIDE monitors 193 subrecipients – this process is overseen largely by one individual. This individual also monitored COVID era funds such as ESSER. With those programs having passed, more time can be re-allocated to subrecipient monitoring. RIDE does review risk scores for sub-recipient monitoring and considers risk as a basis for onsite visits/monitoring. RIDE disagrees that a higher risk assessment was not given for non-completion of the annual survey; we don’t disagree that a site visit was not performed, but that’s due to resource constraints. RIDE will work on documenting these reviews more formally than the current process, while also documenting decisions for either performing a site visit, or not performing a site visit. Anticipated Completion Date: Ongoing Contact Persons: Brandon Bohl, Finance Director, Department of Elementary and Secondary Education brandon.bohl@ride.ri.gov Crystal Martin, Senior Finance Director, Department of Elementary and Secondary Education crystal.martin@ride.ri.gov

2024-044a: Management agrees with this finding and will communicate the requirements for subrecipient monitoring and specifically the review of single audit reports to our agency partners for implementation. 2024-044b: Management agrees with this finding and will communicate the requirements for subrecipient monitoring and specifically the review of single audit reports to our agency partners for implementation. 2024-044c: Management agrees with this finding and will communicate the requirements for subrecipient monitoring; specifically, the documentation of expenses, and meeting notes. Anticipated Completion Date: Completed April 23, 2025 Contact Persons: Paul L. Dion, Director, Pandemic Recovery Office, Department of Administration paul.l.dion@doa.ri.gov Brianna Ruggiero, Chief of Staff, Pandemic Recovery Office, Department of Administration brianna.ruggiero@doa.ri.gov

2024-040 Oregon Department of Emergency Management Assign responsibility to ensure review of subrecipient audit reports Management Response: The Oregon Department of Emergency Management (OEM) concurs with the finding and the recommendations as outlined in the letter and above. OEM is undertaking the following corrective actions to address the recommendations made by the Secretary of State’s Audits Division: • OEM will identify sufficient and appropriate grant accounting staff to perform this work on an ongoing basis, ensure that this work is added to their Position Descriptions, provide them with appropriate training, support, and guidance regarding subrecipient audit reviews. • OEM will establish an annual plan to assign this work out, establish and utilize tracking sheets, and follow up for timely completion. • OEM will work to address the past due FY 24 subrecipient reviews noted in the audit finding letter and above, and will then work to address those from FY23 and FY22. Anticipated completion date: December 31, 2026. Contact person: Amy Mettler, Chief Financial Officer.

2024-030 Department of Education Perform regular fiscal monitoring as part of subrecipient monitoring Management Response: ODE agrees with this finding. ODE will ensure subrecipient fiscal monitoring is performed on the schedule set by department policy by: • Updating the internal procedure and timeline for requesting, reviewing and approving district submissions of claims for IDEA Fiscal Cyclical Monitoring. • Updating current IDEA Subrecipient Fiscal Monitoring manual to clarify updated internal procedure and timeline. The department will develop a procedure to track the completion of cyclical fiscal monitoring by: • Establishing a dedicated digital file to save district claims documentation and email communications for each cyclical monitoring review for each district. • Creating and utilizing a tracking document or system for each Cohort Group that will include the district, date of claim, amount of claim, approval status, date of approval, and location of documentation. • Develop a standard request notification and a standard approval notification for claims documentation. Anticipated Completion Date: June 30, 2025 Contact person: Allyson McNeil, OESO, Director of Resource Management and Operations and Rae Ann Ray, OESO IDEA Fiscal Team, IDEA Part B Grant Manager