Corrective Action Plans

2024-037 Oregon Business Development Department Assign responsibility to ensure review of subrecipient audit reports Management Response: We agree with this recommendation. In January 2025, Business Oregon started the initial work by meeting with DAS SARS team on identifying specific tasks for Business Oregon as the assigned audit agency for the SLFRF award. Business Oregon completed the preliminary reviews and confirmed that 23 out of 24 recipients of the SLFRF award are required for the single audit. Business Oregon contacted the recipients and requested financial reports to proceed with review of subrecipient audits. As of March 2025, the work is still ongoing, and Business Oregon is currently communicating with the recipients. The estimated completion date of this review is 6/30/2025 Anticipated Completion Date: June 30, 2025 Contact person: Imee Anderson, Chief Financial Officer, Mia Seo, Deputy-Chief Financial Officer, Rory Spencer, Accounting Manager

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

2024-037 Oregon Business Development Department Assign responsibility to ensure review of subrecipient audit reports Management Response: We agree with this recommendation. In January 2025, Business Oregon started the initial work by meeting with DAS SARS team on identifying specific tasks for Business Oregon as the assigned audit agency for the SLFRF award. Business Oregon completed the preliminary reviews and confirmed that 23 out of 24 recipients of the SLFRF award are required for the single audit. Business Oregon contacted the recipients and requested financial reports to proceed with review of subrecipient audits. As of March 2025, the work is still ongoing, and Business Oregon is currently communicating with the recipients. The estimated completion date of this review is 6/30/2025 Anticipated Completion Date: June 30, 2025 Contact person: Imee Anderson, Chief Financial Officer, Mia Seo, Deputy-Chief Financial Officer, Rory Spencer, Accounting Manager

Management Response and Corrective Action Plan We agree with this finding as two fields were left blank on the required documentation to one subrecipient. We have corrected the documentation and educated the staff involved in creating and collecting the required documentation to ensure completion. Contact person(s) responsible for the corrective action: Lisa Brabo, Chief Executive Officer, lbrabo@fsacares.org Arcelia Sencion, Chief Strategy & North County Programs Officer, ascencion@fsacares.org Paul Katan, Director of Grants and Partnerships, pkatan@fsacares.org Jaime Kuczkowski, Chief Financial Officer, jaime@balancefm.com Anticipated Completion Date: Education and documentation on the above have already started and will be completed by April 1, 2025.

Management Response and Corrective Action Plan We agree with this finding. A subrecipient monitoring policy was implemented in February 2024 in response to prior year Findings 2023-002 and 2023-003. Due to date of policy implementation, monitoring was executed only once during the current fiscal year, rather than quarterly. Contact person(s) responsible for the corrective action: Lisa Brabo, Chief Executive Officer, lbrabo@fsacares.org Arcelia Sencion, Chief Strategy & North County Programs Officer, ascencion@fsacares.org Kendra Webster, Director of Family Support Services, kwebster@fsacares.org Paul Katan, Director of Grants and Partnerships, pkatan@fsacares.org Jaime Kuczkowski, Chief Financial Officer, jaime@balancefm.com Anticipated Completion Date: Education and documentation on the above have already started and will be completed by June 30, 2025.

NONCOMPLIANCE WITH SUBRECIPIENT MONITORING REQUIREMENTS, CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS, AL No. 21.027, GRANT No. AM-23-0211 Name of contact person: Michael Opie and Peri Whiteclay Corrective Action: The county will update its grant management procedures to include subrecipient monitoring. Proposed Completion Date: June 2025.

2024-001 – SUBRECIPIENT MONITORING Recommendation: The auditors recommended CCSJJC implement an internal control to ensure risk assessment and monitoring procedures are performed and formal written documentation is maintained that evidences its compliance with required subrecipient monitoring activities in accordance with 2 CFR 200. Actions Taken or Planned: CCSJJC management will ensure that risk assessment and monitoring procedures are a part of the process for all subrecipients, both from federal and state funding, to ensure that compliance and regulatory guidelines are met. All subrecipients will be required to submit a complete risk assessment form and will be monitored. This will also become an addition to CCSJJC’s financial policies and procedures regarding subrecipient documentation and activities. Person Responsible: James Lyles, Fiscal Manager Estimated Date of Completion: April 30, 2025

2024-012. Inadequate SLFRF Subrecipient Monitoring State Agency: Governor’s Office of Planning and Budget Federal Agency: Department of the Treasury To help staff at DEQ, DNR, and other agencies managing SLFRF funding improve their understanding of the subrecipient requirements and improve internal controls to ensure compliance with these requirements, GOPB will review its ARPA Reference Guide and other ARPA SLFRF training materials to make sure these materials provide adequate guidance, policies, and procedures to agencies managing ARPA SLFRF funding. GOPB will specifically review guidance on the following: • Establishing and following agency policies and procedures to ensure compliance with subrecipient monitoring requirements. • Communicating required federal award information to sub-recipients • Evaluating each subrecipients risk of noncompliance with federal statutes, regulations, and the terms and conditions of the subaward. • Monitor subrecipients according to their assessed risk and as required by 2 CFR 200.332. As part of the process of reviewing these materials, GOPB will work with DEQ and DNR to understand specific areas of guidance, training, or compliance that need to be strengthened. After reviewing and updating the ARPA Reference Guide and other ARPA SLFRF training materials, GOPB will distribute the updated guide to all agencies managing ARPA SLFRF funding. Additionally, GOPB will hold a dedicated training session with both DEQ and DNR, focusing on key areas such as subrecipient compliance requirements, internal controls, risk-based monitoring, Single Audit requirements, and federal compliance standards. GOPB will also maintain a schedule of regular training, site visits, and reviews to ensure ongoing adherence to monitoring protocols and to reinforce internal controls across all agencies. Contact Person: Duncan Evans, Senior Managing Director of Budget and Operations, 801-538-1592 Anticipated Correction Date: November 30, 2024 State Agency: Department of Natural Resources The Department of Natural Resources will review the ARPA Reference Guide and other GOPB ARPA SLFRF training materials provided by Governor’s Office of Planning and Budget to ensure our agency is compliant with managing all SLFRF subrecipient requirements and improve internal controls. DNR will work with GOPB to ensure that key personnel in our agency are doing the following: • Gaining a better understanding of subrecipient requirements and associated internal controls. Water Resources will review the ARPA Reference Guide and GOPB ARPA SLRF training materials to identify internal control weaknesses so they can be addressed. The Finance Manager, Contract/Grants Analyst and Project Funding Section Manager at the Division of Water Resources will also meet directly with GOPB by December 16, 2024 to ensure we understand all subrecipient monitoring requirements. • Establishing and following written policies and procedures to ensure compliance with subrecipient monitoring requirements. The Finance Manager will establish written policies and procedures by December 16, 2024 to ensure compliance with subrecipient monitoring requirements. • Communicating required federal award information to sub-recipients. Federal award information is included in all ARP A contracts executed by the Division of Water Resources and has been since June 2023. Federal award information associated with ARPA contracts executed before June 2023 were subsequently distributed to those grant applicants so that all grantees have the required federal award information. We will continue to review and ensure we are compliant with this requirement. • Evaluating each subrecipient's risk of noncompliance with federal statutes, regulations, and the terms and conditions of the subaward. Since May 2024 Water Resources has been requiring each ARPA grant applicant to fill out a risk assessment questionnaire. We will continue to assess responses to our grant recipients. The Finance Manager and the Project Funding manager will distribute a risk assessment questionnaire to all other grant recipients who have not filled one out yet so we have this information on file for all of our ARPA grantees. This will be completed by December 16, 2024. • Monitoring subrecipients according to their assessed risk and as required by 2 CFR 200.332. The Finance Manager and the Project Funding Manager will meet prior to December 16, 2024 to determine if additional monitoring tools are necessary for any of our subrecipients, which could include site visits, technical assistance, or additional monitoring based upon potential risk. As part of the process of reviewing these requirements, DNR will work with GOPB to understand specific areas of guidance, training, or compliance that need to be strengthened. DNR will work closely with GOPB to ensure specific personnel are trained, focusing on key areas such as subrecipient compliance requirements, internal controls, risk-based monitoring, Single Audit requirements, and federal compliance standards. DNR will ensure that this corrective action plan is implemented and adhered to. State Agency: Department of Environmental Quality DEQ is in the process of hiring a new FTE, one of whose responsibilities will be to review and monitor DEQ’s compliance with sub-recipient monitoring requirements for ARPA and other federal funds. This will ensure that risk assessments, Single Audit report reviews, and other monitoring activities are completed timely, properly documented, and in compliance with federal requirements. Responsible Person: Craig Silotti, Finance Director, 801 536-4460 Anticipated Completion Date: January 31, 2024

2024-004 Program: Foster Care Title IV-E Federal Financial Assistance Listing Number: 93.658 Federal Grantor: U.S. Department of Health and Human Services Pass-Through: California Department of Social Services Award No. and Year: 2401CAFOST and 2024, 2301CAFOST and 2023 Compliance Requirements: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria: In accordance with Title 2 U.S. Code of Federal Regulations (CFR) 200.332, pass-through entities must comply with the following: • 2 CFR 200.332(b) – Evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors listed in 2 CFR 200.332(b)(1) through (4). • 2 CFR 200.332(d)- Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include the information at 2 CFR 200.332(d)(1) through (4). The California Department of Social Services further clarifies in its County Fiscal Letter No. 23/24-80 that Foster Family Agency (FFA), Group Home, and Short Term Residential Therapeutic Programs (STRTP) are “considered subrecipients and subject to the same audit requirements and require the same degree of oversight as other subrecipients”. Further, while there are some licensing and oversight functions performed by the state over FFAs, group homes, and STRTPs, “counties are still ultimately responsible for review of these audits and their findings, any follow-up to ensure compliance, and any other form of monitoring and oversight required by federal and state laws and regulations.” 2 CFR Section 180.300a, Responsibilities of Participants Regarding Doing Business with Other Persons (and repeated in the California Department of Social Services - County Fiscal Letter No. 21/22 – 115) counties are required to verify that recipients or contracts have not been suspended or debarred by using the federal SAM (Systems for Award Management) Condition: The Social Services Agency (SSA) did not maintain documentation that the subrecipient risk assessment or the monitoring activity tracker was reviewed. Cause: The SSA department did not document its review of the subrecipient risk assessment or the monitoring activity tracker. Effect: The County’s control policies were not consistently followed and documented. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of twelve (12) out of fifty-eight (58) subrecipients were sampled, which included seven (7) Foster Family Agency, four (4) Short Term Residential Therapeutic Programs, and one (1) Transitional Housing Placement-Plus Foster Care types. The condition noted above was identified during our procedures related to subrecipient monitoring and was pervasive to the program. Repeat Findings from Prior Years: Yes, Finding 2023-001. Recommendation: We recommend that the County ensure the review over subrecipient monitoring activity is appropriately documented. Management Response and Corrective Action: 1. Person Responsible: Karen Vu, Procurement Contract Manager, Senior 2. Corrective Action Plan: An activity tracker spreadsheet (check list) was developed and implemented in September 2023 to ensure timely completion of subrecipient monitoring activities. The check list is not a requirement of 2 CFR 200.332, the checklist and risk assessment form were shared with the Auditors during prior year's Single Audit, and the auditors did not raise any concerns related to either during the audit. The subrecipient risk assessment and the monitoring activity tracker is reviewed by supervisors; however, review was not documented. We will accept the auditor’s recommendation and add a signature line to the risk assessment and activity tracker to document review by a supervisor. 3. Anticipated Implementation Date: April 2025

2024-009 Program: Aging Cluster Federal Financial Assistance Listing Number: 93.041, 93.042, 93.043, 93.044, 93.045, 93.052, 93.053 Federal Grantor: U.S. Department of Health and Human Services Passed-Through: California Department of Aging Award No. and Year: AP-2122-22 and 2022, AP-2324-22 and 2024 Compliance Requirements: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of Noncompliance Criteria: Per 2 CFR 200.332, a 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. In monitoring a subrecipient, a pass-through entity must include the information at 2 CFR 200.332(1) through (4). Condition: During our testing of the Orange County Community Resources (OCCR) department’s provisions for subrecipient monitoring requirements, we noted that for one (1) of four (4) subrecipients tested, onsite monitoring and follow-up on documented deficiencies was not performed timely. Cause: Established policies and procedures related to subrecipient monitoring do not specify the timeframe within which monitoring must be completed. Effect: There is an increased risk that the department’s monitoring procedure may not address the subrecipient’s risk of noncompliance. Question Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A non-statistical sample of four (4) out of (10) subrecipients were selected for testing. The condition above was identified during our procedures over subrecipient monitoring. Repeat Finding: No. Recommendation: We recommend the department review its established policies and procedures to ensure subrecipient monitoring is performed timely. Management Response and Corrective Action: 1. Person Responsible: Elsa Rivera, Compliance & Monitoring Manager 2. Corrective Action Plan: Concur. Onsite monitoring and follow-up on documented deficiencies have been performed and/or scheduled in compliance with 2 CFR § 200.332. CFR § 200.332 provides guidance on subrecipient monitoring but does not specify exact timelines for when monitoring must be completed. We provided documentation to demonstrate that we are meeting monitoring requirements. Also, we will follow through with the monitoring activities that have already been scheduled for the subrecipient in question. We will review our departmental subrecipient monitoring practices to ensure compliance with County policy. 3. Anticipated Implementation date: June 30, 2025

Effective late fiscal year 2024; new sub-awards and pass thru grant agreements utilize a cover sheet to ensure all required elements listed in 2 CFR 200.332 are clearly included in the subaward agreements.

COVID-19 – Coronavirus State and Local Fiscal Recovery Funds – Assistance Listing Number 21.027 Recommendation: The County should review and enhance internal controls and procedures to ensure that evaluation of independent audits is performed. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Division of Grants Management will require annual reports and audits from all SLFRF subrecipients. If a subrecipient does not meet the criteria for a annual audit, support for that conclusion will be maintained in each Grantee file. Name(s) of the contact person(s) responsible for corrective action: Elizabeth Meadows Planned completion date for corrective action plan: June 2025

Identifying Number: 2024-004 – Subrecipient Monitoring Finding: The University’s controls were not operating effectively to reasonably ensure the University performed risk assessment and monitoring procedures for its subrecipients. As a result, the University did not comply with the compliance requirements for subrecipient monitoring. The University does not have processes and procedures in place related to risk assessment and subrecipient monitoring. Corrective Actions Taken or Planned: We agree with the auditors’ findings. A draft policy for assessing risk and monitoring of subrecipients has been circulated within our governance structure and will be implemented thus ensuring compliance through appropriate policies and procedures. Person(s) Responsible for Correction Actions: Christine Seitz McCauslin, Ph.D. Anticipated Completion Date: April 30, 2025

Finding No. 2024-007: Inadequate Internal Controls over Monitoring of Subrecipient Audits The following are the actions that have been taken to come into compliance with monitoring subrecipient audits: • Office of Emergency Management’s, Recovery Branch Chief has reviewed the outstanding audit finding and issued the management letter resolving the issue on March 12, 2025. • The Assistant Finance Officer reviewed FAC.gov for outstanding subrecipient audits in February of 2025. At this time, we discovered the two audits in question were not received through the Department of Legislative Audit (DLA). We have updated our process to review the subrecipient audit report tracking spreadsheet at least semi-annually, which will also include a review of FAC.gov to locate audit reports not submitted to DLA so that we can manage the timeliness of our review process and issue management letters, if required, within the 180-day period. • The Director of Administrative Services approved the updated process on March 14, 2025. Contact Person: Angie Lemieux, Director of Administrative Services Anticipated Completion Date: Issued management letter resolving the issue on March 12, 2025

Finding 2024-004: Identifying the Award and Applicable Requirements Contact: Damaris Johnson Title: Controller Phone number: 617-914-0500 Estimated Completion Date: December 31, 2025 Correct Action Plan: Management notes the items on finding 2024-002 also applies to this item. Nonetheless, AUWSF takes any potential significant deficiency in internal control very seriously and will seek guidance from the US State Department to clarify this item and implement any necessary changes.

Finding 2024-002: Subrecipient Monitoring – Risk Assessment Contact: Damaris Johnson Title: Controller Phone number: 617-914-0500 Estimated Completion Date: December 31, 2025 Correct Action Plan: Management does not agree that there is a material weakness related to compliance with the grant. Management would like to note the following points: 1) There are two organizations, The Asian University for Woman (AUW), and the Asian University for Woman Support Foundation (AUWSF). These are separate organizations, but AUWSF exists solely to support AUW, and AUWSF is constantly monitoring AUW. 2) The US State Department has emailed that AUW is NOT a subrecipient of AUWSF. This email was forwarded to the auditors. 3) The US State Department has been substantially involved in helping AUWSF carry out this grant work, since 2022, and has not provided any feedback that the AUWSF should be carrying out additional risk assessment procedures on AUW. 4) AUWSF had a fiscal year 2023 single audit, done by the same auditors here, with substantially the same grants and there was no material weakness related to compliance noted during that audit. 5) A variety of information about the AUW and AUWSF including their clean audited financial statements, internal control policies, and other information is documented and publicly available on the AUW and AUWSF’s joint website. 6) AUWSF notes that it actively monitors and reviews the expenditures of the funds they provide to AUW. The funds are paid in installments and only upon satisfactory receipt of documentation of funds expended are subsequent installments sent. AUWSF receives monthly financial statements and bank statements from AUW to further reconfirm the AUW expenditures. Nonetheless, AUWSF takes any potential significant deficiency in internal control very seriously and will seek guidance from the US State Department to clarify this item and implement any necessary changes.

2024-004: 93.959 – Substance Use Prevention, Treatment, and Recovery Services  Recommendation: We recommend that the County prepare and maintain a written plan to ensure subrecipients are aware of the Uniform Guidance requirements.  Explanation of disagreement with audit finding: There is no disagreement and management agrees with the finding.  Corrective action taken in response to finding: The County Office of Finance has developed a plan that includes a Grant Cover Form that has a line to provide the Assisted Listing (AL) number, if applicable. The form is included with the Grant Application during the Grant approval process. The Grant Cover Form will be reviewed and any AL numbers listed will be placed on the agreements that include subrecipient awards.  Name of the contact person responsible for corrective action: Kevin McMahon, Office of Finance, Caren Bortz. Office of the County Executive and Jason Fetterman, Office of Law.  Planned completion date for the corrective action plan: June 30, 2025.

2024-003: 59.059 – Inclusive Ventures Programs  Recommendation: We recommend that the County prepare and maintain a written plan to ensure subrecipients are aware of the Uniform Guidance requirements.  Explanation of disagreement with audit finding: There is no disagreement and management agrees with the finding.  Corrective action taken in response to finding: The County Office of Finance has developed a plan that includes a Grant Cover Form that has a line to provide the Assisted Listing (AL) number, if applicable. The form is included with the Grant Application during the Grant approval process. The Grant Cover Form will be reviewed and any AL numbers listed will be placed on the agreements that include subrecipient awards.  Name of the contact person responsible for corrective action: Kevin McMahon, Office of Finance, Caren Bortz. Office of the County Executive and Jason Fetterman, Office of Law.  Planned completion date for the corrective action plan: June 30, 2025.

2024-002: 21.027 – COVID-19 – American rescue Plan Act Funds (US Treasury ARPA)  Recommendation: We recommend that the County prepare and maintain a written plan to ensure subrecipients are aware of the Uniform Guidance requirements.  Explanation of disagreement with audit finding: There is no disagreement and management agrees with the finding.  Corrective action taken in response to finding: The County Office of Finance has developed a plan that includes a Grant Cover Form that has a line to provide the Assisted Listing (AL) number, if applicable. The form is included with the Grant Application during the Grant approval process. The Grant Cover Form will be reviewed and any AL numbers listed will be placed on the agreements that include subrecipient awards. Name of the contact person responsible for corrective action: Kevin McMahon, Office of Finance, Caren Bortz. Office of the County Executive and Jason Fetterman, Office of Law.  Planned completion date for the corrective action plan: June 30, 2025.

2024-001: 14.239 – HOME Investment Partnership Program  Recommendation: We recommend that the County prepare and maintain a written plan to ensure subrecipients are aware of the Uniform Guidance requirements.  Explanation of disagreement with audit finding: There is no disagreement and management agrees with the finding.  Corrective action taken in response to finding: The County Office of Finance has developed a plan that includes a Grant Cover Form that has a line to provide the Assisted Listing (AL) number, if applicable. The form is included with the Grant Application during the Grant approval process. The Grant Cover Form will be reviewed and any AL numbers listed will be placed on the agreements that include subrecipient awards.  Name of the contact person responsible for corrective action: Kevin McMahon, Office of Finance, Caren Bortz. Office of the County Executive and Jason Fetterman, Office of Law.  Planned completion date for the corrective action plan: June 30, 2025.

Action taken in response to finding: Program managers will include the UEI numbers for all subrecipients on their contracts in the future. Name(s) of the contact person(s) responsible for corrective action: Shaylyn Davis-Iannaco, Housing Program Manager; Lara Kritzer, Director of Housing and Community Development. Planned completion date for corrective action plan: This will be implemented with all future contracts in FY26, beginning in July 2025.

Finding No. 2024-002: Untimely Review of Subrecipient Single Audit Reports AL and Program Expenditures: Various ($539,084,567) Program Name: Research and Development (R&D) Cluster Corrective Action: Process Improvements: - The University began the annual review of Subrecipient Single Audit reports for FY25 and the review schedule is currently on time and up to date. - Implement scheduled calendar appointment reminders to ensure Single Audit Reports are reviewed and completed on time. (Completed 1/6/2025) - Train additional staff member on subrecipient monitoring review process to assist during heavy volume periods. Expected Implementation: April 2025 Contact: Jennifer A. Ponting (Associate Vice President, Research Administration)

Dear Mr. Waguespack, We have carefully reviewed the finding of Noncompliance with and Inadequate Controls over Subrecipient Monitoring Requirements in your audit letter dated January 28, 2025, and we concur. We have provided the following response to address this item. Please contact me if you have any additional questions or require more information. Our Subrecipient Monitoring Standard Operating Procedure (SOP) and related checklist will be modified to ensure that the first step in the Subaward Development process is the completion of the Subrecipient Risk Assessment by Sponsored Projects staff responsible for managing the award. The Director of Sponsored Projects will sign off on the draft subaward, and will also verify completion of the Subrecipient Risk Assessment and provide concurrence. This corrective action plan will go into effect immediately, to be completed by June 30, 2025. The responsible parties are the Director of Sponsored Projects and the Sponsored Projects department staff.

Dear Mr. Waguespack, Please find below the University's management response to the audit finding titled "Noncompliance with Subrecipient Monitoring Requirements". Management Response: The University concurs with the audit finding and has taken steps to address the issue. To enhance compliance, the Sponsored Programs Finance Administration and Compliance (SPFAC) office conducted mandatory refresher training on subaward processing in accordance with federal regulations on April 22, 2024. The training was led by the Sponsored Programs Administration Manager and attended by all Sponsored Programs Administrators. Despite these efforts, staffing challenges continue to impact full implementation of subrecipient monitoring procedures. Reasons for Finding's Recurrence • Staff Attrition: High turnover has limited personnel expertise in subrecipient monitoring. • Loss of Institutional Knowledge: Frequent staffing changes have disrupted training continuity and knowledge retention. • Increased Workload: A growing research portfolio and outdated systems have delayed implementation of prior corrective actions. • System Limitations: Existing processes, designed for a smaller research operation, struggle to meet increasing demands, compounding compliance challenges. Revised Corrective Actions Planned To continue addressing these challenges and ensure sustainable compliance, the University is implementing the following corrective measures under the supervision of the Department's Director: • Recruitment & Retention Strategies: Exploring new approaches to attract and retain qualified SPFAC personnel. • Dedicated Subaward Compliance Position: Establishing a specialist role to oversee subrecipient monitoring. • Structured Training Program: Enhancing onboarding for new hires to improve compliance readiness. • Technology Enhancements: Leveraging automation to subrecipient monitoring and reduce administrative burden. The University remains committed to making continuous improvements and appreciates your understanding and support as we address these challenges.