Corrective Action Plans

The Organization will update its subrecipient monitoring policies to ensure all required elements as defined in 2 CFR § 200.332 (a)(1) are included in subrecipient agreements, Additionally, a checklist will be established to perform a risk assessment process to evaluate subrecipient risk prior to contract execution and annually thereafter and to verify each subrecipient’s that meets the audit threshold and if required has a current Single Audit on file or is otherwise in compliance.

Condition: Review of the agreements with three subrecipients identified certain communications required were not included in the language of the agreement. Corrective Action Plan: The Center will review required communications and update agreements with subreceipients accordingly. Anticipated Completion Date: June 30, 2025 Responsible Individual: Andy Navarro, Senior Accountant

The District will discuss the results of this audit with our ESC to establish protocols and receive copies of their annual audit reports for review.

2024-003 – Subrecipient Monitoring – Internal Control and Compliance over Subrecipient Monitoring (Significant Deficiency) Condition: During the review of subrecipient monitoring records, several areas were noted for improvement: • For two (2) out of three (3) subrecipients, the official agreement was not formally documented. One subrecipient agreement was executed via internal resolution and email approval; another subrecipient’s agreement lacked sufficient identification and award details, omitting key funding terminology. • The City’s Subrecipient Monitoring Policy, which became effective on April 17, 2024, does not cover the period before the policy took effect. For all three (3) subrecipients, the City is unable to provide any documentation of the review of Financial and Performance Reports. • The required Pre-Award Risk Assessments have not been provided for at least one subrecipient because the City’s Subrecipient Monitoring Policy, which became effective on April 17, 2024, does not cover the period before the policy took effect. Management concurs. Corrective Actions: Staff will prepare new forms for subrecipient monitoring and communicating the requirements to all departments to ensure that subrecipient monitoring will follow the compliance requirements. Name of Responsible Person: Rose Tam, Director of Finance Albert Trinh, Accounting Manager

Management concurs. The City is in the process of updating the Grants manual that will establish and enforce comprehensive subrecipient monitoring protocols. This includes developing standardized monitoring procedures, providing staff training on monitoring requirements, allocating sufficient resources for monitoring activities, and implementing mechanisms for regular review and documentation of monitoring efforts. By strengthening subrecipient monitoring practices, the City can mitigate risks, ensure compliance with grant requirements, and safeguard the effective utilization of grant funds.

Department: Health and Human Services Title: Internal control over TANF subrecipient risk evaluation procedures needs improvement Questioned Costs: None Status: Management’s opinion is that corrective action is not required Corrective Action: The Department disagrees with the finding. The Department evaluates risk on its subrecipients for the purpose of determining the appropriate subrecipient monitoring in multiple ways. The first assessment of risk is when a subaward is competitively bid. The second assessment of risk is built into the Maine Uniform Accounting and Auditing Practices for Community Agencies (MAAP) in which higher risk subrecipients undergo a higher level of testing by Independent Public Accountants. Finally, the Social Service Unit of the Division of Audit performs a risk assessment and tests transactions for those subrecipients that have been determined to be higher risk. Completion Date: N/A Agency Contact: Jim Lopatosky, Director, Division of Contract Management, DHHS, 207-287-5075

Department: Health and Human Services Title: Internal control over TANF program subrecipient cash management needs improvement Questioned Costs: None Status: Management’s opinion is that corrective action is not required Corrective Action: The Department disagrees with this finding. The Department is in compliance with the requirement for minimizing the time between payments to our subrecipients and the disbursement of funds. Payments are made as close as administratively feasible. The Compliance Supplement suggested audit procedures for Cash Management for pass-through entities refers to 200.305(b)(1). That same paragraph states that the timing and amount of advance payments must be as close as is administratively feasible. Completion Date: N/A Agency Contact: Anthony Madden, Deputy Director of Audit, DHHS, 207-287-2834

Department: Health and Human Services Title: Internal control over ICA program subrecipient cash management needs improvement Questioned Costs: None Status: Management’s opinion is that corrective action is not required Corrective Action: The Department disagrees with this finding. The Department is in compliance with the requirement for minimizing the time between payments to our subrecipients and the disbursement of funds. Payments are made as close as administratively feasible. The Compliance Supplement suggested audit procedures for Cash Management for pass-through entities refers to 200.305(b)(1. That same paragraph states that the timing and amount of advance payments must be as close as is administratively feasible. Completion Date: N/A Agency Contact: Anthony Madden, Deputy Director of Audit, DHHS, 207-287-2834

Department: Education Title: Internal control over ESF subrecipient monitoring procedures needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The Department will work with the GEMS software developer to create the collection tool that will be integrated into the FY24 and FY25 ESSER performance report. The School Administrative Unit reports will be due on May 5, 2025 and reviewed by the individuals who continue to support the work of the Emergency Relief Funds. The equipment inventories and real property lists will be maintained in the Department files. Completion Date: April 15, 2025, May 5, 2025, and July 1, 2025, respectively Agency Contact: Shelly Chasse-Johndro, Director, ESEA, DOE, 207-458- 3180

Department: Labor Title: Internal control over CSLFRF subrecipient risk evaluation procedures needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The Department will evaluate and establish procedures to assess risk at the appropriate level for subrecipients. Completion Date: June 30, 2025 Agency Contact: Kimberley Moore, Director, Bureau of Employment Services, DOL, 207-620-0183

Department: Administrative and Financial Services Title: Internal control over CSLFRF reporting needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The Security and Employment Service Center will review contracts with the agencies to verify the classifications. Completion Date: June 30, 2025 Agency Contact: Marilyn Leimbach, Director, Security and Employment Service Center, DFPS, DAFS, 207-248-2556

Department: Professional and Financial Regulation Title: Internal control over HAF Program subrecipient monitoring needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The Department will continue to engage the services of a third-party vendor for subrecipient monitoring. Completion Date: March 6, 2025 Agency Contact: Rachel Hendsbee, Director Administrative Services Division, PFR, 207-624-8500

Department: Education Title: Internal control over CNC subrecipient monitoring procedures needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The Department will implement a monthly status check of the current tracking tool to ensure compliance with the review The Department will update the current high-risk procedure. The Department will develop a procedure for evaluating base year reviews and add a procedure for timelines for adjustments to the claims. Completion Date: July 1, 2025, September 1, 2025, and June 1, 2025, respectively Agency Contact: Jane McLucas, Director of Child Nutrition, DOE, 207-624-6880

Concur. Due to key vacant positions and the inability to fill these positions, the required subrecipient monitoring activities were not completed during the fiscal year ending June 30, 2024. During the current fiscal year, the County has been successful in recruiting these positions and will ensure that the monitoring activities occur. In addition, policies and procedures will be documented on subrecipient monitoring activities to ensure that they are performed on a regular basis.

Management agrees with the finding. The Office of Sponsored Programs will conduct a review of the subrecipient issuance and monitoring process to ensure that roles and responsibilities regarding the timely monitoring of subrecipients' single audit reports are clear and that any personnel engaged in review of the single audit reports receives training regarding these activities.

2 CFR 1000.10 gives regulatory effect to the U.S. Department of Treasury for 2 CFR 200.332 which states, in part, pass-through entities must ensure every subaward includes requirements that the pass-through entity imposes on the subrecipient in order for the pass-through entity to meet its own responsibility to the Federal awarding agency including identification of any required financial and performance reports. The grant’s pass-through entity is the Ohio Office of Budget and Management (OBM). State Fiscal Recovery Funds K-12 School Safety Grants Frequently Asked Questions require recipient schools to complete quarterly financial status reports via the OBM grants portal until they have spent all funds and completed their projects. The District did not have proper internal controls in place to ensure the accurate completion and submission of the quarterly financial status reports. During testing of quarterly financial status reports for the Coronavirus State and Local Fiscal Recovery Funds (AL #21.027), we noted the quarterly financial status report for the period of July 1, 2023 through September 30, 2023 omitted $360,084 in grant expenditures paid during this period. Failure to have the proper controls in place to ensure the accurate submission of the quarterly financial status reports could result in Treasury taking action against the District for failure to comply with programmatic requirements. The District should implement and have controls in place to ensure the quarterly expenditure reports are accurate.

2024-003 Subrecipient Monitoring Responsible Official Mary Chase, Director of Finance Plan Detail Management plans to complete the fiscal year 2024 monitoring of its subrecipient and review its policies and procedures to ensure future monitoring of subrecipients is completed as least on an annual basis. Anticipated Completion Date The corrective action is in the process of being implemented and expected to be completed in fiscal year 2025.

Views of Responsible Officials: Management acknowledges the comment and, following the fiscal year-end, has implemented internal procedures to evaluate subrecipients. These procedures assess risk levels, determine the scope and frequency of monitoring, and ensure compliance with applicable Federal statutes and regulations.

Views of Responsible Officials and Planned Corrective Actions: We are committed to strengthening our internal controls and procedures to ensure full compliance with Uniform Guidance requirements. We also acknowledge that the audit waiver BRAC Bangladesh received from the USAID Mission in Bangladesh was not sufficient to exempt them from conducting a program-specific audit of the Department of State (BPRM) funded project, SPRMCO23CA0152. In response to the finding, BRAC Bangladesh has already conducted an audit of the project, which demonstrated that the financial statements and schedule of expenditures were free from material misstatements. Moving forward, we will amend our subagreement templates to include specific language around USG audit requirements, and the submission of audit reports will be included in the reporting section of the agreements. We will also update our Fiscal Policies and Procedures Manual to formalize the process for receiving and reviewing audit reports, and establishing follow-up procedures to resolve potential audit findings. We will also maintain clear documentation of the submission, review, and follow up of audits.

Finding No. 2024-002 21.027: COVID - 19: Coronavirus State and Local Fiscal Recovery Funds Personnel Responsible for Corrective Action: Name: Edith Robles Department: Finance Title: Director of Finance Anticipated Completion Date: June 30, 2025 Corrective Action Plan: An adequate subrecipient risk assessment policy will be put in place to evaluate and monitor subrecipients. Southwest Organizing Project will provide subrecipients with all required Federal awards identifiers. Edith Robles will ensure that Federal award identifiers are included in subrecipients grant agreements.

Reference Number: 2024-011 Prior Year Finding: No Federal Agency: U.S. Department of Transportation State Agency: Agency of Transportation Federal Program: Highway Planning and Construction Assistance Listing Number: 20.205 Award Number and Year: FFY2023 – FFY2024 Compliance Requirement: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Recommendation: VTrans should review and enhance internal controls and procedures to ensure that all required federal award information is included in subawards and that on-site subrecipient monitoring is conducted timely per the terms of its subrecipient monitoring plan. Views of responsible officials: Management agrees with the finding. Corrective Action Plan: Missing Federal Award Date: The Contract Administration, Grants Unit addressed the deficiency of missing federal award dates during the FY23 State Single Audit (in effect as of 1/12/2024). As part of the updated award execution process, the Grants Unit now verifies that all awards include the federal award date and applicable FAIN number. Awards executed prior to the implementation of this process are being updated during amendments to ensure compliance. Subrecipient Monitoring: The root cause of the subrecipient monitoring deficiency was staffing shortages, which affected the Agency of Transportations (AOT) ability to meet monitoring requirements on time. The AOT monitoring requirements have been transitioned from the Audit Bureau to the Contract Administration, Grants Unit. The Grants Unit has already identified and will prioritize Subrecipients based on the last date monitored. Workflow modifications to include efficiencies are also in progress. These efficiencies will help with timeliness. The revisions to the monitoring activities will be in the VTrans Granting Plan effective July 1, 2025. Scheduled Completion Date of Corrective Action Plan: All corrective actions will be implemented as of July 1, 2025. Contacts for Corrective Action Plan: Tricia Scribner, Administrative Services Manager III tricia.scribner@vermont.gov

Corrective action plan: N/A Implementation dates: N/A Responsible persons: Tim Urbanovsky, Director of Accounting & Financial Reporting Services

Corrective action plan: During discussions with HOME staff, it was determined that the IDIS system, used by the Single-Family Program division for HUD reporting, generates contract activity reports that should alleviate the discrepancy noted during this review. CMSM has requested read-only access to IDIS in order to generate a risk population. Implementation dates: The Department is pending review and approval of IDIS access for appropriate staff. Upon receiving IDIS access CMSM staff will coordinate with HOME staff for training. CMSM anticipates using IDIS in either the third or fourth quarter of the Department’s current fiscal year depending on HUD’s response. Responsible persons: Earnest Hunt, Director of Compliance Subrecipient Monitoring, Robert Moore, Manager of Compliance Subrecipient Monitoring and Ben Rose, Monitor.

Corrective action plan: TANF: The Early Childhood Intervention program will amend all out of compliance contracts to reflect the correct UEI information prior to end of fiscal year 2025. For each new contract moving forward, Program will update its internal contract development checklist to add an item to confirm the UEI is included and correct. SSBG: New contract development procedures will include updated templates that include the most current federal award requirements, including the documentation of UEI. Implementation dates: TANF: May 30, 2025 SSBG: September 1, 2025 Responsible persons: TANF: Janene Roch, Manager of Contracts and Finance, Early Childhood Intervention SSBG: Amy Pedersen, Director of Contracts, Fiscal and Data Management

Views of Responsible Officials and Planned Corrective Action: Current staff believes the 3 requirements listed above were not performed in the past. For remaining active SLFRF subgrants, ASBO will establish a fraud/risk/noncompliance rating and set appropriate monitoring standards. Should any new applications for SLFRF funding be procured, ASBO will require financial statements and a PE Stamp prior to grant agreement execution. ASBO will provide 2 CFR 200 training and ARC rules training to our staff and contractors. Anticipated Completion Date: April 1, 2025 Contact Person: Glen Howie, Jr. Director, Ark State Broadband Office Department of Commerce 1 Commerce Way Little Rock, AR 72202 (501) 682-1123 Glen.Howie@Arkansas.gov