Corrective Action Plans

FINDING 2025-003 Finding Subject: Teacher and School Leader Incentive Grants – Subrecipient Monitoring Contact Person Responsible for Corrective Action: Chris Gearlds, Assistant Superintendent Contact Phone Number and Email Address: (317) 856-5265; cgearlds@decaturproud.org Views of Responsible Official: We concur with Audit Finding Description of Corrective Action Plan: The Teacher and School Leader Incentive Grant was completed during the audit period and the school district does not plan on receiving this award in the future. Therefore, further corrective action is not required and district officials will utilize this information to ensure compliance in other federal awards. Anticipated Completion Date: February 1, 2026

Finding #2025-002 (Late Submission to the Federal Audit Clearinghouse) Responsible Party: Sara Hudson & JCCS PC Anticipated Completion Date: Septemer 1, 2025 (Implemented) Corrective Action Planned: Snowy Mountain Development Corporation has engaged a new audit firm and strengthened management oversight of the audit process and related submission deadlines. Management now actively monitors audit progress, coordinates required deliverables, and tracks federal filing deadlines to ensure timely submission to the Federal Audit Clearinghouse. These procedures have been implemented for the fiscal year ending June 30, 2026. Management anticipates that future Single Audit reports will be completed and submitted in compliance with applicable federal requirements.

Finding 2025-010 U.S. Department of Housing and Urban Development (HUD) AL No. 14.241 Housing Opportunity for Persons with AIDS Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2024-014 Auditee’s Corrective Action Plan: MOHS will enhance and formalize subrecipient monitoring procedures to ensure full compliance with Uniform Guidance requirements. Subrecipient agreement templates will be revised to require inclusion of the subrecipient’s Unique Entity Identifier (UEI) and Federal Award Identification Number (FAIN) for all subawards, in accordance with 2 CFR §§25.300 and 200.332. MOHS has previously developed subrecipient risk assessment and monitoring tools for the Continuum of Care (CoC) program. These tools and procedures will be reviewed, updated as needed, and expanded to apply to all MOHS grants, including HOPWA. This includes documented risk assessments, monitoring plans, and verification that required Single Audit reports are obtained, reviewed, and retained when applicable. MOHS will maintain centralized subrecipient monitoring files containing executed agreements, audit reviews, monitoring documentation, and follow-up actions. Program and fiscal staff will receive training on updated subrecipient monitoring policies and documentation standards to ensure consistent implementation across all funding sources. MOHS will utilize the GMO’s subrecipient monitoring templates provided on their centralized SharePoint platform which include risk assessments, reporting forms, expenditure forms, and metrics forms to ensure all required subrecipient monitoring reporting is completed. Additionally, MOHS will require all grant staff to attend GMO monthly trainings and quarterly grant monitoring meetings to ensure subrecipient monitoring is being conducted and completed. MOHS will also require all grant staff to familiarize themselves with Administrative Manual policy 413-51 Subrecipient Monitoring and Management, which specifies all city-wide requirements for subrecipient monitoring. MOHS will maintain copies of all subrecipient monitoring documents in Workday, the City’s financial system. Contact Person: Sade Creighton-Wade, Chief of Fiscal Services Completion Date: September 30, 2026

Management agrees with the auditor’s finding 2025-01 Subrecipient Monitoring – Audit Verification. The following action will be taken to ensure that the Subrecipient complies with the single audit requirement: • The Finance Director, Kristie Howell, will correspond with the Subrecipient, Grassy Pond Water Company, to clearly state the single audit requirement and due dates. • Cherokee County will request written correspondence from the subrecipient, outlining their course of action and timeline to complete the single audit. • Cherokee County will follow-up with Grassy Pond Water Company on a bi-weekly basis until the 2024 single audit has been submitted, and monthly to ensure that the 2025 audit is being completed as well. • All correspondence will be documented.

State Agency: Office of Mental Health Program Name: Block Grants for Community Mental Health Services ALN #: 93.958 Single Audit Contact: April Wojtkiewicz Title: Director, Office of Community Budget & Financial Management Telephone: (518) 474-5968 E-mail Address: April.Wojtkiewicz@omh.ny.gov Audit Report Reference: 2025-009 Anticipated Completion Date: 3/31/2026 Corrective Action Planned: Office of Mental Health (OMH) updated policies and procedures regarding subrecipient monitoring in March 2025 and will continue to update the federal certification form annually to ensure that all required award identification information is included. Further, OMH initiated an expense report process to review award specific expense reports for the Mental Health Block grant in SFY2024-25. Additionally, while a formalized risk assessment was not conducted, one has been developed to assess subrecipient risk of noncompliance. This risk assessment will be used in conjunction with the review of award specific expense reports to determine those subrecipients that need additional monitoring. Applicable policies and procedures will be updated as appropriate upon completion. Lastly, OMH has adopted a tracking mechanism that will be used to track and review all subrecipient single audit submissions during the upcoming review cycle.

2025-003 Lack of Formal Subrecipient Monitoring Criteria: According to 2 CFR §200.332 (Requirements for Pass-Through Entities), a pass-through entity must monitor the activities of subrecipients as necessary to ensure that federal funds are used for authorized purposes and in compliance with applicable statutes, regulations, and terms and conditions of the Federal award. Required monitoring includes, but is not limited to, the following: a. Reviewing financial and programmatic reports; b. Performing risk assessments of subrecipients; c. Following up on deficiencies identified through audits or reviews; and d. Ensuring subrecipients have required audits under 2 CFR §200.501. Lack of documented subrecipient monitoring constitutes noncompliance with Uniform Guidance. Client Response: While the organization was in constant contact with subrecipients regarding the progress of their programming, those meetings were not transcribed. In the future, the organization will require mid year and year-end impact reports from each grant subrecipient. Proposed Implementation Date – 12/31/2025 Name of Contact Person – John Edwards, Sr. Email: jledwards@umadaop.org Phone: 419-255-4444

2025-001 Audit Submissions the Federal Audit Clearinghouse - Significant Deficiency The audit was submitted on time this year, demonstrating that Opportunities, Inc. has addressed the system gaps that affected last year's submission. The corrective action established clear communication points during the audit process and ensured all timelines were followed. Opportunities, Inc. remains dedicated to upholding the highest standards of fiscal responsibility and regulatory compliance.

Finding Reference: 2024-004 Views of Responsible Officials and Planned Corrective Actions The Agency agrees with this finding and recommendation as presented. In some contexts, the Agency experienced significant turnover in the Finance department during the third quarter, and a new Finance Director was hired during the fourth quarter of fiscal year 2024. The turnover in fiscal staff hindered the accounting processes and oversight that included journal entry review and postings and account reconciliations promptly. As a corrective measure to ensure adhering to a closing schedule and maintaining timely account reconciliations, the Agency reevaluated the fiscal department’s needs and hired new staff, including a finance director, accounts payable, part-time fiscal support specialist, and contracted with a CPA to assist with the following scope of work:  Review all trial fund balance processes.  Prepare a closing schedule that includes reporting and data processing deadlines.  Reconcile all balance sheet accounts in the general ledger chart of accounts.  Timely prepare and file all financial reports required by each award.  Work with the independent auditor to implement an interim audit fieldwork schedule to reduce required work subsequent to fiscal year-end. Name of the contact person responsible for corrective action: Michael Young, President, (301) 274-4474. Planned completion date for corrective action plan: December 31, 2025

Views of Responsible Officials and Planned Corrective Actions We acknowledge the finding regarding the delayed submission of the FY 2024 Single Audit Report to the Federal Audit Clearinghouse, and we appreciate the opportunity to provide our explanation and corrective action plan. To address this finding and prevent future recurrence, the following corrective actions have been initiated: Hiring of CFO Replacement: A qualified replacement for the Chief Financial Officer has been identified and is currently in the final stages of the hiring and onboarding process. This individual will assume responsibility for financial oversight, including audit preparation and timely submission of compliance reports. Interim Oversight and Delegation: In the interim period, the duties previously overseen by the CFO have been temporarily assigned to the Controller and Chief Executive Officer, with close coordination with the Finance Committee of the Board. This ensures proper oversight and continuity of compliance functions during leadership transition. Revised Internal Calendar and Milestone Tracking: An internal compliance calendar is being updated to reflect all critical reporting deadlines, including those under Uniform Guidance. Key deliverables (e.g., SEFA preparation, audit milestones, report reviews) will be tracked and monitored monthly by management to ensure deadlines are met. Enhanced Communication with Auditors: Management will work closely with external auditors to formalize an earlier schedule for yearend fieldwork, allowing for earlier identification of issues and timely resolution to support ontime audit completion. We have determined that the year-end single audit must start no later than January 31of the end of the year. Internal Controls Improvement: Hillcrest is enhancing its internal control framework (aligned with COSO standards) by documenting audit preparation procedures and establishing written protocols for contingency planning in the event of future staff turnover. Hillcrest Children and Family Center is committed to strong financial management, regulatory compliance, and transparency in all its operations. We view this incident as an isolated disruption resulting from an unanticipated leadership transition and are taking proactive steps to strengthen our internal processes. We are confident that the corrective actions outlined above will ensure timely audit completion and reporting in future years. Name of the contact person responsible for corrective action: Carroll Parks, Chief Executive Officer Planned completion date for the corrective action plan: The corrective action plan is currently active and will be moving forward.

Finding 2024-003 - Subrecipient Monitoring Contact Person Responsible for Corrective Action: Danny Yost Contact Phone Number: 812-285-6221 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The County will obtain all subrecipient audit reports and formally document their review of each subrecipient's audit report. Anticipated Completion Date: October 2025

Finding Reference Number: 2024-002 Condition Found: The Organization expended more than $750,000 in federal awards during the fiscal years ended December 31, 2022 and December 31, 2023, but did not have Single Audits performed for those periods. Recommendation: The auditors recommend the Organization establish procedures to monitor annual federal award expenditures and ensure timely compliance with Single Audit requirements. Corrective Action Planned: Management acknowledges that the Organization did not comply with the Single Audit Act requirements for the fiscal years ended December 31, 2022, and December 31, 2023. This was due to a lack of awareness regarding the Single Audit threshold requirements. The Organization has taken the following corrective actions: 1. Quarterly Review of Federal Expenditures: Internal procedures have been implemented to review federal expenditures quarterly to determine whether the Single Audit threshold of $750,000 (increased to $1,000,000 for fiscal year 2025) has been met. 2. Designation of Compliance Officers: The Director of Accounting and the Director of Finance have been designated as responsible for monitoring compliance with 2 CFR §200.501 and ensuring auditors are engaged annually. 3. Compliance Calendar: A compliance calendar has been established to track key federal filing deadlines, including submission of the Data Collection Form and reporting package to the Federal Audit Clearinghouse. 4. Agency Notification: The Organization will contact the relevant federal awarding agencies to inform them of the missed audits for 2022 and 2023 and to seek guidance on any required remedial actions. Responsible Contact Person: Nikel Davis, Director of Accounting Anticipated Completion Date: October 15, 2025

FINDING 2024-003 Finding Subject: COVID 19 Coronavirus State and Local Fiscal Recovery - Subrecipient Monitoring Contact Person Responsible for Corrective Action: Gretchen Parker Contact Phone Number and Email Address: 765-648-6113 gparker@cityofanderson.com Views of Responsible Officials: "We concur with the finding." Description of Corrective Action Plan: The city has several individuals involved in the monitoring of activities related to the COVID 19 Coronavirus State and Local Fiscal Recovery federal award. The city has implemented procedures to ensure oversight and review of subrecipient reports is properly documented. Anticipated Completion Date: September 1, 2025

CORRECTIVE ACTION PLAN July 10, 2025 Cognizant or Oversight Agency for Audit The Praxis Project, Inc. (the Organization) respectfully submits the following corrective action plan for the year ended December 31, 2024. Name and address of independent public accounting firm: AAFCPAs, Inc. 50 Washington Street Westborough, MA 01581 Audit period: January 1, 2024 - December 31, 2024 The findings from the July 10, 2025 Schedule of Findings and Questioned Costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS-FEDERAL AWARD PROGRAMS AUDITS 2024-001 Schedule of Federal Awards Management Recommendation: We recommend that the Organization implement formal procedures to regularly track and monitor cumulative Federal expenditures across all departments, projects and programs. This should include a centralized review process on at least a quarterly basis to assess whether the Single Audit threshold is approaching or exceeded. Procedures should be updated to include: · Establishing a formal process to track all Federal awards on an ongoing basis, including grant numbers, Assistance Listing Numbers (ALNs), contract periods, award amounts, and qualifying expenditures. · Calculating Federal expenditures based upon expenses incurred rather than cash received or invoiced. · Assigning responsibility to a specific individual or department for maintaining the SEFA throughout the year. · Implement quarterly monitoring procedures to track cumulative Federal expenditures and proactively assess whether the Single Audit threshold is likely to be met. · Ensure that program managers and finance personnel are regularly trained to understand the reporting, compliance and audit requirements tied to Federal awards. Implementing these steps will improve the Organization's ability to meet Federal reporting deadlines and meet compliance and audit requirements. 2024-001 Schedule of Federal Awards Management (Continued) Action Taken: In response to the finding, we are taking the following corrective actions: · Effective June 24, 2025, the finance department will implement a standardized process for tracking all Federal awards. · We will ensure that all Federal expenditures are tracked and reported on an incurred-expense basis. · The responsibility for maintaining and updating the SEFA will be formally assigned to the Assistant Director of Finance. · Beginning in the next fiscal quarter, the finance team will conduct quarterly reviews of cumulative Federal expenditures to proactively assess our proximity to the Single Audit threshold. Findings will be documented and reviewed by the Sr. Director of Finance. · We will ensure program managers, finance personnel, and the FS Team are aware and understand Federal compliance, reporting requirements, and audit thresholds. We believe these actions will significantly strengthen our compliance framework, enhance transparency, and ensure that the Organization remains fully prepared for future audits.

Finding 2024-001: Significant Deficiency - Audit Completion and Submission to the Federal Government Compliance Area: Reporting (L) Based on the finding in the fiscal year 2023 audited financial report, the county commissioners set aside $100,000 in their budget to hire or contract with a CPA to assist with audit preparation. This was in addition to $30,000 set aside in the county treasurer's budget for audit consulting. The county commissioners hired an individual in September 2024. That individual left employement with the county in November 2024 and the position was not refilled through the end of fiscal year 2025. The remainder of the FY2024 audit preparation was completed in-house. Due to reductions in revenue and budget constraints, both the $100,000 allocation for a new employee and the $30,000 for consulting services were cut from the commissioners' and treasurer's budgets, so the county is pivoting on audit preparation resposibilities and expanding the number of in-house employees working on different facets of the preparation. With the exception of the CPA that was on staff for two months, the rest of the finance staff has been stable for at least two years and have grown in their knowledge of county finances. We are utilizing 6-7 different staff members on parallel tasks with oversight and assistance from the county treasurer and clerk. We are confident that the audit preparation for FY2025 will be completed months earlier such that trial balances and supporting documentation will be available to our auditors in time to meet the federal submission deadline.

The County’s Corrective Action Plan to address the condition is to put controls in place to ensure subaward agreements are current and include all required information, required information is provided to the subrecipient at the time of award issuance, subrecipients have a UEI, monitoring activities are conducted in accordance with the subaward agreement, and subrecipient risk assessment and audit verification is documented.In addition, finance personnel will be provided with the proper education and training to ensure proper monitoring procedures are being followed.The County is in the process of finalizing an updated subaward agreement that includes all required information. The subrecipient has obtained the proper UEI.The County Auditor, Michelle Samford, will be responsible for ensuring that the Corrective Action Plan is implemented. The anticipated completion date is December 31, 2025.

Response to the Audit Findings FY 2024 Name of the Contact Person Responsible for Corrective Action: Abraham Mock, Executive Director Planned Corrective Action The Buffalo Senior Center recognizes the importance of meeting federal audit submission deadlines. To address this issue and prevent recurrence, we have implemented the following corrective actions: - Created an internal compliance calendar that includes all federal reporting and audit submission deadlines. - Scheduled earlier year-end closeout and reconciliations, with internal deadlines two months prior to the federal deadline. - Allocated additional staff time and resources during year-end to ensure timely preparation of financial and grant documentation. - Established a formal review and submission process with our auditors to ensure all necessary docuemtnation is delievered at least 60 days prior to the submission deadline. - Assigned direct oversight of audit coordination to the Executive Director, with monthly pregress check-ins from July through September. These steps are designed to eliminate delays and ensure full compliance with the 9-month federal submission deadline going forward. Management's Agreement or Disagreement with the Finding Management agrees with the finding. We acknowledge the delay in providing audit documentation and are committed to improving our reporting timeline and internal coordination to ensure timely submission in the future.

Identifying Number: 2024-006 Corrective Actions Taken or Planned: Finding: 2024-006 Agency: internal Name of contact person and title: Keith Olson, Central Accounting Manager Anticipated completion date: Effective immediately / June 2025 Agency’s response: Concur: We agree with this finding. The Central Accounting team will obtain detailed reporting data and request supporting documentation from subrecipients to reconcile/review expenses annually.

Finding 2024-028 Coronavirus State and Local Fiscal Recovery Funds, ALN 21.027 - Subrecipient Audits Management Views For part a., LEO agrees with the finding. All three of MSF’s subrecipient awards for the fiscal year were sampled totaling approximately $274,000 (0.3 percent of the total award). While MSF agrees with the finding that it did not have a written process to verify single audit compliance, management believes that MSF’s risk assessment of subrecipients adequately determined that single audit verification was not required for two of its subrecipients since, based on all anticipated federal awards for the subrecipient, it was not expected that they would reach the expenditure threshold (2 CFR 200.332(f)). The third annually files a single audit, was expected to file a single audit, and did file a single audit. For part b., EGLE agrees with the finding. Planned Corrective Action For part a., the LEO Internal Controls Unit (LEO-IC) will expand LEO’s subrecipient monitoring function for the Coronavirus State and Local Fiscal Recovery Funds and update procedures to include sending an inquiry to subrecipients to determine whether they meet the requirements for a single audit, ensuring that audits are received and reviewed, and issuing management decision letters (when applicable). LEO-IC will train staff on the new procedures and is in the process of hiring another individual to assist with subrecipient monitoring. MSF completed its risk assessment in November 2024 and determined it necessary to update the existing process. On March 4, 2025, MSF implemented an updated process to notify subrecipients of single audit requirements and require feedback on the status of the funding. A Single Audit Certification letter is sent to all subrecipients via email and requires a response to whether a single audit would be required for the fiscal year. The response is then documented and MSF will review the single audits for all subrecipients for which an audit is required to be completed. For part b., the EGLE Budget unit within the Finance Division has assigned responsible staff and began reviewing single audits of applicable subrecipients for fiscal year 2024 activity and will be fully compliant for this subrecipient monitoring cycle and moving forward. Anticipated Completion Date a. LEO: August 31, 2025 MSF: Completed b. EGLE: Completed Responsible Individual(s) a. Christopher Blondell, LEO Allen Williams, LEO Gregory West, MSF Christine Whitz, MSF Lori Mullins, MSF David Meninga, MSF b. Jon Doyle, EGLE Daniel Lance, EGLE

The audit for the year ended June 30, 2023 was not submitted to the Federal Audit Clearinghouse due to issues with the UEI numbers not being renewed timely on the Academy's side. The Finance Director is now responsible for the renewals going forward, and this will not be an issue 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 2024-028 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 2024-014 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

Condition: The Township engaged a contractor to perform procurement activities funded by the revenue loss component of their Coronavirus State and Local Fiscal Recovery Funds award and did not have controls in place to ensure that the contractor was following the Township's procurement policy related to, specifically checking and ensuring vendors were not suspension and debarred prior to the Township entering into the agreements with the contractors. Planned Corrective Action: As part of the procurement process, the Township will require all contractors to provide documentation verifying that neither they nor their subcontractors are suspended or debarred from conducting business with federal agencies. This verification will be conducted through the federal System for Award Management (SAM.gov). To ensure compliance, procurement files will include printed or electronically saved screenshots from SAM.gov confirming the status of each contractor and subcontractor at the time of the contract award. Contact person responsible for corrective action: Wendy Hillman Anticipated Completion Date: 12/31/2025