Corrective Action Plans

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

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.

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

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

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.

CORRECTIVE ACTION PLAN State Fiscal Year Ended June 30, 2024 97.036 Disaster Grants – Public Assistance (Presidentially Declared Disasters) State Agency: NH Department of Safety, Division of Homeland Security and Emergency Management Audit Contact: Austin Brown Title: Chief of Mitigation & Recovery HSEM Telephone: 602-271-2231 E-mail address: NHPA@dos.nh.gov Audit Report Reference: 2024-034, 2023-023 - Subrecipient Monitoring Anticipated Completion Date: April 30, 2025 Corrective Action Planned: HSEM concurs with this finding. The identified issue, where one of the two project award letters did not include language detailing project certification requirements, occurred because the project was incomplete. Historically, programmatic staff did not include certification information in award letters for incomplete projects. Similar to the concerns outlined in finding 2024-002, issues with the award letters were identified and addressed in April/May 2024. The updated award letter template is now used for all projects, regardless of their payment eligibility status at the time of issuance. A copy of the revised award letter template and the award notification fact sheet are attached to this response. The award notification fact sheet was updated in March 2025 and is sent via email upon award notification. It is also available on our website. For the ongoing projects, one of those two projects is still not completed and is on closeout review by FEMA, so a PCCR has still not been received as they have not received their final reimbursement. Programmatic staff will review and update the Quick Reference Guide for PCCRs to ensure compliance and efficiency. Enhancements to the guide will include, at a minimum, copying the shared inbox when sending the final expenditure report to FEMA and saving a PDF copy to the shared drive. Additionally, staff must account for recent changes to the form being hosted on WebEOC, ensuring that a report is requested monthly. Since programmatic staff no longer have direct access to this capability, the revised process must be clearly documented in the Quick Reference Guide. Programmatic supervisors were informed on March 11, 2025, of the need to reinforce internal controls. Remedial training will be provided to programmatic staff upon completion of the guide’s review and update, no later than April 15, 2025. To ensure timely follow-up, calendar reminders will be set for programmatic staff responsible for these tasks, prompting them to send monthly reminder emails for any outstanding PCCRs.

CORRECTIVE ACTION PLAN State Fiscal Year Ended June 30, 2024 Fish and Wildlife Cluster (Assistance Listing #15.605, #15.611, #15.626) State Agency: NH Fish and Game Department Audit Contact: Randy Curtis Title: Federal Aid Administrator Telephone: (603) 271-0801 E-mail address: randy.l.curtis@wildlife.nh.gov Audit Report Reference: 2024-005 – Subrecipient Monitoring Anticipated Completion Date: June 30, 2025 Corrective Action Planned: We partially concur with the finding. A. The Department concurs there were required elements missing from the information included in tested subaward agreements. The Department will develop templates and put in place a process to ensure that all subrecipient agreements contain all required communications. B. The Department concurs and has recently completed and is implementing new internal policies and procedures that address nearly all of the conditions identified in this finding overall. These written policies and procedures were designed to be in compliance with the requirements of 2 CFR Part 200 Subpart D - Subrecipient Monitoring and Management and to establish improved internal controls. The policy includes a process for completing a risk assessment which outlines they types and frequency of monitoring procedures and for documenting their completion. C. The Department partially concurs with this condition. We believe the level of detail included within the invoice was consistent with the terms of the agreements and project budgets and did allow Department staff reviewing the reasonableness of the costs incurred to ensure that they were incurred in accordance with the grant agreement. Additionally, the Department’s updated subrecipient monitoring policies and procedures will provide for testing and requesting detailed backup and support for at least one invoice annually. D. The Department concurs there was no specific evidence denoting approval of the subaward reports. However, Department project leaders do review reports received from subrecipients and typically include them as attachments in our own grant reports to the Fish and Wildlife Service. A step will be added to monitoring procedures to include specific Department approval of subrecipient reports. Further, the Department will include a step for documentation of the receipt and review of subrecipient Uniform Guidance audit reports.

Finding Reference: 2024-009 - Subrecipient Monitoring (UM) Responsible Official: Dr. John Higginbotham, Vice Chancellor of Research and Economic Development Corrective Action Planned: On March 13, 2025, the University of Mississippi issued amendments to notify the two subrecipients that the subawards issued under ALN 95.010 during the fiscal year ended June 30, 2024, were not classified as research and development. The University of Mississippi will ensure that subaward agreements, including all attachments, are reviewed for accuracy by a second party before issuance. Estimated Completion Date: March 13, 2025 Finding Reference: 2024-009 - Subrecipient Monitoring (UMMC) Responsible Official: Mustafa Khawaja, Interim Director of Post-Award Corrective Action Planned: Similar to UMMC’s response on Finding Reference 2024-001, UMMC engaged with a Workday certified consulting firm to review the operational effectiveness of the configuration of Workday, review reports available, and assess processes and procedures. As part of the engagement, this firm also evaluated various operational processes within the contract and grants office. The engagement began in June of 2024 and has made significant changes to Workday to bring operational efficiency into our processes and configurations; as well as, developed reports that identify variances and differences that need to be researched and corrected. The team also corrected reports that were pulling data inaccurately and trained internal UMMC IT staff on how to address system corrections going forward and the methodology to develop/modify IT reports. The firm also revamped our award setup process in Workday and built checklists along with Standard Operating Procedures that bring efficiencies and accuracy into our Award setup process. We also built in roles for review of an award at the time of setup to ensure that errors are quickly identified and corrected in the system. The firm also provided Workday training sessions to help us understand how the different fields are supposed to be utilized, especially in cases where UMMC is either a subrecipient or has a subaward with a different institution. Estimated Completion Date: June 30, 2025

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.

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.

Program: AL 97.036 – Disaster Grants – Public Assistance (Presidentially Declared Disasters) – Subrecipient Monitoring Corrective Action Plan: NEMA has implemented a process, effective immediately, to review the information submitted by subrecipient organizations regarding their 2 CFR Single Audit Certification. Responses will be cross-referenced with our own records of Federal funds passed through NEMA to the subrecipient. Any subrecipient responding that it was not required to conduct a single audit will prompt NEMA to validate against payment data. Any subrecipient’s noncompliance will be followed up by NEMA staff. Contact: Erv Portis Anticipated Completion Date: February 11, 2025

Career and Technical Education Response/Corrective Action Plan: The department agrees with this recommendation The department has developed a system to identify which subrecipients are subject to required audits and are tracking subrecipients to ensure timely submission of required audit reports and appropriate corrective actions. Contact Person: Wayde Sick, Director and Executive Officer and Gwen Ferderer, Finance Director Anticipated Completion Date: August 2024

PDOA: 1. Designing a means to follow-up and ensure timely action of deficiencies through an audit tracking log to monitor reporting submissions, document when they were received, initiated, findings requiring follow-up, and subsequent steps to finalize the audit. 2. Management decisions for applicable findings will be issued and tracked. 3. Improvements have been made with regards to regularity in reporting to more effectively monitor activities of subrecipients consistently with respect to Federal statutes and regulations. 4. PDOA is looking to fill a vacant position with a focus of tracking subrecipient expenditures in the aggregate and tracking single audit submissions on a Commonwealth-wide basis since the Aging Cluster program is material and has material sub-granted expenditures in NSIP and Title III. 5. It is PDOA’s impression that having increased oversight of the SEFA will allow for timely dissemination of management decision letters (MDL) in the six-month timeframe for making a management decision for federal award findings. 6. Discussions have started regarding considerations to take enforcement action against noncompliance by building language into the terms and conditions of the Cooperative Block Grant Agreements to exercise ability to withhold funding as approved in the Cost Allocation Plan. 7. PDOA has reached out to the BAFM to verify all outstanding audit items for PDOA since action is required within six months of receipt. 8. Follow-up procedures resulting from this finding will be reviewed and adjusted as needed to deliver optimal outcomes. Anticipated Completion Date: 06/30/2025 Contact Name: Jennifer Cave, Fiscal Management Specialist, PDOA Audit Liaison PDA: PDA has added a Financial Management Specialist 1 (FMS1) to its complement with the primary duty of agency audit liaison. The FMS1 will report to the PDA’s Budget Office. This is a new position and role within the department and has training and certification requirements to complete which will allow the position to: 1. Evaluate single audit report submissions received from BAFM to determine program purpose acceptability by verifying, at a minimum, that all agency-funded programs are properly included on the applicable financial schedules; that findings affecting the agency contain sufficient information to facilitate a management decision; and that the subrecipient has submitted an adequate corrective action plan. 2. Issue management decisions relative to audit findings and crosscutting findings assigned to the agency for resolution, as required by 2 CFR §200.521. If responsible for the resolution of crosscutting findings, notify the affected agency or agencies upon resolution of such findings. 3. Impose or coordinate the imposition of remedial action in accordance with 2 CFR Part 200.339 and Management Directive 325.08 Amended, Remedies for Recipient Noncompliance with Audit Requirements, when subrecipients fail to comply with the provisions of Subpart F. The new FMS1 will help ensure effective and efficient audit resolutions. This newly created position will also be responsible for the department wide audit tracking log that is in development. Anticipated Completion Date: 06/30/2025 Contact Name: Nichole Nedinsky, Fiscal Management Specialist, PDA Audit Coordinator PDE: The PDE Audit Section is working with divisions to develop processes to ensure timely responses. A training will be conducted by April 2025 on audit procedures, best practices, and federal regulations governing single audit management decisions. Anticipated Completion Date: 04/30/2025 Contact Names: Clayton P. Carroll II, Audit Coordinator; Jessica Sites, Director, Bureau Financial Operations DEP: DEP has updated the concur subrecipient letter to include the specific language related to the management decision that was previously in our non-concur letters. This ensures whichever template is used, the management decision and related finding information will be included in the subrecipient letter. Revised letters were sent to both subrecipients, in which DEP was the lead agency and had findings for in the audited timeframe. Staff are reviewing all the steps of our standard operating procedures to ensure we will be in compliance regardless of whether DEP is or is not the lead agency and regardless of whether we are preparing a concur or non-concur letter for the subrecipient. Anticipated Completion Date: 06/30/2025 Contact Names: Jennifer Brandt, Senior Fiscal Mgmt. Specialist; Kristen Szwajkowski, Lead Fiscal Mgmt. Specialist DHS: As stated in the DHS finding response, this was the result of human oversight, and not a systemic issue with internal controls. We have reminded staff to make sure that a management decision is timely communicated to subrecipients at the time of making the management decision. Anticipated Completion Date: Completed Contact Names: David Bryan, Mgr., Audit Res. Section; Alexander Matolyak, Dir., Div. of Audit & Rev.

To ensure fiscal compliance and operational efficiency, grant activities will undergo enhanced monitoring through the addition of monthly reviews of review revenue and expense recognition, regular comparisons against budget and award terms, and provide targeted training for new grant managers and accounting staff on expenditures to meet grant spend down schedules. This finding relates to one legacy grant.

Type of Finding: Material Weakness in Internal Control Over Compliance, Other Matters Condition: Kansas Division of Emergency Management (Management) did not track, determine or monitor the audit verification requirement for its subrecipients in a timely manner. Recommendation: We recommend that the agency review its procedures for monitoring of annual audits for subrecipients to ensure that subrecipients are audited in accordance with Subpart F timely. We recommend that a clear timeline and tracking for this monitoring be added to the policies and procedures. Views of responsible officials: Management does not agree with this finding. Action taken in response to finding: Explanation of disagreement with audit finding: • KDEM manages the grant expenditures during the entire lifespan of the project. Scope of work is matched with actual expenses and validated before sending to FEMA for close-out. • KDEM’s audit tracker identifies when audit letters were sent and can be verified through email verification sent to sub-recipients. • There is no regulation stipulating what is “timely”. KDEM verifies audits annually. Name(s) of the contact person(s) responsible for corrective action: Jennifer Deal, Fiscal & Grants Management Section Chief Planned completion date for corrective action plan: See above.

Finding: The Foundation is not in compliance with recordkeeping for program monitoring and evaluation, as the Foundation did not comprehensively assess all subrecipients using risk-based/subrecipient monitoring policies and procedures. Staff were not aware of the extent of the requirements to monitor program and fiscal compliance of project sponsors and document results and evidence of compliance or noncompliance. Therefore, a number of project sponsors/subrecipients were not monitored. Corrective Action Taken or Planned: The Foundation has updated its Quality Management Plan to include comprehensive subrecipient monitoring policies. The Foundation’s Quality Management team is working with all programming to implement a robust monitoring process, including risk assessments, adherent to grantor regulations, service delivery, and program outcomes. Date of Completion: January, 2024 Name of Contact Person: Laurie Wettstead, Chief Finance Officer

The Institution is aware of the deadline and will be filing on time going forward.

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 ongoing issue in the futur

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 ongoing issue in the future.

• The Fiscal Director position has not been continuously filled, and since COVID 19 it has proven difficult to hire qualified staff at the rate of pay offered by the Agency . The Fiscal Director is responsible for providing training and supervision to staff, and for completing such tasks as working with our Auditors and scheduling the annual audit. The Organization has hired a CFO for hire however, there are still sometimes difficulty in maintaining steady work flow, meeting deadlines and ensuring year end closing entries and reconciliations are completed timely. In addition, the Auditors contracted with the Agency have begun their reviews much later than they had pre-Covid, also lending to difficulty in meeting deadlines. • Community Action of Greene County Inc. will work to improve employee retention and engagement through coaching, training, wage equity, and improved Human Resource practices. • Community Action of Greene County Inc. will continue to incorporate automated accounting and payroll processes to improve the efficiency and accuracy of fiscal reporting. • A year end closing checklist and calendar has been developed and utilized by the fiscal staff as of Spring 2024. The completed checklist will be shared with the Executive Director following the close out period. • The Executive Director will schedule the Auditors to begin their reviews within 90 days of year end as a condition of their contract. • The Executive Director is responsible for ensuring this corrective action plan is implemented.

The Office of Mental Health (OMH) has updated the federal certification forms in March of 2022 for the MHBG COVID Relief and ARPA awards to include the following award identification information: federal fiscal year of award, federal award period, federal award identification number (FAIN), and federal award document number. The federal certification forms for the annual MHBG awards are created to align with each new Notice of Award (NOA) and include the same award identification information noted above. Due to the timing of when we received the Federal NOA’s in comparison to when the federal certification forms were distributed to sub-recipients, not all sub-recipients may have received the updated form in fiscal year end March 31, 2024. These revised forms were used for all subrecipients in SFY 2024-25. OMH will continue to amend the certification and applicable policies, procedures, and internal controls to incorporate all required identifying characteristics outlined in 45 CFR 75 Section 352 (a) in SFY 2024-25. Additionally, OMH initiated an expense report process to review award specific expense reports for all COVID Relief and ARPA federal grant subrecipients to ensure provider expenditures are following federal guidelines. This process will be rolled out to the other MHBG awards in SFY 2024-25. While a formalized risk assessment was not conducted, one has been developed to assess subrecipient risk of non-compliance. This risk assessment will be used in conjunction with the review of reward 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 subrecipients single audit submissions during the upcoming review cycle.

2024-001 – Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2024 Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Management acknowledges that certain subrecipient Uniform Guidance reports for subrecipients were not reviewed. As noted, 1 of the 25 selections tested was not included in the Post-Award review of subrecipient Uniform Guidance reports. Following a comprehensive review, 12 subrecipients were identified as inadvertently omitted from the overall report data used to conduct the subrecipient Uniform Guidance report analysis for the year ended June 30, 2024. After identification of the missing subrecipients and completed prior to the issuance of this report, the University reviewed the 12 respective entities’ Uniform Guidance reports or appropriate documentation and determined that there was no impact on Tufts University and no follow-up was deemed necessary. By June 30, 2025, and on an annual basis, the University’s Post-Award office will utilize automated reports including the complete data set to review all subrecipient Uniform Guidance reports, consistently document report information, findings noted, and follow-up performed with the subrecipient, if necessary. The consolidated analysis will be reviewed by the Director of Post-Award Research Administration and the University Controller.

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 ongoing issue in the future.

Condition - The data collection form was not submitted within the required time as required by 2 CFR 200.512 for the year ended June 30, 2023. Planned Corrective Action - 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 ongoing issue in the future. Anticipated Completion Date: November 15, 2024 Point of Contact: Mary Ann Johnson

Finding No.: 2023-050 AL Program: 97.036 – Disaster Grants – Public Assistance (Presidentially Declared Disasters) COVID-19 97.036 Disaster Grants – Public Assistance (Presidentially Declared Disasters) Area: Subrecipient Monitoring Questioned Costs: $7,350,898 Contact Person(s): Patrick Guerrero, Governor’s Authorized Rep., PAO Corrective Action Plan: Condition 1-2: The CNMI Public Assistance Office (PAO) acknowledges and agrees with the compliance deficiencies identified regarding subrecipient monitoring and documentation requirements under 2 CFR §200.332 and has developed corrective actions to address these weaknesses. However, PAO respectfully disagrees with the questioned cost determination. The finding relates to deficiencies in monitoring procedures and documentation rather than the allowability, eligibility, or support for the underlying expenditures. The expenditures identified were associated Finding No.: 2023-050, continued AL Program: 97.036 – Disaster Grants – Public Assistance (Presidentially Declared Disasters) COVID-19 97.036 Disaster Grants – Public Assistance (Presidentially Declared Disasters) Area: Subrecipient Monitoring Questioned Costs: $7,350,898 Contact Person(s): Patrick Guerrero, Governor’s Authorized Rep., PAO Corrective Action Plan: with FEMA-approved projects and no specific costs were identified as unallowable, unsupported, outside the approved scope of work, or otherwise ineligible for federal participation. While PAO recognizes that monitoring documentation was insufficient to demonstrate compliance with subrecipient monitoring requirements, PAO believes the appropriate classification is a compliance finding without questioned costs. Accordingly, PAO respectfully requests consideration that questioned costs associated with this finding be reduced to $0. Subrecipient monitoring activities were historically performed alongside project management responsibilities and were not supported by a centralized tracking system. As the number and complexity of Public Assistance projects increased, monitoring activities, documentation, and audit follow-up procedures were not consistently performed or documented. In addition, delays in the completion of CNMI-wide Single Audits and limited responsiveness from certain subrecipients affected PAO's ability to obtain timely financial reports, audit reports, and supporting documentation. PAO is implementing corrective actions in phases to establish a sustainable and documented subrecipient monitoring framework. Phase I – Immediate Actions (Completed/In Progress) • Responsibility for subrecipient monitoring activities has been assigned to the Compliance Manager and Risk Officer to provide dedicated oversight independent of project management functions. • PAO has begun conducting biannual subrecipient risk assessments and documenting risk ratings for active subrecipients. • For nonresponsive subrecipients, PAO will maintain documentation of all attempts to obtain required information and will perform additional follow-up as appropriate. These records will be maintained as evidence of monitoring activities and due diligence. • Standardized monitoring checklists, risk assessment forms, audit review checklists, and follow-up procedures are being developed to improve consistency and documentation. Finding No.: 2023-050, continued AL Program: 97.036 – Disaster Grants – Public Assistance (Presidentially Declared Disasters) COVID-19 97.036 Disaster Grants – Public Assistance (Presidentially Declared Disasters) Area: Subrecipient Monitoring Questioned Costs: $7,350,898 Contact Person(s): Patrick Guerrero, Governor’s Authorized Rep., PAO Corrective Action Plan: • PAO will initiate a centralized tracking process using existing tools, including Excel spreadsheets and shared electronic files, to monitor: o Subrecipient risk assessments. o Financial and performance report submissions. o Single Audit report status. o Monitoring activities performed. o Corrective actions and follow-up requirements. o PAO will continue to document requests for financial reports, audit reports, risk assessment information, and other monitoring documentation. Supporting records, including request emails, follow-up correspondence, meeting invitations, telephone call logs, and responses received from subrecipients, will be retained to demonstrate monitoring efforts and follow-up actions. Phase II – Process Formalization • PAO will finalize written updates to the Subrecipient Monitoring Procedures establishing requirements for: o Risk assessments. o Monitoring frequency. o Financial and performance report reviews. o Single Audit follow-up. o Documentation retention. o Escalation procedures for nonresponsive subrecipients; and o Management review. • PAO will establish a formal Subrecipient Monitoring Register that consolidates monitoring activities, risk ratings, audit status, corrective actions, compliance deadlines, and follow-up actions. • Quarterly management reviews will be implemented to monitor completion of required monitoring activities, assess high-risk subrecipients, and address outstanding compliance issues. • PAO will establish formal procedures to review subrecipient Single Audit reports, verify reporting of FEMA-funded expenditures on the SEFA, document audit reviews, and track corrective actions resulting from audit findings. Finding No.: 2023-050, continued AL Program: 97.036 – Disaster Grants – Public Assistance (Presidentially Declared Disasters) COVID-19 97.036 Disaster Grants – Public Assistance (Presidentially Declared Disasters) Area: Subrecipient Monitoring Questioned Costs: $7,350,898 Contact Person(s): Patrick Guerrero, Governor’s Authorized Rep., PAO Corrective Action Plan: Phase III – Compliance & Monitoring Portal (Future Implementation) • Upon acquisition and implementation of Microsoft 365 resources, PAO will develop a centralized Compliance & Monitoring Portal to serve as the official repository for subrecipient monitoring records. • The portal will include electronic tracking of risk assessments, monitoring activities, audit findings, corrective actions, reporting deadlines, communication logs, and supporting documentation. • Automated reminders, management dashboards, workflow tracking, and document retention controls will be incorporated to strengthen oversight and improve monitoring documentation. These corrective actions will establish a documented, risk-based monitoring framework that improves oversight of subrecipients, strengthens documentation and audit trails, formalizes monitoring procedures, enhances accountability through dedicated compliance personnel, and improves compliance with the requirements of 2 CFR §200.332. Phase I – Ongoing Phase II – June 30, 2027 Phase III – Upon acquisition and implementation of Microsoft 365 resources and completion of staff training. Proposed Completion Date: June 30, 2027 (For Phase II). Phase I & II is Ongoing.