Corrective Action Plans

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

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.