Corrective Action Plans

Program: Various, including AL 84.027 – Special Education Grants to States; AL 84.173 – COVID-19 Special Education Preschool Grants; AL 84.425D – COVID-19 Education Stabilization Fund – Elementary and Secondary School Emergency Relief Fund (ESSER I and ESSER II); AL 84.425U – COVID-19 Education Stabilization Fund – American Rescue Plan – Elementary and Secondary School Emergency Relief Fund (ARP ESSER) – Subrecipient Monitoring Corrective Action Plan: First SPED subrecipient – As education subrecipients have had a significant influx of subawards to mitigate post-COVID supports for Nebraska education with limited staff capacity, the Department has remained mindful of these conditions and is on schedule to complete its annual fiscal monitoring efforts within the normal timelines afforded each year. Second SPED subrecipient – Because the UNL utilizes PVS as allowed by 2 CFR 200.430 in regard to salary and wage benefit costs for employees working on a project under a contractual grant agreement, the NDE going forward will require PVS supporting documentation be submitted as a minimum semi-annually for each contract to verify the salary and benefit costs being requested for reimbursement as recommended by the U.S. Department of Education beginning with any payments occurring after March 1, 2023. Third SPED subrecipient – The documentation to support the review of purchased services and supplies during fiscal monitoring was provided to the APA on March 4, 2024. Single Audits – The Director of Grants Management and Director of Grants Compliance will work collaboratively to ensure all subrecipient audits are reviewed and applicable management decision letters are issued within the requested timeframe. Contact: Jen Utemark, Administrator, Office of Budget & Grants Management Anticipated Completion Date: July 1, 2024

2023-001 Program: Foster Care Federal Financial Assistance Listing Number: 93.658 Federal Grantor: U.S. Department of Health and Human Services Pass-Through: California Department of Social Services Award No. and Year: 2301CAFOST and 2023, 2201CAFOST and 2022 Compliance Requirements: Subrecipient Monitoring Type of Finding: Material Weakness in Internal Control over Compliance and Material Instance of Noncompliance Criteria: In accordance with Title 2 U.S. Code of Federal Regulations (CFR) 200.332, pass-through entities must comply with the following: • 2 CFR Part 200.332(a), Requirements for Pass-Through Entities, states that all pass- through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes certain information as well as all the requirements imposed by the pass-through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award. • 2 CFR 200.332(b) – Evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors listed in 2 CFR 200.332(b)(1) through (4). • 2 CFR 200.332(d) – Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include the information at 2 CFR 200.332(d)(1) through (4). • 2 CFR 200.332(f) – Verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipient’s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 200.501. The California Department of Social Services further clarifies in its County Fiscal Letter No. 22/23- 91 that Foster Family Agency (FFA), Group Home, and Short Term Residential Therapeutic Programs (STRTP) are “considered subrecipients and subject to the same audit requirements and require the same degree of oversight as other subrecipients”. Further, while there are some licensing and oversight functions performed by the state over FFAs, group homes, and STRTPs, “counties are still ultimately responsible for review of these audits and their findings, any follow- up to ensure compliance, and any other form of monitoring and oversight required by federal and state laws and regulations.” 2 CFR Section 180.300a, Responsibilities of Participants Regarding Doing Business with Other Persons (and repeated in the California Department of Social Services - County Fiscal Letter No. 21/22 – 115) counties are required to verify that recipients or contracts have not been suspended or debarred by using the federal SAM (Systems for Award Management). Condition: The Social Services Agency (SSA) did not have any formal controls in place for evaluating each subrecipient’s risk of noncompliance or the purpose of determining the appropriate subrecipient monitoring or for subrecipient monitoring for the Foster Care program. Additionally, the following information was not provided at the time of the subaward for ten (10) of fourteen (14) subawards selected for testing from the SSA’s for the Foster Care program: • Subrecipient’s unique entity identifier • Federal award identification number • Federal award date of award to recipient by the Federal agency • Subaward period of performance • Amount of federal funds obligated to the subrecipient • Amount of federal funds committed to the subrecipient • Federal award project description • Name of federal awarding agency • CFDA/Assistance Listing number • Identification of whether the award is research and development • Indirect cost rate During our testing, we noted for four (4) of fourteen (14) subrecipients selected, SSA did not have documentation that the SAM clearance was performed prior to entering the contract with the subrecipient. The County’s policy was to verify the subrecipient was not suspended or debarred prior to entering the contract, but the County did not retain evidence of this check prior to entering the contract. Cause: The SSA’s procedures did not consistently ensure that the required award information and applicable requires were communicated to the subrecipients. The SSA did not follow their procedures to evaluate the risk of noncompliance or monitor the activities of each subrecipient, and the SSA did not maintain documentation of their verification that every subrecipient is audited, as required. Additionally, the SSA department did not follow their policy to retain documentation of the verification of the information prior to entering the contract. Effect: The County’s control policies were not consistently followed which require compliance with the Subrecipient Monitoring requirements in 2 CFR 200.332 and did not comply with subrecipient monitoring requirements related to the program. Additionally, the County’s control policies were not consistently followed, which required documentation of the verification prior to entering the contract. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of fourteen (14) out of seventy (70) subrecipients were sampled, which included seven (7) FFA, and seven (7) STRTP types. The condition noted above was identified during our procedures related to subrecipient monitoring and was pervasive to the program. Repeat Findings from Prior Years: Yes, Finding 2022-002,2022-005 and 2022-006. Recommendation: We recommend that the County adhere to their policies and procedures in accordance with 2 CFR 200.332 to ensure compliance with subrecipient monitoring requirements. We recommend that the County adhere to their procedures requiring documentation of the SAM clearance prior to entering the contract. Management Response and Corrective Action: Social Services Agency: 1. Person Responsible: Kristi Fiskum, Human Services Deputy Director and Karen Vu, Procurement Contract Manager, Senior 2. Corrective Action Plan: SSA has revised its Subrecipient Monitoring Policy in accordance with 2 CFR 200.332 to ensure compliance with subrecipient monitoring requirements and the updated policy was implemented in September 2023. A check list has been developed to track monitoring requirements and was also implemented in September 2023. 3. Anticipated Implementation Date: Fully implemented as of September 2023

FINDING 2023-002 Finding Subject: COVID-19 – Education Stabilization Fund – Subrecipient Monitoring Summary of Finding: The School Corporation received and passed through to subrecipients $495,386 of ESF funds. The School Corporation is to clearly identify the award and applicable requirements to the subrecipients, evaluate the risk of noncompliance related to the subrecipients to determine appropriate monitoring of the subaward, and monitor the activities of the subrecipients to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. Contact Person Responsible for Corrective Action: Dr. Judi Hendrix, Director of WVEC and Michelle Cronk, CFO of West Lafayette Schools Contact Phone Number and Email Address: Dr. Judi Hendrix Michelle Cronk 765-894-0333 765-746-1602 judi.hendrix@esc5.k12.in.us cronkm@wl.k12.in.us Views of Responsible Officials: We concur with the finding regarding the informing and monitoring of subrecipients for federal grants. Description of Corrective Action Plan: We concur with the findings from the State Audit regarding the 3E grants funds; 2023-002. Our Corrective Action Plan would consist of the following:  Before ESF funds are dispersed to school districts (subrecipients), the WVEC Grant Director will ask districts for proper documentation such as receipts, college entrance letters, staff documented timesheets to support their request for funding.  The WVEC Grant Director will monitor the activities of the subrecipients to ensure that the financial subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals of the grant.  Once the school district’s information and documentation is received and approved, grant funding will be dispersed. Both the Service Center Executive Director and WVEC Grant Manager will approve and sign off on any payment made to a subrecipient.  On a biannual basis (periods ending June 30 and December 31), West Lafayette School Corporation will request the monitoring documentation from WVEC to ensure that proper monitoring is taking place. The WVEC Grant Director will create a sub-grantee reporting procedure:  Monthly spreadsheet with district allowable expense and sign off by Grant Manager, WVEC Executive Director and WVEC Treasurer approval.  This will take place every pay period to monitor the disbursement of any federal funds and to ensure that they are used for allowable expenditures under the grant.  This monitoring will begin in the month of March 2024 and continue until the end of the grant or Final Report, December 31, 2024. This procedure will also be used for other federal grants received.  On a biannual basis (periods ending June 30 and December 31), West Lafayette School Corporation will request the monitoring documentation from WVEC to ensure that proper monitoring is taking place. Anticipated Completion Date: Monthly monitoring will begin promptly (March 2024) and end with the final report of 3E grant activities on December 31, 2024.

Responsible Contact Person(s): Angela Morse, Director of Benefit Programs Frank Smith, Associate Director of Benefit Programs Corrective Action Planned: DSS has requested the vendor's records. Once received, DSS will audit those records to provide reasonable assurance that the contractor administered the LIHWAP federal grant program in accordance with federal statutes, regulations, and the terms and conditions of the federal award before it closes the grant award. Estimated Completion Date: 6/30/2024

The City agrees with the finding. The City's Grant Administrator will provide training to each City department which currently oversees subrecipients, ensuring that all department staff understand general and ARPA-specific subrecipient requirements. Additionally, the Grant Administrator will review City departments' subrecipient management checklists to ensure all required documentation is obtained from subrecipients and reviewed as required. This will be complete by June 30, 2024.

SUBRECIPIENT MONITORING School Building Authority (SBA) Assistance Listing Number 97.036, COVID-19 97.036 The SBA will ensure and review audits of all subrecipients yearly effective February 2024. The SBA will implement policies and procedures to monitor all subrecipients to ensure compliance with federal requirements. This will include, but is not limited to, performing a yearly risk assessment as required by 2 CFR 200.303. This assessment will take into consideration results from the yearly audit of each subrecipient as well as other criteria listed in 2CFR 200.303 paragraphs (b), (d) & (e).

SUBRECIPIENT MONITORING West Virginia Community Advancement and Development (WV CAD) Assistance Listing Number 93.568, COVID-19 93.568 Between the years 2022 and 2023, the Weatherization Assistance Program (WAP) experienced a significant turnover in its staff. As a result of this turnover, the proper adherence to the requirement of 2 CFR 200.332(f) for verifying subrecipients was not followed during the auditing process. To ensure that this requirement is met in the future, WV CAD has taken measures to document the policies and procedures related to the financial audit requirements of 2 CFR 200.332(f) in the current WAP State Plan. A designated team member has been assigned the responsibility of maintaining a comprehensive tracking list, which includes the due dates of audits, their review dates, any necessary subrecipient corrective action plans, the dates of letter correspondence, and the uploading of all relevant documents into the divisions Shared Drive. Additionally, this team member is also responsible for downloading the audits from the Federal Audit Clearinghouse and submitting the information to the Fiscal Monitor for a thorough accounting review. These measures aim to ensure proper compliance and accountability within the Weatherization Assistance Program. This action will be implemented in February 2024.

Finding - The organization did not submit the audit and data collection form within the nine-month due date for the fiscal year 2022. • 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. has implemented a 9 day pay period and is considering a 4 day work week pilot in effort to attract and retain staff. The Agency will continue to take such actions to improve employee retention and engagement. • 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 will be 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 withing 90 days of year end as a condition of their contract. • The Executive Director is responsible for ensuring this corrective action plan is implemented.

Pacific University acknowledges the importance of an effective control environment and closely monitors activities of subrecipients under federal awards. Pacific was able to demonstrate that the selected subrecipients had appropriate audits under Subpart F (or were not subject to such audits). However, the University will enhance controls related to tracking such compliance

State Agency: Office of Mental Health 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 Federal Program(s) (ALN # [s]): Block Grants for Community Mental Health Services (93.958) Audit Report Reference: 2023-017 Anticipated Completion Date: SFY 2024-25 Corrective Action Planned: The Office of Mental Health (OMH) agrees with the recommendations. During the last fiscal year, OMH has strengthened policies and procedures over subrecipient monitoring. Currently OMH requires subrecipients to sign a Federal Certification form outlining the specific terms and conditions included in the Notice of Award for each grant award that they receive. The signatory page on the Federal Certification includes the federal award identification information required per federal guidelines. OMH will continue to amend the Federal Certification and applicable policies, procedures, and internal controls to incorporate all required identifying characteristics outlined in Section 352 (a) in SFY2024-25.

Finding 2023-002 Federal Agency Name: US Department of Health & Human Services, California Department of Social Services Program Name: Child Care and Development Fund Cluster CFDA #93.575 Finding Summary: Material Weakness in internal Control and Material Instance of Non-Compliance Responsible Individuals: Debora Dickerson-Sims, Chief Financial Officer and Scott McGrath, Deputy Director Corrective Action Plan: The Commission plans to fully implement the current policies and procedures to ensure the following align with the Subrecipient Monitoring requirements in 2 CFR 200.332. 1) every subaward is clearly identified to the subrecipient as a subaward and includes the information at 2 CFR 200.332(a)(1) through (6) at the time of the subaward, 2) monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, 3) verify that every subrecipient is audited as required by Subpart F of this part. Anticipated Completion Date: June 30, 2024

2023-001 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: FY2023 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 were not reviewed within a twelve-month period. Additionally, typos were included in risk assessment documentation for 4 of the 25 selections tested indicating a prior fiscal year Uniform Guidance report was reviewed. Following the identification of subrecipient Uniform Guidance findings where no follow-up was documented, the University communicated with the respective entities and determined that there was no impact to the University’s awards. By June 30, 2024, and on an annual basis, the University’s Post-Award office will 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.

Finding No.: 2022-044 AL Program: 97.036 - Disaster Grants - Public Assistance (Presidentially Declared Disasters) Area: Subrecipient Monitoring Questioned Costs: $1,540,330 Contact Person(s): Patrick Guerrero, Governor’s Authorized Rep., PAO Corrective Action Plan: Condition 1: The Public Assistance Office agrees with this finding and acknowledges that, as the pass-through entity, we are responsible for monitoring subrecipients. The Public Assistance Office will strengthen monitoring procedures to ensure compliance with 2 CFR 200.332(e). Beginning September 2025, PAO has begun conducting biannual risk assessments. The PAO will also strengthen documentation and audit trails by maintaining monitoring checklists, review notes, and communications in subrecipient files. Proposed Completion Date: Ongoing Condition 2: The Public Assistance Office agrees with this finding and acknowledges that, as the pass-through entity, we are responsible for monitoring subrecipients. The Public Assistance Office will strengthen monitoring procedures to ensure compliance with 2 CFR 200.332(g). Beginning September 2025, PAO has begun conducting biannual risk assessments. Proposed Completion Date: Ongoing

Management has contracted with a contract accountant who has already started audit preparation services for future audits. The 2022 has been started and will be completed shortly. The 2023 audit will be started shortly. The Native Village expects to be fully caught up by their fiscal year 2025 audit.

We concur with the finding. The Republic has executed a signed subrecipient subaward agreement to formalize the relationship and ensure compliance with applicable requirements. Applicable laws and regulations include the COMPACT Fiscal Procedures for Palau, which take precedence as special terms and conditions where both these procedures and 2 CFR 200 address the same matter. The Ministry of Finance has implemented internal control policies and procedures to identify and document subrecipient relationships at the time of award, monitor subrecipient activities through periodic reporting, and verify compliance with federal and local requirements prior to processing drawdown requests. We further confirm that the program audit requirement for this subrecipient has been met through the separate single audit.

ALN 21.023 – Lack of Internal Controls and Noncompliance with Subrecipient Monitoring – Emergency Rental Assistance Program (Repeat Finding 2021-013) Cleveland County takes the auditor's findings seriously and has already implemented several improvements in documentation, monitoring, and reporting practices. Cleveland County is working toward improvements for Fiscal Year 2025 and has reconciled billing to align with the contract scope of work. However, we recognize the need for documented internal controls and are committed to addressing all recommendations to ensure compliance and transparency in future programs. The County appreciates the constructive feedback and will continue to refine its processes to better serve its citizens.

Vacant positions have been filled and new staff have been assigned to the task of preparing of the SEFA. In addition, the new ERP platform has been operational for 15 months, thereby streamlining the year-end closing process.

Finding Number: 2022-001 Finding Type: Material noncompliance with laws and regulations and significant deficiency in internal controls over Federal awards. Criteria and Condition: Michigan Falun Dafa Association was required to have an audit in compliance with the requirements of 2 CFR Section 200.501 and submit its audit to the Federal Audit Clearinghouse as required by 2 CFR Section 200.512, which was due by September 30, 2023. Auditors’ Recommendation: The auditors recommended Michigan Falun Dafa Association’s strengthening of internal controls procedures over the award process to ensure that all existing and any new compliance requirements are communicated to all involved in the process to ensure timely adherence to all or any requirements. Michigan Falun Dafa Association’s Response to the Finding and Corrective Action Plan: This is the first year the Michigan Falun Dafa Association expended $750,000 or more of federal award received, and as a result, was not aware of the requirement for a compliance audit. Michigan Falun Dafa Association will strengthen its internal control processes and procedures to ensure that compliance requirements will be communicated to all involved in grant administration to ensure timely adherence to all or any requirements for any new grants received. Responsible Individuals: Zhiwei, Xu, President Xinhua Yu, Treasurer Planned Completion Date: Immediate.

The Municipality Administration is committed to complying with all submissions and has ensured the proper signing of an external auditors firm to comply with such requirements.

Finding 2022-009 Subrecipient Monitoring – Material Noncompliance and Material Weakness in Internal Controls Over Compliance Corrective Action Plan: Management concurs with the finding and will adhere to the corrective action plan included in this report. Management plans to revise policies and procedures related to subrecipient monitoring. Anticipated Completion Date: December 31, 2024

The Organization agrees with the finding and recommendation as outlined above. In November 2023, the Organization updated and communicated changes to the Federal Awards Policies and Procedures Manual to ensure all controls are adequate to ensure compliance with federal statutes, regulations, and Uniform Guidance requirements. This was the first year the Organization has been subject to the single audit requirement. The Organization worked with the audit firm to ensure proper reporting and controls were in place. We understand it is our responsibility to ensure our single audit is completed within the required timeline and will work closely with future CPA teams to adhere to required timeframes. In January 2024, the Board of Directors approved the updated version of our Federal Awards Policies and Procedures Manual. The Organization has communicated the policies and procedures to ensure organizational compliance with the updated guidelines. As of March 2024, for fiscal year ended 2023, the Organization has prepared the SEFA and will present these materials concurrent with our regular audit schedule. The SEFA will be updated throughout each fiscal year as new federal funds are awarded. The Organization will continue to identify areas of opportunity to improve compliance with federal requirements.

21.023 - Lack of Internal Controls and Noncompliance with Subrecipient Monitoring Requirement – Emergency Rental Assistance Program (Repeat Finding – 2021-002) Oklahoma County will comply with federal laws and regulations and grant agreements by creating award agreements that are designed and implemented to ensure Subrecipient Monitoring is performed. Anticipated Completion Date: 6/21/2023 Responsible Contact Person: Brian Maughan, BOCC Chairman

21.019 - Lack of Internal Controls and Noncompliance with Subrecipient Monitoring Requirement – Coronavirus Relief Fund (Repeat Finding - 2021-001) Oklahoma County will comply with federal laws and regulations and grant agreements by creating award agreements that are designed and implemented to ensure Subrecipient Monitoring is performed. Anticipated Completion Date: 6/30/2024 Responsible Contact Person: Brian Maughan, BOCC Chairman

FINDING # 2022-010No finding in prior yearAs recommended, the DCA will review current procedures to ensure that all subaward information required by the federal Uniform Guidance is included in all subaward contracts and grant agreements. The DCA has also reviewed its current subrecipient monitoring procedures for standard subawards made by the agency and has determined that no internal control enhancements are required. The HAF award was a unique grant relationship for DCA in that the entire award was passed through to another New Jersey State government agency that is a direct affiliate of the Department. Monitoring procedures were determined based on the close working relationship with our affiliate organization and the fact that less than 1 percent of the grant award was expended through June 30, 2022. Current procedures included a risk assessment of the subrecipient and performance of the single audit desk review of the independent audit report. In addition, the Director of Audit, and the Executive Director of the subgrantee affiliate participate in weekly meetings where updates on the program status can be determined. DCA?s subrecipient monitoring plan also includes the hiring of an Integrity Monitor to oversee and monitor the use of the HAF funds as well as compliance with all HAF program reporting requirements. As program disbursement activity is continuing to increase with the HAF program(s) created more fully up and running, DCA is currently targeting the Integrity Monitor hire to take place sometime within the next three to six months.COMPLETION DATE/CONTACT PERSON Fiscal Years 2023 and 2024John Alexy(609) 913.4385John.Alexy@dca.nj.gov

Dear Mr. Waguespack,Please find below our management response to the audit finding "Noncompliance with Subrecipient Monitoring Requirements".The University does not concur that this is a second consecutive year finding, but in fact the same one from FY2021.The completion of FY2021 audit and the start of FY2022 audit did not allow the University time in between to correct the FY2021 finding.The following is timeline for the FY2021 finding.? Notification of potential finding was issued on 5/26/22.? Preliminary response request was issued on 5/26/2022.? Preliminary finding response was submitted on 6/2/2022.? Audit response request letter was submitted on 6/6/22.? Audit response was submitted on 6/13/22.Sponsored Programs Finance Administration and Compliance (SPFAC) will continue the following corrective action provided in FY2021 and it will be overseen by Director of SPFAC.1. Continue with our procedures to adequately monitor subrecipients.2. Implement a risk assessment questionnaire and have Senior SPFAC staff complete one for every sub recipient per 2 CFR 200.332 (f).