Corrective Action Plans

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.

The Institute has engaged an auditor to complete the December 31, 2022, 2023, 2024, and 2025 Single Audits concurrently, and will submit each reporting package and data collection form to the Federal Audit Clearinghouse as each audit is completed. Thereafter, the Institute will complete the audit and submit the reporting package within nine months after year end. Anticipated completion date: December 31, 2026. Responsible contact person: Kathy Walker, Executive Director.

Federal Program: Direct - USDA Rural Utilities Service award; ALN 10.760, 'Water and Waste Disposal Systems for Rural Communities' (Single Audit / Uniform Guidance).Condition: The Great Northwest Wholesale Water Commission did not complete and submit its reporting package, including the SEFA and the single audit report, to the Federal Audit Clearinghouse within nine months of the fiscal year end. Criteria: Under 2 CFR §200.512, the audit must be completed, and the data collection form and reporting package must be submitted within 30 calendar days after receipt of the auditor's report, or nine months after the fiscal year end, whichever is earlier. Corrective Action Plan: Management acknowledges the finding and has implemented procedures to improve the timely completion and submission of the data collection form to the Federal Audit Clearinghouse. Management has engaged an audit firm to complete the December 31, 2022, 2023, and 2024 audits and will submit the reporting package to the Federal Audit Clearinghouse upon completion. Management will coordinate with the auditors throughout the audit process, monitor applicable reporting deadlines, and establish internal timelines to ensure the audit report and data collection form are submitted within the required time frame prescribed by 2 CFR 200.512(a). Personnel responsible for Corrective Action: Jerri Dearmont, Executive Director Anticipated Completion Date: August 18, 2026

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).