Corrective Action Plans

Finding 2022-061 Disaster Grants - Public Assistance (Presidentially Declared Disasters), ALN 97.036 - Subrecipient Audits Management Views MSP agrees with the finding. Planned Corrective Action MSP will improve monitoring by reconciling expenditures by program to ensure that all subrecipients are included on the single audit tracking sheet for review. In addition, MSP will transition to each division having the responsibility for the completion of their own single audit reviews beginning October 1, 2023. Anticipated Completion Date MSP will reconcile expenditures by program by October 1, 2023, and each division will have their single audit reviews completed by September 30, 2024. Responsible Individual(s) Matt Opsommer, MSP

Finding 2022-040 Formula Grants for Rural Areas and Tribal Transit Program, ALN 20.509 - Subrecipient Audits Management Views MDOT agrees with the finding. Planned Corrective Action MDOT will update and implement its procedures to include management decision letter timelines that are consistent with the Uniform Guidance related to subrecipient report review. Anticipated Completion Date September 30, 2023 Responsible Individual(s) Adam Feldpausch, MDOT Dave Wearsch, MDOT

Finance and the Office of Highway Safety will work together to create policies and procedures to ensure compliance with subrecipient monitoring. Anticipated Completion Date: September 30, 2023 Contact Person: Loren Doyle, Acting Chief Operating Officer / Chief Financial Officer Department of Transportation loren.doyle@dot.ri.gov

SUBRECIPIENT MONITORING ALN Number 93.568 Low Income Home Energy Assistance (LIHEAP) 2022-018 The Mississippi Department of Human Services Should Strengthen Controls Over Onsite Monitoring for the Low-Income Home Energy Assistance Program (LIHEAP). Response: MDHS Concurs that controls should be strengthened over On-Site monitoring for the LIHEAP Program. MDHS also concurs with the following specific recommendations of the OSA and incorporates those recommendations as the foundation for the MDHS Corrective Action Plan (CAP) related to this finding. Corrective Action Plan: 1. Strengthen controls over the subrecipient monitoring process: A. The Office of Compliance, Division of Monitoring has made significant strides in strengthening controls over the subrecipient monitoring process. The Division continues to review and update the processes and procedures as necessary to ensure processes are adequate and effective. Staff are constantly notified/trained on updates to policies, procedures, and regulations to ensure continued compliance with monitoring the agency's subgrant agreements. B. Responsible Party: Kameron Harris, Chief Compliance Officer, Director of Monitoring, Laketha Gilmore C. Completion Date: This corrective action has been implemented and is ongoing. 2. Ensure subgrants are monitored timely and the Report of Findings is issued in a timely manner: A. The Office of Compliance, Division of Monitoring continues to improve upon the monitoring review process. The Division has implemented timeliness requirements to ensure the Agency's compliance with the monitoring process. B. Responsible Parties: Kameron Harris, Chief Compliance Officer, Director of Monitoring, Laketha Gilmore C. Anticipated Completion Date: This corrective action has been implemented. 3. Maintain all supporting monitoring tools, reports, and correspondence in the monitoring file: A. The Division of Monitoring has implemented a quality control measures to ensure all required documentation is included in the monitoring file. B. Responsible Parties: Kameron Harris, Chief Compliance Officer, Director of Monitoring, Laketha Gilmore C. Anticipated Completion Date: This corrective action has been implemented.

ALN Number 17.258, 17.259, 17.278 ? Workforce Innovation and Opportunity Act 2022-023 ? Strengthen Controls to Ensure Compliance with Subrecipient Monitoring Requirements. Cat ? M, Finding Type, A, C1 (MW, MNC) MDES Response: The Mississippi Department of Employment Security concurs in principle with the three conditions noted in the finding. During and prior to this audit, MDES enacted new procedures to address the concerns noted in this finding. MDES renewed its commitment to ensuring that subrecipients are qualified to receive funds. MDES contracted with Booth Management Consultants and more recently Trace Advisory Group to ensure compliance with all DOL monitoring requirements, including on-site monitoring and through other modes. Also, we started implementing a risk-based assessment tool to ensure the performance of a thorough qualification assessment on all grantees. Corrective Action Plan: A. The Offices of Grant Management and Business Management will develop a plan to document our assessment of the subrecipients? awareness of audit requirements at 2 CFR 200.332(f). MDES will start implementing the plan detailed below on or before October 31, 2023. This plan involves the following: 1) Perform a pre-award risk assessment to determine risk for awarding grant and the level of monitoring required during program; 2) Issue a standardized audit requirement letter or agreed upon procedures to all subgrantees to remind them of grant requirements; 3) Receipt of required federal single audit from subgrantees expending more than $750,000 in federal funds from all sources OR receipt of a statement that the entity did not meet this threshold; 4) Document the review and assessment of the audits received for findings or questioned costs using tools, such as the templates found in the DOL Core Monitoring Guide; and 5) Document all required agency action necessary to mitigate the risks identified in the audits. B. COVID-19 caused extensive travel and in-person meeting restrictions nationwide. MDES did not restrict travel or virtual meetings. As contact guidelines fluctuated, the on-site monitoring team had discretion regarding the method to conduct this process. Also during this time, DOL staff observed similar contact restrictions, which limited federal monitoring of MDES. Such challenges and restrictions no longer exist. MDES will perform on-site and remote monitoring, as required. Where possible, MDES intends to conduct future monitoring on-site. MDES management will also hold regular meetings with the subrecipients to monitor progress and to ensure questions related to grant expenditures receive timely responses. C. Although the agency did not perform a risk-based assessment in the year reviewed by the auditors (PY21), MDES did incorporate the Risk Assessment Tool, Tool S from the U. S. Department of Labor?s Core Monitoring Guide, into its review of subgrantees for PY 2022. MDES will continue to ensure the performance of a thorough risk-based assessment on all grantees.

Finding 2022-001 Federal Agency: Various Program Name: Research and Development Cluster Assistance Listing Number: Various Federal Award Year: Programs active between July 1, 2021 ? June 30, 2022 Compliance requirement: Subrecipient Monitoring Finding Type: Significant Deficiency The Office of Research and Sponsored Programs lost both its primary and secondary resources responsible for subrecipient monitoring in July 2020 and June 2021. The University could not replace them immediately due to a hiring freeze during the Covid pandemic. A full time Subaward Coordinator was hired in December 2021. The Subaward Coordinator has operationalized all tasks associated with Subrecipient Monitoring as identified in the Uniform Guidance as well as in accordance with Lehigh policies, procedures and internal controls. The review of current active subawards has been completed, including all single audits for fiscal year 2022, with no findings for any of Lehigh?s subawards. The Subaward Coordinator continues to monitor for the posting of these remaining reports on a weekly basis in order to complete the review of subrecipient single audit reports on a timely basis. We are confident with the full-time focus of the Subaward Coordinator and the enhancements to our subrecipient monitoring processes and controls that this finding is fully remediated. Name of contact person: Cynthia Kane, Assistant Vice Provost, Office of Research and Sponsored Programs. Completion date: May 31, 2022

Finding: The Washington State Department of Transportation did not have adequate internal controls over and did not comply with requirements to issue management decisions for audit findings to subrecipients of the Highway Planning and Construction Cluster. Questioned Costs: Assistance Listing # 20.205 20.205 COVID-19 20.219 20.224 Status: Corrective action complete Corrective Action: The Department is committed to ensuring our programs comply with federal regulations related to subrecipient monitoring. The Department?s Local Programs Division typically issues Management Decision Letters (Decision Letters) to all subrecipients that receive single audit findings related to WSDOT federal grant awards. For the subrecipient in question, the subrecipient had contacted the Division upon realizing a discrepancy in their advertisement practices, which was prior to the auditors issuing the single audit finding. The Division reviewed the subrecipient?s advertisement practices, evaluated and approved the corrective action plan, and implemented a training plan with the subrecipient. Since these activities preceded the issuance of the subrecipient?s single audit finding and resolved the deficiency, the Department elected to forgo a formal Decision Letter. Based on the audit recommendations, the Department will continue to review all single audit findings issued for subrecipients and send Decision Letters. The conditions noted in this finding were previously reported in findings 2021-010, 2020-015 and 2019-017. Completion Date: December 2022 Agency Contact: Jesse Daniels External Audit Liaison PO Box 47320 Olympia, WA 98504-7320 (360) 705-7035 danielje@wsdot.wa.gov

Finding: The Health Care Authority did not have adequate internal controls over and did not comply with federal requirements to ensure subrecipients of the Block Grants for Community Mental Health Services program and the Block Grants for Prevention and Treatment of Substance Abuse program received required single audits, and that it appropriately followed up on findings and issued management decisions. Questioned Costs: Assistance Listing # 93.958 93.958 COVID-19 93.959 93.959 COVID-19 Amount $0 Status: Corrective action in progress Corrective Action: The Authority concurs with the finding. The Authority will: ? Follow established procedures related to the agency-wide monitoring of subrecipients? single audits. ? Issue management decision letters for findings subrecipients received related to programs that are funded by the Authority?s pass-through federal funding. ? Evaluate corrective actions to ensure subrecipients adequately address audit recommendations. Completion Date: Estimated July 2023 Agency Contact: William Sogge, CPA External Audit Liaison PO Box 45502 Olympia, WA 98504-5502 (360) 725-5110 william.sogge@hca.wa.gov

Finding: The Department of Commerce did not have adequate internal controls over and did not comply with requirements to issue management decisions for audit findings to subrecipients of the Low-Income Home Energy Assistance Program. Questioned Costs: Assistance Listing # 93.568 93.568 COVID-19 Status: Corrective action complete Corrective Action: The Department?s internal control officer is responsible for completing the monitoring of federal reporting and issuing management decisions for subrecipients who receive federal audit findings for programs funded with the Department?s federal pass-through funding. Beginning in December 2021, the internal control officer documented all findings, corrective action plans, and communication with subrecipients in a monitoring spreadsheet. This enabled the Department to ensure all efforts in monitoring subrecipients were taken. In May 2022, all management decisions were added to the monitoring spreadsheet which documented the Department?s management decisions. To ensure compliance with federal requirements for subrecipient monitoring, the Department has implemented the following process: ? Review all audit findings issued to Department subrecipients. ? Review each subrecipient?s corrective action plan. ? Review and discuss all findings and corrective action plans with subrecipients to identify and understand the basis for the deficiency and planned corrections. ? Create a management decision for each subrecipient finding, receive leadership approval, and formally communicate the decision to our subrecipient. ? All management decisions will be formally communicated to our pass-through subrecipients within the six-month federal deadline. Completion Date: September 2022 Agency Contact: Gena Allen Internal Control Officer PO Box 42525 Olympia, WA 98504-2525 (360) 480-5149 Gena.Allen@Commerce.wa.gov

Finding: The University of Washington did not have adequate internal controls over and did not comply with federal requirements to ensure subrecipients of the Global AIDS program received required single or program-specific audits, and that it followed up on findings and issued management decisions. Questioned Costs: Assistance Listing # 93.067 93.067 COVID-19 Amount $0 Status: Corrective action in progress Corrective Action: The University maintains that there are adequate internal controls to ensure the Global AIDS program complies with the requirements for pass-through entities as outlined in Uniform Guidance 2 CFR ? 200.332 and the university policy incorporated in Grants Information Memorandum 8. As noted in the finding, the University uses a certification process to obtain information and documentation needed, such as audited financial statements, from each subrecipient and perform a risk assessment using standard risk criteria. For the one exception identified by the auditors, the University misinterpreted the response provided by the subrecipient regarding whether it expended $750,000 or more in federal awards during the fiscal year. Although the single or program specific audit report was not obtained and reviewed, a risk assessment was performed on the subrecipient. With a medium risk rating, the subrecipient was subject to monitoring at the program level throughout the project during the period in question, in accordance with University policy. The University will: ? Update the certification process with all subrecipients to confirm if federal expenditures during a fiscal year exceed the $750,000 threshold to require a single or program-specific audit. ? Issue written management decisions for all applicable audit findings. ? Ensure subrecipients develop and perform acceptable corrective actions to address all audit recommendations, if applicable. Completion Date: Estimated September 2023 Agency Contact: Erick Winger Controller 4300 Roosevelt Way NE Seattle, WA 98195 (206) 543-5322 erickw@uw.edu

Condition: The District overstated expenditures on the ESSER I June 30, 2021 expenditure report. Plan: Grant expenditures should be reviewed and reconciled back to the accounting records prior to submitting final reports; ISBE grants division should be contacted regarding this discrepancy. Anticipated Date of Completion: 6/30/2023 Name of Contact Person: Thomas Akers, Superintendent Management's response: The District agrees that the expenditures claimed on the June 30, 2021 expenditure report was overstated by $10,678 and in the future will review and reconcile the expenditure reports to the accounting records before submitting to ISBE.

Reference Number: 2022-001 Assistance Listing Number: 84.425 Federal Program Title: Education Stabilization Fund Awarding Agency / Pass-Through Entity: U.S. Department of Education, Colorado Department of Education Compliance Requirement: Subrecipient Monitoring Criteria: None for ECSD Corrective Action: The District agrees with the finding and has adopted Policy Regulations: DD-R, Project Partnerships, Sub-Award Grants, Sub-Contracts Pursuant to Grants, and Third-Party Grants Involving District Personnel, Programs or Facilities and; DD-R2, Grants to District Personnel Personnel Responsible: Sandra Farrell, COO and Chelsey Gerard, Director of Finance Completion Date: October 31, 2022

CONDITION: The ROE did not have adequate controls over subrecipient monitoring in compliance with the Code. PLAN: The ROE retroactively conducted monitoring of the subrecipients of the ARP - Social Emotional Learning grant passed through the ISBE. The subrecipients of this grant were all other ROEs in the Area IV hub (ROEs 9, 17, 32, and 54) with funds going out for administration costs. Since it is common knowledge that each ROE is audited annually by the Illinois Auditor General, further audit consideration was unnecessary. The ROE will draft subrecipient monitoring policies and procedures to align with standards. Future monitoring will be scheduled in December 2023. ANTICIPATED DATE OF COMPLETION: New policy and procedures implemented partially in FY23 and fully for FY24. CONTACT PERSON: Ms. Jill Reedy, Regional Superintendent

View of Responsible Officials and Corrective Action Plan –The Organization agrees with this finding. The Chief Financial Officer in collaboration with the Finance Associate and the Financial Consultant will set a calendar at the end fof the fiscal year to ensure timely closeout of the books that will allow ample time to engage and complete the audit prior to the deadline for the FAC filing.

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.

Public Health agrees with the recommendation. We will establish formal procedures for conducting risk assessments of our subrecipients. Public Health will also develop and implement specific subrecipient monitoring procedures and establish a process for obtaining single audit reports from out subrecipients. Finally, we will develop a monitoring mechanism to track subrecipients' compliance with the single audit mandate. Estimated Implementation Date: December 2024 Contact: Melissa Relles, Assistant Deputy Director Division of Operations Center for Preparedness and Response California Department of Public Health

Finding 2021‐009 Monitoring Activities – Subrecipient Monitoring – Material Noncompliance and Material Weakness in Internal Control over Compliance Corrective Action Plan Management will revise the policies and procedures related to subrecipient monitoring and will ensure that policies are established to ensure subawards contain the required federal award information. Expected Completion Date Fiscal Year 2025.

Finding 2021‐008 Subrecipient Agreements – Subrecipient Monitoring – Material Noncompliance and Material Weakness in Internal Control over Compliance Corrective Action Plan Management will revise the policies and procedures related to subrecipient monitoring and will ensure that policies are established to ensure subawards contain the required federal award information. Expected Completion Date Fiscal Year 2025.

Resolved

2021-006: Audit Completion and Submission to the State and Federal Government - Material Weakness and Non-Compliance Views of Responsible Officials: Management agrees with this finding as the Data Collection Form was not submitted to the Federal Audit Clearinghous within nine months after fiscal year-end. However, the Board does not agree that the late filing of the Data Collection Form rationalizes a qualified opinion over Reporting for the Airport Improvement Program. Corrective Action Plan: The Board will fire a contract accountant to assist the Accounting Manager in the timely finanical close to report and audit preparation to ensure timely completion of their finanicial and compliance audits. Anticipated Completion: December 31, 2023 Responsible Party: Tamie Wick, Accounting Manager. Amy Terrell, Airport Director.

Management of the Foundation concurs with the audit finding. When management discovered the requirement had not been met, they immediately contacted an independent auditor to perform the program-specific audit to satisfy the reporting requirements.

Finding No.: 2019-012 Federal Agency: U.S. Department of Health and Human Services CFDA Program: 93.243 Substance Abuse and Mental Health Services Projects of Regional and National Significance Award Number: 5U79SP020710-04 Area: Subrecipient Monitoring Questioned Costs: $468,864 Contact Persons: Perlie Santos, Chief Financial Officer; Reyna Saures, CGC Director; Vincent Camacho, Grants Administrator. Corrective Action: Condition 1 CHCC does not concur with the findings and the $353,864 questioned costs. Pursuant to the terms and conditions of the sub-award agreement, before any subsequent disbursements to the Subgrantee, invoices and receipt and progress reports from the prior disbursements were submitted to the Project Director for review and approval. No subsequent disbursements were issued without compliance to these requirements Condition 2 CHCC does not concur with the findings and the $115,000 questioned costs. The Announcement for the funding availability was published in the local newspaper. 2019-012 Condition 2.pdf Condition 3 CHCC does not concur with the findings and the $25,000 questioned costs. The selected transaction was voided (document type PE); hence no supporting documents were provided. Finding No.: 2019-012, Continued This 2nd disbursement was subsequently processed on July 29, 2019 (PV1456803), when all the required documentation pursuant to the sub-award agreement were complied with. Proposed Completion Date: Not applicable as CHCC does not concur with the findings.

The Council is aware of the audit reporting requirements and will be working with their accountants to prepare future audits timely.