Corrective Action Plans

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.