Corrective Action Plans

FAIN (Federal Award Identification Number) and Federal Award Date: The following action has been implemented to include the FAIN & Award date on all awards for ALN 20.509: All awards executed for Public Transit will include a “Grant Insert Sheet”. The Grant Insert Sheet will be identified on the Part 1 Grant award detail document. Box “36” titled FAIN, will include text that reads “See attachment B”. The Grant Insert Sheet is a document that is completed by the Public Transit Unit and is provided to the Grants Unit for award execution. This sheet includes detailed information related to the award. To address the deficiency, The Grant Insert sheet has been updated to include FAIN Numbers and the Federal Award Date. To ensure the Agency of Transportation meets this compliance requirement, the Grants Unit will verify this information is included prior to award execution. Anticipated completion date: This action went into effect as of January 12, 2024. Person Responsible for Corrective Action: Ross MacDonald, Public Transit Program Manager ross.macdonald@vermont.gov Tricia Scribner, Grants Unit Manager tricia.scribner@vermont.gov Management Review Schedules In the past, The Public Transit Program has used the State Fiscal year for the timing/scheduling of the 3-year Management Reviews. For example, if the completion of the last Management Review occurred in FY 2020, then we would ensure a new Management Review began at any time during FY2023. We understand this could lead to more than exactly 3 years between these reviews. Due to this finding, we will now establish a starting month/date for each provider, with 3-year intervals between the start of each Management Review. We have attached the updated schedule and will adhere to this from this day forward. Anticipated completion date: As of December 27, 2023, the updated Management Review Schedule is in effect. Person Responsible for Corrective Action: Ross MacDonald, Public Transit Program Manager ross.macdonald@vermont.gov

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.

Finding No.: 2022-031 AL Program: 21.027 - Coronavirus State and Local Fiscal Recovery Funds Area: Subrecipient Monitoring Questioned Costs: $61,003,095 Contact Person(s): Tracy B. Norita, Secretary of Finance Corrective Action Plan: Condition 1-3: The Department of Finance agrees with this finding. The Department has recently adopted and approved (August 2025) a Subrecipient Monitoring Policy and Procedures which specifically focused on the implementation of 2 CFR 200.331. The Department will expand on this policy and procedure to include the development and implementation of a comprehensive subrecipient monitoring policies that clearly outline the process for identifying subawards, assessing the risk of noncompliance, and conducting monitoring activities based on those risks. These policies will be aligned with federal requirements and best practices to ensure consistency and accountability. Furthermore, due to internal scheduling constraints and the compressed timeline required to complete the FY22 audit, the requested documents were not submitted by the specified deadline, resulting in this finding. However, the Department maintains all relevant supporting documentation and is prepared to provide it upon request from the Grantor. Proposed Completion Date: Ongoing

Public Health’s Center for Preparedness and Response (CPR) agrees that it did not establish a formal risk assessment process over its subrecipients of ELC COVID-19 awards. CPR will establish and document formal procedures for conducting risk assessments of ELC subrecipients. Public Health will also develop and implement specific subrecipient monitoring procedures. CPR also agrees that it did not obtain single audit reports from ELC subrecipients. CPR will develop and implement procedures outlining the process for obtaining single audit reports from subrecipients, which will include a monitoring mechanism to track 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

Wabanaki Public Health and Wellness received our FY21 audit in April 2023, which did not allow for the changes to be made in time for FY22. The corrective action plan from FY21 continues to be our course of action and will be fully implementing the following to ensure compliance in FY23. Wabanaki Public Health & Wellness followed sections of the subrecipient monitoring for requirements of documentation and follow through, however there were areas in which the audit team brough forth to light that needed some enhancing for procedures. WPHW will follow through with full review of the OMB standards for the subrecipient monitoring and build a check list to determine that each required section/item is followed throughout the period of award. The WPHW team, which includes, the Director of Finance, Financial Quality and Compliance Manager, and the Contract Specialist will be working together to build the required list and procedure and reviewing the checklist for when the award is first presented to allow both parties, (sub awardee and WPHW) to understand the requirements for the award. Throughout the award period WPHW will maintain required documentation following the CFR 200.332 guidelines. The Financial Quality and Compliance Manager will review processes through the periodic review of all awards to verify that monitoring has been completed at the deemed timeframe and all parties involved are maintaining the set forth requirements of the award. Person(s) Responsible: Beth McLean Timing for Implementation: Summer 2023

Assistance Listings number and name 84.425F COVID-19 Education Stabilization Fund?Higher Education Emergency Relief Fund (HEERF) Institutional Portion Award number and years P425F201546-20B, May 6, 2020 through June 30, 2023 Federal agency U.S. Department of Education Compliance requirement(s) Allowable costs/cost principles Questioned costs $4,249,864 Name(s) of contact person: Ross Poppenberger Anticipated completion date: Q1 (January - March) 2023 The District misinterpreted its Federal Indirect Cost Rate (IDC) as it applies to HEERF funding. Although the District applied their prenegotiated IDC rate to the HEERF Grant, the District did not apply the rate to the correct program expenditures when calculating the IDC. The District updated its internal grants IDC calculation policies and procedures to ensure that indirect costs are properly calculated and reviewed for accuracy and written confirmation is obtained from the grantor for a new grant?s IDC calculation. Further, the District is working with the U.S. Department of Education to reappropriate the unallowable funds to allowable direct costs.

Finding # 2022-007 Title of Finding Subrecipient Monitoring Contact Person Brook Hinzman Anticipated Completion Date June 2023 Corrective Action planned to be taken: Will comply and monitor subrecipient spending going forward.

CFDA No. and Name: 10.691 Good Neighbor Authority Responsible Persons: Siri Mullaney, Finance Director Anticipated completion date: June 30, 2023 Corrective Action: Concur. In fiscal year 2023, the Flood Control District was moved from the Public Works Department and formed into a stand-alone department, allowing for the hire of new staff dedicated to the management of federal awards. This increase in oversight will provide the capacity to accurately account for federal awards and comply with requirements such as adherence to the award start and end dates and the receipt of pre-approval by the federal agency for pre-award costs. The County will continue to provide technical assistance and resources to departments managing federal awards.

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 2022-004 Contact Person Responsible for Corrective Action: Chad Shireman Contact Phone Number: 812-738-8241 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The county will be retaining and periodically reviewing the grant application and award to stay current on applicable requirements of the subrecipient in order to ensure compliance. Lines of communication with the subrecipient will be established and maintained to better monitor activities, ensuring that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward and achieves performance goals. Policies and procedures will be adopted and implemented to allow the county to evaluate the subrecipient?s risk of noncompliance. The county will request supporting documentation from the subrecipient when reimbursement requests are made, and this process will be documented in order to provide evidence that it is taking place. Anticipated Completion Date: The anticipated completion date will be December 31, 2023. This will allow the county and the subrecipient to work together to create the necessary policies and procedures. Once created, the remainder of the year will be used to implement them, allowing the county to evaluate all activities for the entire 2023 audit period that will be under review by SBOA in 2024.

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

Assistance listing number and program name: 93.568 Low-Income Home Energy Assistance 93.568 COVID-19 Low-Income Home Energy Assistance Agency: Department of Economic Security Name of contact person and title: Molly Bright, DCAD Assistant Director Anticipated completion date: December 31, 2023 Agency’s Response: Concur The Department of Economic Security will address the audit recommendations, as follows: 1. Spend no more than the maximum 15 percent of program monies for weatherization or other energy-related home repairs. The Department will ensure that LIHEAP funds are allocated appropriately, and will confirm that no more than 15% of the total grant award is allocated for use in weatherization efforts or other energy-related home repairs. The Department constructs a detailed working budget document that is utilized for establishing the proper allocation of federal LIHEAP funding for each grant year. The finance team monitors this established budget to verify and corroborate its validity. The finance team will continue to monitor the LIHEAP budget, but will also improve its engagement with the Department’s programmatic staff to ensure sustained monitoring of the LIHEAP grant and expenditure earmarks. 2. Train newer staff administering the program on the program’s weatherization limitation and on the Division’s policies and procedures to review and approve expenditures considering this limitation. The Department has and will continue to host training sessions with all staff members, existing and new, to ensure awareness of and compliance with the 15% funding allocation restriction on weatherization related costs. The Department’s LIHEAP Policies and Procedures Manual have been shared and discussed with the programmatic staff, with a strong focus placed on the weatherization allocation cap. New procedures and Chart of Accounts elements have been created as a result of this finding to guarantee future compliance with the grant restrictions. 3. Enable the feature in the State’s accounting system to alert the Division of an award’s expenditures approaching the limitation to help ensure the Division does not exceed the weatherization limitation when spending program monies. Prior to the fiscal year 2022 Single Audit, the Department was not utilizing the State’s accounting system to budget weatherization separately for a program period year associated with LIHEAP. This procedure has changed effective immediately, allowing for improved tracking and reviewing of the LIHEAP grant spending guidelines. Additionally, it provides the Department with the ability to verify that the allocation of funding for weatherization efforts does not exceed the LIHEAP grant weatherization limitation. 4. Work with U.S. DHHS to resolve the $211,026 the Division overspent for weatherization or other energy-related home repairs, which may involve returning monies to the federal agency. The Department will collaborate with the U.S. DHHS to determine an appropriate course of action.

Assistance listing number and program name: 93.558 Temporary Assistance for Needy Families 93.558 COVID-19 Temporary Assistance for Needy Families Agency: Department of Economic Security Name of contact person and title: Molly Bright, DCAD Assistant Director Anticipated completion date: June 30, 2024 Agency’s Response: Concur The Department will stop the reimbursement of costs to all nonprofit and contracted subrecipients for items that are disallowed and/or restricted by the regulations provided within the provisions of the federal Temporary Assistance for Needy Families (TANF) grant received by the Department. Additionally, the Department will obtain all supporting documentation needed to ensure compliance with these regulations prior to disbursing any TANF funding to any subrecipient for the purpose of reimbursement or programmatic funding. The Department will also update its policies and procedures for subrecipient monitoring. Furthermore, detailed training for the Department personnel responsible for reviewing and approving subrecipient reimbursement requests will be provided to ensure personnel are capable of identifying costs that are unallowable under federal regulations. The Department will assess the risk of noncompliance violations for each subrecipient and establish a plan of action to address noncompliance. The plan of action will include an array of training and educational processes to ensure applicable personnel are knowledgeable of TANF compliance requirements and Department contracts. The Department will also monitor subrecipients per updated policies and procedures. The Department will continue to resolve the unallowable costs reimbursed to subrecipients as deemed appropriate by the United States Department of Health and Human Services.

Assistance listing number and program name: 21.027 COVID-19 State and Local Fiscal Recovery Funds Name of contact person and title: Kori Kappes, Finance Administrator Anticipated completion date: June 30, 2024 Agency’s Response: Concur The Department will ensure subaward entities provide all records to the division relating to federal awards. The Department will also ensure it retains all records for a period of 3 years from the final expenditure report submission date. The Department will continue to resolve the $10,000 of questionable costs as deemed appropriate by the State of Arizona Office of the Governor and the United States Department of Treasury.

Assistance listing number and program name: 14.231 Emergency Solutions Grant Program 14.231 COVID-19- Emergency Solutions Grant Program 14.267 Continuum of Care Program Agency: Department of Housing Name of contact person and title: Keon Montgomery, Assistant Deputy Director of Programs Molly Bright, DCAD Assistant Director (DES) Anticipated completion date: April 30, 2024 Agency’s Response: Concur Department of Housing response: The Department is no longer reimbursing the subrecipient for unsupported or ineligible costs and is working to resolve the issue. The HUD Field Office is aware of the findings and the Department is working toward resolution. Written policies for reviewing and approving subrecipient reimbursements, as well as, risk assessment will be reviewed and updated. Contract specialists in the Special Needs Division have begun training and the Department will continue to leverage Federal educational resources centered on Grants and Agreements, 2 CFR 200 cost principles and award requirements. Department of Economic Security response: Agency: Department of Economic Security Name of contact person and title: Molly Bright, DCAD Assistant Director Anticipated completion date: June 30, 2024 Agency’s Response: Concur The Department will stop the reimbursement of costs to all nonprofit and contracted subrecipients for all items that are disallowed and/or restricted by the regulations provided for within the provisions of the federal Emergency Solutions Grant Program (ESG), including payments that violate the conflict-of-interest disclosure requirements. Additionally, the Department will revise its cost monitoring policy to ensure compliance with these regulations prior to disbursing any ESG funding to any subrecipient for any purpose. The Department will also update its policies and procedures for subrecipient monitoring. The Department will assess the risk of noncompliance violations for each subrecipient and establish a plan of action to address noncompliance. The plan of action will include an array of training and educational processes to ensure applicable personnel are knowledgeable of ESG compliance requirements and Department contracts. The Department will also monitor subrecipients per updated policies and procedures. The Department will continue to resolve the unallowable costs reimbursed to subrecipients as deemed appropriate by the United States Department of Housing and Urban Development.

Assistance listing number and program name: 12.401 National Guard Military Operations and Maintenance (O&M) Projects Agency: Department of Emergency and Military Affairs (DEMA) Name of contact person and title: Jensen Forde, CFO Anticipated completion date: April 30, 2024 Agency’s Response: Concur DEMA HR anticipates having this completed by April 2024 at the latest. All employee records will be audited, corrected and maintained per the finding. HR staff has received a copy of the Department’s Record Retention Schedule and effective immediately will adhere to the policy.

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