Corrective Action Plans

CORRECTIVE ACTION PLAN State Fiscal Year Ended June 30, 2024 CCDF Cluster (ALN #93.489, #93.575, #93.596) and COVID-19 CCDF Cluster (ALN #93.489, #93.575, #93.596) State Agency: Department of Health and Human Services (DHHS) Audit Contact: Shannon Winn Title: BCDHSC Finance Manager Telephone: 603-271-9663 E-mail address: Shannon.S.Winn@dhhs.nh.gov Audit Report Reference: 2024-025 – Subrecipient Monitoring Anticipated Completion Date: June 30, 2025 Corrective Action Planned: We currently review all the expense details submitted on a monthly basis for our sub-recipients and have program review that the reporting and expense details support the sub-recipients work. However, we did not properly document the procedures that were performed. We have implemented a procedure of direct review of all sub-recipients to include receiving supporting and reviewing documentation, monitoring spends of awarded funds, and working directly with program to ensure the sub-recipient work is being monitored and supports the scope. We will put a procedure in place to establish the necessary monitoring at the start of each FY by utilizing the RAT that sets a minimum standard.

CORRECTIVE ACTION PLAN State Fiscal Year Ended June 30, 2024 93.568 Low-Income Home Energy Assistance State Agency: Department of Energy Audit Contact: Leonard Rautio Title: Chief of Operations Telephone: (603) 271-6008 E-mail address: leonard.j.rautio1@energy.nh.gov Audit Report Reference: 2024-021, 2023-015, 2022-025,2021-027 – Subrecipient Monitoring Anticipated Completion Date: Complete Corrective Action Planned: Concur The Department has put into place processes and updated our procedures to prevent this from happening in the future. However, we were unable to change amendments that were completed prior to the implementation of these procedures. All new contracts and amendments since the change in procedures include the required information. The Department has made changes to processes and personnel to ensure the data compiled and utilized for the Annual Report on Households Assisted by LIHEAP is verified, complete, and accurate. While a federally approved third-party completed the report reviewed for this audit, the Department successfully completed the most recent Annual Household Report (due December 2024).

CORRECTIVE ACTION PLAN State Fiscal Year Ended June 30, 2024 93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) State Agency: Department of Health and Human Services (DHHS) Audit Contact: Richelle Swanson Title: DPHS Finance Director Telephone: 603-271-4613 E-mail address: Richelle.R.Swanson@dhhs.nh.gov Audit Report Reference: 2024-020, 2023-011, 2022-018, 2021-021 - Subrecipient Monitoring Anticipated Completion Date: June 30, 2025 Corrective Action Planned: We currently review all of the expense details submitted on a monthly basis for our sub-recipients. However, we did not properly document the procedures that were performed. We have implemented a financial monitoring checklist that will specify each procedure and include a date that it was completed on. We have submitted attestations verifying the procedures that took place in SFY2024.

CORRECTIVE ACTION PLAN State Fiscal Year Ended June 30, 2024 93.044, 93.045, 93.053 Aging Cluster State Agency: Department of Health and Human Services (DHHS) Audit Contact: Kyra Leonard Title: DBH & DLTSS Finance Director Telephone: 603-271-5052 E-mail address: Kyra.C.Leonard@dhhs.nh.gov Audit Report Reference: 2024-017 – Subrecipient Monitoring Anticipated Completion Date: June 30, 2025 Corrective Action Planned: The Team responsible for the risk assessments will be expanded moving forward to include a member of the Finance team with the intention to collaborate on inclusion of the necessary monitoring activities. Monitoring activities were completed; however, they were not appropriately documented at the time. Therefore, to record the review of the invoices, along with the monitoring activities outlined on the risk assessment, we have implemented a financial monitoring checklist that includes the risk assessment monitoring items. This checklist will specify each procedure and include a date that it was completed on.

CORRECTIVE ACTION PLAN State Fiscal Year Ended June 30, 2024 Fish and Wildlife Cluster (Assistance Listing #15.605, #15.611, #15.626) State Agency: NH Fish and Game Department Audit Contact: Randy Curtis Title: Federal Aid Administrator Telephone: (603) 271-0801 E-mail address: randy.l.curtis@wildlife.nh.gov Audit Report Reference: 2024-005 – Subrecipient Monitoring Anticipated Completion Date: June 30, 2025 Corrective Action Planned: We partially concur with the finding. A. The Department concurs there were required elements missing from the information included in tested subaward agreements. The Department will develop templates and put in place a process to ensure that all subrecipient agreements contain all required communications. B. The Department concurs and has recently completed and is implementing new internal policies and procedures that address nearly all of the conditions identified in this finding overall. These written policies and procedures were designed to be in compliance with the requirements of 2 CFR Part 200 Subpart D - Subrecipient Monitoring and Management and to establish improved internal controls. The policy includes a process for completing a risk assessment which outlines they types and frequency of monitoring procedures and for documenting their completion. C. The Department partially concurs with this condition. We believe the level of detail included within the invoice was consistent with the terms of the agreements and project budgets and did allow Department staff reviewing the reasonableness of the costs incurred to ensure that they were incurred in accordance with the grant agreement. Additionally, the Department’s updated subrecipient monitoring policies and procedures will provide for testing and requesting detailed backup and support for at least one invoice annually. D. The Department concurs there was no specific evidence denoting approval of the subaward reports. However, Department project leaders do review reports received from subrecipients and typically include them as attachments in our own grant reports to the Fish and Wildlife Service. A step will be added to monitoring procedures to include specific Department approval of subrecipient reports. Further, the Department will include a step for documentation of the receipt and review of subrecipient Uniform Guidance audit reports.

Recommendation We recommend updating internal policy over subrecipient monitoring and recommend implementation of effective internal controls and procedures over subrecipient monitoring and tracking that allow for compliance with all applicable federal laws, regulations, and compliance requirements of various federal grants. It seems likely that additional monitoring activities are being performed that are not currently being documented in a central location, and therefore we recommend standardizing the documentation of such activities. Management Response Corrective Action: We concur with this finding and the auditor's recommendation. As stated in the past the Department is in the process of implementing policies and procedures to ensure proper monitoring of subrecipients. The Department has had two significant staff resignations that has hindered the progress on these corrections. The Department has found replacements and will continue with training for both the financial and the grants departments. Subrecipient monitoring tools, such as excel worksheets and checklists are being reviewed and modified to fit the Department's needs. The complete implementation of the subrecipient policies and processes is expected to be completed June 2025. Due Date of Completion: June 30, 2025 Responsible Person(s): Deputy Cabinet Secretary, Grants Unit Manager

1. Person responsible: Assistant Auditor-Controller, Department of Auditor-Controller 2. Corrective action plan: The County agrees with the finding and recommendation. The County hired independent Certified Public Accounting (CPA) firms to monitor CSLFRF subrecipients. The CSLFRF subrecipient monitoring reviews are currently in progress, with the objective of evaluating each subrecipient’s fiscal/administrative procedures, internal controls, records, and compliance with contractual service requirements. Based on an agreed-upon schedule with the Department of the Auditor-Controller, the CPA firms will document their reviews by issuing reports detailing the procedures performed and any findings. The County will be responsible for obtaining corrective action plans from subrecipients, monitoring findings, and ensuring that corrective actions are implemented. 3. Anticipated implementation date: June 30, 2026

2024-003 – Subrecipient Monitoring – Internal Control and Compliance over Subrecipient Monitoring (Significant Deficiency) Condition: During the review of subrecipient monitoring records, several areas were noted for improvement: • For two (2) out of three (3) subrecipients, the official agreement was not formally documented. One subrecipient agreement was executed via internal resolution and email approval; another subrecipient’s agreement lacked sufficient identification and award details, omitting key funding terminology. • The City’s Subrecipient Monitoring Policy, which became effective on April 17, 2024, does not cover the period before the policy took effect. For all three (3) subrecipients, the City is unable to provide any documentation of the review of Financial and Performance Reports. • The required Pre-Award Risk Assessments have not been provided for at least one subrecipient because the City’s Subrecipient Monitoring Policy, which became effective on April 17, 2024, does not cover the period before the policy took effect. Management concurs. Corrective Actions: Staff will prepare new forms for subrecipient monitoring and communicating the requirements to all departments to ensure that subrecipient monitoring will follow the compliance requirements. Name of Responsible Person: Rose Tam, Director of Finance Albert Trinh, Accounting Manager

Management agrees with the finding. The Office of Sponsored Programs will conduct a review of the subrecipient issuance and monitoring process to ensure that roles and responsibilities regarding the timely monitoring of subrecipients' single audit reports are clear and that any personnel engaged in review of the single audit reports receives training regarding these activities.

Reference Number: 2024-011 Prior Year Finding: No Federal Agency: U.S. Department of Transportation State Agency: Agency of Transportation Federal Program: Highway Planning and Construction Assistance Listing Number: 20.205 Award Number and Year: FFY2023 – FFY2024 Compliance Requirement: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Recommendation: VTrans should review and enhance internal controls and procedures to ensure that all required federal award information is included in subawards and that on-site subrecipient monitoring is conducted timely per the terms of its subrecipient monitoring plan. Views of responsible officials: Management agrees with the finding. Corrective Action Plan: Missing Federal Award Date: The Contract Administration, Grants Unit addressed the deficiency of missing federal award dates during the FY23 State Single Audit (in effect as of 1/12/2024). As part of the updated award execution process, the Grants Unit now verifies that all awards include the federal award date and applicable FAIN number. Awards executed prior to the implementation of this process are being updated during amendments to ensure compliance. Subrecipient Monitoring: The root cause of the subrecipient monitoring deficiency was staffing shortages, which affected the Agency of Transportations (AOT) ability to meet monitoring requirements on time. The AOT monitoring requirements have been transitioned from the Audit Bureau to the Contract Administration, Grants Unit. The Grants Unit has already identified and will prioritize Subrecipients based on the last date monitored. Workflow modifications to include efficiencies are also in progress. These efficiencies will help with timeliness. The revisions to the monitoring activities will be in the VTrans Granting Plan effective July 1, 2025. Scheduled Completion Date of Corrective Action Plan: All corrective actions will be implemented as of July 1, 2025. Contacts for Corrective Action Plan: Tricia Scribner, Administrative Services Manager III tricia.scribner@vermont.gov

Career and Technical Education Response/Corrective Action Plan: The department agrees with this recommendation The department has developed a system to identify which subrecipients are subject to required audits and are tracking subrecipients to ensure timely submission of required audit reports and appropriate corrective actions. Contact Person: Wayde Sick, Director and Executive Officer and Gwen Ferderer, Finance Director Anticipated Completion Date: August 2024

Department of Public Instruction Response/Corrective Action Plan: DPI agrees with the finding. We have split the duties of subrecipient review among two employees. One person does the administrative functions and responses to subrecipients who have no findings. The other employee works on the more complex audit reviews. We feel that this change along with the increase to the audit threshold and the end of the COVID related federal funding will allow us to stay in compliance of federal regulations. Contact Person: Jamie Mertz, CFO Anticipated Completion Date: This was implemented January 2, 2025

PDOA: 1. Designing a means to follow-up and ensure timely action of deficiencies through an audit tracking log to monitor reporting submissions, document when they were received, initiated, findings requiring follow-up, and subsequent steps to finalize the audit. 2. Management decisions for applicable findings will be issued and tracked. 3. Improvements have been made with regards to regularity in reporting to more effectively monitor activities of subrecipients consistently with respect to Federal statutes and regulations. 4. PDOA is looking to fill a vacant position with a focus of tracking subrecipient expenditures in the aggregate and tracking single audit submissions on a Commonwealth-wide basis since the Aging Cluster program is material and has material sub-granted expenditures in NSIP and Title III. 5. It is PDOA’s impression that having increased oversight of the SEFA will allow for timely dissemination of management decision letters (MDL) in the six-month timeframe for making a management decision for federal award findings. 6. Discussions have started regarding considerations to take enforcement action against noncompliance by building language into the terms and conditions of the Cooperative Block Grant Agreements to exercise ability to withhold funding as approved in the Cost Allocation Plan. 7. PDOA has reached out to the BAFM to verify all outstanding audit items for PDOA since action is required within six months of receipt. 8. Follow-up procedures resulting from this finding will be reviewed and adjusted as needed to deliver optimal outcomes. Anticipated Completion Date: 06/30/2025 Contact Name: Jennifer Cave, Fiscal Management Specialist, PDOA Audit Liaison PDA: PDA has added a Financial Management Specialist 1 (FMS1) to its complement with the primary duty of agency audit liaison. The FMS1 will report to the PDA’s Budget Office. This is a new position and role within the department and has training and certification requirements to complete which will allow the position to: 1. Evaluate single audit report submissions received from BAFM to determine program purpose acceptability by verifying, at a minimum, that all agency-funded programs are properly included on the applicable financial schedules; that findings affecting the agency contain sufficient information to facilitate a management decision; and that the subrecipient has submitted an adequate corrective action plan. 2. Issue management decisions relative to audit findings and crosscutting findings assigned to the agency for resolution, as required by 2 CFR §200.521. If responsible for the resolution of crosscutting findings, notify the affected agency or agencies upon resolution of such findings. 3. Impose or coordinate the imposition of remedial action in accordance with 2 CFR Part 200.339 and Management Directive 325.08 Amended, Remedies for Recipient Noncompliance with Audit Requirements, when subrecipients fail to comply with the provisions of Subpart F. The new FMS1 will help ensure effective and efficient audit resolutions. This newly created position will also be responsible for the department wide audit tracking log that is in development. Anticipated Completion Date: 06/30/2025 Contact Name: Nichole Nedinsky, Fiscal Management Specialist, PDA Audit Coordinator PDE: The PDE Audit Section is working with divisions to develop processes to ensure timely responses. A training will be conducted by April 2025 on audit procedures, best practices, and federal regulations governing single audit management decisions. Anticipated Completion Date: 04/30/2025 Contact Names: Clayton P. Carroll II, Audit Coordinator; Jessica Sites, Director, Bureau Financial Operations DEP: DEP has updated the concur subrecipient letter to include the specific language related to the management decision that was previously in our non-concur letters. This ensures whichever template is used, the management decision and related finding information will be included in the subrecipient letter. Revised letters were sent to both subrecipients, in which DEP was the lead agency and had findings for in the audited timeframe. Staff are reviewing all the steps of our standard operating procedures to ensure we will be in compliance regardless of whether DEP is or is not the lead agency and regardless of whether we are preparing a concur or non-concur letter for the subrecipient. Anticipated Completion Date: 06/30/2025 Contact Names: Jennifer Brandt, Senior Fiscal Mgmt. Specialist; Kristen Szwajkowski, Lead Fiscal Mgmt. Specialist DHS: As stated in the DHS finding response, this was the result of human oversight, and not a systemic issue with internal controls. We have reminded staff to make sure that a management decision is timely communicated to subrecipients at the time of making the management decision. Anticipated Completion Date: Completed Contact Names: David Bryan, Mgr., Audit Res. Section; Alexander Matolyak, Dir., Div. of Audit & Rev.

FINDING 2024-002 Finding Subject: PPHF Geriatric Education Centers - Subrecipient Monitoring Summary of Finding: Audit Finding 2024-002 states that the University of Southern Indiana did not establish a system of internal controls to ensure that subrecipient audit reports are received and reviewed, when required, to ensure that subrecipients are properly monitored in accordance with Federal regulations. Contact Person Responsible for Corrective Action: Jina Platts, Assistant Vice President for Finance and Administration and Assistant Treasurer Contact Phone Number and Email Address: 812-465-7090; jlplatts@usi.edu Views of Responsible Officials: We concur with the finding that the University should have ensured that subrecipient audit reports were received and reviewed, when required, to ensure that subrecipients are properly monitored in accordance with Federal regulations. The University had other controls in place related to subrecipient monitoring including the review of financial reports and requests for reimbursement for subrecipient expenses. One purpose of collecting and reviewing subrecipient audit reports is to determine the level of monitoring required as high, medium, or low. Although the University treats all subrecipients as high risk, we are unable to issue a formal management decision to subrecipients within six months of acceptance of the audit report by the Federal Audit Clearinghouse without assurance that audit reports are received and reviewed in a timely manner. Description of Corrective Action Plan: The University will update subrecipient monitoring procedures as follows: 1. Upon issuance of a subaward, the Business Office will verify if a subrecipient is subject to single audit according to OMB Uniform Guidance. If so, the subrecipient must provide a complete copy of their most recent independent audit used to meet their OMB Uniform Guidance requirement or a link to their record on the Federal Audit Clearinghouse. 2. The Business Office will review the report to verify that there are no findings that may impact the proposed subaward. In the event there are such findings, the Business Office will notify the Office of Sponsored Projects & Research. Together the two offices will determine an appropriate plan of action and issue a Management Decision Letter as required by Uniform Guidance. 3. The Business Office will identify subrecipients receiving payments quarterly and verify that their most recent audit reports have been received and reviewed. Any audit reports completed after issuance of a subaward will be reviewed as described in #2 above. Anticipated Completion Date: Planned corrective actions to be implemented in January 2025.

Recommendation We recommend updating internal policy over subrecipient monitoring and recommend implementation of effective internal controls and procedures over subrecipient monitoring and tracking that allow for compliance with all applicable federal laws, regulations, and compliance requirements of various federal grants. It seems likely that additional monitoring activities are being performed that are not currently being documented in a central location and, therefore we also recommend standardizing the documentation of monitoring activities, using monitoring logs, monitoring checklists, and audit test sheets, etc. If the Department is experiencing periods where understaffing or staffing turnover is an issue causing risk of noncompliance, we recommend that the Department properly address those risks and consider contracting out certain monitoring controls to a third-party professional service firm. Management Response Corrective Action: Serve New Mexico acknowledges the lack of sufficient documentation for annual site visits and that fiscal monitoring activities for the 2023-2024 program year were not sufficient. To address this, we are revising our policies and procedures to comply with 2 CFR 200.303 (Internal Controls) and 2 CFR 200.332 (Requirements for Pass-Through Entities). Key actions we are implementing include: 1. Site Visits Documentation: We will conduct regular site visits as a component of our monitoring activities for 2024-2025 program year with clear, consistent and documented objectives for each visit and proper documentation of monitoring activities conducted during each visit. 2. Expansion of Fiscal Monitoring: Review of cost documentation will be expanded to include all subgrantees, regardless of risk, and for subrecipients subject to heightened fiscal monitoring, review of more than one month of documentation will be conducted. 3. Centralized Documentation: All supporting documentation will be scanned and stored in a centralized shared folder. This will ensure clarity and accessibility of records, particularly in the event of staff turnover. 4. Collaboration with a Consultant: Our Fiscal and Compliance Officer is working closely with a consultant to streamline fiscal policies and procedures in line with 2 CFR 200—Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. 5. Uniform Audit Test Sheet: We will develop a standardized audit test sheet to ensure that all programmatic and fiscal monitoring activities are consistently documented across all programs. These steps are designed to ensure compliance and enhance the effectiveness of our monitoring processes, addressing the findings of the audit comprehensively Due Date of Completion: June 30, 2025 Responsible Party(ies): Serve New Mexico Director

Recommendation We recommend updating internal policy over subrecipient monitoring and recommend implementation of effective internal controls and procedures over subrecipient monitoring and tracking that allows for compliance with all applicable federal laws, regulations, and compliance requirements of various federal grants. We also recommend standardizing the documentation of monitoring activities, using monitoring logs, monitoring checklists, and audit test sheets, etc. If the Department is experiencing periods where understaffing or staffing turnover is an issue causing risk of noncompliance, we recommend that the Department properly address those risks and consider contracting out certain monitoring controls to a third-party professional service firm. Management Response Corrective Action: The Department acknowledges that we had not completed the required monitoring for Program Years 2022 and 2023. The Department has contracted with a third-party monitor to complete the Program Years 2022 and 2023 monitoring. Program Year 2024 monitoring is on track to be completed by June 30, 2025. The Department has created a corrective action plan to bring the WIOA monitoring into compliance. The Department has completed a risk assessment for Program Year 2024 which is now attached to the grant agreements. The WIOA Monitoring Unit will use the Department’s Grant Risk Assessment tool for future grant agreements. The WIOA Monitoring Unit is in the process of drafting a policy for subrecipient monitoring. This policy will establish monitoring standards for subrecipients and pass-through entities of WIOA Title I-B and related discretionary awards. The policy will include: Frequency of Monitoring Reviews Scope of Monitoring Reviews Monitoring Letters and Reports Due Date of Completion: June 30, 2025 Responsible Party(ies): Administrative Services Division Director

2024-001 – 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: FY2024 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 for subrecipients were not reviewed. As noted, 1 of the 25 selections tested was not included in the Post-Award review of subrecipient Uniform Guidance reports. Following a comprehensive review, 12 subrecipients were identified as inadvertently omitted from the overall report data used to conduct the subrecipient Uniform Guidance report analysis for the year ended June 30, 2024. After identification of the missing subrecipients and completed prior to the issuance of this report, the University reviewed the 12 respective entities’ Uniform Guidance reports or appropriate documentation and determined that there was no impact on Tufts University and no follow-up was deemed necessary. By June 30, 2025, and on an annual basis, the University’s Post-Award office will utilize automated reports including the complete data set to 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.

In response to the findings on subrecipient monitoring, the Organization has updated its Grant Cycle Standard Operating Procedures to align with OMB Uniform Guidance. These revised procedures now require documented checks for suspension or debarment for all subrecipients, along with mandated follow-up on any subrecipient audit findings. In addition, staff have received enhanced training on these requirements, and the onboarding process has been updated to include a focused review of subrecipient monitoring. Finally, a new position has been established to manage vendor purchase orders and maintain comprehensive sourcing documentation, thereby strengthening overall oversight and ensuring ongoing compliance with federal requirements. In addition, the Organization conducts an annual subrecipient risk assessment and maintains a monitoring file for each subrecipient that includes audit reviews, SAM.gov verifications, monitoring communications, and follow-up on audit findings. Documentation is retained to demonstrate ongoing monitoring.

The MOF requires that all necessary documents, including expenditure and financial reports, be submitted prior to the release of subsequent funding. These reports are reviewed and processed by the Compliance Unit once complete. Additionally, the Sub-Grants Monitoring Procedures Manual has been updated to require management, through the Chief of Internal Audit, to prepare a management decision letter. Furthermore, a proposed adjusting entry will be made to recognize a receivable for the overpayment, which will be discussed with the grantor.

The formal process for completing and retaining Subrecipient Agreements is now operational to ensure compliance with programmatic obligations. As the recipient, it is the territory's responsibility to notify the Subrecipient when the federal funds are obligated and provide them with a subrecipient agreement which outlines the terms and conditions of the program. The Disaster Program Financial Specialist is responsible for obtaining the subrecipient agreement and ensure it has been signed by the Applicant/Subrecipient and Governor's Authorized Rep and later provided to the Territorial Public Assistance Officer (TPAO). As such, no funds will be disbursed until the Subrecipient signs and returns the agreement. These agreements are saved in a centralized location for documentation and audit purposes. In accordance with the 2CFR #200 Subpart F, all Subrecipients must comply with applicable audit requirements because the applicant is in the receipt of federal funding. Under 2CFR #200.500 Subpart F applies to any non-federal entity that expends $750,000 or more in federal awards during a fiscal year. Subrecipients meeting this threshold are required to undergo a single audit or a program specific audit for that fiscal year. The TPAO will review audit requirements during the applicant's briefing and will incorporate these requirements into the Subrecipient Agreement.

VIDE, through the Office of Federal Grants (OFG), acknowledges the finding and concurs with the need to strengthen internal controls related to subrecipient identification, monitoring, and compliance with federal audit requirements, as outlined in 2 CFR Part 200, Subpart F. During the period under review, gaps in documentation and monitoring were impacted by staff turnover, leadership transitions, and programmatic shifts, which limited the consistency and precision of subrecipient oversight across programs. In response, OFG has taken steps to reinforce its role as the pass-through entity and to formalize monitoring expectations and processes. OFG is committed to ensuring that all subrecipient agreements clearly identify the federal award and applicable requirements, including reporting, audit, and compliance obligations under 2 CFR Part 200, Subpart F, in accordance with 2 CFR §§ 200.331 and 200.332. Subrecipient agreements will explicitly outline financial, programmatic, and reporting expectations necessary for VIDE to meet its own federal responsibilities. In addition, OFG is strengthening risk-based subrecipient monitoring practices, including evaluating prior audit results, changes in personnel or systems, and the complexity of subawards to determine the appropriate level of oversight. Monitoring activities will include documented reviews of financial and programmatic reports and follow-up on identified deficiencies, as required. Through these actions, OFG is working to ensure that subrecipients are properly identified, monitored, and supported, and that federal funds are expended in accordance with all applicable statutes, regulations, and award terms.

The Government concurs with the auditor’s findings and recommendations. Starting FY25, OMB will identify and monitor federal awarding agencies, requesting single audit results for applicable recipients and including them in monitoring reviews. For revenue replacement projects, Treasury's Final Rule FAQ (13.14) states that these funds do not create subrecipient relationships, thus exempting them from the Single Audit Act due to the absence of a federal program or purpose.

The Government concurs with the auditor’s findings and recommendations. The GVI is currently in the process of developing a comprehensive Grants Management Overarching Standard Operating Policies and Procedures (SOPP) to establish uniform guidance for all grant-related processes, including drawdowns, documentation retention, subrecipient and compliance monitoring. Training will be provided to all staff on the SOPPs.

Recommendation: We recommended the City enhance its subrecipient monitoring activities and establish a formal record-keeping policy to ensure complete and timely documentation of expenses. Views of Responsible Officials: Management concurs with the finding. The City of Adelanto experienced higher than expected staff turnover in the finance department during the timeframe noted in this audit, which caused a backlog in audit preparation and submission, along with certain financial controls implementation interruption. At the time of this audit publishing, Management believes that implementation of such procedures is in compliance with the noted recommendation. Persons Responsible for Corrective Action: City Finance Staff (various) City Department Heads applying for grant funding (various) Anticipated Completion Date for Corrective Action: Corrective action has been immediately implemented in response to the auditors’ recommendation. As financial reporting is still in the process of becoming current, the City anticipates finding to be removed in future fiscal years.

Trailhead is establishing a new Contract and Compliance Coordinator role to oversee contract compliance processes and to ensure that Trailhead’s policy on subrecipient monitoring is followed. This role will be responsible for ensuring that compliance requirements are integrated at the outset of each grant. This role will be responsible for internal monitoring and auditing. This role will ensure that all grant kick-off meetings follow a standard procedure and include: 1) A clear understanding of federal requirements for all involved fiscal, program, and compliance staff 2) Delegated assignments to program staff for implementing and documenting: a) Suspension and debarment prior to contracting with subrecipients b) Subrecipient vs contractor determinations c) Evaluation of each subrecipient’s risk of noncompliance i) Establish the appropriate subrecipient monitoring level based on risk. This compliance role will have the authority to ensure the procedures are completed by the assigned staff. Evidence of the completed procedure must be documented and saved in a newly created contracts database. This database will be a centralized storage that will be reviewed during internal compliance checks to ensure all required steps have been completed and documented. These documents and associated grant and contract documents will be part of an official repository.