Corrective Action Plans

Assistance listing numbers and program names: 14.231 Emergency Solutions Grant Program 14.231 COVID-19 - Emergency Solutions Grant Program 93.558 Temporary Assistance for Needy Families 93.558 COVID-19-Temporary Assistance for Needy Families Agency: Arizona Department of Economic Security (DES) Name of contact person and title: Molly Bright, DES CCSD Assistant Director Anticipated completion date: June 30, 2025 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 of the federal Emergency Solutions Grant (ESG) program and Temporary Assistance for Needy Families (TANF) grant, including payments to personnel that violate the conflict-of-interest disclosure requirements. The Department will revise its expenditure review procedures to ensure compliance with these regulations prior to disbursing any ESG and/or TANF funding to any subrecipient for any purpose. These revisions will include review and approval by applicable management personnel prior to disbursement of federal funding. The Department is also in the process of establishing a divisional Monitoring and Compliance Policy and Procedure Manual which will establish procedures specific to subrecipient monitoring. The Department will continue to 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 programmatic compliance requirements and Department contracts. The Department will also monitor subrecipients per its updated policies and procedures and will ensure proper oversight of federal expenditures as required by federal regulations. The Department has amended its contracts with the applicable subrecipients to more clearly outline the regulatory requirements and expectations for expenditures under the ESG and TANF grants. The Department will also continue to resolve the unallowable costs reimbursed to subrecipients as deemed appropriate by the applicable federal agencies.

2023- 007 - Material Weakness in Internal Control and Material Noncompliance – Sub-recipient Monitoring and Management WPHW understands this finding and recognizes that correction that were planned for FY23 were not able to be fully implemented. One of the significant challenges WPHW had over the past couple of year, in addition to IT system challenges, is staffing. WPHW has hired three individuals to develop our contracting process and had performance issues with all three individuals. In addition to the difficulties with the NetSuite implementation, we have had to re-evaluate our sub-recipient monitoring and management business process. The following process will address this finding: 1) Director of Accounting and the Accounting Manager will review CFR 200.332 and develop a revised business process for the WPHW contract system a. Accounting Team will hire 2 Accounting Specialists who will each have specific sub-recipient monitoring responsibilities 2) Director of Accounting and the Accounting Manager will review all current contract to ensure the following: a. Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes: i. Federal, State or other award identification. ii. Subrecipient name (which must match the name associated with its unique entity identifier); iii. Subrecipient's unique entity identifier; iv. Award Identification Number (FAIN/SAIN); v. Award Date of award to the recipient by the Federal agency; vi. Subaward Period of Performance Start and End Date; vii. Subaward Budget Period Start and End Date; viii. Amount of Federal Funds (if applicable) Obligated by this action by the pass-through entity to the subrecipient; ix. Total Amount of Federal Funds Obligated, if applicable, to the subrecipient by the pass-through entity including the current financial obligation; x. Total Amount of the Federal Award committed to the subrecipient by the pass-through entity; xi. Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA); xii. Name of Federal awarding agency, pass-through entity, and contact information for awarding official of the Pass-through entity; xiii. Assistance Listings number and Title; the pass-through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at time of disbursement; xiv. Identification of whether the award is R&D; and xv. Indirect cost rate for the Federal, State, or other award (including if the de minimis rate is charged) per § 200.414. b. All requirements imposed by the pass-through entity on the subrecipient are in accordance with Federal, State, Local statutes, regulations and the terms and conditions of the award; c. Determines and ensure completion of required financial and performance reports; d. Has an approved federally recognized indirect cost rate negotiated between the subrecipient and the Federal Government or utilizes the de minimus. e. States that subrecipient permit the pass-through entity and auditors to have access to the subrecipient's records and financial statements as necessary for the pass-through entity to meet the requirements of this part f. Details appropriate terms and conditions concerning closeout of the subaward. g. Subrecipient risk assessment that accesses: i. prior experience with the same or similar subawards; ii. previous audits iii. personnel or substantially changed systems iv. Prior monitoring results 1. Subaward conditions will be placed if issues arise 3) Implement sub-recipient monitoring process. a. Conduct invoice review monthly i. All invoices must include full back up and support for expenses ii. All invoices will be reviewed as they are received to ensure expenses are allowable iii. Any issues that arise will be addressed prior to invoice payment b. Conduct contract monitoring visit annually i. Hold a meeting with the sub-recipient to review the following: 1. Reviewing financial and performance reports 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the subaward. 3. Training and technical assistance on program-related matters 4. Determine corrective action for any deficiencies or findings and determine risk 5. Discussion of enforcement action against noncompliant subrecipient This process will be reviewed, and implementation will begin during Q4 FY24. All current FY24 contracts will be reviewed, and monitoring visits scheduled. For FY25, all contracts will be in compliance with requirements.

Condition: The Organization did not clearly communicate the required federal award information and applicable requirements to the subrecipients. The Organization did not evaluate the risk of non-compliance of the subrecipients in order to identify the appropriate monitoring procedures. Statistical sampling was not used in making sample selections. Response: The Organizations’ Board and Chief Executive OGicer (CEO) and key HCEDC StaG recognize the need to further refine subrecipient monitoring. Subrecipients within the identified project are all school districts already under single audit with associated levels of financial controls and reporting. Participating districts, via their appropriate elected boards, were informed the conditions of the grant and individually voted to accept obligations and requirements. Some subrecipients in Fall 2023 did attempt to submit unauthorized expenses, the controls were adequate for management to identify these discrepancies, which were in turn not submitted for reimbursement to the state, and appropriate amendments were made prior to any expense being reimbursed. HCEDC management, in alignment with outsourced controller services via CliftonLarsonAllen LLP, have now further increased controls and monitoring activity. Through the onboarding of a new Grants Management System (GMS) in Fall 2024, subrecipient monitoring activity and profiles are now created for each eligible award. In 2024, the HCEDC has also been much more active in communicating reporting and grants management requirements to subrecipients, including multiple amendments to the ESSER grant program. The new GMS system is built specifically to assist organizations with single audit compliance and has multiple features specific to subrecipient reporting and monitoring.

Condition and Context: ACT noted that it did not request and review audited financial statements for all subrecipients. Recommendation: ACT evaluates the policies and procedures to ensure appropriate monitoring is performed over all subrecipients and reviews audited financial statements for those subrecipients that are required to have an audit performed. Views of Responsible Officials and Planned Corrective Action: ACT accepts the auditors’ recommendation. We will review and update the monitoring policies and procedures to include requesting and reviewing the audited financial statements for those subrecipients that are required to have an audit performed.

Recommendation: We recommend the Society to establish an official written policy for subrecipient monitoring that is in line with the requirements of the Uniform Guidance. The policy should contain components for compliance with and references to Federal requirements, such as review of reports requested from the subrecipient regarding project status, reviewing invoices to ensure spending is limited to expenses involving approved projects, and proper approval procedures key personnel perform to ensure these invoices are valid. Management Response and Corrective Action Plan Management's Response: We appreciate the auditor's thorough review and recommendations regarding our subrecipient monitoring processes. Legal Aid Society of San Bernardino is committed to maintaining the highest standards of compliance with federal regulations and ensuring proper oversight of subawards. We acknowledge the importance of having a comprehensive written policy that aligns with the requirements set forth in 2 CFR part 200, Appendix XI, Compliance Supplement May 2023, sections 3-M-1 and 3-M-2. Corrective Action Plan: 1. Formalize written policy: We will document our existing subrecipient monitoring practices into a comprehensive written policy that fully aligns with 2 CFR part 200, Appendix XI, Compliance Supplement May 2023, sections 3-M-1 and 3-M-2. This policy will include: a. Detailed procedures for reviewing financial and programmatic reports from subrecipients b. Guidelines for following up on and addressing any identified deficiencies c. Clear references to relevant Federal requirements 2. Standardize subaward agreements: We will develop a standardized subaward agreement template that incorporates all required elements as specified in the Uniform Guidance. This will ensure consistency and compliance across all subawards. 3. Enhance approval protocols: We will fortify our existing two-party approval system and bill.com submission process for payments. This reinforced procedure will ensure rigorous oversight and thorough validation of all subrecipient expenses, maintaining a robust checks and balances system that aligns with federal compliance requirements. 4. Implement regular reporting: We will continue our practice of requesting 6-month and end-of-year reports from subrecipients. This will help us monitor processes, identify any budget or client service deviations, and ensure ongoing compliance with subrecipient monitoring requirements. 5. Establish policy review process: We will implement an annual review of our subrecipient monitoring policies to ensure they remain current with any changes in Federal regulations. Planned Implementation Date: November 30, 2024 Responsible Person: Pablo Ramirez, Executive Director

Finding 2023-003 Finding Subject: Covid-19 – Coronavirus State and Local Fiscal Recovery Funds – Subrecipient Monitoring Summary of Finding: The County did not include all required information in the subrecipient agreements during the audit period. Contact Person Responsible for Corrective Action: Debbie Morton-Crum, County Auditor Contact Phone Number: 765-482-2940 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The County Commissioners are responsible for the American Rescue Plan project list along with that responsibility is to have a sub-recipient agreement in place with those outside entities that received American Rescue Plan grant monies from the County. An Internal Control is now in place that requires a sub-recipient agreement in place before a warrant can be paid to those outside entities. We will put procedures in place to ensure that money disbursed to sub-recipient is monitored. Anticipated Completion Date: December 2024

The City will establish an official written policy for subrecipient monitoring that is in line with the requirements of the Uniform Guidance.

Finding 2023-001 – Subrecipient Monitoring Cluster: Research and Development Agency: Department of Health and Human Services Award Names: Safety and Health Risks in Energy Transition for the Commercial Fishing Industry Award Numbers: U01OH012502 Assistance Listing Title: Center for Disease Control and Prevention (CDC) Assistance Listing Number: 93.262 Award Year: FY 2023 To ensure compliance with 2 CFR 200.332 (d), ABS will extend its current policy to review agencies’ annual audited financial statements when Uniform Guidance reports are not available. ABS will appoint a finance team member to review the Uniform Guidance report or financial statements and will offer the project management team feedback toward ensuring necessary monitoring actions are taken. ABS understands the associated funding risks and will begin implementing these processes while we draft and submit our policy update into our Quality Management system. We expect this to be corrected and implemented by December 31, 2024.

In June 2023, following the completion of the 2022 Single Federal Audit, APS immediately implemented additional policies, procedures, and controls to ensure that all subrecipients submit programmatic and financial reports in a timely manner and that these reports are reviewed by the Principal Investigator/Program Manager and Grant Administrator through a new reporting form. This form logs electronic signatures from both the sub-awardee and APS staff. In addition, APS implemented a procedure to review the single federal audit of each sub-awardee annually. APS will review and monitor award amounts and for the required filings annually to ensure that the award amounts are accurate and updated timely to meet all reporting requirements set forth under the Transparency Act. APS implemented the corrective action plan on June 5, 2023. Management's contact responsible for the implementation of the Corrective Action Plan: Name: Jane Hopkins Gould Position: Chief Financial & Operating Officer Telephone number: 301-209-3276

HSEM concurs with the finding. Condition A: NH HSEM Mitigation and Recovery leadership has updated the award letter templates to ensure the necessary information is included as outlined in the condition. Conditions B – D: NH HSEM Mitigation and Recovery leadership updated the Risk Assessment Quick Reference Guide (QRG) and Subrecipient monitoring QRG. A two hour in-person training was conducted on January 31, 2024, to Mitigation and Recovery staff which focused on conducting risk assessments and subrecipient monitoring. This will be reviewed with staff again during an upcoming Section meeting in March 2024.

Condition A: DHHS partially concurs. The review of expenditure details is an integral part of DHHS’ Subrecipient Monitoring and standard language is included in the templates for legal agreements. These five subrecipients were deemed low or no risk, examination of expenditure detail is considered sufficient monitoring. All five of these subrecipients had the inclusion of the monthly detail requirement in the contracts and this was performed prior to the invoice being submitted to AP for payment. DHHS will re-evaluate current practices to ensure that the documentation is sufficient for the current subrecipient monitoring process. Regarding the two selections identified as having risk assessments which did not specify recommended monitoring procedures: The Risk Assessment Tool for one subrecipient was performed after the subaward award. However, as indicated on the Tool, programmatic monitoring activities were included in the contract. DHHS reviewed the monthly back-up documentation provided with the submitted invoices prior to sending them to AP for payment. The risk assessment tool for the second selection was performed after the subaward award. However, as indicated on the tool, programmatic monitoring activities were included in the contract. We reviewed the monthly back-up documentation provided with the submitted invoices prior to sending them to AP for payment. Condition B: DHHS partially concurs. The review of expenditure details is an integral part of DHHS’ Subrecipient Monitoring and standard language is included in the templates for legal agreements. The subrecipients were deemed low or no risk, therefore, examination of expenditure detail is considered sufficient fiscal monitoring. DHHS employs the review of expenditure details, as allowed under 200.332 (d)(1), as an integral part of the Departments Subrecipient Monitoring. A review of the expenditures provides monitoring for the following concerns: • The familiarity a subrecipient has utilizing Federal funds • The subrecipient management teams’ familiarity with Federal funding • Single Audit findings • Any prior return of funding due to non-compliance • The subrecipient’s compliance with the requirements of 200.300 and 302 • Whether the subrecipient has a new financial system DHHS will re-evaluate the risk response parameters to determine that the level of documentation is sufficient to ensure that the procedures performed would be able to identify noncompliance at the subrecipient level. Condition C: DHHS concurs. DHHS will be updating procedures to include contacting vendors to remind them of the deadline regarding the submission of their single audit in the Federal Audit Clearinghouse.

The Department Concurs with paragraph A – Since this same finding was reported in March of 2023 for FY22, items a, c, and d are now included on all federal subaward contracts and policies have been updated to reflect this. The Department will ensure b is also included going forward. The Department concurs with paragraph B - The finding was a result of personnel turnover and medical issues. The Department has hired and trained additional program staff and updated policies to ensure programmatic monitoring and subsequent reports are done in a timely manner. The Department partially concurs with paragraph C. Fiscal monitoring was done for all 3 subrecipients during the federal program year. However, 1 subrecipient monitoring fell outside the state fiscal year so was not covered during the audit period. The Department has changed the wording on its risk assessment procedures to ensure no misinterpretation of the timeframe each subrecipient will be monitored in accordance with its risk assessment. The Department has also changed the requirements of the frequency of fiscal monitoring in each of the risk assessment categories. The Department Concurs with paragraph D – The Department is reviewing policies and procedures and will update them to ensure compliance with 2 CFR section 200.332(a), 2 CFR section 200.332(b) and 2 CFR section 200.521. The Department also created a tracking mechanism to ensure we receive, review, and issue management decisions (if required) in a timely manner. The Department concurs with Paragraph E - The Department is reviewing policies and procedures for both reporting and subrecipient monitoring to ensure data is tested and verified. The Department has already gained increased access to data in current software and is in the process of selecting a vendor for new software that will provide more testing and enhanced internal controls.

Condition A: DHHS concurs. Pursuant to the Subrecipient Monitoring Policy, the risk assessment and determination of subrecipient monitoring activities is performed during the procurement process with the Grants Administrator and the Program Lead. It is the responsibility of Program to perform the requested subrecipient monitoring. The Department provides annual training on the Subrecipient Monitoring Policy. We will reinforce the requirements of the Policy and the ramifications for the Department for the non-compliance in this year’s annual training. Regarding the incomplete Risk Assessment Tool, we will update the Subrecipient Monitoring Policy to include a secondary review of the Tool prior to implementation, as part of our internal controls. Condition B: DHHS does not concur. The Department employs the review of expenditure details, as allowed under 200.332 (d)(1), as an integral part of the Departments Subrecipient Monitoring. The Department’s review of the expenditures provides monitoring for the following concerns: • The familiarity a subrecipient has utilizing Federal funds • The subrecipient management teams’ familiarity with Federal funding • Single Audit findings • Any prior return of funding due to non-compliance • The subrecipient’s compliance with the requirements of 200.300 and 302 • Whether the subrecipient has a new financial system Standard language for the submission of expenditure detail is included in all templates for legal agreements. These subrecipients were deemed low or no risk, therefore, examination of expenditure detail is considered sufficient monitoring. Subrecipient monitoring activities are memorialized in the legal agreements. The Risk Assessment Tool provides a space for the monitoring activities to be selected, however, the Subrecipient Monitoring Policy does require the memorialization of the activities on the Tool for compliance, only to be memorialized in the legal agreement. Condition C DHHS partially concurs. As the subrecipient’s audit report had no findings, we are not required to issue a management decision letter. However, we will be updating our procedures to include contacting the vendors to remind them of the deadline regarding the submission of their single audit in the Federal Audit Clearinghouse.

Corrective Action Planned (Condition A): The DAS analyzed the six items erroneously reported as subawards and noted the errors were isolated to two specific agencies, the Department of Health and Human Services and the Department of Environmental Services. In response to the prior year finding 2022-002, the DAS had strengthened internal controls related to the review and validation of amounts reported by individual state agencies as pass through expenditures. This included an additional control specifically verifying SLFRF pass through expenditures reported by each agency. The DAS will offer additional training relative to identification and reporting of subaward expenditures in its annual statewide Single Audit training and re-evaluate the precision of execution of controls over the validation of pass through reporting in assembling the SEFA for fiscal year 2024. Corrective Action Planned (Conditions B through E): The State largely concurs with the findings and recommendations and has implemented procedures to address the identified conditions already or will do so. With regards to condition B, The State will work with the individual agencies to ensure that individual agencies entering into such agreements clearly indicate the terms required by Uniform Guidance, including permitted indirect cost rates and whether the award is for R&D. The State has already begun this corrective action plan with the agencies. With regards to condition C, for a. and b. for payments by agencies, there are standard procedures for review and authorization of invoices and payments and those payments are documented. For c. The State has already implemented an agency wide framework for subrecipient monitoring. The State will provide re-training for those agencies that had not properly documented monitoring as outlined by the subrecipient risk assessments and ensure monitoring reports are documented. With regards to condition D, The State has already implemented an agency wide framework to help ensure policies and procedures are in place concerning Uniform Guidance Reports. We will work those agencies that had not documented the date received and the review of the Uniform Guidance Reports to ensure written documentation occurs. Where findings have been reported in the Uniform Guidance Report, ensure timely Management Letters are documented and provided with the summary review of Uniform Guidance Report.

DEPARTMENT OF PUBLIC HEALTH 2023-025 Refugee and Entrant Assistance State Administered Programs (Refugee), Opioid-STR Block Grants for Prevention and Treatment of Substance Abuse, COVID-19 - Block Grants for Prevention and Treatment of Substance Abuse (SABG) - Assistance Listing No. 93.566, 93.788, 93.959 Action taken in response to the finding: DPH will continue to automatically generate a subrecipient notification whenever federal funding amounts change. However, because FAIN# and grant award date information is not currently available through our automated systems, we will require bureaus to include a contract attachment that includes this information. The state’s current accounting system is being replaced by a new system, with improved grant functionalities. If the FAIN# and grant award information is available through this system, DPH will be able to add these data to our automatically generated subrecipient notification in the future. Name of the contact person responsible for corrective action: Sharon Dyer, Director Purchase of Service Office Planned completion date for corrective action plan: September 30, 2024

OFFICE FOR REFUGEES AND IMMIGRANTS 2023-024 Refugee and Entrant Assistance State Administered Programs - Assistance Listing No. 93.566 Action taken in response to the finding: ORI will provide the Federal Award Identification Number (FAIN) to the subrecipient in the contract document. ORI will update internal controls and procedures to confirm FAIN number is included in contract documents going forward. Name of the contact person responsible for corrective action: Kelvin Pham Planned completion date for corrective action plan: July 1, 2024

EXECUTIVE OFFICE OF ELDER AFAIRS 2023-022 COVID-19 – Aging Cluster - Assistance Listing No. 93.044, 93.045, 93.053 Action taken in response to the finding: EOEA will review internal processes to ensure that all required information is included in all subaward agreements, including reviewing FFY25 and subsequent Title III subaward agreements to ensure that the required federal award information is present. Name of the contact person responsible for corrective action: Sheila Tunney, EOEA CFO Planned completion date for corrective action plan: EOEA will complete this corrective action plan for the re-issuance of FFY24 subawards following receipt of additional federal awards, anticipated for June/July 2024.

EXECUTIVE OFFICE OF LABOR AND WORKFORCE DEVELOPMENT 2023-012 WIOA Cluster, Employment Service Cluster – Assistance Listing No. 17.258, 17.259, 17.278, 17.207, 17.801 Action taken in response to the finding: The corrective action plan (CAP) for this finding was implemented and completed in Fiscal Year 2023 with the addition of the FAIN numbers to the subawards and the completion of FY23 CommCorp monitoring. MDCS continues to include FAIN as part of the revised documented process and monitoring is current and timely performed. MDCS therefore considers this item to be completed and closed. Name of the contact person responsible for corrective action: Michael Williams, Director of Field management and Oversight Planned completion date for corrective action plan: December 31, 2022

Finding 2023 – 006 CONDITION During the current audit period, the Cook County Department of Public Health (DPH) did not perform adequate monitoring of its subrecipients as required by Federal regulations. CORRECTIVE ACTIONS DPH will implement procedures to ensure that the subrecipient monitoring process is adequately documented to ensure financial monitoring is performed, the subrecipient’s risk of noncompliance is evaluated, and the process includes the review of single audit reports. Management Approval of the Policy and Tools have been shared with the auditors. Implementation Phase includes but will not be limited to 1) identifying designated personnel team/consultant, 2) training staff, and 3) monitoring plan to ensure that the policy is followed. Anticipated completion of the corrective action is estimated to be December 31, 2024. The corrective action will be coordinated by the Director of Grants Accounting.

Finding 2023 – 005 CONDITION During the current audit period, the Cook County Department of Public Health (DPH) did not adequately comply with its subrecipient monitoring requirements in accordance with federal regulations. CORRECTIVE ACTIONS DPH will implement prior corrective action plan for future subrecipients awarded with federal funds. The corrective measure will include adequately documenting financial monitoring and review of single audit reports. Management Approval of the Policy and Tools have been shared with the auditors. Implementation Phase includes but will not be limited to 1) identifying designated personnel team/consultant, 2) training staff, and 3) monitoring plan to ensure that the policy is followed. Anticipated completion of the corrective action is estimated to be December 31, 2024. The corrective action will be coordinated by the Director of Grants Accounting.

Management concurs with this finding. As noted in the response to Subrecipient Monitoring – Improper Communication to Subrecipient, Subrecipient vs. contractor differentiation has been an area of continued improvement. Management believes recent efforts to properly differentiate between subrecipients and contractors has resulted in accurate determinations. However, documentation, ongoing monitoring, and communication are areas for further improvement. To that end, Management has implemented a new subrecipient/contractor determination form that includes both documentation of the determination and a checklist for ongoing compliance and monitoring for both subrecipients and contractors. This form requires that a subrecipient monitoring plan be put in place which will address compliance with all applicable federal award conditions including Single Audits. Management believes implementation of this form/process will reduce the risk of further noncompliance.

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 Amount $0 Status: Corrective action in progress Corrective Action: Completion Date: The University uses an initial certification process to determine whether a subrecipient is subject to the single audit and requests a copy of or link to the online audit report. If the subrecipient is not subject to the single audit, a series of questions are asked and a risk assessment is carried out based on the information gathered. The University does not have an automatic annual process to determine if a subrecipient has received the required single or program-specific audits. Rather, the University relies on the terms of the subaward, which requires the subrecipient to certify that they: • Continue to comply with the Uniform Guidance requirements. • Notify the University of adverse findings. • If not subject to the single audit, provide copies of the most recent program audit or other financial statement audit to allow the University to assess internal controls. To address the audit finding, the University updated the initial certification form to allow for a more definitive determination of whether a subrecipient is subject to the single audit. The University will also strengthen internal controls by: • Verifying with publicly available information to confirm if the audit requirement is applicable. • Implementing an annual assessment for each active federal subaward utilizing questionnaire and publicly available information to be aware of any findings or questioned costs. • Updating tracking mechanism to document each initial and ongoing assessment. The University will continue to issue written management decisions for all applicable audit findings and ensure subrecipients develop and perform acceptable corrective actions to address all audit recommendations. The conditions noted in this finding were previously reported in finding 2022-030. Estimated December 2024 Agency Contact: Erick Winger Controller 4300 Roosevelt Way NE Seattle, WA 98105-4718 (206) 543-5322 erickw@uw.edu

Finding: 2023-062 – DOT&PF management did not issue a management decision for the one single audit finding requiring follow-up in FY 23 within six months as required by federal law. Questioned Costs: None Assistance Listing Number: 20.509 Assistance Listing Title: FGRA Views of Responsible Officials (state whether your agency agrees or disagrees with the finding; if you disagree, briefly explain why): Agree Corrective Action (corrective action planned): The Finance Officer will develop and implement a procedure to ensure management decisions for all subrecipient single audit findings are issued within six months of the audit report's acceptance by the federal audit clearinghouse. Completion Date (list anticipated completion date): June 30, 2024 Agency Contact (name of person responsible for corrective action): Elizabeth Dunayski, Financial Services Manager

In accordance with the audit finding recommendation, the Department of Human Services’ Division of Family Development (DFD) will ensure that the applicable federal award date will be included with the contract award information as required by Uniform Guidance pass-through entity requirements. Subrecipient monitoring was performed in a timely manner in compliance with DHS Contract Policy with the exception of one subrecipient, NJSACC. NJSACC’s fiscal review documents are due back to DFD on April 15, 2024. Once received, DFD will schedule a fiscal review meeting with the agency and the entire process should be completed within one (1) month of receipt. In addition, DFD will review the current policy for clarity, reasonableness, and to ensure compliance. COMPLETION DATE/ CONTACT PERSON June 30 2024 Ann Allen (609) 588-2074 Ann.Allen@dhs,nj,gov

The Department of Health (DOH) will enhance its internal controls and procedures, regarding federal subawards issued by other New Jersey State departments and agencies on behalf of DOH. The Department’s Memorandum of Agreement (MOA) and Memorandum of Understanding (MOU) documents will be updated and enhanced to list and define the specific responsibilities and requirements of other departments and pass-through entities more clearly when issuing subawards with federal funding derived from DOH. If necessary, the updated MOA/MOU documents may also include an Exhibit specific to Subrecipient Monitoring, containing the federal Uniform Guidance compliance requirements including mandatory reporting of subgrantee performance indicators and listing records retention requirements for all documentation of monitored subrecipient activities. COMPLETION DATE/ CONTACT PERSON April 5, 2024 Eric Carlsson (609) 376-8480 Eric.Carlsson@doh.nj.gov