Corrective Action Plans

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

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

Finding Number: 2022-002 ? Subrecipient Monitoring Name of Contact Person: Tamara Colden, Assistant Director Housing and Community Services Department Corrective Action: The Subrecipient Monitoring policy and procedures were updated in August 2022 to include the procedures for evaluating risk for subrecipients and revise monitoring procedures. These procedures will be updated to include checking the Federal Awards clearinghouse annually to assess audit requirements for all subrecipients and ensure the monitoring policy includes procedures when those audits result in any concerns or findings for subrecipients. A revised risk assessment will be conducted for each subrecipient. Proposed Completion Date: 06/30/2023

The DCEO filled the position responsible for issuing MDLs in June 2023.

Aging will hire and train staff; this is already in process.

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

Corrective Action Plan: The Program has designed and implemented policies and procedures that enable the Compliance division to use the risk assessment results as a work plan for performing the site visits and monitoring of subrecipients on an annual basis. COR3 will continue to follow its policy for the management and monitoring of its subrecipients to ensure their compliance in managing federal funds. Contact Person: Alejandro Nieto, Compliance Director Anticipated Completion Date: No later than December 31, 2023

Federal Agency: U.S. Department of Housing and Urban Development Federal Program: 14.218 Entitlement Grants Cluster: Community Development Block Grants/Entitlement Grants Identification Number: B-15-MC-42-0018; B-16-MC-42-0018; B-17-MC-42-0018; B-18-MC-42-0018; B-19- MC-42-0018 Requirement: Activities Allowed or Unallowed; Allowable Costs/Cost Principles; Period of Performance; Reporting; Special Tests and Provisions Type of Finding: Material weakness in internal control over major program; Noncompliance Description of Finding: The City does not have policies and procedures in place to perform the required risk assessment of subrecipients to determine the extent of monitoring procedures, and then perform and document the monitoring procedures performed. Section 2 CFR 200.331 of the Uniform Guidance states that pass-thru entities must evaluate each subrecipient's risk of noncompliance with federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring. This evaluation may include, but is not limited to, (1) The subrecipient's prior experience with the same or similar subawards; (2) The results of previous audits including whether or not the subrecipient receives a single audit and the extent to which the same or similar subaward has been audited as a major program; and (3) Whether the subrecipient has new personnel or new or substantially changed systems. Based on the results of the evaluation, the City would then have to consider the extent to which monitoring procedures are required. At a minimum, the City must, (1) Review financial and performance reports required by the City, (2) Follow-up and ensure that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the City detected through audits, on-site reviews, and other means, and (3) Issue a management decision for audit findings pertaining to the federal award provided to the subrecipient from the City as required by Section 200.521 of the Uniform Guidance. Additionally, the City must perform monitoring visits as stipulated in the contracts between the City and the subrecipients. Recommendation: We recommend the City implement procedures to ensure risk assessment of subrecipients prior to each subaward is performed in accordance with the Uniform Guidance requirements and thoroughly documented. We further recommend that the required subrecipient monitoring be performed and documented for each subaward. Statement of Concurrence: The City of York, Pennsylvania agrees with audit finding 2019-015. Corrective Action: The City of York’s Bureau of Housing Services, CDBG and HOME have implemented a policy to handle risk assessments of subrecipients. The policy contains monitoring procedures and documentation of subrecipients visits for each subaward. Documentation is located in the financial management system, OpenGov. Name of Contact Person Responsible for the Corrective Action: Contact Full Name: Kimberly Robertson Contact title: Business Administrator for Finance Address: 101 South George Street City: York State: Pennsylvania Zip Code: 17401 Phone: (717) 849-2883 E-mail: KRobertson@yorkcity.org Timetable for Correction: The anticipated date for resolving the audit finding is December 31, 2024.