Corrective Action Plans

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.