View of Responsible Officials The Foundation did indicate to the subrecipients that the subawards were federal funds and outlined terms and uses associated with the subawards. The Foundation also monitored and reviewed subrecipient reimbursement submissions and corresponding support to ensure requests complied with the terms and conditions of the subaward. Action planned: • Develop and implement written policies and procedures that: o Establish a formal process for identifying all subrecipients receiving federal awards and determining which ones meet the single audit threshold. o Define procedures to ensure subrecipients complete the required audits under 2 CFR 200 Subpart F. o Outline steps for reviewing subrecipient audit reports, identifying findings related to the Foundation's subawards, and ensuring the subrecipient develops a corrective action plan for those findings. o Formalize the process for the Foundation to issue a management decision on relevant findings within the required six-month timeframe. o Include procedures for considering sanctions if a subrecipient does not comply with audit requirements. • Perform a lookback review: o Review existing subrecipient agreements to identify any instances of non-compliance with past monitoring requirements and ensure the necessary follow-up actions (e.g., obtaining audit reports, issuing management decisions) are completed for those periods. • Establish a monitoring system: o Implement a tracking system (e.g., a spreadsheet or software) to monitor the status of subrecipient audits, deadlines for management decisions, and follow-up on corrective actions. o Designate a responsible individual/department to oversee the subrecipient monitoring process and ensure all requirements are met consistently. Responsibility: The Chief Operating Officer and Finance Manager will work to draft the policy and will bring it to the Audit Committee for review and approval. The Finance Manager will be responsible for overseeing the implementation and ongoing compliance of the new subrecipient monitoring procedures. Timeline: • February 2026: Policy approved and implemented, and lookback review of prior periods completed. • Ongoing: Continuously monitor subrecipients and ensure timely action is taken on all future audit findings.