Management Response AIHEC concurs with this finding. AIHEC is formalizing its subrecipient monitoring procedures by implementing a standardized subrecipient risk assessment template to be completed prior to issuing any subaward, evaluating factors including the subrecipient's prior audit history, financial management capacity, and program complexity. AIHEC will maintain a subrecipient monitoring file for each active subaward documenting the risk assessment, periodic review of financial and performance reports, and follow-up on any deficiencies identified. AIHEC will also confirm and document, for each subrecipient expending $1,000,000 or more in federal awards during its fiscal year, that a Single Audit (or other audit required under Subpart F) was obtained and reviewed. In addition, AIHEC's new grant management software, Grant Vantage, includes subrecipient monitoring functionality, including a subrecipient portal that will allow subrecipients to log in directly and a centralized tracking of subrecipient reporting schedules. This subrecipient monitoring module has not yet been implemented, as AIHEC is currently focused on rolling out the core grants management functionality of the system; however, AIHEC expects to roll out the subrecipient monitoring module by September 30, 2026, which is expected to drastically improve AIHEC's subrecipient monitoring and oversight capabilities. The Director of Finance will be responsible for ensuring monitoring files are complete and current in the interim, with a semiannual internal review of all active subawards. Estimated Completion Date September 30, 2026 Responsible Party Angela Toles, Grants & Compliance Manager, with oversight by Diane Robertsy, Director of Finance