Management Response: COR3 clarifies that during the audited fiscal year, COR3 set up a team specifically aimed at working on centralizing the Subaward Agreements and the creation of an automated procedure for the Subaward process. The Team addressed historical challenges faced by COR3 since April of 2019, when the responsibility to subscribe Subaward Agreements was transferred from FEMA. Among the challenges were: the legacy of over 500 Subrecipients with obligated funds with a manual reimbursement methodology used by FEMA for federal grants in Puerto Rico known as the “270 Process”; continues changes by FEMA in the disbursement process and mandatory clauses to be inserted in subawards; automatic extension to the period of Performance granted by FEMA which generated modified Subawards, and nonresponsive subrecipients. COR3 has continued to prioritize addressing this finding. On August 30, 2023, the Subaward Agreement Automation Project came into effect, and all Subaward Agreement, Amended Subaward Agreements and Modification are submitted and processed through the PR DRS. Prior to generating a Subaward or Modification Agreement, the Grants Portal is reviewed daily to identify new obligated projects in each of the disasters. As part of the process and to ensure that subrecipients are aware of the availability of the Subaward in DRS, we send an email notification which contains all the details regarding Subaward Agreement signature process. As an additional measure, a master tracker has been created, which reflects the status of all signed Subaward Agreements. Corrective Action Plan: All requests for reimbursement (RFR) and requests for advance (RFA) are validated by the Grants Department against the Collaboration Portal Subaward Agreement document library. Such validation must include the verification of a signed subaward agreement for payment to be made. This guarantees that all payments made include Subrecipients that have signed a subaward agreement. Contact Persons: María Cardec, Grants Director, and Tatiana Lorenzo Compliance Director Anticipated Completion Date: Completed as of June 30, 2024.