Federal Agency Name: Corporation for National and Community Service Federal Financial Assistance Listing #94.012 Program Name: September 11th National Day of Service and Remembrance Grants Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Finding Summary: Subawards did not contain minimum required elements in accordance with 2 CFR 200.332. The organization did not consider all suggested elements when evaluating subgrantee’s fraud risk and risk of noncompliance with subaward in accordance with 2 CFR 200.332(c). Documentation couldn’t be provided to substantiate whether suspension and debarment was considered prior to awarding subgrant. The organization required the subgrantee to complete performance reports, however, did not require completion of a financial report in accordance with 2 CFR 200.332(e)(1). The organization did not consider whether subgrantee was required to be audited and therefore did not review whether subgrantee had deficiencies. Corrective Action Plan: Management agrees with the finding and has begun implementing enhanced subrecipient monitoring procedures designed to address each of the identified compliance requirements. Subaward agreements will be revised to include the applicable information and terms required by 2 CFR §200.332. Prior to issuing subawards, management will verify and retain documentation of each prospective subrecipient's suspension and debarment status and will determine whether the subrecipient is subject to Single Audit requirements. Management will review available audit information, including identified findings or deficiencies, when applicable. Management is also enhancing its pre-award risk assessment process to evaluate each prospective subrecipient's risk of noncompliance with the federal subaward. The revised process will incorporate documented risk factors, including prior experience with the same or similar subawards, results of previous audits or other available financial oversight information, personnel and systems used to administer federal awards, and other factors relevant to the subrecipient's ability to comply with federal requirements. The results of the risk assessment will be documented and used to determine the appropriate level and nature of subrecipient monitoring. Subrecipients will be required to submit both programmatic and financial reports during the period of performance. Management will document its review of required reports and will perform additional monitoring, including desk reviews or other procedures, as appropriate based on assessed risk and performance. These procedures will be incorporated into the organization's documented subrecipient monitoring process and retained with the applicable grant records. Responsible Individuals: David Paine - President, Dominique Carver – Operations Director, Miranda Cirtwell – Controller Anticipated Completion Date: February 15, 2026