NATIONAL LEAGUE OF CITIES CORRECTIVE ACTION PLAN For the Year Ended September 30, 2022 U.S. DEPARTMENT OF COMMERCE National League of Cities submits the following corrective action plan for the year ended September 30, 2022. Independent Public Accounting Firm: MARCUM LLP 1899 L Street NW, Suite 850 Washington, DC 20036 Audit Period: The findings from the September 30, 2022 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FEDERAL AWARD FINDINGS AND QUESTIONED COSTS Finding No. 2022-003: Reporting ? Compliance Finding and Material Weakness in Internal Control Over Compliance ALN 11.307 ? Economic Adjustment Assistance, Grant Period: January 1, 2022 to September 30, 2022, Grant Number ED22HDQ3070070 Criteria Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA), prime recipients of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). The prime recipient is required to file a FFATA subaward report by the end of the month following the month in which the prime recipient awards any sub-grant greater than or equal to $30,000. Condition and Context The League did not file a FFATA subaward report for its three subrecipients timely. All FFATA sub-award reports were filed after September 30, 2022, which was more than a month after the League awarded its subrecipients with grants more than $30,000. Recommendation It was recommended that the League implement procedures and enhance internal controls to ensure appropriate and timely compliance with all applicable federal regulations. Action Taken: NLC took the following corrective actions that addressed the noncompliance within the performance period of the subject cooperative agreement: (1) Uploaded all the required subaward data on FSRS.gov on November 13, 2022; (2) Institute a standard checklist procedure associated with issuance or modification of subaward agreements to determine possible applicability of the subaward reporting requirement. _______________ Contact Person Responsible for Corrective Action: Michael Terseck, Chief Financial Officer If the US Department of Commerce has questions regarding this plan, please call Michael Terseck, Chief Financial Officer, (202)329-6358. Sincerely, Michael Terseck Chief Financial Officer National League of Cities