NEW HAMPSHIRE CHILDREN'S TRUST, INC.

EIN: 272458454

UEI: NMCMLLFCZZH3

Data as of August 25, 2026

NEW HAMPSHIRE CHILDREN'S TRUST, INC.5 audit years11 findings5 repeat
5
Audit Years
11
Total Findings
5
Repeat Findings

FY 2025-12-31

Management decision deadline — for entities that funded this organization

The FAC accepted this audit on August 24, 2026. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by February 24, 2027 (183 days from today).

What is a management decision? →
2025-001
Subrecipient Monitoring
REPEAT

2025-001 Improve Controls and Documentation Over Subrecipient Monitoring Federal Program Information Federal Agency: Department of Health and Human Services Award Name(s): Child Care and Development Block Grant Assistance Listing Number(s): 93.575 Award Year: 2022 Compliance Requirement: Subrecipient Monitoring Federal Agency: Department of Health and Human Services Award Name(s): Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises Assistance Listing Number(s): 93.391 Award Year: 2022 Compliance Requirement: Subrecipient Monitoring Type of Finding Compliance Internal Control over Compliance – Significant Deficiency Criteria or Specific Requirement OMB’s Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires that a pass-through entity must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes information as required in 2 CFR 200.332(b). Condition and Context During our fiscal year 2024 audit, we tested a sample of one subrecipient under the Child Care and Development Block Grant in order to determine if the subrecipient agreements contained all required elements per 2 CFR 200.332(b) and ensure sufficient subrecipient monitoring procedures were performed. As a result of our testing, it was identified that the agreement tested did not contain the subrecipient’s unique entity identifier, federal award identification number, federal award date, assistance listing title, assistance listing number, dollar amount available under each federal award and assistance listing number at the time of disbursement, and approved indirect cost rate. While assistance listing number 93.391 was not tested as a major federal program in 2025, and subrecipient monitoring is no longer applicable to 93.575 based on the 2025 Compliance Supplement, we have carried forward the finding from the prior year and applied it to this program as it has not yet been resolved. Cause The Organization did not have adequate controls in place to ensure all required elements were included in subrecipient agreements. Effect or Potential Effect The Organization did not comply with the requirements of the Uniform Guidance regarding communication to subrecipients all the specified elements in 2 CFR 200.332(b). No questioned costs are reported as this requirement is administrative in nature. Recommendation The Organization should address the weakness in internal control noted above and update its subrecipient agreements, policies, and procedures to ensure that all required elements are present to comply with the Uniform Guidance. Views of Responsible Official Management’s corrective action plan is included at the end of this report after the Schedule of Prior Year Findings.

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Full finding narrative

2025-001 Improve Controls and Documentation Over Subrecipient Monitoring Federal Program Information Federal Agency: Department of Health and Human Services Award Name(s): Child Care and Development Block Grant Assistance Listing Number(s): 93.575 Award Year: 2022 Compliance Requirement: Subrecipient Monitoring Federal Agency: Department of Health and Human Services Award Name(s): Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises Assistance Listing Number(s): 93.391 Award Year: 2022 Compliance Requirement: Subrecipient Monitoring Type of Finding Compliance Internal Control over Compliance – Significant Deficiency Criteria or Specific Requirement OMB’s Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires that a pass-through entity must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes information as required in 2 CFR 200.332(b). Condition and Context During our fiscal year 2024 audit, we tested a sample of one subrecipient under the Child Care and Development Block Grant in order to determine if the subrecipient agreements contained all required elements per 2 CFR 200.332(b) and ensure sufficient subrecipient monitoring procedures were performed. As a result of our testing, it was identified that the agreement tested did not contain the subrecipient’s unique entity identifier, federal award identification number, federal award date, assistance listing title, assistance listing number, dollar amount available under each federal award and assistance listing number at the time of disbursement, and approved indirect cost rate. While assistance listing number 93.391 was not tested as a major federal program in 2025, and subrecipient monitoring is no longer applicable to 93.575 based on the 2025 Compliance Supplement, we have carried forward the finding from the prior year and applied it to this program as it has not yet been resolved. Cause The Organization did not have adequate controls in place to ensure all required elements were included in subrecipient agreements. Effect or Potential Effect The Organization did not comply with the requirements of the Uniform Guidance regarding communication to subrecipients all the specified elements in 2 CFR 200.332(b). No questioned costs are reported as this requirement is administrative in nature. Recommendation The Organization should address the weakness in internal control noted above and update its subrecipient agreements, policies, and procedures to ensure that all required elements are present to comply with the Uniform Guidance. Views of Responsible Official Management’s corrective action plan is included at the end of this report after the Schedule of Prior Year Findings.

Corrective Action Plan

Audit Finding Reference: 2025-001 Improve Controls and Documentation Over Subrecipient Monitoring Planned Corrective Action: Updated Financial Policies and Procedures to reflect language surrounding areas of deficiency in December of 2025, specifically listed in 2 CFR 200.332(b). New subrecipients awards include: subrecipient’s unique entity identifier, federal award identification number, federal award date, assistance listing title, assistance listing number, dollar amount available under each federal award and assistance listing number at the time of disbursement, and approved indirect cost rate. This was found during the 2023 single audit completed in 2025, with the corrective action implemented for contracts starting after 7/14/25. 2026 sub-recipient contracts have included the Uniform Guidance required information. Planned Implementation Date of Corrective Action: 7/14/25, included in Financial Policies revisions in December 2025. Person Responsible for Corrective Action: Director of Finance

Prior Finding References

2024-001

About Subrecipient Monitoring →
2025-002
Reporting
REPEAT

2025-002 Improve Controls Over Reporting Federal Program Information Federal Agency: Department of Health and Human Services Award Name(s): Child Care and Development Block Grant Assistance Listing Number(s): 93.575 Award Year: 2022 Compliance Requirement: Reporting Type of Finding Compliance Internal Control over Compliance – Significant Deficiency Criteria or Specific Requirement 2 CFR 200.329 requires non-Federal entities to submit performance reports as required by the Federal awarding agency or pass-through entity in a timely manner as specified in the terms and conditions of the award. Program guidance for the Child Care and Development Block Grant requires that quarterly project progress reports be submitted by specified deadlines unless a formal extension is granted by the awarding agency. Condition and Context During our audit, we tested a sample of quarterly project progress reports under the Child Care and Development Block Grant. The Organization submitted one quarterly project progress reports after the required submission deadline. There was no documentation of a formal extension granted by the awarding agency. Cause The Organization’s internal controls did not ensure timely preparation and submission of required performance reports in accordance with federal program requirements, or ensure that an extension was requested. Effect or Potential Effect Late submission of required reports increases the risk of noncompliance with federal award requirements and may negatively affect the Organization’s ability to demonstrate progress on program objectives. No questioned costs are reported as the requirement is procedural in nature. Recommendation The Organization should implement procedures to ensure that all required performance reports are submitted timely in accordance with federal program requirements and have policies in place regarding formal documentation and approval of extension requests. Views of Responsible Official Management’s corrective action plan is included at the end of this report after the Schedule of Prior Year Findings.

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Full finding narrative

2025-002 Improve Controls Over Reporting Federal Program Information Federal Agency: Department of Health and Human Services Award Name(s): Child Care and Development Block Grant Assistance Listing Number(s): 93.575 Award Year: 2022 Compliance Requirement: Reporting Type of Finding Compliance Internal Control over Compliance – Significant Deficiency Criteria or Specific Requirement 2 CFR 200.329 requires non-Federal entities to submit performance reports as required by the Federal awarding agency or pass-through entity in a timely manner as specified in the terms and conditions of the award. Program guidance for the Child Care and Development Block Grant requires that quarterly project progress reports be submitted by specified deadlines unless a formal extension is granted by the awarding agency. Condition and Context During our audit, we tested a sample of quarterly project progress reports under the Child Care and Development Block Grant. The Organization submitted one quarterly project progress reports after the required submission deadline. There was no documentation of a formal extension granted by the awarding agency. Cause The Organization’s internal controls did not ensure timely preparation and submission of required performance reports in accordance with federal program requirements, or ensure that an extension was requested. Effect or Potential Effect Late submission of required reports increases the risk of noncompliance with federal award requirements and may negatively affect the Organization’s ability to demonstrate progress on program objectives. No questioned costs are reported as the requirement is procedural in nature. Recommendation The Organization should implement procedures to ensure that all required performance reports are submitted timely in accordance with federal program requirements and have policies in place regarding formal documentation and approval of extension requests. Views of Responsible Official Management’s corrective action plan is included at the end of this report after the Schedule of Prior Year Findings.

Corrective Action Plan

Audit Finding Reference: 2025-002 Improve Controls Over Reporting Planned Corrective Action: Director of Operations & Impact created an 18-month reporting deliverables schedule and is reviewed quarterly on 9/22/25. The schedule of reporting deliverables has been added to a dedicated calendar in SharePoint, shared with the President and programs team staff, and a series of reminders and notifications are integrated into the system. The system itself will be reviewed every six months going forward to address any technological issues and make recommendations for improved functionality. Planned Implementation Date of Corrective Action: 9/22/25 Person Responsible for Corrective Action: Director of Operations & Impact

Prior Finding References

2024-002

About Reporting →

FY 2024-12-31

FAC accepted this audit on October 23, 2025 — management decision was due April 23, 2026.

2024-001
Subrecipient Monitoring
REPEAT

2024-001 Improve Controls and Documentation Over Subrecipient Monitoring Federal Program Information Federal Agency: Department of Health and Human Services Award Name(s): Child Care and Development Block Grant Assistance Listing Number(s): 93.575 Award Year: 2022 Compliance Requirement: Subrecipient Monitoring Federal Agency: Department of Health and Human Services Award Name(s): Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises Assistance Listing Number(s): 93.391 Award Year: 2022 Compliance Requirement: Subrecipient Monitoring Type of Finding Compliance Internal Control over Compliance – Significant Deficiency Criteria or Specific Requirement OMB’s Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires that a pass-through entity must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes information as required in 2 CFR 200.332(b). Condition and Context During our audit, we tested a sample of one subrecipient under the Child Care and Development Block Grant in order to determine if the subrecipient agreements contained all required elements per 2 CFR 200.332(b) and ensure sufficient subrecipient monitoring procedures were performed. As a result of our testing, it was identified that the agreement tested did not contain the subrecipient’s unique entity identifier, federal award identification number, federal award date, assistance listing title, assistance listing number, dollar amount available under each federal award and assistance listing number at the time of disbursement, and approved indirect cost rate. While assistance listing number 93.391 was not tested as a major federal program in 2024, we have carried forward the finding from the prior year and applied it to this program as it has not yet been resolved. SECTION III - FEDERAL AWARDS FINDINGS AND QUESTIONED COSTS (CONTINUED) 2024-001 Improve Controls and Documentation Over Subrecipient Monitoring (Continued) Cause The Organization did not have adequate controls in place to ensure all required elements were included in subrecipient agreements. Effect or Potential Effect Due to the weakness in internal controls and compliance finding noted above, the Organization did not comply with the requirements of the Uniform Guidance regarding communication to subrecipients all the specified elements in 2 CFR 200.332. No questioned costs are reported as this requirement is administrative in nature. Recommendation The Organization should address the weakness noted above and update its subrecipient agreements, policies, and procedures to ensure that all required elements are present to comply with the Uniform Guidance. Views of Responsible Official Management’s corrective action plan is included at the end of this report after the Schedule of Prior Year Findings.

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Full finding narrative

2024-001 Improve Controls and Documentation Over Subrecipient Monitoring Federal Program Information Federal Agency: Department of Health and Human Services Award Name(s): Child Care and Development Block Grant Assistance Listing Number(s): 93.575 Award Year: 2022 Compliance Requirement: Subrecipient Monitoring Federal Agency: Department of Health and Human Services Award Name(s): Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises Assistance Listing Number(s): 93.391 Award Year: 2022 Compliance Requirement: Subrecipient Monitoring Type of Finding Compliance Internal Control over Compliance – Significant Deficiency Criteria or Specific Requirement OMB’s Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires that a pass-through entity must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes information as required in 2 CFR 200.332(b). Condition and Context During our audit, we tested a sample of one subrecipient under the Child Care and Development Block Grant in order to determine if the subrecipient agreements contained all required elements per 2 CFR 200.332(b) and ensure sufficient subrecipient monitoring procedures were performed. As a result of our testing, it was identified that the agreement tested did not contain the subrecipient’s unique entity identifier, federal award identification number, federal award date, assistance listing title, assistance listing number, dollar amount available under each federal award and assistance listing number at the time of disbursement, and approved indirect cost rate. While assistance listing number 93.391 was not tested as a major federal program in 2024, we have carried forward the finding from the prior year and applied it to this program as it has not yet been resolved. SECTION III - FEDERAL AWARDS FINDINGS AND QUESTIONED COSTS (CONTINUED) 2024-001 Improve Controls and Documentation Over Subrecipient Monitoring (Continued) Cause The Organization did not have adequate controls in place to ensure all required elements were included in subrecipient agreements. Effect or Potential Effect Due to the weakness in internal controls and compliance finding noted above, the Organization did not comply with the requirements of the Uniform Guidance regarding communication to subrecipients all the specified elements in 2 CFR 200.332. No questioned costs are reported as this requirement is administrative in nature. Recommendation The Organization should address the weakness noted above and update its subrecipient agreements, policies, and procedures to ensure that all required elements are present to comply with the Uniform Guidance. Views of Responsible Official Management’s corrective action plan is included at the end of this report after the Schedule of Prior Year Findings.

Corrective Action Plan

Update Financial Policies and Procedures to reflect language surrounding areas of deficiency, specifically listed in 2 CFR 200.332(b). New subrecipients awards will include: subrecipient’s unique entity identifier, federal award identification number, federal award date, assistance listing title, assistance listing number, dollar amount available under each federal award and assistance listing number at the time of disbursement, and approved indirect cost rate. This was found during the 2023 single-audit, with the corrective action implemented for contracts starting after 7/14/25. Planned Implementation Date of Corrective Action: 7/14/25, will be included in Financial Policies revisions in December 2025. Person Responsible for Corrective Action: Director of Finance

Prior Finding References

2023-001

About Subrecipient Monitoring →
2024-002
Reporting

2024-002 Improve Controls Over Reporting Federal Program Information Federal Agency: Department of Health and Human Services Award Name(s): Child Care and Development Block Grant Assistance Listing Number(s): 93.575 Award Year: 2022 Compliance Requirement: Reporting Type of Finding Compliance Internal Control over Compliance – Significant Deficiency Criteria or Specific Requirement 2 CFR 200.329 requires non-Federal entities to submit performance reports as required by the Federal awarding agency or pass-through entity in a timely manner as specified in the terms and conditions of the award. Program guidance for the Child Care and Development Block Grant requires that quarterly project progress reports be submitted by specified deadlines unless a formal extension is granted by the awarding agency. SECTION III - FEDERAL AWARDS FINDINGS AND QUESTIONED COSTS (CONTINUED) 2024-002 Improve Controls Over Reporting (Continued) Condition and Context During our audit, we tested a sample of two quarterly project progress reports under the Child Care and Development Block Grant. The Organization submitted both quarterly project progress reports after the required submission deadlines. There was no documentation of a formal extension granted by the awarding agency. Cause The Organization’s internal controls did not ensure timely preparation and submission of required performance reports in accordance with federal program requirements, or ensure that an extension was requested. Effect or Potential Effect Late submission of required reports increases the risk of noncompliance with federal award requirements and may negatively affect the Organization’s ability to demonstrate progress on program objectives. No questioned costs are reported as the requirement is procedural in nature. Recommendation The Organization should implement procedures to ensure that all required performance reports are submitted timely in accordance with federal program requirements or have policies in place regarding formal documentation and approval of extension requests. Views of Responsible Official Management’s corrective action plan is included at the end of this report after the Schedule of Prior Year Findings.

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Full finding narrative

2024-002 Improve Controls Over Reporting Federal Program Information Federal Agency: Department of Health and Human Services Award Name(s): Child Care and Development Block Grant Assistance Listing Number(s): 93.575 Award Year: 2022 Compliance Requirement: Reporting Type of Finding Compliance Internal Control over Compliance – Significant Deficiency Criteria or Specific Requirement 2 CFR 200.329 requires non-Federal entities to submit performance reports as required by the Federal awarding agency or pass-through entity in a timely manner as specified in the terms and conditions of the award. Program guidance for the Child Care and Development Block Grant requires that quarterly project progress reports be submitted by specified deadlines unless a formal extension is granted by the awarding agency. SECTION III - FEDERAL AWARDS FINDINGS AND QUESTIONED COSTS (CONTINUED) 2024-002 Improve Controls Over Reporting (Continued) Condition and Context During our audit, we tested a sample of two quarterly project progress reports under the Child Care and Development Block Grant. The Organization submitted both quarterly project progress reports after the required submission deadlines. There was no documentation of a formal extension granted by the awarding agency. Cause The Organization’s internal controls did not ensure timely preparation and submission of required performance reports in accordance with federal program requirements, or ensure that an extension was requested. Effect or Potential Effect Late submission of required reports increases the risk of noncompliance with federal award requirements and may negatively affect the Organization’s ability to demonstrate progress on program objectives. No questioned costs are reported as the requirement is procedural in nature. Recommendation The Organization should implement procedures to ensure that all required performance reports are submitted timely in accordance with federal program requirements or have policies in place regarding formal documentation and approval of extension requests. Views of Responsible Official Management’s corrective action plan is included at the end of this report after the Schedule of Prior Year Findings.

Corrective Action Plan

Director of Operations & Impact will draft an 18-month reporting deliverables schedule to be reviewed quarterly. The schedule of reporting deliverables will be added to a dedicated calendar in SharePoint, shared with the President and programs team staff, and a series of reminders and notifications will be integrated into the system. The system itself will be reviewed every six months going forward to address any technological issues and make recommendations for improved functionality. Planned Implementation Date of Corrective Action: 9/22/25 Person Responsible for Corrective Action: Director of Operations & Impact

About Reporting →

FY 2023-12-31

FAC accepted this audit on August 7, 2025 — management decision was due February 7, 2026.

2023-001
Subrecipient Monitoring
REPEAT

Criteria or Specific Requirement OMB’s Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires that a pass-through entity must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes information as required in 2 CFR 200.332(b). Condition and Context During our audit, we tested a sample of two subrecipients for each assistance listing number in order to determine if the subrecipient agreements contained all required elements per 2 CFR 200.332(b) and ensure sufficient subrecipient monitoring procedures were performed. As a result of our testing, it was identified that the agreements tested did not contain the subrecipient’s unique entity identifier, federal award identification number, federal award date, assistance listing title, assistance listing number, dollar amount available under each federal award and assistance listing number at the time of disbursement, and approved indirect cost rate. Cause The Organization did not have adequate controls in place to ensure all required elements were included in subrecipient agreements. Effect or Potential Effect Due to the weakness in internal controls and compliance finding noted above, the Organization did not comply with the requirements of the Uniform Guidance regarding communication to subrecipients all the specified elements in 2 CFR 200.332. No questioned costs are reported as this requirement is administrative in nature. Recommendation The Organization should address the weakness noted above and update its subrecipient agreements, policies, and procedures to ensure that all required elements are present to comply with the Uniform Guidance. Views of Responsible Official Management’s corrective action plan is included at the end of this report after the Schedule of Prior Year Findings.

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Full finding narrative

Criteria or Specific Requirement OMB’s Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires that a pass-through entity must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes information as required in 2 CFR 200.332(b). Condition and Context During our audit, we tested a sample of two subrecipients for each assistance listing number in order to determine if the subrecipient agreements contained all required elements per 2 CFR 200.332(b) and ensure sufficient subrecipient monitoring procedures were performed. As a result of our testing, it was identified that the agreements tested did not contain the subrecipient’s unique entity identifier, federal award identification number, federal award date, assistance listing title, assistance listing number, dollar amount available under each federal award and assistance listing number at the time of disbursement, and approved indirect cost rate. Cause The Organization did not have adequate controls in place to ensure all required elements were included in subrecipient agreements. Effect or Potential Effect Due to the weakness in internal controls and compliance finding noted above, the Organization did not comply with the requirements of the Uniform Guidance regarding communication to subrecipients all the specified elements in 2 CFR 200.332. No questioned costs are reported as this requirement is administrative in nature. Recommendation The Organization should address the weakness noted above and update its subrecipient agreements, policies, and procedures to ensure that all required elements are present to comply with the Uniform Guidance. Views of Responsible Official Management’s corrective action plan is included at the end of this report after the Schedule of Prior Year Findings.

Corrective Action Plan

Planned Corrective Action: Update Financial Policies and Procedures to reflect language surrounding areas of deficiency, specifically listed in 2 CFR 200.332(b). New subrecipients awards will include: subrecipient’s unique entity identifier, federal award identification number, federal award date, assistance listing title, assistance listing number, dollar amount available under each federal award and assistance listing number at the time of disbursement, and approved indirect cost rate. Planned Implementation Date of Corrective Action: 7/14/25, will be included in Financial Policies revisions in December 2025. Person Responsible for Corrective Action: Director of Finance

Prior Finding References

2022-002

About Subrecipient Monitoring →
2023-002
Procurement & Suspension/Debarment
REPEAT

Criteria or Specific Requirement OMB’s Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires that grant recipients follow procurement procedures for the acquisition of property or services under a federal award. Grantees are required to comply with certain procurement standards as defined in 2 CFR 200.318. These standards include the requirement that the grantee must use its own documented procurement procedures provided that they conform to applicable federal law. In addition, the grantee must maintain records sufficient to detail the history of procurement. Condition and Context During planning procedures for our audit, we concluded that the prior year finding over procurement was not yet remediated. Based on our procedures, there was no supporting documentation retained for those transactions subject to procurement and approvals were given verbally between the requestor and the Executive Director. Cause The Organization did not have adequate controls or policies in place to maintain formal evidence of procurement and to ensure the Organization’s procurement policy was adhered to. Effect or Potential Effect Due to the weakness in internal controls and compliance finding noted above, there is a risk that contracts may be awarded to vendors in a manner that is not consistent with Federal procurement requirements and the Organization’s procurement policy. No questioned costs are reported as vendors subject to procurement policies are below $25,000. Recommendation The Organization should address the weaknesses in internal controls noted above in order to ensure that federal procurements are conducted in accordance with federal requirements and supporting documentation is maintained to support such conclusion. The Organization should ensure that prior to entering into transactions, a review is performed over vendor selection and all required documentation is retained. Views of Responsible Official Management’s corrective action plan is included at the end of this report after the Schedule of Prior Year Findings.

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Full finding narrative

Criteria or Specific Requirement OMB’s Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires that grant recipients follow procurement procedures for the acquisition of property or services under a federal award. Grantees are required to comply with certain procurement standards as defined in 2 CFR 200.318. These standards include the requirement that the grantee must use its own documented procurement procedures provided that they conform to applicable federal law. In addition, the grantee must maintain records sufficient to detail the history of procurement. Condition and Context During planning procedures for our audit, we concluded that the prior year finding over procurement was not yet remediated. Based on our procedures, there was no supporting documentation retained for those transactions subject to procurement and approvals were given verbally between the requestor and the Executive Director. Cause The Organization did not have adequate controls or policies in place to maintain formal evidence of procurement and to ensure the Organization’s procurement policy was adhered to. Effect or Potential Effect Due to the weakness in internal controls and compliance finding noted above, there is a risk that contracts may be awarded to vendors in a manner that is not consistent with Federal procurement requirements and the Organization’s procurement policy. No questioned costs are reported as vendors subject to procurement policies are below $25,000. Recommendation The Organization should address the weaknesses in internal controls noted above in order to ensure that federal procurements are conducted in accordance with federal requirements and supporting documentation is maintained to support such conclusion. The Organization should ensure that prior to entering into transactions, a review is performed over vendor selection and all required documentation is retained. Views of Responsible Official Management’s corrective action plan is included at the end of this report after the Schedule of Prior Year Findings.

Corrective Action Plan

Planned Corrective Action: Revise Financial Policies to require prior written approval from the Executive Director prior to entering into any agreement for expenditures between $10,000 and $49,999. If it is a sole source, written justification must be submitted and approved by the Executive Director prior to the execution of agreement. If multiple bids were obtained, these must also be submitted and the selected vendor approved by the Executive Director prior to the execution of agreement. Planned Implementation Date of Corrective Action: 2/5/2025 Person Responsible for Corrective Action: Director of Finance

Prior Finding References

2022-004

About Procurement and Suspension and Debarment →

FY 2022-12-31

FAC accepted this audit on March 28, 2025 — management decision was due September 28, 2025.

2022-002
Activities Allowed or Unallowed / Cost Allowability / Cash Management / Procurement & Suspension/Debarment / Subrecipient Monitoring

2022-002 Update Documented Policies and Procedures Over Federal Awards Federal Program Information Federal Agency: Department of Health and Human Services, Centers for Disease Control and Prevention Award Name(s): Injury Prevention and Control Research and State and Community Based Programs; Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises Assistance Listing Number(s): 93.136, 93.391 Award Year: 2022 Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Cash Management, Procurement, Subrecipient Monitoring Type of Finding Compliance Internal Control over Compliance – Significant Deficiency Criteria or Specific Requirement OMB’s Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requirements stipulate that federal award recipients must document their policies and procedures over certain aspects of financial and program management. Specifically, written policies are required for the following: • Determination of allowable costs • Employee travel • Cash management • Procurement • Conflicts of interest • Subrecipient monitoring and management Condition and Context Although the Organization has written policies and procedures related to federal awards, certain areas are not fully in compliance with the requirements of the Uniform Guidance. Cause The Organization has not developed written formal documentation of internal controls to encompass all required areas per the Uniform Guidance. Effect or Potential Effect Due to the weaknesses in internal controls noted above, the Organization did not comply with the requirements of the Uniform Guidance over documented policies and procedures. No questioned costs are reported as this requirement is procedural in nature. Recommendation The Organization should address the weakness noted above and update its policies and procedures related to federal awards in order to comply with the Uniform Guidance. Specific attention should be given to subrecipient monitoring, including required information in subrecipient agreements, references to Uniform Guidance, segregation of duties, and language that explicitly prohibits management override of controls. Views of Responsible Official Management agrees with the finding. Management’s corrective action plan is included at the end of this report after the Schedule of Prior Year Findings.

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Full finding narrative

2022-002 Update Documented Policies and Procedures Over Federal Awards Federal Program Information Federal Agency: Department of Health and Human Services, Centers for Disease Control and Prevention Award Name(s): Injury Prevention and Control Research and State and Community Based Programs; Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises Assistance Listing Number(s): 93.136, 93.391 Award Year: 2022 Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Cash Management, Procurement, Subrecipient Monitoring Type of Finding Compliance Internal Control over Compliance – Significant Deficiency Criteria or Specific Requirement OMB’s Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requirements stipulate that federal award recipients must document their policies and procedures over certain aspects of financial and program management. Specifically, written policies are required for the following: • Determination of allowable costs • Employee travel • Cash management • Procurement • Conflicts of interest • Subrecipient monitoring and management Condition and Context Although the Organization has written policies and procedures related to federal awards, certain areas are not fully in compliance with the requirements of the Uniform Guidance. Cause The Organization has not developed written formal documentation of internal controls to encompass all required areas per the Uniform Guidance. Effect or Potential Effect Due to the weaknesses in internal controls noted above, the Organization did not comply with the requirements of the Uniform Guidance over documented policies and procedures. No questioned costs are reported as this requirement is procedural in nature. Recommendation The Organization should address the weakness noted above and update its policies and procedures related to federal awards in order to comply with the Uniform Guidance. Specific attention should be given to subrecipient monitoring, including required information in subrecipient agreements, references to Uniform Guidance, segregation of duties, and language that explicitly prohibits management override of controls. Views of Responsible Official Management agrees with the finding. Management’s corrective action plan is included at the end of this report after the Schedule of Prior Year Findings.

Corrective Action Plan

Audit Finding Reference: 2022-002 Update Documented Policies and Procedures Of Federal Awards Planned Corrective Action: Update Financial Policies and Procedures to reflect Uniform Guidance language surrounding areas of deficiency. Planned Implementation Date of Corrective Action: Implemented 12/6/2023 upon becoming aware of the deficiency. Revised Financial Policies and Procedures to reflect the changes. Person Responsible for Corrective Action: Director of Finance

About Activities Allowed or Unallowed, Allowable Costs / Cost Principles, Cash Management, Procurement and Suspension and Debarment, Subrecipient Monitoring →
2022-003
Cost Allowability

2022-003 Improve Internal Controls Over Timesheet Approvals Federal Program Information Federal Agency: Department of Health and Human Services, Centers for Disease Control and Prevention Award Name(s): Injury Prevention and Control Research and State and Community Based Programs; Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises Assistance Listing Number(s): 93.136, 93.391 Award Year: 2022 Compliance Requirement: Allowable Costs/Cost Principles Type of Finding Internal Control over Compliance – Significant Deficiency Criteria or Specific Requirement Grantees must provide reasonable assurance that federal awards are expended only for allowable activities and that the costs charged to federal awards are allowable and in accordance with the applicable cost principles. Management of the Organization is also responsible for establishing and maintaining effective internal control over compliance with federal requirements that have a direct and material effect on a federal program. A deficiency in internal control over compliance exists when the design or operation of a control over compliance does not allow management or employees, in the normal course of perform¬ing their assigned functions, to prevent, or detect and correct, noncompliance with a type of compliance requirement of a federal program on a timely basis. Condition and Context During our audit, we tested a sample of forty payroll transactions for each assistance listing number in order to determine if charges were properly approved prior to disbursement. As a result of our testing, it was identified that three of the Executive Director’s timesheets were not approved by a knowledgeable individual under assistance listing number 93.136, and three were not approved under assistance listing number 93.391. Cause The Organization did not have adequate controls in place to ensure approval over all timesheets prior to disbursement and application to federal awards. Effect or Potential Effect Due to the weakness in internal controls noted above, there is a risk that amounts charged to federal awards could not be allowable or in accordance with applicable cost principles. No questioned costs are reported as the auditor obtained approved salary documentation and recalculated the Executive Director’s gross pay and application to federal awards without exception. Recommendation The Organization should address the weaknesses in internal controls noted above in order to provide reasonable assurance that federal awards are expended only for allowable activities, and that the costs charged to federal awards are allowable and in accordance with the applicable cost principles. The Organization should implement controls to ensure that all timesheets are approved to ensure allowability of the costs applied to the federal award. Views of Responsible Official Management agrees with the finding. Management’s corrective action plan is included at the end of this report after the Schedule of Prior Year Findings.

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2022-003 Improve Internal Controls Over Timesheet Approvals Federal Program Information Federal Agency: Department of Health and Human Services, Centers for Disease Control and Prevention Award Name(s): Injury Prevention and Control Research and State and Community Based Programs; Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises Assistance Listing Number(s): 93.136, 93.391 Award Year: 2022 Compliance Requirement: Allowable Costs/Cost Principles Type of Finding Internal Control over Compliance – Significant Deficiency Criteria or Specific Requirement Grantees must provide reasonable assurance that federal awards are expended only for allowable activities and that the costs charged to federal awards are allowable and in accordance with the applicable cost principles. Management of the Organization is also responsible for establishing and maintaining effective internal control over compliance with federal requirements that have a direct and material effect on a federal program. A deficiency in internal control over compliance exists when the design or operation of a control over compliance does not allow management or employees, in the normal course of perform¬ing their assigned functions, to prevent, or detect and correct, noncompliance with a type of compliance requirement of a federal program on a timely basis. Condition and Context During our audit, we tested a sample of forty payroll transactions for each assistance listing number in order to determine if charges were properly approved prior to disbursement. As a result of our testing, it was identified that three of the Executive Director’s timesheets were not approved by a knowledgeable individual under assistance listing number 93.136, and three were not approved under assistance listing number 93.391. Cause The Organization did not have adequate controls in place to ensure approval over all timesheets prior to disbursement and application to federal awards. Effect or Potential Effect Due to the weakness in internal controls noted above, there is a risk that amounts charged to federal awards could not be allowable or in accordance with applicable cost principles. No questioned costs are reported as the auditor obtained approved salary documentation and recalculated the Executive Director’s gross pay and application to federal awards without exception. Recommendation The Organization should address the weaknesses in internal controls noted above in order to provide reasonable assurance that federal awards are expended only for allowable activities, and that the costs charged to federal awards are allowable and in accordance with the applicable cost principles. The Organization should implement controls to ensure that all timesheets are approved to ensure allowability of the costs applied to the federal award. Views of Responsible Official Management agrees with the finding. Management’s corrective action plan is included at the end of this report after the Schedule of Prior Year Findings.

Corrective Action Plan

Audit Finding Reference: 2022-003 Improve Internal Controls Over Timesheet Approvals Planned Corrective Action: Executive Director’s bi-weekly timesheet approved by Director of Finance to ensure allowability of charges to federal awards in accordance with applicable cost principles. Planned Implementation Date of Corrective Action: Implemented on 1/20/2023 upon becoming aware of the deficiency. Person Responsible for Corrective Action: Director of Finance

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2022-004
Procurement & Suspension/Debarment

2022-004 Improve Controls and Documentation Over Procurement Federal Program Information Federal Agency: Department of Health and Human Services, Centers for Disease Control and Prevention Award Name(s): Injury Prevention and Control Research and State and Community Based Programs; Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises Assistance Listing Number(s): 93.136, 93.391 Award Year: 2022 Compliance Requirement: Procurement Type of Finding Compliance Internal Control over Compliance – Significant Deficiency Criteria or Specific Requirement OMB’s Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires that grant recipients follow procurement procedures for the acquisition of property or services under a federal award. Grantees are required to comply with certain procurement standards as defined in 2 CFR 200.318. These standards include the requirement that the grantee must use its own documented procurement procedures provided that they conform to applicable federal law. In addition, the grantee must maintain records sufficient to detail the history of procurement. Condition and Context During our audit, we tested a sample of two procurement transactions under assistance listing number 93.136 and one transaction under assistance listing number 93.391 for vendors with expenditures between $10,000 and $49,999 during fiscal year 2022. Of the transactions tested, all were missing supporting documentation to validate justification of why it was sole source as approvals were done verbally between the requestor and the Executive Director. In addition, one transaction under assistance listing number 93.136 did not qualify as meeting the requirements of sole source based on the Organization’s procurement policy. Cause The Organization did not have adequate controls or policies in place to maintain formal evidence of sole source justification and to ensure procurement policy was adhered to. Effect or Potential Effect Due to the weakness in internal controls and compliance finding noted above, there is a risk that contracts may be awarded to vendors in a manner that is not consistent with Federal procurement requirements and the Organization’s procurement policy. No questioned costs are reported as it is not quantifiable. Recommendation The Organization should address the weaknesses in internal controls noted above in order to ensure that federal procurements are conducted in accordance with federal requirements and supporting documentation is maintained to support such conclusion. The Organization should ensure that prior to entering into transactions, a review is performed over vendor selection and all required documentation is retained. Views of Responsible Official Management agrees with the finding. Management’s corrective action plan is included at the end of this report after the Schedule of Prior Year Findings.

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2022-004 Improve Controls and Documentation Over Procurement Federal Program Information Federal Agency: Department of Health and Human Services, Centers for Disease Control and Prevention Award Name(s): Injury Prevention and Control Research and State and Community Based Programs; Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises Assistance Listing Number(s): 93.136, 93.391 Award Year: 2022 Compliance Requirement: Procurement Type of Finding Compliance Internal Control over Compliance – Significant Deficiency Criteria or Specific Requirement OMB’s Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires that grant recipients follow procurement procedures for the acquisition of property or services under a federal award. Grantees are required to comply with certain procurement standards as defined in 2 CFR 200.318. These standards include the requirement that the grantee must use its own documented procurement procedures provided that they conform to applicable federal law. In addition, the grantee must maintain records sufficient to detail the history of procurement. Condition and Context During our audit, we tested a sample of two procurement transactions under assistance listing number 93.136 and one transaction under assistance listing number 93.391 for vendors with expenditures between $10,000 and $49,999 during fiscal year 2022. Of the transactions tested, all were missing supporting documentation to validate justification of why it was sole source as approvals were done verbally between the requestor and the Executive Director. In addition, one transaction under assistance listing number 93.136 did not qualify as meeting the requirements of sole source based on the Organization’s procurement policy. Cause The Organization did not have adequate controls or policies in place to maintain formal evidence of sole source justification and to ensure procurement policy was adhered to. Effect or Potential Effect Due to the weakness in internal controls and compliance finding noted above, there is a risk that contracts may be awarded to vendors in a manner that is not consistent with Federal procurement requirements and the Organization’s procurement policy. No questioned costs are reported as it is not quantifiable. Recommendation The Organization should address the weaknesses in internal controls noted above in order to ensure that federal procurements are conducted in accordance with federal requirements and supporting documentation is maintained to support such conclusion. The Organization should ensure that prior to entering into transactions, a review is performed over vendor selection and all required documentation is retained. Views of Responsible Official Management agrees with the finding. Management’s corrective action plan is included at the end of this report after the Schedule of Prior Year Findings.

Corrective Action Plan

Audit Finding Reference: 2022-004 Improve Controls and Documentation Over Procurement Planned Corrective Action: Revise Policy and Procedure Policies to require prior written approval from the Executive Director prior to entering into any agreement for expenditures between $10,000 and $49,999. If it is a sole source, written justification must be submitted and approved by Executive Director prior to execution of agreement. If multiple bids were obtained, these must also be submitted and the selected vendor approved by Executive Director prior to execution of agreement. Planned Implementation Date of Corrective Action: 2/5/2025 Person Responsible for Corrective Action: Director of Finance

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2022-005
Cost Allowability / Cash Management
QUESTIONED COSTS

2022-005 Improve Controls Over Cash Management and Application of Indirect Cost Rate Federal Program Information Federal Agency: Department of Health and Human Services, Centers for Disease Control and Prevention Award Name(s): Injury Prevention and Control Research and State and Community Based Programs Assistance Listing Number(s): 93.136 Award Year: 2022 Compliance Requirement: Cash Management, Allowable Costs/Cost Principles Federal Agency: Department of Health and Human Services, Centers for Disease Control and Prevention Award Name(s): Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises Assistance Listing Number(s): 93.391 Award Year: 2022 Compliance Requirement: Cash Management Type of Finding Compliance Internal Control Over Compliance – Significant Deficiency Criteria or Specific Requirement Management of the Organization is responsible for establishing and maintaining effective internal control over compliance with federal requirements that have a direct and material effect on a federal program. A deficiency in internal control over compliance exists when the design or operation of a control over compliance does not allow management or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct, noncompliance with a type of compliance requirement of a Federal program on a timely basis. Management of the Organization is also responsible for establishing the appropriate modified total direct cost base and applying the de minimis indirect cost rate accordingly. Condition and Context There is no documented review of requests for reimbursement by an individual that is not involved with preparing the requests. The Director of Finance is both preparing and reviewing requests for reimbursement with no additional oversight. As a result of this, there is also no review over indirect costs charged to the program and the application of the indirect cost rate prior to requests for reimbursement. Cause The Organization did not have adequate controls in place to ensure approval over reimbursement requests prior to submission to the federal agency, including application of the indirect cost rate to the appropriate modified total direct cost base. Effect or Potential Effect Due to the weakness in internal controls noted above, there is a risk that amounts requested to be reimbursed under federal awards could not be allowable or in accordance with applicable cost principles, including application of the indirect cost rate. Questioned Costs Due to the condition noted above, the indirect cost rate was not applied to the appropriate modified total direct cost base and resulted in the following questioned costs. AL Number(s) Name of Federal Program Questioned Costs 93.136 Injury Prevention and Control Research and State and Community Based Programs $35,187 Recommendation The Organization should address the weaknesses in internal controls noted above by requiring two individuals to be involved in requesting reimbursements, and that the review and oversight of reimbursement requests and application of the indirect cost rate be documented. Views of Responsible Official Management agrees with the finding. Management’s corrective action plan is included at the end of this report after the Schedule of Prior Year Findings.

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2022-005 Improve Controls Over Cash Management and Application of Indirect Cost Rate Federal Program Information Federal Agency: Department of Health and Human Services, Centers for Disease Control and Prevention Award Name(s): Injury Prevention and Control Research and State and Community Based Programs Assistance Listing Number(s): 93.136 Award Year: 2022 Compliance Requirement: Cash Management, Allowable Costs/Cost Principles Federal Agency: Department of Health and Human Services, Centers for Disease Control and Prevention Award Name(s): Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises Assistance Listing Number(s): 93.391 Award Year: 2022 Compliance Requirement: Cash Management Type of Finding Compliance Internal Control Over Compliance – Significant Deficiency Criteria or Specific Requirement Management of the Organization is responsible for establishing and maintaining effective internal control over compliance with federal requirements that have a direct and material effect on a federal program. A deficiency in internal control over compliance exists when the design or operation of a control over compliance does not allow management or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct, noncompliance with a type of compliance requirement of a Federal program on a timely basis. Management of the Organization is also responsible for establishing the appropriate modified total direct cost base and applying the de minimis indirect cost rate accordingly. Condition and Context There is no documented review of requests for reimbursement by an individual that is not involved with preparing the requests. The Director of Finance is both preparing and reviewing requests for reimbursement with no additional oversight. As a result of this, there is also no review over indirect costs charged to the program and the application of the indirect cost rate prior to requests for reimbursement. Cause The Organization did not have adequate controls in place to ensure approval over reimbursement requests prior to submission to the federal agency, including application of the indirect cost rate to the appropriate modified total direct cost base. Effect or Potential Effect Due to the weakness in internal controls noted above, there is a risk that amounts requested to be reimbursed under federal awards could not be allowable or in accordance with applicable cost principles, including application of the indirect cost rate. Questioned Costs Due to the condition noted above, the indirect cost rate was not applied to the appropriate modified total direct cost base and resulted in the following questioned costs. AL Number(s) Name of Federal Program Questioned Costs 93.136 Injury Prevention and Control Research and State and Community Based Programs $35,187 Recommendation The Organization should address the weaknesses in internal controls noted above by requiring two individuals to be involved in requesting reimbursements, and that the review and oversight of reimbursement requests and application of the indirect cost rate be documented. Views of Responsible Official Management agrees with the finding. Management’s corrective action plan is included at the end of this report after the Schedule of Prior Year Findings.

Corrective Action Plan

Audit Finding Reference: 2022-005 Improve Controls Over Cash Management and Application of Indirect Cost Rate Planned Corrective Action: Having the Executive Director review and approve state and federal invoices prior to final submission. An indirect analysis spreadsheet was also created to track and adjust indirect rate, if necessary, across all sub-contracts receiving federal funds. Planned Implementation Date of Corrective Action: Implemented Executive Director approval on 5/26/2023 for state invoices, which include federal funds that are passed through to NHCT. Indirect analysis spreadsheet implemented on 7/1/2023. Person Responsible for Corrective Action: Director of Finance

About Allowable Costs / Cost Principles, Cash Management →

FY 2021-12-31

FAC accepted this audit on July 10, 2023 — management decision was due January 10, 2024.

2021-001
Other

2021-001 Update Documented Policies and Procedures Over Federal Awards Federal Program(s) Information Cluster/Program: All Federal Programs Type of Finding Compliance ? Other Matters Criteria or Specific Requirement OMB?s Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requirements stipulate that federal award recipients must document their policies and procedures over certain aspects of financial and program management. Specifically, written policies are required for the following: ?Determination of allowable costs ?Employee travel ?Cash management ?Matching ?Procurement ?Reporting ?Subrecipient monitoring and management Condition and Context Although the Organization has written policies and procedures related to federal awards, certain areas are not fully in compliance with the requirements of the Uniform Guidance. Cause Weaknesses in the design internal controls. Effect or Potential Effect There are no questioned costs as a result of this finding, as there are no costs directly associated with this compliance requirement, and this is a procedural requirement under the Uniform Guidance. Recommendation The Organization should address the weakness noted above and update its policies and procedures related to federal awards in order to comply with the Uniform Guidance. Specific attention should be given to subrecipient monitoring and management, including required information in subrecipient agreements, references to the Uniform Guidance, segregation of duties, and language that explicitly prohibits management override of controls. Views of Responsible Official Management agrees with the finding. Planned Corrective Action Management?s corrective action plan is included at the end of this report after the schedule of prior year findings.

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2021-001 Update Documented Policies and Procedures Over Federal Awards Federal Program(s) Information Cluster/Program: All Federal Programs Type of Finding Compliance ? Other Matters Criteria or Specific Requirement OMB?s Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requirements stipulate that federal award recipients must document their policies and procedures over certain aspects of financial and program management. Specifically, written policies are required for the following: ?Determination of allowable costs ?Employee travel ?Cash management ?Matching ?Procurement ?Reporting ?Subrecipient monitoring and management Condition and Context Although the Organization has written policies and procedures related to federal awards, certain areas are not fully in compliance with the requirements of the Uniform Guidance. Cause Weaknesses in the design internal controls. Effect or Potential Effect There are no questioned costs as a result of this finding, as there are no costs directly associated with this compliance requirement, and this is a procedural requirement under the Uniform Guidance. Recommendation The Organization should address the weakness noted above and update its policies and procedures related to federal awards in order to comply with the Uniform Guidance. Specific attention should be given to subrecipient monitoring and management, including required information in subrecipient agreements, references to the Uniform Guidance, segregation of duties, and language that explicitly prohibits management override of controls. Views of Responsible Official Management agrees with the finding. Planned Corrective Action Management?s corrective action plan is included at the end of this report after the schedule of prior year findings.

Corrective Action Plan

2021-001 Update Documented Policies and Procedures Over Federal Awards Planned Corrective Action New Hampshire Children?s Trust, Inc. agrees with the finding and has reviewed and updated its written policies and procedures related to federal awards, which specifically address the requirements under the Uniform Guidance. New Hampshire Children?s Trust, Inc. distributed revised 2022 policies and procedures to necessary staff, as well as advised and trained its staff on following such policies and procedures, including subrecipient monitoring and management. As well, we updated our travel policy, and reviewed all other pertinent policies. We will further update and revise the subrecipient monitoring policy to included required information in subrecipient agreements, references to the Uniform Guidance, segregation of duties, and language that explicitly prohibits management override of controls. As well, NHCT is instituting additional safeguards in its subrecipient agreements to assess risk and monitor expenses of its subrecipients. Planned Implementation Date of Corrective Action NHCT addressed the need to monitor subrecipients in 2022 and is currently conducting an annual review of its written financial policies and procedures to address the need to include required information in subrecipient agreements, references to the Uniform Guidance, segregation of duties, and language that explicitly prohibits management override of controls. These additional measures will be approved and implemented in 2023.

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