Audit 317761

Finding 2023-001 Identification of the Federal Program: Federal Agency: U.S. Department of Agriculture Food and Nutrition Service Assistance Listing No.: 10.557 – Special Supplemental Nutrition Program for Women, Infants, and Children (WIC) Pass-Through Entity: Indiana State Department of Health Pass-Through Award Numbers: 3610-572900-142500 (22), 3610-572900-142500 (23) Award Years: 10/1/22–9/30/23 and 10/1/23–9/30/24 Criteria or specific requirement (Including Statutory, Regulatory or Other Citation): Applicants for WIC program benefits are screened at WIC clinic sites to determine their WIC eligibility. To be certified eligible, they must meet the following eligibility criteria (7 CFR Sections 246.7(c), (d), (e), (g), and (l)): (a)Categorical – Eligibility is restricted to pregnant, postpartum, and breast-feeding women; infants; and children up to their fifth birthday (7 CFR Sections 246.2 (definition of each category) and 246.7(c)). (b)Identity and Residency – Except in limited circumstances, WIC applicants must be physically present for eligibility screenings and must provide proof of identity. An applicant must also meet the state agency residency requirement. Except in the case of Indian state agencies, the applicant must reside in the jurisdiction of the state. Indian state agencies may require applicants to reside within their jurisdiction. (c)Income – An applicant must meet an income standard established by the state agency or be determined to be automatically (adjunctively) income-eligible based on documentation of his/her eligibility, or certain family members’ eligibility, for the following federal programs: (1) Temporary Assistance for Needy Families, (2) Medicaid, or (3) Supplemental Nutrition Assistance Program (formerly the Food Stamp Program). State agencies may also determine an individual to be automatically income-eligible, based on documentation of his/her eligibility for certain state-administered programs. (d)Nutritional Risk – A competent professional authority (e.g., physician, nutritionist, registered nurse, or other health professional) must determine that the applicant is at nutritional risk. While the broad guidelines for determining nutritional risk are set forth in WIC legislation and regulations, the specific allowable nutritional risk criteria are defined in WIC policy guidance, which is updated periodically. Each state agency may choose which allowable nutritional risk criteria will be used to determine eligibility. When an applicant meets all eligibility criteria, he/she is determined by WIC clinic staff to be eligible for program benefits. Certification periods are assigned to each participant based on categorical status for women, infants, and children (7 CFR Section 246.7(g)). A WIC local agency assigns each eligible person a priority classification according to the classification system described in 7 CFR Section 246.7(e)(4). A person’s priority assignment reflects the severity of his/her nutritional risk. If the local agency cannot immediately place the person on the program for lack of an available caseload slot, the person is placed on a waiting list. Caseload vacancies are filled from the waiting list in priority classification order. State agencies are expected to target program outreach and caseload management efforts toward persons at greatest nutritional risk (i.e., those in the highest priority classifications). Pregnant women are certified for the duration of their pregnancies and for up to six weeks postpartum. Breast-feeding women may be certified approximately every six months, up to one year postpartum, or until the woman ceases breast-feeding, whichever occurs first (7 CFR Section 246.7(g)(1)). Infants are certified at intervals of approximately six months, except that infants under six months of age may be certified for a period extending up to the child’s first birthday, provided the quality and accessibility of health care services are not diminished. Children are certified for six-month intervals ending with the last day of the month in which the child reaches his/her fifth birthday. State agencies also have the option to certify children for a period of one year if the state agency ensures that the child receives the required health and nutrition assessments (7 CFR Section 246.7(g)(1)). Non-breast-feeding women are certified for up to six months postpartum. All categories of participants may be certified up to the last day of the last month of the certification period (7 CFR Section 246.7(g)(1)). Condition: The Corporation screens applicants for eligibility by following the state of Indiana guidelines as provided through the INWIC system used to enter, track, and store information about applicants. Based on guidance contained in 7 CFR Section 246, states were encouraged to move to a paperless system. Specifically, federal guidance contained in 7 CFR 246.7 (i)(4) and (5)(i) outlines acceptable documentation to be included on certification forms as “a description of the document(s) used to determine residency and identity or a copy of the document(s) used or the applicants written statement when no documentation exists,” and “a description of the document(s) used to determine income eligibility or a copy of the document(s) in the file.” The state of Indiana has followed that guidance and does not require the Corporation to retain copies of an applicant’s proof of residence, income, etc., regarding eligibility. Therefore, we were not able to test internal controls over compliance or compliance over the eligibility compliance requirement through re-performance and have issued a qualified opinion based on the scope limitations. Cause: The Corporation follows a paperless system as supported by the state of Indiana. The state does not require third-party supporting documentation of eligibility determinations to be retained. Effect or potential effect: Due to the online nature of the eligibility system, the program does not have documentation available to test compliance with the eligibility requirements. A scope limitation qualified opinion was issued for Assistance Listing 10.557, as we were unable to obtain sufficient documentation supporting the compliance of the Corporation regarding eligibility. Questioned costs: None. Context: Federal expenditures reported in the schedule of expenditures of federal awards for Assistance Listing 10.557 totaled $1,753,528 for the year ended December 31, 2023. Identification as a repeat finding, if applicable: Yes. Prior year finding 2022-001. Recommendation: No further follow-up is required, as management of the Corporation is following the applicable guidance. Views of responsible officials: Management agrees with the finding. No changes in our current procedures are required as we are following the State requirements.

Finding 2023-002 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services Assistance Listing No.: 93.011 – COVID-19 – National Organizations for State and Local Officials Award Numbers: G32HS42634C6, U3SHS45317C6 Award Years: G32HS42634C6: 07/31/2021-5/31/2023: U3SHS45317C6: 11/1/2021-7/31/2023 Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal” entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the “Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Per Award Number G32HS42634‐01‐00 and U3SHS45317‐01‐00, Terms and Conditions Section, page 3, subsection 5, “As the grantee institution, you have the primary responsibility for developing and adhering to your organizational participant incentive policy and maintaining appropriate documentation for each participant gift card. Lastly, it is also the responsibility of the grant recipient to report all grant related costs and it is the responsibility of the sub-recipient to track and report these costs to you as the grant recipient.” Per management’s Gift Card Process – Community Impact – COVID 1 and COVID 2 Grants policy, Section 12, “During scheduled / clinic gift card pick up, the Community Health Worker collects the following information to ensure the gift card is exchanged to the prequalified client who had received prior education: Vaccine Card (ensure 2nd or booster shot is documented), form of ID with the client’s name on it to match with vaccine card and internal spreadsheet, and internal spreadsheet for final confirmation of communication and exchange.” Condition: Participants are eligible to participate in the program and receive a gift card if they received a COVID-19 vaccine. The Corporation screened applicants for eligibility; however, they did not retain supporting documentation to support that the participants in the program had a COVID-19 vaccine. Cause: The Corporation did not have internal controls in place to require supporting documentation be retained to support that the participant had a COVID-19 vaccination. Effect or potential effect: Participant may receive a gift card for participating in the program and not have received the COVID-19 vaccination. Questioned costs: $68,797 – represents the total amount of gift cards distributed in 2023 where documentation to support that the participant had a COVID-19 vaccination was not retained. Context: We selected a sample of 40 gift cards provided to participants in 2023 to perform eligibility testing in which we reviewed evidence of the disbursement and the participant’s attestations as required by the relevant grant agreements. However, the Corporation did not retain evidence that the participant had received a COVID-19 vaccination. The total gift cards provided to participants was $68,797. Federal expenditures reported in the schedule of expenditures of federal awards for Assistance Listing 93.011 totaled $1,586,209 for the year ended December 31, 2023. Identification as a repeat finding, if applicable: Yes. Prior year finding 2022-003. Recommendation: The Corporation should revise its current internal controls to require proof of the participant’s COVID-19 vaccination. Views of responsible officials: Management agrees with the finding. G32HS42634C6 and U3SHS45317C6 ended on May 31, 2023 and July 31, 2023, respectively, and therefore the remediation of the internal controls related to these programs is no longer applicable. However, effective August 15, 2023, the Corporation has implemented the following changes, which we believe would address future internal control considerations. The below procedures were added to the grant checklist which is required on all grants applied for by Corporation entities. Responsible parties are required to document all procedures and sign off on these procedures. The requirements formalize reporting and data management procedures, which include proper management approval and retention of these records. The grant checklist is additionally approved by the grant applicant and Vice President or Executive Director overseeing the grant. Grant Checklist Items Initials and Date Completed Comments Determine if there are any eligibility requirements. If so, please list the requirements and how these requirements will be documented. • All eligibility requirements should be documented and signed off on at the time the eligibility is confirmed. • All documentation of these procedures should be retained and readily available upon request.

Finding 2023-002 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services Assistance Listing No.: 93.011 – COVID-19 – National Organizations for State and Local Officials Award Numbers: G32HS42634C6, U3SHS45317C6 Award Years: G32HS42634C6: 07/31/2021-5/31/2023: U3SHS45317C6: 11/1/2021-7/31/2023 Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal” entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the “Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Per Award Number G32HS42634‐01‐00 and U3SHS45317‐01‐00, Terms and Conditions Section, page 3, subsection 5, “As the grantee institution, you have the primary responsibility for developing and adhering to your organizational participant incentive policy and maintaining appropriate documentation for each participant gift card. Lastly, it is also the responsibility of the grant recipient to report all grant related costs and it is the responsibility of the sub-recipient to track and report these costs to you as the grant recipient.” Per management’s Gift Card Process – Community Impact – COVID 1 and COVID 2 Grants policy, Section 12, “During scheduled / clinic gift card pick up, the Community Health Worker collects the following information to ensure the gift card is exchanged to the prequalified client who had received prior education: Vaccine Card (ensure 2nd or booster shot is documented), form of ID with the client’s name on it to match with vaccine card and internal spreadsheet, and internal spreadsheet for final confirmation of communication and exchange.” Condition: Participants are eligible to participate in the program and receive a gift card if they received a COVID-19 vaccine. The Corporation screened applicants for eligibility; however, they did not retain supporting documentation to support that the participants in the program had a COVID-19 vaccine. Cause: The Corporation did not have internal controls in place to require supporting documentation be retained to support that the participant had a COVID-19 vaccination. Effect or potential effect: Participant may receive a gift card for participating in the program and not have received the COVID-19 vaccination. Questioned costs: $68,797 – represents the total amount of gift cards distributed in 2023 where documentation to support that the participant had a COVID-19 vaccination was not retained. Context: We selected a sample of 40 gift cards provided to participants in 2023 to perform eligibility testing in which we reviewed evidence of the disbursement and the participant’s attestations as required by the relevant grant agreements. However, the Corporation did not retain evidence that the participant had received a COVID-19 vaccination. The total gift cards provided to participants was $68,797. Federal expenditures reported in the schedule of expenditures of federal awards for Assistance Listing 93.011 totaled $1,586,209 for the year ended December 31, 2023. Identification as a repeat finding, if applicable: Yes. Prior year finding 2022-003. Recommendation: The Corporation should revise its current internal controls to require proof of the participant’s COVID-19 vaccination. Views of responsible officials: Management agrees with the finding. G32HS42634C6 and U3SHS45317C6 ended on May 31, 2023 and July 31, 2023, respectively, and therefore the remediation of the internal controls related to these programs is no longer applicable. However, effective August 15, 2023, the Corporation has implemented the following changes, which we believe would address future internal control considerations. The below procedures were added to the grant checklist which is required on all grants applied for by Corporation entities. Responsible parties are required to document all procedures and sign off on these procedures. The requirements formalize reporting and data management procedures, which include proper management approval and retention of these records. The grant checklist is additionally approved by the grant applicant and Vice President or Executive Director overseeing the grant. Grant Checklist Items Initials and Date Completed Comments Determine if there are any eligibility requirements. If so, please list the requirements and how these requirements will be documented. • All eligibility requirements should be documented and signed off on at the time the eligibility is confirmed. • All documentation of these procedures should be retained and readily available upon request.

Finding 2023-001 Identification of the Federal Program: Federal Agency: U.S. Department of Agriculture Food and Nutrition Service Assistance Listing No.: 10.557 – Special Supplemental Nutrition Program for Women, Infants, and Children (WIC) Pass-Through Entity: Indiana State Department of Health Pass-Through Award Numbers: 3610-572900-142500 (22), 3610-572900-142500 (23) Award Years: 10/1/22–9/30/23 and 10/1/23–9/30/24 Criteria or specific requirement (Including Statutory, Regulatory or Other Citation): Applicants for WIC program benefits are screened at WIC clinic sites to determine their WIC eligibility. To be certified eligible, they must meet the following eligibility criteria (7 CFR Sections 246.7(c), (d), (e), (g), and (l)): (a)Categorical – Eligibility is restricted to pregnant, postpartum, and breast-feeding women; infants; and children up to their fifth birthday (7 CFR Sections 246.2 (definition of each category) and 246.7(c)). (b)Identity and Residency – Except in limited circumstances, WIC applicants must be physically present for eligibility screenings and must provide proof of identity. An applicant must also meet the state agency residency requirement. Except in the case of Indian state agencies, the applicant must reside in the jurisdiction of the state. Indian state agencies may require applicants to reside within their jurisdiction. (c)Income – An applicant must meet an income standard established by the state agency or be determined to be automatically (adjunctively) income-eligible based on documentation of his/her eligibility, or certain family members’ eligibility, for the following federal programs: (1) Temporary Assistance for Needy Families, (2) Medicaid, or (3) Supplemental Nutrition Assistance Program (formerly the Food Stamp Program). State agencies may also determine an individual to be automatically income-eligible, based on documentation of his/her eligibility for certain state-administered programs. (d)Nutritional Risk – A competent professional authority (e.g., physician, nutritionist, registered nurse, or other health professional) must determine that the applicant is at nutritional risk. While the broad guidelines for determining nutritional risk are set forth in WIC legislation and regulations, the specific allowable nutritional risk criteria are defined in WIC policy guidance, which is updated periodically. Each state agency may choose which allowable nutritional risk criteria will be used to determine eligibility. When an applicant meets all eligibility criteria, he/she is determined by WIC clinic staff to be eligible for program benefits. Certification periods are assigned to each participant based on categorical status for women, infants, and children (7 CFR Section 246.7(g)). A WIC local agency assigns each eligible person a priority classification according to the classification system described in 7 CFR Section 246.7(e)(4). A person’s priority assignment reflects the severity of his/her nutritional risk. If the local agency cannot immediately place the person on the program for lack of an available caseload slot, the person is placed on a waiting list. Caseload vacancies are filled from the waiting list in priority classification order. State agencies are expected to target program outreach and caseload management efforts toward persons at greatest nutritional risk (i.e., those in the highest priority classifications). Pregnant women are certified for the duration of their pregnancies and for up to six weeks postpartum. Breast-feeding women may be certified approximately every six months, up to one year postpartum, or until the woman ceases breast-feeding, whichever occurs first (7 CFR Section 246.7(g)(1)). Infants are certified at intervals of approximately six months, except that infants under six months of age may be certified for a period extending up to the child’s first birthday, provided the quality and accessibility of health care services are not diminished. Children are certified for six-month intervals ending with the last day of the month in which the child reaches his/her fifth birthday. State agencies also have the option to certify children for a period of one year if the state agency ensures that the child receives the required health and nutrition assessments (7 CFR Section 246.7(g)(1)). Non-breast-feeding women are certified for up to six months postpartum. All categories of participants may be certified up to the last day of the last month of the certification period (7 CFR Section 246.7(g)(1)). Condition: The Corporation screens applicants for eligibility by following the state of Indiana guidelines as provided through the INWIC system used to enter, track, and store information about applicants. Based on guidance contained in 7 CFR Section 246, states were encouraged to move to a paperless system. Specifically, federal guidance contained in 7 CFR 246.7 (i)(4) and (5)(i) outlines acceptable documentation to be included on certification forms as “a description of the document(s) used to determine residency and identity or a copy of the document(s) used or the applicants written statement when no documentation exists,” and “a description of the document(s) used to determine income eligibility or a copy of the document(s) in the file.” The state of Indiana has followed that guidance and does not require the Corporation to retain copies of an applicant’s proof of residence, income, etc., regarding eligibility. Therefore, we were not able to test internal controls over compliance or compliance over the eligibility compliance requirement through re-performance and have issued a qualified opinion based on the scope limitations. Cause: The Corporation follows a paperless system as supported by the state of Indiana. The state does not require third-party supporting documentation of eligibility determinations to be retained. Effect or potential effect: Due to the online nature of the eligibility system, the program does not have documentation available to test compliance with the eligibility requirements. A scope limitation qualified opinion was issued for Assistance Listing 10.557, as we were unable to obtain sufficient documentation supporting the compliance of the Corporation regarding eligibility. Questioned costs: None. Context: Federal expenditures reported in the schedule of expenditures of federal awards for Assistance Listing 10.557 totaled $1,753,528 for the year ended December 31, 2023. Identification as a repeat finding, if applicable: Yes. Prior year finding 2022-001. Recommendation: No further follow-up is required, as management of the Corporation is following the applicable guidance. Views of responsible officials: Management agrees with the finding. No changes in our current procedures are required as we are following the State requirements.

Finding 2023-002 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services Assistance Listing No.: 93.011 – COVID-19 – National Organizations for State and Local Officials Award Numbers: G32HS42634C6, U3SHS45317C6 Award Years: G32HS42634C6: 07/31/2021-5/31/2023: U3SHS45317C6: 11/1/2021-7/31/2023 Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal” entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the “Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Per Award Number G32HS42634‐01‐00 and U3SHS45317‐01‐00, Terms and Conditions Section, page 3, subsection 5, “As the grantee institution, you have the primary responsibility for developing and adhering to your organizational participant incentive policy and maintaining appropriate documentation for each participant gift card. Lastly, it is also the responsibility of the grant recipient to report all grant related costs and it is the responsibility of the sub-recipient to track and report these costs to you as the grant recipient.” Per management’s Gift Card Process – Community Impact – COVID 1 and COVID 2 Grants policy, Section 12, “During scheduled / clinic gift card pick up, the Community Health Worker collects the following information to ensure the gift card is exchanged to the prequalified client who had received prior education: Vaccine Card (ensure 2nd or booster shot is documented), form of ID with the client’s name on it to match with vaccine card and internal spreadsheet, and internal spreadsheet for final confirmation of communication and exchange.” Condition: Participants are eligible to participate in the program and receive a gift card if they received a COVID-19 vaccine. The Corporation screened applicants for eligibility; however, they did not retain supporting documentation to support that the participants in the program had a COVID-19 vaccine. Cause: The Corporation did not have internal controls in place to require supporting documentation be retained to support that the participant had a COVID-19 vaccination. Effect or potential effect: Participant may receive a gift card for participating in the program and not have received the COVID-19 vaccination. Questioned costs: $68,797 – represents the total amount of gift cards distributed in 2023 where documentation to support that the participant had a COVID-19 vaccination was not retained. Context: We selected a sample of 40 gift cards provided to participants in 2023 to perform eligibility testing in which we reviewed evidence of the disbursement and the participant’s attestations as required by the relevant grant agreements. However, the Corporation did not retain evidence that the participant had received a COVID-19 vaccination. The total gift cards provided to participants was $68,797. Federal expenditures reported in the schedule of expenditures of federal awards for Assistance Listing 93.011 totaled $1,586,209 for the year ended December 31, 2023. Identification as a repeat finding, if applicable: Yes. Prior year finding 2022-003. Recommendation: The Corporation should revise its current internal controls to require proof of the participant’s COVID-19 vaccination. Views of responsible officials: Management agrees with the finding. G32HS42634C6 and U3SHS45317C6 ended on May 31, 2023 and July 31, 2023, respectively, and therefore the remediation of the internal controls related to these programs is no longer applicable. However, effective August 15, 2023, the Corporation has implemented the following changes, which we believe would address future internal control considerations. The below procedures were added to the grant checklist which is required on all grants applied for by Corporation entities. Responsible parties are required to document all procedures and sign off on these procedures. The requirements formalize reporting and data management procedures, which include proper management approval and retention of these records. The grant checklist is additionally approved by the grant applicant and Vice President or Executive Director overseeing the grant. Grant Checklist Items Initials and Date Completed Comments Determine if there are any eligibility requirements. If so, please list the requirements and how these requirements will be documented. • All eligibility requirements should be documented and signed off on at the time the eligibility is confirmed. • All documentation of these procedures should be retained and readily available upon request.

Finding 2023-002 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services Assistance Listing No.: 93.011 – COVID-19 – National Organizations for State and Local Officials Award Numbers: G32HS42634C6, U3SHS45317C6 Award Years: G32HS42634C6: 07/31/2021-5/31/2023: U3SHS45317C6: 11/1/2021-7/31/2023 Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal” entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the “Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Per Award Number G32HS42634‐01‐00 and U3SHS45317‐01‐00, Terms and Conditions Section, page 3, subsection 5, “As the grantee institution, you have the primary responsibility for developing and adhering to your organizational participant incentive policy and maintaining appropriate documentation for each participant gift card. Lastly, it is also the responsibility of the grant recipient to report all grant related costs and it is the responsibility of the sub-recipient to track and report these costs to you as the grant recipient.” Per management’s Gift Card Process – Community Impact – COVID 1 and COVID 2 Grants policy, Section 12, “During scheduled / clinic gift card pick up, the Community Health Worker collects the following information to ensure the gift card is exchanged to the prequalified client who had received prior education: Vaccine Card (ensure 2nd or booster shot is documented), form of ID with the client’s name on it to match with vaccine card and internal spreadsheet, and internal spreadsheet for final confirmation of communication and exchange.” Condition: Participants are eligible to participate in the program and receive a gift card if they received a COVID-19 vaccine. The Corporation screened applicants for eligibility; however, they did not retain supporting documentation to support that the participants in the program had a COVID-19 vaccine. Cause: The Corporation did not have internal controls in place to require supporting documentation be retained to support that the participant had a COVID-19 vaccination. Effect or potential effect: Participant may receive a gift card for participating in the program and not have received the COVID-19 vaccination. Questioned costs: $68,797 – represents the total amount of gift cards distributed in 2023 where documentation to support that the participant had a COVID-19 vaccination was not retained. Context: We selected a sample of 40 gift cards provided to participants in 2023 to perform eligibility testing in which we reviewed evidence of the disbursement and the participant’s attestations as required by the relevant grant agreements. However, the Corporation did not retain evidence that the participant had received a COVID-19 vaccination. The total gift cards provided to participants was $68,797. Federal expenditures reported in the schedule of expenditures of federal awards for Assistance Listing 93.011 totaled $1,586,209 for the year ended December 31, 2023. Identification as a repeat finding, if applicable: Yes. Prior year finding 2022-003. Recommendation: The Corporation should revise its current internal controls to require proof of the participant’s COVID-19 vaccination. Views of responsible officials: Management agrees with the finding. G32HS42634C6 and U3SHS45317C6 ended on May 31, 2023 and July 31, 2023, respectively, and therefore the remediation of the internal controls related to these programs is no longer applicable. However, effective August 15, 2023, the Corporation has implemented the following changes, which we believe would address future internal control considerations. The below procedures were added to the grant checklist which is required on all grants applied for by Corporation entities. Responsible parties are required to document all procedures and sign off on these procedures. The requirements formalize reporting and data management procedures, which include proper management approval and retention of these records. The grant checklist is additionally approved by the grant applicant and Vice President or Executive Director overseeing the grant. Grant Checklist Items Initials and Date Completed Comments Determine if there are any eligibility requirements. If so, please list the requirements and how these requirements will be documented. • All eligibility requirements should be documented and signed off on at the time the eligibility is confirmed. • All documentation of these procedures should be retained and readily available upon request.