Corrective Action Plans

CORRECTIVE ACTION PLAN Finding 2023-001 – Internal controls over payroll charges of employees funded by grants (Significant Deficiency) On January 9, 2024, the Eighth Judicial District Court issued a fiscal directive specifically addressing this finding. In that directive signed by the Court Executive Officer and Chief Judge, the court established policies and procedures for salaries and wages charged to all grant programs awarded to the Eighth Judicial District Court, ensuring the costs are based on records that accurately reflect the work performed and applied the policy to all departments. The procedure complies with Federal requirements outlined in 2 CFR 200. The Eighth Judicial District Court mandates that all employees working on grant-funded programs certify their hours worked monthly. i. Employees who work partially on grant programs will be required to submit a timesheet certifying the dates and hours worked. ii. Payroll certifications are required to be signed by the employee and employee’s supervisor and must be sent to the Finance department by the 5th of each month for the prior period worked. iii. The Finance department is required to attach payroll certifications to monthly and quarterly reimbursement requests before submitting them to the grantor for reimbursement.

Finding Number: 2023-002 Planned Corrective Action: Cleveland Play House had extensive turnover during the 2022 and 2023 fiscal years which resulted in several vacancies, including the Director of Finance position, for a significant portion of the year. As a result, many of the reports that are standard practice in our organization were not being completed. In addition, the filing of certain documentation to support expenditures was not being done consistently. The Director of Finance position was not filled until November 2022. As a result, documentation of allowable expenditures is being addressed for the fiscal 2023 audit. In addition to turnover, the organization transitioned to a new general ledger system with a new chart of accounts in fiscal year 2022. As a result of this transition and the vacancies mentioned above, certain data pertaining to the federal programs was not being captured. Management has informed all staff of the requirements to track federal programs within the general ledger accounts. Anticipated Completion Date: September 30, 2024 Responsible Contact Person: Erica Tkachyk, Director of Finance

Charter School Program - Assistance Listing No. 84.282 Recommendation: We recommend the School ensure policies and procedures for payroll expenditures for grant programs be charged to the federal grant based on approved hours worked in the program. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Options Schools, Inc. will implement policies and procedures for payroll expenditures charged to federal grant programs that track approved time worked. Name(s) of the contact person(s) responsible for corrective action: Jack Colwell Planned completion date for corrective action plan: July 1, 2023

This was noted in last year's audit but was identified late in the fiscal year. The time required to do the due diligence and implementation was part of our timesheet review system was not fixed until after June 2023. As noted in last year's goal, Sewall administration completed a review of payroll companies and committed on a new system that began in October 2023. Along with that, we have organized a new internal system of tracking staff's time given the complexities of the many blended funding sources. We have also implemented a regular review and supervision of time sheet allocations.

Finding 2023-003 –Special Education Cluster – Activities Allowed or Unallowed, Allowable Costs/Cost Principles Contact Person Responsible for Corrective Action: Nathaniel Day and Robin LeClaire Contact Phone Number: 317-462-4434 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: We will complete semi-annual certifications. We will also document more fully formal secondary review of vouchers Anticipated Completion Date: Already completed for the 2023-24 audit year

Special Education Cluster – Assistance Listing No. 84.IDEA Recommendation: We recommend management implement procedures to ensure that salaries charged to the grant are appropriate and are supported by the required time and effort support and that a consistent policy is applied. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Moving forward all Time & Efforts Records for federal grant funded positions will be on a single schedule (December and June) of each calendar year and tracked by each program department with support from administrative assistants. All forms will be collected electronically and remain on file in one central location in the Finance Department through Grants. Name(s) of the contact person(s) responsible for corrective action: Shelly Chin – Administrator of Communications, Grants, Partnerships & Strategy Planned completion date for corrective action plan: This will be an ongoing procedure that will be implemented immediately.

Community Development Block Grant – Assistance Listing No. 14.218 Recommendation: Procedures should be updated to review and ensure the accuracy of the financial amounts reported the in the IDIS system. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We have had this issue with the IDIS System in the past and have worked with HUD to correct it. We have reached out to HUD and will work with them again to rectify this issue. Name(s) of the contact person(s) responsible for corrective action: Robert Waters Planned completion date for corrective action plan: ASAP

Views of responsible officials and planned corrective action: Areas of focus will be to update the grant policy manual and provide training to all staff of the College to be sure that the policies contained within are adhered to. Our objectives will be that all current and incoming staff will be provided training on adhering to the policies within and proper approvals. Documentation of approvals can be achieved through our current accounting system and purchasing system. Staff has been briefed and is already working through that process of approvals by putting information through the accounting system. Measurable targets will be achieved by having a requisition and purchase order issued prior to purchase to provide a documentation trail of proper approvals and thus payment. This provides a documentation trail of approvals.

CORRECTIVE ACTION PLAN January 22, 2024 U.S. Department of Education Richmond Area Multi-Services, Inc. (RAMS) respectfully submits the following corrective action plan for the year ended June 30, 2023 Name and address of independent public accounting firm: Lindquist, von Husen & Joyce, LLP 301 Howard Street Suite 850 San Francisco, CA 94105 Audit period: July 1, 2022 to June 30, 2023 The findings from the December 20, 2023 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers in the schedule. FINDING - FEDERAL AWARD PROGRAMS AUDIT CA DEPARTMENT OF REHABILITATION Finding no. 2023-001: Allowable Cost Criteria: Title 2 U.S. Code Part 200.430(i)(1)(vii) requires that there is documentation of personnel expenses charged to the grant, including support to reflect the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one award. Condition: Certain salary amounts billed to the grant were incorrectly allocated, hence overstating the salary billed to the grant. One employee’s salary was allocated 25% to the major program (AL #84.126) from their date of hire in April 2023. Through June 2023, whereas the allocation should have been 2.5% resulting in a $3, 227 over-charge. Another employee hired in June 2023 worked 80.23% for the same major program, but the program was billed for 100% of their salary, resulting in $865 over-charge. Cause: RAMS miscalculated the salary amount that should be charged to the grant which caused the overstatement of their cost-reimbursement billing due to using incorrect time allocation. Effect: Salary costs charged to the program that were unsupported in accordance with allowable cost principles. Questioned Costs: The total amount of salary tested during the audit was $66,576, representing approximately 10% of salary charges to the major program. The amount of questioned costs identified above in relation to the total amount sampled was 6.15% Auditor’s Recommendation: RAMS should consider creating appropriate procedure to monitor salary allocation calculations and ensure that all costs billed are supported by adequate documentation. Action Taken: Subsequent to year-end, RAMS changed its billing procedure to prevent over-billing or inaccurate allocation of payroll costs by adapting a cost allocation method based on the actual hours reported by employee and not the estimated ours used in preparation of the budget. On July 24, 2023, the program manager, division director, billing specialist and finance manage met to review and implement new billing procedure. The effective date of this change was July 1, 2023. If the U.S. Department of Education has questions regarding this plan, please call Eduard Agajanian at 408-394-8778. Sincerely yours, Eduard Agajanian, CFO Richmond Area Multi-Services, Inc.

Proper filing of the documentation supporting the approvals of payments will be maintained with Standard Operating Procedures outlining the processes to ensure consistency and the ability to retrieve documents even turning times of transition. Person(s) Responsible: Gina Grange Timing for Implementation: Complete

The payroll allocation process was adjusted during the fiscal year following the transition that created both the fiscal year 2022 and 2023 findings. This process has also been reviewed by NSF. A system of checks and balances are also in place to make sure wages are accurate between files and the payroll system. Person(s) Responsible: Gina Grange Timing for Implementation: Complete

When the Transportation and Public Works Department (TPWD) receives certified payroll from the contractor, the project manager writes the contract number and sends this to the Department of Finance (Finance). The problem with this method is the project manager never receives confirmation from Finance about receiving these documents and storage of these documents are unknown. To correct this problem, TPWD plans to have the project manager send an email to the receiver in Finance indicating that TPWD has sent it and then have the receiver send an email back once they receive the certified payroll documents. Responsible Party: Gregory Mariscal Supervising Engineer Transportation and Public Works Department Anticipated Implementation Date: April 1, 2024

The City has studied its existing procedures and Information Technology (IT) resources in relation to the three noted exceptions. We have identified how the City’s procedures for inspectors lead to the exceptions and the conditions that allowed for the documentation and evidence of resolved inspection failures to be insufficient: • Since 2017, the City has served as a demonstration agency for what is now HUD’s final National Standards for the Physical Inspection of Real Estate (NSPIRE). The purpose of the demonstration was to conduct Housing Quality Standards (HQS) inspections and inspections under the test protocol simultaneously, with some inspectors using HQS and some inspectors using the test standards. The test standards were conducted using electronic devices so the inspection results could be communicated to HUD, and the HQS inspections continued to be documented using HUD Form 52580. • Utilizing two methodologies for inspection documentation over a time span of greater than five years lead to inconsistent training of new staff, and inconsistent methods and expectations for documenting failed inspection results and follow up. • This condition was exacerbated in Calendar Year 2021 and 2022 when the City began the “catch-up” inspections required by HUD after the COVID-19 inspection waivers. To resolve these issues and correct the conditions going forward, the City will: • Design and implement an inspection application (app) to be used on the inspectors’ mobile devices. The app will be based on HUD’s new NSPIRE Inspection Tool and Checklist. This document has not been assigned a HUD Form number, but is available for review on HUD’s NSPIRE website. The app will be functional on mobile devices even when there is no cellular signal or WiFi connectivity by storing the data, which will be downloaded by the inspector. • The app will include the following features to ensure that documentation is completed properly and timely: - An electronic signature will be required for all inspections, regardless of whether the inspection passed or failed. - An auto-generated summary report of the day’s failed inspections will be emailed to the Supervisors and to the inspector who completed the failed inspection. The report will include the family and owner name, the unit address, identification of the failed items, to whom the responsibility for resolving the failed item is assigned (either family or owner), and the deadline by which the failed items must be resolved. - An auto-generated letter to the family and owner will be mailed and/or emailed within 2 business days of the completed inspection. The letter will include the family and owner name, the unit address, identification of the failed items, to whom the responsibility for resolving the failed item is assigned (either family or owner), the deadline by which the failed items must be resolved, and the potential date of termination if the failed inspection is not resolved. This letter will replace the Failed Inspection Memo which is currently being used by the City to communicate inspection failures. - The app will send email notifications to the Supervisors and inspector beginning 10 days in advance of the repair deadline reminding them that the inspection has not been resolved. - The inspector will use the app to document the resolution of the inspection by indicating what evidence the inspector used to demonstrate the repaired/resolved item. - The inspector will use the app to assign an extension of the deadline when necessary and appropriate. - If a failed inspection has not passed by the deadline or extension, the app will alert the inspector and Supervisor to either document the resolved inspection items or begin the termination process. The City believes that automating these aspects of the failed inspection procedures will prevent the conditions noted in the audit findings by streamlining documentation for the inspectors, alerting supervisors of failed inspections, and providing a consolidated report across all inspectors that can be reviewed regularly. The City has already started the inspection app design process with the IT department, capitalizing and expanding on an existing app that inspectors use for scheduling inspections. When the inspection app is ready to test, the lead inspector, Sylvia Coombs, will begin using it immediately and communicate any feedback to Elizabeth Durham, Rebecca Lane and the IT department. The City anticipates the app will be ready for testing by March 31, 2024. When the app has been tested and refined, Sylvia Coombs and Elizabeth Durham will train the staff in its use and communicate the requirement and expectation that the app is replacing the paper HUD Form 52580 and the Failed Inspection Memo. This change will be implemented by April 30, 2024. Elizabeth Durham and Rebecca Lane will be responsible for monitoring the results of these changes. Responsible Party: Elizabeth Durham Acting Manager Housing and Community Services Department Rebecca Lane Program Specialist Housing and Community Services Department Anticipated Implementation Date: April 30, 2024

Management Response and Planned Corrective Action On occasion, given holidays, vacations, meeting schedules, etc., and the tight payroll submission timeline, it can happen that a timecard may be verbally approved but not signed and scanned when submitted for payroll processing and recording in the GL. Given the growth of the agency and the capacity of our administrative and accounting teams, we are in the process of transitioning to an online timecard process with a more robust payroll processing company. This should eliminate all timecard manual signature approval issues. This will be implemented by June 30, 2024. Views of Responsible Officials and Corrective Actions Management of NBCC agrees with the finding noted above, and will implement proper internal controls to correct the issue noted. Contact Information for Responsible Officials Kristine Schwarz, Executive Director, 805-963-7777

Higher Education Institutional Aid – Fostering Inclusive Excellence for STEM Achievement – Assistance Listing No. 84.031C Recommendation: We recommend the University calculate the indirect costs when the direct cost is incurred instead of claiming the amount per the budget to ensure indirect costs are consistently calculated and allocated throughout the grant term. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to the finding: The Finance department implemented a quarterly process aimed at accurately calculating indirect costs, ensuring their recognition period when expenses are incurred. Name(s) of the contact person(s) responsible for corrective action: Shalini Patel, Controller Planned completion date for a corrective action plan: April 1, 2024

Department staff has reviewed the Legislative Audit Bureau’s (LAB) interim audit memo for Finding 2023-300: Eligibility for the Children’s Health Insurance Program. This is the department’s Corrective Action Plan. Recommendation (2023-300): Eligibility for the Children’s Health Insurance Program We recommend the Wisconsin Department of Health Services work with the federal government to resolve these improper payments, including the determination of the total amount of improper payments, and return these amounts to the federal government, as appropriate. Wisconsin Department of Health Services Planned Corrective Action: The Division of Medicaid Services (DMS) acknowledges that we maintained eligibility under the Children’s Health Insurance Program (CHIP) for individuals who had turned age 19, including SCHIP participants. It was our overarching policy to not terminate health care coverage upon certain changes in circumstances for Medicaid participants during the federal public health emergency (PHE). To comply with this policy, DHS made system changes at the beginning of the pandemic to maintain eligibility for all participants. After CMS provided additional information specific to SCHIP, DHS considered whether to make the necessary system changes to terminate SCHIP participants who turned 19 during the public health emergency. Because of the system limitation and DHS’s overarching goals to maintain continuous coverage, amongst other reasons, DHS decided to temporarily keep all CHIP participants enrolled until the public health emergency ended. DMS leaders met with CMS leaders on May 11, 2022, to discuss this compliance issue and related systems limitations. During that meeting, CMS indicated that they understood the system and communication challenges of having a single program that combines Medicaid and CHIP. CMS also acknowledged that the federal public health emergency was likely to end at any time, so making the required system changes would not be prudent. CMS said they would follow up with Wisconsin if they determined that further state action was needed, but they did not communicate to us after the meeting that they felt the compliance issue needed to be addressed. This confirmed the Medicaid Director’s decision to not pursue costly systems changes to support a change that might only be needed for a short period of time. After the PHE ended, DHS took proactive steps to identify aged-out CHIP participants and ensure that their eligibility was redetermined in the first two months of unwinding. In contrast to the rest of the CHIP and Medicaid population, whose renewals were distributed over a 12-month period from June 2023 through May 2024, these members’ renewals were accelerated to June and July 2023, so that their CHIP coverage would end as soon as possible after the end of the PHE. While we agree conceptually with the finding, the questioned costs identified do not consider that many (if not most) of the ineligible members would have been eligible for Medicaid as childless adults upon aging out of the CHIP program. We will discuss this likelihood with CMS and if necessary, use data available in our CARES eligibility system to assess how many of these members did retain eligibility as childless adults or in other categories of Medicaid after completing renewals in June and July. Anticipated Completion Date: March 31, 2024 Person responsible for corrective action: Jori Mundy, Director Bureau of Eligibility and Enrollment Policy, Division of Medicaid Services jori.mundy@dhs.wisconsin.gov. Rebuttal from the Wisconsin Legislative Audit Bureau - As stated in the finding, and as acknoledged by DHS, DHS maintained continous eligibility for SCHIP participants who were over age 19. This eligibility requirement continue through the public health emergency. Since CHIP and MEDICAID are separate programs, consideration of whether these participants could have been eligible for the Medicaid program would not have been part of our audit. Payments to providers for these participants were funded by SCHIP and not the medicaid program.

Department staff has reviewed the Legislative Audit Bureau’s (LAB) interim audit memo for Finding 2023-302: Social Services Block Grant – FFATA Reporting. This is the department’s Corrective Action Plan.  Recommendation (2023-302): Social Services Block Grant – FFATA Reporting We recommend the Wisconsin Department of Health Services: • Revise its procedures for Federal Funding Accountability and Transparency Act reporting to ensure all subawards funded by federal grants are included in reports used to identify subawards for reporting; and • Develop procedures to identify and report subawards made by the state agencies to which it has transferred federal funding. Wisconsin Department of Health Services Planned Corrective Action: DHS will update FFATA procedures to ensure all DHS federal programs are included in FFATA reporting. DHS will also develop procedures to report the subawards made by other state agencies to whom DHS has transferred federal funding. Anticipated Completion Date: August 31, 2024 Person responsible for corrective action: Vanessa Salata, Section Chief Expenditure Accounting, Bureau of Fiscal Services, Division of Enterprise Services vanessaa.salata@dhs.wisconsin.gov

Department staff has reviewed the Legislative Audit Bureau’s (LAB) interim audit memo for Finding 2023-301: Social Services Block Grant – Subrecipient Contracts. This is the department’s Corrective Action Plan.  Recommendation (2023-301): Social Services Block Grant – Subrecipient Contracts We recommend the Wisconsin Department of Health Services update its procedures for contract development to ensure information provided in its subrecipient contracts identifies the Social Services Block Grant as the federal funding source for the basic county allocation of the community aids program related to the transferred Temporary Assistance for Needy Families funds. Wisconsin Department of Health Services Planned Corrective Action: DHS will change the Assistance Listing Number (ALN) for Temporary Assistance for Needy Families funds transferred to the Social Services Block Grant (SSBG) to the SSBG’s ALN, 93.667, for future Basic County Allocation contracts. Anticipated Completion Date: July 31, 2024 Person responsible for corrective action: Rebecca Mogensen, Section Chief Managerial Accounting, Bureau of Fiscal Services, Division of Enterprise Services rebeccaj.mogensen@dhs.wisconsin.gov

Department staff has reviewed the Legislative Audit Bureau’s (LAB) interim audit memo for Finding 2023-306: Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response – Subrecipient Monitoring. This is the department’s response.  Recommendation (2023-306): Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response – Subrecipient Monitoring We recommend the Wisconsin Department of Health Services: • Review the tracking spreadsheets completed in fiscal year 2022-23, and complete the assessment of the progress and fiscal reports and consideration of potential unallowable costs, document the conclusions, and return funding to the federal government if costs were determined to be unallowable; Wisconsin Department of Health Services Planned Corrective Action: Emergency Health Care (OPEHC) will create a workgroup that includes subject matter expert staff from all impacted areas that will be tasked with reviewing all the tracking spreadsheets for fiscal year 2022-2023. Staff will conduct the recommended assessment on all progress and fiscal reporting to determine any possible unallowable costs under the parameters of the cooperative agreement. The workgroup will coordinate efforts, as needed, with impacted health departments and workers. The workgroup will document all conclusions and, in coordination with leadership, will work with the correct federal agency to discuss and complete any necessary next steps. We recommend the Wisconsin Department of Health Services: • Develop a written monitoring plan for the Cooperative Agreements program that includes a description of the subrecipient monitoring expected for low-moderate-, and high-risk subrecipients; procedures for completing and documenting review of the progress and fiscal reports; procedures for completing and documenting desk reviews or on-site visits; procedures for assessing and documenting the reliance that can be placed on review of a subrecipient’s single audit report; and procedures for documenting management oversight of the monitoring plan. Wisconsin Department of Health Services Planned Corrective Action: The Department of Health Services (DHS), Division of Public Health (DPH) Grant Managers and their designees are responsible for subrecipient monitoring. As part of the ongoing monitoring, DHS DPH recognized opportunities for improvement of this process and began developing a new Internal Controls Checklist during FY 2022-23. On February 15, 2024, DHS DPH Bureau of Operations provided training to DHS DPH staff who regularly work on financial, granting, and/or contracting items on a new Internal Controls Checklist for Federal Funding. This checklist provides DHS DPH federal Grant Managers and their designees a best practice tool for reviewing how their grant activities are carried out and to ensure their consistency with the terms and conditions of the federal award and with federal and state policies. The Internal Controls Checklist guides DHS DPH federal Grant Managers and their designees through a series of questions that, among other things, direct them to have knowledge of, follow, and maintain written policies for administering federal grant programs; document procedures for verifying invoices; archive relevant documentation; ensure financial reports are submitted timely; monitor subgrantees for fiscal and program requirements; document procurement authority; and monitor expenses against waiver and contract limits. The Internal Controls Checklist is to be signed by the Grant Managers or their designees in the last quarter of the grant. The policy states the Section Manager is accountable to make sure the Checklist is completed accurately. Using the Internal Controls Checklist will formalize management oversight as it will be signed by the Section Manager overseeing the grant. The Internal Controls Checklist will be updated to identify the need for subrecipient monitoring to be attributed to the risk levels of subrecipients. Also, it will include direction to document procedures for completing and documenting review of the progress and fiscal reports, procedures for completing and documenting desk reviews or on-site visits, and for procedures for assessing and documenting the reliance that can be placed on review of a subrecipient’s single audit report. Grant Managers and their designees are encouraged to use the Internal Controls Checklist as a monitoring plan by evaluating each item in the checklist and saving the procedures, documents, and emails associated with those steps in a folder, in addition to the program’s usual record keeping practice, to enhance the effectiveness of the information. Grant Managers and their designees may also produce a separate monitoring plan instead of using the Internal Controls Checklist, and if a separate document is produced, management oversight will be documented within the plan. We recommend the Wisconsin Department of Health Services: • Develop a central location to maintain documentation related to the subrecipient monitoring, including email correspondence. Wisconsin Department of Health Services Planned Corrective Action: Grant Managers and their designees maintain documentation related to subrecipient monitoring in various ways, and to provide better consistency, the newly created Internal Controls Checklist provides some recommendations. The Internal Controls Checklist recommends Grant Managers and their designees develop plans for archiving relevant documents for program administration and to maintain information to support subgrantee monitoring, including risk analyses and reporting. Individual units in DHS DPH will develop a central location to maintain documentation related to the subrecipient monitoring, including email correspondence. We recommend the Wisconsin Department of Health Services: • Provide sufficient training to the Department of Health Services staff administering the Health Disparities program to ensure all subrecipient monitoring responsibilities are completed consistently and are based on the risk assessment level determined. Wisconsin Department of Health Services Planned Corrective Action: Current Grant Managers and their designees in DHS DPH who oversee federally awarded programs will be informed of the federal requirements as they relate to 2 CRF s. 200.331, though specific subrecipient monitoring. DHS DPH will administer annual trainings to Grant Administrators and their designees on subrecipient monitoring requirements and policies for conducting risk assessments. Anticipated Completion Date: June 30, 2025 Person responsible for corrective action: Natalie Easterday, Director Office of Preparedness & Emergency Health Care, Division of Public Health natalie.easterday@dhs.wisconsin.gov

Finding 2023-400: Education Stabilization Fund—ESSER Fund Reporting Planned Corrective Action: The Wisconsin Department of Public Instruction (DPI) will use data reporting procedures established after FY21 data to address the FY20 data reporting discrepancies found during the audit. These procedures include data quality testing to ensure data accuracy and will address the discrepancies between the information reported in the federal portal and the data collected in DPI’s grant management system. DPI will have the corrected data available for the Re-Open Data Collection Reporting Period by June 30, 2024. Additionally, DPI will utilize the federal Re-Open Data Collection Reporting period for FY22 to address the discrepancies identified in expenditure data previously reported and use our quality assurance procedures to ensure FY22 data is reflective of the accurate grants management data within WISEgrants and the ESF ESSER report. The federal Re-Open Data Collection Reporting period for FY22 data is between July 29, 2024, and August 15, 2024. The United States Department of Education will not re-open the portal sooner. Anticipated Completion Date: June 30, 2024 Person responsible for corrective action: Shelly Babler, Director Title I and School Support Team Division for Student and School Success Department of Public Instruction shelly.babler@dpi.wi.gov. Kyle Peaden, Assistant Director Title I and School Support Team Division for Student and School Success Department of Public Instruction kyle.peaden@dpi.wi.gov

I am writing to you in response to the finding 2023-500: Coronavirus State and Local Fiscal Recovery Funds. I agree with the finding and recommendation that was identified during the audit. Please see our below action plan that was conducted as soon as we were made aware of the issue: Corrective Action Plan Finding 2023-500: Coronavirus State and Local Fiscal Recovery Funds—Unallowable Costs Planned Corrective Action: Communication was sent out on October 2nd, 2023, to the Division of State Patrol on what classifications were deemed allowable for reimbursement to prevent future unallowable costs. On October 9th, 2023, a journal was completed for $2,173.12 to remove the unallowable costs from the grant. Lastly, on October 10th, the process of reviewing and approving the expenditures being submitted for reimbursement are now completed in three different organizational areas in the Department to ensure compliance with the MOA. Anticipated Completion Date: Completed on October 10th, 2023 Person responsible for corrective action: Cody Castillo, WisDOT Controller Division of Business Management, Bureau of Financial Management Cody.Castillo@dot.wi.gov

Department staff has reviewed the Legislative Audit Bureau’s (LAB) interim audit memo for Finding 2023-309: Coronavirus State and Local Fiscal Recovery Funds – Unallowable Costs. This is the department’s Corrective Action Plan.  Recommendation (2023-309): Coronavirus State and Local Fiscal Recovery Funds – Unallowable Costs We recommend the Wisconsin Department of Health Services ensure it retains documentation to support the costs charged to the Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) program, and work with the Department of Administration and the U.S. Department of the Treasury to resolve the questioned costs we identified. Wisconsin Department of Health Services Planned Corrective Action: As CSLFRF programs have matured, DHS has continued to review and revise our processes. DHS will take this opportunity to ensure that procedures surrounding approving of invoices, storing of documentation, and comprehension of the period of performance are updated and understood by our grant administrators. DHS will work with DOA and US Treasury to resolve the questioned costs. Anticipated Completion Date: June 30, 2024 Person responsible for corrective action: Natalie Easterday, Director Office of Preparedness and Emergency Health Care, Division of Public Health natalie.easterday@dhs.wisconsin.gov

Department staff has reviewed the Legislative Audit Bureau’s (LAB) interim audit memo for Finding 2023-307: Coronavirus State and Local Fiscal Recovery Funds – Unallowable Costs. This is the department’s response.  Recommendation (2023-307): Coronavirus State and Local Fiscal Recovery Funds – Unallowable Costs We recommend the Wisconsin Department of Health Services: • Review its current procedures for approving invoices related to the Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) program to ensure the steps required for approving invoices are appropriate and documented, and that documentation is maintained either in STAR or in a central location accessible in the event of employee turnover; • Take additional steps to ensure that expenditures charged to the CSLFRF program are within the period of performance; • Provide training to staff responsible for approving invoices to ensure staff understand what documentation is required to support approvals and the required period of performance for the CSLFRF; and • Work with the Wisconsin Department of Administration and the U.S. Department of the Treasury to resolve the questioned costs related to the CSLFRF program. Wisconsin Department of Health Services Planned Corrective Action: As CSLFRF programs have matured, DHS has continually reviewed and revised our processes. We will take this opportunity to ensure that procedures surrounding approving of invoices, storing of documentation, and comprehension of the period of performance are updated and understood by our grant administrators, including providing training as necessary. DHS will work with DOA and US Treasury to resolve the questioned costs. Anticipated Completion Date: September 30, 2024 Person responsible for corrective action: Christina Isenring, Director Bureau of Operations, Division of Public Health christinam.isenring@dhs.wisconsin.gov

Finding 2023-105: Coronavirus State and Local Fiscal Recovery Funds—Unallowable Costs Auditor Recommendation: We recommend the Wisconsin Department of Administration ensure only allowable costs are charged to federal grant programs, and work with the U.S. Department of the Treasury to resolve the questioned costs we identified related to the Coronavirus State and Local Fiscal Recovery Funds program. Planned Corrective Action: The Wisconsin Department of Administration (Department) resolved the Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) costs questioned by the auditors by recouping from the school district the amount of the overpayment and obtaining from the local law enforcement agencies documentation of additional eligible expenses in amounts not less than the overpayments. The Department will continue to ensure only allowable costs are charged to federal grant programs. Anticipated Completion Date: December 18, 2023 Person responsible for corrective action: Colleen Holtan, Director Bureau of Financial Management Division of Enterprise Operations colleen.holtan@wisconsin.gov

Finding 2023-102: Emergency Rental Assistance Program—Documentation to Support Applicant Eligibility and Benefit Payments Auditor Recommendation: Obtain required documentation for the four applicants we identified or seek to recoup improper benefit payments it made to these applicants. Planned Corrective Action: The Wisconsin Department of Administration (Department) requested and received from the auditors the four applicants they identified. The Department has reviewed available documentation in its eligibility and benefit determination system and will work with the responsible community action agencies and Energy Services, Inc. (ESI) to obtain required documentation supporting the applicants’ eligibility to receive Wisconsin Emergency Rental Assistance (WERA) Program benefits. Should the Department determine that it provided WERA Program benefits to ineligible recipients, it will seek to recoup the payments made. Auditor Recommendation: Provide additional training and technical assistance to the community action agencies and Energy Services, Inc. (ESI) on the adequacy of supporting documentation that is to be obtained and entered into Home Energy (HE) Plus by the community action agencies and ESI. Planned Corrective Action: The Department will provide additional training and technical assistance to the community action agencies and ESI on the adequacy of supporting documentation obtained and entered into Home Energy (HE) Plus, its eligibility and benefit determination system, based on its monitoring of accepted documentation. Anticipated Completion Date: June 30, 2024. Persons responsible for corrective action: David Pawlisch, Administrator Division of Energy, Housing and Community Resources david.pawlisch@wisconsin.gov