Corrective Action Plans

Mountain Park identified replacement COVID related costs to evidence the spend down of period three Provider Relief funds. These funds are not subject to repayment as the Organization was able to attest and comply with the terms and conditions of the funding, including demonstrating that the distributions received were used for qualifying expenses or lost revenue attributable to COVID-19. Expected completion date: Completed Owner: Sandra Curtice, CFO

The Organization will contact the affected federal agency for guidance on resolution of the billing error. Additionally, the Organization will train management and staff working on the program to ensure an understanding of the program and its allowable costs. Furthermore, management and staff will be trained to review expenses throughout the year to ensure only allowable expenses are charged to the program. The review will include confirming that costs charged to the program are in conformity with any allowable cost elections. The contact person for this corrective action is Annette Kovamees, VP of Revenue and Financial Operations

The Organization will contact the affected federal agency for guidance on resolution of the billing errors. Additionally, the Organization will train management and staff working on the program to ensure an understanding of the program and its allowable costs. Furthermore, staff will be trained to review expenses throughout the year to ensure only allowable expenses are charged to the program. The review of expenses charged to the program will be performed by someone independent from the staff responsible for coding the expenses. The contact person for this corrective action is Annette Kovamees, VP of Revenue and Financial Operations.

April 13, 2023 Roslund, Prestage & Company, P.C. 525 W. Warwick Drive, Suite A Alma, MI 48801 Finding: 2022-001: Significant deficiency in internal control / immaterial non-compliance Federal Program: Block Grants for Prevention and Treatment of Substance Abuse ? Treatment and Women?s Specialty Services Condition: During testing of amounts charged to the grants, it was noted that provider stabilization payments were charged to the Treatment and Women?s Specialty Services grants but were not authorized by the grants. Corrective Action Plan: Mid-State Health Network will review grant documents when implementing new funding initiatives and will seek guidance from the awarding agency as needed. Responsible Party: Amy Keinath, Finance Manager Anticipated Completion Date: October 1, 2022

The Independent External Audit for the fiscal year ended June 30, 2022 included finding #2022-004 in which the District was cited as recording expenditures to the incorrect federal program. Allowable expenditures under the ECF program had not been adjusted to the limits set forth on FCC Form 471, which resulted in an overstatement of expenditures under the ECF program and an understatement of expenditures on the COVID-19 American Rescue Plan Elementary and Secondary Emergency Relief - 3 program. This finding is new to the District as of the 2021-22 Audit and is not a repeat finding. The cause for this finding is the need to reclassify expenditures, amounting to $65,260. The District has recorded these expenditures, of "local share" in the Emergency Connectivity Fund (ECF) budget line. These expenditures should have been expended from the COVID-19 American Rescue Plan Elementary and Secondary Emergency Relief - 3 budget line, as that is where the "local share" was expended. During the 2021-22 Fiscal Year, the School District worked with eRate Central to complete an application totaling $746,356, all of which were approved and committed by the FCC. While the District received this substantial commitment of funds to purchase earmarked technology equipment, the District was also responsible for a local share of some, but not all, devices. These local funds were being paid out of the ARP ESSER 3 Grant, out of a section earmarked for technology purchases. To mitigate findings, such as #2022-004 in the subsequent years, the District will record expenditures properly, using the appropriate budget codes. The District will review its expenditure budget lines and will monitor its usage of Federal Funds more closely. Anticipated Completion Date for Finding 2022-004: October 21, 2022 Person{s) Responsible for Corrective Action: Ryan Palmer & Marianne Romito

The University of New Hampshire respectfully submits the following corrective action plan for the year ended June 30, 2022. Audit period: July 01, 2021 to June 30, 2022 The finding from the schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the numbers assigned in the schedule. FINDINGS?FINANCIAL STATEMENT AUDIT There were no financial statement findings in the current year. FINDINGS?FEDERAL AWARD PROGRAMS AUDITS U.S. Department of Education 2022-001 Education Stabilization Fund ? Assistance Listing Numbers 84.425E and 84.425F Recommendation: We recommend the Universities and Colleges maintain the documentation used during the reporting process to support the numbers included in the public reporting on their website as well as maintain the formal documentation of the review and approval process that the reports go through during preparation. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University of New Hampshire (UNH) will work to resolve the reporting finding for fiscal year 2022 reporting. UNH will develop a process to ensure that the information reported is accurate and supporting documentation used to prepare the reports and review and approval of the reports is retained. Name(s) of the contact person(s) responsible for corrective action: Liz Stevens, Director of Student Financial Services (Student Reporting) Susan Zipkin, Director Accounting and Financial Compliance (Institutional Reporting) Planned completion date for corrective action plan: March 31, 2023 If the U.S. Department of Education has questions regarding this plan, please contact the individuals noted above. Plymouth State University respectfully submits the following corrective action plan for the year ended June 30, 2022. Audit period: July 01, 2021 to June 30, 2022 The finding from the schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the numbers assigned in the schedule. FINDINGS?FINANCIAL STATEMENT AUDIT There were no financial statement findings in the current year. FINDINGS?FEDERAL AWARD PROGRAMS AUDITS U.S. Department of Education 2022-001 Education Stabilization Fund ? Assistance Listing Numbers 84.425E and 84.425F Recommendation: We recommend the Universities and Colleges maintain the documentation used during the reporting process to support the numbers included in the public reporting on their website as well as maintain the formal documentation of the review and approval process that the reports go through during preparation. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Plymouth State University (PSU) will work to resolve the reporting finding for fiscal year 2022 reporting. PSU will develop a process to ensure that future information is reported timely, and the review and approval of the reports is documented and retained. The FY21 Uniform Guidance Single Audit was not finalized until June 2022, which contributed to the recurring issues noted in this finding. Name(s) of the contact person(s) responsible for corrective action: Mary Batch, Director of Finance (Institutional Reporting) Mac Broderick, Director of Student Financial Services (Student Reporting) Planned completion date for corrective action plan: July 31, 2022 If the U.S. Department of Education has questions regarding this plan, please contact the individuals noted above. Keene State College respectfully submits the following corrective action plan for the year ended June 30, 2022. Audit period: July 01, 2021 to June 30, 2022 The finding from the schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the numbers assigned in the schedule. FINDINGS?FINANCIAL STATEMENT AUDIT There were no financial statement findings in the current year. FINDINGS?FEDERAL AWARD PROGRAMS AUDITS U.S. Department of Education 2022-001 Education Stabilization Fund ? Assistance Listing Numbers 84.425E and 84.425F Recommendation: We recommend the Universities and Colleges maintain the documentation used during the reporting process to support the numbers included in the public reporting on their website as well as maintain the formal documentation of the review and approval process that the reports go through during preparation. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Keene State College (KSC) will work to resolve the reporting finding for fiscal year 2022 reporting. KSC developed a process to ensure that the information is reporting timely, accurately, and supporting documentation used to prepare the reports and review and approval of the reports is retained. The FY21 Uniform Guidance Single Audit was not finalized until June 2022, which contributed to the recurring issues noted in this finding. Name(s) of the contact person(s) responsible for corrective action: Catherine Mullins Planned completion date for corrective action plan: July 1, 2022 If the U.S. Department of Education has questions regarding this plan, please contact the individuals noted above. Granite State College respectfully submits the following corrective action plan for the year ended June 30, 2022. Audit period: July 01, 2021 to June 30, 2022 The finding from the schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the numbers assigned in the schedule. FINDINGS?FINANCIAL STATEMENT AUDIT There were no financial statement findings in the current year. FINDINGS?FEDERAL AWARD PROGRAMS AUDITS U.S. Department of Education 2022-001 Education Stabilization Fund ? Assistance Listing Numbers 84.425E and 84.425F Recommendation: We recommend the Universities and Colleges maintain the documentation used during the reporting process to support the numbers included in the public reporting on their website as well as maintain the formal documentation of the review and approval process that the reports go through during preparation. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Granite State College (GSC) will work to resolve the reporting finding for fiscal year 2022 reporting. GSC and the University of New Hampshire (UNH) are in the process of merging as part of a new college within UNH, which resulted in a transition of reporting responsibilities and processes. GSC and UNH will develop a process to ensure that the information reported is accurate and supporting documentation for the review and approval of reports is retained. The FY21 Uniform Guidance Single Audit was not finalized until June 2022, which contributed to the recurring issues noted in this finding. Name(s) of the contact person(s) responsible for corrective action: Andrea Nepveu, Acting Director of Financial Aid (Student Reporting) Susan Zipkin, Director, Accounting and Financial Compliance (Institutional Reporting) Planned completion date for corrective action plan: March 31, 2023 If the U.S. Department of Education has questions regarding this plan, please contact the individuals noted above.

FINDING 2022-002 Contact Person Responsible for Corrective Action: Shawn Spindler, Business Manager/Treasurer Contact Phone Number: 812.926.2090 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The appropriate personnel will prepare some sort of time and effort documentation which will then be approved by the Board of Trustees to have split personnel costs. Anticipated Completion Date: June 2023

FINDING 2022-002 Contact Person Responsible for Corrective Action: Dr. Michael Galvin, Superintendent Contact Phone Number: 812-874-2243 Views of Responsible Official: We concur with the finding for the period of the audit, we have since corrected the actions by the end of the 2021/2022 school year. Description of Corrective Action Plan: Aramark supplies all invoices, TDR and copies of receipts to be verified with the monthly invoice. The Food Service Director then goes through the invoices, receipts, and TDR sheets to verify all charges to the SFA are accounted for and correct. The Food Service Director initials the invoices and receipts to show they have been verified against the TDR and bill for Aramark. When the Food Service Director has completed the verification, they fill out a purchase order to have the ECA pay Aramark. Anticipated Completion Date: The corrective action plan was implemented in April of 2022.

Views of responsible officials and planned corrective actions: Boys & Girls Club has procedure for payroll but recognizes it?s informality. There are features in ADP that we will be implementing including having all employees use the "approve timecard" feature to verify that their time is accurate for each pay period before payroll is submitted each pay period. Supervisors will be required to review all time entries and approve them before the payroll can be processed. This will be documented by using the "approve timecard" feature added to our payroll system. Allocation of time spent in specified efforts for a grant will be designated in the appropriate department on the employee timecard. The Finance Director will designate payroll costs to a grant by using the "class" feature in QuickBooks for all payroll expenditure and generate a payroll summary from the payroll system to be kept with other grant documentation.

Views of responsible officials and planned corrective actions: Flight to Chicago for our National conference. Did not realize upgrading to economy plus for extra leg room was excessive as it fell within the parameters of our approved budget. In the future all employees traveling will adhere to the ?least expensive flight option? and will not charge any additional upgrades to the Federal grants program. We will also review other restrictions on travel for federal grants to ensure compliance.

Audit Finding Number: 2022-01 Finding Details: An effective internal control system was not in place to ensure compliance with the requirements related to the Cost Principles/compliance requirements. Recommendation: We recommend that Paladin Inc.?s management revise a system of internal controls to ensure compliance with the grant agreement and the Special Tests and Provisions Principles compliance requirements. Taken or to be Taken: Revision of the Paladin Travel Reimbursement procedure was made to the procedure already in place. If already taken, date of completion: Paladin has revised detailed procedures for processes involved with the Head Start grant. Staffing processes have been modified to accommodate the additional review of travel reimbursement prior to draws from the grant. If to be taken, estimated date of completion: Revised procedure completed 11-1-2022. Accounting staff completed a review of Head Start draws for travel reimbursement back to 7/1/22 (FY23) to be sure that draws from the grant were correct. Additional Comments: Paladin CFO stated that Paladin did have a procedure in place for processing travel reimbursements; however, it did not have a secondary procedure review in place prior to draws from the federal grant. Paladin contact person(s) responsible for findings. Name and title: Evelyn Marvel, Financial Officer

FA 2022-001 Improve/Strengthen Controls over Expenditures Compliance Requirement: Activities Allowed or Unallowed Allowable Costs/Cost Principle Procurement and Suspension and Debarment Internal Control Impact: Significant Deficiency Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education Assistance Listing Number and Title: COVID-19 - 84.425D - Elementary and Secondary School Emergency Relief Fund COVID-19 - 84.425U - American Rescue Plan Elementary and Secondary School Emergency Relief Fund COVID-19 - 84.425W - American Rescue Plan Elementary and Secondary School Emergency Relief Fund - Homless Children and Youth Federal Award Number: S425D200012 (Year: 2020), S425U2120012 (Year: 2021) S425W210011 (Year: 2021) Questioner Costs: $30,180 Prior Year Finding: None Description: The polices and procedures of the School District were insufficient to provide and adequate internal controls over expenditures as it relates to the Elementary and Secondary School Emergency Relief Fund program. Corrective Action Plans: Revise Federal Programs Handbook to enhance internal controls in the area of contracts. Provide addendums to contracted services to provide for retention bonuses to contracted staff. Estimated Completion Date: June 30, 2023 Contact Person: Seth Taylor, Chief Financial Officer Telephone: 229-723-4337 Email: staylor@early.k12.ga.us

Views of Responsible Officials and Planned Corrective Actions: Executive leadership at Alight determined that the investigation uncovered an extensive breakdown in values and culture within the Alight Uganda program. At this time, Alight has taken the following actions: ? Immediate action was taken to terminate employment with all staff involved in the malfeasance. ? The Uganda leadership team is in the process of being rebuilt. An interim Country Director was appointed and vacancies recruited and hired. ? Fraud training was provided and attended by almost 60 staff across Alight including Ugandan staff. ? Alight?s anonymous global reporting portal was upgraded with communication and training provided to all Alight country programs. ? Alight?s executive leaders conducted policy, procedures and fraud notification training with the Uganda staff including how to report suspected incidence of fraud. ? Executive leaders and Uganda leaders are routinely traveling to field offices to review operations and provide staff the opportunity to report issues. Executive leadership at Alight believes these actions have re-established appropriate values, culture and processes within Uganda and reinforced their importance across Alight countries. Additional fraud training and reporting will be scheduled in fiscal year 2023.

U.S. Department of Health and Human Service Corona-Norco Family Young Men's Christian Association respectfully submits the following corrective action plan for the year ended June 30, 2022. Audit period: July 1, 2021 through June 30, 2022 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS?FINANCIAL STATEMENT AUDIT 2022 ? 001 ? Significant Deficiency ? Financial Statements Closing and Reporting Recommendation: We recommend improving the independent review of monthly financial statements, in particular to the area of collectability of receivable. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Our organization moved from one accounting system to another causing an error in entry/recording. Our organization has implemented the following: Monthly financial reviews including receivable oversight. Review is conducted by organization?s outsourced accountant, Finance Committee as a board function, Department Program Directors, back office administrative person and the YMCA Leadership staff team. Line items are reviewed, and variances are reported in written format each month. Additionally, all receivables are reported and collected within 90 days with a 30-60-90 day follow up plan. Name(s) of the contact person(s) responsible for corrective action: Audrie Echnoz, Chief Executive Officer. Planned completion date for corrective action plan: Beginning July 1, 2022 FINDINGS?FEDERAL AWARD PROGRAMS AUDITS U.S. Department of Health and Human Service 2022 ? 002 ? Cost Principles: Compensation ? Personal Services Federal Program Name: Child Care and Development Block Grant Child Care Mandatory and Matching Funds of the Child Care and Development Fund Assistance Listing Number: 93.575, 93.576 Recommendation: We recommend the entity implement procedures to ensure that documentation in place as in accordance with the OMB's Uniform Guidance. In situation that it was reporting error from a third-party provider, we recommend the entity implement alternative procedures to maintain sufficient documentation. View of Responsible Officials: There is no disagreement with the audit finding. Explanation of disagreement with audit finding: Our organization moved from written time sheets to a digital payroll platform. The training and staff implementation has included ongoing training with policies being rolled out and followed up with each month. Human resources has since reminded all staff of the requirement to approve their timesheets and all supervisors were reminded of this in recent staff meeting. This will be reviewed each payroll period and strong adherence will be followed with follow up action in place. Name(s) of the contact person(s) responsible for corrective action: Audrie Echnoz, Chief Executive Officer. Planned completion date for corrective action plan: Beginning July 1, 2022 If the U.S Department of Health and Human Services has questions regarding this plan, please call Audrie Echnoz, Chief Executive Officer at 951-479-4779.

Purpose: To document Pomona College's Corrective Action Plan relating to finding 2022-001 in its June 30, 2022 Single Audit report. Finding 2022-001 Allowable Costs Criteria: The 2022 OMB Compliance Supplement notes the excerpt below as one of the Allowable Cost criteria: c. Costs did not consist of improper payments, including (1) payments that should not have been made or that were made in incorrect amounts (including overpayments and underpayments) under statutory, contractual, administrative, or other legally applicable requirements; (2) payments that do not account for credit for applicable discounts; (3) duplicate payments; (4) payments that were made to an ineligible party or for an ineligible good or service; and (5) payments for goods or services not received (except for such payments where authorized by law). Statement of Condition: Management charged nonpayroll expenses that had not been incurred as of year-end to a federal grant. Stipends for an 8-week summer program relating to Grant 6117 (Pomona Research in Mathematics Experience), CFDA/ALN: 47.049, that ran from June 9, 2022 to August 6, 2022 were partially incurred by year-end (June 30, 2022), but charged entirely to the grant in FY22. Per the contract with the hired Research Assistants, stipends were to be made in two installments, whereby the second installment relates to the portion of expenditure incurred after year-end. The second installment was charged to the grant in FY22, before the Research Assistants completed their grant-related work. Corrective Action Planned: Finance staff are working with the Director of Sponsored Research to better align stipend payment schedules with our fiscal year-end. Appropriate schedules for the variety of grant- funded summer research will be communicated to the Primary Investigators and academic department staff. Accounts Payable staff will be instructed to reject any participant payment requests that are not in accordance with the approved schedules. Additionally, reviews of each grant payment will be performed at the time of the ?payment request and in July, as part of our year-end close process, to identify any grant expen?es that may have been charged to the incorrect fiscal year and reclassify them accordingly. Name of contact Person responsible for corrective action plan: Associate Treasurer and Controller Mary Lou Woods, and Director of Finance Victoria Roberts Anticipated Completion Date: April 2023

2022-030 Oregon Housing and Community Services Ensure controls over administrative expenditure limits are properly designed and sufficiently detailed to ensure compliance Federal Awarding Agency: U.S. Department of the Treasury Assistance Listing Number and Name: 21.023 Emergency Rental Assistance Program (COVID-19) Federal Award Numbers and Years: ERA 1, 2021; ERA 2, 2021 (COVID-19) Compliance Requirement: Allowable Costs/Cost Principles Type of Finding: Material Weakness Prior Year Finding: N/A Questioned Costs: N/A Criteria: 2 CFR 200.303(a), (c)-(d); 15 U.S.C. 9058a(c)(5)(A); 15 U.S.C. 9058c(d)(1)(C) Department management is responsible for establishing and maintaining effective internal control that provides reasonable assurance the department is managing, evaluating, and monitoring the federal award in compliance with the terms and conditions of the award and taking prompt action when instances of noncompliance are identified. Federal regulations limit the amount of federal funds that can be used for administrative expenditures. The department periodically prepared tracking spreadsheets during the fiscal year to monitor spending and ensure administrative expenditure limitations were not exceeded. We reviewed four randomly selected tracking spreadsheets and noted two tracking spreadsheets where there was insufficient detail to determine what category expenditures were associated with (administrative versus programmatic); and three tracking spreadsheets where there was no indication that the expenditures were within administrative expenditures limitations due to the periodic nature of the tracking. Without sufficiently designed and implemented controls, the department is at risk for exceeding their allowable administrative cost limits. We recommend department management ensure tracking spreadsheets are properly designed and sufficiently detailed to ensure compliance with administrative expenditures limitations. MANAGEMENT RESPONSE: We agree with this recommendation. This was a very fast-paced, complex award with multiple layers of funding. OHCS did have and continues to have a pulse on administrative costs from the various admin funding sources and has not exceeded those allowable limits. Reporting was routinely compiled to show the various allocations and expenditures to date, which included administrative costs. Reporting was not provided in a consistent manner as information from multiple systems was needed, however program and fiscal staff met regularly to review. OHCS is taking careful steps to design a system that will consistently track awards while ensuring spending is in alignment with requirements and is distributed in a timely fashion. In doing so we will create a more consistent framework for tracking new awards to ensure limits and expenditures are consistently documented. Anticipated Completion Date: December 31, 2023 Contact: Jill Smith, Director of Housing Stabilization Division or Beth Brown, Accounting Manager

2022-029 Oregon Housing and Community Services Ensure accessible documentation to evidence compliance with program requirements Federal Awarding Agency: U.S. Department of the Treasury Assistance Listing Number and Name: 21.023 Emergency Rental Assistance Program (COVID-19) Federal Award Numbers and Years: ERA 1, 2021 (COVID-19) Compliance Requirement: Activities Allowed or Unallowed; Allowable Costs/Cost Principles; Eligibility Type of Finding: Material Weakness Prior Year Finding: N/A Questioned Costs: N/A Criteria: 2 CFR 200.302(a); 2 CFR 200.332(a)(5) Department management is responsible for communicating to subrecipients that they are required to permit the department and auditors access to their records as necessary to ensure the department is compliant with program requirements. To ensure compliance with program requirements, subrecipient records must also be sufficiently detailed. The department passed through $140 million phase one program funds to community action agencies (subrecipients) to provide program delivery. The department performed limited fiscal monitoring during the audit period which included procedures to address compliance with activities allowed and allowable cost requirements for administrative costs. The department did not perform any program monitoring during the audit period which primarily addresses compliance with eligibility requirements. To determine whether the department complied with program requirements for the fiscal year, auditors attempted to reconcile detailed subrecipient ledgers with the intent of selecting and testing sample items at each individual subrecipient organization. We noted issues with two individual subrecipients, resulting in an inability to perform testing procedures over a total of $21,438,521 in program expenditures. For the first subrecipient we were able to reconcile their detailed ledgers to the department?s financial records, however their detailed ledger included pass-through payments to a third organization for program delivery. As a result of the combination of direct and pass-through payments, we were unable to obtain sufficiently detailed data that also reconciled to the department?s financial records to select individual transactions for testing. This subrecipient represents $19,877,962 of the unaudited expenditures. For the second subrecipient we were able to reconcile their detailed ledgers to the department?s financial records and select administrative and program transactions for testing. However, the subrecipient was unresponsive to documentation requests to substantiate expenditures. This subrecipient accounted for $1,560,559 of the unaudited expenditures. We recommend department management obtain and reconcile sufficiently detailed subrecipient ledgers and support to substantiate expenditures to allow for fiscal and program monitoring to ensure subrecipients are administering program funds in accordance with program requirements. MANAGEMENT RESPONSE: We agree with this recommendation. To effectively deliver much needed funds to maintain the housing stability of tens of thousands of Oregonians on the brink of experiencing homelessness during the pandemic, agency staff raced to stand up a first-of-its-kind ?single entry point? program for Oregonians to apply for assistance regardless of zip code. In our efforts to focus on speed we acknowledge that there was insufficient planning and capacity to stand up a large-scale emergency program including sufficient assurances our subrecipients could generate evidence of compliance with program requirements including transaction level details to assist with reconciliation. Oregon?s experience is in line with national findings. According to the January 2021 research brief conducted by the National Low Income Housing Coalition around key program challenges with administering emergency rental assistance programs. Survey respondents listed the two most common limitations to be staff capacity and the completeness of applications. Many agencies leaned on whatever local capacity was available to develop programs, review, and process applications, make payments and conduct outreach. Corrective action plan: OHCS had significant compliance monitoring staff turnover in FY22 leading to incomplete subrecipient monitoring reviews. OHCS completing these reviews would?ve ensured subrecipients had adequate time to produce necessary documentation to evaluate compliance, or if not, subrecipients would?ve been required to take corrective actions. For fiscal compliance, OHCS hired a contractor to perform fiscal monitoring of federal funded Grantees. OHCS also hired fiscal staff to pre-FY22 levels, fully trained them, conducted coordinated working sessions, and reached out to the CAA network for discussions on improving processes. OHCS continues to work with the contractor for much needed assistance in monitoring of back log while internal staff move forward to allow for all monitoring to be back on schedule and coordinating both fiscal and program compliance during future fiscal years. Program compliance employees have been hired and compliance efforts are underway. All providers will have internal compliance visits at regular intervals to ensure they have necessary documents and eligibility is being determined in compliance with program requirements. Additionally regular and ongoing check ins and trainings are being offered by program staff. Finally, program compliance teams are working with the Finance compliance team as well as a contracted expert to develop systems and processes in alignment with the Finance compliance team. As a result of program compliance efforts, a risk evaluation is being developed and incorporated into future contracting decisions. Efforts in hiring and systemic investments in infrastructure, processes, and procedures in addition to partner communications have taken place to ensure agency readiness in the event another emergency occurs. As part of our commitment to continual learning, our OHCS research team is collaborating closely with university and national partners to analyze our ERA program data and findings to see what themes emerge for improvement both nationally and in Oregon. Anticipated Completion Date: December 31, 2023 Contact: Jill Smith, Director of Housing Stabilization Division and Dean Criscola, Controller

2022-027 Oregon Housing and Community Services Ensure Monthly and Quarterly reports are accurate and adequately supported Federal Awarding Agency: U.S. Department of the Treasury Assistance Listing Number and Name: 21.023 Emergency Rental Assistance Program (COVID-19) Federal Award Numbers and Years: ERA 1, 2021; ERA 2, 2021 (COVID-19) Compliance Requirement: Reporting Type of Finding: Material Weakness; Material Noncompliance Prior Year Finding: N/A Questioned Costs: N/A Criteria: 2 CFR 200.302(a) and (b)(3); 2 CFR 200.303(a), (c)-(d) Department management is responsible for establishing and maintaining effective internal control that provides reasonable assurance the department is managing, evaluating, and monitoring the federal award in compliance with the terms and conditions of the award and taking prompt action when instances of noncompliance are identified. Additionally, the department is responsible for maintaining records to allow for submission of reports that are accurate and adequately supported. We tested four randomly selected monthly reports and found one report did not accurately report the number of unique households assisted and the amount of the assistance based on the supporting documentation. The department stated the differences were likely due to a transition in subsystem reporting formats and delays in report processing. We tested four quarterly reports, two of which were randomly selected and two of which were judgmentally selected. We found one report where the cumulative obligation amount did not agree to supporting documentation and were not accurate, and one report where the cumulative obligation and cumulative expenditures amounts did not agree to supporting documentation and were not accurate. The department stated these errors were due to erroneously entered information in the federal awarding agency?s reporting portal. Information included in these reports is used by the federal awarding agency to determine whether the department qualifies for receiving reallocation payments, as well as how much of a reallocation would be awarded to the department. Errors in these reports could result in errors in the federal awarding agency?s determination of eligibility for funding, and/or the reallocation formula. We recommend department management update and correct erroneous reports and establish controls to ensure reported amounts are accurate and adequately supported. MANAGEMENT RESPONSE: We agree with this recommendation. Numerous Community Action Agencies (CAAs), after months of exponential growth in program resources without time to strategize and scale operations, reported major capacity issues a chronic backup of applications at the local level. OHCS took the unprecedented step to augment CAA staff to contract with a third-party vendor to clear the backlog. This approach rapidly increased production and moved the federal program closer in line with the state?s then 60-day safe harbor period but came with additional monitoring and reporting challenges. OHCS did meet the reporting timelines and requirements of US Treasury. OHCS relied on information within the applicant tracking system that does have some discrepancies when compared to our accounting records. These discrepancies are due to various factors such as dates within the system causing application activity to be pulled into the reporting detail more than once, or the application tracking system not being updated with the most current payment record information by some grantees disbursing payments. These variances were overcome by relying on our accounting system and records as a control source of actual disbursements. During the audit, it was brought to our attention that the compilation of the application tracking system data at a point in time was not stored to demonstrate the reconciliation with the accounting information. SOS was then not able to verify the application tracking system data figures in one monthly reporting instance that were used to support the numbers reported to US Treasury as the file had likely been overridden. Similarly in one instance, the quarterly cumulative report was also impacted, however future cumulative figures were reported correctly. Corrective action plan: While OHCS submitted monthly and quarterly reports since program inception that include program and fiscal information, we acknowledge that there were some discrepancies between systems when one file was overridden with new information and one other file contained an error. We have taken steps to ensure data integrity and records retention moving forward and future compilations of the application tracking system data will be stored to support the point in time reconciliations and figures reported to US Treasury. One quarterly report will also be refiled if allowable by US Treasury to ensure quarterly figures reported are accurate. Data integrity is of the utmost importance to the agency, and we appreciate the thorough review by the auditing team. Anticipated Completion Date: June 30, 2023 Contact: Beth Brown, Accounting Manager

2022-025 Oregon Housing and Community Services Perform fiscal monitoring for subrecipients administrative expenditures to ensure compliance Federal Awarding Agency: U.S. Department of the Treasury Assistance Listing Number and Name: 21.023 Emergency Rental Assistance Program (COVID-19) Federal Award Numbers and Years: ERA 1, 2021 (COVID-19) Compliance Requirement: Activities Allowed or Unallowed; Allowable Costs/Cost Principles Type of Finding: Material Weakness; Material Noncompliance Prior Year Finding: N/A Questioned Costs: $121,463 (known) (COVID-19) Criteria: 2 CFR 200.332(a)(5) and (d) Department management is responsible for monitoring the activities of subrecipients to ensure subawards are used for authorized purposes and in compliance with federal requirements. Additionally, department management is responsible for communicating to subrecipients that they are required to permit the department and auditors access to their records as necessary to ensure the department is in compliance with program requirements. The department passed through program funds to community action agencies (subrecipients) to provide program delivery, including administrative costs. The department performed fiscal monitoring for only five of their 18 subrecipients during the audit period due to staff turnover. Fiscal monitoring includes procedures to address compliance with activities allowed and allowable cost requirements for administrative costs. Due to the limited fiscal monitoring performed, auditors performed additional procedures at the subrecipient level to determine whether the department was compliant with program requirements. We tested a total of 82 transactions, 70 randomly selected and 12 judgmentally selected from the 13 subrecipients that did not receive subrecipient monitoring during the fiscal year. We noted the following: One subrecipient did not respond to audit requests for documentation, resulting in an inability to test four transactions totaling $4,114. One subrecipient did not provide sufficiently detailed documentation to determine whether 7 transactions were for accurate amounts totaling $117,349. Of those seven transactions, we were unable to determine whether two transactions were for allowable activities or appropriately categorized as administrative expenditures. Without adequate monitoring of subrecipients, the department?s ability to ensure compliance with program requirements is diminished. We recommend department management perform fiscal monitoring to ensure subrecipients are expending administrative funds in accordance with program requirements. MANAGEMENT RESPONSE: We agree with this recommendation. Corrective action plan: OHCS had significant compliance monitoring staff turnover in FY22 which led to a lack of monitoring. OHCS has subsequently hired a contractor to perform fiscal monitoring of all ESG funded grantees. OHCS also hired staff to pre-FY22 levels, fully trained all staff and began developing internal working relationships with program staff to assure operational efficiencies. This includes an annual workshop with all grantees, internal training, and standardizations of monitoring processes. Anticipated Completion Date: June 30, 2023 Contact: Dean Criscola, Controller

2022-064 Oregon Department of Transportation Management should ensure timely review of transfers is documented Federal Awarding Agency: U.S. Department of Transportation Assistance Listing Number and Name: 20.205 Highway Planning and Construction Federal Award Numbers and Years: Various Compliance Requirement: Activities Allowed or Unallowed; Allowable Costs/Cost Principles Type of Finding: Significant Deficiency Prior Year Finding: N/A Questioned Costs: N/A Criteria: 2 CFR 200.303; GAO-17-704G ?10.03, 12.05; ODOT FASM 3.7 The department is responsible for establishing and maintaining internal controls to ensure entries posted in the accounting records are for costs and activities allowable under the federal program. Journal entry review and approval should be clearly documented and readily available for examination. The department has established Financial Administration Standard 3.7, Expenditure Journal Entries, which requires management to transmit signed hard copy supporting documentation of journal entries to financial services after they?ve been reviewed and approved. We tested 40 transfer journal entries moving costs between federal project sub jobs and found that 19 did not have documentation of timely approval. In two cases, approval was documented more than a year after costs were transferred. The 19 entries were all lump sum transfers processed by Program and Funding Services (P&FS). P&FS is authorized to process transfers, moving costs between sub jobs of the same project. These transfers are necessary to align project costs with the appropriate funding source. Per P&FS management, transfers are generally reviewed within a few days. However, documentation of the review has not been occurring until much later due to challenges associated with remote work and policies requiring hard copy documentation. Over $90 million in program costs were transferred between sub jobs in this manner during fiscal year 2022. Without timely review and documentation available to support transfers, unallowable costs or activities could be transferred and billed erroneously to the Federal government. We recommend management ensure procedures for review of transfer journal entries result in timely documented approvals. MANAGEMENT RESPONSE: We agree with this recommendation. Until electronic signatures are implemented, a Federal Aid Funding staff member will be required to print the hard copies, in the office at least monthly; as well as a member of the Statewide Investments Section management team will need to be present to sign the hard copies. Anticipated Completion Date: May 4, 2023 Contact: Katie Parlette, Federal Aid Funding Manager

2022-062 Higher Education Coordinating Commission Improve controls over payroll Federal Awarding Agency: U.S. Department of Labor Assistance Listing Number and Name: 17.258 WIOA Adult Program 17.259 WIOA Youth Activities 17.278 WIOA Dislocated Workers Formula Grant Federal Award Numbers and Years: AA33251LN0; 2019, AA33251L70; 2019, AA33251L90; 2019, AA33251R70; 2019, AA33251R90; 2019, AA34789VS0; 2020, AA34789V90; 2020, AA34789VQ0; 2020, AA347893L0; 2020, AA347895P0; 2020, AA36341E10; 2021, AA36341D90; 2021, AA36341DQ0; 2021, AA36341KY0; 2021,AA36341LA0; 2021 Compliance Requirement: Allowable Costs/Cost Principles Type of Finding: Significant Deficiency Prior Year Finding: N/A Questioned Costs: N/A Criteria: 2 CFR 200.303 Federal regulations require recipients of federal awards to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. The department has implemented the following procedures to ensure payroll costs are correctly charged to the program. Managers approve monthly timesheets submitted by the employees in the state?s payroll system. When managers do not approve by a specified date, the payroll system will automatically approve the timesheet, shown with the words ?system approved.? Additionally, each employee should have a signed position description, which details the duties of the position and the amount of time to be charged for the duties. We selected a nonstatistical random sample of 20 employee timesheets related to 12 employees to ensure payroll was appropriately charged to the program. Additionally, we selected one employee who was on job rotation with the agency from January 2022 through June 2022. We verified payroll timesheets were reviewed by a manager and signed position descriptions were retained per state guidelines, and identified the following exceptions: Two timesheets for one employee did not have evidence of manager approval and 2 timesheets for two employees were reviewed over three months later. For all 12 employees, the position descriptions provided were unsigned or signed upon our request. We did not question these costs as department management verified job duties were appropriate to the program. For the employee on job rotation, 4 of the 6 timesheets were not reviewed and a signed position description was not signed by the employee. According to department management, timesheets were not always approved by the manager as the system will automatically lock and approve the timesheet. For position descriptions, supervisor did not always follow through on obtaining signed position descriptions and for longer term employees a number of boxes could not be located when the agency moved. There is a risk that employees could be improperly charging to the federal program. We recommend department management ensure timesheets are timely reviewed and positions descriptions are completed and retained. MANAGEMENT RESPONSE: We agree with this recommendation. To improve controls over payroll, the HECC and the State of Oregon switched its payroll system from the old Legacy Oregon State Payroll Application (OSPA ? Epay) to the new Workday Payroll as of December 1, 2022. The HECC has since created reminder emails to all Management Staff to submit their respective employees? timesheets in a timely manner. In addition, the new Workday Payroll does not have a feature that automatically locks an employee?s timesheet and auto-approves a timesheet. Each Manager must now manually approve a timesheet for any employee that enters specific time codes for particular grants or use of funds. To address the finding regarding unsigned position descriptions (PDs), the HECC has since ensured that all of the identified PDs have been signed. HECC?s Human Resources Unit (HR) has created a new process going forward requiring all managers to sign the PD at the time of the offer letter and HECC HR to collect the signature from the employee on their first day when HR meets with them. HECC HR also has reviewed all of its existing employees? position description in this process to ensure all positions descriptions are signed. Anticipated Completion Date: August 31, 2023 Contact: Christopher Bui, Budget and Fiscal Manager

2022-018 Oregon Housing and Community Services Controls are needed to ensure program expenditures are allowable Federal Awarding Agency: U.S. Department of Housing and Urban Development Assistance Listing Number and Name: 14.231 Emergency Solutions Grants Program (COVID-19) Federal Award Numbers and Years: E-20-DW-41-0001, 2020 (COVID-19) Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Type of Finding: Material Weakness; Material Noncompliance Prior Year Finding: N/A Questioned Costs: $245,362 (known) (COVID-19) Criteria: 24 CFR 576.100; CPD-21-08 III.E.3 Emergency Solutions Grants-Cares Act (ESG-CV) funds may be used for the five regular Emergency Solutions Grants (ESG) program components, as well as administrative activities: street outreach, emergency shelter, homelessness prevention, rapid re-housing, and homeless management information systems (HMIS). They may also be used for additional activities including, but not limited to, temporary emergency shelter, hazard pay, handwashing stations, cell phones and internet, personal protective equipment, and laundry. The funds are disbursed to the subrecipients after reimbursement requests are submitted. Federal funds totaling $31,894,565 were distributed to 44 subrecipients during fiscal year 2022. We randomly selected 61 individual distributions made by the department to subrecipients. Subsequently, we randomly selected an expenditure from each disbursement request and then judgmentally selected additional expenditures from select disbursements. While gaining an understanding of the department?s internal control process, we learned the review process for subrecipient disbursement requests did not include a detailed verification that underlying expenditures were for allowable activities and costs. Given the department?s incomplete review process, we were unable to verify compliance by testing those reviews. The department requested supporting documentation from the subrecipients, documentation that should have been reviewed and retained by the department, for the required audit procedures to be performed. Our audit procedures were performed in three stages. First, we randomly selected 61 individual distributions made by the department to subrecipients, totaling $5,580,560. These disbursements generally consisted of reimbursement for multiple expenditures made by a subrecipient. Next, we asked the department to request a listing of expenditures from the subrecipients related to those disbursements. Finally, if provided, we agreed the listings to the disbursement and randomly and judgmentally selected individual expenditures from the listings for testing. We were unable to perform any review of 20 disbursements either because we did not receive a listing of the subrecipient?s expenditures, or the listing did not agree to the disbursement selected for testing. These disbursements related to 10 of the 44 subrecipients receiving funds in fiscal year 2022 and $1,475,345 of the $5,580,560 in disbursements selected for testing noted above. From the expenditure listings we did receive, we randomly and judgmentally selected individual expenditures to determine whether the supporting documentation agreed to the amount requested for reimbursement by the subrecipient. Of those 41 individual transactions selected for testing, there was inadequate or no supporting documentation provided for 29 items, and one instance where the request exceeded the support. These exceptions resulted in total questioned costs of $245,362. If requests for funds are not supported by documented expenditures, the department could be unknowingly reimbursing subrecipients for unallowable costs and activities. We recommend management implement internal controls to ensure subrecipient reimbursements are for allowable expendiures. MANAGEMENT RESPONSE: We agree with this recommendation. OHCS had significant staff turnover in FY22, and that coupled with the substantively increased number of subrecipients, lead to a lack of monitoring. OHCS has subsequently hired staff and established vendor relationships to perform fiscal monitoring as a backup for when staff vacancies exist. Additionally, OHCS is on track to complete fiscal and program monitoring for all subrecipients of ESG funds in FY23. Anticipated Completion Date: June 30, 2023 Contact: Dean Criscola, Controller

Finding Number: 2022-005 Finding Title: Allowable Costs/Cost Principles and Reporting Program: Medical Assistance Program 93.778 Name of Contact Person Responsible for Corrective Action: Nicole Hegge - Sr. Manager, Accounting - Finance and Central Services Corrective Action Planned: In order to appropriately report the revenue offset that may impact federal programs, we have updated our quarterly process ensuring that any federal revenue offsets are included in the appropriate fund and report. In some instances, this may still require the County to file amendments to federal reports; however, they will be completed no later than eight weeks following the end of the quarter. Anticipated Completion Date: December 31, 2023

1. Correcting Plan CHEDA staff are aware of allowable cost proper documentations, and will implement an internal control process. 2. Explanation of Disagreement with the Audit Finding There is essentially no disagreement with the finding. 3. Official Responsible for Ensuring CAP Karie Kirschbaum ? Executive Director 4. Planned Completion Date for CAP Immediately. 5. Plan to Monitor Completion of CAP The Executive Director will monitor completion of the CAP.

Finding #2022-004 ? Services billed that were not identified in the student?s IEP. Medical Assistance Program (Medicaid; Title XIX) (93.778) Federal Grantor ? U.S. Department of Health and Human Services Pass-through Entity ? Wisconsin Department of Health Services Condition: Covered school based services billed to Medicaid must be identified within the child?s IEP. A child?s billing sampled during the audit included nursing and transportation services. These services were not listed in the child?s IEP. Questioned costs: $654.12 Criteria: Students with covered services billed to Medicaid must have the services listed within the child?s IEP. Effect: Potentially unallowable billings arise when services are not included within the IEP of students. Cause: Nursing and transportation services were omitted from the child?s IEP, yet were billed to Medicaid. The District did not review the child?s IEP against services billed to ensure compliance. Recommendation: The District should only bill Medicaid for covered services included in IEP. The IEP should be reviewed prior to services being provided and billed to Medicaid. Also, the District should be reviewing the files on a regular basis to ensure compliance with this requirement. Response: We will review the District?s requirements and procedures for billing Medicaid and make any necessary changes to ensure completeness and accuracy. Contact Person: Tracy Case Anticipated Completion: December 31, 2023