Corrective Action Plans

We concur with this finding. Management recognizes the importance of complying with federal grant reporting guidelines. Going forward, the federal grant reporting policy and procedures will be reviewed and amended to ensure that reports and documentation for regulatory agencies are provided in a clear, accurate and easily understood manner. Additionally, all related NHS personnel will be educated on the policy and procedures.

The discrepancies in payroll reporting were identified by Youthprise during 2023. Management discovered that reports downloaded from the third-party processor were not accurately coding salary based on timecard reports submitted by some of its employees. Youthprise is working with its Human Resources consultant, who is working with the 3rd party payroll processor, to correct the reporting issues going forward. Youthprise will review its internal controls going forward to ensure sufficient oversight is maintained over its payroll processes to prevent or detect and correct misstatements on a timely basis.

As of January 1, 2023, LEAP, Inc. is no longer operating the Head Start and Early Head Start Programs. Therefore the auditee did not submit a corrective action plan.

Sacred Heart University Corrective Action Plan Year ended June 30, 2022 Finding 2022-001: Significant Deficiency and Noncompliance: Special Tests and Provisions ? Enrollment Reporting Corrective Action Planned Sacred Heart University has implemented a corrective action plan which involved collaboration with our enterprise resource provider, Ellucian, the Registrar?s Office, and the Department of Information Technology (IT). Sacred Heart University acknowledges that published program lengths reported on National Student Loan Data System (NSLDS) records did not conform with reporting requirements. The University?s ERP, Ellucian, provided instruction on updating the code for programs with ?years to complete,? which enabled the IT department to identify and correct existing active programs. To prevent future errors the Registrar?s Office can access the mnemonic (screen) to code new program records in ?years to complete.? Sacred Heart University processed and submitted the first two branches, 00 and 81, on 3/24/23, and Clearinghouse took steps to update the records. Sacred Heart University acknowledges incorrectly reporting the Graduated status effective date as the last day of classes instead of the last day of final exams at the NSLDS program level for two students sampled during our FY22 Federal Single audit. The University has amended its procedures to avoid potential errors causing nonconformities. The updated procedures will ensure the utilization of the last day of final exams as the Graduated status effective date at the program level and strengthen the review of the graduate file before submitting it to the Clearinghouse. Sacred Heart University acknowledges incorrectly reporting the student program begin date for one student sampled during our FY22 Federal Single audit. The University reported the student in the incorrect branch, discovered the error upon graduation, and moved the student to the correct branch. As a result of the branch correction, the University reported to the NSLDS the start date of the student?s last trimester instead of the actual program start date. The Registrar?s office, working with the Clearinghouse, is taking steps to correct the branch reporting which will fix the reported program start date for this particular student. The University is amending its procedures to prevent further noncompliance. The Registrar?s office is amending the report used to ensure students are selected and reported in the correct branches. The Registrar is also enhancing the report to include data identifying potential erroneous reporting before enrollment data is reported to the Clearinghouse. Contact Person(s) Responsible for Corrective Action Angela Pitcher, University Registrar Lori Jo McEwan, Senior Systems Analyst Anticipated Completion Date April 25, 2023

Finding 2022-001 Condition During the testing of expenditures related to increased nurse agency costs and benefits allocation calculations, we observed that for 2 of the 2 calculations tested did not contain a review and approval prior to submission to detect potential errors in the calculations. Corrective Action Plan Corrective Action Planned: Beginning with PRF reporting period 4 reporting the Organization will begin formally documenting the review of all calculations as part of the submission review process. CFO and Executive Director of Finance will both review all calculations and submissions. Name(s) of Contact Person(s) Responsible for Corrective Action: Thomas Baer, CFO and Mike Pfleegor, Executive Director of Finance Anticipated Completion Date: 3/31/2023

COMMONWEALTH OF PUERTO RICO MUNICIPALITY OF CATA?O Corrective Action Plan For the Fiscal Year Ended June 30, 2022 ______________________________________________________________________________________________________________________ Audit Report: Reports on Compliance and Internal Control in Accordance with Government Auditing Standards and OMB Super Circular Uniform Guidance Audit Period: July 1, 2021 ? June 30, 2022 Fiscal Year: 2021-2022 Principal Executive: Hon. Julio Alicea Vasallo, Mayor Contact Person: Mrs. Maria Perez, Finance Director Phone: (787) 788-0404 Original Finding Number: 2022-002 Statement of Concurrence or Nonconcurrence: We concur with the finding. Corrective Action: We concur with the finding. The Municipality has taken corrective measures for faithful compliance with the established reporting dates. Compliance oversight will be strengthened for this program or any other required funds. Implementation Date: Fiscal year 2022-2023 Responsible Person: Mrs. Maria Perez - Finance Department Director

COMMONWEALTH OF PUERTO RICO MUNICIPALITY OF CATA?O Corrective Action Plan For the Fiscal Year Ended June 30, 2022 ______________________________________________________________________________________________________________________ Audit Report: Reports on Compliance and Internal Control in Accordance with Government Auditing Standards and OMB Super Circular Uniform Guidance Audit Period: July 1, 2021 ? June 30, 2022 Fiscal Year: 2021-2022 Principal Executive: Hon. Julio Alicea Vasallo, Mayor Contact Person: Mrs. Maria Perez, Finance Director Phone: (787) 788-0404 Original Finding Number: 2022-003 Statement of Concurrence or Nonconcurrence: We concur with the finding. Corrective Action: We concur with the finding. The Municipality has taken corrective measures for faithful compliance with the established reporting dates. Training and supervision of compliance personnel for this program or any other required funds will be reinforced. Implementation Date: Fiscal year 2022-2023 Responsible Person: Mrs. Maria Perez - Finance Department Director

COVID-19 Provider Relief Fund ? Assistance Listing No. 93.498 Recommendation: The Organization should review all expense amounts entered into the reporting portal submission to ensure the amounts are accurate and agree to internal supporting documentation. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management has implemented a process that should ensure all future reports are accurate and reviewed prior to submission. This includes a review and verification of expenses that are being reported to ensure they are accurately entered and supported by internal records. Further, management has identified additional infection control related costs which were not claimed during the reporting periods submitted. These costs have been isolated to ensure they are not available for use in future periods. Name of the contact person responsible for corrective action: Mark Sperka, CEO Planned completion date for corrective action plan: March 2023

COVID-19 Provider Relief Fund ? Assistance Listing No. 93.498 Recommendation: The Organization should review all reports prior to submission to ensure they are complete and accurate, and that the information is supported by detailed schedules of all expenses and internal financial statements for lost revenues. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management has implemented a process that should ensure all future reports are accurate and reviewed prior to submission. This includes a review of all lost revenue information and verification of expenses that are being reported. Name of the contact person responsible for corrective action: Mark Sperka, CEO Planned completion date for corrective action plan: March 2023

Finding 2022-012 Personnel Responsible for Corrective Action: Assistant Comptroller - Brian Huggins Anticipated Completion Date: July 2022 Corrective Action Plan: The University has implemented a process to document all allowable costs prior to funds being draw down that will be prepared by a Senior Accountant, reviewed by the Assistant Comptroller and Comptroller for 2nd review, and sent to the CFO for final review and approval prior to requesting reimbursement/cash drawdowns from the Federal Government. Moreover, the University is implement a quarterly grant review process with the grant Principal Investigator to review grant expense allocations. G5 drawdowns will take the second Monday of each month.

Finding 2022-008 Personnel Responsible for Corrective Action: Assistant Comptroller ? Brian Huggins Anticipated Completion Date: July 2022 Corrective Action Plan: The University will document lost revenue in comparison to the Board of Regents approved budget. The calculation will be prepared by the Assistant Comptroller, reviewed by the Comptroller as the 2nd reviewer, and approved by the Chief Financial Officer, as the 3rd and final review for charges being allocated to the grant.

Finding 2022-007 Personnel Responsible for Corrective Action: Assistant Comptroller ? Brian Huggins Anticipated Completion Date: June 2023 Corrective Action Plan: The University's current process is to collect and retain procurement documents for no less than five years. The institution will work to strengthen the current process in place relevant to securing adequate documentation. Supporting documentation was provided for data selection relating to the upgrades to the HVAC, ventilation, and the spacing of the academic facilities which were all completed in accordance with Covid guidelines. The University is working with our third-party payroll provider to automate time and effort reporting.. We are currently using paper forms for reporting until we can implement Time & Effort through ADP. The Director of Title III & Finance Compliance officer to further discuss time and effort.

Finding 2022-004 Personnel Responsible for Corrective Action: Assistant Comptroller ? Brian Huggins Anticipated Completion Date: July 2022 Corrective Action Plan: The University has implemented a process to document all allowable costs prior to funds being draw down that will be prepared by a Senior Accountant, reviewed by the Assistant Comptroller and approved by the Comptroller prior to requesting reimbursement/cash drawdowns from the Federal Government. Moreover, the University is implement a quarterly grant review process with the grant Principal Investigator to review grant expense allocations. G5 drawdowns will take the second Monday of each month.

Finding 2022-003 Personnel Responsible for Corrective Action: Director of Title III and Compliance ? Dr. Neidra Butler Anticipated Completion Date: July 2022 Corrective Action Plan: The University is working with our third-party payroll provider to automate time and effort reporting.. We are currently using paper forms for reporting until we can implement Time & Effort through ADP. The Director of Title III & Finance Compliance officer to further discuss time and effort.

Corrective Action Plan: In September 2022, DSHA implemented new processes for preparing and submitting ERA reports to U.S. Treasury. A third party technical assistance provider now has access to the UST Reporting portal, and coordinates with DSHA program staff to collect data to prepare report submissions. After reporting fields have been populated in the UST Portal, the DSHA Director of Policy & Planning reviews, certifies, and submits reports to UST. DSHA is coordinating with this technical assistance provider to ensure that a record of reporting information is retained after reports are submitted. Responsible Official: Devon Manning, Director of Policy & Planning and Brian Rossello, Director of Housing Finance Completion Date: September 2022

Federal Awards Finding 2022-006 - Emergency Rental Assistance Eligibility Corrective Action Plan: Please see responses to 2022-002, 2022-004, and 2022-005. Responsible Official: Devon Manning, Director of Policy & Planning and Brian Rossello, Director of Housing Finance Completion Date: August 2021 Financial Statement Finding 2022-002 - Internal Control Over Compliance - United States Emergency Rental Assistance Program Corrective Action Plan: DSHA has implemented a Corrective Action Plan which it believes fully addresses the internal control weaknesses identified in connection with the audit finding of a material weakness related to DSHA?s operation of the Emergency Rental Assistance (?ERA?) program. The Corrective Action Plan is comprised of three key elements: 1. Implementation of a new software system that fully addresses certain process issues encountered with its existing software application. 2. Implementation of new process workflows and approvals performed by DSHA personnel to ensure proper approval of case applications and payment of approved applications to proper vendors. 3. Engaging an external consultant to analyze, verify and remediate, as required, applications processed in the predecessor software system. Each of these three elements is further discussed below. In August 2021, DSHA implemented a new software application to accept and process applications for the ERA program and replace its existing application. DSHA implemented this system as a means to correct and resolve the issues it was experiencing with respect to timely and accurate payment processing. The new system included significant improvements in workflow related to payment processing and account verification, as well as other needed program features. With the new software application, one of the root causes of DSHA?s application payment issues was immediately addressed, by eliminating the need to manually upload vendor payment information from its predecessor application to DSHA?s accounting system for payment. The prior manual upload process resulted in various vendor payment issues and erroneous payments. The new software application is a completely self-contained application, with workflow approvals that span from application submittal and approval to vendor payment. Each week all approved applications are automatically batched and sent to DSHA for approval prior to payment. This workflow has resolved previous issues where payments were not made timely for approved applications. The new software application incorporates significant improvements to payment processing and account verification. As mentioned above, there is no need to transfer or upload data between new software application and the accounting system to effect payments of approved applications. The new software application includes a verification process whereby the vendor ACH information is verified by a ?penny test? or small deposit that the user must verify. ACH payments can only be made to accounts that are verified. Once payments are made through new software application, batch details are imported to the accounting software via a custom interface for accounting system transaction reporting. Implementation of New Process Workflows, Approvals and Verifications by DSHA Coupled with the new software application implementation, DSHA implemented updated ERA Program Guidelines and new internal policy and process manuals to ensure its internal controls and processes appropriately addressed the compliance requirements of the ERA program and to ensure properly approved applications are paid to proper vendors. All cases in Approved Status are batched each week by the new software application and sent to DSHA for approval. DSHA reviews each of the approved applications within the batch and approves the batch once verified. At that point, requested funds are wired and payments issued by the new software application. This process has resolved previous instances of non-payment of approved cases. DSHA has developed new Case Auditor and Case Supervisor Process Guides and Checklists, which now standardize the processes used to review, verify and approve applications prior to payment. The new software application case management workflow requires separate Case Auditor and Case Supervisor verification of program requirements and payments prior to approval and payment of an application. Remediation of Prior Case Applications Processed in the predecessor application DSHA has engaged a third-party external consultant to assist it in ensuring that the applications processed in the predecessor application system resulted in payments to appropriate vendors for proper, compliant applications. The objective of this assessment is to identify any applications processed within predecessor application that resulted in either over or under payment to the vendor recipient. Once identified, these over and/or under payments will be remediated. These action plans have been implemented beginning August 2021 for the 2022 Fiscal Year and will remain in effect going forward. Responsible Official: Marlena Gibson, Director of Policy and Planning. Responsible Official: Marlena Gibson, Director of Policy and Planning. Financial Statement Finding 2022-004 ? Internal Control Over Compliance ? United States Emergency Rental Assistance Program Corrective Action Plan: DSHA will take these recommendations under advisement, and review program policies and procedures to ensure they are in accordance with statutory requirements. DSHA will ensure that staff responsible for processing DEHAP applications are training effectively in how to interpret and apply program policies and procedures, and will clearly communicate the expectation that review staff adhere to program policies and procedures consistently. DSHA would like to request clarification on Belfint's interpretation of the statutory requirement around security deposits. To our knowledge, UST has suggested applying a limit of one month's rent as guidance, but has not made this an actual requirement of the federal Emergency Rental Assistance Program. Responsible Official: Marlena Gibson, Director of Policy and Planning.

Corrective Action Plan: DSHA introduced ERA funding to support DEHAP in March 2021 using an application software program. This software accommodated application processing activity, but did not have the capability to issue assistance payments. To issue assistance payments, DSHA was required to manually transfer application information from application processing service into an established payment processing platform; this created opportunity for data entry errors. In August 2021, DSHA transitioned DEHAP to a new application processing software platform. This new platform can accommodate both application processing and payment processing, eliminating the opportunity for data entry errors in the transfer of information from one program process to the next. Responsible Official: Devon Manning, Director of Policy & Planning and Brian Rossello, Director of Housing Finance Completion Date: August 2021

FINDING 2022-001 (Auditor Assigned Reference Number) Contact Person Responsible for Corrective Action: Weston Reed Contact Phone Number: 765-456-7455 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: 1. Starting with the 2023 June quarter-end P&E report which is due in July 31, 2023 City will have another employee review and sign off on the report prior to final submission on line. Anticipated Completion Date: July 31, 2023

Finding 2022-003 Department of Education Education Stabilization Fund - Higher Education Emergency Relief Fund - Student Portion Federal Financial Assistance Listing #84.425E P425E200919- 20B Activities Allowed or Unallowed and Allowable Costs/Cost Principles Finding Summary: Eide Bailly LLP found that the University over-awarded Higher Education Emergency Relief Fund (HEERF) funding to one student based on its determination over eligibility of the student portion of HEERF funding, which is awarded based on (1) expected family contribution and (2) enrollment status. The student was awarded based on fulltime enrollment; however, the student's enrollment status was part-time. Responsible Individuals: Michael Van Surksum, Vice President for Business and Finance; Elizabeth Porteous, Accountant; Karrie Morgan, Director of Financial Aid; Anna Heckenliable, Registrar Corrective Action Plan: Responsible Individuals above will review credit hour reports pulled from the system for accuracy to ensure no hours are duplicated. Anticipated Completion Date: Management expects this finding to be resolved by January 31, 2023.

Management response/corrective action: We will provide training to grant funded employees and their supervisors on proper time keeping and federal grant recordkeeping requirements.

ANTHONY HOUSING AUTHORITY PHONE: 915-886-4650 ?FAX:915-886-2296 1007 FRANKLIN ANTHONY, TEXAS 79821 HOUSING AUTHORITY OF ANTHONY, TEXAS CORRECTIVE ACTION PLAN YEAR ENDED SEPTEMBER 30, 2022 Corrective Action Plan Finding: 2022-001-Significantly large interfund account needs to be reduced Condition: At September 30, 2022, the Low Rent Program owes the Housing Choice Voucher Program $165,833. Corrective Action Planned: The entire balance was paid off subsequent to year-end. Person responsible for corrective action: Mary Grace Saenz, Executive Director Telephone: (915) 886-4650 Housing Authority of the Town of Anthony, Texas Fax: (915) 886-2296 1007 Franklin Anthony, TX 79821 Anticipated Completion Date: Already completed

CORRECTIVE ACTION PLAN (CAP): 1. Explanation of Disagreement with Audit Finding There is no disagreement with the audit finding. 2. Actions Planned in Response to Finding High School for Recording Arts agrees with the finding and will improve internal controls over allowable cost and allowable activities compliance requirements to ensure only allowable costs and activities are charged to federal programs. 3. Official Responsible for Ensuring CAP The Executive Director and Director of Operations are responsible for ensuring corrective action of the deficiency. 4. Planned Completion Date for CAP The planned completion date for the CAP is June 30, 2023. 5. Plan to Monitor Completion of CAP The School Board Chair will be monitoring this CAP.

Finding #2022-001 ? Significant Deficiency Applicable federal program: U. S. Department of Justice Assistance Listing #16.575 Passed through Office of the Governor, Criminal Justice Division Crime Victim Assistance Contract #?s: 3521203; 4219601; 4219602 Contract years: 10/01/21 ? 09/30/22; 10/01/21 ? 09/30/22; 10/01/22 ? 09/30/23 Recommendation: Emphasize adherence to established policies and procedures to ensure payroll, including allocations methodology, are properly followed and reviewed. Planned corrective action: During 2022, HAWC established clear roles and responsibilities regarding the review of the payroll allocations by the Grant Manager to ensure that they are properly calculated and charged to the appropriate grants. The findings above related to the payroll allocations related to pay periods prior to the implementation of the new roles and responsibilities. HAWC has confirmed that the payroll allocations were reviewed by the Grant Manager for all subsequent pay periods. Responsible officer: Chief Financial Officer Estimated completion date: June 2022

2022-002 Activities Allowed or Unallowed, Allowable Costs/Cost Principles Medical Assistance Program ? CFDA No. 93.778 ? Award Period: July 1, 2021 through June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance Response: Adult Care Management, Inc. (ACMI) agrees with the finding of Taylor Roth & Company, PLLC, in the fiscal year 2022 Single Audit (SEFA) that the established internal controls over payroll cost allocation did not operate as intended to ensure appropriate allocation of payroll costs across all programs in the five (5) of the twenty-four sampled payroll periods for one (1) individual. Action: Effective March 10, 2023, the internal control practices of ACMI will be strengthened to support a review system able to prevent and/or detect and correct errors in a timely manner to ensure payroll costs are accurate, allowable, and properly allocated. Specifically, management?s monthly review of all cost allocations will include a review of the data entry hours from payroll timesheets into the payroll allocation spreadsheet of no less than 10% of total reporting employees, with a priority focus on employees reporting time to more than one program / cost center.

2022-001 Internal Controls over Payroll Cost Allocation Type of Finding: Significant Deficiency in Internal Control over Financial Reporting Response: Adult Care Management, Inc. (ACMI) agrees with the finding of Taylor Roth & Company, PLLC, in the fiscal year 2022 Single Audit (SEFA) that the established internal controls over payroll cost allocation did not operate as intended to ensure appropriate allocation of payroll costs across all programs in the five (5) of the twenty-four sampled payroll periods for one (1) individual. Action: Effective March 10, 2023, the internal control practices of ACMI will be strengthened to support a review system able to prevent and/or detect and correct errors in a timely manner to ensure payroll costs are accurate, allowable, and properly allocated. Specifically, management?s monthly review of all cost allocations will include a review of the data entry hours from payroll timesheets into the payroll allocation spreadsheet of no less than 10% of total reporting employees, with a priority focus on employees reporting time to more than one program / cost center.