Corrective Action Plans

2022-030 Strengthen Controls over the Summary Schedule of Prior Audit Findings Federal Agency: U.S. Department of Labor State Entity: Department of Labor (GDOL) Corrective Action Plans: As Georgia progressed towards addressing and pursuing efforts to resolve outstanding Coronavirus Aid, Relief, and Economic Security Act (CARES Act) matters, impediments such as limited workforce and system restrictions hindered progress. Such factors, imposed upon the intents to make system changes, corrections and enhancements. We have taken the following corrective actions in an ongoing effort to bring these findings to full resolution: 2020- 036 Improve Controls Over Eligibility Determinations In addition to steadily reviewing and determining eligibility of responses providing proof of Pandemic Unemployment Assistance (PUA) employment and wages, a task force has been established to assist with this effort. An ongoing campaign is in progress to onboard additional resources to increase the cadence of addressing these items. Claimants who fail to provide adequate proof are manually reconsidered and overpayments established appropriately. Since this process is manually reviewed by staff rather than by system automation, we anticipate this effort will take approximately 60 weeks to complete. When there are indications of potential fraud, additional investigation is pursued to determine if fraud penalties should be imposed. 2021-036 ? Improve Controls over Employer-Filed Claims Effective December 6, 2021, the Employer-Filed Claims (EFC) process was revised to require individuals (employees) to complete an EFC profile to include a real-time identity verification before payments can be made. Employers are responsible for submitting the request for the payment to certify to the individual?s employment status but the individuals must certify their identity and personal information for the claim to be processed. Employees are notified when a claim is filed on their behalf and provided instructions for their portion of completing the EFC process. The MyUI dashboard provides all the EFC correspondence sent to the individual as well as a status of the profile set up and identify verification. Summary We are currently seeking funding to modernize our UI benefits system which will incorporate and improve the controls cited. GDOL will develop and implement procedures to ensure the status of each prior audit finding is reported in an accurate manner. GDOL will ensure staff responsible for submitting the status of prior period audit findings are trained and understand their responsibilities associated with the Summary Schedule of Prior Audit Findings under the Uniform Guidance. Estimated Completion Date: December 6, 2021 Contact Person: Racquel Robinson, Unemployment Policy and Procedures Chief Telephone: 404-232-3190; E-mail: Racquel.Robinson@gdol.ga.gov

2022-029 Improve Controls over the Identification, Recording, and Reporting of Overpayments Federal Agency: U.S. Department of Labor State Entity: Department of Labor (GDOL) Corrective Action Plans: The Georgia Department of Labor did not maintain adequate controls over the identification, recording, and reporting of benefit overpayments associated with the Unemployment Insurance programs. GDOL Response: The Georgia Department of Labor disagrees with this finding. USDOL provides guidance and recommended procedures for crossmatches but does not dictate a frequency or cadence for performing them. The crossmatch process is conducted using third party software which runs a systematic check against weeks in a quarter for which benefits are paid and wages are reported during the same quarter. Although the program may detect weeks paid and wages reported, this alone is not indicative of an overpayment. Therefore, the process involves verification correspondence being sent to both the claimant and the employer, as applicable, to verify the status of employment, the wages earned as well as the weeks in which an individual worked and earned the wages. Based on responses, an assessment is made to determine if an overpayment exists and subsequent actions are taken accordingly. We are prohibited from assuming a match is an overpayment. It is not an overpayment until we have completed a full investigation and provided due process to all parties. The audit report indicates misinterpretation of the data reflected on the federal reports, specifically the ETA 227. The ETA 227 is for reporting of overpayment detection and recovery activities that the Agency performed in a quarter. It is not for reporting the amount of benefits overpaid for specific weeks during that quarter. A federal reporting team was created to accurately identify and track overpayments. The Department is taking necessary actions to complete the overpayment reconciliation for the ETA 227 and 902 reports. Federal regulations require an actual person to review and establish fraudulent overpayments. Due to the volume of claims and the number of cross matches to be performed on all state and federal pandemic programs, it would require multiple GDOL staffing levels to review all cross matches, requiring increased levels of state and federal funding. Summary GDOL has developed an aggressive plan to complete all remaining state and pandemic program cross matches. We have filled all of our budgeted positions for the Overpayment Unit and are utilizing non-overpayment staff to assist with identification and overpayment investigations. Additionally, we are utilizing temp agency staff to perform some clerical duties; however, federal regulations prohibit non-merit staff from adjudicating and releasing overpayment decisions. In early 2022, we started to freeze the overpayment data at the end of every month so that we can conduct periodic reconciliation of the overpayment records. GDOL is coordinating with USDOL to ensure the timely and accurate identification, tracking and reporting of overpayments. GDOL greatly appreciates the feedback and recommendations and will consider this information in future endeavors to modernize and update system and business processes. Estimated Completion Date: January 1, 2022 Contact Person: Crystal Singleton, Policy and Procedure Manager Telephone: 404-232-3183; E-mail: Crystal.Singleton@gdol.ga.gov

2022-028 Improve Controls over Eligibility Determinations Federal Agency: U.S. Department of Labor State Entity: Department of Labor (GDOL) Corrective Action Plans: (1) Identity verification was not performed appropriately in eight instances. GDOL Response: The Georgia Department of Labor disagrees with these findings as it relates to identity verification. The auditors did not identify the type of identity verification procedures not performed or any identity verification procedures that GDOL was required to perform. There was not a mandatory requirement to complete identity verification at the time most of these applications were submitted as the majority of these claims were employer-filed claims (EFC). Identity requirements for EFCs were implemented at a later date. At the start of the pandemic, the identity proofing processes available were Social Security Administration (SSA) verification, Department of Driver Services (DDS) crossmatch and for non-citizens, Department of Homeland Security Systematic Alien Verification for Entitlement (SAVE). As applicable, these processes were performed on all initial regular and EFCs, which includes the eight instances. (2) Non-monetary determination was not performed in two instances. GDOL Response: Instance 1: A disqualifying non-monetary determination was released and disqualification was entered into the system. The system erroneously released a payment for the week in question. An overpayment was established in January 2023. Instance 2: Claim was processed but issue did not get added to the claim to address separation reasons. A non-monetary determination was released in November 2022 to allow benefits. All payable weeks have been processed. There was no detriment to the claimant as they were determined eligible nor was there any monetary loss to the State. (3) Proof of employment or self-employment or a valid offer to begin employment and proof of wages was not submitted by two Pandemic Unemployment Assistance (PUA) claimants. GDOL Response: The GDOL disagrees with the findings related to proof of employment or self-employment or a valid offer to begin employment and proof of wages was not submitted by two PUA claimants. Under the Coronavirus Aid, Relief, and Economic Security Act (CARES Act), claimants did not have to provide proof of employment or self-employment. It was not until Continued Assistance Act (CAA) was enacted December 27, 2020 that such proof was required. The disqualification could not be applied retroactively, as outlined in Unemployment Insurance Program Letter (UIPL) No. 16-20, Change 4. Instance 1: Claimants who established PUA entitlement at the minimum weekly benefit amount were instructed to submit their proof of wages by email. Under the CARES Act, if claimants did not submit proof, federal requirements only allowed for payment of the minimum weekly benefit amount and no disqualification of benefits. The claim cited was originally established and remains established for the minimum weekly benefit amount. In accordance with CAA rules, the claimant was notified to provide proof of employment and wages for weeks paid on or after 12/27/20. To date, no proof has been provided by the claimant. The claimant has been disqualified effective 12/27/20 and an overpayment was established in January 2023. Instance 2: Claimants who established PUA entitlement with a weekly benefit amount greater than the minimum was based on wages entered by the claimant and/or wages reported by the employer. CARES Act only required proof of wages to be submitted. If claimants did not submit proof, federal requirements only allowed for payment of the minimum weekly benefit amount and no disqualification of benefits. Claims established at a higher weekly benefit amount had to be reduced to the minimum amount if no proof was provided. To date, no proof has been provided by the claimant cited. The claim was established above the minimum amount; therefore, benefits were reduced to the minimum amount. In accordance with CAA rules, claimants were notified to provide proof of employment and wages for weeks paid on or after 12/27/20. The claimant has been disqualified effective 12/27/20 and an overpayment was established in November 2022 for weeks paid over the minimum amount under CARES and weeks paid after 12/27/20 under CAA/American Rescue Plan Act (ARPA). (4) Claimants did not self-certify for benefits in 18 instances. GDOL Response: The GDOL disagrees with the findings Claimants did not self-certify for benefits in 18 instances. Employer-Filed Claims (EFC) are submitted by employers on behalf of the claimant. The employer is responsible for attesting to the employment status and weekly earnings of the claimant for the EFC submitted. An affidavit certifying that the employer has obtained earnings from other employment as well as other requirements must be completed before EFCs can be entered or uploaded. Claimants for which EFCs are submitted are considered to be still attached to the employer and are exempt from the requirement to register for employment services per Georgia Employment Security Law Rule 300-2-4-.02. Such individuals are not required to be nor certify on a weekly basis to be able, available and actively seeking work. Additionally, USDOL encouraged states to waive work search requirements for all claimants during the pandemic. (5) Claimant and payment information did not exist in the system of record in one instance. GDOL Response: The identifying information the auditors provided for this claim does not match any claims in our system. Therefore, we are unable to validate the auditor?s finding. Summary The information above is provided for your consideration in dispelling some of the audit findings. GDOL took immediate action to establish the federal UI programs and comply with federal guidance and regulations. There was not a mandatory requirement to complete identity verification at the time most of these applications were submitted. At the start of the pandemic, the identity proofing processes available were Social Security Administration (SSA) verification, Department of Driver Services (DDS) crossmatch and for non-citizens, Department of Homeland Security Systematic Alien Verification for Entitlement (SAVE). As applicable, these processes were performed on all initial regular and employer-filed claims (EFC). Beginning January 2021, PUA applicants were required to complete additional identity verification processes. Beginning in December 2021, all applicants were required to complete identity verification prior to filing a claim for UI benefits. Effective December 6, 2021, the EFC process was revised to require individuals (employees) to complete an EFC profile to include a real-time identity verification before payments can be made. Employers are responsible for submitting the request for the payment to certify to the individual?s employment status, but the individuals must certify their identity and personal information for the claim to be processed. Employees are notified when a claim is filed on their behalf and provided instructions for their portion of completing the EFC process. Additionally, as system deficiencies were identified, changes were made as quickly as possible to mitigate risks of improper payments. Automation of PUA claims was suspended and reviews were handled manually by staff before a determination was released. GDOL established task forces to develop and implement strategies to address the ramped fraud attempts to bypass system and procedural safeguards. We regularly attended fraud meetings with various federal agencies and unemployment agencies from other states to share best practices for combatting fraud. As resources permitted, we did our best to implement these best practices and strategies. Prioritizing system changes was challenging with the time constraints, necessity to build a program based on an established program that operated manually in our state and the demands of all other federal UI programs; but GDOL made every attempt to maximize our system capacity to accommodate the guidelines of each program requirements. Georgia greatly appreciates your time and consideration of our response to the findings and welcome you to contact us if you have any questions. Estimated Completion Date: December 16, 2021 Contact Person: Crystal Singleton, Policy and Procedure Manager Telephone: 404-232-3183; E-mail: Crystal.Singleton@gdol.ga.gov

2022-027 Improve Controls over Administrative Expenditures Federal Agency: U.S. Department of Labor State Entity: Department of Labor (GDOL) Corrective Action Plans: The seven transactions related to utility bills for some local career centers did not have an approval signature from Regional Operations. Each was processed by line staff after being reviewed by a lead worker/manager in Accounts Payable to assure that the account numbers belonged to GDOL. The accounts were confirmed as longstanding accounts and the invoice amounts were reviewed to assure that they were in line with prior billings. These invoices are reviewed again at the end of the day the payment was processed to assure they were processed as appropriate. As stated, we had several regular billers redirect invoices directly to Financial Services in an attempt to avoid misdirected mail during the vestiges of the pandemic. We wanted to avoid the risk of creating adverse relations with any biller or have to use precious time dealing with penalties and fees being added to account balances or service terminations as a result of going beyond the standard payment window. These were standard billings for critically needed utility services that needed to continue uninterrupted. Currently, approval signatures are required on all invoices as was customary prior to the pandemic. Estimated Completion Date: March 15, 2023 Contact Person: John Williams, Accounting Director II Telephone: 404-232-3577; E-mail: john.williams@gdol.ga.gov

2022-026 Improve Controls over Transparency Act Reporting Federal Agency: U.S. Department of Housing and Urban Development State Entity: Department of Community Affairs (DCA) Corrective Action Plans: Since the State audit, DCA has revised its processes and procedures related to the submission of the Federal Funding Accountability and Transparency Act (FFATA) for all federal programs, including CDBG-DR and CDBG-MIT. These processes include a formal review and approval of the report by the Office Director and the Division Director prior to submission. Estimated Completion Date: February 3, 2023 Contact Person: Nina Gyasi, Financial Ops and Reporting Manager Telephone: 404-679-5820; E-mail: nina.gyasi@dca.ga.gov

Corrective action plan: For the annual UI access review, TWC will monitor the annual CAPPS Systems Access Privileges Certification in CAPPS to ensure timely completion. For the code developer/promoter system roles, IT will implement a new quarterly review of developer roles to ensure no staff member has both roles assigned to ensure separation of duties in the system roles. We are also looking at potential technical solutions that would automate and prevent staff being assigned certain roles based on separation of duties. Implementation date(s): February 28,2023 Responsible Persons: Heather Hall, CIO

Corrective action plan: The formula error was identified, corrected and reallocations are now correct. Also, the outdated reallocation journal tool is no longer used. The new journal reallocation tool includes edits to identify discrepancies before a reallocation journal is posted. As an additional verification step, which began with March 2022 reallocations, a new verification report (Fund Source Allocation Compare Report) is run that compares the date the factor was updated to the date the reallocation journal was entered to ensure no changes have been made to the factor. HHSC Accounting will work with Chief Financial Officer (CFO) Operation Support to establish an automated process to strengthen existing verifications. Implementation date(s): August, 31, 2023 Responsible persons: Director, Funds Management

Corrective action plan: Texas Integrated Eligibility Redesign System (TIERS) - In order to bring password settings into compliance with the HHSC Information Security (IS) Security Policy, the TIERS Operations team released tool/method (113.0) successfully into production without any adverse impact. This release was completed on 09/24/2022 and contained the security requirements to restrict minimum allowed password changes from zero (unlimited) to one meaning users are allowed "only" one password change a day. This was verified by CliftonLarsonAllen LLP (CLA) auditors on 12/21/22. Screenshots were also provided to CLA auditors. Implementation date(s): September 24, 2022 Responsible Persons: Director, Information Technology (IT) Infrastructure Services

Responsible Individual: Matthew Zern, Financial Officer Corrective Action Plan: Due to the retirement of Greater Johnstown Area Vocational Technical School?s long time business manager and the sudden resignation of the replacement, the audit was unable to be completed timely. Greater Johnstown Area Vocational Technical School currently has a business manager in place and is expected to file its audit timely beginning with the June 30, 2023, fiscal year ending. Anticipated Completion Date: November 30, 2023.

2022-003 Improve Recordkeeping of Expense Allocations (Block Grants for Prevention and Treatment of Substance Abuse Assistance Listing #93.9592) Recommendation: We recommend that Comprehend maintains supporting documentation of all expense allocations and have it on file and readily available for the audit. Action Taken: Management agrees that supporting documentation is to be maintained to comply with Grant Requirements. Comprehend is currently working with Payroll Provider; ADP, to comply with the complexity of the payroll requirement as its to reconciling allocations of payroll at the program level. This process will be in place by May 2023 under the new provider. Donna Hicks, CFO, and Melanie Hill, Accounting Assistant, are the contact persons responsible for the corrective action.

Finding: 2022-001 Considered a significant deficiency in internal control/immaterial non-compliance. Program: ALN 93.959 Block Grants for Prevention and Treatment of Substance Abuse (Treatment) Criteria: As detailed by 2 CFR 200.402, the total cost of a Federal award is the sum of the allowable direct and allocable indirect costs less any applicable credits. Condition: During testing of amounts charged to the grants it was noted that provider stabilization payments were charged to the Treatment grant but were not authorized by the grants. Cause/Effect: This condition appears to be the result of a misunderstanding of costs allowed under this grant. These costs were not in compliance with 2 CFR 200.402. Questioned Cost: $199,598 Recommendation: We recommend that the Entity review all grant agreements to gain a thorough understanding of allowable costs and then establish/modify internal controls to assure that only allowable costs are charged to the grant View of Responsible Official: Management is in agreement with this recommendation. Corrective Action Plan: SWMBH's provider stability committee will review SWMBH's COVlD-19 Provider Stability plan. Along with the review of the plan, SWMBH will fully understand and execute request in accordance with the SWMBH COVlD-19 Provider Stability plan. Payments of an approved provider stability request will only be funded by Medicaid and Healthy Michigan. Responsible Party: Garyl L. Guidry Jr., MBA Chief Financial Officer Date of completion: August 1, 2023

Kettle Falls School District has already taken action to correct the finding. We utilized a project management firm to oversee the elementary roof project that this finding was based on. We informed them that we were using Federal funds to support the project and asked them to make sure that all rules regarding Federal funds were being followed. However, we learned during this audit that they were not followed. As soon as we learned about a potential issue with our current audit, we made an immediate change to our practice. We no longer rely on the firm to ensure that Federal requirements are being met. We now oversee those requirements, and the district will be certifying the payroll for any project that is being funded through Federal dollars.

2022-002 ALLOWABLE COSTS AND ALLOWABLE ACTIVITIES ? COVID-19 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS Recommendation: We recommend that the County include consideration of any expenditures that may be part of other federal programs as part of their review. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The County will review their procedures to ensure expenditures coded to federal grants are not already claimed by other grant programs. Name of the contact person responsible for corrective action plan: Deborah Erickson, Administrative Services Director Planned completion date for corrective action plan: December 31, 2023

2022-005 ALLOWABLE COSTS AND ALLOWABLE ACTIVITIES ? STATE ADMINISTRATIVE MATCHING GRANTS FOR SUPPLEMENTAL NUTRITION ASSISTANCE PROGRAM (SNAP CLUSTER) Recommendation: We recommend the county ensures that all employees included on the random moment study listing are included on the proper line for reimbursement requests. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The County will review their procedures to ensure the random moments studies are periodically reviewed against payroll and updated appropriately. Name of the contact person responsible for corrective action plan: Deborah Erickson, Administrative Services Director Planned completion date for corrective action plan: December 31, 2023

FINDING 2022-003 Finding: During testing, it was found that 2 out of 25 employees selected in the payroll sample for allowable costs did not have a completed semi-annual certification form or time and effort log for their work within the Title I program. Controls were not effective in ensuring all hours worked or salaries charged to the grant had the proper supporting documentation. Contact Person Responsible for Corrective Action: Carrie McGuire Contact Phone Number: (574) 875-5161 Views of Responsible Official: We concur with the finding Description of Corrective Action Plan: In order to address the issue related to semi-annual certifications not be completed and filed in a timely manner, Concord Community Schools created a Grants and Assessment Coordinator position in May 2022. A person was hired to fill this position starting on July 1, 2022. One of the essential functions of this position is maintaining current and accurate records related to federal and state grants. Starting in January 2023, in addition to the Grants and Assessment Coordinator, a member of the business department will be a second reviewer and sign the semi-annual certifications. Anticipated Completion Date: July 15, 2023

Corrective Action for Finding 2022-001: Internal Controls over Allowable Costs The Theatre agrees with the recommendation. This finding occurred due to a new Controller who did not adequately document expenditures per the grant requirements. This person has since been replaced by the Theatre. Going forward, procedures will be implemented to ensure all grant expenditures are reviewed for allowability. This will include a secondary review performed by the Director of Finance & Operations or designated Theatre personnel knowledgeable of the applicable grant requirements. The Director of Finance & Operations will be responsible for initiating and executing this corrective action plan effective immediately and with an expected completion date by August 31, 2023.

Response and Corrective Action Plan: The District will update the annual calculation to include a comparison of the base used for the indirect cost adjustment. Sarah Kautz, June 30, 2023.

The District Department of Health (DC Health) concurs with the finding, causes and recommendations cited in the fiscal year 2022 single audit for the Immunization Cooperative Agreements (ICA) program. Corrective action plan objectives are to have the following completed in fiscal year 2023: (1) a regular schedule of payroll data runs and reports of budget-to-actual time migrated to a certification platform managed by the Office of Grants Management, (2) full utilization of a uniform navigable tool and one-stop document for supervisors to certify time and effort and to request next actions if actual costs do not align with personnel budgets, (3) to create an IT solution or mechanism to route and track submissions between supervisors, the Office of Grants Management and the Office of the Chief Financial Officer (OCFO), and (4) the SOP will also be updated to integrate any procedural changes resulting from full implementation. See Corrective Action Plan for chart/table

Corrective Action Plan Finding No.: 2022- 003 Condition: Audit procedures identified that the District claimed $48,150 of expenditures related to equipment on their June 30, 2022 reimbursement claim submitted to the Illinois State Board of Education, however these expenditures were not received and paid by the District until July 2022. Plan: The District will implement an expenditure tracking system that will require all supporting documentation be uploaded to an electronic filing sharing system (OneDrive) for all quarterly reporting periods. The District will review submittals against dates for which goods and services were actually received. In addition, the District will implement a receiving protocol to coordinate payables against the receipt of materials. Anticipated Date of Completion: June 30, 2022 Name of Contact Person: James Vreeland, Business Manager Management Response: See above

Finding 2022-002 ? Reporting Federal agency: U.S. Department of Treasury Federal program name: Coronavirus State and Local Fiscal Recovery Fund Assistance Listing Number: 21.027 Federal Award Identification Number and Year: SLFRP2619-2022 Pass-Through Agency: Minnesota Department of Education Pass-Through Number(s): Unknown Award Period: July1, 2021 through June 30, 2022 Type of Finding: Significant Deficiency in internal control over compliance. Corrective Action Plan (CAP): Recommendation: We recommend that the District implement procedures and controls in relation to the required Coronavirus State and Local Fiscal Recovery Funds, to ensure they are completed accurately and timely going forward. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The District will implement procedures and controls over federal funds to ensure all requirements have been met. Name of the contact person responsible for corrective action: Marci Lord, Director of Business Services. Planned completion date for corrective action plan: June 30, 2023.

2022-001 Indirect cost rate incorrectly applied to HEERF lost revenue Cluster: Not appliable Grantor: Department of Education Award Name: COVID-19 - Higher Education Emergency Relief Fund (?HEERF?) ? Institutional Portion Award Year: FY2021 Assistance Listing Number: 84.425F Management acknowledges that indirect costs applied to the HEERF Institutional Portion were initially calculated from a base that included lost revenue. Following identification of the error, indirect costs calculated from lost revenue were removed and allowable costs were substituted in and included in amended Q1 2022 and Q2 2022 quarterly reports. Though all HEERF Institutional Portion funds have been expended, management will ensure that indirect costs are calculated from a base that includes allowable costs only. Moving forward, the Director of Post-Award Research Administration and University Controller will review the indirect cost calculation for all grants where lost revenue is an allowable cost. ___________________________ Jonathan Pearsall University Controller (617) 627-3816

View of Responsible Officials and Planned Corrective Action: Original documents are obtained and provided for all transactions, including inventory, services, and employee records. Time cards and review of salaries, time cards that reflect total time worked, and paid time off will be submitted to the company?s outsourced accountant regularly with signature and supervisory approval. Reporting of these items for employees will be on a monthly basis, and stipend personnel on a quarterly basis. Planned Implementation Date of Corrective Action: Implemented Person Responsible for Corrective Action: Jennille Smith, Executive Director

Federal Award Finding: 2022-001 ? Significant Deficiency in Internal Control and on Compliance with Reporting and Special Tests and Provisions Name and Contact Person: Janet Cadzow, Finance Director Corrective Action: When the ERA1 report for the period ending June 30, 2022 was completed Native Village of Fort Yukon had the intention of spending the entire amount of ERA1 funds that were awarded to them. However, the number of ERA applicants decreased after the June 30, 2022 report was submitted. When the report was completed, the staff was not aware of the Treasury?s definition of obligated and did not have funds promised in a commitment letter. Currently the staff has the knowledge of the Treasury?s definition of obligated and the mistake will not be repeated. The final ERA1 report combined Housing Stability Services with Administration costs on the Administrative Cost Line in the report. When the report was completed, the staff had problems accessing the report in the portal. They attempted to reach out for assistance in the portal but were unable to get an answer. The report was completed with combined Administrative Expenses and Housing Stability Services to submit the report by the deadline. NVFY has reached out to the grantor to correct the report with the costs separated out. NVFY believes the problems they had with reporting portal is the cause of the finding and they did everything they could do to be in compliance. Proposed Completion Date: Already completed.

Department of Health and Human Services 2022-002 Immunization Research, Demonstration, Public Information and Education, Training and Clinical Skills Improvement Projects - Assistance Listing No. 93.185 Recommendation: We recommend the Foundation attend training, review federal requirements, and fully understand the requirements over indirect costs Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: CFGF will engage with external firm to assist with fully understanding requirements related to indirect costs and federal requirements. CFGF will also work with external firm to assist in the identification and selection of additional training opportunities for staff who work on federal programs. Name(s) of the contact person(s) responsible for corrective action: Brett Hunkins Planned completion date for corrective action plan: December 31, 2023

Department: Health and Human Services Title: Internal control over P-EBT Food Benefits needs improvement Questioned Costs: Known: $61,507,558 Likely: None Status: Management?s opinion is that corrective action is not required Corrective Action: The Department disagrees with this finding and does not believe that corrective action is warranted. During the course of the audit, the Department provided the Office of the State Auditor (OSA) with the complete population of recipients as well as the supporting information necessary for OSA to conduct testing to verify compliance with federal program requirements. The only remaining action that is required is for OSA to perform their testing. Completion Date: N/A Agency Contact: Anthony Pelotte, Director, Office for Family Independence, DHHS, 207-624-4104