Corrective Action Plans

2022-003 Accuracy of Federal Reports Throughout the Single Audit process, management discovered that the pandemic caused issues concerning the organization of cash disbursement receipts. In lieu of this finding, management has decided to develop and implement the following procedures: 1. Management will develop a written policy and procedure for a cloud-based document saving subscription, that will be utilized to scan and to upload all invoices/statements/bills/receipts into specific grantor, vendor, and program folders. 2. Management will create a unique email address strictly used as a landing site for pay request, vendor invoices, and receipts. 3. Management will train all current staff and provide training to new hires as a part of orientation in use of the system. 4. Management will monitor the site on a weekly basis, at which time request, payments and receipts will be allocated to the appropriate budget lines.

2022-002 Indirect Cost Allocation Methodology In order to comply with 2 CFR Part 200 subpart E, Appendix IV requirement that NPOs have a policy and procedure that meets the Uniform Guidance for cost principles with specific focus on charging indirect costs, Cleveland UMADAOP will execute the following. 1. Management will develop a written policy that establishes the method for allocating both direct and indirect costs. 2. Management will develop a procedure that outlines the day-to-day execution of the policy and facilitates the documentation to adherence to the policy. This will include identification of a specific role/person responsible for to maintain the policy and procedure. 3. Management will train employees who are responsible for the delivering the programs. In addition, Management will conduct periodic training for those employees that are responsible for the audit function which will include the Business Manager and Executive Director. 4. Management will develop and periodic audit schedule that will allow for monitoring of adherence to the policy and procedures. 5. Management will provide the policy, procedure and audit process to its retained accounting service provider to assist in the execution of the development of the policy, procedure, training and audit process. 6. Management will review allocations monthly and document changes, if applicable.

2022-003: Supporting Documentation Recommendation: We recommend the organization design controls to ensure an adequate review process is in place to review costs charged to grants are properly supported by documentation. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: We will better enforce a policy that expenses must be sufficiently supported by documentation before payment is made. Name(s) of the contact person(s) responsible for corrective action: Joseph Ferlo, President & CEO Planned completion date for corrective action plan: June 30, 2023

FINDING 2022-001 ? Material Weakness and Material Noncompliance ? Budget Variances / Allowable Costs Corrective Action Plan: Analyze actual expenditures monthly, review the budget to actual numbers monthly and use data from this review to prepare a more accurate final budget revision. Responsible Parties: Rod Livingston, Business Manager Anticipated complete date of June 30, 2023 Rod Livingston Business Manager

Finding Reference Number: SA2022-001 Charging Eligible Program Costs to the Correct Category Assistance Listing Number: 21.027 Assistance Listing Title: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Name of Federal Agency: Department of the Treasury Federal Award Identification Number: SLFRP2014 ? Name(s) of the contact person: Marsha Ley ? Corrective Action Plan: City Finance staff will scrutinize the costs charged to the Coronavirus State and Local Fiscal Recovery funds program and based on the expenditure description and support documents will select an appropriate category when coding the costs in the Project and Expenditure Report. When the cost cannot be classified under the following four categories: ?support public health?, ?address negative economic impacts?, ?premium pay to essential workers?, and ?investment in water, sewer and broadband infrastructure?, then Finance staff will include it under ?replace lost public sector revenue? category. Finance staff will notify Budget Team about the amount and the specific expenditures that were classified under lost revenue category, to ensure we are not exceeding allowable amount of $10 million assigned under the ?replace lost public sector revenue? category. Additionally Accounting Manager and Senior Accountant will review the expenditure categories selected on the Project and Expenditure Report. City staff will correct $249,999 taser certification plan expenditure category during the next reporting window on the Department of the Treasury reporting portal. ? Anticipated Completion Date: June 30, 2023

Compliance requirement ? Allowed Cost /Cost Principle Institutional Comments on Findings and Recommendations: 1. The institution does not concur with the auditor finding because the referenced transaction was below the "Micro-purchase" threshold and does not require a quotation. The FAR increase the "Micro-purchase" threshold for natural disasters and national emergencies, among others. The invoice amount of $5899 was a continuation of an initial project under this contractor which have the unique security passwords, IT protocols and other IT requirements for the uniform implementation of intelligent classrooms for remote distance education. Accordingly, the institution does not request a quote. The institution followed the referenced guidelines in the determining the allowability of costs. Additionally, an external consultant reviewed the transaction and costs prior to request reimbursement. The 2 CFR Part 200, Appendix XI Compliance Supplement guide, issued April 2022, makes referenced to the FAQ's and Other Guidance containing information pertinent to the compliance requirements described in the document and encouraged auditor to regularly check the HERF Websites for updated FAQ's and other pertinent guidance and reporting information. The institution followed those referenced FAQ's and guidelines, among other sound administration practices, in the use of the grants. The referenced Compliance Supplemental, under "Activities Allowed or Unallowed" states: "Institutions must demonstrate that costs incurred are allowable under the relevant statutory provision and consistent with the purpose of the ESF "to prevent, prepare for, and respond to coronavirus"". The institution used $5,899 paid to the guidelines as indicated to contractor, to continue enhancing the distance learning program in preventing the spread and contamination of the coronavirus among professors and students by enabling remote distance education. The direct charges for this transaction to the federal award was for allowable costs under the instructions, federal grant and FAQs guidelines as indicated. 2. The institution does not concur with the auditor finding because of what is discussed in No 1 above. In the two cases mentioned, the cost quote may not agree with the invoice, because of some additional services requested, but the amount of the invoice was the correct amount paid and actual cost used to draw the HEERF funds. These invoices were for furniture and partitions divisions, to enable the remote distance education, avoiding physical contact of students and professors, to prevent, prepare for and respond to the COVID-19 emergency. Once again, these incurred and direct charges to the federal award complied with the HEERF objectives and were allowable costs under the authorized uses in the grant award and HEERF guidelines. 3. The institution does not concur with the auditor finding. The referenced three cases may not have a specific or expressed "acknowledgement of receipt" statement, but the acknowledgement was validated by UTC management and with the signatures when the check was issued. Nevertheless, the costs incurred in these invoices were authorized and incompliance with HEERF program and ESF purpose. The direct charges for this transaction to the federal award was for allowable costs under the instructions, federal grant and FAQs guidelines as indicated. 4. Institution does not, firmly, concurs with the auditor finding. This should not even be a finding because the institution strictly followed the FAQs published on March 19, 2021 to calculate the lost revenue and using a comparison between FY-20 and FY 21. That guideline described "Loss of Revenue" as "...those revenues and institution of higher education otherwise expected but were reduced or eliminated as a result of the novel coronavirus 2910 (COVID-2019) pandemic. As such, lost revenues can only be estimated". Nerveless, the result would have been relatively the same if we have use FY21 audited financials. Given the many factors and complexities of the unusual process, the institution followed a conservative approach and reduced those revenue items that have an increase between fiscal year from those with a loss of revenue. Therefore, the institution netted the potential amount of lost revenue to claim. Accordingly, the net amount resulted in $280,929.84. The potential loss of revenue amount could be greater but the institution decided to only claim the referenced estimated amount. These calculations and analysis were further discussed and evaluated by an officer of the Department of Education, with no recommendation on claiming a higher amount because the amount claimed was less than the estimated potential. The guideline indicates: "Reimbursement for lost revenue is allowable for the Institutional Portion program...". The institution claimed this loss of revenue amount from their institutional portion, complying with the HEERF guidelines and the authorized use of the funds. The direct charges for this transaction to the federal award was for allowable costs under the instructions, federal grant and FAQs guidelines as indicated. a. The institution used unaudited figures for FY21 because the audited financial statements were not completed at the time of the calculation. The institution revised the calculations with the audited financial statements, and the results were the same and the claimed estimated amount did not changed. Once again and in accordance with the guidelines, we were estimating the lost revenue with the data available at the moment. b. The institution followed the recommended HEERF guidelines for this complex and novel exercise. The institution considered under the analysis; those revenues otherwise expected but that were reduced as a result of the novel COVID-2019. The contributions as "Support Revenue" from related entities, which were a significant source of revenue for the institution, was not claimed as loss of revenue. The institution specifically claimed those lost revenue items as authorized in the guidelines. Therefore, once again, the UTC was in compliant with the lost revenue referenced guidelines. The direct charges for this transaction to the federal award was for allowable costs under the instructions, federal grant and FAQs guidelines as indicated. c. As explained above, the institution followed a conservative approach and only claimed a net amount of all lost revenue items. The institution only claimed those estimated revenue items, as authorized in the guideline, that suffer a loss between the two fiscal years considered in the evaluation. This was further evaluated by an officer of the DOE. As the guidelines described, since the lost revenues can only be estimated, the institution correctly, analyzed and calculated the best conservative/reasonable estimate of loss revenue with the available data at the moment. Even if we used the auditors' recommended items, the results would have been the same and no revenue item was claim out of the authorized or allowable costs from the guidelines. The direct charges for this transaction to the federal award was for allowable costs under the instructions, federal grant and FAQs guidelines as indicated. Actions Taken or Planned: The institution understands that the incurred and direct charges to the federal award complied with the HEERF objectives and were allowable costs under the authorized uses in the grant award and HEERF guidelines and no further was required.

1. The institution does not agree, nor concurs, with the auditors on this finding because the institution used the reimbursement payment method. This method was the preferred one when the non-federal entity, as our institution, cannot meet the requirements in 2 CFR, section 200.305(b)(1) for advance payment and the federal awarding agency sets a specific condition for use of the reimbursement. Title 2 of the CFR Part 200.305(b)(1), establish among others: "The non-Federal entity must be paid in advance, provided it maintains or demonstrates the willingness to maintain both written procedures that minimize the time elapsing between the transfer of funds and disbursement by the non-Federal entity, and financial management systems that meet the standards for fund control and accountability as established in this part". Furthermore, 2 CFR Part 200.305(b)(3) states: "Reimbursement is the preferred method when the requirements in this paragraph (b) cannot be met, when the Federal awarding agency sets a specific condition per ? 200.208, or when the non-Federal entity requests payment by reimbursement. " Since our institution was not able to meet 2 CFR, section 200.305(b)(1), and the HEERF guidelines has specific condition on how to use the funds; we choose the reimbursement method in the execution of the funds. Our institution adopted all HEERF instructions and guidelines as their policies to comply with the HEERF requirements, in addition to the CFR's regulations. Below some of the guidelines, instructions ad FAQs we adopted followed" a. Higher Education Emergency Relief Fund III, Frequently Asked Questions, American Rescue Plan Act of 2021, Published May 11, 2021, Questions 7 and 11 updated May 24, 2021, Question 36 updated September 30, 2021 b. US Department of Education, Notice of Proposed Institutional Eligibility Criteria, February 25, 2021 c. Federal Register Notice of Interpretation (NOI), regarding Period of Allowable Expenses for Funds Administered under HEERF Program, March 22, 2021 d. HEERF Notice of Interpretation for Period of Allowable HEERF Expenses (March 22, 2021) e. HEERF Lost Revenue FAQs (March 19, 2021) f. HEERF Period of Allowable Expenses Grant Records Notice (March 19, 2021) g. HEERF Grant Program Auditing Requirements (March 8, 2021) h. CRRSAA HEERF II Section 314(a)(1) Frequently Asked Questions (Published January 14, 2021 and Updated: March 19, 2021) i. CRRSAA HEERF II Section 314(a)(2) Frequently Asked Questions (January 14, 2021) j. CRRSAA HEERF II Section 314(a)(4) Frequently Asked Questions (Published January 14, 2021 and Updated: March 19, 2021) k. HEERF I and HEERF II Comparison Fact Sheet (Published January 14, 2021 and Updated: March 19, 2021) 1. HEERF Lost Revenue FAQ's, Published March 19, 2021 m. HEERF II, Public and Private Nonprofit Institution (a)(2) Programs (CFDAs 84.425K), FAQ's, Published January 14, 2021 n. HEERF II, Proprietary Institution Grant Funds for Students (CFDA 84.425Q) ((a)(4) Program), FAQ's Published January 14, 2021, Updated March 19, 2021. o. HEERF II, Public and Private Nonprofit Institution (a)(1) Programs (CFDA 84.425E and 84.425F), FAQ's Published January 14, 2021, Updated March 19, 2021. p. CAREST Act HEERF Rollup FAQs (issued October 14, 2020 and revised November 20, 2020) q. CARES Act HEERF Round 3 FAQs (Issued October 14, 2020 and revised November 20, 2020) r. CARES Act HEERF Supplemental FAQs (Issued June 30, 2020 and revised September 08, 2020) s. CARES Act HEERF Student FAQ's (Issued May 15, 2020) t. CARES Act HEERF Institutional Portion under Section 18004(a)(1) and 18004(c) FAQ's, (Issued April 9, 2020) u. CARES Act HEERF Emergency Financial Aid Grants to Students under Section 18004(a)(1) and 18004(c) FAQ's, (Issued April 9, 2020) v. CARES Act HEERF Institutional Portion under Section 18004(a)(1) and 18004(c) FAQ's, Issued April 9, 2020 w. COVID-19 FAQ's for Title III, IV, V and VII Grantees, June 16, 2020 x. COVID-19 Letter to HEP Grantees on Flexibilities Available Under CARES Act Section 3518, July 1, 2020 2. The institution does not agree, nor concurs, with the auditors on this finding because, as we mention in number 1 above, the institution adopted and followed the federal award and HEERF guidelines in the execution of the funds. The HEER funds were provided during the special national emergency caused by COVID-19. The DOE and HEERF officials issued many written guidelines, instructions, and FAQ's (Frequently Asked Questions) documents, due to the nature and novel of the national emergency situation. The institution adopted, followed, and relied on the many referenced guidelines and exercise extreme judgment to ensure compliance with the federal requirements and use of the funds. The institution belief this referenced guidelines and instruction were very specific and sufficient to execute the use of the funds. All direct charges to federal awards were for allowable costs under the guidelines and instructions from the Department of Education. Some of the allowable costs were verified and validated by an officer of the Department of Education and reviewed by an independent consultant. 3. The institution concurs with the auditor finding. Actions Taken or Planned: The institution begins in addition to the adopted HEERF guidelines, instructions, and CFRs; to develop additional procurement policies and are in the process of completing those policies. The institution expects to have those completed by May 31, 2023.

Below is the corrective action plan for the federal compliance audit finding from our 21-22 financial audit report. FINDING #2022-002: FEDERAL COMPLIANCE ? TIME REPORTING (50000) CORRECTIVE ACTION Staff were trained on timekeeping policies and procedures in the summer of 2022. The Director of State and Federal programs created the PowerPoint Presentation and presented it to staff. Additionally, the district?s website was updated to include the training presentation, training video, sample semi-annual and monthly forms, duty statements, work assignments, and frequently asked questions. The district expects to be in compliance with federal timekeeping requirements for the next audit cycle.

2022-001 Significant Deficiency: Internal control over maintenance of documentation of procedures performed Planned Corrective Action: Management will implement additional procedures to maintain documentation of the review and approval of expenses allocated to federal programs. Anticipated Completion Date: March 31, 2023 Responsible Party: Hasan Suzuk (Executive Director)

FINDING 2022-005 (Auditor Assigned Reference Number) Contact Person Responsible for Corrective Action: Greg Hunt, Assistant Superintendent of Business & Operations Contact Phone Number: (219) 362-7056 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: LaPorte Community School Corporation will review more closely the submission of costs of the Federal Special Education Grant to ensure that earmarking requirements of the Matching, Level of Effort, Earmarking compliance is followed. Anticipated Completion Date: May 15, 2023

Finding 2022-015 U.S. Department of Health and Human Services AL No. 93.568 Total Low-Income Home Energy Assistance Significant Deficiency over Period of Performance Repeat Finding: No Auditee?s Corrective Action Plan: The Office of Home and Energy Programs (OHEP) bureau of The Mayors Office of Children and Family Success (MOCFS) agency has implemented a plan to locate needed files from previous and current fiscal years. The agency has implemented a scanning and uploading Standard Operating Procedure (SOP) that requires each case file to be digitally attached to its application and supporting documents. This will remedy this finding in its totality. Contact Person: OHEP Director ? Rigel Moore Completion Date: March 10, 2023

Finding 2022-018 U.S. Department of Health and Human Services AL No. 93.778 Medical Assistance Program (Medicaid; Title XIX) Material Weakness over Period of Performance Repeat Finding: No Auditee?s Corrective Action Plan: BCHD will implement controls to allow only costs within the period of performance to be charged to the correct grant period within the general ledger. BCHD will ensure that if there are any exceptions that allow for costs to be charged outside the period of performance, the proper supporting documents will be kept. Baltimore City's new financial system, Workday, allows for all supporting documentation to be kept electronically in one system. Policies and procedures for internal controls will be updated to incorporate processes in Workday, and accounting staff will be trained appropriately. Contact Person: Chief Financial Officer ? Unyime Ekpa Completion Date: December 2023

Finding 2022-016 U.S. Department of Health and Human Services AL No. 93.767 Children?s Health Insurance Program (CHIP) Material Weakness Over Compliance and Internal Control over Period of Performance Repeat Finding: Yes Auditee?s Corrective Action Plan: BCHD will implement controls to allow only costs within the period of performance to be charged to a grant. BCHD will ensure that if there are any exceptions that allow for costs to be charged outside the period of performance, the proper supporting documents will be kept. Baltimore City's new financial system, Workday, allows for all supporting documentation to be kept electronically in one system. Policies and procedures for internal controls will be updated to incorporate processes in Workday and the accounting staff will be trained appropriately. Contact Person: Chief Financial Officer ? Unyime Ekpa Completion Date: December 2023

Finding 2022-024 U.S. Department of Health and Human Services AL No. 93.977 Totally Sexually Transmitted Diseases (STD) Prevention and Control Grants Significant Deficiency in Compliance and Internal Control over Period of Performance Repeat Finding: No Auditee?s Corrective Action Plan: BCHD will implement controls to allow only costs within the period of performance to be charged to the correct grant period within the general ledger. BCHD will ensure that if there are any exceptions that allow for costs to be charged outside the period of performance, the proper supporting documents will be kept. Baltimore City's new financial system, Workday, allows for all supporting documentation to be kept electronically in one system. Policies and procedures for internal controls will be updated to incorporate processes in Workday and the accounting staff will be trained appropriately. Contact Person: Chief Financial Officer ? Unyime Ekpa Completion Date: December 2023

Identifying Number: Finding 2022-004 Finding: During our testing of internal controls associated with the Alzheimer?s Program, the Association was not able to provide evidence for the time allocation associated with an employee whose salary was allocated to the program. In addition, for the Alzheimer?s Program, management provided an excel spreadsheet to support the charges that were made to the program rather than reporting from their financial management system that is compliant with Section 200.302. We acknowledge that the Association did track Alzheimer?s program expenditures within a cost center, however, not all of the charges made to the program were properly captured within the cost center. Corrective Action Taken or Planned: We assert that we exercised significant diligence and oversight over the handling of the federal dollars associated with the Alzheimer?s program funding (ALN #93.470) to ensure that such expenditures were (i) for allowable activities and consisted of allowable costs, (ii) tracked within a cost center in the organization?s general ledger and in an Excel spreadsheet that was compiled from support such as invoices and payroll records; and (iii) were not applied against other sources of funding. This was accomplished through the following: ? All invoices submitted to the Alzheimer?s cost center were required to be submitted with signature for approval by their supervisor and were complete appropriately. All expenditures were appropriately documented with necessary signatures, and were submitted for valid purposes. ? The time allocation of the identified employee was approved y the federal government through the budgeting process, and then through quarterly reports submitted through their portal. The internal Personnel Payroll Action Form was not correctly changed to reflect the appropriate allocation of the employee across programs. The employee was thus charged correctly to the federal government, and the federal government reimbursed the agency appropriately. In the future, program allocation will be reconciled in the personnel system to coincide with grant requirements. While we assert that proper oversight of this program was exercised, we understand that the auditors were not able to view the evidence of such review via sign-offs. We will update our policies and procedures to require evidence of our oversight responsibilities be required by means such as sign-offs, email approvals, etc. Further, we will work to adapt our accounting systems to be able to track activity related to federal grants within its own cost center (or sub cost center) so as to minimize the need for external management systems such as Excel spreadsheets. While expenditures against this funding were tracked within a cost center, there were other costs also included in the cost center (thus the use of the Excel spreadsheet to isolate the costs under this federal program). Going forward, a sub cost center for such funds will be utilized, if possible, to eliminate the need for a separate Excel spreadsheet. Name of contact person and title: William Bode, Controller Anticipated completion date: Immediately

Identifying Number: Finding 2022-003 Finding: During our testing of internal controls associated with the ARP program, the Association was not able to provide evidence of the review of time records and invoices to ensure that allowable costs were charged to the program. In addition, management provided an excel spreadsheet to support the charges that were made to the program rather than reporting from their financial management system that is compliant with Section 200.302. Therefore, we could not substantiate the double-counting of expenses did not occur. Corrective Action Taken or Planned: We assert that we exercised significant diligence and oversight over the handling of the federal dollars associated with the ARP funding (ALN 93.498) to ensure that such expenditures were (i) for allowable activities and consisted of allowable costs, (ii) tracked in an Excel spreadsheet that was compiled from support such as invoices and payroll records; and (iii) were not applied against other sources of funding. This was accomplished through the following: ? All invoices submitted against the ARP program were required and did have signature approval of the purchaser and supervisor ? Documentation of all activity was managed from all ARP sources, across all internal department and cost centers through a highly detailed excel spreadsheet managed by a third party contractor. This data was then reviewed by the agency Controller, CFO, and CEO regularly for accuracy against regular updates from the federal government regarding program reporting requirements and issued clarifications from the federal government. While we assert that proper oversight of this program was exercised, we understand that the auditors were not able to view evidence of such review via sign-offs. We will update our policies and procedures to require evidence of our oversight responsibilities be required by means such as sign-offs, email approvals, etc. Further, we will work to adapt our accounting system to be able to track activity related to federal grants within its own cost center (or sub cost center) so as to minimize the need for external financial management systems such as Excel spreadsheets. Name of contact person and title: William Bode, Controller Anticipated completion date: Immediately

Finding 2022-022 U.S. Department of Health and Human Services AL No. 93.940 HIV Prevention Activities Health Department Based Material Weakness over Period of Performance Repeat Finding: Yes Auditee?s Corrective Action Plan: BCHD will implement controls to allow only costs within the period of performance to be charged to a grant. BCHD will ensure that if there are any exceptions that allow for costs to be charged outside the period of performance, the proper supporting documents will be kept. Baltimore City's new financial system, Workday, allows for all supporting documentation to be kept electronically in one system. Policies and procedures for internal controls will be updated to incorporate processes in Workday and the accounting staff will be trained appropriately. Contact Person: Chief Financial Officer ? Unyime Ekpa Completion Date: December 2023

Finding 2022-027 SNAP Cluster, ALN 10.551 and 10.561 - System and Organization Controls Management Views MDHHS agrees with the finding. Planned Corrective Action MDHHS will annually obtain and review the SOC reports for providers that perform key control activities on behalf of MDHHS. In May 2023, MDHHS reviewed the FMG SOC report review requirements and, after further evaluation, determined that a review is not needed for 1 of the 2 SOC reports identified in part b. and both of the SOC reports identified in part c. because they did not perform key control activities on behalf of MDHHS, which will be documented on the required OIAS review template for future SOC report reviews. The review of the SOC reports for the remaining providers is now primarily conducted by the MDHHS Compliance Division. MDHHS will work with other State agencies to identify best practices and document a centralized process to monitor the completion of SOC report reviews. MDHHS will work with OIAS to provide training as necessary. Anticipated Completion Date MDHHS plans to document the centralized process by August 31, 2023 and implement additional monitoring of SOC report reviews by September 30, 2023. Responsible Individual(s) Jim Bowen, MDHHS Andrew Piper, MDHHS

Finding 2022-015 MDHHS, PACAP - Inappropriate PACAP Allocation Management Views MDHHS agrees with the finding. However, the comprehensive set of quality control measures in place during fiscal year 2022 were, and continue to be, effective in detecting errors as designed. For each quarterly cost allocation run, statistical values varying greater than 5.00 percent of the total for that statistical group from the previous quarter are reviewed for accuracy and none of the errors cited in the finding fell outside of this range. Questioned costs from these errors is $426,682 out of $1,635,146,559 allocated in fiscal year 2022 (0.03 percent of all fiscal year 2022 allocated funds by MDHHS). Due to the linear nature of the MDHHS cost allocation process, the large administrative overhead cost pools that are included in the auditor?s samples, such as Rent/Building Occupancy and Departmentwide Administration are allocated across the entire department. The auditor?s review included all related statistical records within each statistical group for the sampled cost pools. This includes almost all statistics used in the cost allocation process for the entire fiscal year because the costs that originate in these cost pools are referenced in all other cost pools. Planned Corrective Action MDHHS implemented additional quality control analysis in comparing statistical values from the current quality control tracking file to the configuration file before loading any files into SIGMA. Any values that do not match will be analyzed and reconciled by MDHHS staff. This ensures that no values are overwritten and that any updated statistical values are reviewed in accordance with the existing quality control policies. Additional analysis steps have also been utilized for the Participants Random Moment Time Study (PRMTS) statistics to add a manual calculation column rather than submitting summarized data. For the Random Moment Time Study (RMTS) statistics, MDHHS has worked with the vendor and the vendor will add a verification check column to ensure that total responses and all adjustments are reconciled. MDHHS will verify completion upon receipt. Anticipated Completion Date MDHHS has implemented the additional quality control analysis to compare statistical values and new steps in analyzing the PRMTS statistics group. MDHHS will be incorporating the new vendor quality control steps related to the RMTS statistics effective July 2023. Responsible Individual(s) Suzanne Kyes, MDHHS Matthew McCool, MDHHS

2022-002 Research and Development Cluster ? Assistance Listing No. 93.310 Recommendation: We recommend the Blood Bank implement procedures to ensure all personnel charges to the program are supported by the minimum time and effort documentation outlined within 200 CFR 200.430. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Blood Bank added review and approval processes to compare actual vs budgeted vs allowable time and effort. Names of the contact persons responsible for corrective action: Bryan Eleazar, CFO; Lisa Alexander, Direct of Grant Accounting; Jeanette Lysse, Controller Planned completion date for corrective action plan: October 29, 2021

Finding ref number: 2022-001 Finding caption: The District did not have adequate internal controls for ensuring compliance with wage rate requirements. Name, address, and telephone of District contact person: Jeri Carlson 33330 8th Ave S Federal Way, WA 98003 253.945.2045 During the course of the audit, the District immediately took steps to obtain and review all certified payroll documents from the beginning of the project to current and verified that the contractor was compliant with federal prevailing wage rules. This information was provided to the Auditors. The District has already taken steps to ensure the additional compliance steps are followed for federally funded construction projects. The District will also ensure staff are appropriately trained on these requirements.

Date: April 21, 2023 Subject: Corrective Action Plan Please find below the Medical University of South Carolina?s (MUSC) Corrective Action Plan for the finding presented by KPMG relating to our fiscal year 2022 audit conducted under the Uniform Guidance. Audit finding reference number: 2022-003 Cash Management Cause and potential effect as presented in the Summary of Findings and Questioned Costs: For 3 of the 40 samples tested, taxes were properly accrued as allowable costs but were drawn prior to payment by the University. While these costs are deemed allowable, they were not paid for prior to seeking reimbursement from the federal agency. The taxes drawn prior to payment totaled $4,035 out of a total of $784,941 tested in the sample of 40. The control to ensure that all costs were paid for prior to seeking reimbursement was not operating effectively to identify instances of noncompliance related to the applicable taxes. Name(s) of the contact person(s) responsible for corrective action: Velma G. Stamp, Director, Grants and Contracts Accounting Michael Laird, Manager, Financial Reporting, Grants and Contracts Accounting Corrective action planned: MUSC tested purchases to determine the extent of the finding. It was found that this issue was isolated to the Department of Lab Animal Research (DLAR) animal purchases made with the departmental Purchasing Card. Once this determination was made all DLAR animal purchasing card transactions were identified, for the period being audited, in order to calculate the use tax required to be paid. MUSC?s tax office then submitted amendments for each month, remitting the additional use tax as well as the applicable penalties to the South Carolina Department of Revenue. No adjustments were needed to be made to the grants impacted as these are otherwise allowable costs. We believe MUSC?s system operates adequately when use tax is flagged as required by our policies and procedures. This instance occurred due to input errors by the employee responsible for this area. As such, we have conducted training with the employee as well as the employee?s manager instructing how purchasing card transactions subject to use tax must be identified when allocating credit card purchases. In addition, we will monitor DLAR credit card purchases to ensure MUSC?s policies and procedures are being adhered to. Anticipated completion date: This corrective action has been implemented and the monitoring will be ongoing. Questions or requests for additional information related to this Corrective Action Plan may be directed to me via email at stampvg@musc.edu or by telephone at 843-792-3657. Sincerely, Velma G. Stamp, Director

2022-074a ? EOHHS will implement an enhanced invoice review documentation requirements for significant contractor invoices to ensure compliance with Uniform Guidance requirements over allowable costs in the Medicaid Program. 2022-074b ? EOHHS will improve procedures to ensure that recoupments are made for identified special education services deemed unallowable for Medicaid reimbursement. Anticipated Completion Date: December 2023 Contact Persons: Jason Lyon, Administrator for Medical Services Executive Office of Health and Human Services jason.lyon@ohhs.ri.gov Christopher Smith, Director of Program Integrity Executive Office of Health and Human Services christopher.smith@ohhs.ri.gov

2022-073a ? EOHHS submitted a State Plan Amendment to CMS to codify the PRTF reimbursement methodology on June 29, 2021. Since 2021, EOHHS and DCYF have been working to respond to CMS comments, including updating the cost report to be used by PRTF providers and amending the proposed State Plan language to address CMS questions on the reimbursement methodology. Anticipated Completion Date: EOHHS anticipates CMS approval of the State Plan Amendment before June 30, 2023. 2022-073b ? EOHHS will continue to work with DCYF to ensure that allowable medical services provided by DCYF providers are billed directly to the MMIS and subject to all designed claims processing, recipient eligibility, and provider eligibility controls. Anticipated Completion Date: Ongoing Contact Person: Dezeree Hodish, Assistant Director, Financial and Contract Management Executive Office of Health and Human Services dezeree.hodish@ohhs.ri.gov

2022-068a ? EOHHS addressed issues with the TPL loopback file between MMIS and RI Bridges with a permanent system fix. 2022-068b ? EOHHS will assess the current process of Medicaid Administration claiming and develop a revised process to require HHS agencies to submit the reconciliations of their quarterly reports to reported expenditures in RIFANS. In addition, the RIFANS documentation will be reviewed and approved prior to submission of the federal report. 2022-068c ? EOHHS will conduct this analysis and create a process to report the MCO tax on the CMS 64.11A. Anticipated Completion Date: December 2023; TPL loopback deployed into RI Bridges production on 5/19/2022. Contact Persons: Brian Tichenor, RIBridges Medicaid Administrator Executive Office of Health and Human Services brian.tichenor@ohhs.ri.gov Allison Shartrand, Assistant Director Financial and Contract Management Executive Office of Health and Human Services allison.shartrand@ohhs.ri.gov Chaz Plungis, Chief of Strategic Planning, Monitoring and Evaluation Executive Office of Health and Human Services charles.plungis@ohhs.ri.gov