Corrective Action Plans

Corrective Action Plan Name of auditee: Buckingham Terrace II, Inc. HUD auditee identification number: HUD Project No. 061-EE-038 Name of audit firm: Carter & Company, CPA Period covered by the audit year: March 1, 2021 through February 28, 2022 CAP prepared by: Name: Debra Minix Position: Management Agent Telephone number: 912-267-1962 1. Current Findings on the Schedule of Findings, Questioned Costs, and Recommendations: Finding 2022-001 Unauthorized withdrawals were made from the replacement reserve by the Housing Corporation without HUD approval as required by the Regulatory Agreement (1) Comments on the Finding and Each Recommendation. Management agrees with the finding and has made the required deposit as of 6/17/2022. (2) Actions Taken on the Finding. Management agrees with the finding and has made the required deposit as of 6/17/2022.

Bridge House #11 Corporation 290 Lenox, 3rd Floor New York, NY 10027 AUDITEE?S CORRECTIVE ACTION PLAN Name and Number of Project Bridge House #11 Corporation, FHA Project Number 012-HD106 Auditor/Audit Firm PKF O?Connor Davies LLP Audit Period June 30, 2022 Finding 2022-001 ? Timely Deposit of Surplus Cash A. Comments on Finding and Recommendations Recommendation ? We recommend that management ensures the surplus cash deposit is done timely in the future. B. Actions Taken or Planned Auditee agrees with this finding. Our policy has been to make surplus cash deposits after the final audit has been issued. Going forward our focus will be to work with the auditor and owner to get the audits finalized earlier so adequate time is left for the deposits to be made. In instances where the final is not going to be issued and allow enough time, the deposit will be made based on the reviewed draft. C. Status of Corrective Action on Prior Findings No prior findings.

CORRECTIVE ACTION PLAN Name and Number of the Project: Cliff View Village II, Inc. No. 112-EE040 Audit Firm: M Group, LLP Audit Period: The year ended December 31, 2022 Compliance Review A. COMMENTS ON FINDINGS AND RECOMMENDATIONS We concur with the findings and recommendations of our auditors regarding our noncompliance as cited in the accompanying Schedule of Findings and Questioned Costs. ACTIONS TAKEN FINDING 3: Section 202 Capital Advance, CFDA 14:157 CORRECTIVE ACTION COMPLETED: The audited financial statements were not entered into the FASSUB system within 90 days prior to year-end. The Company did not have available funds to pay prior year audit fees. HUD approved a residual receipts withdrawal to pay outstanding audit fees and the REAC was filed. We have prepared the corrective action plan as required by the standards applicable to financial statements contained in Government Auditing Standards and by the audit requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principals, and Audit Requirements for Federal Awards. Any questions regarding the above corrective action plan should be directed to Ms. Connie Quillen, Vice President, Asset Living.

CORRECTIVE ACTION PLAN Name and Number of the Project: Cliff View Village II, Inc. No. 112-EE040 Audit Firm: M Group, LLP Audit Period: The year ended December 31, 2022 Compliance Review A. COMMENTS ON FINDINGS AND RECOMMENDATIONS We concur with the findings and recommendations of our auditors regarding our noncompliance as cited in the accompanying Schedule of Findings and Questioned Costs. ACTIONS TAKEN FINDING 2: Section 202 Capital Advance, CFDA 14:157 CORRECTIVE ACTION COMPLETED: On September 28, 2023 the Company deposited the delinquent payment of $120 into the residual receipts account for excess rent. We have prepared the corrective action plan as required by the standards applicable to financial statements contained in Government Auditing Standards and by the audit requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principals, and Audit Requirements for Federal Awards. Any questions regarding the above corrective action plan should be directed to Ms. Connie Quillen, Vice President, Asset Living.

CORRECTIVE ACTION PLAN Name and Number of the Project: Cliff View Village, Inc. No. 112-EE017 Audit Firm: M Group, LLP Audit Period: The year ended December 31, 2022 Compliance Review A. COMMENTS ON FINDINGS AND RECOMMENDATIONS We concur with the findings and recommendations of our auditors regarding our noncompliance as cited in the accompanying Schedule of Findings and Questioned Costs. ACTIONS TAKEN FINDING 2: Section 202 Capital Advance, CFDA 14:157 CORRECTIVE ACTION COMPLETED: The audited financial statements were not entered into the FAASUB system within 90 days prior to year end. The Company did not have available funds to pay prior year audit fees. HUD approved a residual receipts withdrawal to pay outstanding audit fees. We have prepared the corrective action plan as required by the standards applicable to financial statements contained in Government Auditing Standards and by the audit requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principals, and Audit Requirements for Federal Awards. Any questions regarding the above corrective action plan should be directed to Ms. Connie Quillen, Vice President, Asset Living.

Personnel Activity Reports are vital support documents for the billing process for all Federal grant dollars received. There were times when there was no review supervisor available for approval of the individual document. Since the Urban League has expanded staff to include a Quality Assurance and Data Compliance position, this person will be added to the list of individuals who can approve this document for all programs. Additionally, Vice Presidents, program supervisors and the Quality Assurance and Data Compliance position will now have the authority to approve these forms should the review supervisor be unavailable.

During the testing of the compliance requirements of this program, it was determined that the Hospital reported COVID-19 related expenditures within the HHS Provider Relief Fund (PRF) portal that were reimbursed via other sources. Personnel Responsible for Corrective Action: Bart Kenton, Chief Financial Officer Anticipated Completion Date: Change is in process and full adoption is anticipated by September 30, 2022 Corrective Action Plan: The Hospital is going to continue and improve its understanding of the guidance related to this type of reporting and work with their external advisors to ensure future portal submissions are compliant with said guidance.

Program: Various, including AL 84.010 ? Title I Grants to Local Educational Agencies; AL 93.568 ? Low-Income Home Energy Assistance (LIHEAP); and AL 93.659 ? Adoption Assistance ? Cash Management Corrective Action Plan: N/A Contact: Ron Carlson Anticipated Completion Date: N/A

Program: AL 12.401 ? National Guard Military Operations and Maintenance (O&M) Projects ? Cash Management & Reporting Corrective Action Plan: The USPFO Grants Officer Representative (GOR) will continue to work closely with the Cooperative Agreement Program Mangers (CAPMs) to track projected invoices so they are paid out in a timely fashion (per Federal Cash Management requirements) from the Cooperative Agreement advance funds (as required by the State). Also upon implementation of the recommendation to change the data in the SF270 (contained in the Exit Conference), the SF270 submission will track the availability of advance funds ? thereby preventing excessive advance funds requested ? and fully expending current available advance funds to the federal requirements. Contact: Matt Zeigler, Grants Officer Representative Anticipated Completion Date: Implementation will occur at the start of the new State Fiscal Year 01-Jul-2023.

Responsible Official - Faith Williams, Senior Vice President Property & Asset Management Plan Detail - Management will ensure the Project is reimbursed for the erroneously paid invoice. Additionally, management will ensure future non-project operating invoices are not paid with Project operating cash. Anticipated Completion Date - The corrective action is in the process of being implemented and expected to be completed in fiscal year 2023.

Responsible Individuals: Mary R. Duncan, CPA, CGMA, Chief Financial Officer and Cassondra Bolstad PMP, Equipment and Facilities Operations Manager Corrective Action Plan: The Organization has implemented practices for deposits of residual receipts reserves to be made within 60 days of year-end as required by U.S. Department of Housing and Urban Development. Anticipated Completion Date: Current fiscal year 2022, as Equipment and Facilities Operations Manager position was developed and hired in November 2021.

Management Response: The District will review cafeteria operations throughout 2022-2023 and ensure any excess funds be used to provide additional support to the cafeteria program, including the utilization of excess funds for equipment and operational efficiencies.

Findings and Recommendations - 2022 ? 001: Finding Type: Noncompliance with Laws and Regulations. Condition: The Academy?s NSFSA?s fund balance exceeded the allowable three months? average expenditures at June 30, 2022. The Academy had approximately 5.81 months of expenditures as fund balance at June 30, 2022. Recommendation: The Academy should submit a spend down plan and obtain Michigan Department of Education?s prior approval to improve the food quality or take other action to improve the program in accordance with 7 CFR 210.19(a)(2). Corrective Action Plan - The Academy is aware of the finding and is implementing procedures in order to prevent further noncompliance in the future. The Academy will be creating and implementing a spend down plan once approval of the plan is received by Michigan Department of Education. Responsible Department - Business department and Food Service department. Responsible Person - Tammy Visger (Director of Food Service). Planned Completion Date (TBD or Date) - Spend-down plan to be implemented and expected completion prior to June 30, 2023.

Finding 2022-03 - Cash Management Recommendation: The University should implement controls and processes to ensure that all expenses are properly identified and documented before any drawdowns are made. Action Taken: The funding was drawn down as the result of news publications from various sources in August 2021 indicating that the infrastructure package threatened to take away unused relief funds. At the time, no creditable source was able to confirm whether this meant the University would lose unused HEERF II and III funds. To safeguard the student funding, the University drew down the remaining balance for HEERF II, knowing they would have students to award the funds to shortly thereafter. All other HEERF awards were drawn down on a reimbursement basis. Responsible Individual for Corrective Action: Sr. Associate VP / Deputy CFO ? Jennifer Ginnetti Anticipated Completion Date: December 31, 2022

Finding Reference Number: 2022-002 Concur or Do Not Concur: Concur Agree or Disagree with Auditor Recommendations: Agree Actions Taken or Planned on the Finding: Management agrees with the finding. The residual receipts account deficiency will funded in the amount of $18,738 and $1,515. Management will ensure that the residual receipts account is properly funded in the future. Completion Date: August 25, 2022

Finding Reference Number: 2022-001 Concur or Do Not Concur: Concur Agree or Disagree with Auditor Recommendations: Agree Actions Taken or Planned on the Finding: Management agrees with the finding. The excess funds were accrued to submit to HUD. Completion Date: August 25, 2022

FINDING NO: 2022-002 CONDITION THE OCTOBER, 2021 AND THE MARCH, 2022 CLAIM SUBMITTED FOR NATIONAL SCHOOL LUNCH AND SCHOOL BREAKFAST PROGRAM DID NOT AGREE TO THE SUPPORTING DOCUMENTATION. PLAN THE INCORRECT NUMBERING ON THE COUNT SHEETS HAVE BEEN CORRECTED. WE WILL ALSO CREATE A SEPARATE MONTHLY SUMMARY SHEET TO CHECK MEAL COUNTS AGAINST WINS. THE FOOD SERVICE DIRECTOR AND SECRETARY WILL REVIEW THE DAILY COUNT SHEETS BEFORE THE MONTHLY CLAIM FOR REIMBURSEMENT IS FILED. ANTICIPATED DATE OF COMPLETION: IMMEDIATELY UPON LEARNING OF THE OVERSIGHT. NAME OF CONTACT PERSON: RYAN SWAN, SUPERINTENDENT

Tri-County North will make sure that we follow the proper controls on wage requirements and standards to make sure that the contractor is in compliance with prevailing wage rate.

2022-001 - Deposit of Surplus Cash into a Residual Receipts Account Corrective Action Plan No later than 60 days past the end of the fiscal year, we will identify surplus cash in the project funds account and deposit into the residual receipts account. Person(s) Responsible: Greg Shinn, Agency CPA Timing for Implementation: Immediate

2021-001 ? Internal Control Finding over Reporting Auditor Description of Condition and Effect: Internal control procedures are required to ensure the reporting requirements for the Homeland Security Grant Program are being met. The County is required to submit standardized EMD reimbursement reports to report expenditures under Federal Awards. During our testing, we identified $11,884 of expenditures that were not included on the EMD reimbursement reports. As a result of this condition, the County is exposed to an increased risk of not being reimbursed for eligible expenses. Auditor Recommendation: The County should review and reconcile the EMD reimbursement reports to the County?s detailed accounting system records to ensure completeness of the reimbursement requests. Corrective Action: We agree with the finding and will implement this procedure going forward. Responsible Person: Anticipated Completion Date: September 30, 2023

FINDING 2022-004: ESSER - REPORTING CONTACT PERSON: Jessica Garnica, Business Manager CORRECTIVE ACTION: Management will ensure all necessary reports related to federal grants are filed in a timely manner and that PDE requirements are reviewed. Management has already filed the required cash on hand reports for ARP ESSER for the most recent fiscal quarter. Management is confident that the issue can be resolved immediately. PROPOSED COMPLETION DATE: Immediately

Finding Number 2022-002 SPECIAL TESTS AND PROVISIONS- INSURANCE PROCEEDS - COMPLIANCE- INTERNAL CONTROL DEFICIENCY Agency Name FEDERAL AGENCY: PUBLIC AND INDIAN HOUSING, DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT Program ALN 14.850 ? PUBLIC AND INDIAN HOUSING Contract # N/A Criteria Special Tests and Provisions ? Insurance Proceeds - As stated in the April 2022 Compliance Supplement, a Public Housing Agency (PHA) is required to use insurance proceeds to promptly restore, reconstruct, and/or repair any damaged or destroyed property of a project, except when a PHA has written approval from HUD to do otherwise. Unspent insurance proceeds normally are recorded as restricted cash or restricted investments on the Financial Data Schedules (FDS) up to the amount of the repair. In cases of unforeseeable and unpreventable emergencies that include damages to the physical structure of the housing stock, PHAs are allowed to use their Operating Funds to cover the expenses associated with the damages. A PHA?s insurance may cover the damages fully or partially, however, it usually takes time for the PHA to receive the insurance proceeds. Once received, the PHA must reimburse its operating account for any expenses that were initially covered with Operating Funds up to the amount received. If the amount of the insurance proceeds is less than the cost of the repair and the PHA elected to use Operating Funds to cover the difference, the PHA is not allowed to draw down capital funds to reimburse the Low Rent program. Condition/Context The Authority received insurance proceeds to cover catastrophic loss affecting a myriad of locations. The insurance recovery was promulgated on emergency repairs and post-events, many of which were not initiated or needed due to internal fixes. During our review of the insurance proceeds compliance, we noted that the Authority did not document repair expenditures for loss affecting myriad locations and could not correlate one-to-one expenditures to the insurance proceeds in a timely manner from when the insurance proceeds were received. Recommendation We recommend that the Authority correlate one-to-one expenditures to the insurance proceeds received on a timely basis Corrective Action Plan All good faith efforts to correlate emergency expenditures from insurance proceeds will be made in order to capture vendor work on a timelier basis. Catastrophic events (resulting in insurable claims such as the Hurricane Ida related claim selected in Deloitte?s testing) are complicated as the focus is primarily on restoring critical services in many developments, usually located in all five boroughs. The proceeds thus far received were estimated via inspection and the insurance claim remains open for more permanent pricing and repair. Such a claim often takes years to finalize as work scope is prepared and agreed to by insurers? representatives and the Authority. The emergency proceeds received have been used as needed for more repairs requiring them. As identified in the audit, much of the emergency work to date on Hurricane Ida was performed internally by staff at the sites, which did not generate transparent repair expenses. Management will take action, within limitations described above, to improve the correlation of expenditures to the insurance proceeds received on a timelier basis. In order to accomplish, will rely on the Authority?s Asset & Capital Management Department to provide timely work scope to assist in the correlation of more permanent expenditures Action Date Ongoing Final Implementation Ongoing Name And Phone Number Of Person Responsible For Implementation Arlene Orenstein Director of Risk Management 212-306-6682

Federal Agency Name: Department of Health and Human Services Program Name: Block Grants for Community Mental Health Services CFDA # 93.958 Finding Summary: There was no formal documentation of review of wage rates for eight employees selected for testing. There was no formal documented review for the calculation of indirect costs submitted for reimbursement for four months selected for testing. There was no formal documented review for seven reimbursements requests selected for testing. Washburn Center has designed internal controls over these areas; however, the controls were not formally documented. Responsible Individuals: Mohamed Omar, MBA, MS, Chief Administrative Officer Corrective Action Plan: Management will review the current active review process and implement a formal documentation of the review including the appropriate level of management sign off and date of review on the supporting documentation. Anticipated Completion Date: December 2023

View of Responsible Officials The State concurs in part with the premise of the findings identified, but it does not concur with the characterization of the Governor?s Office for Emergency Relief and Recovery (GOFERR), the process for authorizing the relevant subaward and relevant amendments, the nature of the subaward and amendments, or the recommended corrective action. Moreover, the full $49,250,000 identified in the finding was not provided to the subrecipient in one lump sum. The State was allocated $50,000,000 from U.S. Treasury for the purposes of designing and facilitating the State?s HAF program. The State received $5,000,000 from U.S. Treasury up front and received the remainder after approval of the State?s planned program. As a result, the State?s subrecipient received an initial subaward for administrative and planning purposes from within the initial $5,000,000 delivered to the State. The subrecipient was advanced only a portion of those initial funds and then was provided the remainder upon request and justification. A subsequent amendment to that subaward provided additional funds to the subrecipient as needed for the same purpose and as part of the U.S. Treasury required process of designing and then attaining approval for the State?s HAF program. The State ultimately received approval from U.S. Treasury for the State?s HAF program plan, which is a complex multi-faceted program that provides various forms of assistance to homeowners, and then received approval from State officials to launch the program. The State?s program is run entirely through a single subrecipient, New Hampshire Housing Finance Authority, which is the only entity of its kind as a statewide housing authority. This subrecipient facilitates a variety of larger-scale, federally funded housing programs. While developing the State?s HAF program and as it neared the launch date, the State began receiving preapplications through its subrecipient. Additionally, during this time, the State was facilitating its Emergency Rental Assistance (ERA) program, which has provided assistance to renters as opposed to homeowners and is facilitated by the same subrecipient of the State. Within the context of having received nearly 200 preapplications for the HAF program and witnessing a heavy and increasing demand in the rental assistance program, the decision was made to advance the remainder of the State?s HAF allocation ($45,000,000) to its subrecipient in order to provide prompt and adequate assistance, believing the program would experience high demand at the outset and funding shortfalls would be problematic for its success. Moreover, the amount of funds provided to the subrecipient was consistent with past advances to the same subrecipient under the ERA program, and as with prior delivery of funds, the subrecipient placed the funds in an appropriate account. However, demand for assistance did not unfold as anticipated due to the features of the program and the areas of need ultimately demonstrated by applicants after review and processing of initial applications. As part of the State?s monitoring protocols, and in part because of a lower initial expenditure rate than expected, the subrecipient began providing biweekly reports on the usage of funds, which the State has used as a measure of cash on hand. Moreover, the State also engages in standing, calendared, weekly calls with the subrecipient to discuss these reports. The State has provided documentation to support the process outlined above as well. Finally, as a result of the State?s remaining HAF allocation having already been provided to the subrecipient, the recommended corrective action is not feasible. However, the State acknowledges the need to more formally memorialize its review of the subrecipient?s cash on hand. As a result, the biweekly reports received and reviewed by the State will now include a specific section providing such information; review and discussion of that data will be incorporated into the weekly calls with the subrecipient, and the process and protocols will be documented in the State?s transaction processing memo for the program. Corrective Action Incorporation of cash on hand related data in biweekly reports received and reviewed by the State, documentation of that review as part of the weekly calls with subrecipient, and memorialization of the process and protocols in the State?s transaction processing memo for its HAF program. Anticipated Completion Date: Cash on hand data into biweekly reports and documentation of review said data as part of weekly calls with the subrecipient is being is actively being incorporated as of this response. The State will ensure that the transaction processing memo is updated with the requisite processes and protocols during the next update before the end of Q1 2023. Contact Persons: Chase Hagman, Lisa Cota-Robles, and Michele Zangri-Crean

When the project started, the National Trail Local School District was not fully aware of all needed requirements when using federal grant dollars. At that time, the information and directions had not been clearly issued by the State of Ohio and the District was learning about the uses and regulations when it came to COVID dollars. However, once we were aware we immediately made the needed changes. In the future, the District will put controls in place to address this issue to ensure we properly follow the guidelines when using federal grant dollars.