Corrective Action Plans

Corrective Action Plan: The Department will evaluate its existing cash management control procedures to reasonably ensure all federal draw requests are disbursed timely and are drawn only for immediate cash needs, including process improvements to monitor and prevent noncompliance with the cash management requirements. Anticipated Completion Date for Corrective Action: June 2023 Contact Person Responsible for Corrective Action: Deckard Stanger, Chief Fiscal Officer, Ohio Department of Mental Health and Addiction Services 30 East Broad Street, Columbus, Ohio 43215 Phone: 614-752-8367, E-Mail Address: Deckard.Stanger@mha.ohio.gov

Cash funds for the food service program were in excess of the allowed 3 months average expenditures by $519,240. The District will review their current needs for equipment, charges for student meals, etc. and develop a plan for the reduction of cash balances in the lunchroom fund during the current year ended August 31, 2023.

Planned Corrective Action - UESF hired a new Director of Finance for more accurate nd timely reporting. UESF's management plans to acquire additional staff to assist with accounting. Training of Fiscal and operational staff regarding actual time charged will begin in July 2023. All work is reviewed by the Director of Finance and monitored by the Executive Director. Person Responsible - UESF's Executive Director John Rowe. Timing The new Director of Finance was hired in April 2023. Regarding the additional staff the hiring process has begun with proposed additional staff projected to be on board in September 2023. The process to improve accuracy and timeliness will be completed in December 2023. The Executive Director will monitor the process, preparing formal quarterly documentation beginning July 2023.

UNITED STATES DEPARTMENT OF AGRICULTURE Child Nutrition Cluster ? 10.553/10.555/10.559 Corrective Action Plan ? Noncompliance with Reporting Requirements Finding No.: 2022-003 Condition: The District has inadequate controls over reviewing and approving child nutrition monthly ?claims summary? forms. Plan: The administrative assistant will prepare the ?claims summary? forms by obtaining the number of meals served directly from the Manual ?Meal Count Edit Form?. The Superintendent will also review the "claims summary" forms and supporting documentation for accuracy prior to the electronic submissions. Corresponding documents will be manually signed and dated to indicate approval. Anticipated Date of Completion: January 1, 2023 Management Response: The District intends to implement the recommendations in FY 2023. Name of Contact Person: Jon Julius, District Superintendent (P): 217-932-2184

Recommendation: Training of staff should be performed to bring the staff up to date with the implementation of all residual receipts compliance requirements. Action Taken: The Organization will request approval from HUD to pay back the excess residual receipt balance.

Child Nutrition Cluster Reporting Child Nutrition Cluster ? Assistance Listing No. 10.553, 10.555, 10.559 Recommendation: CLA recommends the District implement a review procedure over reimbursement requests where someone other than the preparer reviews the claim to ensure counts agree back to supporting documentation prior to the reimbursement request being filed with the granting agency. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We continue to look for ways to segregate duties and will implement a review procedure for reimbursement requests. Name(s) of the contact person(s) responsible for corrective action: Lisa Miller Planned completion date for corrective action plan: Ongoing

Corrective Action Plan: A comprehensive review of the agency?s policy for federal drawdowns was completed in March 2022 and a revised drawdown process was created and implemented. The new process utilizes the VAP-0009 Unpaid Vouchers BI Cognos report to determine the amount needed to be drawn for each individual grant. This new procedure allows for reconciliation of the amount needed to be drawn (unpaid) to the revenue deposit. If the Unpaid Vouchers report (VAP-0009) total for each grant does not match the requested drawdown, documentation will be provided on the backup documentation explaining the variance. In most cases, the variance is due to a refund received which reduces the amount needed to be drawn. Procedures have been updated to reflect these changes. Anticipated Completion Date for Corrective Action: Completed Contact Person Responsible for Corrective Action: Jennifer Biedenharn, Chief Financial Officer, Ohio Department of Development 77 South High Street, 27th floor, Columbus, Ohio, 43215 Phone: 614-995-4030, E-Mail Address: Jennifer.Biedenharn@development.ohio.gov

Corrective Action Plan: 1. For one of 60 (1.7%) regular Unemployment benefit payments selected for testing, the claimant was paid FPUC benefits of $300 a week for several weeks of benefits which were already paid in state fiscal year 2021. As a result, we will question all duplicate FPUC payments made to this claimant during the audit period, totaling $4,800. a. A defect has been documented and an application development project will be created to remedy the concern. It will be prioritized amongst all of the other efforts currently in progress or planned for OJI. Timelines associated to the remediation is currently unknown. We currently don?t understand the root cause problem and what it will take to resolve it. 2. For eight of nine (88.9%) regular Unemployment benefit claims identified in an OJI system data match as potentially exceeding the maximum allowable amount per week, the claimants were paid $300 in FPUC benefits twice during the same benefit week. As a result, we will question costs for all FPUC payments over the allowable amount to these claimants during the audit period, totaling $17,640. a. A defect has been documented and an application development project will be created to remedy the concern. It will be prioritized amongst all of the other efforts currently in progress or planned for OJI. Timelines associated to the remediation is currently unknown. We currently don?t understand the root cause problem and what it will take to resolve it. 3. Two of two (100%) PUA claims identified in a uFACTS system data match exceeded the maximum allowable number of weeks (79): one by four weeks and the other by two weeks. As a result, we will question the PUA payments exceeding the maximum allowable number of weeks, totaling $1,656. a. A process adjustment has been made to ensure that when adjusting claim for proper payment, that we overpay the appropriate weeks as well. In some cases, that didn?t take place. This was a problem that was quickly identified, and a new process was created to deter this from happening again. We missed the correction on claim, and we have adjusted it. From a system perspective, if previous weeks are subsequently reversed back to paid, causing weeks to be over 79, a process will be identified to potentially mitigate the adjustment. 4. For eight of 60 (13.3%) PUA / FPUC payments selected for testing, the claimant was not eligible to receive benefits for the weeks claimed, was overpaid, or was underpaid, as follows: a. The finding for overpaid or underpaid claims was due to the tsunami of claims/workload the agency faced during the Pandemic as well as unknowledgeable new hires brought on to assist with the massive workload. At this time initial benefits adjudication is timely in its workload however we are still facing a high backlog of cases which have alleged fraud. Benefits adjudication will process claims after a thorough fraud review has been completed. Due to the backlog all of these cases will be late and have a possible under or overpayment. The benefits adjudication team will have any cases/determinations made within 21 days of receipt from BPC fraud dept. Anticipated Completion Date for Corrective Action: June 2024 Contact Person Responsible for Corrective Action: Valerie Shuster, Field Operations District Coordinator, Ohio Department of Job and Family Services 209 West 4th Street, Lorain, OH 44052 Phone Number: 440-244-7802, E-Mail Address: Valerie.Shuster@jfs.ohio.gov

Corrective Action Plan: The following actions will be taken: ? Work with the Ohio Department of Rehabilitation and Correction to obtain more accurate incarceration dates. Currently we are not receiving the dates the claimant is incarcerated in a facility. We are currently receiving their expected release date which does not meet the needs of the office. ? We do not believe there is a need to work with the Department of Health as there has been no discrepancy with the accuracy of the data provided. ? We will create a process to create a weekly review file and save those results for review and evaluation purposes for both death and incarceration records. ? We will create a procedure to investigate the results of the death and incarceration files consistent with our existing procedures to investigate similar situations. Anticipated Completion Date for Corrective Action: January 2024 Contact Person Responsible for Corrective Action: Carl Prideau, Section Chief-BPC, Ohio Department of Job and Family Services 30 East Broad Street, 38th floor, Columbus OH 43215 Phone Number: 614-644-5164, E-Mail Address: Carl.Prideau@jfs.ohio.gov

2022-003 Finding 1. Correcting Plan Monthly meal counts will be calculated in a spreadsheet and the monthly meal counts will be reviewed by someone other than preparer before it is submitted for reimbursement. 2. Explanation of Disagreement with the Audit Findings There is essentially no disagreement with the finding. 3. Official Responsible for Insuring CAP The Superintendent, Todd Selk, is responsible for carrying out the corrective action plan. 4. Planned Completion Date for CAP Immediately 5. Plan to Monitor Completion of CAP The superintendent will monitor completion of the CAP, with reports to the Board of Education, on an annual basis.

Corrective Action Plan: The Ohio Department of Job and Family Services (ODJFS), in coordination with the Ohio Department of Medicaid (ODM), the Department of Administrative Services (DAS), and our vendor teams will continue to work to address system design weaknesses by identifying and prioritizing system changes and updates that impact eligibility determinations and benefit amounts as well as alert volume and processing improvements. Weekly problem review meetings will continue to be held to identify reported system issues and track any needed updates through the normal prioritization and slotting process. These changes will be delivered according to the agreed upon release cadence based on business priority and impact. Upon delivery of such system changes, the team will monitor production to determine if the desired outcome was achieved. ODM and ODJFS continue to meet to analyze the alerts in Ohio Benefits and the group presents recommendations to our vendor team for overall system alert improvements; these recommendations were prioritized and corrected in our normal release cadence through calendar year 2022, with the most recent release occurring in February 2022. The next alert centered release is scheduled for April 2023. Comprehensive alert reduction efforts thus far have reduced the overall ~29 million backlog alerts and drove a ~22 million annual reduction in new arrival of alerts. A system release specific to IEVSs enhancements is planned for R4.6.1 (April 2023) which will streamline the process for county staff to process IEVS matches from the IRS Unearned Income interface. There will be both E-Verify enhancements and a change in the match logic which will result in a reduction in the volume of IRS records that are flagged as IEVS matches. Caseworker time spent on processing IRS IEVS matches is expected to reduce; remaining time spent on IRS IEVS matches is expected to have more value by allowing caseworkers to focus time on matches with an eligibility impact or potential for benefit recovery. Periodic and timely review of IEVS will be completed as follows: ? Each state Fraud Control Specialist is assigned designated county agencies to provide technical assistance and training, as well as to monitor certain reports to ensure compliance with state and federal regulations. The counties will be monitored monthly and those not showing improvement will be offered training and technical assistance as appropriate. When a Fraud Control Specialist notices a county agency falling short of a required threshold, contact is made with county officials and the offer of assistance will be made. Once the number of alerts becomes manageable by the county agency, a Continuous Improvement Plan (CIP) may be required of the county agency if the issue continues over a four-month period of continuous contact and assistance. This type of CIP may be initiated outside the scope of Fraud Control Triad Review. ? The Fraud Control Section will conduct follow-up on Continuous Improvement Plans (CIPs) as part of the Triad Review process. When the county agency responds with a CIP, it is reviewed for clarity, action, and desired outcomes. Once approved, the Fraud Control Section will issue a closure letter for the Triad Review; however, a CIP may remain open for a longer period of time if warranted. We are in the process of creating a procedure and a closure letter for CIPs alone. This procedure will be implemented by June 30, 2023. ? Supervisory Reviews are monitored as part of the Triad Review process. Currently, the question is posed to the county supervisor about conducting random supervisory reviews. We are in the process of creating a procedure within the Triad Review process to be provided a list of IEVS matches that were reviewed by the supervisor. This procedure will be communicated statewide through the Fraud Control Training Program and enforced and verified during the Triad Review process.To continue to support the county caseworker staff, the Ohio Benefits Program provides training materials and promotes ongoing learning about related business processes without requiring in-person training. For each major system release or system enhancement that impacts the end user, updated training materials are produced and disseminated. These materials may take the form of job aids that are posted to the project website, train-the-trainer sessions, and video conferences where system users can ask live questions about the system. In addition to system support and training, the Ohio Department of Job and Family Services (ODJFS) in coordination with the Ohio Department of Medicaid (ODM) continue to provide the following methods by which training and system guidance is provided to CDJFS employees: 1. New Worker Training (NWT): A 12-week, comprehensive Policy and Systems training for new users (or refresher training for existing users) in the Ohio Benefits Worker Portal (OBWP) has been developed. The courses cover Policy and Systems overview, TANF, SNAP, Cash and Case Maintenance, along with the primary Medicaid programs (MAGI & ABD). The training is comprised of multiple, self-guided, Web Based Training (WBT) modules and virtual Instructor Led Training (vILT) sessions that provides `hands on? instruction. 2. Monthly Statewide County Conference: Monthly statewide webinars to cover general OFA updates for SNAP and Cash. These meetings include OFA?s Policy and TA staff, Outcomes and Analysis, Data Reporting, Quality Control, Automated Systems Training and the OB-IMS Help Desk. All areas share information on both refresher topics and emerging policy as well as systems issues where additional training is needed. The meetings are facilitated by the Program & Policy Services area within the Policy section of OFA and provides input on issues needing additional training and guidance. AST provides copies of job aids and other training documents during these support meetings. Recording of statewide training sessions are made available for counties to access on demand. 3. Operational Support Webinars: Bi-weekly webinars are delivered jointly by ODJFS and ODM, to counties for systems-based information and instruction on emerging topics and training related issues. Topics for the webinar are identified through a coordinated effort with the OB-IMS Help Desk, the weekly PBI/Defect Closure meetings and On Demand System Inquiries (received via email), to review any issues or concerns discovered by the Help Desk during the previous week. Counties are also able to submit questions and request topics in advance of the webinars to be reviewed and covered as part of the webinar agenda. 4. Ohio Benefits System Release Webinars: These are delivered jointly by ODJFS and ODM to inform counties about updates and enhancements made in each Ohio Benefits system release. During these webinars, counties are provided information regarding proper systems operation based on the items included in the release and target items that no longer require a workaround by the county worker. 5. Job Aids Available on the Innerweb: Automated Systems Training (AST) routinely provides systems-related job aids for county use that target specific topics and pain points for the counties. On the average, one to two new job aids are either created or updated each week and the Innerweb training pages are routinely referenced during New Worker Training, Operational Support, and Ohio Benefits system release webinars. 6. Quarterly Regional County Operational Support Meetings: Both the Automated Systems Training (AST) and the OB-IMS Help Desk participate in these regionally based, quarterly meetings, along with ODM Operations, Systems, and Policy staff. They provide guidance and system instruction on emerging systems issues and/or where additional training is needed. The meetings are facilitated by the Program & Policy Services area within the Policy section of OFA and provides input on issues needing additional training and guidance. AST provides copies of job aids and other training documents during these support meetings. 7. Quarterly Work Activity Round Table Meetings: Automated Systems Training (AST) and the OB-IMS Help Desk participate in these regionally based, quarterly meetings to provide guidance and system instruction related to TANF Work Activities. The meetings are facilitated by the Outcomes & Analysis area within the Policy section of OFA and provides input on issues needing additional training and guidance. 8. On Demand Systems Inquiries: Automated Systems Training (AST) maintains an email box where counties can submit inquiries about correct data entry and system functionality within the OBWP. Timely responses are provided to these inquiries frequently providing Help Desk confirmed instructions in a timely manner. Many of these inquiries are shared at the meetings and communications channels listed above. 9. System Support for Targeted Policy Training: Automated Systems Training (AST) provides system related content to support targeted Policy training topics to provide a holistic view of the application of policies within OBWP. The targeted training is delivered via virtual meetings and/or WBT modules. Some topic examples include `Expedited SNAP,? `Delayed Processing? and `Early Denial.? Recording of statewide trainings are made available for counties to access later.Interagency Agreement An Interagency Agreement is entered into by the Ohio Department of Job and Family Services (ODJFS) and the Ohio Department of Administrative Services (DAS). This Agreement is entered into for the purpose of setting forth the roles and responsibilities, budget methodology and payment terms, data sharing restrictions, security protocols, and compliance requirements for the Ohio Benefits Program. DAS and ODJFS has completed extensive policy, program, and legal reviews and the final Agreement is in circulation to secure DAS and ODJFS Director?s signatures.

Allowable Costs ? COVID 19 Federal Emergency Management Agency Disaster Grants ? Public Assistance, Assistance Listing Number 97.036, Department of Homeland Security Condition A cost item was submitted twice within the applications of FEMA funds and funded by FEMA. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding. FEMA was notified about the cost item and provided the College with instruction related to the return of funds. In addition, all future applications will be reviewed by a second staff member to prevent submission of a duplicate item. Responsible Official: Kathleen McGuire, Vice President for Financial Services Expected Completion Date: December 1, 2022 Summary Schedule of Prior Audit Findings None noted.

Finding No.: 2022-002 Condition: The District's expenditure report filed for June 30, 2022 included expenditures paid in August 2022. These amounts were not reported as committed or obligated. Plan: Grant expenditure reports will be prepared on the cash basis and obligations reported. The liquidation of the obligations will be reported on subsequent liquidation reports. Anticipated Date of Completion: June 1, 2023 Name of Contact Person: Dale Heidbreder, Superintendent Management Response: There is no disagreement with this finding and management will monitor all future federal reimbursement requests. Committed and obligated expenditures will be reported appropriately, and will be paid within 90 days after project completion.

Finding 2022-002 The reimbursement requests, final reports, specific charges and approved budget amendments/appropriations were not always supported by or in agreement with School District workpapers. The Business Office and the Curriculum Office will work together to promote accuracy in reporting. School Business Administrator 2022-2023 fiscal year

Corrective action plan: Management is implementing a job/cost time and labor system as part of the current Paylocity system currently in place. This new time tracking system will allow individuals working directly on contracts to record time spent on grants on their individual weekly timecards. This system will allow management to report time spent by person by contract within our current payroll and financial system. This enhancement will not be in place until January 2023. In the meantime, management has formalized a quarterly manual review process to document actual time spent per employee per contract along with any needed adjustments to allocation percentages. Personnel responsible for corrective action: Stephanie Cawby, Senior Accountant and Alex Laprade-Velasco, Financial Analyst Estimated corrective action completion date: December 2022 ? Manual quarterly review of contract time spent and adjustments. January 2023 ? Implementation of Paylocity Job Cost Time tracking and roll out to employees

Finding Reference Number: 2022-001 and 2021-001 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 totaling $88,064 were accrued to submit to HUD. Completion Date: January 20, 2023

See Corrective Action Plan for chart/table

Finding 2022-001 Federal Agency Name: Department of Homeland Security, State of Idaho Office of Emergency Management Program Name: Disaster Grants ? Public Assistance CFDA # 97.036 Finding Summary: Administrative labor costs were claimed for reimbursement that fell outside the period of performance of the federal award in two instances. In addition, one instance in which the Cooperative submitted a material cost for reimbursement that was not used in the project. Responsible Individuals: Reed Christensen Corrective Action Plan: Management revised its procedures to ensure a review of labor hours submitted in the future for FEMA-reimbursed projects in order to ensure the labor hours submitted fall more precisely within the Federally specified timeframe of the disaster declaration. As it concerns material cost reimbursements, in the future the work order will be reviewed and reconciled to the ?pick list? quantities. This has also been added to our FEMA-related work procedure. Anticipated Completion Date: March 30, 2023

Finding Number: 2022-001 Planned Corrective Action: Mid-East's Adult Education Financial Coordinator retired at the end of Fiscal Year 2021. As any new position, there was a learning curve and the new Financial Aid Coordinator received limited training with the former Coordinator. Consultants were hired to help, but this specific reconciliation process was not discussed. There has been a recent change in the Adult Education Director's position, and it is the intention of the new Director to eventually cross-train positions. This will assist in the future for a smoother transition between employees leaving and new employees hired. Since the finding, the Adult Education Financial Coordinator has established a checklist of items that need to be completed for each drawdown. This checklist will be placed in each drawdown folder. The Monthly Drawdown Reconciliation plan will include beginning with verifying with Common Origination and Disbursement Center (COD) School Summery report prior to the disbursement. Once the disbursement information is entered into Ed-Express and transferred to COD for the month review of the School Summary report, it will be reviewed to verify that the "Cash>Net Accepted & Posted Disbursements" matches the Achademix Drawdown Batch. Then, again when the disbursement funds are disbursed, a review of the COD School Summary report will occur. At any time, if a variance occurs, it will be addressed immediately. This plan of action went into place with the February 17, 2023 disbursement process. All documentation of any reconciliations will be kept in each drawdown file. The variance of the $866.00 occurred during the final drawdown of Fiscal Year 2022. As the reconciliation process was not in place, the variance was not discovered. As a new Fisca Year started, it was a new batch of funds, and the $866 variance was not discovered until the audit process. The variance was researched and corrected. The correction was located and corrected in Ed Express and had no monetary effect. The School Summary report from COD Cash>Net Accepted & Posted Disbursements" is at zero for 2021-2022, and documentation has been kept on that. The newly implemented checklist and process for reconciliation will prevent variances from happening in the future. Anticipated Completion Date: Currently in place and will continue. Responsible Contact Person: Thasia Shilling, Adult Education Financial Aid Coordinator

Trackers have been created to updated as expenses have been occurred to tie back to quarterly reports submitted. Quarterly reports and support will be reviewed by someone other than the preparer as well for assurance that figures are represented appropriately.

2022-006 Higher Education Emergency Relief Fund (HEERF) ? Cash Management Recommendation: We recommend that the College review their policies surrounding federal grants and ensure a review process is in place to ensure that all necessary compliance requirements are met. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Reporting will be reviewed for compliance and accuracy by FA Solutions, the student accounts coordinator, student aid coordinator and VP of Student Services. Name(s) of the contact person(s) responsible for corrective action: Mariel Lee, Melissa Hennessy, Shannon Stoughton and Matt Payne Planned completion date for corrective action plan: This change will take place immediately.

Federal Award Findings Finding 2023-003 Late Reporting and Noncompliance with Reporting Requirements Name of Contact Person: Nancy Shewfelt, Business Manager Corrective Action Plan: YFSD has hired a new grant director to manage all grants. She is devising systems and timelines to streamline the process and submit in a timely fashion. Once this is in place, we will be compliant. Proposed Completion Date: Implemented July 1, 2022

Condition: The Pennsylvania Department of Revenue requires Reconciliation of Cash on Hand Quarterly Reports for any program for which they are receiving monthly payments. These quarter reports are due the 10th working days of January, April, July and October. The Pennsylvania Department of Education requires annual final expenditure reports to be filed documenting the financial transactions of each grant. The final reports are due within 30 days after the funds are expended but no later than 30 days after the ending of the date of the project. Districts are required to have appropriate controls over the accuracy of preparation and timely filing of final expenditure reports. Views of Responsible Officials and Planned Corrective Actions: The District Business Manager will work with all involved in the process of the Federal Grants filing the expenditure reports quarterly and filing of the final expenditure reports. Procedures will include creating a calendar with the due dates, reporting the expenditures in the accounting software and creating a report with the expenses listed for the month and quarterly. Account numbers will be created according to the PDE accounting manual for the recording of all expenses. The person responsible for the corrective action plan will be the business manager and the anticipated completion date will be June 30, 2023.

2022 ? 008 Reporting (Significant Deficiency and Noncompliance) Management Response: The City agrees with the finding. The City will implement controls to ensure compliance with federal financial management regulations. The City recognizes that it needs to improve its procedures for preparing quarterly report for Treasury funds. Going forward, the Family and Community Services Department will work with the Grants Section to develop and implement standardized procedures for identifying and documenting expenditures, and for reviewing quarterly reports prior to submission. Timeline and Responsible Position: June 2023 ? City Controller/DFAS Deputy Director and Director of Family & Community Services

Finding: 2022-002 Federal Agency Name: Department of Health and Human Services Program Name: COVID-19 HRSA Claims Reimbursement for the Uninsured Program and the COVID-19 Coverage Assistance Fund Federal Financial Assistance Listing #: #93.461 Finding Summary: Audit testing identified one instance in which health services provided to a patient were reimbursed under the federal program, and the health services provided did not meet the terms and conditions of the federal program. Through the coding process, an incorrect diagnosis code was included in the system, and therefore, the patient?s health services flowed into Monument Health?s Uninsured Program workflow which resulted in $3,563 of health services being reimbursed under the federal program. As part of the audit, a sample of 60 patients were selected for testing, accounting for $1,659,497 of $4,344,728 of monies received from the federal agency. Responsible Individuals: Austin Willuweit, Vice President of Finance Jen Schmaltz, Corporate Controller Corrective Action Plan: Monument Health will develop a review process to identify claims that could have a diagnosis coding issue. A return of any excess reimbursement will be completed. Anticipated Completion Date: June 30, 2023