Corrective Action Plans

Individuals Responsible for Corrective Action Plan: Jason Penegar, Vice President - Controller Nisha Eberhart, Accounting Manager Blanca Ramos, Sr. Manager, Compensation and Benefits Accounting Corrective Action Plan: Management will implement a new quality review process to ensure that correct default fund codes are assigned to staff for the DOL WPY grant. In addition, Management will implement a complete oversight review of all grant time charges in advance of the execution of a drawdown of DOL funds. Anticipated Completion Date: June 30, 2023

Finding 2022-001 ? Major Federal Award Programs Audit a. Comments on the Finding and Recommendation We concur with the auditors finding as follows: During the years ended July 31, 2019, 2020, 2021 and 2022, management did not make the required residual receipts reserve deposit in the amount of $81,489 within 90 days of year ended July 31, 2018, as required by HUD. The residual receipts amount has not been deposited as of the date of this report. b. Action(s) Taken or Planned on the Finding: The residual receipt account will be funded when funds are available.

We are in receipt of the Finding to be Reported by Government Auditing Standards, regarding internal control over compliance and material noncompliance. Management agrees with the finding. The Hospital did not reduce COVID related expenses by amounts reimbursed through patient service revenue in the expense section of the HHS, Provider Relief Funds report. Policy and procedures over accounting of these grant funds will be modified to ensure expenses are reduced by applicable revenues before submission of Provider Relief Fund reports. Caryn Hawthorne, Vice President of Finance/Chief Financial Officer, will submit Period 4 HHS reporting by March 31, 2023. The Period 4 reporting will include lost revenue not previously reported offset by the reimbursed expenses from Period 2.

2022-002 Insurance payments not fully deducted from FEMA funding Cluster: Not applicable Grantor: U.S. Department of Homeland Security Award Names: COVID-19 Disaster Grants - Public Assistance (Presidentially Declared Disasters) Award Year: January 20, 2020 ? July 1, 2022 Award Number: 4496DR-MA Assistance Listing Numbers: 97.036 Pass through entity: Massachusetts Emergency Management Agency (?MEMA?) Management?s Views and Corrective Action Plan Management?s View Management agrees with the Auditors? assessment of the System?s internal controls over compliance specifically related to the estimated third-party insurance deduction calculated for COVID-19 PCR tests administered between March 1, 2020 and June 30, 2021 included with one of the eight FEMA projects obligated during fiscal year 2022. The System calculated the third-party insurance deduction by developing an average third-party insurance payment rate per test. A formula error was present in this calculation. Corrective Action Plan Management will create a formal review process whereby third-party insurance deductions will be verified by an individual other than the preparer as part of the FEMA project workbook submission procedures. As of the date of this report, Management has informed MEMA of the error and discussed with MEMA an alternate methodology to calculate the third-party payment deduction. As a result of the alternate methodology identified, the amount owed back to FEMA in the form of an under-estimated medical payment deduction will be substantially less than the $218,000 in questioned costs noted. These monies will be refunded to MEMA as soon as all parties agree on the amount owed. Responsible Official: Michael Knoll, Executive Director, Financial Planning & Analysis Expected Completion Date: September 30, 2023

3/30/2023 Grant Thornton 10 Almaden Blvd., Suite 800 San Jose, CA 95113 RE: Management?s Corrective Action Plan in Response to Fiscal Year 2022 Item 2022-001 ? Significant Deficiency ? Reporting: Special Reporting 1. Contact person: Syble Allen, Controller 2. Plan of action: The Controller, Director of Institutional Research and Student Accounts Director will all be given copies of the prepared FISAP for review and comment at least 3 days prior to FISAP submission each October 1. 3. Anticipated completion date: This new process will be implemented April 1, 2023.

CORRECTIVE ACTION PLAN December 27, 2022 Valley Community Services Board respectfully submits the following corrective action plan for the year ended June 30, 2022. Name and address of independent public accounting firm: Brown, Edwards & Company, L.L.P. 1909 Financial Drive Harrisonburg, VA 22801 Audit period: June 30, 2022 The findings from the June 30, 2022, Schedule of Findings and Questioned Costs (the "Schedule") are discussed below. The findings are numbered consistently with the number assigned in the Schedule. FINDINGS - FINANCIAL STATEMENT AUDIT If the Federal Audit Clearinghouse has questions regarding this plan, please call Devin Foster, Director of Finance, or Dereck Criner, Director of Human Resources and Interim Chief Financial Officer during the audit period, at (540) 887-3200. 2022-007: Emergency Solutions Grant Program - AL #14.231, Controls over reimbursements and program monitoring (Material Weakness) Condition: The Community Based Services Supervisor is the only person involved with submitting reimbursement requests and monitoring the budget and expenditures for the program. A separate review of reimbursement requests is not performed. The accounting department is not involved with managing the program budgets. Criteria: More than one staff person should be involved for accountability and monitoring of the program. Expenditures used to recognize revenue in accounting should correspond to expenses reimbursed or identified for federal and state award programs. Cause: With turnover in accounting staff during the year, items were not reviewed or monitored for the program. Effect: Errors in reporting or misuse of funding could potentially go undetected due to lack of separation of functions and proper oversight. Recommendation: We recommend implementing internal controls over the reimbursement requests and budget monitoring process by involving another person prior to submitting the request. Additionally, spreadsheets used to track grant awards and program expenditures should be reviewed by someone with an understanding of the program such as the Behavioral Health Director or Assistant Director or accounting. Views of Responsible Officials and Planned Corrective Action: Effective February 2022, all requests for reimbursement under this program are submitted by the fund manager to the program's Assistant Director prior to submission to Accounting. Reimbursement filings are provided to Accounting in a timely manner and a fund reconciliation spreadsheet will be created to share with the fund manager and Assistant Director on a monthly basis. Additionally, Accounting now receives a copy of the submitted reimbursement requires and will be including a review of expenses, requests for reimbursement, and reimbursements received as part of the monthly reconciliation. 2022-008: Emergency Solutions Grant Program-AL# 14.231, Controls over cash management and reimbursement requests (Material Weakness) (Continued) Condition: Requests for reimbursement were not submitted timely, with multiple months submitted 80 days after the expenditure had incurred. Amounts recorded for revenue did not accurately reflect final requested reimbursement. Criteria: Reimbursements should be submitted timely and should be provided and reconciled to financial data in general ledger by accounting team. Differences should be resolved, and reimbursement received should ultimately reflect total program revenue in general ledger. Cause: With turnover in staff during the year, items were not always available timely. In addition, management was not always aware of reporting requirements or aware of activity under program reimbursements. Effect: Errors in reporting could ultimately lead to differences in financial accounting vs program activity. Accurate and timely reporting and requests can improve cash flows and ensure program is able to meet funding needs. Recommendation: Additionally, spreadsheets used to track grant awards and program expenditures should be reviewed by someone with an understanding of the program such as the Behavioral Health Director or another individual in the finance department. These spreadsheets should ultimately identify amounts that were submitted for request for reimbursement and be recorded in the general ledger. Amounts recorded for revenue in the general ledger should agree between the two, with monthly or quarterly reconciliations performed to ensure financial reporting accurately reflects spending and reimbursement activity. Views of Responsible Officials and Planned Corrective Action: VCSB will amend the reconciliations process for CHERP to include a documented review and approval of all expenses, reimbursement requests, and reimbursements received. Additionally, the Accountant and Director of Finance are working with the program fund manager to submit requests for reimbursement in a more timely manner. Sincerely yours, Dereck Criner Director of Human Resources

CORRECTIVE ACTION PLAN December 27, 2022 Valley Community Services Board respectfully submits the following corrective action plan for the year ended June 30, 2022. Name and address of independent public accounting firm: Brown, Edwards & Company, L.L.P. 1909 Financial Drive Harrisonburg, VA 22801 Audit period: June 30, 2022 The findings from the June 30, 2022, Schedule of Findings and Questioned Costs (the "Schedule") are discussed below. The findings are numbered consistently with the number assigned in the Schedule. FINDINGS - FINANCIAL STATEMENT AUDIT If the Federal Audit Clearinghouse has questions regarding this plan, please call Devin Foster, Director of Finance, or Dereck Criner, Director of Human Resources and Interim Chief Financial Officer during the audit period, at (540) 887-3200. 2022-007: Emergency Solutions Grant Program - AL #14.231, Controls over reimbursements and program monitoring (Material Weakness) Condition: The Community Based Services Supervisor is the only person involved with submitting reimbursement requests and monitoring the budget and expenditures for the program. A separate review of reimbursement requests is not performed. The accounting department is not involved with managing the program budgets. Criteria: More than one staff person should be involved for accountability and monitoring of the program. Expenditures used to recognize revenue in accounting should correspond to expenses reimbursed or identified for federal and state award programs. Cause: With turnover in accounting staff during the year, items were not reviewed or monitored for the program. Effect: Errors in reporting or misuse of funding could potentially go undetected due to lack of separation of functions and proper oversight. Recommendation: We recommend implementing internal controls over the reimbursement requests and budget monitoring process by involving another person prior to submitting the request. Additionally, spreadsheets used to track grant awards and program expenditures should be reviewed by someone with an understanding of the program such as the Behavioral Health Director or Assistant Director or accounting. Views of Responsible Officials and Planned Corrective Action: Effective February 2022, all requests for reimbursement under this program are submitted by the fund manager to the program's Assistant Director prior to submission to Accounting. Reimbursement filings are provided to Accounting in a timely manner and a fund reconciliation spreadsheet will be created to share with the fund manager and Assistant Director on a monthly basis. Additionally, Accounting now receives a copy of the submitted reimbursement requires and will be including a review of expenses, requests for reimbursement, and reimbursements received as part of the monthly reconciliation. 2022-008: Emergency Solutions Grant Program-AL# 14.231, Controls over cash management and reimbursement requests (Material Weakness) (Continued) Condition: Requests for reimbursement were not submitted timely, with multiple months submitted 80 days after the expenditure had incurred. Amounts recorded for revenue did not accurately reflect final requested reimbursement. Criteria: Reimbursements should be submitted timely and should be provided and reconciled to financial data in general ledger by accounting team. Differences should be resolved, and reimbursement received should ultimately reflect total program revenue in general ledger. Cause: With turnover in staff during the year, items were not always available timely. In addition, management was not always aware of reporting requirements or aware of activity under program reimbursements. Effect: Errors in reporting could ultimately lead to differences in financial accounting vs program activity. Accurate and timely reporting and requests can improve cash flows and ensure program is able to meet funding needs. Recommendation: Additionally, spreadsheets used to track grant awards and program expenditures should be reviewed by someone with an understanding of the program such as the Behavioral Health Director or another individual in the finance department. These spreadsheets should ultimately identify amounts that were submitted for request for reimbursement and be recorded in the general ledger. Amounts recorded for revenue in the general ledger should agree between the two, with monthly or quarterly reconciliations performed to ensure financial reporting accurately reflects spending and reimbursement activity. Views of Responsible Officials and Planned Corrective Action: VCSB will amend the reconciliations process for CHERP to include a documented review and approval of all expenses, reimbursement requests, and reimbursements received. Additionally, the Accountant and Director of Finance are working with the program fund manager to submit requests for reimbursement in a more timely manner. Sincerely yours, Dereck Criner Director of Human Resources

As a result of COVID-19 and the unanticipated school closure the Food Service Fund had an increase in funding that was unexpected. As a correction action the Superintendent, Business Manager and Food Service Director will meet on a quarterly basis to review the Food Service budget and monitor the spend down plan.

Item No. 2022-003 ? Cash Management and Reporting Material Noncompliance Material Weakness in Controls Over Compliance Responsible Party: Brian Lim Financial Services Specialist II HCSA Office of the Agency Director Corrective Action Plan: In meetings with the State, HCSA has clarified that encumbrances were submitted as part of the expenditure reporting and claiming and the State has expressed awareness of this reporting and claiming practice, but to date, HCSA has not been able to obtain documented confirmation that permitted reimbursing HCSA for encumbered amounts. HCSA will take measures to adjust monthly expenditure reports within the Spend Plan and include in the next soonest reporting and claim period actual expenditures, and revisit grant award provisions pertaining to reporting requirements to ensure that both the reports and the claims are prepared using the appropriate basis of accounting. HCSA will resolve with CDPH previously claimed encumbrances and ensure alignment with expenditure reporting requirements and claims for reimbursement requirements. Anticipated Implementation Date: June 30, 2024

Finding 2022-005: Material Weakness over Cash Management and Allowable Costs - Review of Cash Drawdowns Information on the Federal Program: Department of Human and Health - Center for Disease Control: Improving Epilepsy Programs, Services and Outcomes Through Partnerships. Finding: The Uniform Guidance requires organizations to establish internal controls to detect potential noncompliance. The Uniform Guidance also requires organizations who receive funds on a cost reimbursement basis to only draw down funds for allowable expenditures under the grant. Management has an established control in place, in that the VP of Finance reviews the calculation of expenditures not drawn down prior to the submission of the drawdown request. However, the control was ineffective to prevent and detect an erroneous expense journal entry, considered an unallowable expense and is an instance of noncompliance, from being included in the drawdown. Planned Corrective Action: A corrective action was taken and the Foundation returned the funds drawn down to the Department of Treasury. The Foundation has implemented an additional confirmation process where reimbursable expenses will be reviewed along with the draw down prior to draw down. This additional step will ensure that erroneous coding does not result in a funds draw down. Name and Person Responsible: Caro Marie Brown (Senior Director of Finance), June Nolan (Accounts Payable Accountant), and Lindey Camerata (Controller). Anticipated Completion Date: February 2023.

Purchase needed equipment

Views of Responsible Officials and Planned Correction Action: The Grants and Business Departments have worked together to create a process with appropriate checks and balances regarding moving expenses across individual grants and major funds. This process will consist of multiple levels of approval and specific documentation. Any entries will be processed in a timely manner and all expenditure reports will be checked for errors monthly. This process will ensure that expenditure reports are accurate at the time they are submitted for reimbursement.

Views of Responsible Officials and Planned Correction Action: The Grants Department was approved by the Nevada Department of Education to submit RFRs on a quarterly basis in FY23. The Grants Department has followed this approval and submitted all requests by the 15th day of the month following the quarter-end.

Management?s Response to 2022 Audited Financial Statements Findings and Corrective Action Plan: Rural Resources Community Action agrees with the findings reported and has identified corrective action to rectify the findings. The Chief Financial Officer (CFO) understands the importance of recording all revenue and deferred revenue to ensure accurate financial accounting and reporting. The Organization has acquired an accounts receivable module for their accounting software to record accounts receivable monthly. The CFO will be reviewing financial records to make sure all revenue and elimination of intercompany transactions are recorded.

Corrective Action Plan: The organization is implementing new software for tracking client expense, which has functionality to import copies of credit card receipts and check requests into each client?s record. We have emphasized to case managers the importance of keeping receipts. Reasonable completion date: June 1, 2023 Responsible Party: Tanya DeWolf, Director of Refugee Services

Certain matters were brought to our attention as a result of the audit process. These are described more fully in the Schedule of Findings and Questioned Costs. We evaluated the matters noted below, and have described our planned actions as a result. 2022-001 - Program Income - Food Service Fund Balance Management Assessment - We concur with the audit assessment regarding this matter. Planned Corrective Action - The District is aware of the USDA fund balance requirements. The District operated under the Seamless Summer Option during fiscal year 2021-22 which allowed all of our students to eat both breakfast and lunch for free. The District received a large amount of federal funding which in turn resulted in more fund balance than allowed by USDA at 6/30/2022 ($5,466). The Food Service Director and Business Manager are in the process of creating a spenddown plan to be submitted to MDE which will move fund balance within an allowable range. Responsible Party - Business Manager Date of Planned Corrective Action - June 2023

Corrective Action Plan Fiscal Year September 30, 2022 2022-01 Condition:In a sample of 40 centers reimbursement requests 25 of 40 centers, which represents 40 of 112 centers filing claims in fiscal year 2022 with the Sponsor, the period between the last monitor visit of fiscal year 2021 and the first monitor visit of fiscal year 2022 exceed six months. Management response:Management had a decrease in staff due to Covid and had fewer monitors available to complete the monitor visits. Corrective action taken: Management has increased the staff to complete the monitor visits within the required time to avoid a six (6) month lapse between monitor visits of sites. In addition Management has created a software program of the schedule of all Centers to notify Management of the days left prior to a six (6) month lapse. The software will give an alert of the number of days remaining for each Center before it reaches the six (6) months and allow Management to facilitate the timely scheduling of monitor visits.

Finding 2022-002 ? Cash Management ? Pass-Through Entities Condition: Texas Biomed did not provide evidence of effectively designed internal controls to ensure subrecipients are paid by Texas Biomed within 30 days of requests for reimbursement received by Texas Biomed. Texas Biomed paid 2 of 23 subrecipients after 30 days of receipt of the request for reimbursement from the subrecipient, resulting in noncompliance with 2 CFR 200.305(b)(3). Corrective Action Plan: Texas Biomed will implement a more effective operating procedure for subrecipient invoice approval and timely payment that will include timeline expectations for the initial approval request to the applicable principal investigator upon receipt of invoices from the subrecipient, timeline for following-up with the principal investigator on approval requests, timeline and direction for seeking proxy approval if the principal investigator is unavailable or unable to provide a timely response, and timeline for entering the subrecipient invoice in Texas Biomed financial systems facilitating payment upon approval. Responsible Parties: Eduardo Meza, Director, Sponsored Programs Administration Completion Date: June 1, 2023

Finding Number: 2022-003 ? Reporting Name of Contact Person: Tamara Colden, Assistant Director Housing and Community Services Department Corrective Action: A new administrative staff position was added in Fiscal Year 2022-2023 that is is now responsible for submission in EARS to address timeliness issues. Management staff will take the following steps to ensure new staff are aware of policies established for continued commitment to timeliness: 1. Management staff will review current established timelines with staff responsible for submitting reports including reminders. Proposed Completion Date: 06/30/2023

2022-002 Ineligible Expenditures Federal Program: Housing Choice Voucher Program, CFDA No. 14.871 Criteria: All payments must be eligible items under federal guidelines. Condition: During the fiscal year ending June 30, 2022 CARES Act funds were used to provide funds to the board members. Each board member was provided a check in the amount of $2,500. Two of the board members returned their check prior to cashing them once they found out it was not allowed. Questioned costs: $5,000. Effect: Payments were made that are not allowable under HUD of federal guidelines. Cause: PHA was not aware of the limitations in place for payments made to board members. Repeat Finding: This finding was reported in the prior audit as item 2021-002. Recommendation: Reimbursement for the payments should be made to the Housing Authority. Views of responsible officials and planned corrective actions: We have begun the process of reimbursing the amounts paid to the board members and will refrain from making these payments in the future.

Views of responsible officials and planned corrective actions: The Organization agrees with this finding. The Chief Financial Officer will prepare the required reports and the Executive Director will review the grant terms and conditions and the draft of the required reports before approving the submission of the required reports.

Federal Grantor: United States Department of Health and Human Services, Health Resources and Services Administration (HRSA) Assistance Listing No.: 93.461, COVID 19 HRSA COVID 19 Claims Reimbursement for the Uninsured Program and the COVID 19 Coverage Assistance Fund Management agrees with this finding and performed a review of claims submitted to the HRSA COVID 19 Uninsured Program identifying payments for ineligible services and refunded the entire overpayment amount. In March 2022, HRSA announced the discontinuance of the HRSA COVID 19 Uninsured Program, and therefore, remediation of internal controls is no longer applicable. Paula Yarbrough, VUMC Director ? Grants and Contracts, will be responsible for implementation by fiscal year-end 2023.

CORRECTIVE ACTION PLAN (CAP): 1. Explanation of Disagreement with Audit Finding There is no disagreement with the audit finding. 2. Actions Planned in Response to Finding Administration will ensure sufficient backup documentation is available. 3. Official Responsible for Ensuring CAP The Executive Director is responsible for ensuring corrective action of the deficiency. 4. Planned Completion Date for CAP The planned completion date for the CAP is immediate. 5. Official Responsible for Ensuring CAP The Board of Education will be monitoring this CAP

HFP Views of Responsible Officials - Hope for Prisoners’ CEO presently reviews and approves all RFR forms in writing prior to submission. Oversight by specific board members will be provided through a review of the submitted RFR to compare it to the monthly financial reports already being provided.

The City has identified federal grants subject to the Uniform Guidance and will develop written procedures to implement the requirements of 2 CFR § 200.305 Payment.