Corrective Action Plans

Segregation of Duties Supportive Housing for the Elderly – Assistance Listing No. 14.157 Recommendation: The Project should continue to evaluate its staffing in order to segregate incompatible duties whenever possible. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The board of directors will continue to closely monitor the financial operations of the Project. Name(s) of the contact person(s) responsible for corrective action: Mary Gilberts, Management Agent Planned completion date for corrective action plan: June 2025

#2024-002 – Material Weakness – Eligibility Coronavirus State and Local Fiscal Recovery Funds, ALN #21.027 Recommendation We recommend verifying each applicant’s enrollment status with all universities prior to disbursement of scholarship funding. View of responsible officials and planned corrective action The Foundation receives information directly from PASSHE universities to verify enrollment status of applicants. Universities submit information to the Foundation on an electronic form, which includes Student Name, Student ID, Scholarship Amount, Student Enrollment Status, etc. Authorized officials enter their approval by changing “Pending Review” to either “Scholarship Eligible” or “Not Eligible” on the form and keying in the scholarship amount the student is eligible for based on their verified enrollment status, for example: $1,000 for a part time student or $2,000 for a full-time student. For 4 of the 40 applicants sampled during the audit, a PASSHE university created an inconsistency on the form, having not completed or updated the enrollment status column to be consistent with the final amount they verified approved for payment. The key control, i.e. the University’s entry and approval of the eligible amount, prevented any errors from occurring. The Foundation verified the enrollment status for the four applicants identified in the audit, noting that the scholarships were properly disbursed. Going forward the Foundation has updated its verification process with the universities to ensure proper classification of the applicant’s enrollment status is verified in accordance with the eligibility requirements of the grant.

Plan: A second staff member will review certifications and annual certifications to ensure accuracy based on the required back up documentation. Contact: Christina Morin, Program Director. Anticipated completion date: September 1, 2025.

Inaccurate Enrollment Reporting to National Student Loan Data System (NSLDS) Planned Corrective Action: To ensure that both accurate and timely enrollment reporting is transmitted to the National Student Loan Data System (NSLDS) an NSC / NSLDS enrollment confirmation process will be established and implemented by Student Financial Services. For official withdrawals, an additional processing step will be added to the SFS Withdrawal Tracker. The Student Financial Services rep will confirm that the correct withdrawal date has been accurately reported to the National Student Clearinghouse (NSC) by the Registrar’s office and then correctly transmitted to the National Student Loan Data System (NSLDS). If the reported enrollment date does not align with the Last Date of Academic Related Activity, the SFS Representative will notify either the Director of Student Financial Services (Michelle Baker) or the Chief Student Finance Officer (David Burney) to manually adjust the dates in NSLDS. The SFS office will then notify the Registrar’s office that the dates have been manually updated. For unofficial withdrawals, if a student is identified as an unofficial withdrawal (e.g. lack of attendance in a course resulting in an R2T4 calculation being performed) once the withdrawal list has been reported at the end of each semester by the Registrar’s office, the Student Financial Services Representative will confirm that the correct withdrawal date has been accurately reported to the National Student Clearinghouse (NSC) by the Registrar’s office and then correctly transmitted to the National Student Loan Data System (NSLDS). If the reported enrollment date does not align with the Last Date of Academic Related Activity, the SFS Representative will notify either the Director of Student Financial Services (Michelle Baker) or the Chief Student Finance Officer (David Burney) to manually adjust the dates in NSLDS. The SFS office will then notify the Registrar’s office that the dates have been manually updated. Person Responsible for Corrective Action Plan: David Burney, Chief Student Finance Officer Anticipated Date of Completion: Implementation of process will begin 9/30/2024

Completed corrective action: Manager completed correction and new HUD 50059A recertification's corrected for June 30, 2024. Ongoing Corrective Action: Additional file review after recertifications and move-ins. Additional trainings for Income VS Assets for all managers. Complete review of all previous manager's files.

Completed corrective action: Manager completed correction and new HUD 50059A recertification's corrected for June 30, 2024. Ongoing Corrective Action: Additional file review after recertifications and move-ins to be compeleted by a different manager. Additional trainings for Income VS Assets for all managers. Complete review of all previous manager's files.

2024-001 Housing Voucher Cluster – Assistance Listing No. No. 14.871 and 14.879 Recommendation: We recommend management should designate one person to review a sample of the files that have been recertified each month. The purpose of the review is to determine if the tenant files were prepared in accordance with internal policies and verify the compliance deficiencies have been corrected. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Our internal audits take place monthly. The HCV department leadership pulls the list of recertifications, interims, and new admissions and samples 10% of each to ensure they have been done correctly, with all information documented. This internal audit includes checking the rent calculation, utilities, verification documents, and tenant/landlord notification. The agency has been completing this internal practice consistently since February 2024. Name(s) of the contact person(s) responsible for corrective action: Morgan Gower Planned completion date for corrective action plan: In progress as of February 2024 and is ongoing.

OLD TOWNE SQUARE, INC. CORRECTIVE ACTION PLAN YEAR ENDED JUNE 30, 2024 AND 2023 Old Towne Square, Inc 609 SW F Avenue Lawton, OK 73501 Telephone: (580) 353-7392 Fax: (580) 353-6111 Corrective Action Plan Finding: 2024-001-Lack of Adequate Quality Control Regarding Tenant Procedures- Eligibility Condition: The quality of supervision over tenant file functions, such as calculating tenant rent and Housing Assistance Payments should be timely and sufficient to find errors in calculations or mis-application or mis-understanding of procedures. Corrective Action Planned: I am Rita Love, Executive Director. We will comply with the auditor’s recommendation. Person responsible for corrective action: Rita Love, Executive Director Telephone: (580) 353-7392 Old Towne Square, Inc. Fax: (580) 353-6111 609 SW F Avenue Lawton, OK 73501 Anticipated Completion Date: By November 30, 2024

CORRECTIVE ACTION PLAN FOR THE YEAR ENDED MARCH 31, 2024 Title 2, U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Subpart F, Section 511 – Audit Findings Follow-up requires the auditee to prepare a corrective action plan to address each audit finding included in the current year auditor’s reports. The Corrective Action Plan for Current Year Findings present our corrective action plan for the Financial Statement and/or Federal Award Findings described in the accompanying Schedule of Findings and Questioned Costs for the period ended March 31, 2024. Finding 2024-001 Responsible Party Name: Tamara Wallace Position: Executive Director – Management Agent Telephone Number: 816-233-4250 Federal Agency Department of Housing and Urban Development Federal Program Supportive Housing for the Elderly (Section 202) Compliance Requirements A/B - Activities Allowed or Unallowed and Allowable Costs/Cost Principles, C – Cash Management, E – Eligibility, L – Reporting, and N – Special Tests and Provisions Finding Type Financial Statement and Federal Awards Auditee’s Comment on Finding We agree with the auditor’s finding. Corrective Action Management reported that the failure(s) involved records related to the period managed by the predecessor management company. We will request and keep all required documentation from HUD and establish processes and procedures to ensure compliance with the Regulatory Agreement. Anticipated Completion Date September 30, 2024

2024-002 Student Financial Aid – 84.268 – Federal Direct Loan Program, 84.063 – Federal Pell Grant Program, 84.007 – Federal Supplemental Educational Opportunity Grant Program, 84.033 – Federal Work-Study Program Recommendation: We recommend the review process for awarding be documented and retained as support for the review and approval process. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Director of Financial Aid will document each change to an award by printing a new award offer and saving to document tracking. As this is the final year in which Lincoln Christian University will have academic operations, we believe this corrective action to be sufficient for the remainder of the year. Name of the contact person responsible for corrective action: Margie Martin, Director of Accounting Planned completion date for corrective action plan: May 31, 2024.

August 20, 2024 Department of Housing and Urban Development Washington DC East Central Kansas Economic Opportunity Corporation respectfully submits the following corrective action plan for the year ended March 31, 2024. SSC CPAs, PA 3320 Clinton Parkway Court, Suite 120 Lawrence, KS 66047 Audit Period: Year ended March 31, 2024 The finding from March 31, 2024, schedule of findings and questioned costs are discussed below. The finding is numbered consistently with the number assigned in the schedule. FINDINGS AND QUESTIONED COSTS – MAJOR FEDERAL AWARD PROGRAMS 2024-001 Compliance and Controls over Eligibility of the Section 8 Housing Choice Vouchers Program (Significant Deficiency) Federal Agency: U.S. Department of Housing and Urban Development Program Name: Section 8 Housing Choice Vouchers Assistance Listing Number: 14.871 Award Period: March 31, 2024 Recommendation: The Board of Directors and management review the controls over the eligibility process to ensure the process is being followed and implemented correctly. Action Taken (Unaudited): ECKAN will create a policy in its Admin Plan, using any new HOTMA rules that may apply, to require zero-income forms in client files for households claiming zero-income. This Admin Plan edit will be presented to the ECKAN Board of Trustees for approval. Effective immediately (as of date of file inspection) ECKAN will use the Zero Income Verification Form for any new families claiming zero income. This had been a practice within the department but had not been formalized or provided oversight. ECKAN will also take steps to ensure current client files are searched for any families who claimed zero income prior and either locate the form or initiate contact with the family to obtain a completed form. A tracking spreadsheet will be created to ensure a complete list of zero-income households is maintained and monitored by the ECKAN housing staff. Anticipated completion date is March 31, 2025. If the Department of Housing and Urban Development has questions regarding this plan, please call Crystal Anderson at 785-242-7450. Sincerely yours, Crystal Anderson Crystal Anderson CEO East Central Kansas Economic Opportunity Corporation

Plan of Action: The area of compliance evaluated relates to the area of organizational workflow that includes patient intake. Due to the severity of this issue, management has implemented the following as a corrective action:  Contact granting organization for technical assistance with implementing and maintaining compliance during a period of increased staffing shortages and turnovers  Redesigned current workflow and office procedures to include the following changes: o Entry Level intake will only involve information gathering and collection of copays o 1st Level Supervision will review data and determine eligibility of sliding fee and application. The supervisor will also review the application to ensure that all signatures and demographic data has been included. o 2nd Level Supervision will perform random chart audits Monthly o 3rd Level Supervisor will perform random chart audits Quarterly  All patient intake staff will receive one-on-one training on Sliding Fee and the importance of documentation.

2024-001 Sliding Fee Discount Determination Name of Contact Person: Vice President and Chief Financial Officer: Gurjeet Sandhu Corrective Action: Golden Valley Health Centers: • Is providing immediate re-training to staff on issues identified beginning June 11, 2024. • Continues to provide ongoing training to current and new staff involved in Sliding Fee Discount Program (SFDP) on program requirements and proper implementation of sliding fee determination and billing. • Has updated procedures for the Sliding Fee Discount Program approval process in which all sliding fee required documents are first reviewed and approved by a Clinic Supervisor or Center Manager for program compliance. This process was implemented in October 2023, which was at the mid-point of the current fiscal year and will assist in addressing any issues and training proactively. • Will continue ongoing Sliding Fee Audit Tracers and Chart Audits to assess staff knowledge, provide feedback, and offer guidance, as needed. Proposed Completion Date: October 31, 2024

Plan: A procedure will be implemented and documented to ensure that all tenant income and expenses are reviewed by a second individual to ensure accuracy. Anticipated Completion Date: 09/30/2024 Responsible person: Jackie Oliveira, Director of Affordable Housing

Finding No.: 2023-047 AL Program: 93.778 – Medical Assistance Program (Medicaid; Title XIX) Area: Special Tests and Provisions – Provider Eligibility (Screening and Enrollment) Questioned Costs: $28,448,121 Contact Person(s): George J. Cruz, Medicaid Director Corrective Action Plan: The Commonwealth Medicaid Agency (CMA) respectfully disagrees with the auditor’s finding. CMA does not believe the finding fully reflects the Agency's efforts to comply with provider screening and exclusion requirements during the audit period. While documentation supporting certain screening activities was not readily available for auditor review, the Agency has historically performed provider eligibility and exclusion reviews as part of its enrollment and oversight processes. To further strengthen compliance and documentation practices, CMA has developed provider enrollment and screening procedures, conducted retrospective exclusion reviews where documentation was unavailable, and continues to enhance monitoring activities. In addition, the Agency has expanded staffing resources and continues to recruit and assign personnel dedicated Finding No.: 2023-047, continued AL Program: 93.778 – Medical Assistance Program (Medicaid; Title XIX) Area: Special Tests and Provisions – Provider Eligibility (Screening and Enrollment) Questioned Costs: $28,448,121 Contact Person(s): George J. Cruz, Medicaid Director Corrective Action Plan: to provider enrollment, compliance, and program integrity functions to ensure federal screening requirements are consistently performed, documented, and monitored. Proposed Completion Date: Ongoing

Finding No.: 2023-044 AL Program: 93.767 – Children’s Health Insurance Program (CHIP) Area: Special Tests and Provisions – Provider Eligibility Questioned Costs: $7,808,322 Contact Person(s): George J. Cruz, Medicaid Director Corrective Action Plan: The Commonwealth Medicaid Agency (CMA) respectfully disagrees with the auditor’s finding. CMA does not believe the finding fully reflects the Agency's efforts to comply with provider screening and exclusion requirements during the audit period. While documentation supporting certain screening activities was not readily available for auditor review, the Agency has historically performed provider eligibility and exclusion reviews as part of its enrollment and oversight processes. To further strengthen compliance and documentation practices, CMA has developed provider enrollment and screening procedures, conducted retrospective exclusion reviews where documentation was unavailable, and continues to enhance monitoring activities. In addition, the Finding No.: 2023-044, continued AL Program: 93.767 – Children’s Health Insurance Program (CHIP) Area: Special Tests and Provisions – Provider Eligibility Questioned Costs: $7,808,322 Contact Person(s): George J. Cruz, Medicaid Director Corrective Action Plan: Agency has expanded staffing resources and continues to recruit and assign personnel dedicated to provider enrollment, compliance, and program integrity functions to ensure federal screening requirements are consistently performed, documented, and monitored. Proposed Completion Date: Ongoing

Finding No.: 2023-040 AL Program: 93.489/93.575/93.596 – CCDF Cluster COVID-19 93.489/93.575/93.596 CCDF Cluster Area: Eligibility Questioned Costs: $12,490 Contact Person(s): Roselle Teregeyo, CCDF Co-Administrator/Accountant Corrective Action Plan: Condition 1: The CNMI CCDF Program respectfully disagrees with this finding. During the audit period, the CNMI CCDF State Plan for FY 2022–2024, Section 3.1.8, Employment Requirements, permitted the acceptance of a USCIS receipt notice (WAC receipt number) as documentation of employment authorization when applicable. Specifically, the State Plan states that a USCIS receipt indicating a WAC number may be requested when necessary and that additional documentation may be requested to identify applicants who meet the long-term employment criteria. Based on the policies in effect during the certification periods cited above, the CCDF Program determined eligibility using the documentation requirements established in the approved CCDF State Plan. Therefore, the questioned costs associated with these cases were incurred in accordance with the Program's established eligibility policies at that time. The issue occurred during a period of increased application volume when eligibility determinations and document reviews were processed manually. In addition, the State Plan language did not explicitly state that USCIS receipt notices would not be accepted as evidence of employment authorization, which contributed to differing interpretations of acceptable documentation requirements. Although the Program maintains that the cited cases were processed in accordance with the policies in effect during the audit period, the CCDF Program has strengthened its documentation requirements to address concerns raised in prior audits. Effective February 1, 2026, the CCDF Program no longer accepts USCIS employment authorization receipt notices as proof of work authorization. This policy change was implemented through CCDF Memorandum Subsidy FY26 No. 1 and serves as a corrective action to ensure consistency and strengthen compliance with employment verification requirements. Program staff have been notified of the revised policy and eligibility determinations will now require approved work authorization documentation rather than receipt notices. Proposed Completion Date: Completed Finding No.: 2023-040, continued AL Program: 93.489/93.575/93.596 – CCDF Cluster COVID-19 93.489/93.575/93.596 CCDF Cluster Area: Eligibility Questioned Costs: $12,490 Contact Person(s): Roselle Teregeyo, CCDF Co-Administrator/Accountant Corrective Action Plan: Condition 2: The CNMI CCDF Program agrees with this finding. During the audit period, provider payments were processed manually for approximately 1,101 children each month. The manual calculation and entry of subsidy amounts increased the risk of human error, resulting in isolated instances of overpayments and underpayments. To strengthen internal controls and reduce the risk of payment errors, the CCDF Program has been working with a contracted system developer since late 2025 to implement an automated subsidy management system. Once operational, the system will automatically calculate and assign payment amounts based on eligibility factors, including the child's age and approved level of care, thereby reducing reliance on manual calculations. The CCDF Program will continue monitoring payment processes and implementing automated controls to improve payment accuracy and strengthen compliance with program requirements. The Program will initiate recovery of the $390 overpayment identified in Case ID 3040 B through adjustments to provider payments scheduled for August and September 2026. For the underpayments identified in Case IDs 3275 B, 3275 C, and 3600 C, the Program will process payment adjustments and issue the respective amounts owed through the August 2026 provider payment cycle. Proposed Completion Date: September 2026

Finding No.: 2023-028 AL Program: COVID-19 21.023 – Emergency Rental Assistance Program Area: Eligibility Questioned Costs: $99,935 Contact Person(s): Epiphanio Cabrera, Jr., Grants Administrator, OGM-SC Corrective Action Plan: Condition 1a: The Office of Grants Management (OGM) respectfully disagrees with the finding and questioned cost of $8,337.00 because assigned personnel were not made aware to supply supporting documents for the following questioned costs. Possible communication breakdown may exist as per OGM staff, and OGM staffer reported a different request list was furnished at different times. However, OGM is pleased to provide you with copies of the documents for these questioned costs items. I believe that the timing played a major role with the release of this draft document, but OGM should not be penalized. We are requesting this finding be removed based on the explanation provided above. Finding No.: 2023-028, continued AL Program: COVID-19 21.023 – Emergency Rental Assistance Program Area: Eligibility Questioned Costs: $99,935 Contact Person(s): Epiphanio Cabrera, Jr., Grants Administrator, OGM-SC Corrective Action Plan: Condition 1b: The Office of Grants Management respectfully disagrees with the finding and questioned cost of $91,598.00 because assigned personnel were not made aware to supply supporting documents for the following questioned costs. Possible communication breakdown may exist as per OGM staff, and OGM staffer reported a different request list was furnished at different times. However, OGM is pleased to provide you with copies of the documents for these questioned costs items. I believe that the timing played a major role with the release of this draft document, but OGM should not be penalized. We are requesting this finding be removed based on the explanation provided above. Proposed Completion Date: Ongoing Condition 1c: The Office of Grants Management disagrees with the finding and questioned cost of $68,181.00 because assigned personnel were not made aware to supply supporting documents for the following questioned costs. Possible communication breakdown may exist as per OGM staff, and OGM staffer reported a different request list was furnished at different times. However, OGM is pleased to provide you with copies of the documents for these questioned costs items. I believe that the timing played a major role with the release of this draft document, but OGM should not be penalized. We are requesting this finding be removed based on the explanation provided above. Proposed Completion Date: Ongoing Condition 1d: The Office of Grants Management disagrees with the finding and questioned cost of $4,500.00 because assigned personnel were not made aware to supply supporting documents for the following questioned costs. Possible communication breakdown may exist as per OGM staff, and OGM staffer reported a different request list was furnished at different times. For this particular finding, the client was unemployed and thus could not provide an employment verification. Finding No.: 2023-028, continued AL Program: COVID-19 21.023 – Emergency Rental Assistance Program Area: Eligibility Questioned Costs: $99,935 Contact Person(s): Epiphanio Cabrera, Jr., Grants Administrator, OGM-SC Corrective Action Plan: However, OGM is pleased to provide you with copies of the documents for these questioned costs items. I believe that the timing played a major role with the release of this draft document, but OGM should not be penalized. We are requesting this finding be removed based on the explanation provided above. Proposed Completion Date: Ongoing Condition 1e: The Office of Grants Management disagrees with the finding and questioned cost of $19,614.00 because assigned personnel were not made aware to supply supporting documents for the following questioned costs. Possible communication breakdown may exist as per OGM staff, and OGM staffer reported a different request list was furnished at different times. However, OGM is pleased to provide you with copies of the documents for these questioned costs items. I believe that the timing played a major role with the release of this draft document, but OGM should not be penalized. We are requesting this finding be removed based on the explanation provided above. Proposed Completion Date: Ongoing

Finding No.: 2023-022 AL Program: COVID-19 17.225 – Unemployment Insurance (UI) Area: Eligibility Questioned Costs: $-0- Contact Person(s): Zachary Taitano, PUA Program Manager, DOL Corrective Action Plan: The CNMI agrees with this finding and acknowledges that a variance exists between the expenditure report details and the listing of payments from the HireMarianas Portal. We are currently reviewing and reconciling both records to determine the cause of the variance. The Expenditure Detail Listing totals $3,057,097.02, while the HireMarianas benefit listing totals $4,112,291.03. During this review, we identified that the HireMarianas benefit listing total includes benefit tax withholdings and child support deductions. However, these amounts are not included in the Expenditure Detail Listing. Therefore, the variance is attributable to PUA tax withholdings ($169,283), FPUC tax withholdings ($150,054), and child support deductions ($202). After excluding these amounts, the adjusted HireMarianas Portal total is $3,792,752.03. Additionally, a review of the MUNIS system identified 19 late entries not reflected in the original Expenditure Detail Listing of $3,057,092.02. These entries represent FY23 expenditures recorded in FY24 and consist of 10 PUA benefit payments totaling $108,937.63 and 9 FPUC benefit payments totaling $110,625.00, for a combined total of $219,562.63. After incorporating these MUNIS late entries into the Expenditure Detail Listing, the adjusted expenditure total is $3,276,654.65. Based on these adjustments, the remaining variance is $516,097.37. Finding No.: 2023-022, continued AL Program: COVID-19 17.225 – Unemployment Insurance (UI) Area: Eligibility Questioned Costs: $-0- Contact Person(s): Zachary Taitano, PUA Program Manager, DOL Corrective Action Plan: CNMI DOL will continue its review and will coordinate with Geographic Solutions, Inc. (GSI), the HireMarianas Portal vendor, and the Department of Finance to further investigate and resolve any remaining discrepancies and to ensure the accuracy and completeness of reported disbursements. Proposed Completion Date: October 2026

2023-007 Tenant Eligibility Material Weakness Recommendation: In general, we continue to recommend a review of the re-certification process to determine areas of weakness. Specifically, we recommend the use of a standard checklist in the re-certification process. We further recommend that each re-certification clerk’s work be routinely audited. We also recommend more standardization in resident files organization of information, and procedures established to make sure all files are maintained adequately in order to be compliant. Action Taken: The Housing Authority agrees with this finding and will implement this recommendation within 120 days of this audit report.

3. Finding 2023-003: Supplemental Nutrition Assistance Program (SNAP), ALN # 10.551, Grant Period 1/1/23 - 12/31/23. Context: Per the Federal OMB Uniform Guidance Circular Compliance Supplement, each individual who receives benefits under the SNAP program should have a completed eligibility determination on file, which is available for audit review. Corrective Action: A substantial number of the identified cases involved 24-month certification renewal periods. As a result, no 2023 application existed for those cases because the recertifications had been completed in 2022 and were not due again until 2024, pursuant to N.J.A.C. 10:87-6.20, Certification Periods. State regulations permit 24-month certification periods for eligible senior citizens and individuals with disabilities. Please see the attached New Jersey Administrative Code provision supporting the applicable 24-month certification period requirements. PCBSS has also implemented additional enhancements to support the DIMS Unit, where files are scanned and electronically stored. The agency increased staffing responsible for document scanning and streamlined the transfer process from worker units to the DIMS Unit. These improvements help ensure that cases are properly identified, organized, maintained, and that supporting case documentation is completed and uploaded timely. Implementation Date: Commenced in 2023 and ongoing.

2. Finding 2023-002: Temporary Assistance for Needy Families (TANF), CFDA #93.558, Grant Period 1/1/22-12/31/22. There were multiple instances where eligibility files selected for review were unable to be presented for audit review. Context: As per the Federal OMB Uniform Guidance Circular Compliance Supplement, each individual who receives benefits under the TANF program should have a completed eligibility determination on file, which is available for audit review. Corrective Action: PCBSS has implemented additional enhancements to support the DIMS Unit, where files are scanned and electronically stored. The agency increased staffing responsible for document scanning and streamlined the transfer process from worker units to the DIMS Unit. These improvements help ensure that cases are properly identified, organized, maintained, and that supporting case documentation is completed and uploaded timely. Implementation Date: Commenced in 2023 and ongoing.

Medical Assistance Program (Medicaid, Title XIX), CFDA #93.778, Grant Period 1/1/23-12/31/23. Context: As per the Federal OMB Uniform Guidance Circular Compliance Supplement, each individual who receives benefits under the Medicaid program should have a complete eligibility determination on file, which is available for audit review. Corrective Action: PCBSS has implemented additional enhancements to support the DIMS Unit, where case files are scanned and electronically stored. The agency increased staffing dedicated to document scanning and streamlined the transfer process from worker units to the DIMS Unit. These improvements help ensure that cases are properly identified, organized, and maintained, and that supporting documentation is uploaded timely and accurately. Additionally, several Medicaid cases identified during the review were initially established by the State of New Jersey and/or third-party vendors contracted by the State prior to being transferred to the county for ongoing case management responsibilities. As a result, PCBSS did not possess the original applications or supporting eligibility documentation because the initial eligibility determination and enrollment process had already been completed before the cases were transferred to the county. Moving forward, PCBSS will provide auditors with system-generated portal documentation identifying the originating agency responsible for the initial case establishment. Implementation Date: Commenced in 2023 and ongoing.

Director of American Rescue Plan (ARP) Programs, Federal program managers, and Chief Financial Officer October 2023 Management remains committed to continuous improvement and has taken corrective actions to strengthen internal controls, ensure proper documentation retention, and maintain full compliance with applicable federal regulations

The County has since implemented corrective actions to strengthen internal controls and ensure compliance moving forward, including: Providing targeted staff training on eligibility requirements, including self-attestation limitations. Implementing a secondary review process for eligibility determinations and payment calculations when clients self-certify income. Establishing ongoing monitoring procedures, including periodic file reviews. Benton County is committed to maintaining strong internal controls and ensuring compliance with all applicable federal and state requirements. These enhancements are designed to prevent recurrence and support consistent application of program guidelines.