Corrective Action Plans

Name of contact Person: Brittany Naylor, Director of Social Services Corrective Action: This finding is listed as a repeat finding on Technical Errors cited finding in previous audit 2024-002 and continues to be an area of improvement for Lenoir County. Lenoir County takes immediate action to correct any findings and ensure that workers are made aware of job duties and expectations. Lenoir County has effectively maintained the required accuracy standards rate of 95% or higher when determining eligibility for case actions, approvals, terminations and denials. The findings in this area equate to a 98.12% overall accuracy rating. The following changes have been implemented to help alleviate the continued non-compliance in this area. Staff meeting will be held Wednesday, February 18,2026 and the following training materials will be discussed and provided to the Medicaid staff to ensure continued understanding and knowledge of program requirements. Training materials will include but not limited to the following: Learning Gateway modules Magi Budgeting, Magi Budgeting: Income Determination, NC DHHS Medicaid Manual, etc. Modules are given in self learning type atmosphere and then followed up with classroom discussions and activities in an effort to enhance the retainability of information learned to the worker. Provide new budgeting tool that helps with calculating resource and budgetary areas of concern to reduce errors related to incorrect budgeting and resource calculations. Providing staff with copies of the Single County Audit findings, the Corrective Action plan and staff expectations to ensure that staff is well informed of the findings and what is expected from the Corrective Action Plan implementation. Filling the vacant Lead Worker position and provide assistance to the assist the team with applying correct case actions to determine eligibility. Supervisor and Lead Workers will assist staff with utilizing NC Fast Help Job Aids, NC DHHS policy for Medicaid for Families and Children or for Medicaid for the Aged, Blind, and Disabled manuals for reference material to reference, review and retain knowledge to ensure effective training knowledge that is applied to case actions. Supervisors and Lead Workers will complete 2nd party review and evaluate case actions with an increased emphasis on actions cited. Lead Workers turn in 2d party reviews at least once or twice a week to be evaluated and corrections must be made. Supervisors and Lead Workers will continue to monitor case actions and provide monthly statistical data detailing case findings. The Supervisor and Lead Worker will provide a list of findings and maintain scheduled monthly meetings with staff to provide feedback and coaching to ensure continued compliance of program requirements. The meetings held will consist of staff unit meetings and/or individual conferences provided by the Supervisors in an effort to effectively catch and manage error trends that have been discovered from 2nd party review findings. All documentation will be submitted to the Administrator for review and will be discussed and reviewed with the Supervisors during monthly conference meetings. The Administrator will provide monthly updates on case actions and findings to the Director. Proposed Completion Date: Training will be held with Medicaid Staff on Wednesday, February 18, 2026 for eligibility issues cited. Corrective Action Plan will be implemented immediately after training and significant improvement of all areas cited must be maintained by June 30, 2026.

Name of contact Person: Brittany Naylor, Director of Social Services CorrectiveAction:Thisfinding continues to be cited asanongoingeligibilitydeterminationerrorfrom prioraudits, despite exhaustive efforts to resolve the issue. Lenoir County has worked diligently to address the backlog of exparte reviewsand bring all reporting upto date.Based onall availablereports accessibleto ouragency,wehave completedthiseffortand arecurrentonallexpartereviews.Toensureaccuracy,Lenoir Countycontacted theState to confirm whether any additional reports or cases existed that were not reflected in our records. Based on the information provided, there are no outstanding reports listed beyond June 2019. Lenoir County has submitted an additional ticket to determine why these older exparte cases continue to appear as active in the system and to request assistance in resolving this issue. We remain committed to collaborating with the State to identify and address any outstanding exparte reviews that may not be reflected in our current reports. Thisfindingalsodisclosedfourapplicantsand,/orbeneficiariesreceivingassistanceforwhichtherecipientwasnot eligible. This finding consisted of the failure of worker to check all case references to determine eligibility. Lenoir County failed to check and include all financial income on two cases and failed to complete an income budget calculation correctly on one case. The following steps will be added to existing practices to ensure ongoing eligibility compliance. Staff meeting will be held Wednesday, February 18,2026 and the following training materials will be discussed and provided to the Medicaid staff to ensure continued understanding and knowledge of program requirements. MAGI policy manual 3306 - Modified Adjusted Gross Income - will be reviewed and additional guidance provided on how to effectively calculate income correctly to determine eligibility for case actions. Verbally explain and provide MAGI Budgeting: 5% Income Disregard PowerPoint and ensure that staff understand how to apply the deduction correctly to case actions. Verbally explain and provide Reasonable Compatibility PowerPoint and ensure that staff understand when and how to apply reasonable compatibility to case per policy requirements. Providing staff with copies of the Single County Audit findings, the Corrective Action plan and staff expectations to ensure that staff is well informed of the findings and what is expected from the Corrective Action Plan implementation. Staff will be required to complete adding machine calculations and check amounts against NC FAST system calculations to verify correct financial income for case actions. A summary check-off form has been created to ensure that staff are checking NC FAST determinations page to cross reference system eligibility approvals are inline with client case actions. Workers must check household size and compare case composition to ensure correct eligibility results. Supervisor and/or Lead Worker will complete 100% 2nd party reviews on all new hires until each worker receives a 95% or higher accuracy processing rating and will complete a minimum of 5 2nd party reviews for each existing worker to target these key areas of concern until all workers reach and maintain a 95% or higher accuracy processing rating. Staff will correct any findings within three days of receipt of 2nd party review findings. Supervisors and Lead Workers will continue to monitor case actions and provide monthly statistical data detailing case findings. The Supervisor and Lead Worker will provide a list of findings and maintain scheduled monthly meetings with staff to provide feedback and coaching to ensure continued compliance of program requirements. The meetings held will consist of staff unit meetings and/or individual conferences provided by the Supervisors in an effort to effectively catch and manage error trends that have been discovered from 2nd party review findings All documentation will be submitted to the Administrator for review and will be discussed and reviewed with the Supervisors during monthly conference meetings. The Administrator will provide monthly updates on case actions and findings to the Director. Proposed Completion Date: The exparte issue is expected to be resolved when data is received from State, not to exceed timeframeofJune30,2026.Training willbeheldwith MedicaidStaffonWednesday,February18,2026 for other eligibility issues cited. Corrective Action Plan will be implemented immediately after training and significant improvement of all areas cited must be maintained by June 30, 2026.

Corrective Action: Before any expenditure is obligated, all revisions/amendments will be approved in MCAPS first. The business Manager, Federal Programs Director, and Superintendentwill ensure MDE's approval is tangible before any obligations. We will implement a tool that allows this process to be measured daily. Responsible Parties: Avery Johnson, Business Manager Tiffany Willis, Federal Programs Director Corrective Action Start Date: February 18, 2026

FINDING 2025-002 Finding Subject: Title I-A Eligibility Contact Person Responsible for Corrective Action: Jamesi Lemon Contact Phone Number and Email Address: jlemon@lakelandlakers.net Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The School Corporation has made changes in our policy to what is acceptable as proof of residency beginning with the 2025-2026 school year, which has increased compliance from families. Our school secretaries have also been sending home follow-up letter and sending emails to families who have not submitted the correct documentation for residency. The School Corporation now has a Community Eligibility Provision with the USDA when it comes to our food service. All students are now qualified for free lunches under this program. Any free/reduced applications received be scanned and stored after entering the information into PowerSchool. Anticipated Completion Date: Already completed.

FINDING 2025-003 CNC Eligibility Finding Subject: Child Nutrition Cluster - Eligibility Contact Person Responsible for Corrective Action: Patty Kelley Contact Phone Number and Email Address: 812-913-9622 pkelley@bhsc.school Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: The Direct Certification downloads will be done once a month by the Cafeteria Director. The Cafeteria Director will sign the report and forward it to the Treasurer for verification and a second signature. The Direct Certification reports will be kept at the central office. Anticipated Completion Date: This process will be in place by the end of the current fiscal year, June 30, 2026.

Trainings have been conducted during the current school year for principals, secretaries, and cooks at all schools on following correct meal patterns and point of service procedures. The current child nutrition director performs random audits and visits at all schools to make sure schools are following these procedures consistently.

Corrective action plan: FDCM/OI has developed a comprehensive action plan to modernize and increase our detection of fraud in the child care program. Part of this modernization will include increased and more “real-time” monitoring of Board collection efforts. FDCM/OI is partnering with our Information, Innovation, and Insight Division (I3) to develop new dashboards and reports based upon weekly uploaded PIRTS data. This will allow FDCM/OI to generate weekly reports of Board collection letter non-compliance. If a Board fails to issue collection letters in a timely fashion, FDCM/OI will send a report to the Board Executive Director notifying them of non-compliance. Boards are also now required to have a Fraud Point of Contact (POC) that will be FDCM/OI’s direct liaison with the Board for all fraud matters. Additionally, FDCM/OI is conducting weekly PIRTS trainings throughout February for Boards. Boards have been asked to submit up to 5 fact finders who will be responsible for fraud case entry and management. The Board POC is ultimately responsible for every case. FDCM/OI is also reviewing our collection letters as a part of this process and generating prosecution referrals for cases which meet our criteria. It is our belief this will underscore the seriousness of the collection letters and increase their effectiveness. Finally, FDCM/OI will ensure that all relevant controlling documents, e.g. a new Workforce Development Letter, and all previous guidance is updated with this information. Implementation date: February 27, 2026 Responsible person: Jason Stalinsky, Division Director, Division of Fraud Deterrence and Compliance Monitoring.

Corrective action plan: ITS will: • Work with HR and Security to analyze and validate the size and scope of the late submission of access termination requests for separated employees. Communicate the analysis results and recommendations on or before May 1, 2026. • Work with the Information Security Office for continuation of periodic reconciliation of HR data and network accounts. Schedule for reconciliation to be established on or before May 1, 2026. • Work with Human Resources to establish a schedule of periodic reconciliation for HR data and case management application accounts. Schedule for reconciliation to be established on or before May 1, 2026. • Review existing business process for offboarding separated employees and provided recommendations to HR for training and communication for staff. Recommendations to be provided by May 1, 2026. • Determine what technology solution may be needed by August 31, 2026, with consideration of effectiveness of mitigation actions, as noted above. Implementation dates: See Corrective action plan Responsible person: Angie Lindemann, Deputy Chief Information Officer

Corrective action plan: HHSC will conduct an end-to-end review of the sanctions process to identify and implement any needed changes to the business process, training, or system. Implementation date: May 31, 2026 Responsible person: Carrie Robertson, Manager, Strategy and Innovation–Business Integration and Support

Corrective action plan: ITS Management will establish a formal, documented user access review program applicable to both privileged and non-privileged network users. Key actions include: 1. Policy Updates: Revise information technology access control policies and procedures to re-quire periodic (at least annual) reviews of all network user access. 2. Standardized Process and Documentation: Implement a consistent, documented review process and maintain records in a centralized repository to ensure accountability and auditability. 3. Monitoring and Oversight: Implement oversight procedures to track completion of access re-views and remediation of identified issues, with reporting to IT and information security leadership to support governance. Implementation dates: 1. Policy and procedure updates: Expected completion by April 30, 2026 2. Standardized process and repository implementation: Expected completion by May 31, 2026 3. First completed annual review under the revised process: Expected completion by June 30, 2026 Responsible persons: Tara Mitchell, Director of IT Operations Sean Peterson, Chief Information Officer

Corrective action plan: • IT will coordinate with HR on strengthening the separation process, to include HR running separation reports quarterly and sending to IT to cross check. Will perform regular scheduled meetings to discuss the separation process/issues. • IT is testing automatic scripts that will aid in the process and will be implemented this year. • IT will document quarterly access reviews which are already done. • IT will work on enhancing automation and controls; Will utilize AI to assist. Implementation date: May 2026 Responsible person: Chris Bunton, CIO, Texas Department of Agriculture

Finding Reference: 2025-001 – Reporting Condition: During testing of reporting compliance for major federal programs, we selected three of twelve monthly OAF reports submitted during the fiscal year. For each month tested, reported amounts did not reconcile to MOFC’s internal Poundage Distribution reports and Product Code – Agencies by County reports. Specifically, we identified material variances between the OAF reports and internal distribution records, including: October 2024: ACP distributions were omitted from the OAF report, resulting in a variance of approximately 821,528 pounds (projected dollar impact of $262,889). January 2025: VA/Holiday Purchase distributions were omitted from the OAF report, resulting in a variance of approximately 310,898 pounds (projected dollar impact of $155,449). June 2025: Donated distributions, primarily Direct Retail Pickup (DRP) quantities, were omitted from the OAF report, resulting in a variance of approximately 933,505 pounds (projected dollar impact of $1,764,324). Additional differences were noted in purchased distributions of 40,399 pounds (projected dollar impact of $16,968). Although management provided explanations indicating that certain distributions were omitted in error or excluded due to differences in reporting scope, MOFC did not maintain documented reconciliations supporting the reported amounts. Evidence of review and approval demonstrating that differences were identified, investigated, and resolved prior to report submission was not provided. Views of Responsible Officials Items 1 & 2 are both failures of a report in our former ERP to include exception components and needed to be added manually when reporting. This is a result of human error. Item 3 is a result of a WIP component currently being installed into the new ERP to add in programmatic data for agency pickups. This is currently added manually for reporting purposes – also human error. Planned Corrective Action: Implementation of the Direct Retail Pickup poundage integrations into the current ERP will negate the necessity to manually enter the numbers. While this install is occurring, we will continue to manually update. Anticipated Completion Date: Initial discussions have occurred with an anticipated solution provided, tested and approved before the end of FY26 timeframe.

Oversight Agency for Audit, Edward M. Marx Apartments, Inc., respectfully submits the following corrective action plan for the year ended June 30, 2025. Name and address of independent public accounting firm: Bellows Associates, P.A., 5401 N University Drive, Suite 201, Coral Springs, Florida 33067 Audit period: July 1, 2024 through June 30, 2025 The finding from the June 30, 2025 schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. SECTION III – FINDINGS AND QUESTIONED COSTS – MAJOR FEDERAL AWARD PROGRAMS AUDIT FINDING No. 2025-001: Section 202 Supportive Housing for the Elderly, ALN 14.157 Recommendation: Management should ensure that initial and ongoing tenant eligibility documentation is obtained timely and appropriately maintained. Action Taken: Staff training has been provided with additional HUD training inclusive of EIV reporting and tenant file maintenance and included in monthly reporting procedures. If the Oversight Agency for Audit has questions regarding this plan, please call Irene Phillips at 954-835-9200. Sincerely yours, Irene Phillips, CFO Irene Phillips CFO

A. Lack of Formal Review of Student Eligibility Determination Los Angeles City College (Student Support Services Program – Award No. P042A200354) Los Angeles City College acknowledges that internal controls to demonstrate student eligibility for the TRIO SSS Program will need to be modified to ensure there is documented evidence showing approval and eligibility determination by a designated responsible official within the program. TRIO SSS at Los Angeles City College will revise the TRIO SSS application to require a “wet signature” from the TRIO SSS Director. This will ensure that reliable documented internal controls continue to meet and align with federal requirements, adding accountability for student eligibility decisions. Personnel Responsible for Implementation: TRIO Director, Student Support Services Position of Responsible Personnel: TRIO SSS, Director Expected Date of Implementation: As of Winter Session 2026 (January 5, 2026) B. Missing Student Eligibility Documentation Los Angeles Southwest College (Student Support Services Program – Award No. P042A201884) The department will create a Shared Drive to house all pertinent documentation related to the program, if the program is reinstated in the future. Personnel Responsible for Implementation: Dean/Vice President Student Services in place during implementation. Position of Responsible Personnel: Dean, Student Services/Vice President Student Services Expected Date of Implementation: Not Applicable – Program will not be in place moving forward.

Miscalculation of Student Cost of Attendance Auditor Description of Condition and Effect. Of the 40 students tested, we noted 1 student's Cost of Attendance (COA) was inaccurately updated after initial packaging due to the budget not being locked in the system. As a result of this condition, the University is out of compliance with federal guidelines. Auditor Recommendation. We recommend that the University implement a review process to ensure that all student budgets are locked and no changes made without proper review and approval. Corrective Action. The University will implement a review process to ensure that all student budgets are reviewed and locked. Responsible Person. Anne Van, Director of Financial Aid Anticipated Completion Date. June 30, 2026

Program: AL 21.023 – COVID-19 Emergency Rental Assistance Program – Allowability & Eligibility Corrective Action Plan: The ERA2 program officially concluded as of September 30, 2025. Because the program ended, there will be no further eligibility determinations to be made and no additional action is necessary. On all other grant programs for which the Agency is the recipient, eligibility determinations are a shared responsibility of the Agency and the funding entity. Contact: Erv Portis Anticipated Completion Date: Complete

Program: AL 17.225 – Unemployment Insurance – State – Special Tests and Provisions Corrective Action Plan: NDOL will review existing procedures for applying credits to employers. This review will include confirming that credits are applied correctly and that overpayments are properly established. In addition, NDOL will implement enhanced staff review and oversight of employer charging activities to identify and correct errors. NDOL will work closely with its system vendor to address any system issues affecting employer charging and to ensure processes function as intended. Any gaps identified through these reviews will be addressed through procedural updates, targeted staff training, and ongoing monitoring. NDOL will continue to evaluate and refine employer charging procedures to ensure that credits and overpayments are applied accurately. Contact: Andi Bridgmon Anticipated Completion Date: 1/31/2027

Program: AL 17.225 – Unemployment Insurance – State – Allowability & Eligibility Corrective Action Plan: NDOL will reinforce adjudication controls. This includes working with our vendor on wage and other crossmatches to continue making enhancements, so they are as effective as possible. NDOL will also reinforce the importance of obtaining separation information from employers, and employer responses will be reviewed and documented to support accurate eligibility determinations. NDOL agrees that the identification and treatment of excessive wages is an area that warrants additional consideration and will continue to evaluate procedures to ensure wages are applied appropriately. NDOL will also develop additional training related to benefit charging to ensure staff are familiar with applicable requirements and procedures. NDOL remains committed to continuous improvement and will adjust procedures, training, and system functionality as needed. Contact: Andi Bridgmon Anticipated Completion Date: 9/30/2026

Program: AL 93.778 – Grants to States for Medicaid – Allowability & Eligibility Corrective Action Plan: Medicaid eligibility program accuracy unit plans to update internal eligibility staff training, guidance, and communication related to working vital statistics NFOCUS notices as applicable. Individual staff who made errors will receive additional training to ensure they understand policies and procedures going forward. Additionally, the program accuracy unit, responsible for quality control case reviews, will begin the ongoing monitoring of both date of death records and actions taken as a result of notices of death. The Medicaid division is collaborating with the DHHS Information Systems and Technology team to perform root cause analysis for Vital Statistic records that may not have triggered automated case notices, and to evaluate system related internal control improvement opportunities. Contact: Jeremy Brunssen, Tiffanie Green, Anne Harvey Anticipated Completion Date: June 30, 2026

Program: AL 93.778 – Grants to States for Medicaid – Allowability & Eligibility Corrective Action Plan: The Agency has standard operating processes and procedures however worker error resulted in these conditions. The Agency will ensure established standard processes are followed. Additionally, user guides and training materials will be reviewed and updated if deemed necessary for clarity. New guidance material will be issued if deemed necessary. Individual staff who made the errors will be followed up with to ensure they understand the policies. Contact: Tiffanie Green Anticipated Completion Date: June 30, 2026

Program: AL 93.778 – Grants to States for Medicaid – Allowability & Eligibility Corrective Action Plan: The Agency has standard processes and procedures for processing renewals timely and updating budgets to reflect changes that have occurred within a household; however, worker errors resulted in these conditions. The Agency will ensure established standard processes are followed. Additionally, user guides and training materials will be reviewed and updated if deemed necessary for clarity. Individual staff who made the errors will be followed up with to ensure they understand the policies. Contact: Tiffanie Green Anticipated Completion Date: June 30, 2026

Program: AL 93.778 – Grants to States for Medicaid – Allowability Corrective Action Plan: DHHS and Medicaid and Long-Term Care (MLTC) have been actively implementing procedures and controls to ensure that payments are allowable, adequately supported, and in accordance with State and Federal regulations. As noted in the early management letter, the findings and conditions are consistent with findings from prior year(s) audits. As a result, the department had already taken significant actions throughout State Fiscal Year 2025 to implement several procedures and controls which are expected to mitigate the majority of the conditions observed in the audit. Specifically, in late February 2025, MLTC implemented systematic controls to require that GPS/IVR visit verification and recipient signature is captured for visits to be submitted for claim payment. Additional changes included tightening down, or reducing, the radius of the geofence area for location verification. Additionally, in late June 2025, the department implemented additional, significant procedures and controls which include the requirement of all PAS and Home and Community Based caregivers and providers obtain and use their unique National Provider Identifier (NPI) on all visits and claims for visits to be submitted for claim payment, new systematic controls that do not allow for unreasonable billing of units/hours in a day on both a client and caregiver level, and new controls that parse the client authorizations into weekly segments which create limits for the number of hours/units per week that can be billed for services for a client, based on the authorized amounts in the client assessment. DHHS and MLTC will continue to monitor data and claims and identify and evaluate opportunities to implement additional controls and procedures that ensure payments for these services are allowable and in accordance with State and Federal regulations. In addition to the changes in MLTC, the following actions are being implemented by Child and Family Services (CFS). CFS will collaborate with the Nebraska State Patrol to develop an automated process to compare the addresses of foster parents with the Sex Offender Registry on a quarterly basis to ensure that no registered sex offenders reside at the same household address as a ward of the state. Additionally, Agency-Supported Foster Care contracts and Relative/Kinship Caregiver Agreements will be amended to include a requirement that caregivers report all criminal citations, charges, convictions, and any individuals who have moved into the home within five (5) business days to CFS. Finally, Foster Care Regulations require background checks for all individuals in the foster home who are 18 years of age and older. There are certain crimes that make a person ineligible to provide foster care, while other criminal convictions fall under the discretionary category. To ensure consistency, CFS has centralized the review and approval of discretionary convictions that are not subject to mandatory exclusion. Contact: Jeremy Brunssen, MLTC Kathleen Stolz, CFS Anticipated Completion Date: 6/30/2026 (ongoing)

Program: AL 93.575 and 93.596 – CCDF Cluster – Allowability & Eligibility & Matching Corrective Action Plan: The Agency will evaluate and develop new processes to review and ensure that attendance records match billing documents, authorizations, and claims. An evaluation of the Provider Portal will be completed to identify enhancements to this area. The Agency will develop a new fraud prevention process for the Resource Development team to enhance controls over attendance, billing, and the auditing of provider claims, and to ensure compliance. A Provider Probation process will be implemented to address identified billing concerns. The Agency will evaluate current regulations and requirements surrounding provider rate increases related to the Step Up to Quality provider rate enhancements and develop a process to address concerns with exceeding private pay rates. Contact: Nicole Vint Anticipated Completion Date: September 30, 2026

Program: AL 93.575 – COVID-19 Child Care and Development Block Grant – Allowability Corrective Action Plan: In 2025, The Agency developed a subrecipient monitoring tool to ensure effective controls and processes are in place. The Agency will review all findings and take appropriate actions when warranted. Contact: Nicole Vint Anticipated Completion Date: June 30, 2026

Program: AL 93.566 – Refugee and Entrant Assistance State/Replacement Designee Administered Programs – Allowability & Eligibility Corrective Action Plan: The Refugee Resettlement Program has requested eligibility system changes to prevent eligibility errors. In addition, the Refugee Resettlement Program performs monthly reviews of RMA enrollees and will coordinate case reviews with the RMA team to ensure comprehensive case review. Retraining of eligibility staff will occur as needed. Contact: Sara Bockelman Anticipated Completion Date: April 30, 2026