Corrective Action Plans

REFERENCE: 2023-008 – Special Tests and Provisions – Satisfactory Academic Progress SFA Cluster (Assistance Listing No. 84.063, 84.268) Federal Grantor: U.S. Department of Education Facility: CHI Health School of Radiologic Technology Finding: CHI Health School of Radiologic Technology had no documented evidence of review and approval of Satisfactory Academic Policy. Additionally, the Satisfactory Academic Policy did not contain all required elements according to federal regulations. Corrective Action Plan: CHI Health School of Radiologic Technology has revised the Satisfactory Academic Policy to incorporate the required components. Additionally, CHI Health will implement documentation procedures including an agenda and minutes for their annual meeting to review the school policies. Person Responsible: Robert Hughes, Program Director, CHI Health School of Radiologic Technology Expected Completion: June 2024

Due to turnover and transitions in key positions, on-boarding of agencies did not include these three locations on the annual site visit schedule. In FY 2024 new procedures have already been implemented for on-boarding, new personnel have been assigned oversight of agencies, and two compliance departments, one in Accounting and one in Partner Services, have been fully established to monitor compliance.

Cluster name: TRIO Cluster Assistance Listing number and name: 84.042 TRIO – Student Support Services 84.047 TRIO – Upward Bound Award numbers and years: P047A171009, September 1, 2017 through August 31, 2022 P047A170820, September 1, 2017 through August 31, 2023 P042A200873, P042A201342, and P042A200859, September 1, 2020 through August 31, 2025 P047A221154 and P047A221160, September 1, 2022 through August 31, 2027 Federal Agency: U.S. Department of Education Compliance Requirements: Eligibility Questioned costs: $5,612 Name of contact persons: Kristina Winterstein, Associate Controller, District Business Services Anticipated completion date: June 30, 2024 The District is aware of the importance of maintaining effective internal control over federal awards and ensuring compliance with applicable federal regulations. The District will work with the TRIO project directors at each college to review and revise existing procedures to require an independent and knowledgeable employee review and approve student eligibility determinations prior to awarding program services to them. The District will enhance communication and training efforts to ensure that the TRIO project directors and all staff administering the TRIO programs understand all eligibility requirements and related district-wide policies and procedures. As of March 21, 2024, the questioned costs for the program have been resolved.

Finding 2023-003 – Eligibility – Significant Deficiency in Internal Control over Compliance Management acknowledges the audit finding and wants to reinforce that despite challenges in the cost of attendance; there were no over or under-awards to students. To address this finding, our Quality Assurance team will oversee a weekly review of the cost of attendance to ensure financial aid packages align with approved budgets, enabling early identification of discrepancies for prompt correction. Based on these reviews, individual and group coaching will be implemented to address areas of concern. A refresher training and updated tools and guidance will be completed to reinforce best practices and align with institutional policy and procedure for calculating the cost of attendance. Through these concerted efforts, NU hopes to demonstrate its full commitment to addressing the audit findings. Contact Person Responsible for Corrective Action: Brandy Baker, Director of Quality Assurance Angela De Angelini, AVP Processing and Fiscal Operations Anticipated Completion Date: June 2024

Procurement Recommendation: We recommend that the Organization follow the current policies and procedures over covered transactions to maintain documentation supporting the procurement for 5 years following the end of the contract. Views of Responsible Officials: There is no disagreement with this finding. Action taken in response to finding: Enlace Chicago is committed to following the procurement process and requirements outlined within the policies and procedures. Name of the contact person responsible for corrective action: Laura Velazquez, Director of Finance Planned completion date for corrective action plan: June 30, 2024.

Finding # 2023-002: Significant deficiency over eligibility Immaterial noncompliance over period of performance U.S. Department of Education 84.044A TRIO Programs Cluster: TRIO – Talent Search Finding: Applications to the program should be reviewed and approved prior to acceptance into the program. Twenty applications out of 40 tested did not have proof of either initial or secondary review. Recommendation: Applications should have advisors or college prep specialists sign off and review prior to the program manager doing secondary review and acceptance. Corrective Action: We will have the Executive Director and College+ Program Manager ensure that all advisors review applications before sending to the College+ Program Manager for approval and acceptance. Anticipated Completion Date: June 30, 2024

2023-003 – Student Financial Aid Cluster – (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 (f) 84.379 – Year Ended June 30, 2023 Criteria: 34 CFR 685.203 states, "A student may not receive a Federal Direct Subsidized Loan amount that exceeds the student’s estimated cost of attendance for the period of enrollment less the borrower’s expected family contribution and estimated financial assistance for that period.” Condition: The College did not properly disburse direct loans for 1 out of 40 students (2.5%). Views of Responsible Officials: The financial aid office staff will complete the packaging aid and loans learning tracks on the Federal Student Aid Training Center. The staff will complete this training annually to ensure compliance of all regulations. Responsible Person: Andra Butler, Assistant Vice President of Financial Aid Implementation Date: October 2023

Recommendation: The Authority should designate an individual to review tenant files to ensure that the income reported on the HUD-50058 is supported with proper calculations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The HACMB currently has a Quality Control Coordinator who is designated to review samples of tenant files to ensure compliance. The HACMB has reviewed its Quality Control process for areas of improvement; (1) The Quality Control Coordinator will increase the number of file samples that are undergoing the Quality Control process. (2) The Quality Control Coordinator will hold bimonthly reviews with the specialists to ensure the same standard processes are being followed and to focus on each targeted area that needs assistance the most. The Section 8 staff will be notified of the appropriate action to take regarding any finding in the files. Name(s) of the contact person(s) responsible for corrective action: Suzie Millien, Director of Section 8-HCV. Planned completion date for corrective action plan: 3/31/2024.

Corrective Action Planned: Community Action Center of Northfield (CAC) is working with our food sourcing partners to investigate better accounting practices from their end to more accurately facilitate USDA food inventory before the food stuffs are delivered to CAC. Additionally, CAC will investigate cost-efficient models of physical inventory for in-kind donated (free) food. Name(s) of Contact Person(s) Responsible for Corrective Action: Scott Wopata, Executive Director, will be responsible for leading correct actions Anticipated Completion Date: While CAC is hopeful to receive more accurate inventory records from our food sources, this is outside of our control. Additionally, initial research into inventory management systems have proven extremely cost prohibitive as they relate to technology and/or labor, especially related to in-kind donated (free) food. We will pilot manual weekly inventory counts in the 2024/25 fiscal year with full corrective actions to reflect the outcome of those pilot studies.

Name of Responsible Individual: Chad Wick, Director Financial Aid Corrective Action: In an effort to maximize the utilization of student aid, current student workers were reviewed for FWS eligibility. Those students identified were awarded the FWS funds without being notified though they did indicate they were interested in FWS funds. The Financial Aid Office and Human Resources will collaborate to ensure that work study students are not allowed to start work until they have followed proper hiring procedures within the PeopleAdmin system. The Financial Aid office is also modifying the way this award will be offered in 2024-2025. The Financial Aid office will add this award to the automated process when students are first packaged. At that time, they will need to accept or decline the offer. From acceptance, the student will be prompted to complete a short training video on acquiring a University job. Upon completion of the video the students will be provided an automated link to the PeopleAdmin system where they will have access to the open jobs on campus. The Financial Aid office will receive an automated confirmation from the PeopleAdmin system that all necessary documents and training have been completed. The Financial Aid office will assign an individual to oversee this process. Anticipated Completion Date: June 30, 2024

Names of Responsible Individuals: Chad Wick, Director Financial Aid and Brian Emery, Associate Director Financial Aid Corrective Action: The University will transition from a manual awarding process to an automated process. The Financial Aid office was awarding this manually which led to mistakes when ISIR data changed or other awards were added or removed. FSEOG funds were used to assist students to pay off balances allowing them to register for the next semester. During the 2023 and 2024 fiscal years the Financial Aid office experienced several staffing changes including the termination of the Financial Aid Director. In March 2023, a consultant firm was engaged to assist with the 2024 fiscal year. The Financial Aid office will review all 2023-2024 FSEOG awards to ensure that student aid is calculated, awarded and disbursed correctly. The Financial Aid office will run a Fund Management Report to obtain a list of all students who were awarded FSEOG and compare that to the Pell Fund Management Report. This will ensure that all students who received FSEOG funds were also awarded Pell. The Financial Aid office will then review the amounts of the FSEOG awards to make sure no one was awarded more than the maximum threshold. The Financial Aid office will review the COA calculation for each student awarded FSEOG to verify that it was calculated correctly. For 2024-2025 the Financial Aid office has modified the packaging rules to automate the packaging of FSEOG which will eliminate any manual changes to the award. This should ensure that only students eligible for the award receive it and the amount is correct. The Financial Aid office has also modified the setup of their Student Information System for 2024-2025 so that the COA will be automatically calculated which should eliminate the need for any manual calculating of COA and eliminate improperly calculated COAs. Anticipated Completion Date: June 30, 2024

Management will continue to accumulate proper supporting documentation to support their compliance with the eligibility compliance requirement and to provide such documentation, when legally possible. Responsible party: Cynthia Amodeo, CEO Myra Ricard, Program Director Anticipated Completion Date: uncertain at this time due to existing New York State law.

Views of responsible officials and planned corrective action: Areas of focus will be to put in place written policies in procedures for the Financial Aid office, including the area of enrollment reporting, which is also done by Institutional Research, to provide appropriate updating of the NSLDS records. This will include creating checks and balances to be sure that enrollment reporting is working and being updating timely. The Federal Student Aid website offers many resources in the form of training, including access to on-demand resources which provide a documented learning assessment. Our objectives will be that all current and incoming Financial Aid staff, along with Institutional Research staff, will be required to undergo training in the area of enrollment reporting, including the supervisor with whom the Financial Aid office reports to. This training will be annually and periodically throughout the year. In addition, daily add and drop reports are generated which would allow more frequent updating of the NSLDS system. Objectives will be to put in place to provide checks and balances to be sure that enrollment reporting is timely. Measurable targets will be achieved by documenting the training within a shared electronic drive between the supervisor and the Financial Aid office. The Financial Aid office shall be responsible for monitoring that the enrollment reporting is being done timely. In addition, periodic and monitored checks-ins of staff in Institutional Research with whom the responsibility to update NSLDS is with.

Due to a sudden and unanticipated staffing shortage, R2T4 calculations were performed beyond the required timeframe. In the case where a student receives all F’s on their transcript, we cannot determine the students’ last date of attendance or academic activity, since F grades do not include this information (unlike W grades) and the college is a non-attendance taking institution. In this case, federal guidelines allows schools to use the midpoint of the payment period for the calculation. In these cases, all calculations would be based on the same date each term. In review of FA22 records, the calculations were performed in March 2023, but the withdrawal dates used to calculate eligibility were 10/21/22, the FA22 term midpoint. All policies and procedures relating to R2T4 processing have been reviewed and updated, and a review of all prior year calculations will be performed as well, to ensure compliance. Additional staff have been trained in the process, and calculations are being performed. Adequate and trained staff will ensure that all required calculations are performed accurately, and according to required timelines. In addition, the Financial Aid Office is transitioning from the SAM to the Colleague Financial Aid System (starting in 2024-25) which will provide a more automated and integrated process, with enhanced internal controls.

Corrective action plan: • On the first Friday of each month, the Housing Choice Voucher Program staff meets to discuss program policies and procedures for training purposes. At each meeting, specific aspects of administering the program are reviewed, along with the related HUD policies. Staff members are given the opportunity to ask any questions on any procedures or policies they may not understand. Activities from the Nan McKay Rent Calculation training are passed out to staff to complete individually. After staff completes the activity, the answers are reviewed as a group. Other activities take place which involve the staff answering questions regarding various case studies of situations that may occur in the daily activities of administering the HCV Program. • January 9th – 11th, all HCV and PBV Specialist received Combo HCV/LIPH Rent Calculation training with HOTMA updates from Nan McKay and Associates. • Review and update Administrative Plan/SOP with Policies and Procedures to ensure all staff is familiar with policies and procedures. • Staff restructuring • In-service meetings with Compliance Specialist as staff challenges some write ups of deficiencies to ensure that there are mutual understandings of policies. • HCV/Occupancy Specialists have been instructed to triple check all certifications for accuracy to mitigate the possibility for careless errors PERSONS INVOLVED HCV Case Management Staff Asset Manager RAD Project Based Voucher Community Manager Compliance Specialist Compliance Supervisor HCV Program Director Occupancy Specialist MONITORING The Compliance Supervisor and Specialist will continue to monitor files. The Compliance Supervisor and Specialist will begin adding the CFR Regulation and or Administrative Plan Policy and page number to each deficiency write-up to assist staff in understanding the error so that staff will not make consistent errors. The Compliance Supervisor will provide to staff recommendations for improvement. It is hopeful that a greater number of participant files will be audited throughout the year for both the HCV Program and for the PBV communities. On the first Friday of each month, the Housing Choice Voucher Program staff meets to discuss program policies and procedures for training purposes. During these meetings specific aspects of administering the program are reviewed, along with the related HUD policies. Staff members are given the opportunity to ask any questions on procedures or policies they may not understand. During many meetings, activities from the Nan McKay Rent Calculation training are passed out to staff to complete individually. After staff completes the activity, the answers are reviewed as a group. Staff also answers questions regarding various case studies that may occur in the daily activities of administering the HCV Program. We also have NRHA’s Compliance staff provide training to review common errors and to discuss any areas staff may have that are gray with audited files. Staff has also gone through an intensive training on the common errors per NRHA’s Compliance Department. Quarterly Quality Control trainings are held with caseworkers lead by the NRHA Compliance Department to address concerns and common errors. The Admission and Continued Occupancy Policies (ACOP) and Administrative Plan policies and procedures are reviewed to ensure that all staff has a clear understanding of the proper ways of calculating income, applying allowances, using proper payment standards, and approvals of lease ups and completion of certifications. A departmental quality control team was established to ensure there is consistency of policies and procedures and that when new procedures are implemented the processes are properly documented and disseminated to all staff. A departmental quality control sub-team was formed after the audit to include the actual custodians of program participant files comprised of:  1 Tax Credit PBV Property Manager  1 LIPH Property Manager  1 Compliance Specialist  1 Occupancy Specialist  1 Senior HCV Specialist  1 Tax Credit Administrative Assistant NRHA Caseworkers and Administrative Staff have been instructed to triple check all certifications for accuracy to mitigate the possibility for careless errors. The NRHA Compliance Department continues to audit files for the HCV Program to ensure that files are being processed properly; income calculated correctly, verifications are in the file, HAP payments issued are correct, and that units are inspected timely. Findings are noted and must be corrected by the Case Worker or Administrative Staff and the file is reevaluated by the Compliance Department to ensure findings were corrected. NRHA Caseworkers and Administrative Staff have been instructed to triple check all certifications for accuracy to mitigate the possibility for careless errors. The NRHA Compliance Department continues to audit files for the HCV Program to ensure that files are being processed properly; income calculated correctly, verifications are in the file, HAP payments issued are correct, and that units are inspected timely. Findings are noted and must be corrected by the Case Worker or Administrative Staff and the file is reevaluated by the Compliance Department to ensure findings were corrected. NRHA will continue to investigate the possibility of increasing the number of program participant files reviewed by the Compliance Department. NRHA has begun contract negotiations with a new software vendor. It is the feeling of the agency that with a different software platform the errors being made will lessen as the information gathered to perform rent calculations will be in a more automated form. It is anticipated that this will lessen staff time needed to enter the information and thus allow for more time to be spent verifying accuracy of information. The timeline for implementation is for the software to be live at the beginning of the 2026 fiscal year. This over-riding strategy is to be done in conjunction with the steps outlined below to mitigate this situation.

FINDING NO. 2022-004 Statement of Condition: Management had developed activity level controls over compliance that included compliance review of all tenant certifications of income used in determining the amount of rent amounts due from eligible PRAC 202 participants (tenants) by the Coast compliance department. However, during our testing, management had no documentation evidencing such reviews had occurred; further, during our interview process of site staff (community managers), staff asserted that no such reviews had occurred, and that no feedback on tenant certifications was provided by the compliance department. Auditor Recommendation: Management should have a process to review and approve all tenant certifications being prepared by site staff (community managers). The approval process should include an approval stamp or some other evidence that each file has been reviewed by the compliance department and is approved for processing. Further, senior management should have an ongoing monitoring process to ensure that the compliance department is carrying out the review process. Action Taken: Management agrees with the recommendation of the auditor, and will ensure that evidence of certification review and approval is documented with a approval stamp or some other documentary evidence.

Department staff has reviewed the Legislative Audit Bureau’s (LAB) interim audit memo for Finding 2023-300: Eligibility for the Children’s Health Insurance Program. This is the department’s Corrective Action Plan. Recommendation (2023-300): Eligibility for the Children’s Health Insurance Program We recommend the Wisconsin Department of Health Services work with the federal government to resolve these improper payments, including the determination of the total amount of improper payments, and return these amounts to the federal government, as appropriate. Wisconsin Department of Health Services Planned Corrective Action: The Division of Medicaid Services (DMS) acknowledges that we maintained eligibility under the Children’s Health Insurance Program (CHIP) for individuals who had turned age 19, including SCHIP participants. It was our overarching policy to not terminate health care coverage upon certain changes in circumstances for Medicaid participants during the federal public health emergency (PHE). To comply with this policy, DHS made system changes at the beginning of the pandemic to maintain eligibility for all participants. After CMS provided additional information specific to SCHIP, DHS considered whether to make the necessary system changes to terminate SCHIP participants who turned 19 during the public health emergency. Because of the system limitation and DHS’s overarching goals to maintain continuous coverage, amongst other reasons, DHS decided to temporarily keep all CHIP participants enrolled until the public health emergency ended. DMS leaders met with CMS leaders on May 11, 2022, to discuss this compliance issue and related systems limitations. During that meeting, CMS indicated that they understood the system and communication challenges of having a single program that combines Medicaid and CHIP. CMS also acknowledged that the federal public health emergency was likely to end at any time, so making the required system changes would not be prudent. CMS said they would follow up with Wisconsin if they determined that further state action was needed, but they did not communicate to us after the meeting that they felt the compliance issue needed to be addressed. This confirmed the Medicaid Director’s decision to not pursue costly systems changes to support a change that might only be needed for a short period of time. After the PHE ended, DHS took proactive steps to identify aged-out CHIP participants and ensure that their eligibility was redetermined in the first two months of unwinding. In contrast to the rest of the CHIP and Medicaid population, whose renewals were distributed over a 12-month period from June 2023 through May 2024, these members’ renewals were accelerated to June and July 2023, so that their CHIP coverage would end as soon as possible after the end of the PHE. While we agree conceptually with the finding, the questioned costs identified do not consider that many (if not most) of the ineligible members would have been eligible for Medicaid as childless adults upon aging out of the CHIP program. We will discuss this likelihood with CMS and if necessary, use data available in our CARES eligibility system to assess how many of these members did retain eligibility as childless adults or in other categories of Medicaid after completing renewals in June and July. Anticipated Completion Date: March 31, 2024 Person responsible for corrective action: Jori Mundy, Director Bureau of Eligibility and Enrollment Policy, Division of Medicaid Services jori.mundy@dhs.wisconsin.gov. Rebuttal from the Wisconsin Legislative Audit Bureau - As stated in the finding, and as acknoledged by DHS, DHS maintained continous eligibility for SCHIP participants who were over age 19. This eligibility requirement continue through the public health emergency. Since CHIP and MEDICAID are separate programs, consideration of whether these participants could have been eligible for the Medicaid program would not have been part of our audit. Payments to providers for these participants were funded by SCHIP and not the medicaid program.

Finding 2023-104: Homeowner Assistance Fund—Documentation to Support Applicant Eligibility and Benefit Payments Auditor Recommendation: Revise its procedures to ensure the Department of Administration completes a sufficient review to ensure adequate supporting documentation is included in the Homeowner Assistance Fund program’s computer system prior to an approval of the benefit payment. Planned Corrective Action: The Wisconsin Department of Administration (Department) will revise its procedures to ensure it completes a sufficient review to ensure adequate supporting documentation is included in the Homeowner Assistance Fund program’s computer system prior to an approval of the benefit payment. Auditor Recommendation: Provide training or other technical assistance to the community action agencies on the adequacy of supporting documentation agencies are to obtain, evaluate, and enter into the Homeowner Assistance Fund program’s computer system. Planned Corrective Action: The Department will provide additional training and technical assistance to the community action agencies on the adequacy of supporting documentation agencies are to obtain, evaluate, and enter into the Homeowner Assistance Fund program’s computer system, the requirements for which are as contained in its Wisconsin Help for Homeowners (WHH) Program Manual. Training and technical assistance will be provided through communications with program administrators and during program monitoring. The Department further notes that, after providing nearly $70 million in assistance to help prevent foreclosure through mortgage, tax, and utility payments to more than 8,600 Wisconsin households facing pandemic-related financial hardship, the WHH Program closed to new applications on March 8, 2024.Anticipated Completion Date: June 30, 2024. Persons responsible for corrective action: David Pawlisch, Administrator Division of Energy, Housing and Community Resources david.pawlisch@wisconsin.gov

Finding 2023-101: Homeowner Assistance Fund – Service Organization Controls Auditor Recommendation: Obtain the service organization audit report for the computer system used to administer the Homeowner Assistance Fund. Planned Corrective Action: The Wisconsin Department of Administration (Department) has requested and will obtain the service organization audit report for the computer system used to administer the Homeowner Assistance Fund. Anticipated Completion Date: Immediately following the issuance of the service organization audit report for the period ended May 31, 2024, which is anticipated to be received not later than September 30, 2024. Auditor Recommendation: Complete a review of the service organization audit report, assess the effectiveness of the internal controls on the computer system maintained by the service organization, and document its review. Planned Corrective Action: The Department will develop the means to inform and document its review of the service organization audit report and its assessment of the effectiveness of the internal controls on the computer system maintained by the service organization. The Department will utilize those means to evidence reviews and assessments it completed but did not document as reported to and by the auditors, and for future received service organization audit reports, including the report that will be obtained for the period ended May 31, 2024. Anticipated Completion Date: June 30, 2024, as related to the development and use of the means to evidence prior completed but undocumented reviews and assessments, and within thirty days of receipt of the service organization audit report for the period ended May 31, 2024, which is anticipated to be received not later than September 30, 2024. Auditor Recommendation: Complete a review of the complementary user entity controls at the Department of Administration that are required to be in place for it to rely on the service organization audit report, document its review, and implement user entity controls, if needed. Planned Corrective Action: The Department will develop the means to inform and document its review of the complementary user entity controls at the Department that are required to be in place for it to rely on the service organization audit report, and will implement user entity controls, if needed. The Department will utilize those means to evidence the review of complementary user entity controls it completed but did not document as reported to and by the auditors, and for complementary user entity controls contained in future service organization audit reports, including the report that will be obtained for the period ended May 31, 2024. Anticipated Completion Date: June 30, 2024, as related to the development and use of the means to document the prior completed but undocumented review, and within thirty days of receipt of the service organization audit report for the period ended May 31, 2024, which is anticipated to be received not later than September 30, 2024. Persons responsible for corrective action: David Pawlisch, Administrator Division of Energy, Housing and Community Resources david.pawlisch@wisconsin.gov

Finding 2023-103: Emergency Rental Assistance Program—Subrecipient Monitoring Auditor Recommendation: Review its existing monitoring procedures and ensure adequate management oversight procedures are established, documented, and followed. Planned Corrective Action: The Wisconsin Department of Administration (Department) has reviewed its existing monitoring procedures, designed to ensure that subrecipients use the subaward for authorized purposes, take timely and appropriate action on all deficiencies detected through monitoring, and comply with the terms and conditions of the subaward, as required by 2 CFR s. 200.332 (d) through (f), and its own policies and procedures. The Department will improve the completeness and effectiveness of its monitoring program by ensuring that management oversight procedures are appropriately established, documented, and followed. Auditor Recommendation: Complete review and follow-up with the community action agencies or Energy Services, Inc. (ESI) identified by its existing monitoring procedures. Planned Corrective Action: The Department will complete review and follow-up with the community action agencies or Energy Services, Inc. (ESI) in accordance with its existing monitoring procedures.Auditor Recommendation: Consider if additional monitoring should be completed for the community action agencies or ESI for the months during FY 2022-23 when the Department of Administration paused monitoring for the Emergency Rental Assistance Program. Planned Corrective Action: To maintain the integrity of its Emergency Rental Assistance monitoring program, the Department will complete additional monitoring of the community action agencies and ESI during FY 2022-23, including during the period acceptance of new program applications was temporarily paused. Anticipated Completion Date: June 30, 2024. Persons responsible for corrective action: David Pawlisch, Administrator Division of Energy, Housing and Community Resources david.pawlisch@wisconsin.gov

Finding 2023-102: Emergency Rental Assistance Program—Documentation to Support Applicant Eligibility and Benefit Payments Auditor Recommendation: Obtain required documentation for the four applicants we identified or seek to recoup improper benefit payments it made to these applicants. Planned Corrective Action: The Wisconsin Department of Administration (Department) requested and received from the auditors the four applicants they identified. The Department has reviewed available documentation in its eligibility and benefit determination system and will work with the responsible community action agencies and Energy Services, Inc. (ESI) to obtain required documentation supporting the applicants’ eligibility to receive Wisconsin Emergency Rental Assistance (WERA) Program benefits. Should the Department determine that it provided WERA Program benefits to ineligible recipients, it will seek to recoup the payments made. Auditor Recommendation: Provide additional training and technical assistance to the community action agencies and Energy Services, Inc. (ESI) on the adequacy of supporting documentation that is to be obtained and entered into Home Energy (HE) Plus by the community action agencies and ESI. Planned Corrective Action: The Department will provide additional training and technical assistance to the community action agencies and ESI on the adequacy of supporting documentation obtained and entered into Home Energy (HE) Plus, its eligibility and benefit determination system, based on its monitoring of accepted documentation. Anticipated Completion Date: June 30, 2024. Persons responsible for corrective action: David Pawlisch, Administrator Division of Energy, Housing and Community Resources david.pawlisch@wisconsin.gov

The Director of Nutrition Services, hired August 2023, has been trained on the verification process and procedures along with timeline compliance requirements.

Identifying Number: 2023-001: Adjustments to Project Rental Assistance Payments Condition/Finding: During our review of eligibility testing support, we noted that for the tenant’s annual reexaminations and certifications under HUD Project Rental Assistance Contract Number FL29-S951-006, the incorrect amount of contract rent was being utilized on the forms to calculate the projects tenant assistance payment. The Project incorrectly double counted the utility allowance of $51 and was using a gross rent rate of $833 to calculate the tenant rental assistance payment when it should have only used a gross rent rate of $782 per the contact. This resulted in the Project requesting a tenant rental assistance payment that was $51 more than what it should have been for each tenant on the Housing Owner’s Certification and Application for Housing Assistance Payments (HAP) for 3 months of fiscal year 2023. Upon the Project’s analysis, it was determined that the total amount of the error, net of vacancies, was $14,724. Corrective Action Taken or Planned: Management has established procedures to ensure that there is a better process to check the amounts of contract rent being approved on the re-examinations and certifications of tenants. This includes, but is not limited to, an additional review step and control for confirmation of the correct contracted and billed amounts. These additional procedures also include processes with more closely reviewed monthly HAP forms by the appropriate personnel to ensure that the amounts being requested of HUD are in line with the appropriate contract rates. Corrective action has been implemented with all corrections approved by and reconciled with HUD. This has already been fully implemented at the organization as of the date of this letter. The primary designated official is the Chief Financial Officer. With our best regards, Paul Dennison Chief Financial Officer

2023-005 Eligibility – Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The financial aid office designed a new process to coordinate with the academic office to review SAP status of students and ensure appropriate letters will be sent. Name(s) of the contact person(s) responsible for corrective action: Jason Benavides, Interim Director of Financial Aid Planned completion date for corrective action plan: 6/30/2025

2023-004 Eligibility – Assistance Listing No. 84.063 Recommendation: We recommend the College provide additional resources to ensure all compliance requirements are met. 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 works with the third-party servicer to ensure accurate and timely disbursement dates to COD. Name(s) of the contact person(s) responsible for corrective action: Jason Benavides, Interim Director of Financial Aid Planned completion date for corrective action plan: 6/30/2025.