Corrective Action Plans

Action Taken: The Houston Housing Authority agrees with this fining and related recommendations. During 2024 the voucher and public housing programs converted to a new software system. Yardi is not the principal operating system for both the voucher and public housing programs. This system conversion has required that work flows had to be modified. This modification and implementation of a new processing system did not allow staff to conduct the necessary reviews of existing files to make sure that the compliance related materials that should be found in each file were to be completed. This issue has been discussed and there will be an internal review conducted on file samples to determine what compliance deficiencies are prevalent. Corrective action steps will be implemented to address these issues designed to correct them. Additional training resources will be devoted to staff in these departments designed to improve quality control with these program areas. The Senior Vice President of Voucher Operations will be focused on improving the quality of our files that support the voucher operations.

Management concurs with the finding. The Organization revised its tenant monitoring procedures to ensure timely annual recertification of income and compliance with HUD rent adjustment requirements. Training is being provided to all property management staff, and management has implemented procedures to ensure all required actions are taken when a tenant becomes over-income. As of December 14, 2024 lease agreements have been updated to include language that states once a tenant is over the income limit, they are considered ineligible and their rent will immediately be adjusted to the HUD market rent.

Name of contact Person: Brittany Naylor, Director of Social Services Corrective Action: Lenoir County will implement the following for the Food and Nutrition Services case actions cited for the Single County Audit Fiscal Year ending June 30, 2024. • All workers will be given a 2nd party review form to utilize as a check off sheet to make sure everything needed was documented, attached, and forms sent correctly, etc. to ensure each case is updated correctly • Staff meeting will be held Wednesday, January 29, 2025 and the following printouts of policy/DSS Administrative letter will be given out to each worker and reviewed together as a group. DSS Administrative letter EFS_FNS_AL-35-2020 in regards to Telephonic Signature for Food and Nutrition Services Applications and Recertifications (amended) as of September I, 2020. (Where to document on applications and recertifications and must have a standalone note and cannot contain any additional characters or spaces). FNS policy 260 paragraph 12. Verbally explain and provide the ABAWD with the DSS 8569 Consolidated Work Notice, and explain that the case file must be documented with the date the notice was verbally explained, how the notice was given, if by hand deliver or mailed. Findings showed that the 8569 was created, but not changed to SENT from DRAFT. FNS 305 Rules for Budgeting Income, FNS 310 Budgeting New, Changed and Terminated Income, FNS 3 I 5 Special Budgeting Income, FNS 40 Deductions, FNS 350 Whose Income is Counted. Also explain to workers to double check attachments to make sure after being attached it could be pulled back up to review and to make sure information is attached as it should be. Ensure that SUA 's are updated correctly, that case information is documented and verified. • Supervisors will run and monitor NCF AST O&M reports daily to disparage overdue reviews or overdue applications. • Lead Worker turn in 2nd party reviews at least once or twice a week to be evaluated for error trends to the Staff Development Specialist for review. • Error trend rep011s are compiled by Staff Development Specialist and turned in monthly to Economic Services Administrator. • Staff Development Specialist will keep an excel spreadsheet detailing the errors cited and determine any error trends that need to be addressed. Unit meetings and individual conferences provided by the Supervisors in an effort to effectively catch and manage error trends that have been reported by the Staff Development Specialist. • Meetings held with Lead Workers, Medicaid Supervisors, Staff Development Specialist and Administrator to evaluate error trends. Monthly trainings held, as needed, to review error trend findings of 2nd party reviews completed with staff. • Providing staff with the knowledge of the audit information, the performance improvement plan and what staff expectations are. Staff Meeting to be held to address audit findings and to start training process for staff to obtain knowledge needed to remain in compliance with policy standards. Proposed Completion Date: February 15, 2025

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 2023-002 and continues to be an issue for Lenoir County. Several of these are system issues, but the primary root causes of these findings again were due to extreme staffing shortage of trained individuals during this fiscal year. Many of new staff in this division have been employed less than a year and are still in training. The work increase has caused a significant impact on this unit, but the unit works as a team to try to ensure work demands are being met daily. New staff members have been added and are showing improvement of policy and how to apply policy to case actions, which will help reduce the increased number of technical errors found during this audit period. Supervisors and Lead Workers continue to train with staff when errors from 2nd party reviews are discovered. Lenoir County takes immediate action to correct any findings and ensure that workers are made aware of job duties and expectations. Trainings, staff meetings, and conferences have already been conducted or planned to help workers to understand these errors that were cited and the importance of mitigating these errors while completing daily case actions. Lenoir County has always been committed in completing work demands effectively, timely and efficiently as possible. Lenoir County will continue to implement the strategies and work diligently to ensure that the following goals and standards are being met. Lenoir County has effectively maintained the required accuracy standards rate of 96.8% or higher when determining eligibility for case actions, approvals, terminations and denials Implementation of new Staff Development Specialist, Jacqueline Thomas, to the team to help lead and direct Lead Worker to fulfill job duties and requirements and to ensure that work demands and goals are being met effectively and timely. Staff Development Specialist and Lead Workers to implement hands on classroom activities using a variety of sources and techniques in an attempt to guide and teach staff. Tools used to implement training would 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. Traditional lecture type atmosphere provided in a classroom setting. Structured tests given to workers to detect where weaknesses could be in an effort to streamline and strengthen a workers skill set. • NCFast Help Job Aids, NC DHHS policy for Medicaid for Families and Children or for Medicaid for the Aged, Blind, and Disabled manuals created and given to each worker for reference material to study during training processes. • Review and application templates provided to each worker to give them a guided checklist to aide them with completing case actions in work assignments. • Supervisors will run and monitor NCF AST O&M reports daily to disparage overdue reviews or overdue applications. • Lead Workers turn in 2nd party reviews at least once or twice a week to be evaluated for error trends to the Staff Development Specialist for review. • Error trend reports are compiled by Staff Development Specialist and turned in monthly to Economic Services Administrator. • Staff Development Specialist will keep an excel spreadsheet detailing the errors cited and determine any error trends that need to be addressed. Unit meetings and individual conferences provided by the Supervisors in an effort to effectively catch and manage error trends that have been reported by the Staff Development Specialist. • Meetings held with Lead Workers, Medicaid Supervisors, Staff Development Specialist and Administrator to evaluate error trends. Monthly trainings held, as needed, to review error trend findings of 2nd party reviews completed with staff. • Providing staff with the knowledge of the audit information, the performance improvement plan and what staff expectations are. Staff Meeting to be held to address audit findings and to start training process for staff to obtain knowledge needed to remain in compliance with policy standards. • Continue to complete 100% 2nd party reviews on all new workers and pull findings within month of completion. New workers should be released from 100% 2nd party review process and move to process listed above when accuracy rating meets 98% for three consecutive months. Proposed Completion Date: For policy compliance will start immediately and goal completion is set for February I5, 2025. Trainings conducted to remedy policy misinterpretations, by conducting monthly meetings, one-on-one conferences, and completion of remedial testing either through the Learning Gateway or unit created tests.

Name of contact Person: Brittany Naylor, Director of Social Services Corrective Action: This finding continues to be listed as an ongoing eligibility determination error from prior audits. Lenoir County has been actively and aggressively working on the backlog of the expa1ie reviews to complete this report. Based on NCFAST system, there are no other reports beyond June 2019, however, the expartes in question were dated prior to this date. Steps implemented to mitigate and resolve this issue have been thwarted due to limited staffing and increase work demands. The goal is for Lenoir County to have the backlog completed by July 31, 2025. The overall plan for Lenoir County has been effective even with these issues or concern. In the prior plan, Lead Workers were instructed to pull all the SSI Exparte reports (3) from the NCFAST system weekly and manage these reports effectively. Lead Worker would either complete or assign exparte reviews to staff for completion. Supervisors would then receive lists from the Lead Worker showing the number of expartes assigned to each worker and the Supervisor must check reviews each week against the workers' application pending logs. The reports are to then be checked by the Lead Worker and Supervisor for completion and verified monthly. To help mitigate this problem, the following additional steps will be implemented to the existing plan of action to ensure that Lenoir County meets this goal. •Implementation of new Staff Development Specialist, Jacqueline Thomas to the team to help lead and direct Lead Worker to fulfill job duties and requirements and to ensure that work demands and goals are being met effectively and timely. •Staff Development Specialist will meet with the Lead Worker and get weekly updates on the progress until backlog report has been completed and finalized. •Staff Development Specialist will keep a detailed report on any issues and concerns and give a weekly report to the Administrator on the status of this issue. •Administrator will give updated status report to the Director at monthly meetings. Proposed Completion Date: As of this date, Lenoir County is still working to complete the backlog from June 2019 -December 31, 2022.

Views of Responsible Officials: Management agrees and will plan to submit the June 30, 2025 Single Audit by March 31, 2026.

CHES! has implemented a new process in entering the sliding fee applications in the Electronic Health Records system (Nextgen) to ensure compliance with the program requirements of the sliding fee program. The new process includes a thru date for all sliding fee applications at which time an alert will pop-up when the file is accessed that the sliding fee application has expired.

U.S. Department of the Treasury Department of Housing and Community Development respectfully submits the following corrective action plan for the year ended June 30, 2024. Audit period: July 1, 2023-June 30, 2024 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAMS AUDITS Department of Housing and Community Development 2024-014 COVID-19 – Emergency Rental Assistance Program – Assistance Listing No. 21.023 Recommendation: We recommend that the Department review and enhance supervisor review and approval to ensure that program requirements are consistently performed. Documentation to support compliance with the requirements should be maintained and readily available for review. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The subrecipient who administered the assistance for three (3) of the four (4) affected records has fully expended ERA 2 funds. DHCD will review the subrecipient’s internal approvals process and tenant notification process to determine where improvements can be made and issue recommended recordkeeping changes for the subrecipient to implement for future federal subawards. DHCD will review and make necessary changes to program policy guides as necessary to strengthen case file recordkeeping requirements and ensure that case file reviews for direct financial assistance programs include a review of notifications to clients. In prior desk monitoring and file audits, the relevant subrecipient files always included a notification of assistance to the tenant. Name(s) of the contact person(s) responsible for corrective action: Danielle Meister Planned completion date for corrective action plan: April 30, 2025 2024-015 COVID-19 – Homeowner Assistance Fund – Assistance Listing No. 21.026 Recommendation: The Department should reevaluate current process, implement proper controls, and perform additional training over time and effort reporting. The Department should not seek federal reimbursement unless they can substantiate that the time and effort was dedicated to the federal program. Documentation should be readily available for audit. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Monthly reporting to Senior Management of any exceptions to the federal timesheet process will be required to ensure that all federal timesheets are completed and received in a timely manner. Name(s) of the contact person(s) responsible for corrective action: Wade Simmons Planned completion date for corrective action plan: April 30, 2025 If the U.S. Department of the Treasury has questions regarding this plan, please call Crystal Quinzani at (301) 429-7840.

Department of Labor (DOL)Financial Statement Preparationinancial Statement Preparation. Unemployment Insurance – Assistance Listing No. 17.225 Recommendation: We recommend the Department implement procedures and internal controls to ensure that it complies with program requirements, that it maintains documentation, and that documentation is readily available for audit. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Recommendation: We recommend the Fund establish procedures to ensure that financial reporting is performed in a timely manner and provide accurate and relevant information. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The team that was assembled to work through the audit has also been enlisted to redesign the process and build new tools to create UI Trust Fund financial statements every month. While this is still in development, we plan to have it functioning accurately by May of 2025. Name(s) of the contact person(s) responsible for corrective action: John Fahnbutu. Planned completion date for corrective action plan: 5/30/2025 Recommendation: We recommend the Fund establish procedures to ensure that financial reporting is performed in a timely manner and provide accurate and relevant information. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The team that was assembled to work through the audit has also been enlisted to redesign the process and build new tools to create UI Trust Fund financial statements every month. While this is still in development, we plan to have it functioning accurately by May of 2025. Name(s) of the contact person(s) responsible for corrective action: John Fahnbutu. Planned completion date for corrective action plan: 5/30/2025 Maryland Department of Labor- Unemployment Insurance Trust Fund (the Fund) respectfully submits the following corrective action plan for the year ended June 30, 2024. Audit period: July 1, 2023-June 30, 2024 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FINANCIAL STATEMENT AUDIT MATERIAL WEAKNESS

14.251 Economic Development Initiative, Community Project Funding, and Miscellaneous Grants Federal Grantor: Department of Housing and Urban Development Compliance Requirement: Internal Controls over Procurement, Suspension and Disbarment Criteria: Non-federal entities who receive federal grants may not contract with entities that are suspended, disbarred, or otherwise excluded from receiving or participating in Federal awards. Condition: The Organization did not have controls in place to ensure vendors were eligible to receive federal awards. Cause: The Organization did not implement proper internal controls to verify that all contractors were eligible to participate in programs funded with Federal awards. Effect: Without proper internal controls, the Organization may not properly identify vendors that are ineligible to participate in federal contracts. Questioned Costs: None. Auditor's Recommendation: We recommend policies and procedures be implemented related to suspension and disbarment whereby the Organization can identify any ineligible contractors prior to entering in to any contracts with vendors. Corrective Action: The Organization will implement appropriate policies and procedures related to suspension and disbarment as part of any future grant application and management process. We will identify ineligible contractors prior to entering into vendor agreements and will monitor existing contractors to ensure they have not become ineligible.

Action Taken: Management acknowledges the findings and the material weakness in internal control and material noncompliance in its waiting list management. We accept responsibility for the deficiencies in internal control over the waiting list and are committed to implementing corrective actions that address missing documentation and lack of transparency in following the Authority's Administrative Plan and HUD guidelines when selecting applicants from its waiting list. Immediate corrective actions include: • Only using the electronic records of applicants from the Authority's housing software and not creating external waiting lists. • Reconcile and Reconstruct: Immediately reconcile the waiting list and reconstruct missing documentation for voucher issuance. • Cleanup Waiting List: The Authority's waiting list is closed, and staff are currently working to purge it. • Update Procedures: Ensure staff know and are trained on waiting list procedures to ensure compliance with HUD regulations and the Authority's Administrative Plan. • Implement Controls: Establish a periodic supervisory review to verify document completeness during the voucher issuance process. • Training: Provide staff with ongoing training on proper, consistent, and compliant wailing list administration. • Retention: Ensure all records are maintained according to federal retention requirements. Name of Responsible Person: Catherine Lamberg, CEO, and Jackie Otto, COO, and Daporsha Abernathy, HCVP Director Projected Completion Date: Some of the corrective activities are underway. We anticipate completing these activities by June 1, 2026.

Finding: 2024-005 Material Weakness in Internal Control Over Eligibility – WIC Special Supplemental Nutrition Program for Women, Infants, and Children (10.557) Corrective Action: We will develop a checklist for eligibility documentation and conduct quarterly file reviews and implement corrective actions as a result of those reviews. We will also provide training to program staff on the eligibility documentation requirements. Proposed Completion Date: February 28, 2026 Name of Contact Person:Tomiko Fisher, Chief Operating Officer

Finding: 2024-004 Material Weakness in Internal Control Over Special Tests – Health Center Program (93.224) Corrective Action: We will develop a checklist for patient discount documentation and implement a control requiring supervisor approval for overrides. We will also perform monthly file audits and report exceptions to the appropriate personnel. Proposed Completion Date: February 28, 2026 Name of Contact Person: Lane Baker, CHW Chief Operating Officer

2024-005 Material Weakness in Internal Control over Compliance 10.558 – Child and Adult Care Food Program Commonwealth of Pennsylvania, Department of Education Contract Number: 359-46-477-8 Condition: During our testing of participant eligibility, we selected a sample of 40 participants receiving meals at centers contracted with the CBS Food Program. For 2 of the 40 participants, management was unable to provide complete and valid eligibility documentation. In one instance, the only available eligibility form had been prepared in a future fiscal year, and in another instance, the eligibility form could not be located at all. Recommendation: We recommend that management strengthen its CACFP eligibility documentation procedures to ensure that all required forms are properly completed, collected, and retained for every participant. This should include implementing a standardized intake process, maintaining timely reviews to confirm completeness of eligibility files, and developing a tracking or monitoring system to identify missing or outdated documentation. Management should also reinforce internal expectations for timely updating of eligibility files and ensure staff are trained on CACFP documentation requirements. Repeat Finding: No Explanation of Disagreement with Audit Finding There is no disagreement with the audit finding. Action taken in response to finding: On February 1, 2025, Community Benefit Solutions rolled out the KidKare software system wide. KidKare is a CACFP software that allows Community Benefit Solutions to digitally process all eligibility-documentation, standardize the enrollment procedures, ensure forms are completed in accordance with the relevant regulations, request updated documentation upon the expiration of enrollment forms, and digitally store all the eligibility related information for all participants. Planned completion date for corrective action plan: June 30, 2025

Concord’s Compliance Dept has implemented procedures to ensure the tenant security deposits are correctly recorded, tenant eligibility is correctly determined and that the tenant lease files are properly maintained in accordance with HUD’s requirements.

The District acknowledges that the fiscal year 2024 Single Audit was not completed within the nine-month deadline. Fiscal year 2024 was the District’s first year meeting the expenditure threshold requiring a Single Audit, and staff were not previously aware that the Single Audit shared the same nine-month reporting requirement as the annual financial statement audit. The District is implementing procedures to prevent recurrence, including obtaining additional training on Single Audit requirements and updating internal reporting calendars to ensure timely completion in future years. The District is committed to compliance with all federal and state reporting requirements moving forward.

Management Response The owner/manager of the building, St. Philip the Evangelist Episcopal Church, occupied by St. Philip’s Child Development Center (the Center) declared bankruptcy and ceased operating in November 2024. Maintenance on building systems and its structures had been deferred for several years. On July 27, 2025, the building experienced a roof leak causing a catastrophic flood. The building was evacuated and the Office of State Superintendent (OSSE) notified. OSSE sent an inspector to the site the following day who declared the building unsafe for occupancy. The Church was unable to cover any costs for the necessary repairs. On July 30, 2025 the Board of Directors made the difficult decision to suspend operations, but to continue as a Board, maintain the Center’s 501(c)3 status and its corporate registration. Furthermore, the Board is using this time to research current community needs, space availability and cost, and the effect of the Federal government’s waning support for early childhood education. Once this exercise is complete, the Board will determine the Center’s ability to reopen in an alternate site and address the findings in an appropriate manner.

Review individual grants for eligibility and documentation requirements • Create a policy to review the application for eligibility and ensure second approval on each application • Retain all documentation required by the grants

FINDING 2024-013 Finding Subject: Title I Grants to Local Educational Agencies - Eligibility Contact Person Responsible for Corrective Action: Tricia Hudson, Curriculum Director & Federal Grants Administrator Contact Phone Number and Email Address: 812.279.3521, ext. 16242; hudsont@nlcs.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The school district will maintain documentation of the nonpublic schools’ rosters with supporting poverty documentation in the form of free and reduced meal applications saved on file with the Title I application annually. Anticipated Completion Date: The school district began the practice above for the 2023-24 school year. The school district has supporting documentation of free and reduced lunch status for nonpublic school students for the 2023-24 school year and moving forward. This corrective action will be fully completed by June 30, 2026.

Federal Agency: US Department of Education Federal Program Name: Federal Perkins Loan Program Assistance Listing No.: 84.038 Recommendation: We recommend reviewing procedures around Perkins Loan Program funds and implementing reconciliations and review to the third-party servicer reports. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The university has implemented policies and procedures regarding reconciliations for Perkins loan services managed by a 3rd party supplier. Name(s) of the contact person(s) responsible for corrective action: Danyel Tolbert, Bursar Planned completion date for corrective action plan: Complete

Federal Agency: US Department of Education Federal Program Name: Federal Perkins Loan Program Assistance Listing No.: 84.038 Recommendation: We recommend reviewing procedures and requirements regarding Perkins third-party service providers to ensure compliance with regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The university has implemented policies and procedures regarding reconciliations for Perkins loan services managed by a 3rd party supplier. Name(s) of the contact person(s) responsible for corrective action: Danyel Tolbert, Bursar Planned completion date for corrective action plan: Complete

2024-005 – Insufficient Financial Management Finding: Our audit procedures disclosed that the Organization drew down more revenues than expenditures incurred. Recommendation: We recommend that Homeward Bound Adirondack, Inc. establish oversight practices to ensure that all revenues and expenses are recorded appropriately and reconciled to the proper drawdown requests Action Taken: We are creating a policy and procedure to include the bookkeeper submitting the weekly expenses to the Executive Director for review and sign off prior to executing the draw downs to ensure proper allocation of costs. The Executive Director has contacted the Fox grants team concerning this matter.

2024-003 – Ineligible Program Participants Finding: Our audit procedures disclosed that several program participants were determined ineligible based on missing documentation of participants being a veteran or having qualifying military service. Recommendation: We recommend that Homeward Bound Adirondack, Inc. implement an eligibility checklist to ensure all required eligibility documentation is complete and accurate prior to approving payments. We also recommend Homeward Bound Adirondack, Inc. provide appropriate training to staff on documentation of eligibility requirements and that their training be documented for each staff. Action Taken: Policies have been developed and were reviewed at mandatory staff training on 10/29/25

Finding # 2024-002: Significant deficiency over eligibility 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. One application out of 40 tested had the same person doing initial and secondary review. Recommendation: Applications should consistently have advisors or college prep specialists sign off and review prior to the program manager doing secondary review and acceptance. Corrective Action: Management adopted a policy requiring separate reviews effective April 2024. The exception noted occurred before the new policy was implemented. 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: April 2025

Supporting Documentation for Family Size Allowable Costs, Eligibility – Housing Choice Vouchers – CFDA No. 14.871 Recommendation: Management should create an internal monitoring system to ensure that tenant files are scanned/saved appropriately, and the documentation meets all program guidelines. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management is reviewing work completed by the Housing Specialists more frequently, by performing more Quality Control evaluations, reviewing software-flagged errors, and establishing more check-ins with staff who are producing frequent errors. If frequent errors persist after consistent coaching, Corrective Action Plans will be put in place for those staff members. Termination of employees unable to produce accurate work will be enforced if coaching and Corrective Action Plans prove unsuccessful. Names of the contact persons responsible for corrective action: April Clark and Nicole Thompson Planned completion date for corrective action plan: Currently Implemented & Ongoing