Corrective Action Plans

We agree that CAC did not summarize agency wide or program specific internal controls and reporting requirements as required by 2CFR 200.303 and the CAC Management Services Manual. In order to ensure that the reporting requirements and specific internal controls of all awards made to CAC are summarized in adherence to 2 CFR 200.303 and the CAC Management Services Manual, the following corrective action will be implemented: Beginning in the FY2025 fiscal year, CAC will add a senior level staff position designated as Director of Compliance. The Director of Compliance will review and update current policies and procedures regarding specific internal controls, compliance reporting and eligibility for all awards received by CAC. The Director of Compliance will work with the Chief Program Officer and the Chief Financial Officer to ensure the development and application of program specific procedures and internal controls for reporting and determining eligibility for federal award programs. The projected date for full implementation of the corrective action plan for this finding is June 30, 2025. The contact persons for this corrective action are: Barbara Kelly, Executive Director, Windie Wilson, CAC Human Resources Director, Misty Goodwin, CAC Chief Program Officer, David Mincey, CAC Fiscal Services Manager/Internal Auditor, CAC Director of Compliance, to be selected.

The financial aid department has developed a Direct Loan workflow process in accordance with federal guidelines. Utilizing Colleague's software, the financial aid office can now accurately assess students' aid eligibility to ensure they are appropriately awarded. Colleague has Award Eligibility Critiera (AEC) rules invoked at transmittal to determine if the student is eligible to receive loan funds.

2022-001 Condition: Deficiencies Noted in Maintenance of Tenant Files Steps to resolve: Management agrees with the audit finding and the auditor’s recommendation. We will implement procedures and changes to ensure that this finding will be cleared by the subsequent fiscal year audit. Individual responsible for correction: Mr. Damon Dunbar, Executive Director Timeframe: As of December 31, 2024

2022-002 a. Name of Contact Person Responsible for Corrective Action Name: Mary Beth Sheffield Title: Child Nutrition Director Phone Number: 662-423-3206 b. Corrective Action Planned: The District will increase training to appropriate personnel and ensure all documentation is fully reviewed to make sure requirements are met before processing eligibility applications. c. Anticipated Completion Date: 10/08/2024

The Organization accepts the recommendation of the auditor. In the future, the Organization will implement an additional internal control regarding the verification of eligibility for Educational Opportunity Centers' participants. Specifically, in cases where the staff member who signed the "Verification of Eligibility and Acceptance" form does not check off the citizenship status or need areas on the form, the data entry specialist will return the participant folder to that staff member to obtain the required eligibility information before including the participant in the database. In the event that the eligibility information is unobtainable, the participant will not be input into the database nor counted as a participant. In addition, more periodic testing of files will be undertaken to identify any participants who do not have the necessary eligibility information, with corrective action taken as needed.

Finding 2022-003 Federal Agency Name: Department of Health and Human Services Program Name: COVID-19 Provider Relief Fund and American Rescue Plan Federal Financial Assistance Listing: #93.498 Initial Fiscal Year Finding Occurred: 2021 Finding Summary: The Corporation did not have an adequate internal control policy in place to ensure review and approval of the lost revenue calculation and report submitted to the Department of Health and Human Services for Period 3 and Period 4. Responsible Individuals: Renee Henry, Corporate Controller Corrective Action Plan: Management will implement a control process which includes a secondary review and approval of any future lost revenue calculation and report submitted under the federal program. Anticipated Completion Date: March 31, 2024

Finding 2022-003 Federal Award Finding Name of Official Responsible for Corrective Action: Earl Richardson, First AME Housing Association Interim Executive Director Corrective Action Planned: Explanation: We acknowledge the oversight and would like to provide context to understand better the circumstances that led to the delay. We had internal challenges when our previous management company departed, leaving us with incomplete files and late recertifications or recertifications that never started, making it next to impossible to catch up promptly. Next, staff staffing issues contributed to the delays because staff members were not properly trained. Despite these challenges, we recognize the importance of adhering to HUD regulations and are committed to taking corrective measures. Corrective Actions Taken: We initiated immediate corrective actions to rectify the situation upon discovering the late recertifications. We have instituted the following measures to prevent the recurrence of late annual recertifications: 1. Created a recertification schedule and calendar with the annual recertification date, specific dates to notify residents that their annual recertification is due, and dates for submitting the information to CMS and to trac. The schedule and calendar are submitted to the executive director every two weeks to monitor progress, and a meeting is scheduled with staff every two weeks to review recertification issues. 2. We hired a consultant specializing in recertification to train the staff and work with staff daily to answer questions concerning our certification. Our recertification consultant is permanently on call to answer certification issues and continuous staff training. These measures are designed to ensure timely compliance with HUD regulations and to strengthen our internal processes.

Finding 2022-002 Federal Award Finding Name of Official Responsible for Corrective Action: Earl Richardson, First AME Housing Association Interim Executive Director Corrective Action Planned: Reviewing the audit report, we acknowledge discrepancies in our income calculation and verification processes. We understand the critical importance of accurate income assessments in determining HUD HAP eligibility and share your commitment to maintaining the program's integrity. To rectify the identified issues, we have initiated the following corrective actions. 1. Review and Update Procedures: We have thoroughly reviewed our existing income calculation and verification procedures. Based on this review, we are revising and updating our procedures to ensure compliance with HUD regulations and guidelines. 2. Staff Training: Recognizing the importance of well-trained staff in accurately executing income verification processes, we are implementing a comprehensive training program. This program will cover HUD guidelines, income calculation methods, and verification protocols to enhance the skills of our staff involved in the eligibility determination process. 3. Internal Audits and HUD Compliance Control: We are implementing an internal audit and compliance control program to regularly review and assess our income calculation and verification This proactive approach will help identify and address potential issues before they escalate. We have hired an outside consultant skilled in HUD compliance to review all new applications for compliance and to communicate with staff the corrections needed before tenant applications are submitted to CMS and Trac for final approval and payment. 4. Enhanced Documentation: We understand the significance of maintaining detailed and accurate documentation. Our organization is implementing measures to enhance documentation practices, ensuring that all relevant information is recorded and readily available for audit purposes. By doing this, we assure you that this will not be a repeat finding. 5. Communication and Collaboration with HUD: We are committed to maintaining open lines of communication with the HUD office. Any changes to our procedures, policies, or protocols related to income calculation and verification will be promptly communicated to the HUD office for review and feedback. We aim to ensure that our organization fully complies with HUD requirements and that we continue to provide accurate and reliable information for HAP eligibility.

The district no longer exists due to consolidation. The proper process will be practiced in the new district for the allocation of Title 1 funds by the Director of Federal Programs. Anticipated completion date: 6/30/23

Item 2022-001 – Eligibility: Eligibility for Individuals Federal Program – Healthy Start Initiative Assistance Listing Number – 93.926 Material Weakness Condition: The Council did not have internal controls established for an independent review that the participants accepted into the program met the qualifying criteria. Eligibility may be determined by the Council employees or by certain health care facilities. Corrective Action: The Healthy Start Program does monitor clients closely for eligibility according to their residential zip code (the primary criteria for eligibility.) and verified perinatal status. The Fatherhood Program, requires participants have a partner who participated in the Healthy Start program. Beginning October 1, 2022, the Program Coordinator for Healthy Start reviewed the eligibility documentation to verify status but did not sign documentation for this verification. The Healthy Start Program transitioned to another local non-profit October 31, 2023.

Phillips County Housing Authority respectfully submits the following corrective action plan for the year ended December 31, 2022. Contact person responsible for corrective action: Ms. Edna Turner, Executive Director Name and address of independent public accounting firm: Miller & Rose, PA 1309 East Race Searcy, AR 72143 Audit period: Year ended December 31, 2022 Oversight Agency: U.S. Department of Housing and Urban Development Federal Financial Assistance Listing No. 14.871 Housing Choice Voucher 2022-001 Tenant Files Condition and Criteria: The Authority’s purpose for existence is providing decent, safe and affordable housing to low-income persons. As such, the Authority prepares a file for each admitted family, which contains information necessary to determine eligibility for assistance and calculations of rent assistance to be paid on the family’s behalf. HUD regulations prescribe the content of these family files. These requirements consist of the following: a. As a condition of admission or continued occupancy, require the tenant and other family members to provide necessary information, documentation, and releases for the PHA to verify income eligibility. b. For both family income examinations and reexaminations, obtain and document in the family file third party verification of: (1) reported family annual income; (2) the value of assets; (3) expenses related to deductions from annual income; and (4) other factors that affect the determination of adjusted income or income-based rent. c. Determine income eligibility and calculate the tenant’s rent payment in accordance with HUD regulations. d. Select tenants from the public housing waiting list in accordance with the PHA’s tenant selection policies. e. Reexamine family income and composition at least once every 12 months and adjust the tenant rent and housing assistance payment as necessary. Population and Items Tested: Testing of the thirty-seven files revealed the following deficiencies: 1. One file lacked proper utility allowance documentation. 2. One file revealed an incorrect Housing Assistance Payment. 3. One file in which a lease and housing assistance payment contract was not executed. Recommendation for Corrective Action: A thorough review of tenant files should be performed for the purpose of eliminating the deficiencies. Responsible Official’s Response: We will comply with the auditor’s recommendation. We continue to strive to eliminate any deficiencies in this area. We have instituted checklists and review procedures to preclude any errors in documentation. Anticipated Completion Date: November 1, 2023

The management overseeing the process has been completely replaced to ensure a fresh perspective and unwavering dedication to implementing robust internal controls. To address the shortcomings identified in Finding 2022-003, the Authority commits to a targeted action plan aimed at ensuring timely compliance with reporting requirements. Central to our approach is the engagement of a fee accountant, recognized for expertise in HUD reporting and public housing financial management. This specialist will be tasked with overseeing and streamlining our reporting processes. By leveraging this expertise, we aim to quickly rectify past reporting lapses and ensure future submissions are timely and compliant with HUD requirements. The new fee accountant will conduct a comprehensive review of our current reporting mechanisms, identify bottlenecks, and implement best practices tailored to our operations. This decisive action, centered around the expertise of the newly appointed fee accountant, demonstrates our commitment to enhancing our financial management practices and aligning with HUD's reporting expectations. Through these measures, we anticipate not only meeting HUD's deadlines but also setting a new standard for operational excellence within our Authority.

Finding Number: 2022-009 Planned Corrective Action: Monthly financial statements are now completed to ensure evidence for each entity. The staff in finance is working on more timely audits. Anticipated Completion Date: September 2024 Responsible Contact Person: Sherrie Boudinot

Even though the Academy transferred $683,606 of ESSER funds to LKAYA based on the intergovernmental agreement that was in place during that time, the Academy itself did incur ESSER eligible costs that could have been applied against these ESSER dollars if they had remained within the Academy. The costs incurred involved improvements to technology, maintaining and increasing additional staff, curriculum materials, instructional supplies, and staff training to name a few.

CORRECTIVE ACTION PLAN Program: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing No.: 21.027 Federal Agency: Department of the Treasury ? Pass-through from the State of California Award No.: WWID 4SSO10370 & CA 1910156 Award Year: Fiscal year 2021-2022 Category of Finding: Activities Allowed or Unallowed, Allowable Costs Name responsible for correction action plan: Emily Armstrong, Revenue Services Manager The corrective action planned: Payments applied to the 93 water bills and 81 wastewater bills will be reversed on the customer?s accounts. A notice will be issued to customers via mail and email (where possible) of the discrepancy. The funds will be returned to the State pursuant to their outlined procedures. Moving forward, the City will ensure that there is a multi-layered approval process to review the eligibility period of any State funding to identify the correct eligible applicants prior to disbursement. For future funding related to water and/or waster bills, the list of eligible applicants will be compiled by an analyst within the department and will be reviewed by the Revenue Services Manager and Assistant Finance Director prior to disbursement. Anticipated completion date: March 24, 2023

2022-003 Eligibility – Tenant Files Section 8 Housing Choice Vouchers Program – CFDA Number 14.871 Mainstream Vouchers – CFDA Number 14.879 Material Weakness in Internal Control and Material Noncompliance Repeat of Finding from March 31, 2021 (Finding 2021-003, Significant Deficiency) Condition: Out of a total tenant population of approximately 1,775 tenants, 25 files were selected for testing, but testing was suspended after 24 files due to the number of errors. Exceptions were noted as follows: • 1 tenant file error where the Authority performed their rent reasonableness procedures on a 2-bedroom unit for a 1-bedroom unit, and the comparable rents did not appear reasonable. • 1 tenant file had the following errors and correcting the errors would decrease the HAP rent by $23: o 1 error for miscalculation of the tenant’s social security income o 1 error for miscalculation of the tenant’s medical expense. • 1 tenant file had the following errors: o Two members of the household did not check the box on the 214-affidavit form indicating their eligible immigration status, but based on their birth certificates, they have eligible immigration status. o Miscalculation of the tenant’s utility allowance amount. Correcting the utility allowance amount would not change the HAP rent. • 1 tenant file error where the utility allowance amount was calculated correctly but was reported incorrectly on the 50058 form. Correcting this error would not change the HAP rent. • 1 tenant file had the following errors: o The 50058 form reported the wrong number of bedrooms in the unit. o The tenant did not sign the lease agreement. • 1 tenant file error where the tenant’s utility allowance amount was calculated incorrectly. Correcting the utility allowance amount would not change the HAP rent. • 1 tenant file had the following errors & correcting the errors would decrease HAP rent $11: o Miscalculation of the tenant’s social security income o Miscalculation of the tenant’s medical expense. • 1 tenant file had the following errors and correcting the miscalculation of tenant’s income and utility allowance would decrease the HAP by $8.: o Miscalculation of the tenant’s supplemental security benefit o Miscalculation of the tenant’s utility allowance amount. o The tenant’s supplemental security benefit income was coded as social security income when it should have been coded as supplemental income on the 50058 form. o Missing 214-affidavit form for a member in the tenant’s household, but based on their birth certificate, they have eligible immigration status. o Member of the household, over the age of 18, did not sign and date the 9886 form. o The HAP contract was not signed and dated by the Authority. • 1 tenant file error due to a missing signed lead base paint form. • 1 tenant file had the following errors: o The 50058 form incorrectly reported the tenant’s monthly rent. Correcting this error increases the HAP rent by $8. o The lease agreement’s signature page is missing. • 1 tenant file error where the rent reasonableness procedure was performed one month after the tenant’s move-in date. The rent appears reasonable, but should have been performed before the tenant’s move-in date. • 1 tenant file had the following errors: o Missing HAP contract and lease agreement. o Missing rent reasonableness support. • 1 tenant file error for missing rent reasonableness support. • 1 tenant file had the following errors: o The utility allowance amount was calculated correctly but was reported incorrectly on the 50058 form. Correcting this error would not change the HAP rent. o The lease agreement’s signature page is missing. • 1 tenant file had the following errors: o Miscalculation of the tenant’s social security income. Correcting the miscalculation would decrease the HAP by $2. o Miscalculation of the tenant’s annual unreimbursed medical expense. Correcting the miscalculation would have no effect on the HAP rent. o The tenant’s name was reported incorrectly on the 50058 form. • 1 tenant file had the following errors: o A member of the household did not check the checkbox on the 214-form indicating their immigration status. However, based on the tenant’s birth certificate, the tenant has eligible immigration status. o A member of the household over the age of 18 didn’t sign and date the 9886 form. o General assistance was included as household income when it should have been excluded. Correcting this error would increase the HAP rent by $12. o Missing rent reasonableness support. o The landlord did not sign the lease agreement. • 1 tenant file had the following errors: o A member of the household did not check the checkbox on the 214-form indicating their immigration status. However, based on the tenant’s birth certificate, the tenant has eligible immigration status. o Missing support for total annual unreimbursed childcare costs. o Missing support for total annual unreimbursed medical expense. Recommendation: The Authority should correct the deficiencies noted in the tested files and utilize an ongoing quality control review process on the entire tenant population to ensure proper compliance with the requirements related to tenant eligibility. Ongoing staff training and timely management reviews should be utilized to ensure staff is aware of acceptable procedures. In addition, the Authority should review staffing levels, skill sets and case load. Action Taken: We concur with the recommendation. Due to the COVID-19 pandemic and related staff absences and turnover, we were unable to provide an ongoing quality control review processes and provide ongoing staff training and timely management reviews. We are focused on implementing such procedures and will review staffing levels, skill sets, and case load for each employee.

Views of Responsible Officials QHS agrees with the finding and accepts the recommendation.

Finding 2022‐002: Eligibility‐(Material weakness in Compliance, Internal Control, and Service Provision within the APA (Assistance Program) Program) Effect: The Organization provided APA/R&P program funding to ineligible refugees and lawful permanent residents due to inadequate verification and inconsistent documentation practices. Auditor's Recommendation: The Organization should enhance its eligibility verification process to ensure that only enrolled refugees receive funding. Implementing regular training for staff and updating guidelines will help maintain accurate and complete documentation, ensuring compliance and maximizing the effectiveness of the APA/R&P program. Management Response: We agree with the recommendation and have also submitted the following response: Ensuring refugee eligibility as a sub-recipient of HIAS involves a comprehensive and diligent process. Staff are trained in verification and eligibility as required by the funder and follow an enhanced eligibility verification process. Screening is completed at the funder level to ensure refugee eligibility and program placement. Once approved, a referral is sent to the designated providers. Eligibility: The referral number designates the refugee to a program; even though the Funder system lists “None,” the referral is eligible. For the 7 in the sample, each refugee had a designated approved number from HIAS Verification: In the one exception where a refugee was a lawful permanent resident, JFSSV conducted its due diligence in the verification process and identified the client. This was immediately reported to the funder and rectified as required by the funder. Documentation: During the fiscal year 21/22, amidst the wrap-up of COVID-19, intake was conducted via telehealth processes, and verbal approval was accepted. Additionally, not all services required forms to be signed, such as “providing information on accessing legal permanent resident status, family reunification procedures, assisting school-age children.” These services were verbally discussed during the intake process and updated in the refugees' case notes in the funder system. JFSSV has provided Harshwal & Company LLP with detailed explanations on all samples and provided testing requirements with refugee backup during the audit. JFSSV ensures proper documentation and support as required by the grantor's requirements, and JFSSV adheres to all monitoring visits and grant program reviews To address the specific concerns raised regarding internal controls over compliance and eligibility verification, JFSSV will: Enhance the Eligibility Verification Process: JFSSV will continue to review and strengthen its eligibility verification process to ensure that only enrolled refugees receive funding. Regular Staff Training: JFSSV will ensure continuous training to ensure they are well-versed in the updated guidelines and best practices for eligibility verification and documentation required from the Funder. Improve Documentation Practices: JFSSV will continue best practices in validating eligibility determinations and related documentation to be complete, accurate, and current. This includes maintaining thorough records in the case note log within the Funder’s system.

Upon the completion of the annual audits for FY22 – FY24 management will file Form SF-SAC with the USDA. Thereafter the annual audit will be completed on a timely basis which will allow for the timely filing of the Form SF-SAC with the USDA. The SAC filing for FY 21 has been completed. Anticipated Completion Date-11/30/2024.Responsible Contact Person-Kathleen Boyce, CFAO

2022-005 Temporary Aid for Needy Families (TANF) Federal Financial Assistance Listing Number: 93.558 Federal Grantor: U.S. Department of Health and Human Services Pass-Through: California Department of Social Services Award No. and Year: 1946001347-A7 2022 Compliance Requirements: Eligibility Type of Finding: Significant Deficiency Management’s or Department’s Response: Imperial County Department of Social Services agrees with the finding. Views of Responsible Officials and Corrective Action Plan: The Count of Imperial, Department of Social Services, is committed to maintaining robust monitoring and oversight controls in place to ensure that applicant eligibility is thoroughly reviewed and approved. The Department will continue to monitor compliance with policies to ascertain that eligibility technicians follow guidelines for redetermination of recipients of need and amount of assistance, including to retain acceptable documentation to support the determinations. The Department will implement enhances training and guidance to include refresher training that will be developed based on needs identified during this review. The training will address any changes in regulations and/or internal processes. Name of Responsible Person: Paula S. Llanas, County of Imperial – Department of Social Services Director Implementation Date: September 1, 2024

With the newly hired staff as of October 2022, the process of selecting eligible tenants from the list has been accomplished by identifying the preference and verifying in writing th ereason for such preference to move forward with the housing the applicant. All verification is kep tin the eligible tenant file. the existing staff has had 10-15 years' experience maintaining Federal program waiting list.

Management agrees that in order to maintain the integrity of the accounting and financial reporting system, and to ensure timely reporting, an adequate system of internal controls should be designed and implemented to ensure effective operation. Management is aware of the reconciliation issue between the receivables in Sewer and Solid Waste Funds which, in part, is due to inherent limitation in the system used for utility billings. Staff is working diligently to perform the reconciliations or to develop a different methodology of accurately reporting receivables in both Funds. The complete and accurate reconciliations between these two funds should take place during FY 2024-25. Earlier reconciliation is possible. Management agrees to the adjustments related to OPEB and other liabilities, writing off significant uncollectible interfund receivables, amounts due from other governments, and capital assets. Management and staff are preparing a detailed and comprehensive schedule of accounting duties for the year-end closing process, to include individuals responsible for completing each task along with completion dates and sign-off elements. The OPEB and other liabilities, writing off significant uncollectible interfund receivables, amounts due from other governments, and capital assets are corrected during FY 2022-23. Timely issuance of audit reports involves collaboration and teamwork between auditor and auditee. The finance staff worked diligently and promptly responded to the auditors’ requests for information and documentation. The timeliness of reconciliations related to the Sewer and Solid Waste funds were delayed but were not associated with the rest of the funds. However, the audit of all financial information of the Town was suspended for more than a year when the lack of reconciliations for these two funds was brought to the attention of the auditors. Name of Responsible Person: Emad Gewaily, Director of Finance Implementation Date: June 30, 2025

The Project will adhere to the HUD rent subsidy program in accepting applications, determining eligibility, calculating the tenant's contribution toward rent and utilities, and calculating subsidy in accordance with HUD.

Management Response #2022-014: Due to software update with DC Department of Health, the January 1 – March 31, 2022, records were not available, nor were internal reviews of eligibility requirements support available as required. Corrective Action Plan: • The Grants program management team will expand upon our current process to ensure eligibility determination is verified and documented. • Training will be provided to staff on performing income eligibility verification to include taking a screen shot of the eligibility and storing it on a protected shared drive with a de-identified naming convention. This will allow us to have a warehouse of the eligibility verification that can be referenced when needed. It shall be maintained by the WIC Director with limited access and password protection. Policy/procedure manuals for the WIC Dept will be updated to reflect this new requirement and ensure compliance. Responsible Party: Tracy Harrison, COO

The Houston Housing Authority agrees with this finding. The Houston Housing Authority has for the past several months undertaken a program to review all voucher files for purposes of getting all deficiencies corrected. During this process if other required documents are found to be missing steps are being taken to complete the missing documentation and make sure that the files are complete. This review is substantially completed with final completion expected in the third quarter of 2024. Procedures have been implemented with regards to preventing this situation from recurring. Where needed staff will be provided the necessary training to make sure that all HCVP staff have the skills needed to successfully complete their job tasks. To facilitate this training, the Houston Housing Authority has created a training center that is made available to not only Houston Housing Authority staff but also others to provide a wide variety of training classes. Current leadership at the Houston Housing Authority is committed to having a competent trained staff working in the HCVP as well as other departments with the agency. This work is handled by the Voucher Program Operations department. The VP of this department and the Director of this department are primarily responsible for making sure the necessary corrections are made and the fill review is completed within the third quarter of 2024.