Corrective Action Plans

Management's views: When Amistad was notified by the City of El Paso about the error in January of 2022, management immediately started addressing the concern and made various steps to ensure solutions and best practices were being implemented. The auditor has a copy of the timeline and all steps that were taken. Amistad was able to recover $876,464, from all utility companies, the City approved the revisions to the application, and there was no negative impact to the agency. Amistad pledged to assist all customers that were impacted. Proposed corrective action: In regard to the corrective action plan, the process to address the issue started in January of 2022. A detailed timeline and corrective action plan were provided to SBNG. Amistad made several changes immediately such as identify ing and separating homeowners from renters, modified the application, added the Eligibility Verification Checklist and included a section for the Supervisor to review. Based on the feedback from the Audit, Amistad will continue to improve the process of reviewing new grant contracts so we can identify gray areas of compliance from the very beginning. For each new grant, management will make sure experienced members of the staff will evaluate the design of the program's procedures before the program rolls out. Also, for eligibility screening, we will continue to have a dual review of participant files to assist with identifying inconsistencies on the application. The $1,386.92 that was identified as an exception has been identified as ERA II funds. The City of El Paso has approved Amistad to use the $1,386.92, for the utility assistance program to assist renters. Anticipated correction date: As stated earlier, the corrective action plan started in January of 2022. Staff have received multiple trainings and will continue to receive trainings regarding best practices and contracts, along with implementation of programs. The recommendations that the auditor has provided have already been in process and will continue to be addressed through training and quality assurance checks. In regard to the one exception noted, the City of El Paso has approved Amistad to use the $ 1,386.92, for the utility assistance program to assist renters during FY2023. Responsible Official: Andrea Ramirez, Chief Executive Officer.

Corrective Action Plan ? 9/26/2023 Responsible Party: Donna Crutchfield, Director of Revenue Cycle Finding: During audit review of the COVID 19 HRSA testing and treatment payments received in 2022, two claims were discovered incorrectly charged to the COVID uninsured grant. Comments on the Finding and Recommendation Management is in agreement with this finding. Action(s) Taken or Planned on the Finding ? Build already existed in Epic to stop any uninsured patients that met COVID guidelines at time of service for review. This also includes build that stops claims if HRSA plan added later in the process for review. Expanded Plan on Actions Taken ? 09/26/2023 1. Actions planned on one claim found in audit. Refund will be issued for $122.69 for TIN 710236856 NPI 1043240682. 2. Actions planned for additional claim found in audit. Refund will be issued for $74.20. TIN 710236856 NPI 1174553796. 3. Refund process - Current credit balance policy is attached. Note all government payers are due to be reviewed and worked within a 60-day timeline. This is current as of 4/10/2023. 4. Note that auditors listed an extrapolated figure under projected costs based off the two claims found in the sample audit. The two claims found will be refunded. Missed other insurance information was due to patients? lack of presentation of insurance info at the time of service. 5. Going forward to ensure all meet credit guidelines. If there is a HRSA credit on a claim, it will be worked within policy guidelines. 6. As mentioned in previous plan, initial build exists (as of May 2020) in Epic to stop any uninsured patients that met COVID guidelines at time of service for review. This review allows to check for other coverage. There is also build that stops coverage if HRSA coverage is added later on in the process for a second review. Insurance coverage can be retroactively assigned after HRSA is filed. In this event, this would show as a credit if another payment was received and then be refunded by policy. In summary: ? Patient visit is set to review and confirm no active coverage is present, insurance coverage discovery was run, patient's visit was associated with COVID related service. ? HRSA coverage added and patent is keyed to HRSA portal for member ID to file claim. HRSA also checks insurance verification on their side and will notify if HRSA found active coverage not located by us. 5. Contact information for additional Questions: Donna.Crutchfield@baptist-health.org or 501-202-6440.

View of Responsible Officials 1. We concur. The Provider enrollment unit (PEU) is currently working on revalidations not completed and have a plan to deposition those providers while ensuring minimal disruption to member services and protecting limited provider networks disciplines such as the mental health network. I, the PEU administrator have been conducting biweekly meetings with Conduent and our business systems analyst to develop a plan and a systematic approach to revalidate all providers in the future. I am currently drafting a policy and procedure memo that will outline the new process for revalidations so that revalidations will be timely and complete in the future. Once the new process is implemented, I intend to review revalidations with Conduent at our biweekly provider enrollment meetings to ensure the revalidation process is conducted in a timely fashion and the implemented process for revalidations is working in that all revalidations are performed timely. As for the past due revalidations, the PEU anticipates all past due provider revalidations, prior to the PHE, to be either completed or be terminated by the beginning of March 2023. 2. We partially agree. The attestation signed in 2012 does not have an expiration and there is no Federal regulation or State law that requires this to be renewed, however, based on the finding last year, the Office of Medicaid Services did a new attestation in 2022. The 2022 attestation also does not have an end date and is not required to be renewed at any time. The attestation ends when the agreement is terminated by either parties. Anticipated Completion Date: March 2023 Contact Person: Stephanie Aulis

View of Responsible Officials We concur with the finding. Corrective Action: Condition A The Bureau of Employment Supports has been undergoing massive programmatic changes over the past 2 to 3 years. As part of those changes, there has been an updated Work Verification Plan submitted which will help to address some areas where errors have occurred. Keeping in mind that for a period of close to 2 years, due to the COVID pandemic, NHEP was not holding participants accountable for not returning signed employment plans to NHEP staff. The focus for that time was to ensure that families were housed, fed and safe, therefore, services focused on their immediate needs. Participants who entered the NHEP program during that time were not held accountable to returning a signed employment plan therefore it did not become part of their routine with NHEP. While COVID restrictions have been lifted, participants seem to have needed some time to reintegrate into the NHEP program and the mandatory expectations. NHEP staff and leadership will continue to remind participants and become more diligent in ensuring that signed employment plans are on the forefront of their daily responsibilities. It should be noted that in a couple of instances, employment plans were created as part of a Service Determination Appointment and very quickly after the participant was deemed exempt from the Work Program (NHEP) so the employment plan was not necessary and became a moot point. A Director?s Memo will be sent out by the end of this week which will allow Employment Plans to be acknowledged and accepted by the participant in multiple ways (not just with a wet signature) thereby increasing the likelihood of participants returning accepted employment plans to NHEP staff. Making this shift will mitigate the difficulties that are causing participants to not return their signed employment plans to NHEP staff and will decrease instances where there is not an accepted employment plan on file. NHEP leadership will hold a state wide mandatory staff training where ways to prioritize the monitoring and obtainment of accepted employment plans will be outlined and discussed. Field Support Managers will continue to monitor their staff on a quarterly basis, however, will add a monthly check on having accepted employment plans to their responsibilities. Condition B Part of the changes that NHEP has implemented have included a new Activity Tracking form which has made tracking hours more efficient and easier for the participant as well as the Employment Counselor. We believe that this activity tracker as well as the decrease in mandatory forms will allow for more accuracy and fewer errors moving forward. Uploading documents into the e-folder was found to be error prone, therefore, on March 1, 2023, NHEP leadership provided guidance and training on a specific process of indexing and scanning documents to ensure that moving forward the Employment Counselors are checking their e-folder?s to ensure that documents are properly uploaded and visible. This process was initially sent out to the field as a suggestion in 9/2022, however, on 3/1/23 this process was sent out as an expected process moving forward. Also, through cursory investigations, we believe that this new process, combined with the new Activity Tracking form, has already shown to be effective in improving the accuracy of supporting and recording hours. NHEP leadership has also been working with the NEW HEIGHTS system to streamline the process of uploading documents to further decrease the potential for errors. A change request form was submitted approximately one year ago. Also during the time period of this audit, NHEP was requiring pay stubs from employed participants and completing ?overrides? of the number of work hours that a participant worked during the week if that number was different than what was auto-populating based on information obtained by and entered by eligibility. NHEP discontinued that practice. NHEP no longer requires pay stubs from participants as that is a function of eligibility. NHEP utilizes the number of hours worked per week based on the number of hours entered by eligibility. This change will ensure that employment hour errors no longer occur. In order to address issues of audit findings, within the next 90 days, NHEP leadership is holding a state wide mandatory staff training where more in-depth information on the audit process will be shared including audit ?tests?, ?questions? and ?corrective action plans?. Historically in NH, the audit process was not shared with the NHEP staff making them unaware of the expectations and/or findings of the audit. NHEP staff were trained to complete certain processes and enter particular data but were never able to connect that back to anything. While we have been introducing this process more and more to our staff, we intend to hold a training to help them more thoroughly understand why they are doing what they are doing and remind them that what they do is reviewed for accuracy as part of the federal audit process. We believe that this transparency will create buy-in from the staff to put systems in place for themselves and to self-monitor more. Anticipated Completion Date: December 31, 2023 Contact: Brigitte Bowmar, Program and Workforce Administrator III

Finding 2022-001 ? Eligibility ? Material Weakness in Internal Controls Over Compliance and Material Non-Compliance Condition and Context: As part of our testing of eligibility, using a random number generator, we selected 25 days the Organization was open for food distribution during the year ended December 31, 2022. Out of the 25 days tested, the Organization did not follow intake guidelines for required eligibility and data collection prescribed by the Washington State Department of Agriculture for 12 different days. Planned Corrective Action: The organization implemented procedures to collect client intake data for one of the programs identified in testing and expects to continue making progress on the remaining program during 2023 and 2024. Responsible Division/Office and Individual: Mike Cohen, Executive Director Estimated Completion Date: 12/31/2024

This letter is in reference to the following audit finding reference. The enrollment status change was not appropriately reported for three students out of a sample of forty. In each instance, the University of Bridgeport notified the National Student Clearinghouse of the student graduating from the University, but the student?s enrollment status had not been properly updated within the system. The University of Bridgeport has a reconciliation process in place to verify that student?s enrollment status is checked after submitting batch rosters to the National Student Clearinghouse, however the process failed to identify these exceptions. The university of Bridgeport?s proposed corrective action is as follows: 1. The Office of the Registrar will take over Clearinghouse reporting responsibilities from Information Technology. 2. The Office of the Registrar will submit to Clearinghouse enrollment and DegreeVerify files. 3. IF, exceptions are received back from the Clearinghouse, the corrections will made by The Office of the Registrar and with support from Information Technology if needed. 4. Corrections to the file are then sent to Financial Aid. 5. Financial Aid will then submit the corrections to the National Student Loan Database System. 4. These procedures will be recorded in a comprehensive manual. Anticipated Completion date: October 1, 2023 Name of Contact Person: Melissa Quinlan, Ph.D. Vice President of Institutional Effectiveness and Student Systems Carmen Rosa University Registrar Sincerely, Melissa Quinlan, Ph.D. Vice President of Institutional Effectiveness and Student Systems

Finding 2022-005 U.S. Department of Agriculture CFDA # 10.565, 10.568, 10.569 Food Distribution Cluster Finding Summary: As part of the audit done by Eide Bailly LLP, a lack of internal controls were identified in eligibility determinations for the CSFP and Emergency Food Assistance Programs. Two tested samples did not have the proper documentation. Responsible Individuals: Melissa Sobolik, CEO, David Stachon, CFO Corrective Action Plan: The GPFB will ensure all documents for TEFAP and CSFP programs have proper signatures by necessary parties going forward. This will be done as paperwork is completed and retained in the file. Anticipated Completion Date: March, 2023

2022-001 ? SPECIAL TESTS AND PROVISIONS ? CARES ACT FUNDING Other Matter/Significant Deficiency Auditee?s Response and Planned Corrective Action HHA has completed the necessary training recommended by HUD and addressed the use of the ineligible expenses with HUD. This issue was considered closed as of December 20, 2021. Planned Implementation Date of Corrective Action: Immediately Person Responsible for Corrective Action: Clara Ruiz-Vargas, Executive Director

Program: Medicaid Cluster Federal Financial Assistance Listing Number: 93.778 Federal Grantor: U.S. Department of Health and Human Services Passed-Through: California Department of Public Health Award No. and Year: 2022 Compliance Requirements: Eligibility Type of Finding: Significant Deficiency in Internal Control Criteria: Title 42 Chapter IV Subchapter C Part 425 Subpart J Section 435.907, Application, states that the agency must accept an application from the applicant, an adult who is in the applicant's household, as defined in ? 435.603(f), or family, as defined in section 36B(d)(1) of the Code, an authorized representative, or if the applicant is a minor or incapacitated, someone acting responsibly for the applicant, and any documentation required to establish eligibility which includes via the internet Web site, by telephone, via mail, in person, and through other commonly available electronic means. Condition: During our testing of the SSA?s provisions for eligibility requirements, we noted for three (3) of sixty (60) samples the department did not retain the participant?s application, which is part of the County?s process and internal control. Cause: The SSA department did not ensure case workers were following the department?s policies and procedures relating to the eligibility determination process. Effect: The County?s control was not consistently followed, which requires case workers to retain the participant?s application. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: Non-statistical sample of sixty (60) out of two hundred ninety-four thousand and one hundred sixteen (294,116) participants were selected for eligibility testing. The condition above was identified during our testwork of the SSA?s internal controls over eligibility. Repeat Finding from Prior Years: No. Recommendation: We recommend the SSA department adhere to their policies and ensure case workers retain participant applications. Management Response and Corrective Action: Social Services Agency: 1. Person Responsible: Cristina Espinoza, Administrative Manager I, Assistance Programs, Policy and Operations Team 2. Corrective action plan: Department will provide Single Audit findings in a mandatory Program Summary meeting that all staff will attend. At the meeting, department will address the findings in detail and remind staff who administer Medi-Cal to: ? Ensure case documentation such as: initial application and supporting verification are imaged ? Enter case comments that support case actions The department will also continue to have the Quality Assurance team complete case reviews to ensure eligibility workers are following policies and procedures in completing accurate eligibility determinations. 3. Anticipated Implementation date: April 2023

Program: Supplemental Nutrition Assistance Program (SNAP) Cluster Federal Financial Assistance Listing Number: 10.561 Federal Grantor: U.S. Department of Agriculture Passed-Through: California Department of Social Services Award No. and Year: 217CACA4S2514, 227CACA4S2514, 217CACA4Q7503, 227CACA4Q7503, 217CACA4S2519, 227CACA4S2519, 217CACA4S2520, 227CACA4S2520, 217CACA5S9018, 217CACA6F1003, 227CACA7F1003 and 2022 Compliance Requirements: Special Tests and Provisions Type of Finding: Significant Deficiency in Internal Control Criteria: 7 CFR sections 272.10 and 277.18 require State agencies to automate their SNAP operations and computerize their systems for obtaining, maintaining, utilizing, and transmitting information concerning SNAP. This includes: (1) accurately and completely processing and storing all case file information for eligibility determination and benefit calculation; (2) providing an automatic cutoff of households at the end of their certification period unless recertified; and (3) generating data necessary to meet federal issuance and reconciliation reporting requirements. Condition: In establishing a new case, the client is certified to receive benefits for a one-year period (certification period). The intake and certification process require that information on the CF-37 and SAWS 2 be obtained to determine eligibility and assist in the benefit calculation. Further, prior to case worker approval of benefits, the Income Eligibility Verification System (IEVS) report is required to be processed in certain circumstances. During our testing of the SSA department?s provisions for special tests and provisions requirements relating to ADP System for SNAP, we noted the following instances: ? For thirteen (13) of forty (40) participants selected for testing, there was no evidence that a case worker reviewed and certified the participants IEVS report. ? For three (3) of forty (40) participants selected for testing, the income verification document used in the benefit calculation was not retained by the department. Cause: The condition is primarily caused by the SSA department not following policies and procedures in place to ensure the eligibility case files contain documentation to support eligibility and benefit calculations. Effect: Case data may not be current or accurate in the case file or the system, which could lead to initial and continued eligibility errors, inaccurate benefit calculations, and benefit overpayments. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A non-statistical sample of forty (40) out of one hundred eleven thousand and fifty-one (111,051) participants were selected for special tests and provisions relating to ADP System for SNAP. The condition above was identified during our testwork of the SSA?s internal controls over special tests and provisions. Repeat Finding from Prior Years: No Recommendation: We recommend the County strengthen its established policies and procedures with regard to initial and ongoing eligibility determination, required documentation and verifications, maintenance of participant files, and ensure that policies and procedures are strictly adhered to by County personnel. Management Response and Corrective Action: Social Services Agency: 1. Person Responsible: Cristina Espinoza, Administrative Manager I, Assistance Programs, Operations and Policy Team 2. Corrective action plan: Department will provide Single Audit findings in a mandatory Program Summary meeting that all staff will attend. At the meeting, department will address the findings in detail and remind staff who administer CalFresh to: ? Review and process IEVS reports timely and accurately ? Ensure case verifications are imaged and documented in case comments to support case action ? Review the budget wrap-up screen thoroughly for every case The department will also continue to have the Quality Assurance team complete case reviews to ensure eligibility workers are following policies and procedures in completing accurate eligibility determinations. 3. Anticipated Implementation date: April 2023

Finding Number: 2022-007 Federal Program, Assistance Listing Number and Name: ALN 14.241, Department of Housing and Urban Development, Housing Opportunities for Persons With Aids (HOPWA) and COVID-19 HOPWA Condition: Original Finding Description: In conjunction with eligibility testing, instances of noncompliance specific to the rental assistance calculation were identified. Contact Person Responsible for Corrective Action: Denise Fair and Angelique Tomsic Anticipated completion date: July 2023 Planned Corrective Action: In FY23, the City implemented a review of 100% of clients who received subsidy services. The intensive review is being performed to help ensure all required documents are saved and accurate. A corrective action plan will be documented and further reviews put in place to help ensure compliance and consistency for all rental calculations. The city will also continue to work with its contractor on process improvements. In addition, as part of the AFCAP process, the City will work with the department to perform internal reviews to help ensure processes are being followed

Finding Number: 2022-006 Federal Program, Assistance Listing Number and Name: ALN 10.557, Department of Agriculture, Special Supplemental Nutrition Program for Women, Infants and Children (WIC) Condition: Original Finding Description: The City of Detroit did not have adequate controls in place to exercise its oversight responsibility of eligibility determinations that were performed by a contractor for the program. Contact Person Responsible for Corrective Action: Denise Fair Anticipated completion date: July 2023 Planned Corrective Action: The City will implement controls to ensure that Health Department provides oversight of the contractor and the participant eligibility process. The Health Department has hired a WIC Program Director who will monitor participant eligibility compliance and ensure that eligibility policies and procedures are maintained and followed. Through the AFCAP project process, the City will also review the contract in detail to help ensure full compliance

Management has reviewed the process for recertifications and have contracted with a HUD qualified technical resource person to review, correct if necessary, and advise to ensure timely recertifications.

CORRECTIVE ACTION PLAN The Rockport Housing Authority (RHA) acknowledges the findings in our annual audit completed by Marcum. We will implement the following to resolve the current issues: Federal Awards - Section 8 Housing Choice Voucher Program Instances of Income, Asset, or Medical Miscalculation or Insufficient Verification RHA has already put together a checklist to make sure that all items are collected and calculated properly. All annual re-examinations are currently up to date. In addition, the Executive Director will periodically select files to audit. Incorrect Payment Standard RHA has noted on future calendar to have the Board of Directors approve Payment Standards within 30 days of HUD releasing the rates. RHA's HCV Specialist will be notified immediately of the new rates to enter into PHA web and begin using with Annual and Interim certifications. This item has been added to the file checklist. Utility Allowance The Utility Allowance was add to the file checklist and will be reviewed during each annual and interim exam to assure that the proper amount is given to each Section 8 participant. RHA did experience some significant staffing changes over the last 18 months with both Executive Director and HCV Specialists. An interim Executive Director is currently in place and keeping a watchful eye on all items. In addition, a new HCV Specialist has been on board since February and RHA was able to secure an experience Section 8 consultant to train the new associate. Person Responsable for Corrective Action: Marie Mathes, Interim Executive Director Planned Implementation Date: Already complete.

During the 2022 audit of PrairieStar Health Center, Inc. FORVIS found multiple instances of the sliding fee being either set up incorrectly or calculated incorrectly. Plan to Correct Finding Multiple steps will be taken to correct this finding. ? Meet with coding and billing staff to determine how to communicate when changes are made to the account after the sliding fee pulls in. There were several instances of the number of units being changed after the slide had applied to the account that were not communicated to the billing staff so that they could change the slide to the appropriate amount. ? Increased training of staff. This will be two pronged: 1) training for staff on calculating sliding fee eligibility and setting up the slide and 2) training for staff on making adjustments to sliding fees on a patient?s account. ? Increased review of slide setup, eligibility calculations, etc., to confirm compliance. Date of Completion Within the next month, we will hold a meeting with the billing and coding staff to determine the best way to communicate changes to accounts that have the sliding fee applied before units are changed. There is no completion date for the training and review. These will become routine, ongoing functions of the department. Responsible Party Shandi Stallman, Chief Financial Officer, is the party that has overall responsibility for this corrective action. In addition, the Business Office Managers for Medical, Dental, and Vision will play a key part in training and review.

FINDING 2022-002 ? R2T4 Calculation Program Name: Federal Pell Grant ALN and Program Expenditures: 84.063 ($729,843) Award Number: P063P213629 Federal Award Year: July 1, 2021 to June 30, 2022 Questioned Costs: $1,988 Condition Found: The R2T4 calculation was completed incorrectly for three of the five students in our R2T4 testing sample. The Federal Pell Grant funds disbursed were not adjusted for module courses that the students did not begin. In addition, the incorrect semester start date was used for two of the three students. Corrective Action Plan: Management agrees with the auditors? finding and their recommendation. The Financial Aid Director recalculated the R2T4s for the students in question. The Financial Aid Director determined that $1,988 of Federal Pell Grant funds should be returned for these students. On September 12, 2022 these funds were returned to the Department of Education. The remaining R2T4 calculations completed by the College were reviewed and there were no additional errors. The Financial Aid Director has improved R2T4 calculation procedures to ensure that the Federal Pell Grant is adjusted for module courses that a student does not begin attendance in before completing the R2T4 calculation. Anticipated Completion Date: The corrective action was completed on September 12, 2022. Contact Person (for both findings): Brian Rains, Director of Financial Aid 417-268-6045

FINDING 2022-001 ? Verification Program Name: Federal Pell Grant ALN and Program Expenditures: 84.063 ($729,843) Award Number: P063P213629 Federal Award Year: July 1, 2021 to June 30, 2022 Questioned Costs: $1,000 Condition Found: The adjusted gross income was not updated to the amount reported on the tax return during the verification process for one of the forty students in our sample. Corrective Action Plan: Management agrees with the auditors? finding and their recommendation. The Financial Aid Director updated the adjusted gross income and recalculated the EFC and Federal Pell Grant award for the student in question. The Financial Aid Director determined that $1,000 of Federal Pell Grant funds should be returned for this student. On September 12, 2022, $1,000 of Federal Pell Grant funds was returned to the Department of Education. Anticipated Completion Date: The corrective action was completed on September 12, 2022.

Finding Number: 2022-1 Enrollment Reporting to NSLDS Planned Corrective Action: An existing report has been tweaked to include all potential SSN issues, and the Registrar?s Office will be retrained on how to use this report. Each time an enrollment report is submitted, this report will be reviewed to verify that no issues exist. Person Responsible for Corrective Action Plan: Kelly Vickers (Registrar) Anticipated Date of Completion: October 1, 2022

Condition: Eligibility for ERAP1 required that individuals self-attest that they had a need for rental or utility assistance under the ERAP program. Eligibility is defined in the OMB's compliance supplement and guidance. Reason Improvement Needed: Eligibility is a key component of the ability of any Federal agency or funding recipient to disburse funds under the COVID-19 funding. The Center needs to ensure that eligibility is monitored and thoroughly checked to ensure individuals who are not eligible do not receive funding. Cause of Condition: The Center paid out funds as it was required by current guidance. ERAP1 was to be paid out on self-attestation standards allowing the affected renters the ability to "self-certify" that they were in need of the rental assistance and other utility assistance in order to gain access to the funds. When ERAP2 was administered, the guidance changed to require the Center to request and validate multiple types of support to ensure that the funds were necessary for the individual. Effect of Condition: Self attestation leaves the onerous of being truthful on the individual receiving the funds and takes the ability to deny one's funding for fraudulent reasons out of the hands of the Center. Perspective Information: We don't find this to be a systemic issue. The Center has complied with all types of eligibility testing requirements each year for the ERAP 1 and ERAP2 funding. The Center only identified the fraud during FY21 in the ERAP1 funding when the ERAP2 guidelines changed and some of the same individuals applied for the funding again. Identification of Repeat Findings: This is NOT a repeat finding from the prior year. Client Response: The Center has turned over the names and amounts of funds that were fraudulently gained from the ERAP1 program to the pass-through entity by which it received the original funding. The pass-through entity is the prosecuting entity who will determine how to properly move forward with the fraud claims. The Center has fulfilled its duty to report any fraud identified in the program.

Finding 2022-002 - Continuum of Care Tenant Files - Eligibility - Internal Control over Tenant Files - Noncompliance and Material Weakness Corrective Action Plan: The Housing Authority of the City of Greenville (HACG) has implemented and/or will implement the following by our fiscal year-end September 30, 2023: a. Program Coordinators will maintain all Continuum of Care Tenant files in individual file folders designated by special purpose voucher program. All loose documents will be anchored in tenant files. b. An action plan has been developed for the Continuum of Care programs to ensure that all program files are HUD, State, and GHA compliant starting with October 1, 2022, files through the current. c. Continuum of Care fiscal year 2023 (October 2022-September 2023) re- exams and interims will be caught up and complete as they become effective. All tenant files will be reviewed and compliant by FYE2023 . d. All late/overdue re-exams will be compliant by FYE2023. e. During FYE2023, the Deputy Executive Director/COO or designee will perform quality controls on all Continuum of Care tenant files processed each month prior to initialization. f. File checklist sheets will be placed in each file upon quality control review to be signed off by the Deputy Executive Director/COO or designee. g. Additional training will be required and ongoing for Program Coordinators. h. Other internal control measures will be implemented to eliminate future audit findings. Person Responsible: Shanetta Moye, Deputy Executive Director/COO Anticipated Completion Date: September 30, 2023

Finding 2022-001 - Low Rent Public Housing Tenant Files - Eligibility - Internal Control over Tenant Files - Noncompliance and Significant Deficiency Corrective Action Plan: The Housing Authority of the City of Greenville (HACG) has implemented and/or will implement the following by our fiscal year-end September 30, 2023: a. Low Rent Public Housing tenant files will be reviewed and quality controlled each month prior to initialization (25th of each month) by the Senior Property Manager and the AMP Property Manager. b. An action plan has been developed for Low Rent Public Housing to ensure that all Public Housing files are HUD and GHA compliant starting with October 1, 2022, files through the current. c. Low Rent Public Housing calendar-year 2023 (October 2022-September 2023) re-exams are substantially complete, as they become effective. All tenant files will be reviewed and HUD-compliant by FYE2023. d. During FYE2023, the Senior Property Manager will perform 25% quality control of the monthly re-exams processed by the AMP Property Managers. Additionally, the AMP Property Managers will perform 50% quality controls of the monthly re-exams and interims processed by the Assistant Property Managers. e. File checklist sheets will be placed in each file upon quality control review to be signed off by the Senior Property Manager and the AMP Property Managers. A copy of the completed checklist with signatures will be forwarded to the Deputy Executive Director/COO. f. Additional training will be made available as necessary. g. Other internal control measures will be implemented as deemed necessary by the Deputy Executive Director/COO, to eliminate future audit findings. Person Responsible: Shanetta Moye, Deputy Executive Director/COO Anticipated Completion Date: September 30, 2023

U.S. Department of Treasury New Jersey Housing and Mortgage Finance Agency respectfully submits the following corrective action plan for the year ended December 31, 2022. Audit period: January 1, 2022 ? December 31, 2022 The finding from the schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. FINDINGS?FEDERAL AWARD PROGRAMS AUDITS SIGNIFCANT DEFICIENCY U.S. Department of Treasury 2022-001 Eligibility ? Homeowners Assistance Fund? Assistance Listing No. 21.026 Recommendation: The Agency should evaluate the steps it takes to ensure that any required documentation not gathered from the client is obtained prior to finalizing an application and providing housing assistance. Any changes in this methodology should be documented in the program policies and procedures and communicated to all employee who engage in the application process. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: ERMA applicants can submit required documentation with the assistance of a contracted Housing Counseling Agency or via the application portal directly. The two examples that caused this recommendation can be attributed to applicant error, as well as a missed review by the processing vendor. To ensure that required documentation not gathered from the applicant is followed-up on and obtained timely and to minimize future occurrences, the Agency has (1) revised the required documentation list to simplify the documentation gathering process for the applicant, and (2) provided additional training on the required documentation process to the Housing Counseling Agencies, processing/underwriting vendor and ERMA program staff. All approvals are reviewed by a supervisor, or their designee, to ensure all required documents pertinent to the applicant?s eligibility are present prior to providing ERMA assistance. Name(s) of the contact person(s) responsible for corrective action: William Schmidt (Assistant Director of HAF); James Abrams (HAF Program Manager); Tina White (HAF Program Manager) Planned completion date for corrective action plan: Both the training and the changes to the required documentation list were completed in May of 2023. If the U.S. Department of Treasury has questions regarding this plan, please call Kimberly A. Sked at 609- 278-7669.

2022-001 Incorrect Pell Disbursement - Student Financial Aid Cluster Assistance Listing Number 84.007, 84.033, 84.063, 84.268, Grant Period - Year Ended June 30, 2022 Condition Found: During our student file testing we noted one student out of forty had was not disbursed the correct Pell Grant award. Based on the student?s enrollment status and need, the College under awarded the student by $680. We consider this to be an instance of noncompliance relating to the Eligibility Compliance Requirement. Corrective Action Plan: In response to this finding, Oakton Community College had already updated the student's federal Pell grant award, disbursed the additional Pell to the student, and reported the subsequent adjustment to COD on May 4, 2022. The Financial Aid Manager also met with the financial aid advisors to share the finding. Responsible Person for Corrective Action Plan: Jamie Peterson, Manager of Student Financial Assistance Dr. Cheryl Warmann, Registrar/Director of Student Financial Support Implementation Date of Corrective Action Plan: May 4, 2022- Student Record Adjustment June 14, 2022 - Internal training with financial aid advisors

As required by OMB Uniform Guidance, we have provided below our response and corrective action plan addressing the findings in the ?Report on Federal Awards in Accordance with the OMB Uniform Guidance? for the year ended December 31, 2022. Management?s Views and Corrective Action Plan Finding 2022-002 ? Reporting ? Significant Deficiency in Internal Control Over Compliance NorthBay Healthcare Corporation and its Affiliates dba NorthBay Health agree with the finding and management has implemented a corrective action plan. Management has implemented a more precise review control over future federal award reporting submissions to ensure all reported expenditures comply with the terms and conditions of the federal award. Further, NorthBay Healthcare Corporation and its Affiliates dba NorthBay Health had sufficient unused lost revenues of approximately $114,915,000 and $133,021,000 from the Periods 3 and 4 Provider Relief Fund reporting to fully cover the Provider Relief Fund distributions for Periods 3 and 4, respectively. Date of Corrective Action: September 15, 2023 Party Responsible for Corrective Action: Theo Rallis, Assistant Vice President of Finance

Program: AL 21.026 ? COVID-19 Homeowner Assistance Fund ? Allowability & Eligibility Corrective Action Plan: Coaching has been provided to the appropriate review staff. Contact: Major General Bohac Anticipated Completion Date: Completed