Corrective Action Plans

Reference Number: 2022-002 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Public and Indian Housing Federal Catalog Number: 14.850 Federal Grant Number: Not Applicable Category of Finding: Eligibility Classification of Finding: Material Weakness in Internal Control over Compliance Material Noncompliance Authority?s Response & Actions Taken No corrective action is required for this finding because the Authority?s Sunnydale-Velasco, Potrero Annex and Terrace public housing properties, all part of HOPE SF initiative, have been transferred out of the Low Rent Public Housing Program (LRPH). In 2020, the Authority began the accelerated conversion project (HQS conversion), a major undertaking to transform existing public housing sites owned by the Authority, Sunnydale-Velasco (Sunnydale) and Potrero Hill ? including Potrero Annex and Terrace. The conversion transferred the ownership of the public housing units to SFHA Housing Corporation, a blended component unit. To comply with guidelines from the U.S. Department of Housing and Urban Development (HUD), the public housing department has reviewed and updated the tenant files for each phase of the HQS conversion to ensure completeness and accuracy and compliance of the documents with the HCV program for intake requirements. The Authority has completed the accelerated conversion and the transition of the public housing tenant files to the HCV program on September 30, 2022. The public housing units were brought up to Section 8 physical standards (Housing Quality Standards, HQS) and assigned Project-Based Vouchers (PBV) Housing Assistance Payments (HAP) contracts through the Housing Choice Voucher (HCV) program. SFHA Housing Corporation will operate the properties as Project-Based Section 8, until the time that the units will be disposed to the developers for redevelopment, pursuant to their redevelopment schedule and agreement. Anticipated Implementation Date September 30, 2022 Name(s) and Title(s) of Contact Person(s) Responsible for Correction Action Kendra Crawford, Director of Housing Operations

Sharon Armijo Clerk ? PO Box 197 (575) 533-6400 Joyce Laney Treasurer ? PO Box 407 (575) 533-6384 Lillie Laney Assessor ? PO Box 416 (575) 533-6577 Keith Hughes Sheriff ? PO Box 467 (575) 533-6222 Lucinda Howell Probate Judge 100 Main St. Reserve, New Mexico 87830 Buster F. Green Commissioner District No. 1 Audrey H. McQueen Commissioner District No. 2 Haydn Forward Commissioner District No. 3 Commission Office PO Box 507 ? (575) 533-6423 FAX (575) 533-6433 Loren Cushman County Manager 2022-001 (2018-003) Procurement of Goods and Services (Significant Deficiency) Condition ? During our test work of a sample of 35 transactions we noted the following: County not following disbursements policy and procedures: ? No PO, PO not attached (6 of 35) P cards (6 of 20) ? 1 month ? no documentation of commission review of monthly check register ? Invoice referenced but not attached ? Taxes paid on goods (6 instances) ? 2 instances with no supporting documents Procurement ? (under $20,000) ? 1 No PO ? 1 No supporting documents Procurement ? (> $20,000 & <$60,000) ? 3 instances of only 1 quote ? 2 No supporting documents The County continues to have documentation retention or application issues, no progress from prior year. Corrective Action Plan ? Staff has been proactive in ensuring that purchase orders and invoices are attached to checks and has created a filing system for processed checks. Staff has been proactive in confirming receipts of goods/services, requesting receipts from purchasers, and generally following the NM Procurement Code and County Procurement Policy. Checks are currently being backed up electronically along with purchase orders and other supporting documentation of purchase receipt and justification. Staff has been proactive in obtaining NTTC forms for businesses and utilizing vendors with current state contracts. Staff has created a binder for documenting monthly review of purchases by Commission including maintain original signatures of Commission members. In instances where procurement has found it impossible to obtain three quotations, staff has maintained adequate documentation of best efforts made to obtain said quotes and has conversed with legal to determine that best efforts is adequate in these instances. Responsible Position: Chief Procurement Officer/Accounts Payable Timeline for Correction: Completed Catron County Corrective Action Plan (continued) 2022-002 (2018-006) Local Government Budget Management System (LGBMS) Reporting Incomplete (Other Non-Compliance Repeated with modification. Condition ? The County did not include all budget expenditures in the LGBMS system. The County reported total budgeted expenditures for their original budget in LGBMS of $10,965,065. The actual budget amounts that should have been reported were $11,239,091. The County did not present a revenue budget to the Commission for approval when the Commission approved the expenditure budget. In addition the County did not enter the revenue budget into the budget to actual reporting system to aid in budget monitoring. The County continued to have budget compliance, monitoring and reporting issues in the current year, and therefore no progress has been made regarding budget in the current year. Corrective Action Plan ? We did hire a Finance Director and then almost immediately put him to work as Interim County Manager. A full time County Manager finally started March 22, 2023. The Finance Director?s goal is to have the County?s reporting to the DFA a routine matter ? accurate and on time. Responsible Position: Finance Director Timeline for Correction: June 30, 2024 2022-003 (2018-002) Maintenance of Capital Assets (Material Weakness) Repeated. Condition ? ? Construction In Process is not maintained and lacks a consistent process for adding to the depreciation schedule. ? Depreciation schedule was not updated or calculated for the entire fiscal year. The County digressed in its maintenance of capital asset records and documentation. Corrective Action Plan ? One of the goals of the new Finance Director is a complete review of Catron County?s capital asset records. Responsible Position: Finance Director Timeline for Correction: June 30, 2024 Catron County Corrective Action Plan (continued) 2022-004 Personnel File Maintenance (Significant Deficiency) Statement of Condition ? We tested a sample of 10 Payroll transactions and noted the following: ? Three instances (3 of 10) where the current payrate was not substantiated by a personnel action form. ? One personnel file did not include any current documents ? all documents were for 2017 and prior. ? One personnel file lacked a PERA membership application. Corrective Action Plan ? The County has made available training through NM EDGE where we can learn to improve procedures, and best practices to develop strategies on completing internal controls. Auditors did provide valuable feedback on what was necessary to complete Personnel files and those suggestions will be implemented form there on. Responsible Position: HR/Payroll Clerk Timeline: June 30, 2023 2022-005 Solid Waste Receipts Audit Trail (Significant Deficiency) Statement of Condition ? The Solid Waste department?s receipting system lacks a clear audit trail. ? No schedule indicating receipts by customer, only a total page of deposit amount (5 deposits for dump fees totaling $9,696) ? Cash deposits were co-mingled with other cash deposits for the day and therefore not traceable specifically to solid waste cash receipts (all solid waste receipts ? 10 receipts tested totaling $19,392) ? No receipts are issued for each customer (receipts only issued upon customer request) No copies or records of receipts that were issued were maintained (all solid waste receipts ? 10 receipts tested totaling $19,392) Corrective Action Plan ? 1. Solid Waste Clerk will attach a corresponding customer receipt to all spreadsheets. 2. Treasurer?s Office has reconciled the second issue listed above. 3. Convenience Center Attendants will immediately receipt all customers. Responsible Position: Solid Waste Clerk/Coordinator Timeline: April 30, 2023 2022-006 Travel and Perdiem Procedures and Regulations Not Properly Followed (Other Non-Compliance) Statement of Condition ? We tested a sample of 10 travel transactions and noted the following: ? 5 instances where no travel form (per policy) was attached to approve travel $2730.64. ? 1 instance where mileage rate reimbursed was $.46 per mile rather that $.45 per mile ? total over allowable reimbursement was $1.25. Corrective Action Plan ? New travel forms have been created pursuant to DFA Per Diem rates from Memo dated April 12, 2022. New staff has been proactive in ensuring that travel requests are handled timely and properly. Responsible Position: Accounts Payable Timeline: Completed Catron County Corrective Action Plan (continued) 2022-007 Lack of Maintenance of Grant Documentation (Material Weakness) Statement of Condition ? During our test work of federal award reimbursements and expenditures and New Mexico capital Outlay Appropriations, documentation and supporting invoices and reimbursement requests as well as grant award agreements were not available or present in County records. Reimbursement requests are not timely. County is not following award guidelines to maintain the accounting of grant activity for reimbursement requests, expenditures and supporting documentation. The County has numerous awards that are not managed and status of awards is not current. Corrective Action Plan ? The County hired a Finance Director. Even though he spent most of his first eight months as Interim county Manager, he was able to assemble grant documents and collect grant funds that had been waiting for years to be claimed. As we now also have a full time County Manager, this part of the Finance Director?s job should improve even more. Responsible Position: Financial Director Timeline: June 30, 2023 2022-008 (2020-007) Late Audit Report ? (Other Non-Compliance) Repeated with modification Statement of Condition ? The audit report was submitted to the State Auditor?s Office after the county due date of December 1, 2021. This finding remains essentially the same as prior year. Corrective Action Plan ? We are glad the auditor is taking part of the responsibility here. However, if the County can keep a consistent staff in the Commission Office following proper procedures, the audit will definitely go smoother and quicker. Responsible Position: Finance Director Timeline: June 30, 2024

Reference # and title: 2022-001 Public Housing Tenant Files ? Eligibility ? Rent Calculations Federal program and specific federal award identification: Asst. Listing Number Award Year FEDERAL GRANTER/ PASS THROUGH GRANTOR/PROGRAM NAME United States Department of Housing and Urban Development Public and Indian Housing Program 14.850 2021 and 2022 Condition: The Code of Federal regulations, the Housing Authority Admissions and Occupancy Plan and specific HUD guidelines in documenting and maintaining Public Housing tenant files. Our review of seventy-five (75) Public Housing Tenant Files revealed the following discrepancies: ? There were eight (8) instances of income miscalculations. We noted that the income miscalculations were mainly related to wage calculation or child support calculations. We extrapolated the total potential error and found it to be material to the financial statements at both the total and singular AMP level. ? There was one (1) instance of a file missing required childcare deduction verification. Corrective action planned: Monroe Housing Authority will develop more effective processes for measuring, monitoring, and reducing errors in subsidy payments due to rent calculation and tenant underreporting of income. Implementations and strategies to include: ? Resolution of income and rent issues identified in the report and communication to Tenants where applicable. ? Development and implementation of an ongoing quality control review process of income at initial certification and re-examination to mitigate wage/income calculation errors to PHA and tenants by: o Hiring (1) FTE to perform quality control review of verification of income (upfront and/or a third party), and Tenant files upon new lease and re-examinations. o Developing a Tenant File Review checklist to document the result of file reviews. ? Partner with the National Association of Housing and Redevelopment Officials (NAHRO) to train staff on Public Housing Occupancy, Eligibility, Income and Rent training to accurately calculate Tenant Rent and avoid common errors in occupancy and eligibility functions in addition to understanding updates to the HUD-50058. Person responsible for corrective action: Mr. William Smart, Executive Director Anticipated completion date: 6/30/2023

2022-001 Sliding Fee Discount Determination Name of Contact Person: Missy Hyman, CFO Corrective Action: Winn Community Health Center, Inc. will: - Immediately retrain staff involved in the Sliding Fee Discount Program (SFDP) on program requirements and proper implementation of sliding fee determination and billing. - Perform periodic audits of sliding fee transactions Proposed Completion Date: December 31, 2023

Management's View and Corrective Action Plan Finding 2022-001 - Non-Compliance with Timely and Accurate Student Enrollment Change Submissions to the National Student Loan Data System (NSLDS): Grantor: U.S. Department of Education Program Name: Student Financial Assistance Cluster Award Names: Federal Pell Grant Program and Federal Direct Loan Program Award Year: 7/1/2021 - 6/30/2022 Assistance Listing Numbers: 84.063 and 84.268 Management agrees with the finding and in concurrence with the recommendations has developed the following corrective action plan: The Registrar?s Office will manually reconcile enrollment status after each submission to the National Student Clearinghouse (?NSC?) submission to ensure student enrollment changes are submitted completely and timely. Alan Hatton, the Senior Associate Registrar, is responsible and has implemented this corrective action plan in February of 2023. Signed and Acknowledged, Kath Dunlop, Registrar

CORRECTIVE ACTION PLAN Catholic Charities respectfully submits the following corrective action plan for the year ended June 30, 2022. Name & address of public accounting firm: Jones & Roth CPAs 260 Country Club Rd. Ste. 100 Eugene OR 97401 Audit Period: June 30, 2022 Major Federal Award Findings: Finding Reference #: 2022-001 Significant deficiency Recommendation: We recommend management review the current internal control procedures and implement additional procedures to ensure annual recertifications are performed as required by HUD. Corrective Action: Management will work with Cascade Management to improve the internal control procedures to ensure annual recertifications are performed as required by December 31, 2022. Questions regarding this corrective action plan may be directed to Marci Pierce, Chief Financial and Administrative Officer, at (503) 688-2646.

Response and Corrective Action Plan: The District will review current policies and procedures for bonus payouts. Cindy Lewis, June 30, 2023.

Finding Number: 2022-002 Finding Title: Eligibility Program: 93.778 Medical Assistance Program Name of Contact Person Responsible for Corrective Action: John Stepien - Financial Assistance Supervisor Corrective Action Planned: Ongoing communication with agency Eligibility staff will occur regularly. Unit meetings are planned and will be held twice per month with Health Care as a standing agenda item. The importance of updating MAXIS with reported information will be discussed at these meetings. DHS also provides County and Tribal nations with regular update meetings which agency staff will be encouraged to watch every other Wednesday. In addition, the HCE-PIX meetings are specifically directed toward heath care and the updates that were made to policy and procedure. These meetings occur between 2 to 5 times per month and the information shared will also be a topic of discussion during our semimonthly unit meetings. During the unwinding period of the Public Health emergency DHS has sent out several bulletins with policy updates and the procedures these new policies require along with agency responsibilities. Communicating these changes regularly will aide in the appropriate and accurate determination of Health Care eligibility. Anticipated Completion Date: July 01, 2023 and ongoing.

Finding Reference Number; 2022-002 Federal Agency:Department of Agriculture (USDA) Description of Findi ng: Criteria: : 2 CFR Section 200.318 stipulates that a non-Federal entity must use its own documented procurement procedures which reflect applicable state, local, and tribal Jaws and regulations, provided that the procurements conform to applicable Federal law and the standards identified in Part 200 Subpart D. Additional ly, 2 CFR Section 200.213 stipulates that no awards, subawards, or contracts be awarded to parties that are debarred, suspended, or otherwise excluded from or inel igible for partici pation in Federal assistance programs or activities. Condition: During audit testing performed by Mengel, Metzger, Barr & Co, LLP, they noted the following: - The contractors util ized by the Food Bank in 2022 were not properly checked for compl iance requirements regarding debarment. They did not have a control in place to ensure the contractors used for their covered transactions were not made with a debarred or suspended party . Statement of Concurrence or Nonconcurrence: The Food Bank agrees with this findi ng. Corrective Action : The Food Bank has implemented procedures to ensure all contracted vendors are vetted to ensure they are not on the federal exclusion list. All contractors used in 2022 have been checked and are not on the list. Name of Contact Person: Renee Law, Chief Financial Officer; phone number 518-786-3691 ext 226; email ReneeL@Regionalfoodbank.net. Projected Completion Date: May 31, 2023

Deficiencies in the Medicaid Eligibility Determination Process Department Name: Health and Human Services Contact Name / Telephone Number of Person Responsible for CAP: Eva Fulcher - (919) 813-5343; Betty Dumas-Beasley - (919) 527-7739 The Department reviewed the errors identified in the audit and will follow-up with each responsible county to correct the beneficiary record. When applicable, the Department will issue overpayment recoupment notices to the affected counties as required by state statute. Anticipated Completion Date: June 30, 2023.

Errors in Medicaid Provider Billing and Payment Process Department Name: Health and Human Services Contact Name / Telephone Number of Person Responsible for CAP: Natasha Bostick-Drake - (919) 710-7891; Cathy Pace - (919) 527-7005 The Division of Health Benefits (DHB) will analyze each error identified in the audit and take appropriate action. A Tentative Notice of Decision (TND) will be sent to each provider to recoup any overpayment identified. Provider Education Letters will be sent to all providers with identified errors. DHB will conduct a six-month post payment review of the affected providers? fee-for-service paid claims to determine if errors are recurring. Anticipated Completion Date: December 31, 2023. DHB will work with General Dynamics Information Technology (GDIT) to update the Maternity Event billing rates that were in error for the affected time periods in NC Tracks. DHB will reprocess the claims and pay at the correct rate. DHB will review and enhance rate setting internal controls to mitigate the risk of this error recurring. Anticipated Completion Date: June 30, 2023.

FINDING 2022-001: 84.007 Federal Supplemental Education Opportunity Grant, 84.033 Federal Work Study Program, 84.038 Federal Perkins Loans, 84.063 Federal Pell Grant Program, 84.268 Federal Direct Loan Program, 84.379 Teacher Education Assistance for College and Higher Education Grants Recommendation: The College should perform and document an annual risk assessment to determine the College's specific risks relevant to protecting consumer nonpublic personal information. At a minimum, the College should have at least one risk statement aligned or referenced to each of the three required areas noted in the GLBA law at 16 CFR 314.4 (b). Finally, the College should identify and document at least one safeguard (i.e., control) for each of the risks identified and document in the risk assessment. Each control should be aligned or referenced to the risk(s) to which the safeguard applies. Action To Be Taken: The College will complete a GLBA risk assessment that addresses (1) employee training and management; (2) information systems, including network and software design, as well as information processing, storage, transmission and disposal; and (3) detecting, preventing and responding to attacks, intrusions, or other systems failures and document safeguards for identified risks. The College will complete the assessment in accordance with the December 9, 2021 Federal Trade Commission (FTC) issued final regulations to amend the Standards for Safeguarding Customer Information, including ensuring the College?s written information security program includes the nine elements included in the FTC?s regulations. Responsible Individual for Corrective Action: Scott Seidman, Director of IT Services Anticipated Completion Date: June 15, 2023

Finding 2022-003: COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Plan to Correct: If we are to receive federal funding of this kind in the future we will insure the validity of any expense chosen after verifying against the standards set by the fund guidelines before expenditures are made or any reporting is completed. Internal staff will also review work papers in detail to double check data integrity to ensure reporting is accurate. We will work with our CPA firm or other appropriate consultant if we have any questions surrounding expenses chosen. Responsible Party: Denise Doucette, CFO/VP Estimated Completion: Ongoing.

SIGNIFICANT DEFICIENCY 2022-001 Financial Close Process Recommendation: The Authority should re-evaluate its financial reporting system: reviewing the general ledger mapping and close processes. This determines whether additional controls over the preparation of the final trial balances and related schedules can be implemented to provide reasonable assurance that financial statements are prepared in accordance with U.S. GAAP and HUD Public Housing Authority accounting briefs. We recommend the Authority to review its current procedures for reconciliations and year end close procedures and evaluate the need for additional review to ensure accurate reporting. Explanation of disagreement with audit finding: While management agrees that improvements are needed, related to the newly implemented financial software the City of Arlington adopted; including mapping of the general ledger and with coordination with the Federal Data Schedule (FDS), management believes actual internal controls are effective as demonstrated by previous audits. The AHA should have until 6/30/2023 to complete the audit. However, because AHA is a component unit of the City, the timeline to complete the audit is much earlier, reducing the time available to complete the corrections needed to account for the new financial software. Action planned in response to finding: Management and the City of Arlington are working with consultants to improve general ledger mapping and crosswalks to the FDS. Name(s) of the contact person(s) responsible for corrective action: Mindy Cochran and Borhan Uddin Planned completion date for corrective action plan: June 30, 2023 2022~002 Housing Voucher Cluster-Assistance Listing No. 14.871/14.879 Recommendation: We recommend that the Authority reviews its internal controls over obtaining and maintaining income, expense tenant file documentation, and reviewing the calculation to ensure compliance with eligibility requirements. Explanation of disagreement with audit finding: There is no disagreement with this finding. However, management maintains that internal controls are effective noting that errors are found and corrected through the internal control processes. Human errors do occur, and internal controls cannot cover the thousands of transactions processed annually. AHA's SEMAP scores consistently recognize AHA as a high performer, scoring all points in indicators 3 and 10 which monitor correct calculations for adjusted income and correct tenant rent calculations. AHA does intend to increase internal audits through the addition of a dedicated compliance staff member. Action planned in response to finding: Both errors have been corrected. The total dollar amount of rental assistance provided was $162 for both errors. AHA is in the process of hiring for additional compliance reviews. Name(s) of the contact person(s) responsible for corrective action: Mindy Cochran Planned completion date for corrective action plan: Corrections have been made for the two files indicated, and hiring for compliance is expected to be complete by June 30, 2023.

Condition/Finding: During review of eligibility testing support, it was noted that for the tenant?s annual re-examinations and certifications under HUD Project Rental Assistance Contract Number FL29-S951-006, the incorrect amount of contract rent was being utilized on the forms to calculate the projects tenant assistance payment. The Project incorrectly double counted the utility allowance of $51 and was using a gross rent rate of $833 to calculate the tenant rental assistance payment when it should have only used a gross rent rate of $782 per the contract. This resulted in the Project requesting a tenant rental assistance payment that was $51 more than what it should have been for each tenant on the Housing Owner?s Certification and Application for Housing Assistance Payments (HAP) for 8 months of fiscal year 2022. Upon the Project?s analysis, it was determined that the total amount of the error, net of vacancies, was $37,585. Corrective Action Taken or Planned: Management has established procedures to ensure that there is a better process to check the amounts of contract rent being approved on the re-examinations and certifications of tenants. This includes, but is not limited to, an additional review step and control for confirmation of the correct contracted and billed amounts. This additional procedures also includes processes with more closely reviewed monthly HAP forms by the appropriate personnel to ensure that the amounts being requested of HUD are in line with the appropriate contract rates. Corrective action has been implemented with all corrections approved by and reconciled with HUD. This will be fully implemented and realized by the close of the current calendar year, December 31, 2022. The primary designated official is the Chief Financial Officer.

2022-001 Reporting ? Assistance Listing No.: CFDA Nos.: 10.553 School Breakfast Program, 10.555 National School Lunch Program, and 10.559 Summer Food Service Program for Children Condition: The District?s supporting documentation for meal counts used to submit for reimbursements from the State inconsequentially did not agree to the meal counts submitted. Audit Recommendation: In order to prevent future occurrences of this deficiency, we recommend that management ensure that good record keeping is kept at all buildings of where the meals are served. We also recommend the records are reviewed effectively and efficiently each month for accuracy. Corrective Action Implemented: In the 2022-2023 school year, the district resumed using the cafeteria management system for daily recordkeeping of meals sold. Further, the district adopted the use of a backup recordkeeping tally sheet that includes multiple levels of verification to strengthen this control. Person Responsible for Implementing the CAP: Pamela Strompf, Food Service Director Implementation Date: 2022-2023 school year

2022-004 Child Nutrition Cluster (10.55X) Condition and Cause: The District was required to verify one application for program eligibility and properly report results. During our review, the District did not properly update the School Food Authority Verification Collection Report for 2021-2022 based on the results of the verification sample. Criteria: By November 15th of each school year, the District must verify the current free and reduced price eligibility of households selected from a sample of applications that it has approved for free and reduced price meals. Results of this verification must be properly reported in the School Food Authority Verification Collection Report. Effect: Because of improper reporting, the District?s verification report did not accurately reflect the results of the verification sample. In addition, the District could be inaccurately providing free or reduced lunches to students. Auditor?s Recommendation: The District should review the federal requirements for completing verification of applications to ensure that future verifications completed by the District are complete and appropriate and properly report on the verification report. Grantee Response: A new process will be put in place for future income verifications to ensure the entire verification process will be completed accurately and timely. Contact Person: David Boland Anticipated Completion: On-going

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Voucher Cluster Assistance Listing Number: 14.871 & 14.879 Passed Through: Direct Award Pass Through Number: N/A Compliance Requirement Affected: Special Provisions Award Period: 2022 Type of Finding: Material Weakness in Internal Control over Compliance. Recommendation: We recommend that the Authority design and implement internal controls over special provisions. Other provisions, such as reasonable rent, housing quality standards inspections, and HQS enforcement, should be reviewed by someone independent of the initial preparation/inspection. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Authority will evaluate implementing reviews over tenant files, financial and performance reports, and other special provisions. Name of the contact person responsible for corrective action plan: Kim Wallace, Executive Director Planned completion date for corrective action plan: December 31, 2023

We are looking at ways to streamline/standardize our expenditure procedures so that documents live in consistent places that we can locate as necessary even if staff turnsover. We are also looking at additional training for staff and managers. Finally, the increase in finance team mentioned above should help review documentation on a more contemporary basis. Anticipated Completion Date: September 30, 2023 Responsible Contact Person: David Maloney, Shelter House Controller

Program: Emergency Rental Assistance Program Assistance Listing No.: 21.023 Federal Agency: U.S. Department of the Treasury Passed-through: Direct Award Award Year: 2021/2022 Compliance Requirement: Eligibility Type of Finding: Significant Deficiency, Instance of Noncompliance Views of Responsible Officials: We concur with the finding. Corrective Action Plan: The Emergency Rental Assistance Program (ERAP) is closed. It was a temporary program and the deadline to expend funds has passed. Should the County consider implementing a similar program in future, this recommendation will be included. Responsible Individual(s): Anne Putney, Principal Management Analyst Anticipated Completion Date: N/A

Program: Temporary Assistance for Needy Families Program Assistance Listing No.: 93.558 Federal Agency: U.S. Department of Health and Human Services Passed-through: California Department of Social Services Award Year: 2021/2022 Compliance Requirement: Allowable Costs, Eligibility and Special Tests and Provisions Type of Finding: Material Weakness, Instances of Noncompliance Views of Responsible Officials: We concur with the finding. Corrective Action Plan: Finding Part 1: Two (2) out of 60 cases tested were missing the annual redetermination for the reevaluation of their benefits and eligibility requirements. Solano County has policies and procedures as well as systematic processes set up to ensure that redeterminations are processed annually. It is Solano County?s policy that the SAWS 2 Plus, Rights and Responsibilities and the Child Support Questionnaire and Notice and Agreements be processed which require workers to: ? Conduct a telephone interview with the recipient, print the forms, and document the County Use Section which requires worker?s signature and date. ? Mail the forms to the recipient for signature ? Upon return, review the SAWS 2 Plus and additional forms for completeness ? Initiate the required case action based upon information provided on the forms A redetermination of eligibility of the recipient shall be completed at least once every twelve (12) months. The annual CalWORKs Redetermination requires a face-to-face or telephone interview with the parent or person responsibility for the child or the person having responsibility for the care and control of the child. The Division Managers implemented a Quality Assurance Unit of lead workers to conduct 2-3 case reviews per month for all workers. Case reviews are a valuable tool in assessing case accuracy and recognizing quality casework. The case reviews are used to develop and strengthen worker and supervisory skills, provide structure for measuring results, identify, correct and prevent errors, and strengthen accountability to the programs and services we delivery as an agency. Specific corrective actions are outlined below to prevent these errors in the future: ? The CalWORKs Program Specialist will work with Hiring and Staff Development to strengthen the eligibility redetermination handbook with verbiage to emphasize the following: o The renewal be authorized only after required forms are received by the county and scanned into the document imaging system. o Ensure that redetermination dates are correct in the system at application and renewal. o Highlight these requirements when training this topic ? The CalWORKs Program Specialist will discuss the findings and redetermination requirements in the following ways: o Monthly Program Support Forum conducted with managers, supervisors, and lead workers o Issue a reminder memorandum to all staff o Written material will be published in the Monthly Program Support Newsletter to all staff Finding Part 2: In 31 out of 60 cases, we found that the review of the IEVS was not documented during the application or annual re-determination applicable to the fiscal year. However, we found that the related recipients/cases were eligible. It is Solano County?s policy to maintain program integrity. All CalWORKs (TANF) cases are required to be reviewed to assist with the eligibility determination using the Income and Eligibility Verification System (IEVS) at application and annual redetermination. ? IEVS is a computer cross match of State wage data, Unemployment Insurance Benefit data, wage data maintained by the Social Security Administration, and unearned income data maintained by the Internal Revenue Services and/or Franchise Tax Board. ? Staff is required to initiate the required case action and notices based on information received from the report, which includes generating adequate and timely notice. ? IEVS is system-generated at application. Effective February 2021, the CalWIN system auto-generates IEVS at least 15 days prior to the beginning of the redetermination due month. Specific corrective actions are outlined below to prevent these errors in the future: ? An ad-hoc report will be developed to generate monthly to help ensure the reports are reviewed and signed off by workers. A process will be put in place to ensure supervisors and lead workers follow up with the completion of these reports. ? The CalWORKs Program Specialist will work with Hiring and Staff Development to strengthen the eligibility handbook sections for Application, Annual Redetermination, and IEVS Interfaces. ? The CalWORKs Program Specialist will discuss the findings and IEVS requirements in the following ways: o Monthly Program Support Forum conducted with managers, supervisors, and lead workers o Issue a reminder memorandum to all staff o Written material will be published in the Monthly Program Support Newsletter to all staff Responsible Individual(s): Daniel Horel, Employment and Eligibility Services Manager Thomas West, Employment and Eligibility Services Manager Anticipated Completion Date: June 30, 2023

Subject: Hennepin County?s 2022 Corrective Action Plan Finding# 2022-004?Eligibility Program: Medical Assistance Program (ALN 93.778) Type of Finding: Material Weakness in Internal Control over Compliance; Other Matter Compliance Finding Condition: During our testing, we noted the following instances of noncompliance in the sample of 120 case files tested: ? One MAXIS case file had assets greater than their applicable household size asset limit. While beneficiaries may reduce their assets to continue to qualify, there was no documentation in the case notes showing the applicant reduced their assets subsequent to renewal in order to continue to qualify for benefits. ? One MAXIS case file had different bases of eligibility in MAXIS and MMIS where MAXIS indicated the beneficiary was ?EX? (age 65 or older) while MMIS indicated the beneficiary was ?DX? (disabled). ? One METS case file included documentation of verification of income that did not match the information entered into METS. ? One METS case file did not have a SSN entered at either the initial application date nor any of the subsequent renewal dates. No exemptions to the requirement to submit a SSN was noted in the case within METS. In addition, the County does not have effective internal controls over eligibility of the Medicaid program: ? The County does not have a formalized supervisory case file review process in place to ensure accuracy and completeness of inputs into the MAXIS and METS systems. ? We were not able to review and test the automated application controls and the related ITGCs within the MAXIS, METS and MMIS systems, all of which are state systems that are administered by the state and required to be used by the County, to determine whether the system controls are adequately designed and implemented and operating effectively for the determination of eligibility. Hennepin County?s Corrective Action Planned in Response to Finding: Program staff will design internal controls to ensure eligibility inputs are correctly entered, and information required by contract is retained. Hennepin County Employee Responsible for the CAP: Jackie Poidinger Planned Completion Date for CAP: December 31, 2023 Hennepin County will encourage the State to provide an independent audit of the design and implementation of MAXIS, METS, and MMIS system controls for the benefit of all counties. Hennepin County Employee Responsible for the CAP: Andra Roethler Planned Completion Date for CAP: December 31, 2023

Subject: Hennepin County?s 2022 Corrective Action Plan Finding# 2020-005?Eligibility Program: Foster Care Title IV-E (ALN 93.658) Type of Finding: Significant Deficiency in Internal Control over Compliance Condition: While we were able to test manual compensating controls over activities allowed or unallowed, allowable costs/cost principles and eligibility, we were not able to review and test the automated application controls and the related ITGCs within the MAXIS and SSIS systems that reside within the State of Minnesota, but are utilized by the County, to determine whether the system controls are adequately designed and implemented and operating effectively. Hennepin County?s Corrective Action Planned in Response to Finding: Hennepin County will encourage the State to provide an independent audit of the design and implementation of MAXIS and SSIS system controls for the benefit of all counties. Hennepin County Employee Responsible for the CAP: Andra Roethler Planned Completion Date for CAP: December 31, 2023

Subject: Hennepin County?s 2022 Corrective Action Plan Finding# 2022-002?Eligibility Program: WIC Special Supplemental Nutrition Program for Women, Infants, and Children (WIC) (ALN 10.557) Type of Finding: Significant Deficiency in Internal Control over Compliance Condition: While testing the eligibility requirement, we noted procedures and controls were not operating as designed to ensure that only those eligible were approved for WIC. In our sample of 40 cases, two cases had no evidence that an independent review of the eligibility determination occurred. In addition, while we were able to test manual compensating controls over eligibility determination, we were not able to review and test the automated application controls and the related information technology general controls (ITGCs) within the HuBERT system, a state system that is administered by the state and required to be used by the County for eligibility determination, to determine whether controls are adequately designed and implemented and operating effectively. Hennepin County?s Corrective Action Planned in Response to Finding: Program staff will establish a process to strengthen eligibility determinations. Hennepin County Employee Responsible for the CAP: Jill Wilson Planned Completion Date for CAP: December 31, 2023 Hennepin County will encourage the State to provide an independent audit of the design and implementation of HuBERT system controls for the benefit of all counties. Hennepin County Employee Responsible for the CAP: Andra Roethler Planned Completion Date for CAP: December 31, 2023

Finding Number: 2022-004 Condition: The notifications related to the direct loan borrowers did not include information on the right to cancel or instructions on how to cancel the loans. Planned Corrective Action: The University?s new financial aid module does not have the capability to send emails. That functionality does exist in the University?s new student information system. Consequently, effective for Fall 2022 semester, the Office of Financial Aid partnered with Office of the Controller ? Student Accounts to generate emails on a weekly basis to any student who receives a disbursement of Title IV funds. By May 1, 2023 the University will create similar procedures to identify disbursements of Parent PLUS loans and then coordinate with Office of the Controller - Student Accounts to leverage the student information system to send notifications to parent borrowers. Contact person responsible for corrective action: Marshall Rumsey, Senior Associate Director, Office of Financial Aid Anticipated Completion Date: Completed September 8, 2022 (student), to be completed May 1, 2023 (parent)