Corrective Action Plans

Finding Number: 2022-005 Condition: The University awarded incorrect Pell awards to certain students based on the Pell Payment and Disbursement Schedule. Planned Corrective Action: The University?s new financial aid module was modified to use the census date for Pell recalculation rather than an arbitrary number of days into the term that did not match the University policy. The correction for this finding was implemented prior to aid being disbursed for the Fall 2022 semester. Contact person responsible for corrective action: Cheryl Whitman, Associate Director, Office of Financial Aid Anticipated Completion Date: Completed August 31, 2022

Statement of Condition: In connection with our lease file review, we noted one out of three tenants did not have a recertification performed timely or the income verification with the use of the HUD Enterprise Income Verification ("EIV") performed timely. Corrective Action: Due to either tenant non-compliance or challenges with scheduling meetings with tenants or obtaining verifications, some recertifications were completed late. REACH has policies in place to complete recertifications timely, and will be providing ongoing training and guidance to staff to make sure the policies are being followed.

Finding ? Return of Funds Condition Out of forty students selected for testing, nine students were under awarded Pell grants based on their EFC and COA. This is not a statistically valid sample. Views of Responsible Officials and Planned Corrective Actions The University begins to award students prior to the new Pell Grant schedule release in late March. In April our software provider, Ellucian, releases an update for us to upload with the new Pell Grant schedule. This update was completed but some of the Pell Grants that had been packaged prior to the update were not reprocessed and repackaged with the new Pell Grant amounts. This error was due to a loss of personnel that had previously managed the reprocessing of the Pell Grants. Management has already reprocessed any students for 2022-23 to ensure correctness of Pell awards for the current year. Additionally, management has adopted new step by step procedures in writing to assist with the reprocessing/repackaging of Pell Grant awards to ensure that proper practices will be followed on a forward basis. Management is also in the process of reviewing 21-22 Pell awards and will disburse any shortfalls by December 31, 2022 to impacted students. Responsible Official: Frank Mullen Completion Date: 10/26/2022

Corrective Action: Supervisors and Lead Workers randomly conduct 2nd party reviews on case actions completed by IMC workers. All new hires go through and extensive training plan and are only released when error rate is 5% or less. Workers must continue to maintain an overall rating of 95% to be released from all of their work being 100% 2nd party reviewed. Work issues and errors are corrected immediately when discovered and Lead Workers and Supervisors provide training to the unit or individuals, as needed. The County remains proactive in resolving all errors cited while battling issues with turnovers, limited staff, and inexperienced staff. An effective training plan has been implemented and is administered by the Staff Development Specialist and the Lead Worker Unit. Monthly and one-on-one conferences are conducted to discuss error citing found and coaching or refresher trainings are conducted. Proposed Completion Date: Immediate actions have been taken to resolve issues cited. The County continues to complete 2nd party reviews on each worker and evaluate error trends cited for corrections needed through coaching, refresher courses or training. Trainings pertinent to the specified findings will be completed by 12/01/2022.

Corrective Action: Lead Workers will run the exparte logs weekly and assign them to workers and send notifications to respective supervisors to oversee. Lead Workers and Supervisors will monitor the reports to ensure reviews are completed within 30 days of receipt. Lead Workers will have the overall responsibility to ensure that report and reviews remain in compliance and are worked thoroughly and correctly. Lead Workers and Supervisors will monitor and train new workers and ensure workers are able to retain policy knowledge and apply said knowledge to case actions accurately. The Supervisor over the Lead Workers will conduct conferences and discuss and monitor report findings for continued timely completion. Proposed Completion Date: Immediate action taken to resolve issues found. This task will be ongoing and will be mitigated through training and implementation of more effective fiscal controls, with a proposed completion by 12/01/2022. These case citing?s resulted from tasks being assigned to workers who were no longer employed or moved to new positions and failed to complete case actions before leaving or moving from assigned job post. This citing was also a result of limited staff to monitor the tasks once position was vacated. The County has made every effort to minimize and mitigate the issues and findings cited and to strengthen the training process for the Medicaid Unit.

Identifying Number: 2022-001 Audit Finding: Eligibility Requirements for Refugee and Entrant Assistance, Federal Assistance Listing Number 93.566 for 2022 issued by the US Department of Health and Human Services. (Repeat) Corrective Action Planned: Management of the Organization is requiring regular ongoing training for all federal programs. All files will be reviewed on a regular basis by a supervisor to ensure eligibility checklists have been used and completed and that all required documentation is contained in the files. The checklists themselves are being reviewed on a regular basis to ensure they reflect current federal guidelines. The biggest reason leading to this finding is that the checklists had not been signed off documenting review procedures were in place. We are now requiring staff to sign off on all checklists and are working to improve the checklists documentation to ensure that all internal controls are documented properly. We note that due to the large increase in the number of people being served, the organization has recently hired additional staff to maintain the content of the files to achieve compliance. Compliance managers will be assigned whose sole duty is to verify the required documentation exists in the files. The compliance managers will report to a supervisor who is independent of the program leadership. The name of the contact person responsible for the corrective action: Jeff Gulde, Executive Director The anticipated completion date: To be completed by March 31, 2023.

IU Health designed and implemented internal controls over the allowability of expenses and amounts submitted in the HRSA and ARP reports. These internal controls were precise enough to ensure that the submissions were compliant with HRSA reporting guidance. In fact, IU Health reached out directly to HRSA to confirm the appropriateness of its election. IU Health remained consistent in utilizing the annual budget as a basis for lost revenue past 2020. As inferred from the annual budget approval date threshold of March 27, 2020, our 2021 and 2022 budgets were prepared using prepandemic years as a baseline expectation. IU Health also conversed directly with HRSA wherein a representative confirmed our use of option 2 as appropriate for Period 3 and beyond, because, according to the representative, the intention of the written regulation did not literally mean budget approval for years past 2020 to have occurred prior to March 27, 2020. As our annual budgets were already naturally materially in line with our long-range plan that was approved in December of 2019, it seemed we were adhering to the spirit of the guidelines set forth. For future periods, IU Health will elect option 3 for lost revenue. Contact Person(s) Responsible for Corrective Action: David Burton Anticipated Completion Date: Effective for Period 5 deadline of September 30, 2023

Finding Number: 2022-005 Condition: The University improperly reported the students that withdrew within the COD System as a result of the COVID-19 national emergency. Planned Corrective Action: The Student Financial Aid (SFA) office agrees with the finding that certain withdrawn students were improperly reported in COD because of the COVID-19 national emergency. SFA evaluated its R2T4 procedures and strengthened its internal controls by discontinuing the practice of automatically adding the COVID indicator to students who withdrew. Contact person responsible for corrective action: Lana Greaves, Senior Associate Director, Student Financial Services Anticipated Completion Date: 4/15/2023

The accurate reporting of campus-level OPEID is required by federal regulation for Title IV students, and although the reporting provides data on Title IV programs, it does not prompt repayment on loans or have any impact on a student's federal aid eligibility. Pursuant to a root-cause analysis conducted by the University, it was determined (and ultimately acknowledged) by the servicer that it had failed to follow established protocols prior to transmitting this information to NSLDS, which led to this finding. The information provided by the University was accurate and consistent with the methodology we use regularly to transmit information to this servicer. The U.S. Department of Education requires independent compliance audits for third-party servicers that help colleges and universities administer Title IV programs and, as part of our on-going due diligence, we reviewed the attestation opinion issued by the independent auditor, who noted no issues with respect to this particular compliance requirement or the servicer?s ability to comply with it. The University has discussed with the third-party servicer its process for submitting Campus-Level information to the NSLDS, and changes are being made by the servicer to ensure its own compliance with the methodology for transmitting data to the NSLDS. The University is also undertaking a detailed review of this servicer?s performance to mitigate the risk of recurrence.

Cluster: Not applicable Federal Agency: Department of Health and Human Services Award Names: Substance Use Disorder Treatment and Recovery Support Services Award Numbers: T1081685 Assistance Listing Title: Opioid STR Assistance Listing Number: 93.788 Award Year: 2021 - 2022 Pass-through entity: NH Dept of Health and Human Services Management understands and agrees that there was a failure to follow the documentation requirements of the Opioid STR award during the majority of the time period covered by the audit. In June 2022 the Doorway began implementing a screening tool used at the time of patient intake to determine which patients are eligible under the grant. Additionally, a process will be implemented to perform the required income reassessments every 4 weeks and to track time and differentiate costs between eligible and non-eligible patients. Any patient deemed ineligible in the initial screening or subsequent four week reassessments will continue to be treated, but the associated cost will not be charged to the grant. This documentation will be reviewed a minimum of two times per year by Cheshire?s Compliance Manager, and more frequently if errors are found. Results will be reported to the Chief Operating Officer and the Chief Financial Officer Cheshire has implemented a separation of duties where the clinic administrator will ensure and maintain appropriate documentation, while a senior finance analyst will review and verify appropriateness prior to invoicing the grant. This process will add an additional check to be certain only eligible patients are charged to the grant. Leadership Responsible: Daniel Gross, Chief Financial Officer ? Cheshire Medical Center Anticipated Completion Date: 9/30/2023

Finding 2022-001, Significant Deficiency over Eligibility (Repeat Finding); Medicaid Cluster (Medicaid), Assistance Listing Number 93.778, U.S. Department of Health and Human Services, passed through the N.C Department of Health and Human Services (NCDHHS), Division of Medical Assistance. Recommendation: The County train and monitor employees on the eligibility determination process; also recommend the County review and amend current policies and procedures in place to ensure that all eligibility determination documentation is completed and retained by the County. Corrective Action Plan: The County will complete a quarterly review of errors in income, resources, and social security number and citizenship verification. For those staff identified by the targeted review with errors in these areas, supervisors will provide refresher training on Medicaid policy requirements. Additional targeted reviews will be completed monthly until the deficiencies are corrected. Proposed Completion Date: 1/31/2023 for initial quarterly review 2/28/2023 for refresher training for identified staff 7/31/2023 for additional reviews as needed for identified staff Contact Person: Yolanda McInnis, Economic Services Division Director

Finding 2022-003, Material Weakness ? Eligibility Second Party Reviews; Temporary Assistance for Needy Families, Assistance Listing Number 93.558, U.S. Department of Health and Human Services, passed through the N.C Department of Health and Human Services (NCDHHS), Division of Social Service. Recommendation: The County abide by the State policies in terms of the frequency and amount of case reviews each month; also recommend that policies and procedures are documented surrounding second party reviews and be reinforced to ensure that reviews are being completed and followed up as necessary. Corrective Action Plan: By the 10th workday of every month, the WFFA QA Reviewers will begin to randomly assign cases to WFFA Supervisors and QA team as a checklist in Donesafe for the 25% SPR review. When QA make their assignments on the main form the QA quarter on the checklist should coincide with the month the case was assigned. For example, case was assigned on December 7th for a November action. Case was audited on Jan 3 (Jan 17th deadline) Therefore, this case should be marked as DocuSign Envelope ID: 6BCAC0B4-BD53-4ECF-BA2D-C7510B4F94EC 4th Quarter. QA will attempt to assign the same case for SPR and regular audits whenever possible. The QA Supervisor will send out an email at the start of a quarter to the Program Manager and Auditors to address pending checklists that need to be completed before their deadline. Proposed Completion Date: The Corrective Action will be immediately implemented in response to the auditors? recommendations. Contact Person: Janny Mealor, Assistant Division Director

Corrective Action Plan: Ohio?s corrective action plan for this finding includes system improvements, additional coordination with the Ohio Department of Job and Family Services (ODJFS) on monitoring the processing of IEVS alerts, and additional monitoring of county caseworkers? processing of IEVS alerts by ODM?s Medicaid Eligibility Quality Control (MEQC) unit. ODM and ODJFS continue to meet to analyze the alerts in Ohio Benefits and the group presents recommendations to our vendor for overall system alert improvements; these recommendations were prioritized and corrected in our normal release cadence. The next alert centered release is scheduled for April 2023. Comprehensive alert reduction efforts reduced overall ~29 million backlog alerts and drove a ~22 million annual reduction in new arrival of alerts. ODM, ODJFS and DAS remain committed to improving the alert functionality. ODM and ODJFS meet monthly to discuss triad reviews completed by ODJFS, that evaluate the counties? IEVS alert processing. ODM County Engagement follows up with the counties after these meetings to discuss action plans for working IEVS alerts. ODJFS also conducted a statewide training in July 2022 that focused solely on IEVS alerts processing. Additionally, some counties have taken part in one-on-one IEVS alerts trainings that have proven to be very beneficial. A system release devoted to IEVS enhancements is planned for R4.6.1 (April 2023) which will streamline the process for county staff to process IEVS matches from the IRS Unearned Income interface. There will be both E-Verify enhancements and a change in the match logic which will result in a reduction in the volume of IRS records that are flagged as IEVS matches. As a result, caseworker time spent on processing IRS IEVS matches is expected to reduce. The resulting time is expected to have more value by allowing caseworkers to focus time on matches with an eligibility impact or potential for benefit recovery. During SFY22, the MEQC unit continued to monitor IEVS alerts during the CMS pilot review process. During the review process, if it was determined that a case was processed with an unworked IEVS alert that resulted in a case processing error, it was cited as a technical deficiency and the county was notified. IEVS alerts will continue to be monitored by the MEQC unit going forward. Anticipated Completion Date for Corrective Action: ? The Ohio Benefits system improvement work and IEVS alert training ? Completed and continuing in fiscal year 2023 ? IEVS enhancement system release - April 2023 Contact Person Responsible for Corrective Action: Nathan Bowers, Program Integrity Audit Compliance Coordinator, Ohio Department of Job and Family Services 50 West Town Street, Columbus, Ohio 43215 Phone Number: 614-705-1049, E-Mail Address: Nathan.Bowers@medicaid.ohio.gov

Corrective Action Plan: ODM has either completed or begun corrective action on all of the following recommendations. CDJFS Caseworker Case Processing Weaknesses AOS cited caseworker reliance as an eligibility process weakness. While Medicaid eligibility systems have been updated to bring efficiencies in the Medicaid renewal and enrollment processes, human intervention is integral to ensure cases are processed accurately and appropriately. The dependence on caseworker knowledge and judgement is ongoing and is not perceived as a weakness, but an expectation for a state supervised county administered program. The federal regulation at 42 CFR ?431.10(c) limits the state?s ability to delegate authority to make eligibility determinations to only a government agency which maintains personnel standards on a merit basis. CMS provided additional information in its response to Q32 in the COVID-19 Public Health Emergency Unwinding Frequently Asked Questions for State Medicaid and CHIP Agencies document dated October 17, 2022, indicating that the merit-based personnel standards apply to all eligibility determination functions that require discretion, whereas contractors may be used to support the administrative functions of the eligibility determination process that do not require discretion. This guidance to states supports ODM?s established process that caseworkers are expected to exercise their own judgement with regard to the eligibility determination. Further, it would not be an effective use of federal or state funds to build an eligibility system in such a way that every possible exception scenario can be addressed by system rules and functionality. There are simply too many permutations of household scenarios and eligibility outcomes to make that a feasible option. As a result, caseworker knowledge, judgement, and discretion are integral to the eligibility determination process. AOS cited caseworker training as an eligibility process weakness. ODM, in collaboration with ODJFS, will continue to conduct a variety of trainings throughout the year as described below. While not yet mandatory, all trainings are offered to all 88 CDJFS agencies and are open to caseworkers and supervisors. In addition, high priority trainings are offered live on various days and times and are made available online to view at any time. At this time, we do not yet have the technology available to assign learning plans to county caseworkers and ensure completion, however ODM continues to consider its options for mandating training for county employees, and the advantages and disadvantages of that approach. ? New Worker Training - In SFY2022, the new worker training program underwent a total overhaul to update materials, improve interactivity, and close information gaps between programs. New worker training sessions are scheduled quarterly in 2023 and are offered to all new workers across the state. A new worker training began on February 27, 2023. ? Regularly Scheduled Webinars - ODM hosts monthly webinars and other targeted trainings throughout the year with all 88 counties. The monthly webinars include policy updates, training material, and general guidance or instruction on recent changes and issues. During SFY2022, ODM provided training updates on over 30 policy or procedural topics. Targeted trainings are scheduled to continue throughout 2023. Recordings for presentations are made available to access online at any time. ODM and ODJFS also host Operational System Release Webinars to review implemented system enhancements and fixes. ? On-Demand Inquiry Assistance - Technical Assistance and System support are provided via email for counties to submit questions and receive ODM guidance on both policy and procedures, as well as how to process within the Ohio Benefits system. During the return to routine eligibility operations period, county ?Ambassadors? have access to a Return to Routine Operations Team channel with real-time Q&A support, as well as training materials and desk aids. ? Future Training Plan - Moving forward, training will be a critical success factor for closing the knowledge gap(s) identified during various audits. ODM County Technical Assistance (TA) will identify the training topics, develop curriculum and training delivery methods for the identified training areas. To ensure successful and timely delivery, ODM TA will develop a 24-36 month training schedule of development, review, and delivery milestones to monitor progress. Calendar year 2023 training will focus on returning to routine case processing outside of the PHE, including revisiting conditions of eligibility, electronic verification processing, and proper discontinuance processes. ODM conducted six live sessions in February 2023, addressing returning to routine eligibility operations and will conduct a variety of trainings in April and May on eligibility basics, considering how many case workers have not determined eligibility outside of the public health emergency continuous eligibility restrictions. Recordings of these sessions are available on the County Resources page and will be converted to the Ohio Benefits Program website. The ODM Medicaid Eligibility Quality Control (MEQC) Unit continually monitors Medicaid case processing accuracy. The MEQC Unit reviews CDJFS eligibility determinations, verifies accuracy of recipient information in Ohio Benefits, verifies information is being maintained to support the eligibility decision, and evaluates timeliness of applications. All MEQC error and technical deficiency findings are shared with the CDJFS agencies for review, appeal, and correction if warranted. The federally mandated MEQC Pilot review is currently underway and is expected to be completed in March 2023, at which time regular case evaluations will begin. ODM promptly notifies the CDJFS agencies of errors, and the root cause analysis and corrective action plans are requested. The communication between MEQC and our ODM partners, ensures potential vulnerabilities in the eligibility determination process are being addressed promptly. In addition to the offered trainings and MEQC monitoring efforts, ODM has made significant improvements to the ex parte renewal process during SFY22, to increase the number of Medicaid renewals that occur in the system without county caseworker intervention. These ex parte updates are expected to greatly assist the CDJFS agencies and decrease the burden of processing cases, while also improving accuracy. The MEQC unit has been reviewing a sample of ex parte cases each month to ensure system modifications were effective. System improvements, CDJFS training, and monitoring will be ongoing as the Medicaid program continues to change over time. System Weaknesses Ohio Benefits generates alerts to notify CDJFS caseworkers of actions to be taken on a Medicaid or CHIP case. These alerts may include potential dates of death, notifications that individuals have moved to another state, and information about changes in income. Alerts are an important feature of the Ohio Benefits system. ODM has worked with ODJFS and DAS to reduce the volume of alerts generated in an attempt to improve the usability of the information for CDJFS caseworkers. ODJFS monitors IEVS alert completion. ODM has implemented automation using bots to help work and clear certain alerts. In 2021, multiple small releases, or `sprints? were implemented as part of the plan to reduce the volume of alerts being generated. Alert reduction efforts reduced overall ~29 million backlog alerts and drove a ~22 million annual reduction in new arrival of alerts. ODM, ODJFS and DAS remain committed to improving the alert functionality. The table below shows the impact in each of the sprints during SFY22 and the beginning of SFY23. Sprint Deployment Interface Projected Backlog Reduction Actual Backlog Reduction Projected Arrival Reduction-Monthly Actual Arrival Reduction Per Month Cumulative yearly Arrival Reduction 3 7.8.21 UCB SDX/SSI 936K 936K 399K 451K 4.7M 4 7.8.21 110K 115K 1.3M R3.8 8.14.21 Healthchek, Verification, LTC, DODD, DRC Incarceration, SVES Prisoner, AVS, Buy-IN 300K 736K 66K 63K 792K 5 9.17.22 SSP Document Upload, Companion EDBC 8.3M 9M 90K 100K 1.2M 6 4.15.23 IRS TBD TBD 33K TBD TBD ODM has plans for additional improvements in 2023 to reduce the volume of alerts generated. A sprint is scheduled in April 2023, after monitoring the impact of the initial five sprints. ODM continues to work with DAS and ODJFS on correcting defects and implementing enhancements to the existing alerts. In release R4.3 (August 2022), eight defects impacting alerts were corrected and in release R4.3.1 (September 2022), two alert enhancements were implemented, along with one additional defect fix. This weakness will continue to be remediated through future system modifications. ODM will continue to work collaboratively with DAS to update Ohio Benefits to bring efficiencies in effort to improve Medicaid eligibility determination outcomes. Several releases are scheduled into 2023 to improve system functionality. ODM will continue to evaluate enhancements to assist DAS in determining if the desired outcome was achieved.

Project Legal Name: Partnership for Children and Families Audit Firm: CohnReznick LLP Period covered by the audit: July 1 2021 ? June 30, 2022 Corrective Action Plan prepared by: Name: Kristy Arey Position: Executive Director Telephone Number: 919-774-9496 The following is a recommended format to be followed by the auditee for preparing a corrective action plan: A. Current Findings on the Schedule of Findings, Questioned Costs and Recommendations 1. Finding 2022-001 a. Comments on the Finding and Each Recommendation Management understands the importance of full compliance with all regulations found in major programs. Management is aware of this finding and has procedures in place to avoid further findings. b. Action(s) Taken or Planned on the Finding Management has implemented controls to ensure that all child eligibility documents are collected, approved and maintained by the Partnership for the duration of the compliance period. In order to ensure all documentation is collected for each child we have created a checklist that team members will check off and initial when accepting applications from parents. In addition, a third party who did not collect the application will review all applicants to determine if all appropriate documentation was collected and review the application to ensure the child is eligible. Once they have completed their review they will initial and date that the application is complete and ready for placement. All completed and approved applications will be maintained by PFCF for the remainder of the compliance period. This control was adopted and implemented in fiscal year 2022.23.

Views of Responsible Officials and Planned Corrective Actions: The Department of Human Services is in agreement with the findings related to missing application/renewal forms for the 3 noted cases. Since receipt of the clarification from the state regarding Medicaid record retention, staff have been informed to retain all documents used in determining eligibility for the life of an active case. To prevent inadvertent removal of these documents, procedures have been put in place to ensure required materials are maintained during the transition of older paper case records to a paperless format within the Virginia Case Management System (VaCMS). A case purging checklist procedure was implemented in September 2020. The checklist was created to assist staff in ensuring that required documents are maintained and submitted for scanning to the electronic record. Case record materials for Medicaid began being scanned into the VaCMS/DMIS system at application in 2015 so there is less of a chance that cases established after that time will be missing an application or other required documents. The case purging checklist procedure implemented in September 2020 continues to be a requirement as cases are transitioned to an electronic record in the Virginia Case Management System (VaCMS). In an effort to prevent further findings related to this issue, staff were instructed to ensure all required documents are present in the system, including an application, as part of the manual Medicaid renewal process. Since the Federal Public Health Emergency (PHE) related to COVID-19 began in March 2020 state procedures regarding the completion of Medicaid renewals and actions have been modified. To ensure Medicaid recipients did not lose or have a reduction in coverage during the PHE they were not penalized for failure to complete the Medicaid renewal process and beginning in March 2021 the state called for localities to cease processing Medicaid renewals entirely. Therefore, while staff handled the unprecedented increase in applications and cases for all benefit programs, they were not completing the Medicaid renewal process and as a result reviewed less cases for missing documents including applications during this period. As of December 2021 the state Medicaid program continues to operate under these modified procedures. In order to ensure the application review process continues staff have been advised to evaluate for required Medicaid applications when completing any case action on any benefit program (not just a Medicaid case action). Monthly supervisor monitoring will include monitoring for compliance with this procedure. In addition, for cases that are automatically renewed through the exparte process, with no intervention from staff, available state exparte reports continue to be utilized to identify cases that may not contain an application. For these cases staff will request new/renewal applications to bring the case into compliance. The monthly exparte reports contain thousands of cases so the expectation is that not all cases are able to be assessed through this process. Responsible Officials: Lisa Calloway, Chief of Eligibility Anticipated Completion Date: Due to the volume of Medicaid cases, correction of this issue will be ongoing. The above processes will be continued as necessary to correct identified deficiencies. Monitoring for compliance will be performed on an ongoing basis.

Corrective Action Plan: The Ohio Department of Job and Family Services (ODJFS) in coordination with the vendor team and Department of Administrative Services (DAS) has linked this finding to a newly identified defect in the Use Case/Rules base functionality in the Ohio Benefits (OB) system. Upon review, the logic and functionality of the TANF Data Report (TDR) is not the issue. However, the data being fed to the report is inaccurate based on this defect. ODJFS, in coordination with the vendor team, DAS, and the Ohio Department of Medicaid (ODM) will review and prioritize this defect fix as quickly as possible. Correction of the defect will include validation during User Acceptance Testing as well as post deployment validation in production. Any required clean-up for historical data will also be reviewed to determine if it is allowable/appropriate. Anticipated Completion Date for Corrective Action: June 2023 Contact Person Responsible for Corrective Action: Christina Burt, Program Administrator 2 (Bureau Chief), Ohio Department of Job and Family Services 30 East Broad Street, Columbus, Ohio 43215 Phone Number: 614-644-1621, E-Mail Address: Christina.Burt@jfs.ohio.gov

Corrective Action Plan: ? Foster Care CB-496 (quarter ending September 30, 2021) o The error on Line 10a was a result of keying errors in the worksheet which were transferred to the federal report. Line 10a was overstated by $2,183 ($1,091.50 ffp). We will make a prior period adjustment on the 3/31/23 CB-496 report to correct the error. ? The error on Line 16a was a result of keying errors in the worksheet which were transferred to the federal report. Line 16a was overstated by $63,449.75 ($31,749.88 ffp). We will make a prior period adjustment on the 3/31/23 CB-496 report to correct the error. ? A prior period amount was entered on the 9/30/21 Foster Care report in OLDC with an incorrect Funding Category. The Funding Category determines which line on the report captures the claim. The amount of $171 was claimed on Line 5 but should have been claimed on Line 6. The FFP for both lines is 50%, so there is no financial discrepancy. We will make a prior period adjustment on the 3/31/23 CB-496 report to correct the error. ? WIOA Cluster ETA-9130 (Statewide Rapid Response for quarter ending March 31, 2022): o The error on Line 10g was a result of a keying error. This error was corrected on the June 2022 Statewide Rapid Response ETA 9130 report. The unit supervisors will continue to review the supporting documentation of the analyst completing the report and check for keying errors before the report is submitted for review by the section chief. Anticipated Completion Date for Corrective Action ? CB-496 adjustments ? March 2023 ? WIOA error - Completed Contact Person Responsible for Corrective Action: Nahshon Moore, Financial Manager, Ohio Department of Job and Family Services 30 East Broad St., 37th floor, Columbus, Ohio 43215 Phone Number: 614-728-2898, E-Mail Address: Nahshon.Moore@jfs.ohio.gov

Corrective Action Plan: 1. For one of 60 (1.7%) regular Unemployment benefit payments selected for testing, the claimant was paid FPUC benefits of $300 a week for several weeks of benefits which were already paid in state fiscal year 2021. As a result, we will question all duplicate FPUC payments made to this claimant during the audit period, totaling $4,800. a. A defect has been documented and an application development project will be created to remedy the concern. It will be prioritized amongst all of the other efforts currently in progress or planned for OJI. Timelines associated to the remediation is currently unknown. We currently don?t understand the root cause problem and what it will take to resolve it. 2. For eight of nine (88.9%) regular Unemployment benefit claims identified in an OJI system data match as potentially exceeding the maximum allowable amount per week, the claimants were paid $300 in FPUC benefits twice during the same benefit week. As a result, we will question costs for all FPUC payments over the allowable amount to these claimants during the audit period, totaling $17,640. a. A defect has been documented and an application development project will be created to remedy the concern. It will be prioritized amongst all of the other efforts currently in progress or planned for OJI. Timelines associated to the remediation is currently unknown. We currently don?t understand the root cause problem and what it will take to resolve it. 3. Two of two (100%) PUA claims identified in a uFACTS system data match exceeded the maximum allowable number of weeks (79): one by four weeks and the other by two weeks. As a result, we will question the PUA payments exceeding the maximum allowable number of weeks, totaling $1,656. a. A process adjustment has been made to ensure that when adjusting claim for proper payment, that we overpay the appropriate weeks as well. In some cases, that didn?t take place. This was a problem that was quickly identified, and a new process was created to deter this from happening again. We missed the correction on claim, and we have adjusted it. From a system perspective, if previous weeks are subsequently reversed back to paid, causing weeks to be over 79, a process will be identified to potentially mitigate the adjustment. 4. For eight of 60 (13.3%) PUA / FPUC payments selected for testing, the claimant was not eligible to receive benefits for the weeks claimed, was overpaid, or was underpaid, as follows: a. The finding for overpaid or underpaid claims was due to the tsunami of claims/workload the agency faced during the Pandemic as well as unknowledgeable new hires brought on to assist with the massive workload. At this time initial benefits adjudication is timely in its workload however we are still facing a high backlog of cases which have alleged fraud. Benefits adjudication will process claims after a thorough fraud review has been completed. Due to the backlog all of these cases will be late and have a possible under or overpayment. The benefits adjudication team will have any cases/determinations made within 21 days of receipt from BPC fraud dept. Anticipated Completion Date for Corrective Action: June 2024 Contact Person Responsible for Corrective Action: Valerie Shuster, Field Operations District Coordinator, Ohio Department of Job and Family Services 209 West 4th Street, Lorain, OH 44052 Phone Number: 440-244-7802, E-Mail Address: Valerie.Shuster@jfs.ohio.gov

Corrective Action Plan: The following actions will be taken: ? Work with the Ohio Department of Rehabilitation and Correction to obtain more accurate incarceration dates. Currently we are not receiving the dates the claimant is incarcerated in a facility. We are currently receiving their expected release date which does not meet the needs of the office. ? We do not believe there is a need to work with the Department of Health as there has been no discrepancy with the accuracy of the data provided. ? We will create a process to create a weekly review file and save those results for review and evaluation purposes for both death and incarceration records. ? We will create a procedure to investigate the results of the death and incarceration files consistent with our existing procedures to investigate similar situations. Anticipated Completion Date for Corrective Action: January 2024 Contact Person Responsible for Corrective Action: Carl Prideau, Section Chief-BPC, Ohio Department of Job and Family Services 30 East Broad Street, 38th floor, Columbus OH 43215 Phone Number: 614-644-5164, E-Mail Address: Carl.Prideau@jfs.ohio.gov

Corrective Action Plan: ? Office of Unemployment Insurance Operations (OUIO) will develop a schedule of cross matches to ensure the matches are being performed timely and as intended. If the information necessary to complete the cross-matches is obtained from an outside party, the Department will work with the entity to ensure the information is obtained timely. Additionally, the Department will continue to prioritize issues based on the aging of issues created by the cross-matches, monitor the issue backlog, ensure issues are being addressed timely, and the Notices of Determination are issued in a timely manner. ? OUIO will develop quality reviews focusing on the timing of the fact-finding questionnaires generated by the OJI and/or uFACTS systems once an issue has been created. ? OUIO will develop periodic management reviews over the certification of OJI and uFACTS overpayments to the Ohio Attorney General and subsequent collections. ? OUIO will develop system enhancements within OJI to ensure the monetary fraud overpayment penalty amounts are being applied to each applicable overpayment. Management should monitor the system enhancements to ensure they are being captured, properly applied, and appropriately collected. Anticipated Completion Date for Corrective Action: June 2024 Contact Person Responsible for Corrective Action: Carl Prideau, Section Chief-BPC, Ohio Department of Job and Family Services 30 East Broad Street, 38th floor, Columbus OH 43215 Phone Number: 614-644-5164, E-Mail Address: Carl.Prideau@jfs.ohio.gov

Corrective Action Plan: The Office of Community Development (OCD) is in the process of implementing a new timeline for ESGP funding to be compliant with federal regulations. The following steps of the corrective action have already been completed. 1. Since the OHTF account balance is now in the position to allow OCD to commit funds earlier within the program year, the HCRP timelines can be adjusted to meet HUD?s 60-day requirement. 2. OCD must handle this change cautiously as HCRP serves Ohio?s most vulnerable population, the homeless, and our most vulnerable grantees, non-profit organizations. Interruptions in services and operating support would be detrimental to both. Both are dependent upon the continuity of OCD?s programs? timing. Therefore, a series of meetings have been scheduled with grantees to strategize about the most seamless way to implement this change with the least disruption in services and support. The first meeting was held on February 24, 2023. The second one is scheduled for March 31, 2023. 3. OCD will discuss this topic with the Supportive Housing Advisory Group in the fall of 2023. This meeting is part of Ohio?s Consolidated Planning Process to gather stakeholders input to create Ohio?s Annual Action Plan to submit to HUD for approval. A public comment period is built into the process as well, so additional feedback may be gathered to consider. Finally, the new timeline will be approved by HUD within the Annual Action Plan. 4. While OCD is having meetings and gathering feedback, staff will be working on the internal impact this change may create. System requirement changes and delays they may cause; report deadline shifts and alignment with other homeless reporting systems; and staff workload balance in coordination with other programs are a few we are aware of at this point. Also, the program planning begins far in advance to the grantee application submission. Therefore, timelines get set and approved early on. There are times when our allocation amounts are released from HUD late which delays our application process. There are times when HUD issues our grant agreement late which will require OCD to hold all grantees? agreements until ours is executed. Either one will cause a disruption in services after the program period is changed to an earlier start date. All these factors must be carefully considered prior to making this transition, so that surprises and delays are kept to a minimum. In some cases, a back-up plan will be required. Anticipated Completion Date for Corrective Action: September 2024 Contact Person Responsible for Corrective Action: Talia D. Givens-Gore, Program Operations Manager, Ohio Department of Development 77 South High Street, 26th floor, Columbus, Ohio 43215 Phone Number: 614-728-8140, E-Mail Address: Talia.Givens-Gore@development.ohio.gov

2022-001 Sliding Fee Discount Determination Name of Contact Person: Brent Copen, CFO Corrective Action: LifeLong Medical Care will: - Immediately retrain staff involved in Sliding Fee Discount Program (SFDP) on program requirements and proper implementation of sliding fee determination and billing. - Train all new staff at new hire orientations, conduct an internal audit, and retrain current staff based on outcome as needed. - Perform periodic audits of sliding fee transactions Proposed Completion Date: January 31, 2023

Corrective Action Plan: The Ohio Department of Job and Family Services (ODJFS), in coordination with the Ohio Department of Medicaid (ODM), the Department of Administrative Services (DAS), and our vendor teams will continue to work to address system design weaknesses by identifying and prioritizing system changes and updates that impact eligibility determinations and benefit amounts as well as alert volume and processing improvements. Weekly problem review meetings will continue to be held to identify reported system issues and track any needed updates through the normal prioritization and slotting process. These changes will be delivered according to the agreed upon release cadence based on business priority and impact. Upon delivery of such system changes, the team will monitor production to determine if the desired outcome was achieved. ODM and ODJFS continue to meet to analyze the alerts in Ohio Benefits and the group presents recommendations to our vendor team for overall system alert improvements; these recommendations were prioritized and corrected in our normal release cadence through calendar year 2022, with the most recent release occurring in February 2022. The next alert centered release is scheduled for April 2023. Comprehensive alert reduction efforts thus far have reduced the overall ~29 million backlog alerts and drove a ~22 million annual reduction in new arrival of alerts. A system release specific to IEVSs enhancements is planned for R4.6.1 (April 2023) which will streamline the process for county staff to process IEVS matches from the IRS Unearned Income interface. There will be both E-Verify enhancements and a change in the match logic which will result in a reduction in the volume of IRS records that are flagged as IEVS matches. Caseworker time spent on processing IRS IEVS matches is expected to reduce; remaining time spent on IRS IEVS matches is expected to have more value by allowing caseworkers to focus time on matches with an eligibility impact or potential for benefit recovery. Periodic and timely review of IEVS will be completed as follows: ? Each state Fraud Control Specialist is assigned designated county agencies to provide technical assistance and training, as well as to monitor certain reports to ensure compliance with state and federal regulations. The counties will be monitored monthly and those not showing improvement will be offered training and technical assistance as appropriate. When a Fraud Control Specialist notices a county agency falling short of a required threshold, contact is made with county officials and the offer of assistance will be made. Once the number of alerts becomes manageable by the county agency, a Continuous Improvement Plan (CIP) may be required of the county agency if the issue continues over a four-month period of continuous contact and assistance. This type of CIP may be initiated outside the scope of Fraud Control Triad Review. ? The Fraud Control Section will conduct follow-up on Continuous Improvement Plans (CIPs) as part of the Triad Review process. When the county agency responds with a CIP, it is reviewed for clarity, action, and desired outcomes. Once approved, the Fraud Control Section will issue a closure letter for the Triad Review; however, a CIP may remain open for a longer period of time if warranted. We are in the process of creating a procedure and a closure letter for CIPs alone. This procedure will be implemented by June 30, 2023. ? Supervisory Reviews are monitored as part of the Triad Review process. Currently, the question is posed to the county supervisor about conducting random supervisory reviews. We are in the process of creating a procedure within the Triad Review process to be provided a list of IEVS matches that were reviewed by the supervisor. This procedure will be communicated statewide through the Fraud Control Training Program and enforced and verified during the Triad Review process.To continue to support the county caseworker staff, the Ohio Benefits Program provides training materials and promotes ongoing learning about related business processes without requiring in-person training. For each major system release or system enhancement that impacts the end user, updated training materials are produced and disseminated. These materials may take the form of job aids that are posted to the project website, train-the-trainer sessions, and video conferences where system users can ask live questions about the system. In addition to system support and training, the Ohio Department of Job and Family Services (ODJFS) in coordination with the Ohio Department of Medicaid (ODM) continue to provide the following methods by which training and system guidance is provided to CDJFS employees: 1. New Worker Training (NWT): A 12-week, comprehensive Policy and Systems training for new users (or refresher training for existing users) in the Ohio Benefits Worker Portal (OBWP) has been developed. The courses cover Policy and Systems overview, TANF, SNAP, Cash and Case Maintenance, along with the primary Medicaid programs (MAGI & ABD). The training is comprised of multiple, self-guided, Web Based Training (WBT) modules and virtual Instructor Led Training (vILT) sessions that provides `hands on? instruction. 2. Monthly Statewide County Conference: Monthly statewide webinars to cover general OFA updates for SNAP and Cash. These meetings include OFA?s Policy and TA staff, Outcomes and Analysis, Data Reporting, Quality Control, Automated Systems Training and the OB-IMS Help Desk. All areas share information on both refresher topics and emerging policy as well as systems issues where additional training is needed. The meetings are facilitated by the Program & Policy Services area within the Policy section of OFA and provides input on issues needing additional training and guidance. AST provides copies of job aids and other training documents during these support meetings. Recording of statewide training sessions are made available for counties to access on demand. 3. Operational Support Webinars: Bi-weekly webinars are delivered jointly by ODJFS and ODM, to counties for systems-based information and instruction on emerging topics and training related issues. Topics for the webinar are identified through a coordinated effort with the OB-IMS Help Desk, the weekly PBI/Defect Closure meetings and On Demand System Inquiries (received via email), to review any issues or concerns discovered by the Help Desk during the previous week. Counties are also able to submit questions and request topics in advance of the webinars to be reviewed and covered as part of the webinar agenda. 4. Ohio Benefits System Release Webinars: These are delivered jointly by ODJFS and ODM to inform counties about updates and enhancements made in each Ohio Benefits system release. During these webinars, counties are provided information regarding proper systems operation based on the items included in the release and target items that no longer require a workaround by the county worker. 5. Job Aids Available on the Innerweb: Automated Systems Training (AST) routinely provides systems-related job aids for county use that target specific topics and pain points for the counties. On the average, one to two new job aids are either created or updated each week and the Innerweb training pages are routinely referenced during New Worker Training, Operational Support, and Ohio Benefits system release webinars. 6. Quarterly Regional County Operational Support Meetings: Both the Automated Systems Training (AST) and the OB-IMS Help Desk participate in these regionally based, quarterly meetings, along with ODM Operations, Systems, and Policy staff. They provide guidance and system instruction on emerging systems issues and/or where additional training is needed. The meetings are facilitated by the Program & Policy Services area within the Policy section of OFA and provides input on issues needing additional training and guidance. AST provides copies of job aids and other training documents during these support meetings. 7. Quarterly Work Activity Round Table Meetings: Automated Systems Training (AST) and the OB-IMS Help Desk participate in these regionally based, quarterly meetings to provide guidance and system instruction related to TANF Work Activities. The meetings are facilitated by the Outcomes & Analysis area within the Policy section of OFA and provides input on issues needing additional training and guidance. 8. On Demand Systems Inquiries: Automated Systems Training (AST) maintains an email box where counties can submit inquiries about correct data entry and system functionality within the OBWP. Timely responses are provided to these inquiries frequently providing Help Desk confirmed instructions in a timely manner. Many of these inquiries are shared at the meetings and communications channels listed above. 9. System Support for Targeted Policy Training: Automated Systems Training (AST) provides system related content to support targeted Policy training topics to provide a holistic view of the application of policies within OBWP. The targeted training is delivered via virtual meetings and/or WBT modules. Some topic examples include `Expedited SNAP,? `Delayed Processing? and `Early Denial.? Recording of statewide trainings are made available for counties to access later.Interagency Agreement An Interagency Agreement is entered into by the Ohio Department of Job and Family Services (ODJFS) and the Ohio Department of Administrative Services (DAS). This Agreement is entered into for the purpose of setting forth the roles and responsibilities, budget methodology and payment terms, data sharing restrictions, security protocols, and compliance requirements for the Ohio Benefits Program. DAS and ODJFS has completed extensive policy, program, and legal reviews and the final Agreement is in circulation to secure DAS and ODJFS Director?s signatures.

Corrective Action Plan: Each state Fraud Control Specialist is assigned designated county agencies to provide technical assistance and training, as well as to monitor certain reports to ensure compliance with state and federal regulations. The counties will be monitored monthly and those not showing improvement will be offered training and technical assistance as appropriate. When a Fraud Control Specialist notices a county agency falling short of a required threshold, contact is made with county officials and the offer of assistance will be made. Once the number of alerts becomes manageable by the county agency, a Continuous Improvement Plan (CIP) may be required of the county agency if the issue continues over a four-month period of continuous contact and assistance. This type of CIP may be initiated outside the scope of Fraud Control Triad Review. The Fraud Control Section will conduct follow-up on CIPs as part of the Triad Review process. When the county agency responds with a CIP, it is reviewed for clarity, action, and desired outcomes. Once approved, the Fraud Control Section will issue a closure letter for the Triad Review; however, a CIP may remain open for a longer period of time if warranted. We are in the process of creating a procedure and a closure letter for CIPs alone. This procedure will be implemented by June 30, 2023. Supervisory Reviews are monitored as part of the Triad Review process. Currently, the question is posed to the county supervisor about conducting random supervisory reviews. We are in the process of creating a procedure within the Triad Review process to be provided a list of IEVS matches that were reviewed by the supervisor. This procedure will be communicated statewide through the Fraud Control Training Program and enforced and verified during the Triad Review process. Anticipated Completion Date for Corrective Action: ? The Ohio Benefits system improvement work and IEVS alert training ? Completed and continuing in fiscal year 2023 ? IEVS enhancement system release - April 2023 ? Triad Review closure letter procedures ? June 2023 Contact Person Responsible for Corrective Action Chris Dickens, Fraud Control Section Chief, Ohio Department of Job and Family Services 30 E. Broad Street, 37th Floor, Columbus, OH 43215 Phone Number: 614-387-5499, E-Mail Address: Chris.Dickens@jfs.ohio.gov