Corrective Action Plans

Views of Responsible Officials and Planned Corrective Actions: Anita Moreau has implemented policies to ensure all information is captured on the Meal Benefit Income Eligibility Forms. These policies have been provided to all centers. On February 3, 2023, TDA reviewed the Corrective Action Plan provided by Anita Moreau and has concluded its review.

In October of 2022 there was no waiting list in the Housing Management Software, there was not a handwritten waitlist that could be located. Staff entered all applications that were located into the software by date and time and with preferences that are in the out-of-date Admissions and Occupancy Policy and Administrative Plan. Documentation was submitted to the San Antonio Field Office in September of 2023 to show the waitlist and the families that have been selected in order of the waitlist or removed at the request of the family.

In November of 2022 the Housing Authority started using a Rent Reasonableness form that compares the unit in question to two other units of the same type with similar amenities and age. If the unit in question is a Tax Credit property the Housing Authority uses the unit?s most currently rented, listed on the back of The Request for Tenancy Approval form, provided by the landlord to ensure the rent paid for assisted units is not more than unassisted units.

2022-002 Enrollment Reporting to NSLDS Planned Corrective Action: Admissions department and registrar department will provide a list of all non-true freshman to the financial aid department. The financial aid department will run NSLDS reports to determine if students have utilized financial aid in the past. Each student that has received aid in the past will be reported to NSLDS whether they utilize any federal aid at ABU or not. Person Responsible for Corrective Action Plan: Laurel Bartlett- Admissions Director, John Rocha- Financial Aid Director, Janie Taylor- VP of Academic Affairs / Registrar Anticipated Date of Completion: Spring 2023

Identifying Number: 2022-001 Finding: Three student?s enrollment changes were not reported to the National Student Loan Data System (NSLDS) within the 60 day timeframe for the School?s reporting on the roster file submissions. Corrective Actions Taken or Planned: MHSL has hired an outside consultant through Agilyx to create a new enrollment report that will more accurately track and report the enrollment statuses for all students. MHSL will be using this report starting Fall 2022. The Director of Financial Aid now completes enrollment reporting. For each report, students will be selected by Director at random to manually review. Assistant Director of Financial Aid will also select a group at random to review for accuracy. This way both the person who runs the report and a person who does not will review a random sample of students. Also, additional scheduled date for enrollment reporting have been added to the school transmission schedule including j Term and summer. This will prevent late reporting over the summer. Contact Person: Lynn LeMoine ? Dean of Students; Katie Kuehl ? Registrar; and Nick Anderson ? Financial Aid Director. Anticipated Completion Date: Fall 2022

LAKE LAND COLLEGE COMMUNITY COLLEGE DISTRICT NO. 517 MATTOON, ILLINOIS CORRECTIVE ACTION PLAN FOR CURRENT-YEAR AUDIT FINDINGS FOR THE YEAR ENDED JUNE 30, 2022 CORRECTIVE ACTION PLAN Finding No. 2022-001 ? Internal Controls over Student Financial Assistance Special Test and Provisions Condition: A. During compliance testing of ?Special Tests and Provisions ? Return of Funds? we noted that for eight (8) out of twenty five (25) students tested the College utilized the incorrect semester end date for the Spring 2022 semester. B. During the compliance testing of ?Special Tests and Provisions ? Eligibility? we noted that one (1) student out of forty (40) students tested the College utilized the 2020-2021 Pell payment schedule versus the 2021-2022 Pell payment schedule. Plan: A. The College will develop internal controls to ensure that the correct semester dates are utilized for the return of funds calculation to determine the amount of the Title IV assistance earned by the student. B. The College will establish procedures to ensure their software is utilizing the current Pell payment schedule. Anticipated Date of Completion: Immediately upon learning of the deficiency. Contact Person Responsible for Corrective Action: Jennifer Hedges, Director of Financial Aid and Veteran Services 98

Corrective Action plan to the College will implement a process to review, update, and verify student eligibility requirements. The following is the process to review, update and verify student eligibility requirements: 1. Financial Aid Rep assist student with completing FAFSA 2. Financial Aid Rep pulls NSLDS to make sure loan amounts and grants are not used up. 3. NSLDS print out is uploaded to campus IVY 4. Once the FAFSA summary is in Campus IVY and the funding is created, the usage amount is shown. 5. Once loan and Pell amounts are sent to COD and approved 6. Campus IVY will send a batch with student loan and Pell amounts to the school to be reviewed. 7. The student accounts office will then review the student loan and Pell amount against the student schedule. 8. Based on course load/scheduled credits the student account will update the amounts on the batch 9. Student accounts will ok the batch once corrections to eligibility are made and send back to Ivy for payment.

Corrective Action Plan Marygrove Nonprofit Housing Corp II, dba McGivney Bethune Apartments Project No. 044-EE011 Year Ended December 31, 2022 September 28, 2023 FEDERAL AWARD FINDINGS AND QUESTIONED COSTS 2022-001 ? Eligibility - Tenant File Documentation Finding Type. Material noncompliance; Material weakness in internal controls over compliance (Eligibility) Federal programs U.S. Department of Housing and Urban Development Supportive Housing for the Elderly (CFDA# 14.157) Condition. Out of a sample of 8 tenant files, it was noted: 1. One out of eight instances where a tenant EIV was not run within 90 days of move in, however third party support was received upon move in; 2. One out of eight instances where a tenant's saving account was not verified by a third party; 3.Two out of eight instances where a tenant file was missing completely or missing substantial documentation used to support the tenant assistance payment. Further, we noted that a tenant waitlist was not maintained during the year. Effect. As a result of this condition, certain tenant files did not contain all required supporting documentation. Plan. Management agrees with finding 2022-001. All files are to be inspected in the current fiscal year to ensure compliance with HUD regulations. File maintenance will be competed following each move in and annual recertification. In addition to one-on-one training, the housing administrator has signed up for additional training including a WebEx on annual recertification and a basic EIV course. Additional training sessions are forthcoming. Contact Person Responsible for This Corrective Action: Laura Maisevich, Senior Housing Manager Anticipated completion date: December 31, 2023

Adults? & Children?s Alliance is submitting the following Corrective Action Plan for Significant Deficiency found during audit for FY22 (10/1/2021-09/30/2022) Found in Section II ? Financial Statements Findings 2022-001 ? Lack of Segregation of Accounting Duties (Repeat finding 2021-001) Criteria: Proper internal control structure includes review of journal entries, bank reconciliations and the schedule of expenditures of federal awards, as well as an adequate system for recording and processing entries to the financial statements, in accordance with generally accepted accounting principles. Condition: The limited number of staff in the accounting department results in certain functions that are not properly segregated which normally would enhance internal control, including the lack of review of journal entries, bank reconciliations, and the schedule of expenditures of federal awards. Cause: The internal control structure does not provide an appropriate segregation of duties for the financial reporting process. Effect: Although this condition is not unusual for an entity the size of the Organization, the condition may affect the Organization's ability to initiate, record, process, and report financial data consistent with the assertions of management in the financial statements. Recommendation: It is the responsibility of management and those charged with governance to determine whether to accept the risk associated with this condition because of cost or other conditions. We recommend the Organization evaluate current procedures and segregate where possible and implement compensating controls.Responsible Official?s Response: Management will evaluate current procedures and segregate where possible and implement compensating/alternative controls appropriately according to staffing and budget. Corrective Actions: ACA will continue to work with Bottom Line Accounting Services when finances do not align Lisa Dunlap, the Executive Director, works with Bottom Line Accounting Services to find resolution. Lisa Dunlap, Sandra Lee the CACFP Director and Denise Hess additional staff will work together for checks and balances for payroll, Quick Books for accounts payable/receivables, journal entries, banking, and CACFP program as well as any other financial activity. Quick books ? data entry Accounts payable Accounts receivable Roles and Responsibilities for Bottom Line Accounting Services Outline best practices for QBO JE?s, Deposits, or other entries for clear tracking. ? Review client posted payroll tax postings. ? Review organizations key transactions and financial statements for previous months ? Create and recommend posting monthly accounting allocations and/or adjustments. ? Assist staff with monthly accounting close and recommend appropriate accounting systems to ? be set up. Review reconciled monthly banking and investment accounts and maintain required ? supporting schedules. Provide QuickBooks online accounting support and QB training requested. ? Perform quarterly reconciliations of designated general ledger accounts. ? Assist clients as requested with preparations of annual audit. ? Recommend modifications to chart of account structure from information provided by client ? to enhance retrieval of necessary financial information. Completion time: On going. Contact person: Lisa Dunlap Lisa.dunlap@acainc.org 651-481-9320 2022-002 - Reporting Information on the SEFA Criteria: 2 CFR Part 200.510(b) states that the auditee must prepare a schedule of expenditures of federal awards for the period covered by the auditee's financial statements which must include the total federal awardsexpended. Federal program and award identification must include, as applicable, the Assistance Listing Number and title, the federal award identification number and year, the name of the federal agency, and the name of the pass-through entity, if any. This information enables the auditee to reconcile amounts presented in the financial statements to related amounts in the schedule of expenditures of federal awards. Condition: Management did not have a process in place to prepare a complete schedule of expenditures of federal awards, including identifying COVID-19 funding. The audit firm cannot serve as a compensating control. Cause: Proper processes were not in place for management to prepare the schedule of expenditures of federal awards. Potential Effect: As a result of this condition, there is a higher risk that the schedule of expenditures of federal awards could be incomplete or contain errors that are not detected. Recommendation: The Organization should review its policies and procedures to ensure all expenditures charged to federal grants are properly identified, recorded in the general ledger, and reflected on the schedule of expenditures of federal awards. Responsible Official's Response: Management is now aware that Emergency/Covid funds should have been separated by line when reporting even though from the same source, grant and pass-through grant number. Corrective Actions: SEFA The Schedule of Federal Awards report is completed by Lisa Dunlap with review from Bottom Line Accounting Services. Funding strands will be broken out and identified accordingly by funding type, grant number, pass through grant number as well as identified in general ledger with same information. Completion time: On going. Contact person: Lisa Dunlap Lisa.dunlap@acainc.org 651-481-93 202022-003 ? Meal Counts Federal Program: Assistance listing number 10.558, Child and Adult Care Food Program ? United States Department of Agriculture Compliance Requirement: Eligibility Criteria: A properly designed system of internal control over compliance with the requirements of federal programs allows entities to meet those requirements set forth by the federal government. Under the Child and Adult Care Food Program, the Organization is required to monitor eligibility of meals being reimbursed to providers. Condition: 1 of the 40 providers tested for meal counts had discrepancies. The provider's reimbursement improperly included 2 additional breakfast meal counts. Cause: The Organization noted a deduction of a breakfast count should have been made, however rather than deducting another breakfast count was added resulting in 2 additional breakfast meal counts. Questioned Costs: The results of this noncompliance did not result in any questions costs. Potential Effect: As a result of this condition, there is a higher risk that the provider meal counts are inaccurately reimbursed. Recommendation: The Organization should review its policies and procedures to ensure all provider meals charged to federal grants are properly reflected in the reimbursement request. Responsible Official's Response: This was a human error; management will continue to follow policy and procedures in place to ensure all meals charged to the federal grant are properly reflected in the reimbursement request. Corrective Actions: The 1/40 provider meal count finding was human error. Management will continue to follow the policies and procedures set in place to ensure all meals charged to federal grants are properly reflected in the reimbursement request. Completion time: On going. Contact person: Lisa Dunlap Lisa.dunlap@acainc.org 651-481-9320

Finding #2022-001 ? ALN 84.010, Title ? ISAS; L. Financial Reporting Corrective Action Planned: The District will implement controls to ensure reimbursement requests include proper expenditures. Anticipated Completion Date: November 2022

1. Finding 2022-1 a. Comments on the Finding and Each Recommendation Management agrees with the finding. b. Action(s) Taken or Planned on the Finding In 2022 we hired additional oversight staff at the corporate level and changed the procedure for reviewing and approving annual certifications as well as monitoring EIV reporting. We have implanted new EIV procedures to ensure timely EIV reporting. All HUD staff has been trained on the new procedures.

Finding 2022-002 ? Tenant File Documentation Maintenance Corrective Action The Authority will implement and execute strengthened controls over tenant file documentation maintenance processes and procedures. Erial Branch, Executive Director, has assumed the responsibility of executing strengthened controls over tenant file documentation maintenance as of April 30, 2023.

Management?s Response and Planned Corrective Actions: 1. The name of the contact person(s) responsible for the corrective action a. Kathleen Broadhurst, Sr Director of Finance/ShelterCare 2. The corrective action planned: a. Pinehurst Management overseeing property through 4/30/23. A new management agent will be identified to take over the property after 4/30/23. b. Ensure that the new managing agent employs an onsite manager with HUD compliance experience. c. Currently prioritizing recertifications by oldest first. d. Monthly review of TRACS reports to ensure recertifications are being completed in a timely manner. 3. The anticipated completion date: a. New processes will be implemented by 5/1/2023.

2022-003 Incorrect Direct Loans Disbursement Amount - Student Financial Aid Cluster Assistance Listing Number 84.007, 84.033, 84.063, 84.268, 84.038 Grant Period - Year Ended June 30, 2022 Condition Found During our student file testing we noted four students out of forty were not disbursed the correct Direct Loans award. Based on the student?s enrollment status and need, the College over awarded Direct Loans to the students by $2,993. We consider this to be a significant deficiency relating to the Eligibility Compliance Requirement. Corrective Action Plan Due to the institutional policy, we have updated our process to check and recalculate all loans for the current semester in the following semester by the census date. Responsible Person for Corrective Action Plan Jeremy Hurse ? Director of Student Financial Services Deborah Beck ? Associate Director of Student Financial Services Implementation Date of Corrective Action Plan 01/16/2023

2022-002: Missing Exit Counseling Documentation - Student Financial Aid Cluster - Assistance Listing #s 84.033, 84.007, 84.063, 84.268, 84.038 - Grant Period - Year Ended June 30, 2022 Condition Found During our student file testing, we noted three students out of forty did not have documentation in their file that exit counseling was sent thirty days after the student withdrew from the College. We consider the missing exit counseling to be an instance of non-compliance with the Eligibility Compliance Requirement. Corrective Action Plan We have updated our process to check for any students who have withdrawn from the institution. After speaking with the registrar?s office, we are creating a report that will provide us with the withdrawal date so we may begin notifying students of their requirement for exit counseling. Responsible Person for Corrective Action Plan Jeremy Hurse ? Director of Student Financial Services Deborah Beck ? Associate Director of Student Financial Services Implementation Date of Corrective Action Plan 01/16/2023

Finding No. 2022-002: Reporting (Significant Deficiency) Action Management implemented procedures for review of the expenses to be reported for infection control. For the fiscal year ended June 30, 2022, a review was conducted but only against the General Ledger report for the reporting period. Rather than relying solely on the General Ledger report, each invoice listed on the report will be pulled from Accounts Payable and reviewed both by the Controller and CFO to ensure the appropriateness of the expense to be reported on the PRF report prior to submission.

FINDING 2022-011 Contact Person Responsible for Corrective Action: Whitney Dixon, Treasurer, Samantha Todd, Grants Manager, and Christopher Dixon, Director of Nutrition Contact Phone Number: 574-533-8631 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Eligibility ? Real Time Reports During the October Pupil Enrollment process, the student roster will be pulled from Data Exchange (DEX). The student data will be pulled from the food service software. This data will be compared and digitally signed by building principals. Student socioeconomic status will be reviewed and verified by the food service manager or designee. The reviewed and verified PE report will be digitally reviewed and signed by the CFO and Superintendent. Eligibility ? Direct Certifications/Income Applications Monthly the grants manager completes the DC download and imports the data into the school nutrition software. Once completed, the Director of School Nutrition verifies the information and signs the download document that is saved on the districts network. This control was implemented in March 2023. Participation of Private School Children Participation is determined by a process that includes standardized test scores and teacher input to determine what services are required. Test scores are provided at the beginning of the year, middle of the year, and end of the year to monitor and adjust accordingly the services that are required. Assistant Superintendent, Tracey Noe will review and sign the participation list and approve services at the nonpublic schools. This process will be implemented during the 2023-24 grant cycle. Anticipated Completion Date: October 2023, March 2023 and July 2023, respectively.

CORRECTIVE ACTION PLAN Federal Award Findings Finding No. 2022-001: Significant Deficiencv over Internal Controls for Eligibilitv Condition For 5 out of 11 selections, no support was provided by management to document independent review and verification of income amounts reported by the selected participants. Recommendation It was recommended that UPO: (1) Implement procedures and documents needed for documentation and retention of the review and approval of eligibility criteria, and (2) provide training about the procedures related to the documentation of eligibility evaluation. Management Action UPO Management acknowledges the audit finding and will ensure that staff follows the internal control activities designed to adhere to HHS guidelines as issued in the Federal Register. UPO will institute continuous training and increased monitoring of compliance with regards to the review and retention of income eligibility documentation presented by the participants. Anticipated Completion Date: September 30, 2023 If there are any questions regarding this plan, please call Andrew Harris, VP and Chief Financial Officer (CFO), at 202-238-4648. Sincerely, Andrea Thomas President and CEO

ALVERNO APARTMENTS, INC. 98 Hawthorne Road Pittsburgh, PA 15209 CORRECTIVE ACTION PLAN March 24, 2023 United States Department of Housing and Urban Development Alverno Apartment, Inc., respectfully submits the following corrective action plan for the year ended December 31, 2022. Name and address of independent public accounting firm: Maher Duessel, CPA's 503 Martindale Street, Suite 600 Pittsburgh, PA 15212 Audit period: January 1, 2022 - December 31, 2022 The finding from the December 31, 2022 schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. FINDINGS?FINANCIAL STATEMENT AUDIT None FINDINGS? FEDERAL AWARD PROGRAMS AUDITS Finding 2022-001 Department of Housing and Urban Development HUD Supportive Housing for the Elderly (Section 202) ALN Number 14.157 Recommendation: The Property should have internal controls in place to review Form HUD-50059 to ensure all documentation used to calculate the tenant rent and assistance payment is supported and properly calculated. Action taken: The Property has a Recertification Checklist. The managers have been reminded to utilize the checklist to its fullest when recertification. Also, managers have been reminded to double check all calculations after submitting to the servicer, Paulhus and Associates. If the Department of Housing and Urban Development has questions regarding this plan, please call Dan Barbusio at 412-646-5193.

The County will continue to monitor supervisory processes. Additionally, the County will perform preliminary testing to ensure process is operating effectively.

In 2023, the County will continue to monitor actions implemented at DSS after the third quarter of 2022. Additionally, the County will perform preliminary testing to ensure process is operating effectively.

The Organization is aware of the eligibility finding and is working to correct all known errors and develop a system to prevent future occurrences.

2022 ? 005 Allowable Activities and Costs/Cost Principals (Significant Deficiency and Noncompliance) Management Response: Management agrees with the finding. The grants distributed by the Economic Development Department were a lifeline to small businesses that were just holding on. While a strong program was set up in a very short timeframe some reviews and follow-up were not completed. Additionally, the Family & Community Services Department will ensure timesheets are signed timely. Additionally, the department will work with the Grants Section to ensure timesheets, Kronos and Peoplesoft agree. Timeline and Responsible Position: June 2023 ? Department Directors, Economic Development, Family & Community Services and Transit

The Controller and Compliance Officers are working together to correct the previously filed reports to update the estimated total number of students at the institution that are eligible to receive Emergency Financial Aid Grants to Students under the CARES (a)(1) subprogram and the CRRSAA and ARP (a)(1) subprograms. Completion Date: April 2023 Contact Person: Tom Corley, Controller and Director of Fiscal Operations and Carrie Stevens, Associate Vice President of Compliance

Student Accounts Receivable, Controller?s Office, and IT are working together to develop more real-time reporting and tracking for student account refund balances to identify student accounts with refund balances that remain undistributed more than seven days after being created to prioritize those accounts for refund processing. Completion Date: June 30, 2023 Contact Person: Heather Long, Director Student Accounts