Corrective Action Plans

Corrective Action Plan for Current Year Findings Finding 2022-001: Timely Processing of Participant Applications: Department of Health and Human Services - AL #93.568 Low Income Home Energy Assistance Program #Ll-023-024, #Ll-022-024 Corrective Action: WICAA has developed a streamlined approach for assessing incoming applications, differentiating between complete and incomplete applications at the beginning of the processing cycle. This will ensure that complete applications can be promptly processed. Additionally, if a substantial number of unprocessed applications are nearing 10 days of the deadline for processing, our staff will be notified that there is a need for overtime. Overtime requirements will be assessed weekly. These modifications are anticipated to result in applications being processed within the allowable number of days. Person Responsible: The Energy Assistance Director has primary responsibility with oversight by the Executive Director. Timing for Implementation: Immediately; Carole Barr, Executive Director; Debbie Kearschner, Finance Director

The institution does not dispute this finding. This was an isolated incident and no further instances of this nature occurred. The staff member mistakenly thought that a PLUS denial from a prior academic year was for the academic year in question, thereby awarding additional Unsub for an independent student. Once the error was found, the ineligible Unsub amount was returned. Staff was provided proper training with respect to reviewing documentation to confirm accuracy of awards being packaged. This finding was reviewed with all staff members in the department to ensure compliance moving forward.

2022-002 Housing Choice Vouchers - Assistance Listing No. 14.871 - Eligibility Recommendation: The Authority should implement processes to ensure that all documentation is received and that the correct inputs are being accurately reported on the HUD-50058. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: During this time GHA's HCV program was extremely short staffed and GHA was using temporary employees to assist in program delivery. Specifically, the department suffered two staff- members deaths, one family emergency that removed dedicated staff from this task, and two resignations. GHA has hired and trained new staff to ensure that recertifications are being performed annually for all tenants as applicable. The annual recertifications will be three months ahead by the end of 2023. Name(s) of the contact person(s) responsible for corrective action: Maria Godwin Planned completion date for corrective action plan: GHA has hired and trained new staff and will conduct additional refresher training courses for existing staff focusing on accuracy. This will be complete by August 2023. GHA annual recertification's are currently being completed timely and will be three months ahead by the end of 2023.

See corrective action plan for chart/table.

Deficiencies in the TANF Eligibility Determination Process Department Name: Health and Human Services Contact Name / Telephone Number of Person Responsible for CAP: Allison Smith - (919) 527-6316 The Division of Social Services will provide targeted training and support for the two counties in error and will continue to provide support to prevent future errors from occurring. Anticipated Completion Date: June 30, 2023.

Brownsville Housing Authority respectfully submits the following corrective action plan for the year ended June 30, 2022. Name and address of independent public accounting firm: Miller & Rose, PA 1309 East Race Searcy, AR 72143 Audit period: Year ended June 30, 2022 B. FINDINGS - FINANCIAL STATEMENTS AUDIT None C. FINDINGS AND QUESTIONED COSTS-MAJOR FEDERAL AWARD PROGRAMS AUDIT DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT 2022-001 Family Eligibility Files Federal Program: Housing Choice Voucher, CFDA No. 14.871 Criteria: The Authority?s purpose for existence is providing decent, safe and affordable housing to low-income persons. As such, the Authority prepares a file for each admitted family, which contains information necessary to determine eligibility for assistance and calculations of rent assistance to be paid on the family?s behalf. HUD regulations prescribe the content of these family files. These requirements consist of the following: a. As a condition of admission or continued occupancy, require the tenant and other family members to provide necessary information, documentation, and releases for the PHA to verify income eligibility. b. For both family income examinations and reexaminations, obtain and document in the family file third party verification of: (1) reported family annual income; (2) the value of assets; (3) expenses related to deductions from annual income; and (4) other factors that affect the determination of adjusted income or income-based rent. c. Determine income eligibility and calculate the tenant's rent payment in accordance with HUD regulations. d. Select tenants from the public housing waiting list in accordance with the PHA's tenant selection policies. e. Reexamine family income and composition at least once every 12 months and adjust the tenant rent and housing assistance payment as necessary. Condition: Exceptions were noted in the review of family eligibility files. Questioned costs: None Context: Testing of nineteen family files revealed the following deficiencies: 1. Three files contained errors in the documentation of household income. 2. One file lacked social security number documentation. 3. One file lacked appropriate rent reasonableness documentation. 4. One file lacked a housing quality standard (HQS) ?passed? inspection. Recommendation: A thorough review of tenant files should be performed for the purpose of eliminating the deficiencies. Views of responsible We will comply with the auditors? recommendations. We have already begun officials and planned reviewing files and corrected the deficiencies. corrective actions:

Finding 2022-004 ? Eligibility (Significant Deficiency and Non-compliance) Corrective Action: Legal Services Alabama services provided services related to eviction proveedings and other legal services that aided in housing stability. LSA will continue its policies and procedures used for case acceptance and eligility requirements. LSA will review its policies for potential improvements. The review will be conducted by the second quarter of 2023 and any changes will be implemented by the third quarter of 2023. Contact Person: Michael Forton, Director of Advocacy; (256) 551-2671; mforton@alsp.org

Finding 2022-002 ? Case Requirements (Significant Deficiency and Non-compliance) Corrective Action: LSA will provide training to all attorneys and support staff on the policies and procedures involved, with a particular emphasis on the documentation requirements. LSA will also be conducting periodic internal reviews of case files to ensure compliance with all required documentation requirements. These reviews should include a review of financial eligibility documentation, including exceptions, if any. Finally, LSA will review and update any necessary policies and procedures as needed to ensure compliance. Updates to policies and procedires and training will becompleted by the third quarter of 2023. Contact Person: Michael Forton, Director of Advocacy; (256) 551-2671; mforton@alsp.org

Person(s) Responsible for Implementing the Corrective Action: Jenny Holden Senior Director, Grants and Community Development Corrective Action Planned: Management has implemented additional steps in the fraud prevention procedures previously implemented. Anticipated Completion Date of Corrective Action: Management has implemented the corrective actions during FY 2023.

1. Comments on Findings and Recommendation Management acknowledges failure to comply with timely EIV Master File Reports required to be completed as part of tenant move in certification process and EIV Master File process. 2. Actions Taken or Planned The Corporation will regularly monitor and reconcile the creation and retention of background checks and Income reports as part of the move in process. Additional training was provided and corrective action was taken. Management is reviewing and revising the EIV policy. 3. Status of Corrective Actions on Prior Findings The Corporation did not remediate the prior year finding for failure to comply with timely EIV Income Reports.

2022-002: Missing Entrance Counseling Documentation - Student Financial Aid Cluster - Assistance Listing #s 84.007, 84.033, 84.063, 84.268 - Grant Period - Year Ended June 30, 2022 Condition Found: During our student file testing, we noted one student out of 40 did not have documentation in their file to verify that entrance counseling occurred before the disbursement of loans. We consider the missing entrance counseling to be an instance of noncompliance with the Eligibility Compliance Requirement. Corrective Action Plan: We have updated our Loan checklist procedures to include printing the Master Promissory Note and Entrance Counseling confirmation off of the Common Origination and Disbursement website. Those print outs will be included in the student loan application packet and will be kept with the other student loan documents in the student?s file. Responsible Person for Corrective Action Plan: Eric Johnson ? Director of Financial Aid Implementation Date of Corrective Action Plan: 10/6/2022

FINDING 2022-005 ? Overaward ALN and Program Expenditures: 84.268 ($149,449) Award Number: P268K223976 Federal Award Year: July 1, 2021 to June 30, 2022 Questioned Costs: $4,237 Condition Found: There was a combined total of $4,237 of overawards given to four of the twenty-eight students in our sample. Corrective Action Plan: Management agrees with the auditors? finding and their recommendation. The School reclassified $648 of subsidized funds as unsubsidized funds in December 2022. The School returned a $3,589 of unsubsidized loan funds to the Department of Education in December 2022. The Financial Aid Director will limit the total amount of aid a student receives to his or her cost of attendance and verify the cost of attendance used on internally created spreadsheets is correct. Anticipated Completion Date: The corrective action was completed on December 13, 2022 Contact Person Valorie Quesenberry, Financial Aid Coordinator 513-763-6659

Finding 2022-005 Federal Agency Name: Department of Health and Human Services Program Name: COVID-19 Provider Relief Fund and American Rescue Plan Applicable Federal Award Number and Year ? Period 2 TIN #420953968 Federal Financial Assistance Listing #93.498 Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs/Cost Principles Finding Summary: The Organization?s Period 2 report to HHS included expenditures that were not properly supported. Responsible Individuals: Mario Van Dijk, CFO Corrective Action Plan: Management is aware of the expenditures, even though small in amount, that were not properly supported, and lost revenue calculation and some of the expenditure listings not being reviewed separate from the preparer. The organization has created processes around preparing and reviewing for items such as this. The finance team is committed to these changes to improve accuracy of our work. Anticipated Completion Date: September 28, 2023

Views of Responsible Officials: Executive management agrees with this finding, and has provided additional training to employees responsible for processing move outs.

2022-001 Contact Person Terry Hanson, Executive Director Corrective Action Plan The Authority has encountered turnover with their tenant specialists and will review, implement, and document controls that will ensure file reviews are performed in a timely manner. Planned Completion Date for CAP Immediately

OLIVET COMMUNITY SCHOOLS CORRECTIVE ACTION PLAN YEAR ENDED JUNE 30, 2022 Olivet Community Schools respectfully submits the following corrective action plan for the year ended June 30, 2022. Auditor: Maner Costerisan 2425 E. Grand River Ave., Suite 1 Lansing, Michigan 48912 Audit Period: Year ended June 30, 2022 District Contact Person: Gail Williams, Business Office Manager The findings from the June 30, 2022 schedule of findings and responses are discussed below. The findings are numbered consistently with the number assigned in the schedule. Finding ? Federal Award Findings and Question Costs Finding 2022-001 Considered a significant deficiency Recommendation: The District should submit and implement a required corrective action plan, for the 2022- 2023 school year that will adequately reduce the food service fund balance. Action to be Taken: Management agrees with the finding and we are in the process of developing a plan to spend down the food service fund balance. Anticipated Completion Date: June 30, 2023

Finding No. 2022-005 ? Eligibility (Significant Deficiency) State Department of Labor and Industrial Relations AL Number: 17.225 Program Title: Unemployment Insurance Direct Award from: UI 3644 21 55 A 15, UI 3590 20 60 A 15, UI 35700 21 55 A 15, UI 37219 22 55 A 15 Condition Per Administrative Rule 12-5-35(c), an individual may be considered available for work for any week if they make a minimum of three work search contacts each week, unless the individual is exempt from the work search requirements or be subject to a modified work search requirement consistent with and reflective of local area policies and local labor market opportunities. Findings identified three claimants who did not comply with the above requirements and were improperly paid. Current Status of Corrective Action Plan Concur. Hawaii will resend our revised written procedures regarding Administrative Rule 12 5 35(c) dated January 16, 2020, to ensure staff is aware and compliant with our Work Search requirements to ensure proper payment of benefits in the future. To address the modified work search requirements for specific islands or locality, Hawaii will provide staff with a written policy regarding this matter. Person Responsible Sheryl Maligro, UI Program Specialist Supervisor Anticipated Date of Completion June 30, 2023

CFDA Numbers: Various Program: Student Financial Assistance Cluster Corrective Action: The Registrar's Office has implemented a comparison process where graduates are verified against the National Student Clearinghouse grad only file. Implementation Date: 8/21/22 Corrective Action: The Registrar's Office has implemented a process to verify SSNs on record and correct student records. Implementation Date: 1/20/22 Corrective Action: The Registrar's Office will develop a business process to review term withdrawals for program/campus level discrepancies. Implementation Date: 6/12/23 Contact Person: Scott Campbell and Amanda Fijal

2022-002 Housing Choice Voucher Cluster ? All Programs Recommendation: We recommend that the Authority?s management reviews the accounting information which is the best means of preventing and detecting errors and irregularities.. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: In order to remedy and mitigate audit findings that we have seen building over the past several years, PHA is in the process of moving from a traditional caseload model to a functional task-based model. We will be using SharePoint trackers for transparency, a QC system including running completed HUD-50058?s through an Excel QC Tool to monitor for complete and accurate files, and using software deficiency reports and HUD SEMAP reports to monitor program compliance. Name of the contact person responsible for corrective action: Deborah Madsen, Executive Director Planned completion date for corrective action plan: 12/31/2023

Finding Number:2022-002 Finding: Management did not complete reviews of tenant file applications and recertifications during a portion of the year to ensure compliance with HUD eligibility requirements. Staff turnover and shortages resulted in the review procedure not being completed. We recommend management implement timely review of all tenant files after they have been prepared to ensure all participants in the program meet the eligibility requirements. Corrective Action: The compliance oversight of the Project was maintained by the same individual from the Project's acquisition during 2016 through her retirement in 2022. Due to staffing shortages after the employee's retirement, there was a portion of the year when no review of account reconciliations of the reserve accounts were being completed and reviewed. Management has filled that position and subsequently brought the account reconciliations up-to-date. Anticipated Completion Date: 6/30/2023 Responsible Contact Person: Executive Director of Rosecrance Central Illinois

Findings 2022 ? 003 Emergency Rental Assistance (ERA) Program Federal Assistance Listing # (21.023) ? Allowable Costs/Eligibility Corrective Action Plan: Key considerations are: Treasury added flexibility between the ERA 1 and 2 programs relaxed the burden of proof necessary for applicants to qualify for funding. 1. The reduction of burden and qualifications allowed for self-attestation, third party income verification or certification, and internal policies to reduce burden as supported by the Treasury. 2. Rental payments calculations and assumptions on timing may not have taken into consideration the FAQ guidance covering overall ceilings on payments in ERA I funding once ERA II was in place, which allowed for an 18-month cap on both funding sources. DPD will continue to work towards recovering over-allocations to awardees and initiate collection efforts directed towards owners and landlords. As we finalize the ERA II program by September 2024, DPD will reconcile the payment status of the ERA II awardees and notify awardees of overpayment and repayment requirements. Please reference the following: ERA-FAQ and ERA Questions. https:www.google.com/url?sa=t&source=web&rct=j&url=https:home.treasury.gov/system/files/136/ERA-FAQ-8-25-2021.pdf&ved=2ahUKEwjZ05HLjOL_AhVEkmoFHaXiAMwQFnoECCIQAQ&usg=AOvVaw1SKQl-IN3zig70bkVCxj9C

CORRECTIVE ACTION PLAN YEAR ENDED JUNE 30, 2022 COGNIZANT OR OVERSIGHT AGENCY U.S. Department of Health and Human Services INDEPENDENT PUBLIC ACCOUNTING FIRM Karlsson & Lane, An Accountancy Corporation 4725 First Street, Suite 226 Pleasanton, California 94566 AUDIT PERIOD - For the year ended June 30, 2022 The findings from the June 30, 2022 Schedule of Findings and Questioned Costs are discussed below. FINDINGS - FEDERAL AWARD PROGRAMS AUDIT 2022-001 The Organization should implement a procedure and control to determine program participant eligibility on at least an annual or six month schedule as required by the program. Action: The Organization agrees with the finding, and will implement procedures to implement the recommendation. Conclusion: If the U.S. Department of Health and Human Services has questions regarding this plan, please contact Charlie Meade at: 3170 23rd Street San Francisco, CA 94110 (415) 625 5220 cmeade@shanti.org CORRECTIVE ACTION: Following this audit finding, Shanti?s HIV Programs performed an internal review of all clients served during FY 2021-present to identify active clients out of compliance with Ryan White eligibility. Shanti?s HIV Programs will rectify the auditor?s findings in the following ways: All clients with outstanding eligibility documents will be reached out to regarding their compliance status and HIV Programs staff will attempt to obtain proper documentation. If a client is unable to provide Ryan White eligibility documents, they may sign an attestation stating that they are a San Francisco resident and their income is at or below 500% of the Federal Poverty Level. When eligibility documentation is received, HIV Programs will update the ARIES database, the client?s chart and Shanti?s internal tracking document. Shanti will communicate status updates regarding client eligibility and will inform the appropriate parties if any clients served during the FY 22-23 contract period were not able to prove Ryan White eligibility. Previously reported UOS and UDC that remain undocumented will be restated with February 2023 reporting. POLICY & PROCEDURE CHANGES: HIV Programs? Policies and Procedures will be updated to reflect that clients who are not in compliance with Ryan White eligibility should not receive services or be billed for until documentation is provided. o The Director of HIV Programs will review a listing of all clients out of compliance monthly. o HIV Care Navigators and/or the HIV Program Coordinator will follow-up with clients out of compliance to obtain documentation. o The Director of HIV Programs will review the clients reported monthly into ARIES and sign off that all clients are eligible and documented to have received services during the month. o The Director of HIV Programs will sign off on all UOS and UDC reported monthly to finance for inclusion on the monthly invoices to the City. PROJECTED COMPLETION DATE: Shanti?s HIV Programs Department is working diligently to update Ryan White eligibility documents for all clients served during the FY 21-22 and FY 22-23 contract periods. The corrective action plan is anticipated to take until the end of the FY 22-23 contract period (2/28/23).

Prior approval for capital expenditure: We have reviewed our controls over grant expenditures with new staff to ensure that controls over compliance are followed. We have made one modification that includes a review of recorded expenditures recorded in the general ledger prior to year-end to ensure that all items recorded have required approval.

Finding 2022-002: Verification of Free & Reduced Price Application (NSLP) Recommendation: We recommend the District perform the verification of free & reduced price applications by the deadline published by DESE. Planned Corrective Action: The District will ensure future verifications of free & reduced price applications will be completed by the deadline published by DESE.

PEEKSKILL HOUSING AUTHORITY 807 Main Street Peekskill, New York 10566 Phone: (914) 739-1700 Fax: (914) 739-1787 Corrective Action Plan ? March 31, 2022 Audit Findings 2021-1 Condition: Deficiencies Noted in Examination of Low Rent Public Housing Tenant Files Steps to resolve: We will review the internal control procedures over tenant file recertifications and documentations. Management has implemented procedures to clear this finding in FY 2023. Timeframe: By FYE March 31, 2023 Individual responsible for correction: P. Holden Croslan, Executive Director