Corrective Action Plans

2022-004 Eligibility: Public Housing Tenant Files Public and Indian Housing Program ? CFDA Number 14.850 Material Weakness in Internal Control, Material Noncompliance Repeat Finding from June 30, 2021 reported as Finding 2021-002 Condition: Out of a total tenant population of approximately 300 tenant files, 25 files were selected for testing (but stopped testing after 18 files due to the volume of errors). Exceptions were noted as follows: ? 1 tenant file where the Authority was unable to locate and therefore could not test items such as Form 9986, personal declaration form, birth certificates, social security cards, income and deduction support, and EIV verification. The Authority indicated it was recreating the file. ? 2 tenant files with missing 214 affidavits. ? 1 tenant file where the 214 affidavit was not signed. ? 5 tenant files where the personal declaration form was not in the file. ? 1 tenant file where the Form 9886 was not in the file. ? 1 tenant file where the Form 9886 was signed approximately 3 months after the recertification date. ? 4 tenant files with income issues which may have changed the tenant rent amount: o 1 file where there was no support for the family contribution listed on the 50058. o 1 file where there was no support for the child support listed on the 50058. o 2 files where general assistance income (food stamps) was listed as income on the 50058 but should have been excluded. ? 4 tenant files with deduction issues which may have changed the tenant rent amount: o 1 file where the utility allowance of $91 was not on the 50058. This was corrected subsequently on an interim certification. o 1 file where the ?Disclosure of Information? form listed weekly child care expenses, but no child care expenses were deducted on the 50058 and there was no documentation or support in the file explaining if the child care expenses were deductible. o 1 file where the ?Recertification Summary? form listed weekly medical expenses, but no medical expenses were deducted on the 50058 and there was no documentation or support in the file explaining if the medical expenses were deductible. o 1 tenant file where the prior year utility allowance of $82 was used instead of the current utility allowance of $90. ? 1 file where the tenant is paying a flat rent of $686. However, the flat rent appears to be the amount from the previous year and it doesn?t appear that a current flat rent study was conducted or approved. ? 1 file where the dependent date of birth listed on the 50058 did not agree to the birth certificate. ? 2 files where the birth certificates were missing. ? 2 files where the social security cards were missing. ? 1 file where the EIV was not in the file. Auditor?s Recommendation: The Authority should correct the deficiencies noted in the tested files and utilize an ongoing quality control review process on the entire tenant population to ensure proper compliance with the requirements related to tenant eligibility. Ongoing staff training and timely management reviews should be utilized to ensure staff is aware of acceptable procedures. In addition, the Authority should review staffing levels, skill sets and case load. Action Taken: As was also instituted for HCV participant files, the Authority has instituted a checklist sheet that will occupy the front interior of all tenant files. This checklist will contain every document that is required to be placed in the tenant file. The Authority has and will affirm the use of its procedures, and continue to implement procedures to ensure all tenant files are maintained in accordance with policies and procedures. Additionally: ? All noted deficiencies will be corrected and cured on or before March 31, 2023. ? The Authority has also taken steps to stabilize staff by hiring a Property Manager and an Occupancy Specialist that will support the Public Housing Department. ? The Authority has implemented a 100% quality control review of all participant files. Task will be completed by an outside specialized compliance consulting company. The consulting company will report initial findings to the Authority and deficiencies will be cured before the final completion of certification. Thereby reducing any additional findings with tenant files. Task began February 1, 2023, and will continue for one year. ? Repeated noted errors will be reported to the Senior Property Manager and additional hand?s-on training regarding deficient items will be completed as necessary

2022-001 Eligibility: HCV Tenant Files Section 8 Housing Voucher Cluster (Section 8): Section 8 Housing Choice Vouchers Program ? CFDA Number 14.871 Mainstream Vouchers ? CFDA Number 14.879 Material Weakness in Internal Control, Material Noncompliance Repeat Finding from June 30, 2021 (Finding 2021-001 and originally reported in 2017 as Finding 2017-001) Condition: Out of a total tenant population of approximately 1400 vouchers, 26 files were selected for testing. Exceptions were noted as follows: ? 1 utility allowance error where the utility allowance amount of $288 on the 52667 form was reported on the 50058 form for $298. This had no effect on the HAP rent. ? 2 214 affidavit errors where a member of the tenant?s household did not checkmark the box on their 214 forms indicating that they are either a U.S. citizen or a permanent resident. Based on the birth certificates, the member of the households were a U.S. citizen. ? 1 214 affidavit error where the 214 form was missing for a member of the tenant?s household. ? 1 income error where one of the tenant?s pay check was missing for the tenant?s income calculation. Basing the tenant?s wage income calculation on the support in the tenant file would not have changed the HAP rent. ? 1 HAP contract error where the HAP contract is missing from the tenant file. ? 2 9886 errors where members of the household over the age of 18 did not sign and date the 9886 forms. ? 2 deduction errors where members of two households, who were 18 years of age, received a $480 deduction. Correcting this error caused the HAP rent to decrease by $12 for each tenant. ? 1 lead base paint error where the lessor (landlord) did not sign the form to indicate that the information provided to the tenant is accurate. ? 2 EIV errors where the EIV form was not generated or were missing for the tenant?s annual recertification. ? 1 50058 error where the tenant?s childcare support was coded as unemployment benefits on the 50058. ? 1 tenant file unavailable for review due to Hurricane IAN, but no support could be provided. In addition, we also noted as part of our new admissions testing (21 files tested out of approximately 203 new admissions) the following: ? 1 tenant file unavailable for review due to Hurricane IAN, but no support could be provided. Auditor?s Recommendation: The Authority should correct the deficiencies noted in the tested files and utilize an ongoing quality control review process on the entire tenant population to ensure proper compliance with the requirements related to tenant eligibility. Ongoing staff training and timely management reviews should be utilized to ensure staff is aware of acceptable procedures. In addition, the Authority should review staffing levels, skill sets and case load. Action Taken: The Authority has implemented a 100% quality control review of all participant files. Task will be completed by an outside specialized compliance consulting company. The consulting company will report initial findings to the Authority and deficiencies will be cured before the final completion of certification. Thereby reducing any additional findings with tenant files. Task began February 1, 2023, and will continue for one year. Repeated noted errors will be reported to the HCV Manager and additional hand?s-on training regarding deficient items will be completed as necessary

2022-004 Special Tests and Provisions ? CARES Act Funding Material Weakness / Material Noncompliance The Housing Authority completed modifications to the main office building with CARES Act funding. The Section 8 specialist employees work in the main office building with the administrative staff of the Housing Authority. Prior to COVID, the Section 8 specialists were working in cubicles which were not compliant with the CDC guidelines of distance. CARES Act funding was used to build separate offices and install an air filtration system. The rest of the main office was only modified to stay uniform with the other modifications such as painting and new flooring. The amount of the total project charged to the HCV program was in relation to what improvements were made as well as which employees were occupying the space. Effective July 2022, Section 8 is leasing this section of the main office, which was approved by HUD QAD. This finding has been corrected. The Comptroller, Jennifer Yager, worked with the outside auditors as well as the CFO consultant to resolve the posting errors. Jennifer can be reached at 203-596-2640.

This issue was from a previous year, and has been corrected this current fiscal year (2022-2023) and will not be an issue moving forward.

CORRECTIVE ACTION PLAN Audit Finding 2022-001 Special Tests and Provisions Enrollment Reporting: Significant Deficiency in Internal Control Over Compliance Data Transmission Errors - University of Redlands data submitted to its third-party provider, the National Student Clearinghouse, will be audited via reports generated from directly from the NSLDS. The University Registrar will request access to the respective federal sites in order to run said reports. Delayed Degree Conferral - The Academic Catalog currently lists 4 conferral or graduation dates: Commencement, May 31, August 31, and December 31. This language will be changed to confer degrees the date of the last semester enrolled. - Degrees awarded outside of the typical reporting cycle will be reported manually through the National Student Clearinghouse and not held until the next degree reporting cycle. Contact Person Responsible for Corrective Action: Eric Maczka, University Registrar; eric_maczka@redlands.edu, 909-748-8333 Anticipated Completion Date: December 31, 2022

The District will monitor vendors to ensure they are able to accept federal monies. Samantha Schweizer, Business Administrator by 6/30/2023.

Management?s view: Management agrees with auditor recommendation. Refer to Corrective Action Plan for expected date of completion. Proposed corrective action: Continue to revisit procedures to ensure patients are placed on the correct sliding fee category based on information provided upon admission and that the fee determination is reviewed and updated as needed. All front office staff and backup staff have and will continue to receive annual training from an expert on the sliding scale fee. The Office Manager has put steps in place to ensure proper data entry into the Electronic Medical Records system by front office staff. These steps include, detailed document outlining step by step instructions for data entry pertaining to SSF for office staff, periodic audits of patient charts and continued training of staff. Amador Health is implementing a new Electronic Health Records that is expected to streamline processes and provide additional training for staff. Anticipated correction date: September 15, 2023, allowing for implementation of new system and training. Responsible official: Eileen McKeen, CFO

Finding 2022-004 The Authority agrees with the finding and responds stating that our project is relatively small with only one administrative staff. The board has reviewed this issue and determined there are no additional procedures which can reasonably be done to eliminate these deficiencies and accepts them.

Contact Person Anthony Longie, Executive Director Corrective Action Plan Has been implemented with checklist in each file. Planned Completion Date for CAP Immediately

ASI - JACKSON COUNTY, INC. HUD PROJECT NO. 126-HD028 CORRECTIVE ACTION PLAN Department of Housing and Urban Development ASI-Jackson County, Inc. respectfully submits the following corrective action plan for the year ended December 31, 2022. Name and address of Independent Public Accounting Firm: Bjorklund & Montplaisir 1 Lincoln Center, Suite 470 10300 SW Greenburg Road Portland, Oregon 97223 Audit period: January 1, 2022 through December 31, 2022 The findings from the December 31, 2022 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the number assigned in the schedule. FINDINGS ? FINANCIAL STATEMENT AND FEDERAL AWARD FINDING Department of Housing and Urban Development Finding No. 2022-001 - Section 811, CFDA 14.181 Recommendation: The Project should complete the recertification process for the remaining tenants. Planned Corrective Action: The tenant recertifications will be monitored by the owner to ensure they are being completed in a timely manner. Anticipated Date of Completion: June 30, 2023 If the Department of Housing and Urban Development has questions regarding this plan, please call Chuck Reuter at (651) 645-7271. Sincerely, 04/26/23 Chuck Reuter Date

DHCF and DHS concur with the findings. For bullet point #1 of the findings noted: Fourteen (14) of the cases were delayed because of caseworker inaction within 45 days. However, of those (14) cases, all were sent notices. There were system tickets created for multiple cases listed however they were created well after the 45 days. As a corrective action DHS will provide refresher training and reinforce oversight controls to ensure caseworkers and supervisors are processing applications within federally required timeframes. DHCF is working on enhancing the medical application in the District Direct resident portal to ensure a user-friendly experience for residents to submit applications online. As a result, we expect to see a decrease in delays to application processing as well as a decrease in caseworkers having to trigger notices as the online forum will automate the mailing of notices. For bullet point #2 of the findings noted: One (1) of the cases sighted for lack of verification of SSN was an improper caseworker application of the death process. On 12/09/22 the agency received a death certificate for the beneficiary confirming the decease date of 11/26/22. An application was later received on 12/22/23 with no indication of need for retro- services. The application was improperly processed due to the death notification date. As a corrective action refresher training will be provided to caseworker to ensure the proper application of the death process. For bullet point #3 of the findings noted: One (1) of the cases sighted for lack of verification of SSN was an improper caseworker application of the death process. On 12/09/22 the agency received a death certificate for the beneficiary confirming the decease date of 11/26/22. An application was later received on 12/22/23 with no indication of need for retro- services. The application was improperly processed due to the death notification date. As a corrective action refresher training will be provided to caseworker to ensure the proper application of the death process. One (1) of the cases sighted for lack of verification was a result of improper application of COVID procedures. A request was made to the hub to match SSN and citizenship information attested to by the beneficiary. No match was returned by the hub; RFI /General communication was issued to request citizenship verification; no response was received however COVID PHE rules prohibited closure of case; eligibility was extended on the back end. Although the RFI /General communication was issued correctly, the COVID process to clear the verification to prevent termination was not. The process to clear verifications was not applicable to SSN and Citizenship and this case should have been denied for failure to verify. Although COVID processes are no longer in place as a corrective action the district will incorporate the manual citizenship process into the refresher training related to beneficiaries whose hub ping returns as null. See Corrective Action Plan for chart/table

CFSA concurs with the findings as stated. For bullet point #1 of the findings noted: This appears to be a data entry error that occurred during the eligibility team?s preparation for the single audit. The room & board costs that occurred during the erroneous ?Eligible Not Reimbursable? period on the redetermination form were claimed to title IV-E in real time during CFSA?s quarterly claiming process. The Supervisory Eligibility Specialist has already begun a 10% quarterly quality review process of all eligibility determinations. For bullet point #2 of the findings noted: The youths in question were enrolled in high school at the start of the school year (and reflected as such in the FACES system) but were actually chronically truant. CFSA?s Business Services Administration and the Office of Youth Empowerment have implemented a joint quarterly review of the educational/employment/incapacity status of 18-to-21-year-old youth who are IV-E eligible to ensure that they meet federal requirements to support IV-E claims on their behalf. For bullet point #3 of the findings noted: The issues with background checks pertained to ?other adults residing in the home? who were not the licensed foster parents. The corrective action going forward is to produce source documentation during the audit that identifies the household composition of the foster family home so that the auditors have a clear picture of those who are adults and therefore require evidence that background checks were completed satisfactorily for IV-E eligibility purposes. CFSA will include the sections of the applications/re-applications for foster family home licensure, as appropriate, into the digital catalogue of readily available licensure documentation available for audit retrieval. These documents corroborate household composition for the purpose of identifying who, within the household, requires background checks. See Corrective Action Plan for chart/table

DOEE agrees with the conditions and recommendations of this finding. DOEE proposes to strengthen its controls in the following manner: ? DOEE?s third party database developer updated the code in fiscal year 2022 to prevent occurrences of incorrect benefit amounts generated due to an error in identifying correctly inputted income amounts. The overall operations and maintenance of the eligibility systems ensure the code remains updated with accurate information. ? In fiscal year 2022, DOEE implemented a quality assurance (Q/A) check of benefit payments to identify database errors and duplicate benefits before submitting benefit payments to Utility vendors. DOEE continues this process today to ensure that database errors are identified and addressed in a timely manner. DOEE?s database developer will create and modify the second review report that is exportable to formats that can be read and understood and inclusive of all signed second application reviews. ? DOEE will conduct, and require participation by staff in, quarterly system demonstration and refresher trainings in order to strengthen existing policies and procedures to ensure the review of applications and household size are correctly recorded into the system. See Corrective Action Plan for chart/table

The Department of Human Services (DHS) agrees with the finding in this report. The DCAS System is currently configured to receive the Title II benefit information via the SSA BENDEX periodic data match process. However, the Title II benefit information is shared with DCAS only when the benefit information with the SSA changes. In the scenario where a TANF benefit is certified on a new application, the BENDEX PDM process will not provide the Title II benefit information to DCAS. Hence, we have seen evidence of the data matches not happening up until the point when the benefit information recorded with SSA has changed. The SSA SolQi interface does provide a customer?s Title II and Title XVI benefit information at the time of the initial application, however, this interface in DCAS is configured as a verification interface. In other words, if the customer has reported income from the Social Security Administration, then the DCAS System uses the data match with the SolQi interface to verify the information reported. If a verification is outstanding on the reported benefit from the SSA, and the information received from SolQi matches, then DCAS system is configured to systematically resolve the verification. Hence, there has been evidence of the record received via SolQi, however, the record was not used to update the internal evidence which is used by the eligibility rules. DHCF DCAS teams are tracking system enhancements, logged in internal JIRA tickets ? DSM-3185 and DSM-3186 to enhance DCAS? interface with SolQi to leverage the interface at initial application and during the recertification process to ensure that the DCAS System has the most up to date income information from SSA to determine eligibility. These tickets are currently scoped for the FNS-AWL-CAP-5 releases planned for fiscal year 2024. See Corrective Action Plan for chart/table

Department of Human Services (DHS)/Economic Security Administration (ESA) concur with the findings. DHS Division of Program Operations (DHS/DPO) have embarked on a partnership with Office of Information Systems (OIS) and the Division of Innovation and Change (DICM) to create a unique identifier in DC Access System (DCAS) which will be utilized to properly associate case documents with the appropriate Integrated Case number in DIMS. This process will reduce and/or eliminate unassociated documents in DIMS. In addition, DPO/ESA and OIS will partner to conduct refresher training for staff on how to properly scan and tag case documents as well as how to conduct searches for case documents in DIMS. See Corrective Action Plan for chart/table

The findings from the Summary of Auditor's Results: Section Ill - Federal Award Findings 2022-001 - Eligibility - Housing Choice Voucher - 14.871 Significant Deficiency and Material Noncompliance Summary of Condition and Criteria Incomplete documentation and income calculation errors. Recommendation We recommend the Authority increase training and cross-training to better prepare staff to adjust to periods of high turnover and increased supervisory and quality control reviews, to ensure compliance with HUD regulations. Corrective Action The HCV department is recently under new management; all procedures are being evaluate for accuracy, with emphasis on the noted area of noncompliance. There will be increased staff training and file review.

Finding 2022-003 Criteria or Specific Requirement: CFDA 14.850; US Department of Housing and Urban Development; Public and Indian Housing; annual contributions contract number FW-7097; fiscal year ending March 31, 2022. Eligibility requirements in accordance with 24 CFR 960 relating to admission to, and occupancy of, public housing. Recommendation for Corrective Action: Establish procedures for managements review and supervision over tenant?s annual certifications. Specific internal control procedures should be implemented to ensure, for both family income examinations and reexaminations, documentation in the family file of: (1) waiting list documentation; (2) properly executed rent choice documentation; (3) utility allowance schedule annually updated reflecting the current cost and using normal patterns of consumption for the community as a whole, and current local utility rates; and (4) other factors that affect the determination of adjusted income or income-based rent in accordance with 24 CFR section 960. Views of Responsible Officials: We will review tenant?s files for the deficiencies identified above and implement new internal control procedures to correct these conditions. We will also provide increased supervision and training over this area. Planned Corrective Action/Action Taken: We will review tenant?s files for the deficiencies identified above and implement new internal control procedures to correct these conditions. We will also provide increased supervision and training over this area. We anticipate a complete resolution of this type of error by December 31, 2022. Anticipated Completion Date: We will have this resolved by December 31, 2022 Auditors Evaluation of Auditee Comments: Management?s comments in relation to its corrective action plan appear reasonable, valid, and supported with sufficient, appropriate evidence.

Corrective Action Plan Village of Spring Valley Housing Authority 2022 Audit Finding 2022-001 ? Eligibility Auditee?s Response and Planned Corrective Action The Authority has had staff and consultant turnover during the period under audit. Additionally, the eviction moratorium and lasting effects from the COVID-19 pandemic have resulted in delayed or nonexistent response from tenants regarding obtaining the necessary documentation for eligibility requirements. The Authority has evidentiary documentation supporting their attempts to obtain the required documents from the tenants, including certified letters. The courts suspended evictions during the eviction moratorium that resulted from the COVID-19 pandemic, which includes evictions for nonpayment and noncompliance. The Authority has been working with legal counsel on these matters and continues to pursue this vigorously. The Authority has also hired new staff and consultants who have been diligently working to implement improvements to the administrative systems related to recertifications. Planned Implementation Date of Corrective Action: March 2023 Person Responsible for Corrective Action: Keith Burrell, Executive Director

Views of Responsible Officials and Planned Corrective Actions: Staffing turnover limited ability for portfolio property managers to effectively manage tenant files at each building location. Inglis has contracted with an external expert regarding implementation and process training for Yardi, the new property management system. Once fully implemented there are several key internal controls within the system that will alert property management team to tenant issues regarding rent and recertifications. Items such as documenting extenuating circumstances in TRACS and updating the form 50059 will occur more timely once Inglis has successfully implemented Yardi property management system for each property.

2022-015 Improve Controls over Medicaid Capitation Payments for Medicare Members Federal Agency: U.S. Department of Health and Human Services State Entity: Department of Community Health (DCH) Corrective Action Plans: This correction was put into production on 7/1/2022. The recoupments began April 1, 2023, to coincide with the termination of the continuous coverage requirement of the Public Health Emergency (PHE). Estimated Completion Date: April 1, 2023 Contact Person: Lynnette Rhodes, MAP Executive Director Telephone: 404-656-7513; E-mail: lrhodes@dch.ga.gov

2022-023 Strengthen Controls over Eligibility Records Federal Agency: U.S. Department of Health and Human Services State Entity: Department of Human Services (DHS) Corrective Action Plans: ? The Program will work with the Community Action Agencies (CAAs) and the third party to modify the data system and establish a Community Services Block Grant (CSBG) Eligibility Date and Federal Poverty Level percentage or categorical eligibility status within the data system with each application. ? This modification will clearly identify the date that the household was eligible for CSBG services and ensure compliance with 42 U.S.C. ? 9902 (defining "low-income" and "poverty line"). The Household will be eligible for CSBG services for 90 days. At the 90-day marker, the Agency must re-determine eligibility to continue CSBG services. The services will end at the end of the current Federal Fiscal Year Contract and must be reestablished annually. ? For community events or indirect services aimed at assisting low-income communities, in accordance with 42 U.S.C. ? 9901 (objectives and purposes of the CSBG program), the CAAs will flag these events in the data system as "Community Event" and document the event's purpose, attendance, and any relevant eligibility information for participants. This approach will help demonstrate the services? validity and ensure compliance with the CSBG program's objectives. ? DHS will provide the reconciliation parameters and methodology to the CAAs for their quarterly reconciliation. ? The Program will update the CSBG Policy Manual and distribute to the network. The Program will provide training and guidance to the network to ensure that policies and procedures are consistently enforced and operating effectively. Estimated Completion Date: August 1, 2024 Contact Person: Cynthia Bryant, Unit Director Telephone: 470-259-8188; E-mail: cynthia.bryant@dhs.ga.gov

2022-032 Improve Controls over Employer-Filed Claims Federal Agency: Various Federal Agencies: U.S. Department of Homeland Security U.S. Department of Labor State Entity: Department of Labor (GDOL) Corrective Action Plans: The Georgia Department of Labor disagrees with this finding. The Employer Filed (Partial) Claims (EFC) program originated in the late 1960?s and was designed to allow employers with short term, temporary periods of lack of work for their employees to retain their workforce when work resumes. This is a program that many large manufacturers in Georgia rely on when they have temporary plant shutdowns and have for decades. When GDOL has attempted in the past to limit this program, we have met strong resistance from Georgia?s manufacturers. This program optimizes our ability to process and pay mass numbers of claims more quickly, such as what occurred at the beginning of the pandemic. EFCs may be filed by an employer with respect to any complete pay-period week during which an otherwise full-time employee works less than full-time, due to lack of work only, and earns an amount not exceeding his/her unemployment insurance weekly benefit amount. Such claims shall not be submitted or allowed for vacation days regardless of whether such vacation days were requested by the employee or established by the employer. Effective March 19, 2020, a temporary, Emergency Rule 300-2-4-05(1), containing Rule 300-2-4-.09(1) was signed which required employers to electronically submit EFCs on behalf of their employees whenever it is necessary to temporarily reduce work hours or there was no work available for a short period of time. Employers were allowed to file such claims for full and part time employees whose earnings had been reduced. In July 2020, the Rule was sunset and employers were no longer required to file EFCs. EFCs may be filed online by single entry or upload or paper. An employer may submit EFCs for regular state unemployment insurance programs including available extended benefits programs with the same eligibility requirements as regular UI, such as Pandemic Emergency Unemployment Compensation (PEUC) and State Extended Benefits (SEB), given all regular UI entitlement is exhausted. By electing to submit EFCs on behalf of the individuals, the employer is responsible for attesting to the employment status and weekly earnings of the individual for the EFC submitted. An affidavit certifying that the employer has obtained earnings from other employment as well as other requirements must be completed before EFCs can be entered or uploaded. Individuals for which EFCs are submitted are considered to be still attached to the employer and are exempt from the requirement to register for employment services per Georgia Employment Security Law Rules 300-2-4-.02. Such individuals are not required to be nor certify on a weekly basis to be able, available and actively seeking work. The GDOL disagrees that we would not provide the requested information to the auditors. The data requested relates to an ongoing federal criminal investigation. GDOL did not provide the data with concerns that dissemination of the data to a third party could jeopardize the ongoing criminal investigation and create legal risk for GDOL. GDOL stated that the auditors should obtain permission from the United States Department of Justice as a condition to dissemination of the data. GDOL did not receive any confirmation that the auditors had discussed the matter or coordinated with the US Department of Justice. Even though there have been some publicized indictments, the US Department of Justice has confirmed to GDOL that the investigation is ongoing and future indictments are anticipated. Notwithstanding, GDOL reiterates it would be happy to share the relevant data in its possession with assurances that the auditors will not publicize or disseminate any of the audit data without first consulting with the US Department of Justice. GDOL is also happy to cooperate with the auditors and provide information relating to how GDOL discovered the methods and schemes used by the fraudsters; however, GDOL has serious concerns about any publication of such information or of any other specific vulnerabilities in GDOL?s systems that would serve to encourage or perpetuate additional unemployment insurance fraud. Summary When we identified employer fraud schemes, we followed the guidance issued by United States Department of Labor (USDOL) and collaborated with the United States Department of Labor Office of Inspector General (OIG) to investigate these cases. Effective December 6, 2021, the EFC process was revised to require individuals (employees) to complete an EFC profile to include a real-time identity verification before payments can be made. Employers are responsible for submitting the request for the payment to certify to the individual?s employment status, but the individuals must certify their identity and personal information for the claim to be processed. Employees are notified when a claim is filed on their behalf and provided instructions for their portion of completing the EFC process. The MyUI Customer Portal dashboard provides all the EFC correspondence sent to the individual as well as a status of the profile set up and identify verification. Prior to the implementation of the EFC profile requirement, GDOL utilized the Social Security Administration (SSA) crossmatch and Systematic Alien Verification for Entitlement (SAVE) verification processes to verify the identity of claimants where employers submit claims on their behalf. GDOL has no plans to stop utilizing the EFC program as it is an effective and popular program among employers with a successful 60-year track record. GDOL greatly appreciates the feedback and recommendations and will consider this information in future endeavors to modernize and update system and business processes. Estimated Completion Date: December 6, 2021 Contact Person: Crystal Singleton, Policy and Procedure Manager Telephone: 404-232-3183; E-mail: Crystal.Singleton@gdol.ga.gov

2022-030 Strengthen Controls over the Summary Schedule of Prior Audit Findings Federal Agency: U.S. Department of Labor State Entity: Department of Labor (GDOL) Corrective Action Plans: As Georgia progressed towards addressing and pursuing efforts to resolve outstanding Coronavirus Aid, Relief, and Economic Security Act (CARES Act) matters, impediments such as limited workforce and system restrictions hindered progress. Such factors, imposed upon the intents to make system changes, corrections and enhancements. We have taken the following corrective actions in an ongoing effort to bring these findings to full resolution: 2020- 036 Improve Controls Over Eligibility Determinations In addition to steadily reviewing and determining eligibility of responses providing proof of Pandemic Unemployment Assistance (PUA) employment and wages, a task force has been established to assist with this effort. An ongoing campaign is in progress to onboard additional resources to increase the cadence of addressing these items. Claimants who fail to provide adequate proof are manually reconsidered and overpayments established appropriately. Since this process is manually reviewed by staff rather than by system automation, we anticipate this effort will take approximately 60 weeks to complete. When there are indications of potential fraud, additional investigation is pursued to determine if fraud penalties should be imposed. 2021-036 ? Improve Controls over Employer-Filed Claims Effective December 6, 2021, the Employer-Filed Claims (EFC) process was revised to require individuals (employees) to complete an EFC profile to include a real-time identity verification before payments can be made. Employers are responsible for submitting the request for the payment to certify to the individual?s employment status but the individuals must certify their identity and personal information for the claim to be processed. Employees are notified when a claim is filed on their behalf and provided instructions for their portion of completing the EFC process. The MyUI dashboard provides all the EFC correspondence sent to the individual as well as a status of the profile set up and identify verification. Summary We are currently seeking funding to modernize our UI benefits system which will incorporate and improve the controls cited. GDOL will develop and implement procedures to ensure the status of each prior audit finding is reported in an accurate manner. GDOL will ensure staff responsible for submitting the status of prior period audit findings are trained and understand their responsibilities associated with the Summary Schedule of Prior Audit Findings under the Uniform Guidance. Estimated Completion Date: December 6, 2021 Contact Person: Racquel Robinson, Unemployment Policy and Procedures Chief Telephone: 404-232-3190; E-mail: Racquel.Robinson@gdol.ga.gov

2022-028 Improve Controls over Eligibility Determinations Federal Agency: U.S. Department of Labor State Entity: Department of Labor (GDOL) Corrective Action Plans: (1) Identity verification was not performed appropriately in eight instances. GDOL Response: The Georgia Department of Labor disagrees with these findings as it relates to identity verification. The auditors did not identify the type of identity verification procedures not performed or any identity verification procedures that GDOL was required to perform. There was not a mandatory requirement to complete identity verification at the time most of these applications were submitted as the majority of these claims were employer-filed claims (EFC). Identity requirements for EFCs were implemented at a later date. At the start of the pandemic, the identity proofing processes available were Social Security Administration (SSA) verification, Department of Driver Services (DDS) crossmatch and for non-citizens, Department of Homeland Security Systematic Alien Verification for Entitlement (SAVE). As applicable, these processes were performed on all initial regular and EFCs, which includes the eight instances. (2) Non-monetary determination was not performed in two instances. GDOL Response: Instance 1: A disqualifying non-monetary determination was released and disqualification was entered into the system. The system erroneously released a payment for the week in question. An overpayment was established in January 2023. Instance 2: Claim was processed but issue did not get added to the claim to address separation reasons. A non-monetary determination was released in November 2022 to allow benefits. All payable weeks have been processed. There was no detriment to the claimant as they were determined eligible nor was there any monetary loss to the State. (3) Proof of employment or self-employment or a valid offer to begin employment and proof of wages was not submitted by two Pandemic Unemployment Assistance (PUA) claimants. GDOL Response: The GDOL disagrees with the findings related to proof of employment or self-employment or a valid offer to begin employment and proof of wages was not submitted by two PUA claimants. Under the Coronavirus Aid, Relief, and Economic Security Act (CARES Act), claimants did not have to provide proof of employment or self-employment. It was not until Continued Assistance Act (CAA) was enacted December 27, 2020 that such proof was required. The disqualification could not be applied retroactively, as outlined in Unemployment Insurance Program Letter (UIPL) No. 16-20, Change 4. Instance 1: Claimants who established PUA entitlement at the minimum weekly benefit amount were instructed to submit their proof of wages by email. Under the CARES Act, if claimants did not submit proof, federal requirements only allowed for payment of the minimum weekly benefit amount and no disqualification of benefits. The claim cited was originally established and remains established for the minimum weekly benefit amount. In accordance with CAA rules, the claimant was notified to provide proof of employment and wages for weeks paid on or after 12/27/20. To date, no proof has been provided by the claimant. The claimant has been disqualified effective 12/27/20 and an overpayment was established in January 2023. Instance 2: Claimants who established PUA entitlement with a weekly benefit amount greater than the minimum was based on wages entered by the claimant and/or wages reported by the employer. CARES Act only required proof of wages to be submitted. If claimants did not submit proof, federal requirements only allowed for payment of the minimum weekly benefit amount and no disqualification of benefits. Claims established at a higher weekly benefit amount had to be reduced to the minimum amount if no proof was provided. To date, no proof has been provided by the claimant cited. The claim was established above the minimum amount; therefore, benefits were reduced to the minimum amount. In accordance with CAA rules, claimants were notified to provide proof of employment and wages for weeks paid on or after 12/27/20. The claimant has been disqualified effective 12/27/20 and an overpayment was established in November 2022 for weeks paid over the minimum amount under CARES and weeks paid after 12/27/20 under CAA/American Rescue Plan Act (ARPA). (4) Claimants did not self-certify for benefits in 18 instances. GDOL Response: The GDOL disagrees with the findings Claimants did not self-certify for benefits in 18 instances. Employer-Filed Claims (EFC) are submitted by employers on behalf of the claimant. The employer is responsible for attesting to the employment status and weekly earnings of the claimant for the EFC submitted. An affidavit certifying that the employer has obtained earnings from other employment as well as other requirements must be completed before EFCs can be entered or uploaded. Claimants for which EFCs are submitted are considered to be still attached to the employer and are exempt from the requirement to register for employment services per Georgia Employment Security Law Rule 300-2-4-.02. Such individuals are not required to be nor certify on a weekly basis to be able, available and actively seeking work. Additionally, USDOL encouraged states to waive work search requirements for all claimants during the pandemic. (5) Claimant and payment information did not exist in the system of record in one instance. GDOL Response: The identifying information the auditors provided for this claim does not match any claims in our system. Therefore, we are unable to validate the auditor?s finding. Summary The information above is provided for your consideration in dispelling some of the audit findings. GDOL took immediate action to establish the federal UI programs and comply with federal guidance and regulations. There was not a mandatory requirement to complete identity verification at the time most of these applications were submitted. At the start of the pandemic, the identity proofing processes available were Social Security Administration (SSA) verification, Department of Driver Services (DDS) crossmatch and for non-citizens, Department of Homeland Security Systematic Alien Verification for Entitlement (SAVE). As applicable, these processes were performed on all initial regular and employer-filed claims (EFC). Beginning January 2021, PUA applicants were required to complete additional identity verification processes. Beginning in December 2021, all applicants were required to complete identity verification prior to filing a claim for UI benefits. Effective December 6, 2021, the EFC process was revised to require individuals (employees) to complete an EFC profile to include a real-time identity verification before payments can be made. Employers are responsible for submitting the request for the payment to certify to the individual?s employment status, but the individuals must certify their identity and personal information for the claim to be processed. Employees are notified when a claim is filed on their behalf and provided instructions for their portion of completing the EFC process. Additionally, as system deficiencies were identified, changes were made as quickly as possible to mitigate risks of improper payments. Automation of PUA claims was suspended and reviews were handled manually by staff before a determination was released. GDOL established task forces to develop and implement strategies to address the ramped fraud attempts to bypass system and procedural safeguards. We regularly attended fraud meetings with various federal agencies and unemployment agencies from other states to share best practices for combatting fraud. As resources permitted, we did our best to implement these best practices and strategies. Prioritizing system changes was challenging with the time constraints, necessity to build a program based on an established program that operated manually in our state and the demands of all other federal UI programs; but GDOL made every attempt to maximize our system capacity to accommodate the guidelines of each program requirements. Georgia greatly appreciates your time and consideration of our response to the findings and welcome you to contact us if you have any questions. Estimated Completion Date: December 16, 2021 Contact Person: Crystal Singleton, Policy and Procedure Manager Telephone: 404-232-3183; E-mail: Crystal.Singleton@gdol.ga.gov

Corrective action plan: For the annual UI access review, TWC will monitor the annual CAPPS Systems Access Privileges Certification in CAPPS to ensure timely completion. For the code developer/promoter system roles, IT will implement a new quarterly review of developer roles to ensure no staff member has both roles assigned to ensure separation of duties in the system roles. We are also looking at potential technical solutions that would automate and prevent staff being assigned certain roles based on separation of duties. Implementation date(s): February 28,2023 Responsible Persons: Heather Hall, CIO