Corrective Action Plans

Department of Health & Human Services Centers for Medicare & Medicaid Services 31 Forsyth Street, SW, Room 4T20 Atlanta, Georgia 30303-8909 The South Carolina Department of Health and Human Services respectfully submits the following corrective action plan for the year ended June 30, 2022. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS ? FEDERAL AWARD PROGRAM AUDIT DEPARTMENT OF HEALTH AND HUMAN SERVICES 2022-004 Medicaid Cluster; Children?s Health Insurance Program (CHIP) ? Assistance Listing No. 93.775, 93.777, 93.778; 93.767 Recommendation: We recommend eligibility reviews be performed annually in accordance with the South Carolina Medicaid Policies and Procedures Manual. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The agency will resume standard review processing in April 2023 in response to requirements outlined in the Consolidated Appropriations Act 2023. The state has developed a comprehensive operational plan for completing this work including: ? Policy and procedure updates ? Hiring additional staff in response to attrition during the public health emergency (PHE) and staffing levels needed to complete the anticipated work ? Additional staff augmentation through a third party vendor to assist with specific data entry tasks associated with review processing ? Staff refresher training on eligibility review policies and procedures ? A comprehensive Communication Plan for sharing relevant information regarding unwinding activities with stakeholders such as beneficiaries, agency staff, call centers, providers, managed care plans and community organizations ? Outreach to inform beneficiaries about the review process and how to contact the agency with changes to contact information and questions they may have ? Distribution of reviews. The state has 12 months during the unwinding period to initiate reviews and 14 months to complete the work. ? Workload management plan to react to staffing needed for both application and review processing. Name(s) of the contact person(s) responsible for corrective action: Lori Risk Planned completion date for corrective action plan: June 2024 (End of Unwinding Period)

Finding: 2022-005 Name of contact person: Jessica Wall, DSS Director Corrective Action: YCHSA continues to provide training on The Work Number. This is also checked during the second party review process. Additionally, The Work Number is now located within NCFast so there is no need for staff to run this in an older program outside the NCFast system. Staff utilize a checklist to ensure the correct application of Medicaid policy and adequate information being used to determine eligibility. A training will be held on this checklist to ensure staff are knowledgeable to its intended use and it is being used correctly and consistently. Eligibility Supervisors will complete knowledge checks with Medicaid staff to evaluate the effectiveness of recent trainings. This will be done in a group setting and will use active applications/cases as a guide to determine if information has been requested accurately. Following the knowledge checks, Medicaid staff will be given anonymous surveys to complete in an effort to discern improvements or continued areas of need. Due to the age of the cases pulled (many of these being from 2019) the staff involved in these cases are no longer here. Proposed Complinace Date: Training on The Work Number has already been provided to staff and the new checklist is already in use. YCHSA will continue to conduct second party reviews at a higher amount compared to the state mandate. Training will occur by 12/31/22.

Finding: 2022-004 Name of contact person: Jessica Wall, DSS Director Corrective Action: YCHSA will provide training to staff on the review of checklists that have previously been provided. A training will be held on this checklist to ensure staff are knowledgeable to its intended use and it is being used correctly and consistently. Second party reviews will continue to ensure that resources are being entered correctly in NCFast. Eligibility Supervisors will complete knowledge checks with Medicaid staff to evaluate the effectiveness of recent training on resources. This will be done in a group setting and will use active applications/cases as a guide to determine if resources have been evaluated accurately. Following the knowledge checks, Medicaid staff will be given anonymous surveys to complete in an effort to discern improvements or continued areas of need. Due to the age of the cases pulled (many of these being from 2019) the staff involved in these cases are no longer here. Proposed Complinace Date: Training will occur by 12/31/22 and second party reviews will continue indefinitely.

Finding: 2022-003 Name of contact person: Jessica Wall, DSS Director Corrective Action: YCHSA continues to second party Medicaid cases with at least 100 cases being viewed each quarter (more than the state requirement of 76). YCHSA will provide training to staff on the review of checklists that have previously been provided. A training will be held on this checklist to ensure staff are knowledgeable to its intended use and it is being used correctly and consistently. Eligibility Supervisors will complete knowledge checks with Medicaid staff to evaluate the effectiveness of recent trainings. This will be done in a group setting and will use active applications/cases as a guide to determine if information has been entered accurately. Following the knowledge checks, Medicaid staff will be given anonymous surveys to complete in an effort to discern improvements or continued areas of need. Due to the age of the cases pulled (many of these being from 2019) the staff involved in these cases are no longer here. Proposed Complinace Date: Increased second party reviews are in place currently and will continue with at least 100 cases being second-party reviewed each quarter. Training will occur by 12/31/22 around how to properly enter information and which information should be included.

2022-004 SPECIAL PROVISIONS Federal Agency: U.S. Department of Agriculture Federal Program Name: Supplemental Nutrition Assistance Program Assistance Listing Number: 10.561 Federal Award Identification Number and Year: 222MN127Q7503 & 222MN101S2514 - 2022 Award Period: October 1, 2021 through September 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Recommendation: We recommend that the County ensure for casefile review that the cases are reviewed by a separate person that the determining worker. In cases of heightened sensitivity when the lead makes the determination, the case should be reviewed by their supervisor. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The County will implement the recommendation immediately. Name of the contact person responsible for corrective action plan: Diane Arnold, Sherburne County Auditor-Treasurer Planned completion date for corrective action plan: Already corrected

Finding 2022-001 - Ineffective Internal Controls (Significant Deficiency) Recommendation: We recommend the Authority retain copies of properly approved invoices and journal vouchers to support allowable costs related to the Housing Voucher Program expenditures. We recommend the Housing Manager retain each internal review file conducted during the year as support the Authority completed the programs required self-audit related to recertifications of participants. We further recommend the Authority document and retain managements review of the waiting list following the pull for top of the list letters. Action Taken: The agency has implemented stronger internal controls regarding oversight and approval of invoices and journal vouchers. Effective October 1, 2023, Managers will be initialing all invoices prior to entering in the system. The Finance Manager will approve the bills to pay from a list of approved invoices generated from the accounting system, and the Account Coordinator will generate the payments/collate with invoices and forward them to the ED for final review against the approved invoices and signature. The Housing Programs Manager has implemented a quarterly random sampling of files to ensure oversight of the requirements of documentation and certifications. These quarterly reviews are saved on our server for future reference and utilize spreadsheets for HALC for tracking and compliance purposes and using a random sampling app online. In regard to documenting the oversight of the waiting list, effective September 1, 2023, the Housing Programs Manager is now coordinating this process. The Administrative Assistant pulls the waiting list, signs it and then turns it in to the Housing Programs Manager for review for accuracy and to verify that applicants are being pulled in the correct order according to HALC policy. The Housing Programs Manager then signs the list and uploads it into a file on the HALC server. The Housing Manager will then quarterly process a random sampling and pull the applicant file to review on a quarterly basis. This will be documented for future review.

FINDING 2022-003 ? Subsidized Loan Allocation Condition Found: The amount of Subsidized and Unsubsidized Federal Direct Loans awarded was incorrect for one of the fifty-four students in our sample that received Federal Direct Loans. Corrective Action Plan: The Financial Aid Director updated reallocated $1,407 of unsubsidized loan funds as subsidized loan funds on August 3, 2022. Procedures will be improved to ensure that subsidized loan eligibility is reviewed before awarding unsubsidized loans. Anticipated Completion Date: The corrective action was completed on August 3, 2022. Contact Person Tirzah Knight, Director of Financial Aid 918-335-6252

Finding 2022-002 - U.S. Department of Education (USDEJ. Title IV Student Financial Aid Programs (deficiency}: We observed the following conditions in connection with our testing of the various U.S. Department of Education, Title IV, Student Financial Assistance Programs: 1. One (1) out of 10 students tested did not have timely or accurate enrollment reporting to the National Student Loan Data System (NSLDS). 2. One (1) out of 60 students tested was overpaid Pell funds. The over awarded funds were subsequently returned. 3. One (1) out of 60 students tested was not eligible for but was awarded Federal Supplemental Educational Opportunity Grant (FSEOG). The University subsequently returned the ineligible grant amount. 4. One (1) out of 60 students tested showed a discrepancy during verification testing where we observed tax documents submitted with an incorrect social security number. The questioned cost is $5,195. 5. Two (2) out of Five (S) students tested did not show the returned amount on the student's statement of account during R2T4 testing. Both statements of account were subsequently updated with the returned amounts. Corrective Actions - 1. NSLDS reporting is actively reconciled monthly with our financial aid servicer and, as of August 18, 2022, the University confirmed 97.18% reported. The University will continue to actively monitor this reporting to ensure accuracy and timeliness. 2. The University will monitor and review the process of enrollment more thoroughly with the third-party financial aid processor to ensure all non-enrolled students are not included in payment batches. The University has moved to a new third-party financial aid processor in a further effort to ensure compliance with Title IV regulations. 3. The University will monitor and review the process of enrollment more thoroughly with the third-party financial aid processor to ensure all non-enrolled students are not included in payment batches. The University has moved to a new third-party financial aid processor in a further effort to ensure compliance with Title IV regulations. 4. The University will monitor and review the process of verification more thoroughly with the third-party financial aid processor to ensure all applicable steps are taken and that all information is accurate. The University has moved to a new third-party financial aid processor in a further effort to ensure compliance with Title IV regulations. 5. The University has implemented a new student information system, as well as processes to ensure that Title IV transactions are applied timely to student ledgers. The University also notes that, in the case of this finding, the Title IV funds were returned timely and accurately.

A. Comments on Findings and Recommendations: We agree with the finding and recommendation. B. Actions Taken or Planned: By November, the Vice President of Financial Aid will update the Withdrawal Checklist to include a final enrollment field to notate the number of hours enrolled. The Withdrawal Checklist will also include a checkbox to notate that all financial aid has been updated to the proper enrollment status prior to completing the R2T4 calculation.

Name of Responsible Individual: Melanie Mason, Director of Student Financial Aid Corrective Action: The University will transition from a manual review process to an automated electronic process utilizing a combination of both Informer and Colleague reports. The process will compare components of the Cost of Attendance to the student?s current billing as of the census date. Each Financial Aid counselor will run the automated report for their students and freeze each student?s award budget. This freeze process will prevent any further changes to the award budget for the student. Confirmation of this review will be provided to the Director of Financial Aid by each counselor. The Director will verify the process has been completed. Anticipated Completion Date: March 31, 2023

Corrective Action Plan Federal Award Findings and Questioned Costs For the Fiscal Year Ended June 30, 2022 Finding 2022-001 ? A. Activities Allowed or Unallowed; B. Allowable Costs/Cost Principles; E. Eligibility; N. Special Tests and Provisions Federal program information: Federal Program: 93.461, HRSA COVID-19 Claims Reimbursement for the Uninsured Program and the COVID-19 Coverage Assistance Fund (COVID-19 Uninsured Program) Federal Agency: U.S. Department of Health and Human Services (HHS), Health Resources and Services Administration (HRSA) Locations: Various Award Numbers: Various Award Period: July 1, 2021 through June 30, 2022 Summary of finding: UC Health did not design or appropriately document internal controls to monitor the terms and conditions and underlying HRSA COVID-19 Uninsured Program regulations during the COVID-19 pandemic. Additionally, UC Health did not have internal controls in place to formally document its compliance with the HRSA COVID-19 Uninsured Program?s allowability and eligibility requirements. While management has processes in place to review claims for potential insurance coverage before initial billing, evidence of insurance reviews and subsequent verification of lack of coverage was not retained. Refunds required to be made to the HRSA COVID-19 Uninsured Program were not identified timely. Planned corrective action: Management has reviewed claims submitted to the HRSA COVID-19 Testing for the Uninsured Program for potential payments for ineligible services and timely processed refunds as appropriate. In March 2022, HRSA announced the discontinuance of the HRSA COVID-19 Testing for the Uninsured program and, therefore, remediation of internal controls in no longer applicable. Completion date: December 31, 2022 Responsible contact person: Crag Cain, Vice President of Revenue Cycle Management

Similar to other DHS programs, DHS has implemented an after-action review of information submitted, using a contracted vendor. DHS faced challenges implementing a program with 67 counties and no central eligibility determination system. DHS has learned that implementing the supportive services and multi-sector partnerships was challenging in the context of the global pandemic and workforce shortages. This made DHS dependent on local county reports to maintain program oversight and compile statewide data for submission to US Treasury. DHS plans to strengthen this control as we plan for future emergency or pandemic programs related to rental assistance. Anticipated Completion Date: 06/30/2023 Contact Person and Title: Joel O?Donnell, Director, Bureau of Program Support, OIM

In Response to Federal Award Finding, Finding 2022-003 ? Material Weakness and Material Noncompliance ? Special Tests ? Sliding Fee. Health centers must obtain sliding fee applications so that amounts owed for health center services by eligible patients are adjusted (discounted) based on the patient?s ability to pay. We tested 60 sliding fee encounters and noted that 1 of 60 sliding fee encounters tested received the wrong slide. We noted 6 of 60 sliding fee applications were missing an approving sign off. We noted 2 of 60 sliding fee applications were missing and not on file. We noted 1 out of 60 sliding fee applications did not properly document an extension in the slide eligibility period. We noted 1 out of 60 sliding fee encounters was not properly charged a lab visit fee in accordance with the policy. Lastly, we noted 1 out of 60 sliding fee encounters had a wrong correcting adjustment applied to the patient account. Responsible Person: Stephanie Smith, CPA, Chief Financial Officer Corrective Action Planned: Management will ensure sliding fee applications are completed and properly approved and that discounts for eligible patients are properly calculated, documented in files, processed and extended correctly when applicable, for each sliding fee patient. Management has carefully revised training materials for staff as well as new staff, and will work to ensure controls are followed to verify sliding fee discounts applied are correct based on the patient application. To help ensure compliance, the organization has already begun conducing sampling throughout the year to verify sliding fee applications are obtained, completed correctly, and applied accurately to accounts. Anticipated Completion Timeframe: To be completed by 3/31/23.

Finding 2022-004 Name of contact person: Amy Alligood, Income Maintenance Administrator Corrective Action: Supervisors will be second partying records internally to ensure accuracy of cases. Applications will be reviewed and recertifications will be monitored on a rotation basis. Findings from second party reviews will be reviewed with the worker to monitor a pattern for errors and will review policy guidelines to ensure worker is knowledgeable of policy requirements. Training will also be provided to ensure all files include online verifications, work number searches, register of deeds search, documented resources of income, and ensure those amounts agree to information entered in NCF AST. Supervisors will provide training to ensure workers are aware of proper documentation required to support eligibility decisions. Proposed completion date: Training will be provided the week of November 7, 2022, to review findings and corrective action items. Trainings will continue every week to review policy changes, NCF AST updates as well as common errors that may be found during second party reviews. There were four (4) technical errors cited with a review date from a prior fiscal year.

Finding 2022-003 Name of contact person: Amy Alligood, Income Maintenance Administrator Corrective Action: "Staff will be trained on state communications as it relates to applicants' benefits and the importance of sharing information with all areas which the participant receives benefits. Currently the lead worker manages the notifications received to ensure timely processing of SSI terminations. Agency processes have been reviewed to monitor SSI terminations to prevent recertifications from becoming overdue. " Proposed completion date: "Training will be provided the week of November 7, 2022, to review findings and corrective action items. State communications will continue to be monitored. One (1) technical error cited for an untimely SSI Exparte Review was for a prior fiscal year. "

Finding 2022-002 Name of contact person: Amy Alligood, Income Maintenance Administrator Corrective Action: Supervisors will be second partying records internally to ensure accuracy of cases. Applications will be reviewed and recertifications will be monitored on a rotation basis. Findings from second party reviews will be reviewed with the worker to monitor a pattern for errors and will review policy guidelines to ensure worker is knowledgeable of policy requirements. Training will also be provided to ensure all files include online verifications, documentation of resources of income, and ensuring those amounts match information entered into NCF AST. Supervisors will provide training to ensure workers are aware of proper documentation required to support eligibility decisions. Checklists have been established to include errors cited during audit. Checklists are to be completed at applications and recertifications. Proposed completion date: Training will be provided the week of November 7, 2022, to review findings and corrective action items. Trainings will continue every week to review policy changes, NCF AST updates as well as common errors that may be found during second party reviews. There were four (4) technical errors cited with a review date from a prior fiscal year.

Finding 2022-001 Name of contact person: Amy Alligood, Income Maintenance Administrator Corrective Action: "Supervisors will be second partying records internally to ensure accuracy of cases. Applications will be reviewed and recertifications will be monitored on a rotation basis. Findings from second party reviews will be reviewed with the worker to monitor a pattern for errors and will review policy guidelines to ensure the worker is knowledgeable of policy requirements. Training will be provided to ensure all files have accurate information entry to include correct household composition and correct income calculations. Supervisors will provide training to ensure workers are aware of proper documentation required to support eligibility decisions. Checklists have been established to include errors cited during audit. Checklists are to be completed at applications and recertifications. " Proposed completion date: Training will be provided the week of November 7, 2022, to review findings and corrective action items. Trainings will continue every week to review policy changes, NCF AST updates as well as common errors that may be found during second party reviews. There were six ( 6) technical errors cited with a review date from a prior fiscal year.

Finding: 2022-011 Department of Human Services Response/Corrective Action Plan: The Department agrees with the recommendation. The department will work with NDIT to ensure they restart and maintain the access and security reviews. Contact Person: Tory Brabandt, Medicaid Enterprise Director Anticipated Completion Date: June 30, 2023

Finding: 2022-009 Department of Human Services Response/Corrective Action Plan: The Department agrees with the recommendation. The department will work with NDIT to ensure they restart and maintain the risk analysis and security review for MMIS. Contact Person: Tory Brabandt, Medicaid Enterprise Director Anticipated Completion Date: December 31, 2023

Finding: 2022-019 Department of Human Services Response/Corrective Action Plan: The Department agrees with the recommendation. Due to Medicaid continuous enrollment requirements ending on March 30, 2023, the SPACES system will be converted back to its normal rules and this issue should not happen again. The Department will do a review of CHIP eligibility to ensure incorrect claims are identified and corrected. Claims paid in error will be adjusted to reflect the proper category of eligibility, so the applicable fund code is applied, which will apply the correct FMAP. Contact Person: Erik Elkins, Assistant Director, Medical Services Anticipated Completion Date: April 30, 2023

2022-002 Recertifications 14.881 Moving to Work Demonstration Program ? Award No. OCD26401344019MTW 14.871 Housing Choice Voucher Program (Housing Voucher Cluster) ? Award No. OCD26401344019HCV Responsible Official John Hillis Director of Inspections & Property Owner Services, Systems, and Compliance Plan Detail After a detailed RFP process, Metro Housing has selected an outside vendor (Nan McKay) to assist with completing a backlog of regular reexaminations amassed during calendar years 2020 and 2021. The contract was signed on September 27, 2022. By clearing up this backlog of work, Metro Housing staff working on the completion of regular re-exams for the Section 8 HCVP and MTW programs will be able to renew their focus on completing current work timely and accurately. Metro Housing is also making changes to decrease caseload sizes for Program Specialists while also streamlining workflows to better internal and external communication needed to complete our tasks. The roll-out of this new setup should be complete before the end of the current calendar year. Anticipated Completion Date June 30, 2023 ? All reexaminations will be current, and past due percentages will be lowered to acceptable levels.

October 31, 2022 Corrective Action Plan Finding: 2022-001 Condition Found: The Center has not applied sliding fee discounts to patient charges consistent with its sliding fee discount program. Individual(s) Responsible for Corrective Action: Ken ?JR" Porter Executive Director, Toni Howard Billing manager Planned Corrective Action: ? Update the sliding fee discount program policy to more clearly define family size and income, including examples of source documents ? Create and use a form to document the calculation of the household income entered into the EHR ? Review the complexity of the discount schedule and consider whether it would be beneficial to change the schedule from percentage discounts to flat dollar amounts for Category B, C, D and E ? Develop routine internal monitoring procedures to perform periodic testing of sliding fee discounts to help ensure the discounts are provided consistent with the Center?s sliding fee discount program Anticipated Completion Date: December 2022 Sincerely, Ken ?JR? Porter Executive Director White Mountain Community Health Center 298 White Mountain HWY, Conway, NH 03818 Phone: 603-447-8900 X321 Fax: 603-447-4846 jrporter@whitemountainhealth.org

2022-Single Audit 01 Department of Social Services Title IV-E Adoption Assistance A sample of 40 children that received Title IV-E adoption subsidies during FY2022 was tested for compliance with the above criteria and the observations were noted below. ? 40 out of 40 children - Met the eligibility requirements, had special needs that prevented them from being placed without a subsidy, and could not return home. ? 40 out of 40 children - RDSS made reasonable efforts to place the children without the subsidy or waived the requirement as it was not in the best interest of the child. ? 40 out of 40 children ? The adoption assistance agreements were signed prior to the final adoption decree, the authorized amounts were in line with the State?s rates, and payments were issued in accordance with the agreements. ? 9 out of 40 children ? Sufficient evidence of the completion of the required criminal background and child abuse and neglect registry checks for the adoptive parents and adult household members was not in the adoption case files. The home studies and report of investigations narrative indicated the required checks were completed for the adoptive parents and household members but did not identify when they occurred. Also, in some cases, it was not noted if the adoptive parents met the eligibility requirements for the criminal record checks. As such, the auditors were unable to confirm when the checks occurred, and supporting documentation was not provided prior to the completion of fieldwork. In addition, during the initial file review, documents such as court orders, negotiation documents, and annual affidavits were missing from some of the files. The Adoption Unit was ultimately able to retrieve and provide the missing items. However, an opportunity exists to improve the adoption case file documentation. Recommendations: ? We recommend that the Children, Families, and Adults (CFA) Deputy Director develop and implement a quality control process to ensure that the required documentation is maintained in the adoption case files. ? We recommend that the CFA Deputy Director develop and implement standard documentation requirements for documenting the completion of the background checks in the adoption case files. Explanation of disagreement with audit finding: n/a ? no disagreement Action planned/taken in response to finding: Audit Recommendation: We recommend that the Children, Families, and Adults (CFA) Deputy Director develop and implement a quality control process to ensure that the required documentation is maintained in the adoption case files. RDSS Corrective Action Plan: The Reunification and Permanency Program Manager or designee will conduct quarterly adoption case reviews using the VDSS Guidance Section 3.9.3 - Adoption Records. The quarterly case sample represents 10% of the case and all cases will be reviewed at least once annually. Any findings will be documented to include corrective actions, person responsible and timeframe for correction. The Reunification and Permanency Program Manager or designee will review cases to confirm corrections. Audit Recommendation: We recommend that the CFA Deputy Director develop and implement standard documentation requirements for documenting the completion of the background checks in the adoption case files. RDSS Corrective Action Plan: All RDSS Adoptions files must include the VDSS Adoption File Checklist and the child?s adoptive family documentation. The required adoptive parent documentation includes: o Criminal Background Check Results - Licensed Child Placing Agencies ( Non-Conviction and/or Conviction Letter); Local Department of Social Services (Office of Background Investigations Determination Letter) o Sworn Statement of Affirmation o Child Abuse and Neglect Central Registry Check results for adoptive parent and adult household members. The Adoption and Resource Families Supervisors are responsible for monitoring compliance with documentation requirements for completion of the background checks, including insuring that documentation is requested from child ?placing agencies and third parties. Standard documentation requirements regarding background checks will be included in the quarterly review by the Reunification and Permanency Program Manager or designee. Name(s) of the contact person(s) responsible for corrective action: Brinette Jones, Deputy Director, Division Children, Families and Adults Lavinia Hopkins, Reunification and Permanency Program Manger Planned completion date for corrective action plan: Ongoing, beginning 2nd quarter 2023 If there are any questions regarding this plan, please contact Brinette Jones at (804) 646-4543.

2022-Single Audit 02 Department of Social Services TANF Eligibility A sample of 40 FY2022 TANF cases was tested for compliance with the above criteria and the observations were noted below. ? 24 out of 40 cases files tested did not contain adequate documentation to verify eligibility requirements and approval of benefits. Approximately, 55% of the reviewed files lacked evidence that the workers verified the relationship between the minor children and the applicant and that the children were living in the home. ? 1 out of 40 case files tested, the assistance unit captured a child that was not living in the household, which inappropriately increased the monthly benefit amount. ? 1 out of the 40 cases tested did not contain evidence that the eligibility worker inquired about the applicant?s indication on the application that they were not in compliance with probation/sentencing terms prior to approving the application. Recommendations: ? We recommend that the Economic Support and Independence Deputy Director develop and implement a quality control process to ensure the required eligibility verifications are conducted and properly documented in the case files. Explanation of disagreement with audit finding: There is no disagreement with the finding. Action planned/taken in response to finding: All supervisors within the Economic Support & Independence Division of the Richmond Department of Social Services (RDSS) will be expected to complete a minimum of three case readings per month for each direct report assessing eligibility within the TANF program. In addition, all team members who assess TANF eligibility will be required to complete refresher trainings on uploading documents to the Document Management Imaging System (DMIS), Documentation and Verifications, and Application Processing, which will include categorical requirements and conditions of eligibility. Name(s) of the contact person(s) responsible for corrective action: Sarah Raring & Tricia Wyatt Planned completion date for corrective action plan: June 30, 2023 If there are any questions regarding this plan, please contact Sarah Raring at (804) 646-3332 or sarah.denhamraring@rva.gov.

In regard to the two students who were never reported as graduated, the College did in fact submit the required documentation to the National Student Clearinghouse (?NSC?) for further processing to the NSLDS, but the updates were reported as rejected due to errors by the NSLDS. The College has updated the students' records on the NSC and will monitor the NSLDS portal weekly to ensure that all student updates are processed and correct on both the campus and program levels. In regard to the publication of the length of the Master?s level program, the College is revising its documentation and publication of the length of the Master?s program to reflect adjustments to the program that reduced the amount of time needed to complete the program. In addition, the College?s student information system was reviewed/updated to accurately reflect the published length for each program. To assure that the information is being transmitted correctly, the College will monitor the next six months of enrollment updates to ensure that each student, in the different programs, has the correct publication program length.