Corrective Action Plans

The District publishes or solicits proposals for all contracts equal to or in excess of $25,000. Vendors are required to include a Certification Regarding Debarment, Suspension, and Other Responsibility Matters and SBA will verify vendor certification at https:www.beta.sam.gov/

Finding Reference: 2022-003 Federal Agency: Department of Treasury Compliance Requirement: Eligibility Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Federal Program: 21.023 ? Emergency Rental Assistance Grant Award: ERAPI Charles County Condition/Context: SMTCCAC did not provide proof of review of the shared document among participating ERAP agencies in Charles County to avoid duplication of benefits for four (4) of the 60 rental assistance claims selected for testing. Criteria: Internal Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Cause: SMTCCAC did not adequately monitor controls to ensure proper review of the shared document among participating ERAP agencies in Charles County resulting in the potential duplication of benefits. Effect: Failure to review the shared document used among participating ERAP agencies in Charles County could result in duplication of benefits. Questioned Costs: None Recommendation: We recommend that SMTCCAC consistently verify the shared document used among participating ERAP agencies in Charles County to avoid duplication of benefits. Views of Responsible Officials and Planned Corrective Actions: See Corrective Action Plans section.

Finding Reference: 2022-002 Federal Agency: Department of Treasury Compliance Requirement: Allowable Costs (Non-Payroll) Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Federal Program: 21.023 ? Emergency Rental Assistance Grant Award: ERAP I Charles County Condition/Context: FSTA selected a sample of sixty disbursements of rental assistance claims for testing and noted the following errors: ? SMTCCAC mistakenly processed a duplicate payment of $7,700 for an eligible claim, which was one (1) of the 60 rental assistance claims selected for testing in Charles County ERAP I grant. ? SMTCCAC made a payment of $31,800 to a landlord for one (1) of the 60 rental assistance claims selected for testing, for which another agency had made a payment for the same claim before SMTCCAC. Criteria: Internal Control: Per 2 CFR section 200.303(a), a non-Federal entity must: establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Compliance: Under OMB guidance, Public Law (Pub. L.) No. 107-300, the Improper Payments Information Act of 2002, as amended by Pub. L. No. 111-204, the Improper Payments Elimination and Recovery Act, Executive Order 13520 on reducing improper payments, and the June 18, 2010 Memorandum on Enhancing Payment Accuracy - Any payment that should not have been made or that was made in an incorrect amount, including an overpayment or underpayment, under a statutory, contractual, administrative, or other legally applicable requirement; and includes ? (i) any payment to an ineligible recipient;(ii) any payment for an ineligible good or service; (iii) any duplicate payment; (iv) any payment for services not received; and (v) any payment that does not account for credit for applicable discounts. Cause: Due to staff turnover, the claim of $7,700 was submitted to Finance for payment twice. SMTCCAC did not sufficiently monitor controls to detect the duplicate payment. Additionally, SMTCCAC did not adequately monitor controls to ensure proper review of the shared document among participating ERAP agencies in Charles County to avoid the duplication of benefits for the claim of $31,800. Effect: The duplicate expenditure included in the program cost was deemed unallowable. The landlord involved in the rental assistance claim confirmed receiving two checks, each totaling $7,700. SMTCCAC did not require the landlord to return the duplicate funds, nor did it establish a repayment plan after the landlord expressed a willingness to establish a repayment agreement. Ultimately, the landlord chose to apply the duplicate payment of $7,700 towards future rents for the applicable tenant. During FY2023, Charles County identified the duplicate check and promptly requested the return of duplicate payment of $7,700 from SMTCCAC. During a program file audit by Charles County, it was determined that a duplicate expenditure included in the program cost was deemed unallowable. In FY2022, SMTCCAC paid $31,800 to a landlord who had already received payment from another participating ERAP agency. Despite notifications from SMTCCAC, the landlord has not/was not willing to return the duplicate funds to SMCTTAC. Charles County has notified SMTCCAC on numerous occasions about the need to reimburse the County for the duplicated funds. Once the funds are received, Charles County will return the monies to the State of Maryland. In March of 2023, the County also sent an invoice of $31,800 requesting SMTCCAC to return the $31,800. Questioned Costs: $7,700 ? duplicate payment made to a landlord for a rental assistance claim selected for testing. $31,800 ? duplicate payment made to a landlord for a rental assistance claim selected for testing. Recommendation: We recommend that SMTCCAC implement effective controls to prevent duplicate payments. Additionally, we recommend that SMTCCAC consistently verify the shared document used among participating ERAP agencies in Charles County to ensure that a claim has not been applied for and paid by other agencies. Views of Responsible Officials and Planned Corrective Actions: See Corrective Action Plans section.

Our agency has implemented a scanning system which prints bar codes on each document that automatically goes to the correct tenant file. After documents have been signed they are scanned in. This will help alleviate misplaced documents/files. Staff has also been instructed to always put any type of correspondence with tenants in the electronic tenant file.

Identifying number: 2022-001 Identification of the federal program: U.S. Department of Education Student Financial Aid Cluster Finding: Uniform Guidance for Student Financial Aid (SFA) Programs {III. Compliance Requirements, N. Special Tests and Provisions, 4. Enrollment Reporting ? Compliance requirements (34 CFR 685.309 (b)(2)(i))} stipulates that unless it expects to submit its next updated enrollment report to the secretary within the next 60 days, the school must notify the Secretary within 30 days after the date the school discovers that a loan under title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended. The University did not properly provide to the National Student Loan Data System (NSLDS) notification for one student who withdrew or graduated during FY 2022. Anticipated Completion Date: Action Already Taken Person Responsible: Colin Hilton-MacFarlane, Executive Director of Institutional Research and Effectiveness Corrective Actions Taken or Planned: The Office of Institutional Research and Effectiveness reports graduated students to the National Student Clearinghouse upon degree conferral. The concern about solely relying on a third-party to submit to the National Student Loan Data System was identified in the FY2021 audit with a management response involving reconciling extracts directly from NSLDS to validate that all graduated students were successfully reported (and updating directly within NSLDS for any that failed to be submitted by NSC). The finding in this FY2022 audit occurred prior to the management response and associated business process implementation from the FY2021 audit. The institution remains confident this direct reconciliation within NSLDS will resolve future instances of a lack of timely reporting. This finding also involved a rare case of a student completing a master?s level degree program and immediately enrolling in a subsequent master?s level degree program. The institution believes this uncommon circumstance may have contributed to this specific failure in NSC reporting the graduated status to NSLDS, so although the new business process of reconciliation should prevent the general case of this issue, specific review within NSLDS of students immediately moving from one degree program to another upon graduation will be conducted to ensure no additional mitigations are necessary beyond what has already been implemented to address the general case.

Reporting views of responsible officials and planned corrective actions Management will put controls and procedures in place that ensure all tenant files are maintained in accordance with the HUD Handbook.

1. Current Findings on the Schedule of Finding, Questioned Cost and Recommendation a. Finding 2022-001 (14.157 ? Supportive Housing for the Elderly ? Section 202 Capital Advance) Tenant Files Condition: Move-ins: 1. In one (1) instance out of nine (9) tenant files tested, the employment income reported on Form HUD-50059 was $11,400; however, the supporting documentation verified in the tenant file, indicated $15,678 ($10,05 per hour for 30 hours per week, over 52 weeks). 2. In one (1) instance out of nine (9) tenant files tested, the ?Non-Smoking Lease Addendum? was not signed by management. 3. In one (1) instance out of nine (9) tenant files tested, the ?Non-Smoking Lease Addendum? identified the Project as Terra Quest, Inc. 4. In three (3) instances out of nine (9) tenant files tested, the Security Deposit Agreement was not maintained in the tenant?s file. 5. In three (3) instances out of nine (9) tenant files tested, the Security Deposit Agreement was not signed by management. Recertification: 1. In one (1) instance out of eight (8) tenant files tested, the Notice and Consent for the Release of Information (Form 9887) was not dated by the tenant. 2. In one (1) instance out of eight (8) tenant files tested, the Applicant?s/Tenant?s Consent to the Release of Information (Form 9887-A) was not dated by the tenant. 3. In one (1) instance out of eight (8) tenant files tested, the Verification of Criminal Background Check form was not signed by the tenant. 4. In one (1) instance out of eight (8) tenant files tested, the Form HUD-50059 was not dated by the tenant. 5. In one (1) instance out of eight (8) tenant files tested, the ?EIV? document was not maintained in the tenant file, for verification of the tenant?s income. 6. In one (1) instance out of eight (8) tenant files tested, the Housing quality inspection form was not maintained in the tenant?s file. 7. In one (1) instance out of eight (8) tenant files tested, the ?Lease Addendum, for Violence Against Women and Justice Department Reauthorization Act of 2005? was not dated by the tenant. 8. In five (5) instances out of eight (8) tenant files tested, the ?Notification of rent increase resulting from recertification process ? Section 202 PRAC?s form? was not maintained the tenant?s file. 9. In one (1) instance out of eight (8) tenant files tested, the ?Notification of rent increase resulting from recertification process ? Section 202 PRAC?s form? was addressed to another tenant. 10. In one (1) instance out of eight (8) tenant files tested, the Quality Assurance Information form was not dated by the tenant. Move-outs: 1. In one (1) instance out of three (3) tenant files selected for testing, the tenant file could not be located. 2. In one (1) instance out of two (2) tenant files tested, the security deposit disposition notice was not maintained in the tenant file. (1) Comments on the Finding and Each Recommendation. Management concurs with the finding and the auditor?s recommendation that Ridgeview Terrace, Inc. process applicants and tenants, including recertification of tenants in accordance with guidelines established by the Department of Housing and Urban Development prior to the tenant occupying the unit. By performing these procedures, the risk of incurring questioned costs will be significantly reduced. (2) Actions Taken on the Finding. Corrected going forward.

Recommendation: We recommend that the University disburses the remaining award to the student and implement procedures to ensure awards are properly disbursed to students who have more than a three-term budget. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The remaining award was disbursed to the student when the issue was identified. The correction to the student was completed on June 22, 2022. EOU Financial Aid will enhance their procedures to include the development of an exception report. The EOU Financial Aid Office will coordinate with the Information Technology department to create a report, which will be scheduled to automatically be delivered daily during the first four weeks of each term (before our Pell Recalculation Date (PRD), or institutional census date). After this date, the student enrollment levels cannot be changed. Anytime the student's disbursement amount does not match what it should be for the student's enrollment level on the report, the Financial Aid staff assigned, will be notified and will immediately adjust the disbursement level to match on any miscalculated awards, locking the period to ensure the correct amount is disbursed.. Name(s) of the contact person(s) responsible for corrective action: Jason Hibbert, Interim Director of Financial Aid Planned completion date for corrective action plan: April 2023

To Whom It May Concern: This letter includes the corrective action plan in response to the audit finding from the Single Audit for the 2020-2021 Award Year. Audit Finding: 2022-001: Under the Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Program, providers are required to submit reporting to the Health Resources Services Administration (HRSA). During the single audit, it was determined that roughly $2.4 million of expenses were reported as general expenses in Period 2, were also included as general expenses in Period 1 reporting. We agree with the audit finding and action will be taken to improve this gap going forward by updating procedures for these kinds of requirements. Controls will be implemented whereby there will be a secondary reviewer along with the appropriate sign-off validating the data has been accurately reported to ensure we are in compliance. The contact person responsible for the corrective action plan is James Salerno. The corrective action plan has been implemented as of January 1, 2023. Please let me know if you have any additional questions.

See Corrective Action Plan for chart/table

See Corrective Action Plan for chart/table

Enrollment Reporting to National Student Loan Data System (NSLDS) Planned Corrective Action: To date all past due enrollment and graduate reports have been filed with the National Student Clearinghouse (NSC). The Registrar?s Office is currently clearing any and all error resolution reports that are generated for each submission. This week the May 2022 graduates error report was cleared. This leaves the summer and fall terms of 2022 to be corrected. Those should be resolved no later than 5/15/2023. The Registrar?s Office reported the spring 2023 reports and are back on a transmission schedule. Person Responsible for Corrective Action Plan: Ann Marie Vickery ? Interim Registrar Anticipated Date of Completion: 5/15/2023

1. Finding 2022-001 a. Comments on the Finding and Each Recommendation: Management agrees with the finding. b. Action(s) Taken or Planned on the Finding The Corporation will take the following steps: (1) Develop a plan to address staffing and turnover issues: we will work with the HR department to develop a plan to address staffing and turnover issues. This may include conducting a salary and benefits review to ensure that we are competitive in the market, providing opportunities for professional development and growth, and creating a positive work environment; (2) Prioritize the completion of annual recertifications: we will work with the team to prioritize the completion of annual recertifications. This will involve allocating additional resources, if necessary, and bringing in outside help to complete the recertifications on time; (3) Develop a monitoring plan: we will develop a monitoring plan to ensure that annual reexaminations are completed on time. This will include regular checks of tenant files and random sampling to ensure compliance with the regulations; (4) Train staff: we will ensure that all staff involved in the annual reexamination process are trained on the importance of completing them on time, the potential consequences of failing to do so, and the regulations and policies related to annual reexaminations; and (5) Implement a tracking system: we will implement a tracking system to ensure that annual reexaminations are completed on time. The system will include reminders for staff and tenants and a process for tracking the progress of each recertification.

Finding 2022 ? 001 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster Assistance Listing Number: 14.871/14.879 Federal Award Identification Number and Year: MO002VO - 2022 Award Period: January 1, 2022 ? December 31, 2022 Compliance Requirement: Eligibility Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Condition: Exceptions noted in 1 out of 40 files tested for eligibility requirements. The Authority was unable to provide documentation for releases of information or third-party verification of reported family annual income, the value of assets, or expenses related to deductions from annual income. Cause: The Authority did not maintain supporting documentation within the tenant file. Auditor?s Recommendations: Recommend that the Authority implements controls to ensure the tenant files include all required documentation at the time of recertification. Response to Finding 2022-001 The Authority generally concurs with the auditor?s findings and recommendations. The 2022 Audit included the review of 40 HCV files and deficiencies were noted in only one file. The Authority was unable to provide documentation for releases of information or third-party verification of reported family annual income, the value of assets, or expenses related to deductions from annual income. Action Taken: The implementation of a Corrective Action Plan to address the errors to ensure that the tenant files include all required documentation at the time of recertification began on August 1, 2023. To provide consistency, increase staff knowledge and reduce errors, training began immediately and will continue on an annual and as needed basis. In addition, HAKC will increase quality control file reviews and conduct such reviews on a more frequent basis to identify errors sooner and address the cause of errors quickly to prevent systemic errors. Errors will be identified by error type and the person who made the error. Patterns of errors will be monitored, and additional training provided for similar error types that are frequently repeated and persons who are identified as frequently making errors. Quality reviews will be conducted for all files to ensure that all required documents are in the files. It is anticipated it will take one year to complete the initial file review. After the initial review files will be selected randomly and reviewed according to an established quality control schedule. Each team member will be responsible to collect missing documents identified when completing an annual recertification, interim recertification or change of unit. The Director and Supervisor will assist the Deputy Executive Director and Executive Director in overseeing these corrective actions during the next fiscal year. Name of the contact person responsible for corrective action: Edwin Lowndes Executive Director Planned completion date for corrective action plan to be fully implemented: March 1, 2024.

2022-003 Section 8 Housing Choice Vouchers Recommendation: We recommend the Authority implement controls to ensure all tenant file documentation is accurate and available, and that management review their procedures relating to PIC uploads to ensure compliance with HUD's requirements and timelines. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: 1. The PHA will implementing a Compliance Team to create and enforce a quality assurance plan. The plan will include a 100% file audit of HCV Participant Files to ensure full compliance, and PHA will process all corresponding corrections. 2. The Quality Assurance employees will continue to complete 10% of monthly internal file audits for recertification and 100% of new admissions, to ensure accurate calculations. The Quality Assurance team will also ensure that all proper documentation is present and accurate in all participant files. 3. In addition, PHA will contract a third-party consultant to complete a one-time 100% file audit, then test 10% of participant files, monthly. 4. The HCV Department Team, except for our inspectors, will complete Rent Calculation Training and obtain the exam certification, with a minimum requisite passing score of 80% Additionally, the third-party consultant will provide the HCV Team with technical support required to reconcile file deficiencies noted during the 100% file audit. Planned completion date for the corrective action plan: December 31, 2023; Ongoing Person Responsible: Armeca Crawford, Chief Executive Officer

2022-001 - Eligibility: Public Housing Tenant Files Material Weakness in Internal Control, Material Noncompliance Condition: Out of a total tenant population of 1,275, 25 files were selected for testing. Exceptions were noted as follows: ? 6 files where the annual re-examination was not performed within 12 months. Recommendation: The above-mentioned change will only result in non-timely annual re-examinations for some tenants for one time, and will effectively correct itself in future years. Nonetheless, the Authority should review all annual re-examinations for all tenants and immediately perform annual re-examinations for any remaining tenants that have not already had their next re-examination Action Taken: The Authority concurs with this finding and has begun a review of all files to identify any remaining tenants that have not had a timely annual re-examination and to immediately conduct any needed re-examinations. Effective Date: September 19, 2023 Contact Information Brian Griswell, Executive Director SC Regional Housing Authority No.1 218 Spring Street Laurens, SC 29360 (864) 984-6568

Housing Voucher Cluster ? Assistance Listing No. 14.871/14.879 ? 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 taken in response to finding: The Authority has made several improvements to the processes in which the staff verify eligibility for the HCV program. In 2021, the Authority created a Director of Program Compliance and Training position to ensure that all HCV staff receive consistent training that is congruent with HUD policies and regulations and the Authority?s Administrative Plan. The Director of Program Compliance and Training instructs staff on HCV processes, procedures, and regulations, and monitors staff progress throughout their development. With the assistance of the Director of Program Compliance and Training, the Authority now provides staff with detailed training regarding calculations of adjusted income, the proper steps to determine and calculate required deductions, and the importance of third-party verification required for HCV program eligibility. The Authority has also taken the initiative to complete its own internal audits at random intervals, at least once a year. The HCV Director completes these audits using HUD?s Section Eight Management Assessment Program (SEMAP) audit template. Following these internal audits, the HCV Director meets with staff to discuss any areas of concern and ensure errors are properly corrected. During this meeting, staff receive training on any errors discovered, and recommendations for additional training. Name(s) of the contact person(s) responsible for corrective action: Nicole O?Dell/Katrina Sommer Planned completion date for corrective action plan: On-going

FINDING 2022-008 Contact Person Responsible for Corrective Action: Nicole Wolverton, CFO Contact Phone Number: 219-881-5536 Views of Responsible Official: We concur with the audit finding. Description of Corrective Action Plan: A policy and procedure will be created and implemented to ensure that the documentation required to support a student?s socioeconomic status is reviewed and retained for Eligibility compliance. This information will be reviewed and entered by the Testing department with a final review by the Federal Programs Administrator. Anticipated Completion Date: Gary Community School Corporation will implement this procedure by September 2023.

Corrective Action Plan Federal Award Findings and Questioned Costs For the Year Ended December 31, 2022 Finding 2022-001 ? A. Activities Allowed or Unallowed, B. Allowable Costs/Cost Principles, E. Eligibility Federal program information: Federal Program: HRSA COVID-19 Claims Reimbursement for the Uninsured Program and the COVID-19 Coverage Assistance Fund (93.461) Federal Agency: U.S. Department of Health and Human Services (HHS), Health Resources and Services Administration (HRSA) Locations: Various Award Numbers: Various Award Period: January 1, 2022, through December 31, 2022 Summary of finding: Premier Health Partners and Subsidiaries (the Company) did not appropriately design and execute internal control procedures to review for retroactive insurance that subsequently became effective for the date(s) of service on patient accounts previously billed to and reimbursed by the COVID-19 Uninsured Program. Corrective Action Plan: Premier Health will submit all claims paid by the HRSA COVID-19 Uninsured Program to a third-party vendor to perform a search for any retroactive insurance coverage for these patients for the service dates submitted and paid by this program. Any accounts found to have retroactive insurance coverage for dates submitted will be paid back to the HRSA Uninsured Program by December 31, 2023. Expected Completion Date: December 31, 2023 Responsible Contact Persons: Amanda Ricci-Adkins ? System VP Revenue Cycle, Mike Sims ? System VP & Corporate Controller

The Emergency Rental Assistance Program was developed in response to the pandemic and was implemented swiftly to meet the needs of low-income tenants affected by Covid-19. The program design involves fourteen partner agencies and their varying accounting systems. In March 2021, UWMC began this emergency program with an existing system, the Smart Referral Network (SRN) software, which was adapted in order to quickly launch the program. In March of 2022, the SRN tool was replaced with a software system (Neighborly) more specifically designed to administer and report on ERAP. The new data system facilitates reconciliation to the detailed payment data. Management agrees that the expenditures for the reporting period were overstated and accepts the recommendation along with implementing the following corrective action. UWMC conducted a comprehensive reconciliation of program data to financial expenditure records of its partnering agencies through June 30, 2022. In the current fiscal year, all partnering agencies are required to submit program data through the online Neighborly software along with providing a general ledger report that supports and is reconciled to the data submitted prior to receiving reimbursement. This new procedure was put in place for reimbursements effective January 1, 2023 forward. For reimbursements from July 1, 2022 ? December 31, 2022, we are going to reconcile past reimbursement requests to the partner agency general ledger report retroactively. The UWMC staff member overseeing these reconciliations with support from the UWMC Finance Department is: Kelly DeWolfe, Community Impact Director, Financial Stability kelly.dewolfe@unitedwaymcca.org (831)318-1997

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. Historically, the management and auditing of tenant files was entirely under the process flows for property management team. Going forward the Inglis Compliance department will sufficiently sample and review tenant files throughout year to assure tenant files are accurate and audit ready at any given time.

FINDING 2022-003 ? Eligibility ? Significant Deficiency in Internal Control over Compliance Condition/Context: A sample of 40 students were selected from a list of all students enrolled and awarded federal student aid in fiscal year 2022. Cause: The exceptions occurred as a result of the lack of effective internal controls in place to review completed financial aid packages against approved University budgets. Corrective Action Plan: In order to simplify the awarding process, In June of 2022 NU changed its COA policy to align with credits taken rather than expected months. This was done by our processing team under Kimberly Quinn. This has allowed for a simpler process and ensures a more accurate capture of all aspects to the cost of attendance. The Quality Assurance team, under Brandy Baker, has also included a review of COA as part of their regular file review process which will allow us to capture and correct any potential errors. The QA of COA updated its review in July of 2022 to match the changes made by the processing team.

Finding 2022-001: Annual income incorrectly reported per HUD 4350.3 REV-1, Change 4, Chapter 5: Paragraph 5-6I. & HUD 4350.3 REV-1, Change 4, Chapter 5: Exhibit 5-2 and 24 CFR 5.609(b) and (c). Section 8 Housing Assistance Payment Program 14.195 Eligibility Management?s view: Management concurs with the finding that annual income was not calculated correctly on a certain tenant. We believe the miscalculation was the result of confusion on the nature of a portion of the tenant's income that was exempt. We believe the error was a simple mistake and not an internal control weakness or a significant deficiency. Proposed corrective action: Although mistakes will happen, management believes that a comprehensive training program is important and serves to minimize unnecessary errors. Training, specific to this incident, has been conducted with property staff by seasoned, experienced corporate compliance personnel. Anticipated correction date: October 26, 2022 Responsible official: Jerry Burkholder, Controller

Views of Responsible Officials: Management agrees with the finding. Person Responsible for Corrective Action: Tanya Williams, Assistant Family Outreach Director Corrective Action Plan: Management has implemented a review process by which all eligibility determinations are reviewed and approved by supervisory personnel with sufficient knowledge of program eligibility requirements. CNCAP has developed a screener sheet which will be completed for each participant prior to being served. Anticipated Completion Date: January 3, 2023

Finding 2022-001 Federal Agency Name: United States Department of Health and Human Services Health Resources & Services Administration Program Name: COVID-19 Provider Relief Fund and American Rescue Plan Rural Distributons (PRF) CFDA # 93.498 Finding Summary: The Reporting Period 2 Provider Relief Fund Report was not properly reviewed prior to submission, resulting in a reporting error related to lost revenues. Responsible Individuals: Denise LeBlanc, Chief Financial Officer Corrective Action Plan: Controls will be added to ensure all federal and state reporting is reviewed by a member of the financial services staff, who was not the preparer of the report, prior to submission. The amount of lost revenue will be corrected in subsequent reporting. Anticipated Completion Date: Ongoing as of September 1, 2022