Corrective Action Plans

Finding 2022-002 ? Allowable Costs and Activities, Eligibility ? Compliance and Control Funding Federal Award No. 21.023 Emergency Rental Assistance Program ? COVID 19 Corrective Action Plan: The Commission management identified questionable applicants for assistance during fiscal years 2021 and 2022 and agrees with the finding regarding ALN 21.023. Internal controls have been enhanced to mitigate and help prevent further exposure to noncompliance. This includes the adoption of a formal fraud, waste, and abuse policy in July 2021 as well as providing additional training to employees and third parties that are responsible for reviewing and approving applications in order to better detect invalid applicants to prevent funding these applicants. In May 2021 the Commission hired an Internal Compliance Manager and has engaged a third party law firm and a consulting group to provide consultative assistance to improve processes and to assist in investigating applications deemed to be questionable. Further, internal staffing capacity has been expanded with the creation of the Community Programs Processes Department in fall 2021 and the Data and Analytics Department in early 2022. Additional investigative techniques such as ?mass denial metrics? and tiered level reviews have been implemented into weekly application processing. Processes will continue to be implemented in response to changes in behavior by ineligible actors and ineligible application submission attempts. Staff has set regular internal coordination meetings to improve communication and aid in the identification of new indicators. Internal compliance staff actively participates in national groups administering similar programs, and explores and adopts new preventative measures demonstrated to be effective in other states. Completion Date: The Commission implemented additional compliance review procedures during fiscal year 2021 and expects to conclude its investigation of the fiscal year identified cases during calendar year 2023. Contact Person: Steve Whitson, Director of Community Programs

Finding 2022-001 ? Allowable Costs and Activities, Eligibility ? Compliance and Control Funding Federal Award No. 14.231 Emergency Solutions Grant Program ? COVID 19 Corrective Action Plan: The Commission management identified questionable applicants for direct rental assistance during fiscal years 2021 and 2022 and agrees with the finding regarding ALN 14.231. Internal controls have been enhanced to mitigate and identify instances of potential noncompliance. The funding for the direct rental assistance under this program was concluded and the final disbursements made in early May 2021. The Commission hired an Internal Compliance Manager in May 2021 and has engaged a third party law firm and a consulting group to provide consultative assistance to improve processes and to assist in investigating applications deemed to be questionable. A formal fraud, waste and abuse policy was adopted in July 2021. During fiscal year 2022, MHDC undertook extensive efforts to detect instances of ineligible applicants and documentation irregularities, which resulted in identification of these instances of applicant noncompliance. Completion Date: The Commission implemented additional compliance review procedures during fiscal year 2021, reviewed applications to identify potentially fraudulent applications during fiscal year 2022 and expects to conclude its investigation of identified cases during fiscal year 2023. Contact Person: Steve Whitson, Director of Community Programs

2022-001 - Eligibility: Section 8 Housing Voucher Cluster (FALN #14.871) Criteria HUD regulations of Annual Income (24 CFR ? 5.609), Eligible Family Status (24 CFR ? 5.403), Citizenship and Eligible Immigrant Status (24 CFR ? 5.506) and Disclosure of Social Security Numbers (24 CFR ? 5.216) require the collection and retention of certain tenant information to document the eligibility determination for each recipient. Condition The results of our testing indicated that certain items were unable to be located in the file, as follows: ? In one instance, income verification support did not agree to HUD Form 50058. ? In one instance, social security verification was missing from the tenant file. Questioned Costs Not determinable. Context We selected a sample of 60 files for review. Our sample was a statistically valid sample. Effect The tenant file documentation was incomplete. Cause The cause is unknown. Recommendation We recommend that Park City improve its internal processes to ensure tenant files contain the required documentation. Park City's Response Park City Communities ("PCC") has contracted with an outside firm to manage, staff and run the Housing Choice Voucher program. They have implemented a quality control system to review every file. This quality control process will make sure core documents are retained and timely submission of Form 50058's are completed. Contact: Jillian Baldwin Email & Phone Number : jbaldwin@oarkcitycommunities.org (203) 337-8900

Housing Choice Voucher: Tenant Eligibility - Significant Deficiency Contact Person: Sherryann Brown, Interim Executive Director New Admission EIV compliance ? The HCV Director will do random quality control to check participant files for compliance with tenant income verification and annual recertification. ? A new admissions report will be run monthly. ? Each Eligibility Specialist will be tasked with running the monthly EIV report and placing it in the participant file. TARGET DATE: July 1, 2023

The District has already developed an automated summer Pell solution. The solution has been tested by the field and Central Financial Aid Unit (CFAU) and will be implemented Summer 2023. Personnel responsible for implementation: Steve Giorgi Position of responsible personnel: CFAU Financial Aid Manager Expected date of Implementation: Summer 2023

Finding 2022-005 ?Medicaid ? Eligibility Contact Person Responsible for Corrective Action: Scott Miller, Heather Lawson Contact Phone Number: 765-659-1339 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The School Corp switched Medicaid providers in FY23, and will monitor the new provide to ensure compliance with the federal requirements. Anticipated Completion Date: June 30, 2023

Oversight Agency for Audit, EHDOC Teamsters Residences, Inc. respectfully submits the following corrective action plan for the year ended June 30, 2022. Name and address of independent public accounting firm: Bellows Associates, P.A., 5401 N University Drive, Suite 201, Coral Springs, Florida 33067 Audit period: July 1, 2021 through June 30, 2022 The findings from the June 30, 2022 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDING NO. 2022-002: Section 207/223(f) Mortgage Insurance for the Refinancing of Existing Multifamily Housing Projects, CFDA 14.155 Recommendation: The Project should verify initial tenant income through the EIV system in a timely manner and maintain all required tenant documentation. Action Taken: Training will be provided to all managers regarding the importance of running the EIV 90 day Income Reports on a timely basis. Will instruct managers on how to set up alerts to run 90-day reports on our software One Site. If the Oversight Agency for Audit has questions regarding these plans, please call Christine Harris at 954-835-9200. Sincerely yours, Christine Harris Accounting Manager

Finding No. 2022-002 ? Alternative to Abortion Program ? CFDA No. 93.558; Grant No. 1701MOTA View of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and the recommended procedures have been implemented. Supervisors will ensure that necessary proofs are obtained and documented.

Finding No. 2022-001 ? Alternative to Abortion Program ? CFDA No. 93.558; Grant No. 1701MOTA View of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and the recommended procedures have been implemented. Supervisors will ensure that all client files have proof of eligibility during quarterly file reviews.

Finding 2022-002 For the 2022 HEAP season, our Energy Assistance department was understaffed, and we saw a 40% increase in emergency fuel applications, as well as a 13% increase (704) in new heating assistance applications. We have since added three more fulltime staff, in addition to the four staff we had, and expect that our certification time will be well within the 30 business day requirement. We also added hiring and retention incentives to facilitate full staffing, and promoted a staff member to a Supervisor position, resulting in a much smoother operational workflow. This corrective action plan was completed by August 2, 2023. The responsible party is LeeAnn Horowitz, 207-338-6809.

Finding Number: 2022-002 Incorrect Enrollment Reporting to National Student Loan Data System (NSLDS) Planned Corrective Action: Change the academic software set up to more accurately reflect the last date of attendance for DCC Online classes by adding the last date possible for the student to attend at the end of the last week (rather than the beginning of the week only). And, once the term has ended, exit anyone who has not registered (or pre-registered) for the next semester within two weeks of the end of the term. Person Responsible for Corrective Action Plan: Crystal Laidacker, Registrar Anticipated Date of Completion: Immediate

Re: Auditee's Response and Corrective Action Plan - Finding No. 2022-002 Gentlemen: Having reviewed the draft of our FY 2022 audit we are offering the following corrective action to resolve the deficiencies as per the audit finding: Finding Reference 2022-002 The Authority concurs with this finding. As a result of similar findings in the Authority's SEMAP scoring we have reviewed our existing procedures and have retained consultants to assist us in training staff in a more personal setting. The WHA plans to utilize the use of electronic recordings of inspections in our PHA Web computer software to more accurately monitor inspections and inspection failures. The WHA also has focused the consultants' trainings on improving the inspection procedures and the HQS enforcement procedure. Training new and additional staff and developing more comprehensive steps in the inspection, re-inspection and rent withholding will improve our HQS enforcement. Very truly yours, John F. Gollinger Executive Director Person Responsible for Corrective Action:, 781-894-3357

Re: Auditee's Response and Corrective Action Plan - Finding No. 2022-001 Gentlemen: Having reviewed the draft of our FY 2022 audit we are offering the following corrective action to resolve the deficiencies as per the audit finding: Finding Reference 2022-001 The Authority concurs with this finding. As a result of similar findings in the Authority's SEMAP scoring we have reviewed our existing procedures and have retained consultants to assist us in training staff in a more personal setting. We believe that having replaced some staff and training new staff we shall be able to correct the deficiencies found in selecting applicants from the wait list. We are leasing at a more frequent pace than in the past and expect leasing to ramp up so that staff will have ample opportunity to go through the proper procedures more frequently than in the recent past with the benefit of having direct oversight and advice from expert advisors. We expect that this training process will prevent the errors that were made in the past fiscal year. Very truly yours, John F. Gollinger Executive Director Person Responsible for Corrective Action:, 781-894-3357

Planned Corrective Action: Applicable staff will be briefed on the finding and training will be provided on both written policy and procedure. The Housing Authority has a quality assurance program to monitor and ensure the proper documentation is contained within the tenant files. The Housing Authority will continue to implement its file review system for the Section 8 Program. Although the system cannot ensure 100% compliance, its effectiveness is demonstrated in the high percentage of compliance. Anticipated Completion Date: 6/30/23. Responsible Contact Person: Leah Eppinger, Executive Director.

Federal Program: ALN 10.557, U.S. Department of Agriculture (? WIC Special Supplemental Nutrition Program for Women, Infants, and Children) Condition per Auditor: Controls in place were not adequate to ensure the County maintained responsibility for compliance with eligibility standards when eligibility determinations are made by the contractor. Planned Corrective Action: Management will implement and follow a process of reviewing of eligibility intake and certification performed by contractor employees by internal County representative. This will be completed by the internal county WIC Compliance Manager or designee and will utilize the audit tools provided by the state that includes monitoring of eligibility intake and certification. The WIC Compliance Manager will request contractors to complete audit reporting templates monthly and flag any items in need of further investigation with the contractor. Anticipated Completion Date: 9/30/2024 Responsible Contact Person: Natalie Dean Wood and Dr. Avani Sheth

2022-004 ? Enrollment Reporting Cluster: Student Financial Assistance Sponsoring Agency: Department of Education Award Names: Federal Pell Grant Program and Federal Direct Student Loans Award Numbers: Not applicable Assistance Listing Titles: Federal Pell Grant Program and Federal Direct Student Loans Assistance Listing Numbers: 84.063 and 84.268 Award Year: 2021-2022 Pass-through entity: Not applicable Campus 1 The mismatch between the enrollment effective dates on the campus-level and program-level reports identified by PwC auditors occurred due to a bug in the Campus Solutions system during the calculation of enrollment status change dates. The campus-level status date was sometimes incorrectly set as blank, which was then set to the term start date by NSLDS import process. As of September 14, 2022, the Office of the Registrar has modified the program that creates the NSLDS data file to correct the blank status dates, removing the mismatches that were found by PwC auditors. This ensures that the campus-level and program-level effective dates match. Campus 2 Historically, reporting to the National Student Clearinghouse (the ?Clearinghouse?) of students? enrollment status, e.g., full-time status, has been accomplished via enrollment files. These files are submitted at least every 30 days to ensure changes in enrollment status, especially withdrawals, are captured in a timely manner. To update enrollment status to graduated, two other processes have been relied upon: ? The first process uses Graduates Only files. Relying on the Clearinghouse?s advice, Graduates Only files are submitted for spring quarter only. ? The second process is the degree file submissions to support third-party verification of students? degrees through the Clearinghouse. When a degree file is submitted, the enrollment status should be updated to graduated. The issue exists with the second process where, for a variety of reasons, the Clearinghouse process does not successfully update every enrollment record with a graduated status when the degree file is submitted. These problems typically occur when students have been in more than one Clearinghouse branch, such as medical students in more than one degree program, students receiving their degree in a quarter in which they were not registered, and students who do not have a SSN. The campus began to recognize these problems in the summer of 2022 and had already decided to utilize a feature available in the quarterly Clearinghouse enrollment reporting to send a graduated status, rather than full-time status, whenever a student has graduated. This change, which is scheduled to be implemented in March 2023, will resolve most of the issues in which students may not have been reported to NSLDS as graduated. Effective immediately, error reports will be methodically checked and resolved after degree files are submitted to the Clearinghouse to ensure that enrollment records are updated for every student. By adjusting and coordinating the timing and sequencing of file submissions, the number of ?false? errors will be greatly reduced, and the error resolution process will be manageable. The resequencing of files submission will begin with the Spring 2023 semester. These two steps, in addition to the continuation of enrollment and degree reporting, should eliminate cases of students not being reported to NSLDS as graduated. For inquiries regarding this finding, please contact Cruz Grimaldo (510) 316-2932 and Jerry Lopez at (415) 476-4181 who are responsible for the corrective action.

2022-002 Economic Injury Disaster Loan ? Assistance Listing No. 59.008 Recommendation: The School should implement procedures to ensure that information in the loan application is accurate. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Operations Manager, Outside Accounting Firm, Head of School, and Board Chair will review loan applications to ensure accuracy prior to submission. Name(s) of the contact person(s) responsible for corrective action: Aaron Fielding (323) 850-3755 Planned completion date for corrective action plan: Completed as of April 4, 2023.

Finding 2022-002: Section 202 Supportive Housing for the Elderly, Capital Advance and Project Rental Assistance Contract, ALN 14.157; HOME Investment Partnerships Program, ALN 14.239 Anticipated Completion Date: September 30, 2023 Recommendation: It was recommended Sessions Village 202 complete new HUD-50059-A forms for residents where the form was missing from their file. After the new HUD-50059-A forms are completed, it was recommended Sessions Village 202 contact their HUD account executive and determine the corrective action needed to revise the housing assistance payment vouchers, if necessary. Also, it was recommended staff involved in the tenant eligibility process review the requirements and revise their current internal controls over tenant eligibility needed to ensure the appropriate procedures are performed going forward. Action Taken: Sessions Village 202 obtained the new HUD-50059-A form effective June 6, 2022 for one of the residents where it was missing. The second resident has moved out of the community, and therefore they are unable to obtain the document. Sessions Village will contact their HUD account executive and determine the corrective action needed to revise the housing assistance payment vouchers. The Property Manager will implement controls to ensure the appropriate forms are completed correctly and are kept in the files going forward.

Finding 2022-001 - Allowable Costs/Costs Principles - Ineligible Wire Transfer ALN - 14.182, Noncompliance & Material Weakness Corrective Action Plan: ALL subsequent requests for wire transfers will be immediately verified with the person(s) or company that has requested the wire transfer. In addition, the Authority will strongly discourage the use of wire transfers. Person Responsible: Connie Stewart - Executive Director Anticipated Completion Date: This has already been completed as soon as the issue was discovered.

Finding No. 2022 ? 009 Special Tests ? Institutional Eligibility Finding: The Conservatory did not report staff changes in the positions of Chief Financial Officer and the Financial Aid Administrator as required. Corrective Action Taken or Planned: The Office of Financial Aid and the Bursars Office will review the reporting requirements and develop formal procedure on the process of notifying the DOE of these changes. Expected completion April 2023. Responsible person Kathleen Jewett, Director of Student Accounts

Finding: 2022-017 Department of Human Services Response/Corrective Action Plan: The Department disagrees with the recommendation. NDVerify allows eligibility workers to search multiple interfaces/sources for all household members included in a LIHEAP case at the same time, however, the Department does allow for other means, such as hard copy verification from the applicant or a third-party, to support eligibility determinations. It is important to note, since fully transitioning to SPACES, no errors have been noted. Contact Person: Rachel Iverson Schafer Director of Program Administration Anticipated Completion Date ND Verify will continue to be a source for workers to utilize. FY2024 LIHEAP training will continue to train on the value of using this interface.

Finding: 2022-016 Department of Human Services Response/Corrective Action Plan: The Department agrees with the recommendation. The Department receives a monthly report of all payments made during the heating season. The report contains the case number, read/delivery date, and service code, allowing staff to identify potential duplicate payments. Staff will research potential duplicates, maintain a log and notes on each situation and any necessary follow-up with Human Service Zone eligibility workers. The Department does allow a child to be in two separate cases at the same time due to joint custody arrangements. A SPACES system enhancement will be implemented in December 2022, providing a warning edit when adding an individual that is known in another LIHEAP case. The edit serves as a notification to eligibility workers to verify that joint custody is appropriate in the case and to alert them to instances of a duplicate child when they may not have been aware. Contact Person: Rachel Iverson Schafer Director of Program Administration Anticipated Completion Date: Effective January 18, 2023, the system will give a warning if a client is active in another case. This will give the worker an opportunity to research and use policy to determine which case(s) the client should be in.

Finding: 2022-015 Department of Human Services Response/Corrective Action Plan: The Department agrees with the recommendation. The Department will ensure eligibility workers are properly trained to determine and verify eligibility for households that are NOT vulnerable as they are receiving rent-free housing that includes the cost of fuel (for heating). Contact Person: Rachel Iverson Schafer Director of Program Administration Anticipated Completion Date: Update policy for FY2024 heating season and include in the FY2024 training. Updated policy by October 1, 2023. Training to be completed by October 29, 2023.

Department of Health Finding: 2022-005 Department of Health Response/Corrective Action Plan: The Public Health Division of the Department of Health and Human Services (formerly Department of Health) agrees with the recommendation. Procedures and additional internal controls have been added to ensure all required award information is communicated to subrecipients, to the extent this information is available. Contact Person Karol Riedman, Assistant CFO Anticipated Completion Date Completed

AIS Documentation for Title I Students Condition: The District had fifteen students Title /folders which were lacking documentation to meet the District's Academic Intervention Service ("AIS") internal control plan to show and track the students ' progress. Cause: Some AIS of the teachers and staff were not good about printing the students' progress notes and putting the info in the students AIS folder to keep track of the students' progress. Corrective Action: AIS Student progress will be entered into RT/ Direct (electronic folder tracking system) on a quarterly basis by AIS providers. The information entered will be used to assess the students' progress and the need/or adjustments in academic interventions provided. In addition, reports from RT/ Direct will be utilized to ensure only Title eligible students are receiving the Federal assistance. Corrective Action Implemented by: The Corrective Action will be implemented by the Director of Curriculum, Instruction and Technology. Correction Action Implementation Date: The Corrective Action will implemented immediately, with notes being required in all AJS student. Files by the end of the third quarter of the 22-23 school year.