Corrective Action Plans

The Corporation contacted the local Continuum of Care and regional HUD office in an effort to verify the required number of units occupied by individuals meeting the definition of "homeless". The local Continuum of Care had no record of the original grant agreement or required number of "homeless" to be served. The Corporation contacted three staff in the regional HUD office, including the staff that had been our representative for annually renewed operation and support service grants for the two projects. Regional HUD staff were not able to provide a copy of the original grant agreements which would indicate the number of persons to be served by each project. HUD staff stated that they do not keep copies of grant agreements longer than seven years. Corporation management will continue to work with HUD personnel to determine the continuing compliance requirements of the Continuum of Care funding received for initial construction or rehabilitation. Corporation management will continue to serve individuals meeting the definition of homelessness at its two projects and document evidence in the file.

Finding: 2022-004 Name of Contact Person: Carolyn Moser, Health & Human Services Director Corrective Action/Management?s Response: Audit Finding Review Training is held with Family and Children's Medicaid to review Audit results and errors found. Verification sheet for F&C Medicaid are reviewed. This form is to be used for every application and recertification. Additional trainings/unit meetings are also held throughout the year. Areas covered are review of: Child Support referrals, income, verification of Social Security Number, tax household, household relationship, reacting to changes, addresses, and OVS. Ongoing trainings continue. Individual conferences are held with each worker with an error. During the conference, the case record is reviewed along with policy, error explanations and steps to take to prevent error from reoccurring. Each quarter Pender County is required to submit to the State a Quarterly Report of cases 2nd party reviewed along with verification of trainings held, agendas and attendance sheets. Pender is required to review over 120 cases per quarter. There are 4 Medicaid Supervisors. Each month supervisors pull cases from each worker to 2nd party review. Supervisors meet with each worker that they have an error or internal control issue. Errors and internal control issues are discussed monthly at Unit meetings. Policy, manual changes, Admin letters, job aids and other information are also discussed and reviewed monthly during Unit meetings. Proposed Completion Date: Immediately and ongoing. Finding: 2022-005 Name of Contact Person: Carolyn Moser, Health & Human Services Director Corrective Action/Management?s Response: The County has corrected and resubmitted the impacted report and continues to pay close attention to detail when compiling all of the data for payroll calculations. Once resubmitted, there were no monies owed, just minor adjustments in allocations between programming. Additionally, the Business Officer has worked with the Internal Audit Compliance Officer in the Finance Department to strengthen the excel formulas and lessen the inherent opportunity for errors. Finance also implemented additional checks during the 1571 monthly review process to ensure elimination of any such errors prior to submission. Proposed Completion Date: Immediately and ongoing. Finding: 2022-006 Name of Contact Person: Carolyn Moser, Health & Human Services Director Corrective Action/Management?s Response: The County, much like other local governments around the State and Country, has experienced turnover from employee resignation and longterm employee retirements. The County met requirements for 2nd party reviews when program supervisor positions were filled, and in the future will ensure that there is a back up or at least a look back period for 2nd party reviews for periods of SNAP program supervisor vacancies. Proposed Completion Date: Immediately and ongoing. Finding: 2022-007 Name of Contact Person: Carolyn Moser, Health & Human Services Director Corrective Action/Management?s Response: The County, much like other local governments around the State and Country, has experienced turnover from employee resignation and long-term employee retirements. The County met requirements for 2nd party reviews when program supervisor positions were filled, and in the future will ensure that there is a back up or at least a look back period for 2nd party reviews for periods of LIHEAP program supervisor vacancies. Proposed Completion Date: Immediately and ongoing.

Name of Contact Person: Carolyn Moser, Health & Human Services Director Corrective Action/Management?s Response: The County, much like other local governments around the State and Country, has experienced turnover from employee resignation and long-term employee retirements. The County met requirements for 2nd party reviews when program supervisor positions were filled, and in the future will ensure that there is a back up or at least a look back period for 2nd party reviews for periods of LIHEAP program supervisor vacancies. Proposed Completion Date: Immediately and ongoing.

Name of Contact Person: Carolyn Moser, Health & Human Services Director Corrective Action/Management?s Response: The County, much like other local governments around the State and Country, has experienced turnover from employee resignation and long-term employee retirements. The County met requirements for 2nd party reviews when program supervisor positions were filled, and in the future will ensure that there is a back up or at least a look back period for 2nd party reviews for periods of SNAP program supervisor vacancies. Proposed Completion Date: Immediately and ongoing.

The McAllen Chamber of Commerce will develop and adopt a written policy that clearly defines the procedures and requirements for suspension and debarment verification, in alignment with 2 CFR 200, for current and future programs that are directly and indirectly funded through federal grants. In addition, the McAllen Chamber of Commerce has retroactively verified suspension and debarment verification, in alignment with 2 CFR 200, of recipients that have received funding. No recipients, who received federal grants, were found to be In suspension and debarment.

A. Current Findings on the Schedule of Findings and Questioned Costs 1. Finding 2022-001 a. Comments on the Finding and Each Recommendation We agree with the finding and the auditor's recommendation has been adopted. b. Action(s) Taken or Planned on the Finding Management agrees with the finding. In addition to hiring a new Director of Compliance and rebuilding the compliance team in 2021 to review and approve certifications, we have increased our corporate operations team and they are now responsible for reviewing all certification due dates weekly with the site teams to ensure timely completion of certifications.

CORRECTIVE ACTION PLAN July 27, 2023 United Stated Department of Health and Human Services Northern Oswego County Health Services, Inc. d/b/a ConnextCare respectfully submits the following corrective action plan for the year ended December 31, 2022. Cohn Reznick LLP 350 Church Street Hartford, CT 06103 Audit Period: December 31, 2022 The findings from the December 31, 2022, schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FEDERAL AWARDS FINDINGS AND QUESTIONED COSTS SIGNIFICANT DEFICIENCY 2022-001 - Sliding Fee Scale Discount Recommendation The Center should establish a system of internal controls to ensure that all sliding fee discounts are properly calculated based on family size and income. Action Taken ConnextCare as established the following system of internal controls, effective immediately: 1) Monthly internal audits of new patient records being entered into our practice management system. This review will ensure the proper character (U) is entered into the Sliding Fee Scale tab. 2) Review of accounts when new Income Verification forms are received from the patients to ensure that reported income aligns with the practice management system. In addition, perform monthly audits of 25 active Sliding Fee Scale patients for proper Slide percentage and calculation. 3) Additional training provided to all Patient Access Representatives, Medical and Dental Billing Staff on proper calculation of a self-pay eligible sliding fee scale patient. If the Cognizant or Oversight Agency for Audit has questions regarding this plan, please call: Tracy Wimmer, CFO at (315) 298-6569, ext. 2020. Tracy Wimmer Sr. VP/Chief Financial Officer

The Authority has attempted to segregate accounting duties by having a person who does not initiate, prepare or post disbursements review the bank statements and co-sign all checks. The Authority will continue to monitor its policies and procedures in an effort to improve control efficiencies, however, at this time, the Authority has determined that the cost of eliminating the deficiency would exceed its benefit.

U.S. Department of Housing and Urban Development 2022-001 HOME Investment Partnerships Program ? Assistance Listing No. 14.239 Recommendation: We recommend that policies and procedures are implemented to ensure required certifications are completed and reviewed in a timely manner as required by HOME regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management has hired additional staff in the Compliance Department for internal audits of files. Certification status is checked on a weekly basis for all funding program. Training of compliance requirements takes place during the onboarding process for all employees. Name(s) of the contact person(s) responsible for corrective action: Flo Beaumon Planned completion date for corrective action plan: January 1st, 2023

FINDING 2022-003 Contact Person Responsible for Corrective Action: Kasey Clark Contact Phone Number: 574-772-1604 Views of Responsible Official: We concur with the findings. Description of Corrective Action Plan: The income guidelines will be uploaded into the food service system after printing off the government site and two people will have eyes on them and this has started for 2022/2023. Anticipated Completion Date: March 2023

Department: Health and Human Services Title: Internal control over deceased client cases and claims analysis needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The Department will complete a review of claims identified by OSA and if that analysis suggests that procedures need to be enhanced, the Department will do so. Completion Date: May 31, 2023 Agency Contact: Anthony Pelotte, Director, Office for Family Independence, DHHS, 207-624-4104

Department: Health and Human Services Title: Internal control over cost of care assessments needs improvement Questioned Costs: Undeterminable Status: Management?s opinion is that corrective action is not required Corrective Action: The Department agrees with the two exceptions found by the Office of the State Auditor. However, we believe that the Department has reasonable assurance with the controls in place that results in a 97% compliance rate with the COC calculations, which is a 2% increase from last year. In the prior year's finding the Department committed to continuing to achieve a 95% compliance rate and CMS agreed with the Department and closed the prior finding. No corrective action is necessary as a result of an error rate of only 3%. The Department will continue to actively manage and monitor the Cost of Care system in compliance with federal regulations. Completion Date: N/A Agency Contact: Anthony Pelotte, Director, Office for Family Independence, DHHS, 207-624-4104

Department: Health and Human Services Administrative and Financial Services Title: Internal control over Medicare Part B premium payments needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The Office for Family Independence (OFI) will incorporate the CMS business change processes (ELMO portal) into the Buy-In Reconciliation standard operating procedures. OFI will implement technology improvements in support of reducing manual data entry and increased regulatory compliance. Completion Date: September 30, 2023 and June 1, 2024 respectively Agency Contact: Anthony Pelotte, Director, Office for Family Independence, DHHS, 207-624-4104

Department: Health and Human Services Title: Internal control over the CCDF Cluster eligibility determination process needs improvement Questioned Costs: None Status: Management?s opinion is that corrective action is not required Corrective Action: DHHS believes the current internal controls that are in place provide reasonable assurance that DHHS is managing the funds in compliance with all regulations. Reasons include; ? The ongoing quality assurance process is one of the major controls in place. In 2019, the OCFS Quality Assurance (QA) team, separate from the Child Care Subsidy Program (CCSP) team, comprised of 10 staff, began conducting 23 CCSP case reviews per month. This is systematic monitoring. QA uses the initial documentation submitted by the parent (applications, proof of income, etc.) and checks it against the information in the MACWIS system to ensure eligibility is calculated correctly and data was entered accurately. ? A summary of findings from the QA check is provided to CCSP management each month. CCSP management documents the needed remediation plan, with the Financial Resource Specialist (FRS) making the necessary corrections as soon as possible. Additionally, CCSP management conducts internal periodic audits of files and evaluates deficiencies. ? Information Technology Controls minimizes potential errors by utilizing pre-defined drop-down menus of approved entries. Several fields limit the number of characters allowed to be entered or only allow numeric entries. ? The Information Technology system provides an enhanced internal control that provides visual cues to enter dollar amounts. Users receive an error message if data is entered incorrectly. ? The Financial Resource Specialist Staff Manual provides detailed, step-by-step instructions of the process for entering information into the Information Technology system to ensure accuracy and consistency of data entry. Staff are trained using this manual and are provided ongoing access to the manual. Staff undergo regular training on the eligibility determination process. DHHS believes the process and technical solutions in place are a reasonable attempt to assure proper eligibility determination for CCSP funding. Completion Date: N/A Agency Contact: Todd Landry, Director of the Office of Child and Family Services, DHHS, 207-624-7900

Department: Health and Human Services Title: Internal control over TANF performance reporting and work participation procedures needs improvement Questioned Costs: None Status: Management?s opinion is that corrective action is not required Corrective Action: Due to the nature of corrective action plans, and the timing of recent edits to the standard operating procedures in February and May of 2022, a corrective action plan is not warranted at this time. Completion Date: N/A Agency Contact: Anthony Pelotte, Director, Office for Family Independence, DHHS, 207-624-4104

Department: Health and Human Services Title: Internal control over TANF client child support sanction procedures needs improvement Questioned Costs: None Status: Management?s opinion is that corrective action is not required Corrective Action: The Department disagrees with this finding. The Office for Family Independence (OFI) has sufficient internal controls in place to ensure compliance with Federal requirements. Specifically, based on the finding's stated condition, OSA did not take exception with the 22 items that were actually tested for compliance. Additionally, OFI has provided sufficient information for OSA to identify and conduct the audit and compliance testing of cases referred by DSER for sanction. The Department has provided OSA with the following material as requested: 1. The list of all sanction referrals generated by OFI-DSER, the Title IV-D agency. 2. The list of all OFI-TANF clients actually sanctioned by TANF Eligibility. 3. The list of all OFI-TANF clients 4. Copies of all emails pertaining to all sanction activity 5. Access to our Automated Client Eligibility System which includes all documented case notes. Completion Date: N/A Agency Contact: Anthony Pelotte, Director, Office for Family Independence, DHHS, 207-624-4104

Department: Health and Human Services Title: Internal control over Income Eligibility and Verification System procedures needs improvement Questioned Costs: None Status: Management?s opinion is that corrective action is not required Corrective Action: The Department disagrees with this finding. The Office for Family Independence (OFI) has conducted the required IEVS eligibility verifications. Additionally, sufficient evidence of these efforts has been provided to the Office of the State Auditor so that audit procedures can be performed in accordance with Federal regulations. OFI utilizes the Federally provided IEVS system which integrates the three named population groups (Medicaid, SNAP, TANF). The IEVS discrepancy reports have not contained Federal program indicators since program inception over 20 years ago. This is consistent with the methodology utilized by the Social Security Administration, as they too group the OFI programs together in their discrepancy reports. These same reports have been provided for prior Single Audits without being considered an exception condition. Upon request, the Department provided OSA: 1. All IEVS discrepancy reports for State fiscal year 2022, containing cases for Medicaid, SNAP, and TANF. 2. A complete listing of all TANF cases subject to IEVS in State fiscal year 2022. 3. Access to our Automated Client Eligibility System, which documents all IEVS related case notes. Completion Date: N/A Agency Contact: Anthony Pelotte, Director, Office for Family Independence, DHHS, 207-624-4104

Department: Labor Title: Internal control over UI claim payments needs improvement Questioned Costs: Known: $19,278 Likely: $2,700,000 Status: Management?s opinion is that corrective action is not required (first item) Corrective action in progress (remaining items) Corrective Action: The Department disagrees with the findings around the PUA program and the timing of the notices to provide Proof of Employment for continued eligibility. USDOL in its guidance acknowledged that it would take time to implement the new requirement from a systems and operational perspective. The Department worked diligently to implement the new requirement (along with other requirements from the CAA) as soon as possible. Furthermore, the PUA program was a one-time program created by the Federal government in response to the COVID-19 pandemic, to provide monetary support to those individuals who traditionally do not qualify for unemployment compensation benefits. All CARES Act programs, including PUA, ended in September, 2021. At this time there is no corrective action we can take, as the program no longer exists in its prior form. At most we may still see PUA eligibility as a result of a pending appeal, or court case. We will follow established processes at that time, which are based on Federal guidance provided. The Department will add a text field to obtain more information on the location of a job fair or the name of an activity when a claimant reports a CareerCenter job fair or other activity as a work search. Information will be provided to businesses through a new report for review. The Department will create a work search issue for fact-finding and possible adjudication when a claimant reports a CareerCenter Job Fair or other activity as a work search more than three times. The Department will review functionality of Vital Statistics Crossmatch to ensure that all data related to date of death for active claimants is received as timely as possible. The Department will add system controls when entering a date of birth, both for claimants and businesses to prevent avoidable data entry errors. Completion Date: June 30, 2023 (second and third items), June 30, 2024 (fourth and fifth items) Agency Contact: Laura Boyett, Director, Bureau of Unemployment Compensation, DOL, 207-621-5156

Department: Education Title: Internal control over CACFP eligibility needs improvement Questioned Costs: Known: $50,275 Likely: Undeterminable Status: Corrective action complete Corrective Action: The Department added to the check list a space for the on-site documentation for the pre-approval site visit to be uploaded into CNPWeb. The Department made the pre-site visit mandatory before the start of the program. Completion Date: March 6, 2023 Agency Contact: Jane McLucas, Director of Child Nutrition, DOE, 207-624-6880

Department: Health and Human Services Title: Internal control over the eligibility determination process needs improvement Questioned Costs: None Status: Management?s opinion is that corrective action is not required Corrective Action: The Department disagrees with this finding. The systems we have in place are both necessary and sufficient in meeting programmatic requirements to ensure accurate eligibility determinations are being made. There has been no citation of federal regulation provided by OSA during this review that contradicts this. The Department would like to note: 1. Supervisors do a minimum of 1 case reading per month and a minimum of 1 call monitoring per week for staff on phones. It is commonplace for them to do more, especially for a new employee, or known coaching issues. 2. These case readings were tracked by supervisors and units and were tracked centrally on our Streamline Management Y-Drive in SFY2022. 3. Phone calls can be referenced by Supervisors in real time or afterwards, via recording. 4. Specifics of case reading, and call monitoring were formalized with specific expectations in multiple categories, which were followed up on by coaching staff if not all of the expectations were met. With a goal of continuous improvement, it was also noted to the OSA that we formally implemented the Calabrio System which dramatically enhanced and further automated our ability to track Case Readings and Call Monitoring performance statewide in June of 2022. A corresponding user guide was also developed and implemented in June of 2022. This example of continuous quality improvement has led to a more holistic understanding of trends and training needs. Furthermore, SNAP cases are randomly selected and reviewed by USDA partially-funded SNAP Quality Control staff. These findings are reported monthly to FNS and OFI senior management. A team of QC, training, program, operations, business technology and senior management meet bi-weekly to review trends and implement solutions. These have included technological enhancements, reminder e-mails, targeted trainings, and pop quizzes. While this effort focuses on SNAP, the vast majority of SNAP cases also involve MaineCare, and some include TANF. Solutions for one program typically aid all. Completion Date: N/A Agency Contact: Anthony Pelotte, Director, Office for Family Independence, DHHS, 207-624-4104

Department: Health and Human Services Title: Internal control over automated SNAP eligibility determinations and benefit calculations needs improvement Questioned Costs: Known: $2,952 Likely: $7,686,166 Status: Corrective action in progress Corrective Action: The management of OFI will review the standard operating procedures to identify opportunities for improvement and distribute to all staff involved. Completion Date: June 1, 2023 Agency Contact: Anthony Pelotte, Director, Office for Family Independence, DHHS, 207-624-4104

Legal Services Corporation CFDA #09-742018 Legal Services Corporation -Basic Field - General CFDA #09-742018 Legal Services Corporation - Basic Field - Native American Eligibility Significant Deficiency in Internal Control over Compliance 2022-005 Condition: One instance identified in which the Grant Compliance Checklist wasn't completed as required by DPLS policy. Additionally, one instance identified in which Form 1644 Disclosure of Case Information was not completed timely, resulting in the case information not being reported to the Corporation. Auditor's Recommendation: We recommend DPLS review policies and procedures with applicable employees and remind them of the importance of established review and monitoring processes. Management's Response: All employees have received additional training on compliance procedures and new employees will receive the same. All files being closed are now reviewed first for accuracy by the case handler of that file. The files are double checked by the office secretary for accuracy. At the end of the quarter, all files are sent to compliance for a third review. Any needed corrections are noted by compliance and the file is then sent back to the office where it originated from to be corrected. Then the corrections to the file are reported back to compliance to verify that they have been made. Responsible Individuals: Dawn Marshall, Compliance Officer, Tom Mortland, Executive Director, Annemarie Michaels, Deputy Director. Anticipated Completion Date: December 31, 2023.

Item 2022-003 ? Software Access Restrictions Significant Deficiency Recommendation: New employees should be evaluated for proper software access and authority. The ability to edit subrecipient eligibility status should be limited to key partner agency personnel, and the Organization should routinely review the list of authorized users for accuracy. The organization monitors subrecipient eligibility through software. Only certain users should be having access to edit sub recipient eligibility status. In one of five selections an employee was improperly granted authority to edit subrecipient eligibility status. Management Views: Management agrees with the finding. Action Planned: New employees will be reviewed for appropriate levels of access upon Onboarding. Checklist will be maintained in department and periodically reviewed. Anticipated Completion Date: June 30,2023 Responsible Party: Ying Thao, IT Director

Finding 2022-009 Inadequate Request for Information Name of contact person: Theressa Smith, Deputy Social Services Director Corrective Action: Training completed on August 23, 2022. Electronic verifications and hierarchy of verifications was discussed with all Medicaid Staff. A follow up training will be scheduled for the first quarter of 2023. Agency will continue to complete second party reviews to monitor compliance with Medicaid policy. Agency will conduct quarterly trainings to address accuracy. Agency will send a monthly email reminder to address trending errors. Proposed Completion Date: By March 31, 2023 and ongoing

Finding 2022-008 Untimely Review of SSI Termination Name of contact person: Theressa Smith, Deputy Social Services Director Corrective Action: Training completed on November 3, 2022. Policy MA-1000 and MA-1100 was discussed with all Adult Medicaid Workers. Job aids and powerpoint from The Learning Gateway were reviewed and distributed to all Adult Medicaid workers. Proposed Completion Date: November 3, 2022 and ongoing