Corrective Action Plans

The Department of Human Services (DHS) agrees with the findings that appropriate actions were taken to approve the case, however, the reviewing supervisor failed to update the Supervisory Case Review form with 1) date the discussion was held with the eligibility worker, the date the eligibility worker made corrections, and the date the eligibility worker review was completed and 2) failed to enter comments on “No” responses on various questions. DHS will enforce current policies and procedures and will ensure that Supervisory Case Reviews are updated and double-checked by the supervisor once the eligibility worker make the corrections prior to OSSE’s report being submitted to reflect the accurate information. The corrective action plan developed for the Child Care Services Division (CCSD) is to conduct refresher training with the CCSD Supervisory Leadership Team on the requirements for the supervisors reviewing the case files. The supervisors will double-check the Supervisory Case Review forms to ensure it is completed in its entirety including all recommended corrections. The 2nd level reviewer will make sure the Supervisory Case Review forms are correct and reflect the findings and corrections. The Supervisory Case Review form will be revised. Contact: Ann Pierre, Deputy Administrator, Division of Customer Workforce Employment & Training (DCWET) Estimated Completion Date: September 30, 2025 See Corrective Action Plan for chart/table

The Department of Human Services (DHS)/Economic Security Administration (ESA) concur with the findings. The TANF corrective action plan outlines several key actions to enhance compliance and reduce improper payments. First, policies and procedures will be updated to mandate responses to all eligibility questions and require verification of documentation before case approval. System enhancements in DCAS will introduce validation rules to prevent incomplete submissions and block duplicate payments without supervisory clearance. Staff will receive mandatory refresher training focused on documentation requirements and proper DCAS data entry and verification processes. Felony Conviction questions are asked in the Integrated paper benefits application. DCAS system updates are needed to the DCAS online and case worker portal IEG scripts. Contact: Francine Miller, Deputy Administrator Estimated Completion Date: September 30, 2026 See Corrective Action Plan for chart/table

The Office of the Deputy Mayor for Planning and Economic Development (DMPED) does not concur with the auditor’s finding regarding the allowability of rent per the CPF guidance. DMPED’s current grant procedures include a legal review and analysis by its Office of General Counsel (OGC) to determine activities that are allowed or unallowed and allowable costs/cost principles to ensure only allowable expenses are charged to federal programs as required under 2 CFR Section 200.403. Before DMPED approved the payment of rent for the Whitman-Walker Saint Elizabeth’s Expansion project, DMPED OGC had conducted legal analysis and determined that payment of rent qualifies as an allowable cost. DMPED had also received Treasury approval the summer prior (July 2024) for ancillary costs needed to operationalize the capital asset. As part of its Corrective Action Plan, DMPED will commit to seeking expressed approval from the awarding Federal agency in cases where the project guidance may be unclear and where DMPED OGC has interpreted the guidance, in order to validate DMPED’s interpretation. As a result, DMPED will take the following steps outlined below: 1. Evaluate its procedures in identifying Activities Allowed or Unallowed and Allowable Costs/Cost Principles to ensure only expressly allowable expenses are charged to the program as required under 2CFR Section 200.403. Estimated Completion Date: July 6, 2025 2. Add internal controls and policies that include clearer protocols around seeking awarding Federal Agency approval in cases where DMPED OGC has interpreted the guidance, in order to validate DMPED’s interpretation of generalized categorical guidance. Estimated Completion Date: August 6, 2025 Contact: Darya Razavi, Program Manager, Office of the Deputy Mayor for Planning and Economic Development See Corrective Action Plan for chart/table

The Office of the Chief Financial Officer/Office of Finance and Treasury (OCFO/OFT) for Department of Human Services (DHS) concurs with this finding. The process to manage card distribution is manual, utilizing paper forms. UPO is evaluating the current policy and procedures to identify areas for improvement, including additional validation steps. Any updates to the policy and procedures will be documented in the EBT Program Manual and shared with the District. Employees will be held accountable for their performance in following the policy and procedures as documented in the EBT Program Manual. The Quarterly UPO internal audits, and the Quarterly Regis audits will continue to assist in identifying areas for improvement. The EBT Manager and Supervisors will define and implement a process for additional review and validation of the daily paperwork with the Card Production Specialists to ensure compliance of policy and procedures. Contact: Joseph Cobb, Contracting Officers Technical Representative (COTR) and Payment Operation Center Manager Estimated Completion Date: September 30, 2026 See Corrective Action Plan for chart/table

The Department of Human Services (DHS) and Department of Health Care Finance (DHCF) DC Access System (DCAS) team agree with the findings. For the twelve (12) findings, DHS/ESA has identified the description of the deficiencies, examined the magnitude and geographic extent of the deficiencies, identified the actions completed to eliminate the deficiencies. The District will focus on efforts that will create the maximum impact, which includes creating new options for collaboration, streamlining current communication, and introducing cross-functional prioritization. These strategies will help the District move projects toward completion and are rooted in continuous quality improvement. To guide its strategic efforts and track its impact, DHS has outlined the following four phases of corrective action plans to be taken to ensure the deficiencies will be eliminated: • Review and Prioritization, • Design and Development, • Implementation, and • Monitor and Evaluation. Each phase has several process steps including a completion document that signals the permission to move to the next phase. The detailed process steps are documented under DHS’ Consolidated Semi-Annual SNAP Advance Warning Letter Corrective Action Plan and FFY2025 Quality Control Corrective Action Plan reports. The corrective action plan is facilitated by the Quality Improvement Program and since implementing this process in January 2021, the District has identified root causes for errors and gaps in internal auditing and evaluation processes. Therefore, the flow of the semi-annual corrective action plans reflects the District’s commitment to a collaborative corrective action plan - expanding the data analysis section to include data and analysis of internal methods, a complete summary of each phase completed, and a timeline for upcoming phase/project completion. Contact: Stephanie Bloch-Newman, Deputy Administrator for Innovation & Change Management Estimated Completion Date: September 30, 2026 See Corrective Action Plan for chart/table

Name of Auditee: Town of Huntington Housing Authority Name of Audit Firm: EFPR Group, CPAs, PLLC Period Covered by the Audit: September 30, 2024 CAP Prepared by: Steve Nakano, Executive Director Phone: (631) 427-6220 (A) Current Finding on the Schedule of Findings and Questioned Costs (2) Finding 2024-002 (a) Comments on the finding and recommendation - The Authority agrees with the finding. The Authority also agrees with the recommendations, please see below for action taken. (b) Action taken - The Authority will conduct a thorough review of all tenant files to identify and resolve missing documentation, including signed applications, lease agreements, proof of citizenship or eligible immigration status, independent income verification, HUD forms (50058 and 9886), rent reasonableness documentation, and HQS inspection records. Staff will work to obtain missing documents from tenants, landlords, or other necessary parties. A standardized checklist should be used to ensure all required items are present in each file moving forward. (c) Planned implementation date of corrective action - Completed by September 30, 2025.

Dear Cognizant or Oversight Agency for Audit: The Women’s Home respectfully submits the following corrective action plan for the year ended December 31, 2024. Name and address of independent public accounting firm: Doeren Mayhew Assurance, 2600 North Loop West, Suite 2600 , Houston TX, 77092. The finding discussed below from the Schedule of Findings and Questioned Costs (the schedule) for the year ended December 31, 2024 is numbered consistently with the number assigned in the schedule. Federal Award Finding 2024-001 Corrective Action Plan: We will incorporate quarterly audits of income verification by our grants compliance manager. Regular chart audits by the program team will be conducted to review all documents and re-certify as necessary. Contact Person Responsible for Corrective Action: Ms. Anna Coffey, Chief Executive Officer Anticipated Completion Date: Respectfully submitted, Ms. Anna Coffey Chief Executive Officer

Responsible Official’s Response: The City acknowledges the deficiency and has taken measures to prevent this from occurring again. The City has engaged the services of an Interim Finance Director who is experienced and skilled in governmental accounting. The Interim Finance Director will remain with the City through the FY2025 audit and will be responsible for the audit and any single audits for this fiscal year. In addition, the City will retain the Interim Finance Director to train current and future staff to ensure the City is in compliance with any and all current and future federal, state and local grants.

Responsible Official’s Response: The City acknowledges the deficiency and has taken measures to prevent this from occurring again. The City has engaged the services of an Interim Finance Director who is experienced and skilled in governmental accounting. The Interim Finance Director will remain with the City through the FY2025 audit and will be responsible for the audit and any single audits for this fiscal year. In addition, the City will retain the Interim Finance Director to train current and future staff to ensure the City is in compliance with any and all current and future federal, state and local grants.

Reference Number: 2024-002 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Housing Choice Cluster Federal Catalog Number: 14.871 and 14.879 Federal Grant Number: Not Applicable Category of Finding: Eligibility Classification of Finding: Material Weakness in Internal Control over Compliance Material Noncompliance Authority’s Response & Actions Taken The Authority has made considerable progress in addressing the backlog of annual re-examinations that resulted from the transition of a third-party contractor to new third-party contractors to administer its Project-Based and Tenant-Based Voucher Programs. The material weakness was further exasperated by tenants not responding to re-examination notices or failing to provide the required income and household documentation by established deadlines. In an effort to avoid unnecessary subsidy terminations and protect vulnerable tenants, the Authority’s administrative plan allows for extended grace periods and repeated follow-ups. While this tenant-centered approach helped mitigate adverse outcomes for families, it also contributed to delays and ultimately resulted in noncompliance with HUD’s timeliness requirements. The Authority recognizes the critical importance of conducting timely and accurate annual reexaminations to maintain program integrity, ensure proper subsidy determination, and remain in compliance with HUD regulations. With that said, the Authority continues to work diligently with its third-party HCV contractors, city department partners, onsite service providers and property management companies to ensure the Authority is timely recertifying all assisted households. Although the Authority has established procedures to initiate reexaminations 150 days in advance of their due dates, a significant portion of the delays cited in the recent audit were the result of tenant non-responsiveness—specifically, the failure to provide required documentation despite multiple notices and outreach efforts. Importantly, all overdue reexaminations identified during the audit were ultimately completed. Each of the affected households was determined to be eligible under HUD guidelines, and housing assistance payments (HAPs) were accurately processed based on verified household information. The Authority remains committed to its tenant-centered mission, which prioritizes preventing unnecessary subsidy terminations and supporting household stability. At the same time, the Authority fully recognizes the importance of complying with HUD’s reexamination timelines. The corrective actions outlined below are designed to ensure that tenant-related delays are minimized, documented, and managed in a way that prevents the recurrence of this material weakness. To address this finding and in accordance with the Authority’s Administrative Plan and HUD rules and regulations, the Authority has already implemented the following actions starting fiscal year 2023-24: • Initiating the Annual Re-examination process 150 days before the required anniversary date to give households more time to comply. • Reviewing the report of outstanding Annual Re-examinations on a weekly basis. • Scheduling additional partner calls with property management and resident services to assist non-compliant families. • Enforcing Annual Reexamination compliance through the Intent to Terminate process • Scheduling and completing on-site visits for senior-disabled sites and non-restricted sites with large numbers of families out of compliance. • Reviewing discrepancies between the Authority’s System of Record and PIH Information Center, the official database of HUD. Per CFR 24 985.3, Section 8 Management Assessment Program (SEMAP) Indicator 9 for Annual Reexamination, 95% of all households must be recertified within 14 months of their last annual recertification to maintain full compliance, and 90% of all households must be recertified within 14 months to maintain partial compliance with the SEMAP Assessment standards required by HUD. The Authority expects to hit 90% by the end of the SEMAP year September 30, 2025. Anticipated Implementation Date September 30, 2025 Name(s) and Title(s) of Contact Person(s) Responsible for Correction Action HCV Contractors Kendra Crawford, Director of Housing Operations

The Management of the Authority agrees with the findings; we will implement improved internal controls to ensure that all annual recertifications are performed in a timely manner and that all required documents are kept in an organized manner. The Authority hired a Compliance Specialist in May 2025 to perform quality control checks on the files to eliminate errors. The HCV Program Director is the responsible party, and controls will be in place by the end of the September 30, 2025 fiscal year.

The Management of the Authority agrees with the findings; we will implement improved internal controls to ensure that all annual recertifications are performed in a timely manner and that all required documents are kept in an organized manner. The Authority hired a Compliance Specialist in May 2025 to perform quality control checks on the files to eliminate errors. The Public Housing Director is the responsible party, and controls will be in place by the end of the September 30, 2025 fiscal year.

Planned Implementation Date of Corrective Action: July 2025 Person Responsible for Correctove Action: Krishonna Murray, Executive Director I. 2024-001 Eligibility Rent Calculation Other Matter/Significant Deficiency The Authority had instances of missing income verifcation. Gardner Housing Authority has establised a system of internal control over the participant recertification process that meets HUD's requirements. Seven (7) to ten (10) files will be reviewed fiscally for quality assurance.

FINDING No. 2024-003: Section 202 Supportive Housing for the Elderly, ALN 14.157 Recommendation: The Project should implement procedures to ensure all documentation related to applicants and tenants are properly executed and maintained, and that the manager verifies eligibility by obtaining all required documents for potential tenants while verifying and maintaining support for tenant income eligibility through the EIV system in a timely manner. Action Taken: Staff training has been provided with additional HUD training inclusive of EIV reporting and tenant file maintenance and included in monthly reporting procedures. If the Oversight Agency for Audit has questions regarding this plan, please call Irene Phillips at 954-835-9200. Sincerely yours, Irene Phillips, CFO Irene Phillips CFO

Corrective Action Plan Details Finding Number: 2024-002 Program: Disaster Grants - Public Assistance (Presidentially Declared Disasters) Assistance Listing Number 97.036 Federal Emergency Management Agency Passed through Mississippi Emergency Management Agency Responsible Official: Adam Moore, CFO Finding Detail: Expenses reimbursed from other sources and unsupported expenses were not identified. Appropriate calculations of cost formulas were not utilized for medication reimbursement amounts claimed. Corrective Action Planned: Management concurs with the finding and will implement additional internal controls over the identification of eligible expenditures for the Disaster Grants program. Expenditures identified as potential grant program expenditures will be reviewed by the controller, and final approval of each expense by the chief financial officer to ensure they are eligible expenses and have not been reimbursed by any other sources. We anticipate these additional controls to be in place by September 30. 2025. The Chief Development Officer will oversee the corrective action. Anticipated Completion Date: September 2025

Expenditures submitted for the Alabama Medicaid Administrative Claiming Program included expenditures suppported by federal funds and undocumented costs. Contact Person: Dr. Brock Nolin, Superintendent Corrective Action: Claims will be adjusted to correct the duplication of federal funds and undocumented costs. Policies and procedures will be implemented according to the recommendations found in the Schedule of Findings and Questioned Costs. Proposed Completion Date: Prior the submission of the July-September 2025 claim.

Re: FY23-24 Federal Single Audit Finding (2024-001) Name(s) of Contact Person(s) Responsible for Corrective Action: Sean Perez, Finance Director; Jeff Gilbreath, Executive Director Hawaiʻi Community Lending (HCL) is diligent and ensures all grant requirements are met for Federal, State, and private funding awards. Due to the transitioning of its Finance Directors upon the start of the FY23-24 audit, the proper procedures to correct the CDFI ERP project account were miscommunicated, and the Schedule of Expenditures for Federal Awards (SEFA) were not reduced to reflect the proper adjustments. The corrective action being taken by HCL leadership is to ensure all loans disbursed and charged to restricted grants are reviewed thoroughly by the Finance Director. The Finance Director will review all eligibility requirements that are met, to include the eligible mapping area, as required and provided by the funder. This thorough review of eligibility will ensure that all loans charged to restricted funding will be properly allocated and charged correctly. In addition to the thorough review mentioned above, HCL will develop procedures to review the SEFA, in detail, which is prepared by a third-party accounting vendor. The procedures will include an extensive review of expenditures by the Finance Director and subsequent review and approval by the Executive Director to ensure all expenses are eligible and allocated properly to our federal grants. Once the SEFA has been fully reviewed and approved by the Finance Director and Executive Director, it will be forwarded to the auditors. Additional staff may be involved in the review and eligibility confirmation process to ensure accuracy. Internal audits of expenditures will also be completed on a quarterly basis. The anticipated completion date of this corrective action plan is June 30, 2025. Mahalo, Jeff Gilbreath Executive Director Hawaiʻi Community Lending

The Division will contact each unit distributing TEFAP assistance and communicate the requirement to retain documentation regarding the determination of client eligibility. This was also reviewed during the NW Division’s Social Service conference in April 2025. Anticipated Completion Date: 10/1/25. Responsible Contact Person: Julie Luft, NW Social Services Director

South Landry Parish Housing Authority P.O. Drawer E Grand Coteau, LA 70541 Phone: (337) 662-3573 Fax: (337) 662-3583 HOUSING AUTHORITY OF SOUTH LANDRY PARISH, LOUISIANA CORRECTIVE ACTION PLAN YEAR ENDED DECEMBER 31, 2024 Corrective Action Plan Finding: Finding 2024-001-Re-examination Of Tenant Eligibility and Rent Not Timely Done-Special Tests Condition: Tenant eligibility and rent should be examined on an annual basis, as required by federal regulations. Corrective Action Planned: I am Denise Moore, Executive Director and Designated Person to answer this audit finding. We will do as the auditor recommends and timely do the re-exams in the future. Person responsible for corrective action: Denise Moore, Executive Director Telephone: (337) 662-3573 South Landry Parish Housing Authority Fax: (337) 662-3583 P.O. Drawer E Grand Coteau, LA 70541 Anticipated Completion Date: December 31, 2025

Views of Responsible Officials: Prior to receiving this finding in the prior year, HIPS was not in the practice of saving documentation of financial or programmatic reporting submission. Staff responsible for submissions are now documenting submission of reports as of 2024. HIPS Finance Manager has been tasked with checking all spreadsheet calculations prior to submissions of financial reporting.

Park City has implemented a secure, digital document management protocol requiring that all income verification forms and re-examination documents be scanned and stored within Yardi, our newly adopted digital management system. This transition ensures that all records are accurately maintained, securely stored, and readily accessible for audits and inspections. By digitizing these critical documents, we are enhancing regulatory compliance, reducing administrative inefficiencies, and strengthening data integrity. This approach aligns with best practices for record retention and enables swift retrieval of documentation to meet oversight and inspection requirements Contact: Jillian Baldwin Email & Phone Number : jbaldwin@oarkcitycommunities.org (203) 337-8900

A memo relating to HUD and PHA verification requirements has been issued to staff. Utility allowance schedule set up in software has been confirmed for accuracy. Staff has been reminded to ensure appropriate Utility Schedule is applied during processing of transactions. Internal quarterly Quality Control reviews are also in place. Contact: Jillian Baldwin Email & Phone Number : jbaldwin@oarkcitycommunities.org (203) 337-8900

View of Responsible Officials and Corrective Actions: The following steps have been and are being taken regarding tenant certifications: 1. We issued a Request for Proposals for a third-party Contractor to perform all recertifications. We intend to award this Contract in July 2025. 2. All Managers and assistant Managers will use the third-party Contractor to learn proper recertification and documentation procedures.

Finding 2024-013 Medicaid Cluster, ALN 93.775, 93.777, and 93.778 and Children's Health Insurance Program, ALN 93.767 - Expenditure Processing for Medical Payments Management Views MDHHS agrees with the finding. Planned Corrective Action MDHHS has been working to ensure correct eligibility classifications in Bridges at the time of payment and a system change was implemented in April 2021 to correct the issue. All new cases are correctly routed. MDHHS is continuing to update cases following the end of the public health emergency (PHE) and expects that all existing cases will be updated by July 2025, as MDHHS completes a mass update and renewals for existing cases. MDHHS identified and updated its manual process of transferring expenditures from the Medicaid Cluster to the Children’s Health Insurance Program in June 2021; and will continue this manual process, on a quarterly basis, by completing a summary-level adjustment determined by analyzing CHAMPS payment data and Bridges eligibility data until all existing cases have been updated. Anticipated Completion Date July 2025 Responsible Individual(s) Brant Cole, MDHHS Logan Dreasky, MDHHS Crystal Kline, MDHHS

Finding 2024-055 Low-Income Home Energy Assistance, ALN 93.568 - Eligibility Determinations Management Views MDHHS agrees with the finding. Planned Corrective Action MDHHS implemented quarterly case reads beginning in fiscal year 2023, and during April 2023, MDHHS began monthly meetings with the BSC analyst team to discuss common errors, answer questions, provide guidance, and on a quarterly basis discuss the results of the State Emergency Relief (SER) case reads. During April 2024, MDHHS SER program policy management and staff began attending BSC leadership meetings to discuss SER case read data findings, policy changes, and communicate common errors found during audits. In addition to updating verification requirements on October 1, 2023, SER program policy management and staff added copay verification requirements on October 1, 2024. MDHHS completed system updates during April 2024 to allow specialists access to directly upload verification documentation to the electronic case file instead of providing the documentation to other areas to process and upload. MDHHS will provide annual training directly to counties that fail to meet the state average for SER case reads relating to verification of the client's income, client contribution payment, and proof of energy crisis. MDHHS will continue to communicate with BSCs and local offices regarding the requirements to obtain adequate verification and maintain sufficient documentation to support SER processing. MDHHS will also continue to provide direct SER guidance and clarification through the SER mailbox. Anticipated Completion Date September 30, 2025 Responsible Individual(s) Bethany Cabanaw, MDHHS Kent Schulze, MDHHS Julie McLaughlin, MDHHS