Corrective Action Plans

Finding 2022-002, Material Weakness - Eligibility Corrective Action Plan: Goal: To ensure eligibility determination related to income documentation and calculation is completed appropriately for all applications by auditing a minimum of 5% of all applications completed monthly per employee and retaining electronic copies of the audits in One Drive. Plan: Designated Supervisors/Managers, Senior Income Maintenance Caseworkers, and Quality Assurance staff will be tasked with auditing cases using the state audit form. Performance Improvement Strategies: 1. Errors will be discussed individually with staff via monthly conferences with their supervisor or member of the supervisory team. 2. Copies of audit forms will be shared with staff which will identify trends, areas of improvement and progress. 3. In-service training will be developed based on common errors offered throughout the fiscal year and for all staff who are responsible for administering this program. 4. The QA/Training department will collaborate with Economic Services to develop a checklist to review approved applications that includes income documentation and calculation to ensure timely benefits to customers. Responsible Parties: Energy Programs Team and Customer Care Center Team management as well as the Quality Assurance Team will perform second party audits on 5% of all processed Low-Income Household Energy Assistance Program applications. Timeframes: Audits will be completed and retained on a monthly basis by IMC III (Lead Worker), and supervisor.

Finding No: 2022-001 Response: Agree Planned Corrective Action: An age waiver has been submitted to HUD and is currently being reviewed. We are awaiting their decision. While we await a decision, Meadow Lane will review all existing applications for eligibility and advise any existing applicants who are not of age that they are no longer eligible via mail. Anticipated Completion Date: Pending HUD approval of age waiver Contact Person: Christina Villanueva, CFO United Hebrew Geriatric Center

Finding #2022-002 ? Significant Deficiency Applicable federal programs: U. S. Department of Justice Assistance Listing #16.575 Passed through Office of the Governor, Criminal Justice Division Crime Victim Assistance Contract #: 3521203 Contract year: 10/01/21 ? 09/30/22 Crime Victim Assistance Contract #?s: 4219601 and 4219602 Contract years: 10/01/21 ? 09/30/22 and 10/01/22 ? 09/30/23 Recommendation: Provide additional staff training to ensure that HAWC?s internal control procedures that require review of client files are followed. Planned corrective action: Management will review and ensure compliance with policies and procedures regarding the review and approval of client files to ensure that reviews are completed. Responsible officer: Chief Quality Officer Estimated completion date: August 20, 2023

1. Finding 2022-001 a. Comments on the Finding and Each Recommendation We recommend that the Board of Directors continues to work with HUD to resolve the outstanding balance. b. Action(s) Taken or Planned on the Finding The Board of Directors has continued to work with HUD to resolve the outstanding balance. The last communication from HUD was on July 28, 2022 noting the issue is currently under review.

November 17, 2022 To: Chair of the Audit Committee From: Debra Martin, Vice President for Finance and Administration RE: Response to Baker Tilly Audit Communication ? Uniform Guidance Audit Findings Finding 2022-001: Significant Deficiency - Return of Title IV Fund Calculations Program: Student Financial Assistance Cluster Assistance Listing Number (ALN): Various Federal Agency: U.S. Department of Education Federal Award Identification Number: Various Federal Award Year: June 30, 2022 Criteria: 34 CFR 668.22 requires that when a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV grant or loan assistance that the student earned as of the student's withdrawal date in accordance with Federal regulations and return the unearned portion of the grant or loan funds to the Title IV programs as soon as possible but no later than 45 days after the withdrawal date. Condition: Two students of five students tested had incorrect/missing calculations. One student was disqualified during the term after the first 8 week session in the Associate Degree of Nursing and could not continue into the second 8 week session. The University did not note the disqualification and withdrawal timely and did not perform an R2T4 calculation as required and the $2,473.53 of direct loans calculated by the auditor was not returned. One student's number of days attended (numerator) was calculated incorrectly at 25 days but should have been 26 days and therefore $59.53 too much Pell was returned. The auditors noted that a total of four students withdrew from the Associate Degree of Nursing program from the population file provided, and two students were not selected by the auditors. The University reviewed these students and noted one student completed more than 60.01% although the auditors learned that the student was disqualified at the end of the first 8 week session and therefore should have had an R2T4 calculation and return, and one student the R2T4 calculation was performed, however the auditor noted the number of days attended (numerator) was calculated incorrectly at 51 days but should have been 52 days and included a negative amount of Pell grant that ?could have been disbursed?. The University noted that an estimated term end date of May 7, 2022 was input in the system and was not updated to the actual term end date of May 6, 2022. As this could impact all students who withdrew during the Spring 2022 term, the auditors noted 21 students in the population file provided who withdrew during spring 2022, and four of those students were noted as withdrawing before 60% and were not tested by the auditors. The University reviewed these students and noted two additional students with incorrect denominators used in their calculations, the auditor reviewed only the denominators for these students and agrees. The sample was not a statistically valid sample. Cause: The University?s controls surrounding completing timely and accurate refund calculations did not operate as designed and resulted in exceptions. Effect: The calculations of funds to be returned to the Department of Education did not occur or were incorrect. Questioned costs: Questioned costs of $2,301.70 (ALN No. 84.268), and $59.53 (ALN No. 84.063) were noted during testing. Context: Exceptions were noted for 2 of the 5 students selected for testing. There were a total of 33 students who withdrew during fiscal year 2022 that received Title IV aid. Recommendation: It is recommended that University personnel review the calculations generated by the University's software system to ensure they are timely and accurate. It is also recommended that the control structure be reviewed to ensure all student who withdraw during a term are identified in a timely manner. Management?s Response: The University will review withdrawal controls and procedures so that students who withdraw are identified and correctly processed in a timely manner. The University will also engage our software system Consultant to examine system settings to ensure accurate and timely Return of Title IV calculations occur. Further, management reviewed and performed the same recalculations for the remaining 28 students in the population. Of those, 24 had no findings or errors and the remaining only had a small amount of excess available Pell funding or loan eligibility. The Pell amounts were awarded and students with loan availability were notified and asked to respond if they wished to borrow the additional funds. All amounts were not material. Correction Action: The Registrar?s Office will provide the Financial Aid Office with final academic calendars in advance to ensure that proper start and end dates of academic periods are correct in the Financial Aid System. Multiple employees (as opposed to a single person) in the Financial Aid office will be tasked with confirming the accuracy of the calendar set-up in advance of the start of each semester. We have also reminded the Nursing department of timely communication of student disqualifications to the Registrar?s office to assist in recognizing students who may fall into this category. In addition to these steps, the University is exploring systematic changes in colleague that will split the ADN and ABSN programs into two separate 8 week sessions with separate start/end dates, as opposed to one 16 week semester that has two sessions within. An RT24 output report will now be automatically generated and reviewed by the Director of Financial Aid every two weeks. Furthermore, the University will apply the same refund calculation policy to ADN students who are academically disqualified, as we do all other student populations. This will ensure accuracy when determining the number days attended and earned amounts of federal aid when processing R2T4 calculations. The University will dedicate additional resources, staff and technology, to manage withdrawal notifications and to process then in a timely manner.

2022-001 - Non-compliance Specific steps to be taken to correct the situation (including a timetable for performance of the CAP) or reason why corrective action is not necessary (including disagreement with the finding): NTMA has recently adopted a new student financial management system that will assist in determining correct calculated awards and is a State of the art financial aid packing system. We are retiring Transcripts, a very antiquated system that was not set up to provide the error free outcomes required. Jenzabar Financial Aid, our new SMS, enacts group processing and direct data imports from the DoE, manages funds to and from the COD system. Flexibility to award using federal and institutional methodologies, automates COA calculations etc.. Jenzabar is a Financial Aid System built by financial aid people. It was set up in manner that is meant to be more compliant and more robust streamline process. It has automated the entire financial aid process. In addition, we are also considering the use of a servicer and requiring financial aid staff to take an additional continuing education and they will be attending virtual workshops that the DoE offers each year.

Corrective Action Plan for Current Year Findings Finding 2022-001: Timely Processing of Participant Applications: Department of Health and Human Services - AL #93.568 Low Income Home Energy Assistance Program #Ll-023-024, #Ll-022-024 Corrective Action: WICAA has developed a streamlined approach for assessing incoming applications, differentiating between complete and incomplete applications at the beginning of the processing cycle. This will ensure that complete applications can be promptly processed. Additionally, if a substantial number of unprocessed applications are nearing 10 days of the deadline for processing, our staff will be notified that there is a need for overtime. Overtime requirements will be assessed weekly. These modifications are anticipated to result in applications being processed within the allowable number of days. Person Responsible: The Energy Assistance Director has primary responsibility with oversight by the Executive Director. Timing for Implementation: Immediately; Carole Barr, Executive Director; Debbie Kearschner, Finance Director

The institution does not dispute this finding. This was an isolated incident and no further instances of this nature occurred. The staff member mistakenly thought that a PLUS denial from a prior academic year was for the academic year in question, thereby awarding additional Unsub for an independent student. Once the error was found, the ineligible Unsub amount was returned. Staff was provided proper training with respect to reviewing documentation to confirm accuracy of awards being packaged. This finding was reviewed with all staff members in the department to ensure compliance moving forward.

2022-002 Housing Choice Vouchers - Assistance Listing No. 14.871 - 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 planned/taken in response to finding: During this time GHA's HCV program was extremely short staffed and GHA was using temporary employees to assist in program delivery. Specifically, the department suffered two staff- members deaths, one family emergency that removed dedicated staff from this task, and two resignations. GHA has hired and trained new staff to ensure that recertifications are being performed annually for all tenants as applicable. The annual recertifications will be three months ahead by the end of 2023. Name(s) of the contact person(s) responsible for corrective action: Maria Godwin Planned completion date for corrective action plan: GHA has hired and trained new staff and will conduct additional refresher training courses for existing staff focusing on accuracy. This will be complete by August 2023. GHA annual recertification's are currently being completed timely and will be three months ahead by the end of 2023.

See corrective action plan for chart/table.

Deficiencies in the TANF Eligibility Determination Process Department Name: Health and Human Services Contact Name / Telephone Number of Person Responsible for CAP: Allison Smith - (919) 527-6316 The Division of Social Services will provide targeted training and support for the two counties in error and will continue to provide support to prevent future errors from occurring. Anticipated Completion Date: June 30, 2023.

Brownsville Housing Authority respectfully submits the following corrective action plan for the year ended June 30, 2022. Name and address of independent public accounting firm: Miller & Rose, PA 1309 East Race Searcy, AR 72143 Audit period: Year ended June 30, 2022 B. FINDINGS - FINANCIAL STATEMENTS AUDIT None C. FINDINGS AND QUESTIONED COSTS-MAJOR FEDERAL AWARD PROGRAMS AUDIT DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT 2022-001 Family Eligibility Files Federal Program: Housing Choice Voucher, CFDA No. 14.871 Criteria: The Authority?s purpose for existence is providing decent, safe and affordable housing to low-income persons. As such, the Authority prepares a file for each admitted family, which contains information necessary to determine eligibility for assistance and calculations of rent assistance to be paid on the family?s behalf. HUD regulations prescribe the content of these family files. These requirements consist of the following: a. As a condition of admission or continued occupancy, require the tenant and other family members to provide necessary information, documentation, and releases for the PHA to verify income eligibility. b. For both family income examinations and reexaminations, obtain and document in the family file third party verification of: (1) reported family annual income; (2) the value of assets; (3) expenses related to deductions from annual income; and (4) other factors that affect the determination of adjusted income or income-based rent. c. Determine income eligibility and calculate the tenant's rent payment in accordance with HUD regulations. d. Select tenants from the public housing waiting list in accordance with the PHA's tenant selection policies. e. Reexamine family income and composition at least once every 12 months and adjust the tenant rent and housing assistance payment as necessary. Condition: Exceptions were noted in the review of family eligibility files. Questioned costs: None Context: Testing of nineteen family files revealed the following deficiencies: 1. Three files contained errors in the documentation of household income. 2. One file lacked social security number documentation. 3. One file lacked appropriate rent reasonableness documentation. 4. One file lacked a housing quality standard (HQS) ?passed? inspection. Recommendation: A thorough review of tenant files should be performed for the purpose of eliminating the deficiencies. Views of responsible We will comply with the auditors? recommendations. We have already begun officials and planned reviewing files and corrected the deficiencies. corrective actions:

Finding 2022-004 ? Eligibility (Significant Deficiency and Non-compliance) Corrective Action: Legal Services Alabama services provided services related to eviction proveedings and other legal services that aided in housing stability. LSA will continue its policies and procedures used for case acceptance and eligility requirements. LSA will review its policies for potential improvements. The review will be conducted by the second quarter of 2023 and any changes will be implemented by the third quarter of 2023. Contact Person: Michael Forton, Director of Advocacy; (256) 551-2671; mforton@alsp.org

Finding 2022-002 ? Case Requirements (Significant Deficiency and Non-compliance) Corrective Action: LSA will provide training to all attorneys and support staff on the policies and procedures involved, with a particular emphasis on the documentation requirements. LSA will also be conducting periodic internal reviews of case files to ensure compliance with all required documentation requirements. These reviews should include a review of financial eligibility documentation, including exceptions, if any. Finally, LSA will review and update any necessary policies and procedures as needed to ensure compliance. Updates to policies and procedires and training will becompleted by the third quarter of 2023. Contact Person: Michael Forton, Director of Advocacy; (256) 551-2671; mforton@alsp.org

Person(s) Responsible for Implementing the Corrective Action: Jenny Holden Senior Director, Grants and Community Development Corrective Action Planned: Management has implemented additional steps in the fraud prevention procedures previously implemented. Anticipated Completion Date of Corrective Action: Management has implemented the corrective actions during FY 2023.

1. Comments on Findings and Recommendation Management acknowledges failure to comply with timely EIV Master File Reports required to be completed as part of tenant move in certification process and EIV Master File process. 2. Actions Taken or Planned The Corporation will regularly monitor and reconcile the creation and retention of background checks and Income reports as part of the move in process. Additional training was provided and corrective action was taken. Management is reviewing and revising the EIV policy. 3. Status of Corrective Actions on Prior Findings The Corporation did not remediate the prior year finding for failure to comply with timely EIV Income Reports.

2022-002: Missing Entrance Counseling Documentation - Student Financial Aid Cluster - Assistance Listing #s 84.007, 84.033, 84.063, 84.268 - Grant Period - Year Ended June 30, 2022 Condition Found: During our student file testing, we noted one student out of 40 did not have documentation in their file to verify that entrance counseling occurred before the disbursement of loans. We consider the missing entrance counseling to be an instance of noncompliance with the Eligibility Compliance Requirement. Corrective Action Plan: We have updated our Loan checklist procedures to include printing the Master Promissory Note and Entrance Counseling confirmation off of the Common Origination and Disbursement website. Those print outs will be included in the student loan application packet and will be kept with the other student loan documents in the student?s file. Responsible Person for Corrective Action Plan: Eric Johnson ? Director of Financial Aid Implementation Date of Corrective Action Plan: 10/6/2022

FINDING 2022-005 ? Overaward ALN and Program Expenditures: 84.268 ($149,449) Award Number: P268K223976 Federal Award Year: July 1, 2021 to June 30, 2022 Questioned Costs: $4,237 Condition Found: There was a combined total of $4,237 of overawards given to four of the twenty-eight students in our sample. Corrective Action Plan: Management agrees with the auditors? finding and their recommendation. The School reclassified $648 of subsidized funds as unsubsidized funds in December 2022. The School returned a $3,589 of unsubsidized loan funds to the Department of Education in December 2022. The Financial Aid Director will limit the total amount of aid a student receives to his or her cost of attendance and verify the cost of attendance used on internally created spreadsheets is correct. Anticipated Completion Date: The corrective action was completed on December 13, 2022 Contact Person Valorie Quesenberry, Financial Aid Coordinator 513-763-6659

Finding 2022-005 Federal Agency Name: Department of Health and Human Services Program Name: COVID-19 Provider Relief Fund and American Rescue Plan Applicable Federal Award Number and Year ? Period 2 TIN #420953968 Federal Financial Assistance Listing #93.498 Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs/Cost Principles Finding Summary: The Organization?s Period 2 report to HHS included expenditures that were not properly supported. Responsible Individuals: Mario Van Dijk, CFO Corrective Action Plan: Management is aware of the expenditures, even though small in amount, that were not properly supported, and lost revenue calculation and some of the expenditure listings not being reviewed separate from the preparer. The organization has created processes around preparing and reviewing for items such as this. The finance team is committed to these changes to improve accuracy of our work. Anticipated Completion Date: September 28, 2023

Views of Responsible Officials: Executive management agrees with this finding, and has provided additional training to employees responsible for processing move outs.

2022-001 Contact Person Terry Hanson, Executive Director Corrective Action Plan The Authority has encountered turnover with their tenant specialists and will review, implement, and document controls that will ensure file reviews are performed in a timely manner. Planned Completion Date for CAP Immediately

OLIVET COMMUNITY SCHOOLS CORRECTIVE ACTION PLAN YEAR ENDED JUNE 30, 2022 Olivet Community Schools respectfully submits the following corrective action plan for the year ended June 30, 2022. Auditor: Maner Costerisan 2425 E. Grand River Ave., Suite 1 Lansing, Michigan 48912 Audit Period: Year ended June 30, 2022 District Contact Person: Gail Williams, Business Office Manager The findings from the June 30, 2022 schedule of findings and responses are discussed below. The findings are numbered consistently with the number assigned in the schedule. Finding ? Federal Award Findings and Question Costs Finding 2022-001 Considered a significant deficiency Recommendation: The District should submit and implement a required corrective action plan, for the 2022- 2023 school year that will adequately reduce the food service fund balance. Action to be Taken: Management agrees with the finding and we are in the process of developing a plan to spend down the food service fund balance. Anticipated Completion Date: June 30, 2023

Finding No. 2022-005 ? Eligibility (Significant Deficiency) State Department of Labor and Industrial Relations AL Number: 17.225 Program Title: Unemployment Insurance Direct Award from: UI 3644 21 55 A 15, UI 3590 20 60 A 15, UI 35700 21 55 A 15, UI 37219 22 55 A 15 Condition Per Administrative Rule 12-5-35(c), an individual may be considered available for work for any week if they make a minimum of three work search contacts each week, unless the individual is exempt from the work search requirements or be subject to a modified work search requirement consistent with and reflective of local area policies and local labor market opportunities. Findings identified three claimants who did not comply with the above requirements and were improperly paid. Current Status of Corrective Action Plan Concur. Hawaii will resend our revised written procedures regarding Administrative Rule 12 5 35(c) dated January 16, 2020, to ensure staff is aware and compliant with our Work Search requirements to ensure proper payment of benefits in the future. To address the modified work search requirements for specific islands or locality, Hawaii will provide staff with a written policy regarding this matter. Person Responsible Sheryl Maligro, UI Program Specialist Supervisor Anticipated Date of Completion June 30, 2023

CFDA Numbers: Various Program: Student Financial Assistance Cluster Corrective Action: The Registrar's Office has implemented a comparison process where graduates are verified against the National Student Clearinghouse grad only file. Implementation Date: 8/21/22 Corrective Action: The Registrar's Office has implemented a process to verify SSNs on record and correct student records. Implementation Date: 1/20/22 Corrective Action: The Registrar's Office will develop a business process to review term withdrawals for program/campus level discrepancies. Implementation Date: 6/12/23 Contact Person: Scott Campbell and Amanda Fijal

2022-002 Housing Choice Voucher Cluster ? All Programs Recommendation: We recommend that the Authority?s management reviews the accounting information which is the best means of preventing and detecting errors and irregularities.. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: In order to remedy and mitigate audit findings that we have seen building over the past several years, PHA is in the process of moving from a traditional caseload model to a functional task-based model. We will be using SharePoint trackers for transparency, a QC system including running completed HUD-50058?s through an Excel QC Tool to monitor for complete and accurate files, and using software deficiency reports and HUD SEMAP reports to monitor program compliance. Name of the contact person responsible for corrective action: Deborah Madsen, Executive Director Planned completion date for corrective action plan: 12/31/2023