Corrective Action Plans

Finding Number:2022-002 Finding: Management did not complete reviews of tenant file applications and recertifications during a portion of the year to ensure compliance with HUD eligibility requirements. Staff turnover and shortages resulted in the review procedure not being completed. We recommend management implement timely review of all tenant files after they have been prepared to ensure all participants in the program meet the eligibility requirements. Corrective Action: The compliance oversight of the Project was maintained by the same individual from the Project's acquisition during 2016 through her retirement in 2022. Due to staffing shortages after the employee's retirement, there was a portion of the year when no review of account reconciliations of the reserve accounts were being completed and reviewed. Management has filled that position and subsequently brought the account reconciliations up-to-date. Anticipated Completion Date: 6/30/2023 Responsible Contact Person: Executive Director of Rosecrance Central Illinois

Findings 2022 ? 003 Emergency Rental Assistance (ERA) Program Federal Assistance Listing # (21.023) ? Allowable Costs/Eligibility Corrective Action Plan: Key considerations are: Treasury added flexibility between the ERA 1 and 2 programs relaxed the burden of proof necessary for applicants to qualify for funding. 1. The reduction of burden and qualifications allowed for self-attestation, third party income verification or certification, and internal policies to reduce burden as supported by the Treasury. 2. Rental payments calculations and assumptions on timing may not have taken into consideration the FAQ guidance covering overall ceilings on payments in ERA I funding once ERA II was in place, which allowed for an 18-month cap on both funding sources. DPD will continue to work towards recovering over-allocations to awardees and initiate collection efforts directed towards owners and landlords. As we finalize the ERA II program by September 2024, DPD will reconcile the payment status of the ERA II awardees and notify awardees of overpayment and repayment requirements. Please reference the following: ERA-FAQ and ERA Questions. https:www.google.com/url?sa=t&source=web&rct=j&url=https:home.treasury.gov/system/files/136/ERA-FAQ-8-25-2021.pdf&ved=2ahUKEwjZ05HLjOL_AhVEkmoFHaXiAMwQFnoECCIQAQ&usg=AOvVaw1SKQl-IN3zig70bkVCxj9C

CORRECTIVE ACTION PLAN YEAR ENDED JUNE 30, 2022 COGNIZANT OR OVERSIGHT AGENCY U.S. Department of Health and Human Services INDEPENDENT PUBLIC ACCOUNTING FIRM Karlsson & Lane, An Accountancy Corporation 4725 First Street, Suite 226 Pleasanton, California 94566 AUDIT PERIOD - For the year ended June 30, 2022 The findings from the June 30, 2022 Schedule of Findings and Questioned Costs are discussed below. FINDINGS - FEDERAL AWARD PROGRAMS AUDIT 2022-001 The Organization should implement a procedure and control to determine program participant eligibility on at least an annual or six month schedule as required by the program. Action: The Organization agrees with the finding, and will implement procedures to implement the recommendation. Conclusion: If the U.S. Department of Health and Human Services has questions regarding this plan, please contact Charlie Meade at: 3170 23rd Street San Francisco, CA 94110 (415) 625 5220 cmeade@shanti.org CORRECTIVE ACTION: Following this audit finding, Shanti?s HIV Programs performed an internal review of all clients served during FY 2021-present to identify active clients out of compliance with Ryan White eligibility. Shanti?s HIV Programs will rectify the auditor?s findings in the following ways: All clients with outstanding eligibility documents will be reached out to regarding their compliance status and HIV Programs staff will attempt to obtain proper documentation. If a client is unable to provide Ryan White eligibility documents, they may sign an attestation stating that they are a San Francisco resident and their income is at or below 500% of the Federal Poverty Level. When eligibility documentation is received, HIV Programs will update the ARIES database, the client?s chart and Shanti?s internal tracking document. Shanti will communicate status updates regarding client eligibility and will inform the appropriate parties if any clients served during the FY 22-23 contract period were not able to prove Ryan White eligibility. Previously reported UOS and UDC that remain undocumented will be restated with February 2023 reporting. POLICY & PROCEDURE CHANGES: HIV Programs? Policies and Procedures will be updated to reflect that clients who are not in compliance with Ryan White eligibility should not receive services or be billed for until documentation is provided. o The Director of HIV Programs will review a listing of all clients out of compliance monthly. o HIV Care Navigators and/or the HIV Program Coordinator will follow-up with clients out of compliance to obtain documentation. o The Director of HIV Programs will review the clients reported monthly into ARIES and sign off that all clients are eligible and documented to have received services during the month. o The Director of HIV Programs will sign off on all UOS and UDC reported monthly to finance for inclusion on the monthly invoices to the City. PROJECTED COMPLETION DATE: Shanti?s HIV Programs Department is working diligently to update Ryan White eligibility documents for all clients served during the FY 21-22 and FY 22-23 contract periods. The corrective action plan is anticipated to take until the end of the FY 22-23 contract period (2/28/23).

Prior approval for capital expenditure: We have reviewed our controls over grant expenditures with new staff to ensure that controls over compliance are followed. We have made one modification that includes a review of recorded expenditures recorded in the general ledger prior to year-end to ensure that all items recorded have required approval.

Finding 2022-002: Verification of Free & Reduced Price Application (NSLP) Recommendation: We recommend the District perform the verification of free & reduced price applications by the deadline published by DESE. Planned Corrective Action: The District will ensure future verifications of free & reduced price applications will be completed by the deadline published by DESE.

PEEKSKILL HOUSING AUTHORITY 807 Main Street Peekskill, New York 10566 Phone: (914) 739-1700 Fax: (914) 739-1787 Corrective Action Plan ? March 31, 2022 Audit Findings 2021-1 Condition: Deficiencies Noted in Examination of Low Rent Public Housing Tenant Files Steps to resolve: We will review the internal control procedures over tenant file recertifications and documentations. Management has implemented procedures to clear this finding in FY 2023. Timeframe: By FYE March 31, 2023 Individual responsible for correction: P. Holden Croslan, Executive Director

FINDING ? FEDERAL AWARD PROGRAMS AUDIT LEGAL SERVICES CORPORATION 2022-002 Legal Services Corporation ? CFDA No. 09.120000 Noncompliance: The last time the Board documented review and approval of financial eligibility guidelines was at the April 2019 meeting. They would have been required to review and approve them again by April 2022. Recommendation: Implement a reminder system to ensure the review and approval of financial eligibility guidelines is documented at a minimum of every three years. Responsible Person for Corrective Action: Tom Fritzsche, Executive Director Corrective Action to be Taken: PTLA faced a challenging year in 2022 with a significant change in leadership, which resulted in this deadline being missed. In particular, at the time of the Board of Directors meeting when the triennial review of our client financial eligibility policy would have occurred, PTLA's Executive Director had recently passed away, and the Board was fully engaged in the search process for a new ED. Moving forward, PTLA will develop a reminder system to ensure this review and approval occurs on a timely basis. The anticipated completion date for this corrective action is June 22, 2023. The review and approval will take place at the next board meeting, at which time a regular schedule will be established for timely review.

FINDING ? FEDERAL AWARD PROGRAMS AUDIT LEGAL SERVICES CORPORATION 2022-001 Legal Services Corporation ? CFDA No. 09.120000 Noncompliance: Out of sixty-four case files tested, three files did not contain the required retainer agreement. One file did not have a signed citizenship attestation statement documented. Neither of these cases were considered brief advice and consultation. Recommendation: We recommend that every effort be made to obtain retainer agreements and citizenship attestation early in the representation process and follow-up on those that are not returned. Responsible Person for Corrective Action: Tom Fritzsche, Executive Director Corrective Action to be Taken: Pine Tree holds biannual mandatory staff trainings on the LSC regulations, which include a review of the requirements for retainers and citizenship attestations. We have processes in place to obtain the required documents on paper or electronically. Pine Tree continues to prioritize compliance with these rules. In addition to continuing our biannual training of all staff about the regulations and how to fulfill them, we will continue to work on policies and procedures, and stay up to date on technological advances, that can help us overcome the factors that led to the occasions in which clients did not return the documents that Pine Tree provided for their review and completion. We will continue to evaluate the barriers, and systematic solutions to reduce them, that make it difficult to obtain the required paperwork from some clients, which can include the time-sensitive nature of our work, clients? inability to meet in person, the large geographic size of our service area, and some clients? significant mental health issues that limit their capacity to complete paperwork. The anticipated completion date for this corrective action is June 21, 2023 (scheduled all-staff LSC regulation training) ? the training will include reminders and training about these requirements. The other steps to work on overcoming some of the barriers will continue as ongoing action.

FINDING 2022-003- U.S. DEPARTMENT OF TREASURY - ELIGIBILITY SIGNIFICANT DEFICIENCY Federal Assistance Listing Number: 21.023- Emergency Rental Assistance Program Grant Number: Various Grant Period: Various We are implementing the following procedures to address the auditing finding 2022-003: There are no current grants for this program, or any other client assistance programs for the Northern Counties we serve. The Hillsborough / Pinellas program will train Northern County staff on the usage of their flow chart they developed listing the grants and the requirements of each grant so employees can follow which grant the prospective client is eligible in order for implementation to prevent eligibility issues in the future. We will implement Case Reviews once a program is established.

FINDING 2022-001- U.S. DEPARTMENT OF HOUSING AND DEVELOPMENT- ELIGIBILITY MATERIAL WEAKNESS Federal Assistance Listing Number: 14.239 HOME Investment Partnerships Program Grant Number: Various Grant Period: Various We are implementing the following procedures to address the auditing finding 2022-001: Prior to the recent internal audit of PH3, we were still rebounding from the effects COVID 19 had on our procedures at Pinellas Hope Apartments. We went through a period of significant staff turnover which resulted in falling behind on a procedure of reviewing files on a regular basis. We have subsequently hired new staff with Property Management experience and have reviewed and corrected all the current files. We also have restarted our procedure of Monthly peer reviewed audits of files for new move-ins.

FINDING 2022-002- U.S. DEPARTMENT OF HOUSING AND DEVELOPMENT- ELIGIBILITY SIGNIFICANT DEFICIENCY Federal Assistance Listing Number: 14.231 Emergency Solutions Grant Program Grant Number: Various Grant Period: Various We are implementing the following procedures to address the auditing finding 2022-002: The program has implemented a flow chart listing the grants and the requirements of each grant so employees can follow which grant the prospective client is eligible. Catholic Charities will continue to conduct case reviews/ supervision on the 2nd Thursday of every month, to ensure compliance to the grants of the program involved. Files are swapped with Mercy House to complete this reviews /supervision. The case managers and case aides in both Hillsborough and Pinellas counties are involved. The person in charge of the file reviews and checks income and uses the rent calculation sheet to verify if the household meets the correct AMI.

Plan - The Association has brought the eligibility concerns to the attention of the NRWA. ARWA will work with NRWA and USDA to update a list of eligible systems. Staff will be required to check for population size and/or USDA qualification status prior to claiming a contact. If a system is eligible based on other qualifying information, documentation of that will be entered into the system on the day it is recorded. The Program Manager will review contacts claimed for eligibility each week and follow up on those in question with the staff member responsible for the contact, as well as provide a summary each month to the Executive Director. Individuals Responsible - Mike Baumgartner, Steve Berry, and Derek Pierce Completion Date - Plan has been implemented as of the date of audit submission.

Finding: 2022-001 ALN and Title: 10.565 ? Commodity Supplemental Food Program Cluster Name: Total Food Distribution Cluster Federal Agency: U.S. Department of Agriculture Passthrough Entity: State of Nevada Department of Agriculture Name of Contact Person: Sue Saunders, Director of Finance Corrective Action Plan: Management has implemented a filing system to ensure the collection of current clients as well as a recertification process. CSFP/SNW created a monthly, site specific, year and alphabetized list filing system to aid in the assurance of the certification & recertification. Certification and recertification are occurring at CSFP/SNW distribution sites. In addition, we have a tracking system in our TJOP Salesforce Software System. Currently, we are working towards establishing a digital certification application process. Proposed Completion Date: September 30, 2023

Oversight Agency for Audit, Senior Citizens Housing Development Corporation of Boston, Inc. respectfully submits the following corrective action plan for the year ended December 31, 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: January 1, 2022 through December 31, 2022 The findings are 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. SECTION III - FINDINGS AND QUESTIONED COSTS ? MAJOR FEDERAL AWARD PROGRAMS AUDIT FINDING No. 2022-001: Section 202 Supportive Housing for the Elderly, ALN 14.157 Recommendation: Management should verify eligibility in a timely manner and perform background checks prior to tenant acceptance. Action Taken: This was an oversight from a former community manager. Management has provided current staff with additional training on HUD guidelines and regulations.

Northeast Indiana Works (NEINW) will continue to the use the established file review process. NEINW will be conducting a system wide WIOA file review. This review will be done in stages and will be completed by the end of May 2023. NEINW will deliver training to all staff to reacquaint them with the virtual service delivery model, including, but not limited, to the application process. This training will be conducted during the weekly Thursday morning training session on January 5, 2023. A follow up session will be held on January 12, 2023 to address any questions and to train staff who may have been absent during the January 5th session. Person(s) Responsible: NEINW President and CEO, CFO, Director of WorkOne Services and Director of Quality Initiatives Timing for Implementation: Staff training will be conducted in January 2023. System wide file review will be completed by the end of May 2023.

CORRECTIVE ACTION PLAN Name and Number of the Project: See below Audit Firm: M Group, LLP Audit Period: The period from December 9, 2021 (Inception) through December 31, 2022 Gretna Village, LP VHDA (Project No. 02-1709-HF/SP and 02-1710-HCD) $ Unknown Waters at James Crossing, LP (FHA/Contract No. VA36-L000-130) $ Unknown Waters at Augusta, LP (FHA/Contract No. SC16-M000-060) $ Unknown Compliance Review COMMENTS ON FINDINGS AND RECOMMENDATIONS We concur with the findings and recommendations of our auditors regarding our noncompliance as cited in the accompanying Schedule of Findings and Questioned Costs. ACTIONS TAKEN OR TO BE TAKEN FINDING #2022-003: Section 8 Housing Assistance Payments Program. CFDA: 14.195 CORRECTIVE ACTION TO BE COMPLETED: The Project's will review and monitor tenant eligibility and documentation procedures to ensure compliance. We have prepared the corrective action plan as required by the standards applicable to financial statements contained in Government Auditing Standards and by the audit requirements of Title 2 US. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principals, and Audit Requirements for Federal Awards. Any questions regarding the above corrective action plan should be directed to Mr. Michael Nguyen, President of Atlantic Housing Management, Tnc.

Temporary Assistance for Needy Families (TANF) ? Assistance Listing No. 93.558 Recommendation: We recommend the County implement a process to ensure that errors identified in the TANF quality control review process are addressed in a timely manner. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: This is in isolated incident in our QA process. We have built a system with ticklers, and we missed this one. We will implement a secondary review by our QA supervisor to make sure all QA issues have been resolved in a timely manner. Name of the contact person responsible for corrective action: John McGraw ? Program Manager of Professional Standards Planned completion date for corrective action plan: July 1, 2024

Corrective Action Plan 1. The corrective measures pertaining to DVHA?s enhanced oversight of Gainwell?s contractual obligation to DVHA to provide licensure validation service and documentation of active licensure will include established benchmarks for the overall improvement of the service, expansion of automated search services, progress reports and overall reduction of manual processes. By 5/1/2023 Gainwell will provide the DVHA Oversight & Monitoring Unit with Progress Reports that will be shared at the Fiscal Agent meeting and with DVHA Leadership to track progress and/or report roadblocks and escalate issues of any actual or potential failures to timely perform provider revalidations. Gainwell will use the Provider Management Module (PMM) and other services available to validate license of a provider. For those providers that cannot be validated through PMM or other services, Gainwell will send a letter notice to those providers. Letter notice must be sent no later than 30 days prior to a license expiration date. Gainwell shall submit to DVHA on a weekly basis a list of providers who have been notified that they are due for re-validation and have not responded within 14 days of license expiration date. Gainwell will use PMM and other services available to validate license of a provider. For those providers that cannot be validated through PMM or other services, Gainwell will send a letter notice to those providers. Letter notice must be sent no later than 30 days prior to a license expiring. The written detailed procedure for license updates will be finalized by 04/01/23 between the State and Gainwell and will include the following: a. Update the look forward period in the license screening service to 45 days. As a result, PMM will be updated automatically when the license screening service is available to locate an updated license. This configuration update will be in place by 04/01/23. For those licenses that the screening service is not able to locate an updated license, Gainwell will review and manually check for an updated license. If a new license is found, Gainwell will update accordingly. Gainwell will explore using Lexis Nexis as an additional service for manual review of license information and provide an update of potential solution by 03/17/23. If determined the Lexis Nexis solution is not viable, Gainwell will propose additional solution options by 05/01/23. b. Any provider whose license was not automatically updated as part of the screening service and could not be manually updated through the review process, an expiring license notification will be sent to the Mail-To contact information on file 30 days prior to their license expiration date. The expiring license notifications will be activated in PMM as of 04/01/23. Providers will be notified of this change in process as of 03/01/23 via banner. c. Gainwell will provide a weekly report of any providers whose license is set to expire in 14 days. This report will be delivered weekly beginning 04/17/23, two weeks after start date of license notifications. DVHA will work with Gainwell to finalize a process to address those providers listed. d. Gainwell will activate the termination job within the PMM that will automatically end a provider?s contract with VT Medicaid when no license was obtained through the process listed above by the license end date. This termination job will be activated on 06/05/23, two months after starting license notification. Notification to providers of this change in process will be sent no later than 05/01/23, via banner. Prior to the termination job being activated, Gainwell will continue to manually terminate when no updated license information is obtained, unless written exception is received from DVHA. All exception requests will be stored as part of the provider?s electronic record within PMM. By March 1st, 2023, Gainwell will provide the following information to DVHA: The databases, services, and available in state and out of state agencies Gainwell currently uses and plans to use in order to monitor and verify provider licenses and certifications; and 2. As of December 31, 2023, all revalidations will electronically reside in PMM. By December 31, 2023, All paper files, maintained prior to the implementation of the PMM, will be cataloged and sent to secure storage. To ensure all records are available for review, all application data is now being processed through PMM and available on demand. This includes paper application sent in by providers, Gainwell inputs the paper application into PMM. 3. The Letters of Good Tax Standing have been obtained. A standard operating practice is in place documenting the process. The process of validating tax standing in writing from the Tax Department has been in effect since April 2022. Providers who had their tax standing validated prior to April 2022 via phone or email were not solicited to obtain a written notification from the Tax Commissioner. At this time, the State has determined that it is not necessary to obtain a retroactive written notification from the Tax Commissioner for tax standing prior to April 2022. As of April 2022, all tax standing reviews are validated with a letter from the Tax Department and documented in the PMM. Scheduled Completion Date of Corrective Action Plan: 1. January 1, 2024 2. December 31, 2023 3. Completed Contacts for Corrective Action Plan: Suellen Bottiggi, DVHA Director of Member and Provider Services suellen.bottiggi@vermont.gov Peter Moino, AHS Director of Internal Audit peter.moino@vermont.gov

Corrective Action Plan: 1. The corrective measures pertaining to DVHA?s enhanced oversight of Gainwell?s contractual obligation to DVHA to provide licensure validation service and documentation of active licensure will include established benchmarks for the overall improvement of the service, expansion of automated search services, progress reports and overall reduction of manual processes. By 5/1/2023 Gainwell will provide the DVHA Oversight & Monitoring Unit with Progress Reports that will be shared at the Fiscal Agent meeting and with DVHA Leadership to track progress and/or report roadblocks and escalate issues of any actual or potential failures to timely perform provider revalidations. Gainwell will use the Provider Management Module (PMM) and other services available to validate license of a provider. For those providers that cannot be validated through PMM or other services, Gainwell will send a letter notice to those providers. Letter notice must be sent no later than 30 days prior to a license expiration date. Gainwell shall submit to DVHA on a weekly basis a list of providers who have been notified that they are due for re-validation and have not responded within 14 days of license expiration date. The written detailed procedure for license updates will be finalized by 04/01/23 between the State and Gainwell and will include the following: a. Update the look forward period in the license screening service to 45 days. As a result, PMM will be updated automatically when the license screening service is available to locate an updated license. This configuration update will be in place by 04/01/23. For those licenses that the screening service is not able to locate an updated license, Gainwell will review and manually check for an updated license. If a new license is found, Gainwell will update accordingly. Gainwell will explore using Lexis Nexis as an additional service for manual review of license information and provide an update of potential solution by 03/17/23. If determined the Lexis Nexis solution is not viable, Gainwell will propose additional solution options by 05/01/23. b. Any provider whose license was not automatically updated as part of the screening service and could not be manually updated through the review process, an expiring license notification will be sent to the Mail-To contact information on file 30 days prior to their license expiration date. The expiring license notifications will be activated in PMM as of 04/01/23. Providers will be notified of this change in process as of 03/01/23 via banner. c. Gainwell will provide a weekly report of any providers whose license is set to expire in 14 days. This report will be delivered weekly beginning 04/17/23, two weeks after start date of license notifications. DVHA will work with Gainwell to finalize a process to address those providers listed. d. Gainwell will activate the termination job within PMM that will automatically end a provider?s contract with VT Medicaid when no license was obtained through the process listed above by the license end date. This termination job will be activated on 06/05/23, two months after starting license notification. Notification to providers of this change in process will be sent no later than 05/01/23, via banner. Prior to the termination job being activated, Gainwell will continue to manually terminate when no updated license information is obtained, unless written exception is received from the DVHA. All exception requests will be stored as part of the provider?s electronic record within PMM. By March 1st, 2023, Gainwell will provide the following information to DVHA: The databases, services, and available in state and out of state agencies Gainwell currently uses and plans to use in order to monitor and verify provider licenses and certifications; and 2. To ensure all providers revalidate a minimum of every 5 years, PMM is automatically assigning the revalidation due date. Providers are notified 90 days prior to the due date and again at 45 days, if the provider does not revalidate by the due date, their contract is automatically terminated. At this time, all active providers are assigned a revalidation due date and every provider converted from the old system to PMM has a schedule that will result in revalidation of all legacy providers by December 31, 2023. Exception: If a provider?s revalidation application is returned to them, the provider has until their revalidation due date, or 30 days, whichever is greater, to correct and resubmit their revalidation. Example: Provider?s revalidation due date is 12/30/23 and their revalidation application is returned on 12/29/23. The provider will have until 01/29/24 to correct and resubmit. 3. The Letters of Good Tax Standing have been obtained. A standard operating practice is in place documenting the process. The process of validating tax standing in writing from the Tax Department has been in effect since April 2022. Providers who had their tax standing validated prior to April 2022 via phone or email were not solicited to obtain a written notification from the Tax Commissioner. At this time, the State has determined that it is not necessary to obtain a retroactive written notification from the Tax Commissioner for tax standing prior to April 2022. As of April 2022, all tax standing reviews are validated with a letter from the Tax Department and documented in the PMM. Scheduled Completion Date of Corrective Action Plan: 1. January 1, 2024 2. December 31, 2023 3. Completed Contacts for Corrective Action Plan: Suellen Bottiggi, DVHA Director of Member and Provider Services suellen.bottiggi@vermont.gov Peter Moino, AHS Director of Internal Audit peter.moino@vermont.gov

Corrective Action Plan: ? One of sixty participants selected for testing turned 19 during the fiscal year. Due to the COVID-19 Public Health Emergency, states did not get authority to move customers from one MEC coverage group to another MEC coverage group until January 2021. The SoV began transitioning eligible age-off?s in March 2021. A report was created to capture anyone who had aged off since the start of the PHE. HC eligibility staff worked through the report to determine if customers were eligible to transition to another MEC coverage group. This individual was not captured on the report. They did not get transitioned until April 20, 2022 when the customer called and asked to be screened for Medicaid new adult. This case appears to be an isolated case and has since been corrected. ? For one of sixty participants, eligibility determination exceeded 45 days. Due to the COVID-19 Public Health Emergency, the SoV was accepting self-attestation for all income and resource verifications until November 1, 2021. In this case, the customer applied via the self-service portal and their MAGI-income verification line item (VLI) was pending. The SoV had reports in place at the time to pull all self-service applications with pending VLI?s to manually change them to verified. The SoV ran a report in October 2021 prior to the state resuming verifications for new applications to ensure all pending verification line items were verified and customers were enrolled timely. This appears to be an isolated case. Scheduled Completion Date of Corrective Action Plan: ? Age-off correction: April 20, 2022 ? Eligibility determination timeliness: September 15, 2021 Contacts for Corrective Action Plan: Nicole McAllister, DVHA-HAEEU HCAA II nicole.mcallister@vermont.gov Sarah York, DVHA-HAEEU HCAA I sarah.york@vermont.gov

Corrective Action Plan: The Child Development Division (CDD) has recently switched to a new IT system, Child Development Division Information System (CDDIS), that will check for the child?s IV-E eligibility and check to make sure that the child is in an eligible placement. With these checks it will allow the child to be marked as IV-E eligible or not and draw down the appropriate funding to match the eligibility. Scheduled Completion Date of Corrective Action Plan: July 31, 2023 Contacts for Corrective Action Plan: Karolyn Long ? Karolyn.Long@vermont.gov Emily Hazard ? Emily.Hazard@vermont.gov

Finding 2022-002 Contact Person: Lily Rakness Parra, County Clerk Corrective Action Planned: Washakie County agrees with the finding of 2022-002. A Sams.gov account has been activated in order to verify that entities that are being utilized for County business are not excluded from or are ineligible for participation in Federal programs or activities. Also, the County is currently drafting a Procurement Policy for Washakie County to utilize for the use of Federal funding as well as in an everyday manor of purchasing and maintenance of county facilities in order to satisfy above finding.

B. Finding 2022-002 a. Comments on Findings and Recommendations 2022-002: All tenant income is verified at initial move in and at each annual and interim certification. The instance of non-compliance pertained to a tenant that only had social security income for her March 1, 2022, Annual Recertification, meaning that her verification would have been through the HUD EIV system and would not have been transmitted electronically to the auditors. Management believes the report was properly run. Additionally, our policies include running EIV master file reports on a monthly basis which would have alerted management to the presence of a new job or unreported income in the household had there been any.

Corrective Action Plan - Finding: 2022-001: Special Tests and Provisions - Enrollment Reporting - Significant Deficiency in Internal Controls over Compliance. Corrective Action Plan: The University uses Microsoft Forms reporting to notify service units of withdrawals. The Dean (or designee) of each program must manually update the Microsoft Office report of a withdrawal ad indicate the effective date, which triggers automated emails to the appropriate units. In the one instance of late reporting, the student was required to withdraw due to a no pass of a class, but he was allowed to complete a clinical/experiential course before being withdrawn. The Dean failed to enter the student's information after the student completed the clinical/experiential course, causing the delay in reporting. The Dean has since begun using reminders on his calendar to withdraw students in this situation. In addition, our Director of Institutional Assessment is in the process of developing and programming logic in the Micrsoft Forms report that allows the Dean to enter a future withdrawal date but delays the reporting of the withdrawal to the service units until that date, allowing the Dean to enter the information into the form immediately after a no pass that requires withdrawal. This will prevent the need to manual reminders to enter the date and prevent late withdrawal notifications. Contact Person Responsible for Corrective Action: Sally Mickelson, Director of Financial Aid. Anticipated Completion Date: December 31, 2022.

Community Teamwork, Inc. agrees with this finding and will provide policies and guidance trainings to all staff on a weekly basis. CTI staff will be required to attend DHCD bi-monthly trainings. In addition, CTI has finalized the hiring of a Quality Control Manager who will start on November 28, 2022, and the addition of the Quality Control Manager will help provide ongoing internal quality control.