Corrective Action Plans

CORRECTIVE ACTION PLAN Oversight Agency for Audit: U.S. Department of Treasury The City of Peabody, Massachusetts respectfully submits the following corrective action plan for the year ended June 30, 2022. Name and address of independent public accounting firm: Powers & Sullivan, LLC 100 Quannapowitt Parkway, Suite 101 Wakefield, MA 01880 Audit period: July 1, 2021 through June 30, 2022 The finding from the June 30, 2022, schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. FINDINGS?FEDERAL AWARD PROGRAMS AUDITS U.S. DEPARTMENT OF EDUCATION Passed through Massachusetts Department of Elementary and Secondary Education Education Stabilization Fund Education Stabilization Fund Federal Assistance Listing No. 84.425, 84.425C, 84.425D and 84.425U 2022-003: Controls for Monitoring Payroll Charged to the Grant Compliance Requirement: Allowable Costs/Cost Principles Type of Finding: Compliance and Internal Control Over Compliance ? Other Matter Criteria or Specific Requirement: Grantees must provide reasonable assurance that Federal Awards are expended only for allowable activities and that the costs of goods and services charged to Federal awards are allowable and in accordance with applicable cost principles. Condition: Payroll expenditures charged to the Education Stabilization Fund grant are required to be supported with documentation (i.e., semi-annual certifications and personnel activity reports) substantiating that the employees are eligible to be charged to the grant and that the payroll charged relates to time spent accomplishing grant objectives. The City utilizes semi-annual time and effort certification forms to document the eligibility of the employees paid out of the grant. These forms, however, were not consistently completed for each employee charged out of the grant. Furthermore, the forms that were completed did not include all data required by federal and state guidelines. Context: The City did not maintain sufficient documentation to demonstrate compliance with federal and state time and effort reporting requirements in accordance with the provisions of Title 2 U.S. Code of Federal Regulations Part 225 Cost Principals for State, Local, and Indian Tribal Governments. Effect: The City has not complied with the federal and state time and effort reporting requirements. Cause: Management has not established written guidelines and procedures outlining the time and effort reporting and documentation requirements that department heads must adhere with to ensure compliance with federal and state time and effort reporting requirements. Such guidelines and procedures should indicate under what circumstances semi-annual certifications and personnel activity reports (PARS) are required. Management also has not adopted and implemented standardized forms that include all data as required by federal and state guidelines to demonstrate compliance with these requirements. Questioned Costs: Total payroll costs charged to the grant in 2022 totaled $2,997,132, which was paid on a bi-weekly basis throughout the year. Three of the pay periods were selected for testing, which totaled $241,339 for 73 employees paid out of the grant during those pay periods. From the pay periods selected for testing, the following known questioned costs were identified: "SEE CORRECTIVE ACTION PLAN FOR TABLE" Repeat Finding: This matter was reported as a finding in the previous year as finding 2021-004. Recommendation: The City should establish written policies and procedures outlining the time and effort reporting and documentation requirements that must be adhered with to ensure compliance with federal and state time and effort reporting requirements. Management should adopt and implement standardized forms that include all data required by federal and state guidelines and provide training to ensure that program personnel understand the time and effort reporting requirements. Views of Responsible Officials and Planned Corrective Actions: The School District immediately began redesigning the form used for time and effort reporting, and the School District will immediately begin reissuing and recollecting the forms for the education stabilization grant for 2022, as well as into future periods. If the Oversight Agency has questions regarding this plan, please call Samuel Rippin, School Business Manager, at 978-536-6520. Sincerely yours, Samuel Rippin School Business Manager City of Peabody

CORRECTIVE ACTION PLAN Oversight Agency for Audit: U.S. Department of Treasury The City of Peabody, Massachusetts respectfully submits the following corrective action plan for the year ended June 30, 2022. Name and address of independent public accounting firm: Powers & Sullivan, LLC 100 Quannapowitt Parkway, Suite 101 Wakefield, MA 01880 Audit period: July 1, 2021 through June 30, 2022 The finding from the June 30, 2022, schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. FINDINGS?FEDERAL AWARD PROGRAMS AUDITS U.S. DEPARTMENT OF EDUCATION Passed through Massachusetts Department of Elementary and Secondary Education Title I Grants to Local Educational Agencies Title I Grants to Local Educational Agencies Federal Assistance Listing No. 84.010 2022-002: Controls for Monitoring Payroll Charged to the Grant Compliance Requirement: Allowable Costs/Cost Principles Type of Finding: Compliance and Internal Control Over Compliance ? Other Matter Criteria or Specific Requirement: Grantees must provide reasonable assurance that Federal Awards are expended only for allowable activities and that the costs of goods and services charged to Federal awards are allowable and in accordance with applicable cost principles. Condition: Payroll expenditures charged to the Title I grant are required to be supported with documentation (i.e., semi-annual certifications and personnel activity reports) substantiating that the employees are eligible to be charged to the grant and that the payroll charged relates to time spent accomplishing grant objectives. The City utilizes semi-annual time and effort certification forms to document the eligibility of the employees paid out of the grant. These forms, however, were not consistently completed for each employee charged out of the grant. Furthermore, the forms that were completed did not include all data required by federal and state guidelines. Context: The City did not maintain sufficient documentation to demonstrate compliance with federal and state time and effort reporting requirements in accordance with the provisions of Title 2 U.S. Code of Federal Regulations Part 225 Cost Principals for State, Local, and Indian Tribal Governments. Effect: The City has not complied with the federal and state time and effort reporting requirements. Cause: Management has not established written guidelines and procedures outlining the time and effort reporting and documentation requirements that department heads must adhere with to ensure compliance with federal and state time and effort reporting requirements. Such guidelines and procedures should indicate under what circumstances semi-annual certifications and personnel activity reports (PARS) are required. Management also has not adopted and implemented standardized forms that include all data as required by federal and state guidelines to demonstrate compliance with these requirements. Questioned Costs: Total payroll costs charged to the grant in 2022 totaled $1,114,060, which was paid on a bi-weekly basis throughout the year. Three of the pay periods were selected for testing, which totaled $76,705 for 25 employees paid out of the grant during those pay periods. From the pay periods selected for testing, the following known questioned costs were identified: "SEE CORRECTIVE ACTION PLAN FOR TABLE" Repeat Finding: This matter was reported as a finding in the previous year as finding 2021-003. Recommendation: The City should establish written policies and procedures outlining the time and effort reporting and documentation requirements that must be adhered with to ensure compliance with federal and state time and effort reporting requirements. Management should adopt and implement standardized forms that include all data required by federal and state guidelines, and provide training to ensure that program personnel understand the time and effort reporting requirements. Views of Responsible Officials and Planned Corrective Actions: The School District immediately began redesigning the form used for time and effort reporting, and the School District will immediately begin reissuing and recollecting the forms for the Title I grant for 2022, as well as into future periods. If the Oversight Agency has questions regarding this plan, please call Samuel Rippin, School Business Manager, at 978-536-6520. Sincerely yours, Samuel Rippin School Business Manager City of Peabody

CORRECTIVE ACTION PLAN Oversight Agency for Audit: U.S. Department of Treasury The City of Peabody, Massachusetts respectfully submits the following corrective action plan for the year ended June 30, 2022. Name and address of independent public accounting firm: Powers & Sullivan, LLC 100 Quannapowitt Parkway, Suite 101 Wakefield, MA 01880 Audit period: July 1, 2021 through June 30, 2022 The finding from the June 30, 2022, schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. FINDINGS?FEDERAL AWARD PROGRAMS AUDITS U.S. DEPARTMENT OF EDUCATION Passed through Massachusetts Department of Elementary and Secondary Education Special Education Cluster Special Education Grants to States Federal Assistance Listing No. 84.027 Special Education Preschool Grants Federal Assistance Listing No. 84.173 2022-001: Controls for Monitoring Payroll Charged to the Grant Compliance Requirement: Allowable Costs/Cost Principles Type of Finding: Compliance and Internal Control Over Compliance ? Other Matter Criteria or Specific Requirement: Grantees must provide reasonable assurance that Federal Awards are expended only for allowable activities and that the costs of goods and services charged to Federal awards are allowable and in accordance with applicable cost principles. Condition: Payroll expenditures charged to the Special Education Cluster grant are required to be supported with documentation (i.e., semi-annual certifications and personnel activity reports) substantiating that the employees are eligible to be charged to the grant and that the payroll charged relates to time spent accomplishing grant objectives. The City utilizes semi-annual time and effort certification forms to document the eligibility of the employees paid out of the grant. These forms, however, were not consistently completed for each employee charged out of the grant. Furthermore, the forms that were completed did not include all data required by federal and state guidelines. Context: The City did not maintain sufficient documentation to demonstrate compliance with federal and state time and effort reporting requirements in accordance with the provisions of Title 2 U.S. Code of Federal Regulations Part 225 Cost Principals for State, Local, and Indian Tribal Governments. Effect: The City has not complied with the federal and state time and effort reporting requirements. Cause: Management has not established written guidelines and procedures outlining the time and effort reporting and documentation requirements that department heads must adhere with to ensure compliance with federal and state time and effort reporting requirements. Such guidelines and procedures should indicate under what circumstances semi-annual certifications and personnel activity reports (PARS) are required. Management also has not adopted and implemented standardized forms that include all data as required by federal and state guidelines to demonstrate compliance with these requirements. Questioned Costs: Total payroll costs charged to the grant in 2022 totaled $2,026,400, which was paid on a bi-weekly basis throughout the year. Three of the pay periods were selected for testing, which totaled $136,921 for 72 employees paid out of the grant during those pay periods. From the pay periods selected for testing, the following known questioned costs were identified: "SEE CORRECTIVE ACTION PLAN FOR TABLE" Repeat Finding: This matter was reported as a finding in the previous year as finding 2021-002. Recommendation: The City should establish written policies and procedures outlining the time and effort reporting and documentation requirements that must be adhered with to ensure compliance with federal and state time and effort reporting requirements. Management should adopt and implement standardized forms that include all data required by federal and state guidelines and provide training to ensure that program personnel understand the time and effort reporting requirements. Views of Responsible Officials and Planned Corrective Actions: The School District immediately began redesigning the form used for time and effort reporting, and the School District will immediately begin reissuing and recollecting the forms for the special education grant for 2022, as well as into future periods. If the Oversight Agency has questions regarding this plan, please call Samuel Rippin, School Business Manager, at 978-536-6520. Sincerely yours, Samuel Rippin School Business Manager City of Peabody

The Organization agrees with the finding. The staff assigned to this particular client had performance issues related to completing paperwork. The staff and their supervisor created a plan to complete outstanding reports, but the staff was terminated before this report was prepared. The Organization developed a revised tracking and submission system, and additional training on the new system will take place in November 2022.

Finding 2022-001 a. Comments on the Finding and Each Recommendation Management agrees with the finding. b. Action(s) Taken or Planned on the Finding In 2022 we hired additional oversight staff at the corporate level and changed the procedure for reviewing and approving annual certifications as well as monitoring EIV reporting. We have implanted new EIV procedures to ensure timely EIV reporting. All HUD staff has been trained on the new procedures.

Finding #2022-001 - Segregation of Duties (Prior Year Finding #2021-001) Condition: Proper segregation of duties is an important aspect of any control system. Management is responsible for the design, installation and maintenance of an appropriate system of internal control. The limited size of the District?s office staff prevents the ideal segregation of functions. The following duties lack adequate segregation of duties: The District uses e-signatures to approve purchase orders. Two individuals have access to the e-signatures and have the ability to create new vendors, enter invoices, print checks, record journal entries and record activity on the general ledger. Both individuals also have access to the payroll system. The person reviewing free and reduced food service eligibility can also enter information into the system to determine eligibility. Effect: Errors or intentional fraud could occur and not be detected timely by other employees in the normal course of their responsibilities as a result of the lack of segregation of duties. Cause: Limited number of personnel. Criteria: Segregation of duties is an aspect of internal control intended to prevent or decrease opportunities of intentional and unintentional errors and fraud. Duties and responsibilities are properly segregated if no single individual either has control over all phases of a transaction or has the ability to both make and conceal an error, whether such error is intentional or unintentional. Recommendation: The Board of Education and the Superintendent should continue to monitor the transactions and the financial records of the District. We also encourage the District to continue to identify cost effective opportunities to improve the design of the internal control structure. Response: We agree with this finding but do not believe it is cost effective to increase the office staff in an attempt to bring about a more effective segregation of duties. The Superintendent approves purchase orders and the Board of Education approves monthly accounts payable checks, and one of the school secretaries or the board treasurer reviews the bank reconciliations. The Board of Education and Superintendent will continue to monitor transactions of the District. Finding #2022-001 - Segregation of Contact Person: Heather Droessler Anticipated Completion: Not applicable

2022-003 - Eligibility ? Tenant Files Section 8 Housing Choice Vouchers ? CFDA Number 14.871 Material Weakness in Internal Control, Material Noncompliance Repeat of 9/30/21 Finding 2021-005 (Originally reported as finding 2020-005 at 09/30/20) Condition: Out of a total tenant population of approximately 884 leased vouchers, 25 files were selected for testing in a statistically valid sample. Exceptions were noted as follows: ? 1 error where the lease agreement was not signed by the owner ? 1 error where the file did not contain a signed lease agreement ? 1 error where the file did not contain a signed HAP contract. Also, during our New Admissions testing (11 tested out of 108 new admissions) we noted the following: ? 1 error where the HAP contract was signed but not dated by the Authority. ? 1 error where the lease agreement was not signed by the owner. ? 4 errors where the RFTA was signed but not dated by the landlord and/or by the tenant. Recommendation: The Authority should correct the deficiencies noted in the tested files and utilize an ongoing quality control review process on the entire tenant population to ensure proper compliance with the requirements related to tenant eligibility. Ongoing staff training and timely management reviews should be utilized to ensure staff is aware of acceptable procedures. In addition, the Authority should review staffing levels, skill sets and case load. Action Taken: The Authority has hired an outside CPA firm to conduct quarterly reviews of files and to assist in training staff on HUD compliance requirements. The noted deficiencies in the tested files are being corrected and staff will continue to receive adequate training involving the compliance of all the Department of Housing Urban Development (HUD) requirements.

2022-004 - Eligibility ? Tenant Files Public and Indian Housing Program ? CFDA Number 14.850 Significant Deficiency in Internal Control, Other Matters Required to be Reported Repeat of 9/30/21 Finding 2021-003 (originally reported at 9/30/19 as Finding 2019-009) Condition: Out of a total tenant population of approximately 141 tenants, 15 files were selected for testing in a statistically valid sample. Exceptions were noted as follows: ? 1 tenant file where the tenant?s flat rent was overstated by $4 due to a miscalculation. ? 1 tenant file where the tenant?s flat rent was overstated by $2 due to a miscalculation. ? 1 tenant file where the tenant?s income was miscalculated. Correcting this error caused the tenant?s rent to increase by $6. ? 1 tenant file where the tenant?s income was miscalculated. Correcting this error caused the tenant?s rent to decrease by $63 ? 1 tenant file where the tenant?s General Assistance was coded as wages on the 50058 form. Recommendation: The Authority should correct the deficiencies noted in the tested files and utilize an ongoing quality control review process on the entire tenant population to ensure proper compliance with the requirements related to tenant eligibility. Ongoing staff training and timely management reviews should be utilized to ensure staff is aware of acceptable procedures. In addition, the Authority should review staffing levels, skill sets and case load. Action Taken: The Authority has hired an outside CPA firm to conduct quarterly reviews of files and to assist in training staff on HUD compliance requirements. The noted deficiencies in the tested files are being corrected. Although this is a repeat finding, the Authority has made great strides in the current fiscal year reducing the error rate by 72% from the prior year. The Authority will continue to improve file reviews and training procedures to ensure the files meet the required guidelines. Effective Date: June 26, 2023 Contact Information Chanosha N.E. Lawton, CEO Housing Authority of the City of Aiken, South Carolina PO Box 889 Aiken, South Carolina 29802 (803) 617-7978

The Department agrees with the finding and recommendation. A memo will be issued to all Kin-GAP eligibility staff to remind them of their responsibility to ensure that all required Kin-GAP documents and forms are received and reviewed for accuracy prior to the continuance of Kin-GAP funding beyond age 18. The memo will also instruct the eligibility staff to ensure that all required documents are maintained in the Kin-GAP case file. Additionally, the Quality Assurance Eligibility Supervisors (QA/ES) will randomly sample and review additional Non-Minor Kin-GAP case files to ensure all required forms are received, and are appropriately filed in the case file.

Responsible Official Caronanne Procaccini, Director of Client Self-Sufficiency and Compliance Plan Detail CACCI will implement a new annual income calculation sheet that is completed by program personnel to support the income information entered into the CSG Engage database. Prior to any assistance payments being made, program staff will review income verification documentation to ensure it is consistent with the annual income calculated during intake. Anticipated Completion Date September 30, 2023

Finding ref number: 2022-002 Finding caption: The District did not have adequate internal controls to ensure compliance with federal Title I requirements for allocating funds to school buildings. Name, address, and telephone of District contact person: Gabriela Chacon, 411 E Saddle Mountain Dr. Mattawa, WA 99349 Tel: (509) 932-4565 Ext: 3031 Corrective action the auditee plans to take in response to the finding: (If the auditee does not concur with the finding, the auditee must list the reasons for disagreement). The Wahluke School District concurs with this finding. The following corrective actions will be taken: ? The Title I Program Director will work closely with the Grants Manager and Director of Finance to ensure that the annual application is completed correctly, including the allocations to school buildings. ? An action plan was submitted to OSPI which includes initial planning with the District Office team prior to the beginning of the school year, as well as monthly meetings with the Title I Program Director to ensure ranking and allocations are maintained. ? The district now has a Grants Manager that is working closely with the Title I Program Director to ensure that the buildings are within ranking order. Anticipated date to complete the corrective action: 08/31/2023

Management?s view: Management is in agreement that the tenant eligibility age according to the regulatory agreement is 62. Through miscommunication, the property staff incorrectly believed that non-subsidized units were not subject to the minimum age of 62, but that the minimum age of 55 was allowable in keeping with current trends and fair housing standards. Proposed corrective action: Management has adopted the proper age restriction in accordance with HUD requirements at a minimum of 62. Communication has been made to property staff regarding the proper/correct age restriction. Management is also adopting the auditor?s recommendation of requesting a waiver from HUD in order to maintain the economic soundness of the property. Anticipated correction date: 7/15/2022. Responsible official: Jerry Burkholder, Monarch Properties, Inc. Management Agent.

Cluster name: TRIO Cluster Assistance Listing number and name: 84.042 TRIO ? Student Support Services 84.047 TRIO ? Upward Bound Award numbers and years: P042A200873, September 1, 2020 through August 31, 2025 P042A201342, September 1, 2020 through August 31, 2025 P042A200859, September 1, 2020 through August 31, 2025 P047A171009, September 1, 2017 through August 31, 2022 P047A171082, September 1, 2017 through August 31, 2022 Federal Agency: U.S. Department of Education Compliance Requirements: Eligibility Questioned costs: $14,678 Name of contact persons: Kristina Winterstein, Associate Controller Anticipated completion date: December 31, 2023 The District is aware of the importance of maintaining effective internal control over its federal awards and ensuring compliance with applicable federal regulations. The District will review and, as necessary, revise current policies and procedures relating to student eligibility as it relates to the TRIO?Upward Bound programs as well as the policies and procedures relating to documenting the calculation and payment of student stipends to ensure compliance with applicable federal regulations. The District will enhance communication and training efforts to ensure records are maintained that demonstrate appropriate review and approval of student eligibility prior to awarding program services.

Finding: 2022-001: Plan: A second staff member will review certifications and annual certifications to ensure accuracy based on the required back up documentation. Contact: Christina Morin, Program Director Anticipated completion date: March 15, 2023

Corrective Action Plan: This finding was also found during the past two fiscal year?s Single Audit and is a carryover issue stemming from the same underlying problem. The RESEA Program has been in a state on ongoing transition coming out of the COVID-19 pandemic as the Department needed to close the Program for a significant period during the pandemic and then subsequently transitioned to more of a virtual / flex program in calendar year 2021 and 2022. The Department has taken additional steps to try and correct this finding. For example, the Department instituted a mandatory check list for staff to complete as cases are closed. This was developed and provided to staff in June 2022. The RESEA supervisor continues to conduct random sampling on casefiles for accuracy reviews and will continue to provide ongoing supervisor feedback and staff training. Scheduled Completion Date of Corrective Action Plan: June 30 , 2023 Contacts for Corrective Action Plan: Cameron Wood, UI Director Cameron.Wood@vermont.gov

The Department acknowledges and accepts this finding, and as this is a repeat finding from last year?s ACFR audit, the Department maintains the same response and corrective action plan. The Pandemic Unemployment Assistance (PUA) program did not exist prior to the COVID-19 global health pandemic. Unlike the unemployment insurance program, which has been in existence since 1935, the PUA program did not have the inherent checks and balances built into the system to ensure proper program administration. Instead, state workforce agencies were expected to build the PUA program from the ground up with little guidance from the USDOL all the while managing through a pandemic that caused unprecedented upheaval in the employment status of millions of citizens. It is accurate that the Vermont Department of Labor was not able to implement the necessary checks and balances into the PUA program to ensure proper program eligibility. As has been pointed out in the audit finding, it was not until nine months after the start of the PUA program that Congress passed legislation that required documentation to be provided to substantiate program eligibility. At that time, due to the significant and unprecedented strains on the Department of Labor?s resources, the newly established documentation requirements were not able to be implemented prior to the end of the PUA program. The Department acknowledges that the lack of the ability to review claimant financial eligibility may have resulted in improper payments. It is important to point out that UIPL 16-20, Change 4 was issued on January 8, 2021, providing no time for UI programs to implement the required changes while still continuing to provide vital economic assistance to tens of thousands of individuals. The only other recourse available to the Department at that time would have been to stop program payments from issuing until the new eligibility requirements were reviewed. This would have left claimants without benefits for months while the Department used our limited financial and staff resources to implement the necessary changes. This is the result of the continuously changing eligibility requirements built from hastily implemented legislation and program design. In calendar year 2022, the Department began the process of retroactively reviewing all PUA claims that were filed and paid after the date of UIPL 16-20, Change 4 to ensure that proper documentation was provided to ensure program eligibility. Where appropriate, claims are being placed into an overpayment status and collection efforts will ensue. Corrective Action Plan: As mentioned above, the Department was aware that it was unable to implement the documentation requirement for the PUA program as required by the amendments to the CARES Act. The Department had every intention of going back and retroactively reviewing PUA claims for documentation and requiring submission for those claims that lacked adequate documentation retroactively. The USDOL Regional Office is aware of the process identified by the Department to resolve this issue retroactively. The Department has begun this work in early 2022 and will continue this review for PUA program eligibility for as long as USDOL provides the funding to do so until the Department has reviewed all PUA claims filed in calendar year 2021. Scheduled Completion Date of Corrective Action Plan: June 30, 2024 Contacts for Corrective Action Plan: Cameron Wood, UI Director Cameron.Wood@vermont.gov

Finding No. 2022?001 ? Special Tests and Provisions ? Return of Title IV Funds Condition found. The return of Title IV funds as calculated by the University was performed after the required 45 days, in the following case: Student Id. No. Determination date Refund date 92710 6/24/2022 8/24/2022 Management Response The University agrees with the finding. Corrective Action Plan The University affirms its understanding of its obligation to submit the return of Title IV funds due to a total withdrawal to the Department of Education no later than 45 days after the determination date, the date that the school became aware that the student withdrew. In this case, the disbursement of Title IV funds was posted at the same date and time the R2T4 was processed, and one process blocked the other. To avoid this issue, officials must be aware that process that involve return of funds should be processed on different days than the disbursement of Title IV funds are processed. Name of the Contact Person Responsible for Corrective Action Elaine Nu?ez, Financial Aid Office Director Anticipated Completion Date During fiscal year 2022-2023

SECTION III ? FEDERAL AWARD FINDINGS AND QUESTIONS COSTS FINDING 2022-002 ? CONTROLS AND NONCOMPLIANCE OVER ELIGIBILITY AND DISBURSEMENT Management?s Response The College accepts this finding and will continue to undergo updates in procedures regarding documentation retention. Plan SSC Student Financial Aid is in the process of developing an electronic document retention system. In the meantime, all documents are being retained in student files via hardcopy format under the supervision of the Manager. Each Friday the Manager (Coordinator in the absence of Manager) and Director audit files of students receiving FSEOG to verify document retention. Additionally, the College is implementing a Colleague rule to prevent disbursement of FSEOG to any student who does not have a $0 EFC. This is in addition to the existing rule that requires a student to be receiving a Federal Pell Grant in order to have a Federal SEOG disbursement paid to their College account. Anticipated Date of Completion 1/1/2023 Name of Contact Person Avianca Taylor

R2T4 Planned Corrective Action: ETBU Registrars office is now informing the Financial aid office of any student who withdrawals or that is reported as not attending in courses from the second FLEX terms. Financial aid is awarded based on total payment period enrollment and any notification of change in enrollment will result in a review and recalculation of aid eligibility if necessary. Reports were revised to reflect changes in enrollment after primary term census. Person Responsible for Corrective Action: Troy White, Registrar and Linda Slawson, Director of Financial aid. Anticipated Date of Completion: Already implemented.

Finding Number: 2022-002 Planned Corrective Action: Cost of attendance budgets will be established prior to any financial aid awarding. Person Responsible for Corrective Action Plan: Director of Financial Aid Compliance, Elease Cox Anticipated Date of Completion: Already implemented, Fall 2022

Recommendation: The County Children and Youth Services department should implement a file checklist to ensure copies of all Adoption Assistance recipients are complete. Program directors should review the file checklist and compare to the file when determination of eligibility is complete. Checklists should be signed and dated to ensure the approvals are completed. Staff should be trained on eligibility file record requirements and use of checklists to ensure consistent application of the policies. Action Taken: Starting in February 2023, the County Human Services Department hired a consultant that is completing an internal reconciliation of and review of all 2022-2023 records. Adoption file requirements and checklists have been implemented by the consultant to ensure consistent and complete files. The County CYS office will implement the checklists and policies of the consultant in file management. In addition, action is being taken to digitize all records for active adoption assistance recipients to ensure access is maintained and changes to Adoption Assistance files are kept updated. Responsible Individual for Corrective Action: Angelique Hiers, County of Delaware Department of Human Services Director Completion Date: December 31, 2023

Views of Responsible Officials and Planned Corrective Actions: During the pandemic, the TEFAP program was expanded using COVID-19 relief funds. Three Square had a misunderstanding in the classification of these supplemental commodities, and believed them to be part of COVlD-19 relief and as such did not necessitate an executed TEFAP Agency Partner Services Agreement. The four entities mentioned in the finding who received TEFAP commodities only received these supplemental COVlD-19 commodities. This finding was not pervasive throughout the organization, but rather isolated to a temporary program, which has now ended. To ensure effective internal controls, Three Square has designed a system to ensure an executed TEFAP Agency Partner Services Agreement is obtained prior to any TEFAP distribution to an Agency Partner. Moving forward, our agency services team will review all orders containing any federal commodity, regardless of the federal program. They will verify eligibility before approval is given to the warehouse to deliver the products.

Finding: 2022-006 Name of contact person: Brittany Majors (Program Manager), Meredith Farmer (Leadworker) Corrective Action: In this instance, the work number was being ran manually on their website and this informaiton was housed in the County's former document management system, Compass. This verification was lost and was unable to be recovered from the Cyber Incident in 2020. The State has since updated NCFAST functionality to include the running of work number through the NCFAST website. Therefore, moving forward all results will already be housed in that State supported system. The County would like to State that results returned recently support the action taken. Unit meeting was held to remind the workers to run work number in NCFAST. Proposed Completion Date: 9/30/2022

Finding: 2022-005 Name of contact person: Brittany Majors (Program Manager), Donna Rimmer (AM Supervisor), Joanna Thompson (Leadworker) Corrective Action: Due to a higher volume of vacancies and new hires with no previous Income Maintenance experience it has taken the Adult Medicaid unit some time to get all positions filled and staff trained adequately enough to assist with the processing of cases. During the time of extreme turnover the case workers in place prioritized cases which resulted in the client receiving a greater benefit as advised by the administrative letters issued by DHB given due to the PHE continuity of beneifts was in place. During this time frame the State only allowed specific reduction of benefits/terminiations. Therefore, these individuals would have continued to recieve the same benefit regardless of the SSI review being completed or not. The County has since filled all IMC II positions in that unit and hired a contracted trainer to assist with training in the Adult Medicaid unit. Workloads have been evaluated and specialized based off of program to reduce/eliminate processing errors moving forward. Proposed Completion Date: 9/23/2022

Finding: 2022-004 Name of contact person: Brittany Majors (Program Manager), Donna Rimmer (AM Supervisor), Joanna Thompson and Meredith Farmer (Leadworkers) Corrective Action: Adult Medicaid Supervisor updated the cover sheet/ checklist and documentation outline utilized by all caseworkers when making their determination of eligibility in hopes of reducing/eliminating any oversight which occurred during the past evaluations. The County would like to state that although data entry data occured in regards to resource evidence there where no benefits granted in error. Proposed Completion Date: 10/20/2022