Corrective Action Plans

2022-015 Improve Controls over Medicaid Capitation Payments for Medicare Members Federal Agency: U.S. Department of Health and Human Services State Entity: Department of Community Health (DCH) Corrective Action Plans: This correction was put into production on 7/1/2022. The recoupments began April 1, 2023, to coincide with the termination of the continuous coverage requirement of the Public Health Emergency (PHE). Estimated Completion Date: April 1, 2023 Contact Person: Lynnette Rhodes, MAP Executive Director Telephone: 404-656-7513; E-mail: lrhodes@dch.ga.gov

2022-023 Strengthen Controls over Eligibility Records Federal Agency: U.S. Department of Health and Human Services State Entity: Department of Human Services (DHS) Corrective Action Plans: ? The Program will work with the Community Action Agencies (CAAs) and the third party to modify the data system and establish a Community Services Block Grant (CSBG) Eligibility Date and Federal Poverty Level percentage or categorical eligibility status within the data system with each application. ? This modification will clearly identify the date that the household was eligible for CSBG services and ensure compliance with 42 U.S.C. ? 9902 (defining "low-income" and "poverty line"). The Household will be eligible for CSBG services for 90 days. At the 90-day marker, the Agency must re-determine eligibility to continue CSBG services. The services will end at the end of the current Federal Fiscal Year Contract and must be reestablished annually. ? For community events or indirect services aimed at assisting low-income communities, in accordance with 42 U.S.C. ? 9901 (objectives and purposes of the CSBG program), the CAAs will flag these events in the data system as "Community Event" and document the event's purpose, attendance, and any relevant eligibility information for participants. This approach will help demonstrate the services? validity and ensure compliance with the CSBG program's objectives. ? DHS will provide the reconciliation parameters and methodology to the CAAs for their quarterly reconciliation. ? The Program will update the CSBG Policy Manual and distribute to the network. The Program will provide training and guidance to the network to ensure that policies and procedures are consistently enforced and operating effectively. Estimated Completion Date: August 1, 2024 Contact Person: Cynthia Bryant, Unit Director Telephone: 470-259-8188; E-mail: cynthia.bryant@dhs.ga.gov

2022-032 Improve Controls over Employer-Filed Claims Federal Agency: Various Federal Agencies: U.S. Department of Homeland Security U.S. Department of Labor State Entity: Department of Labor (GDOL) Corrective Action Plans: The Georgia Department of Labor disagrees with this finding. The Employer Filed (Partial) Claims (EFC) program originated in the late 1960?s and was designed to allow employers with short term, temporary periods of lack of work for their employees to retain their workforce when work resumes. This is a program that many large manufacturers in Georgia rely on when they have temporary plant shutdowns and have for decades. When GDOL has attempted in the past to limit this program, we have met strong resistance from Georgia?s manufacturers. This program optimizes our ability to process and pay mass numbers of claims more quickly, such as what occurred at the beginning of the pandemic. EFCs may be filed by an employer with respect to any complete pay-period week during which an otherwise full-time employee works less than full-time, due to lack of work only, and earns an amount not exceeding his/her unemployment insurance weekly benefit amount. Such claims shall not be submitted or allowed for vacation days regardless of whether such vacation days were requested by the employee or established by the employer. Effective March 19, 2020, a temporary, Emergency Rule 300-2-4-05(1), containing Rule 300-2-4-.09(1) was signed which required employers to electronically submit EFCs on behalf of their employees whenever it is necessary to temporarily reduce work hours or there was no work available for a short period of time. Employers were allowed to file such claims for full and part time employees whose earnings had been reduced. In July 2020, the Rule was sunset and employers were no longer required to file EFCs. EFCs may be filed online by single entry or upload or paper. An employer may submit EFCs for regular state unemployment insurance programs including available extended benefits programs with the same eligibility requirements as regular UI, such as Pandemic Emergency Unemployment Compensation (PEUC) and State Extended Benefits (SEB), given all regular UI entitlement is exhausted. By electing to submit EFCs on behalf of the individuals, the employer is responsible for attesting to the employment status and weekly earnings of the individual for the EFC submitted. An affidavit certifying that the employer has obtained earnings from other employment as well as other requirements must be completed before EFCs can be entered or uploaded. Individuals for which EFCs are submitted are considered to be still attached to the employer and are exempt from the requirement to register for employment services per Georgia Employment Security Law Rules 300-2-4-.02. Such individuals are not required to be nor certify on a weekly basis to be able, available and actively seeking work. The GDOL disagrees that we would not provide the requested information to the auditors. The data requested relates to an ongoing federal criminal investigation. GDOL did not provide the data with concerns that dissemination of the data to a third party could jeopardize the ongoing criminal investigation and create legal risk for GDOL. GDOL stated that the auditors should obtain permission from the United States Department of Justice as a condition to dissemination of the data. GDOL did not receive any confirmation that the auditors had discussed the matter or coordinated with the US Department of Justice. Even though there have been some publicized indictments, the US Department of Justice has confirmed to GDOL that the investigation is ongoing and future indictments are anticipated. Notwithstanding, GDOL reiterates it would be happy to share the relevant data in its possession with assurances that the auditors will not publicize or disseminate any of the audit data without first consulting with the US Department of Justice. GDOL is also happy to cooperate with the auditors and provide information relating to how GDOL discovered the methods and schemes used by the fraudsters; however, GDOL has serious concerns about any publication of such information or of any other specific vulnerabilities in GDOL?s systems that would serve to encourage or perpetuate additional unemployment insurance fraud. Summary When we identified employer fraud schemes, we followed the guidance issued by United States Department of Labor (USDOL) and collaborated with the United States Department of Labor Office of Inspector General (OIG) to investigate these cases. Effective December 6, 2021, the EFC process was revised to require individuals (employees) to complete an EFC profile to include a real-time identity verification before payments can be made. Employers are responsible for submitting the request for the payment to certify to the individual?s employment status, but the individuals must certify their identity and personal information for the claim to be processed. Employees are notified when a claim is filed on their behalf and provided instructions for their portion of completing the EFC process. The MyUI Customer Portal dashboard provides all the EFC correspondence sent to the individual as well as a status of the profile set up and identify verification. Prior to the implementation of the EFC profile requirement, GDOL utilized the Social Security Administration (SSA) crossmatch and Systematic Alien Verification for Entitlement (SAVE) verification processes to verify the identity of claimants where employers submit claims on their behalf. GDOL has no plans to stop utilizing the EFC program as it is an effective and popular program among employers with a successful 60-year track record. GDOL greatly appreciates the feedback and recommendations and will consider this information in future endeavors to modernize and update system and business processes. Estimated Completion Date: December 6, 2021 Contact Person: Crystal Singleton, Policy and Procedure Manager Telephone: 404-232-3183; E-mail: Crystal.Singleton@gdol.ga.gov

2022-030 Strengthen Controls over the Summary Schedule of Prior Audit Findings Federal Agency: U.S. Department of Labor State Entity: Department of Labor (GDOL) Corrective Action Plans: As Georgia progressed towards addressing and pursuing efforts to resolve outstanding Coronavirus Aid, Relief, and Economic Security Act (CARES Act) matters, impediments such as limited workforce and system restrictions hindered progress. Such factors, imposed upon the intents to make system changes, corrections and enhancements. We have taken the following corrective actions in an ongoing effort to bring these findings to full resolution: 2020- 036 Improve Controls Over Eligibility Determinations In addition to steadily reviewing and determining eligibility of responses providing proof of Pandemic Unemployment Assistance (PUA) employment and wages, a task force has been established to assist with this effort. An ongoing campaign is in progress to onboard additional resources to increase the cadence of addressing these items. Claimants who fail to provide adequate proof are manually reconsidered and overpayments established appropriately. Since this process is manually reviewed by staff rather than by system automation, we anticipate this effort will take approximately 60 weeks to complete. When there are indications of potential fraud, additional investigation is pursued to determine if fraud penalties should be imposed. 2021-036 ? Improve Controls over Employer-Filed Claims Effective December 6, 2021, the Employer-Filed Claims (EFC) process was revised to require individuals (employees) to complete an EFC profile to include a real-time identity verification before payments can be made. Employers are responsible for submitting the request for the payment to certify to the individual?s employment status but the individuals must certify their identity and personal information for the claim to be processed. Employees are notified when a claim is filed on their behalf and provided instructions for their portion of completing the EFC process. The MyUI dashboard provides all the EFC correspondence sent to the individual as well as a status of the profile set up and identify verification. Summary We are currently seeking funding to modernize our UI benefits system which will incorporate and improve the controls cited. GDOL will develop and implement procedures to ensure the status of each prior audit finding is reported in an accurate manner. GDOL will ensure staff responsible for submitting the status of prior period audit findings are trained and understand their responsibilities associated with the Summary Schedule of Prior Audit Findings under the Uniform Guidance. Estimated Completion Date: December 6, 2021 Contact Person: Racquel Robinson, Unemployment Policy and Procedures Chief Telephone: 404-232-3190; E-mail: Racquel.Robinson@gdol.ga.gov

2022-028 Improve Controls over Eligibility Determinations Federal Agency: U.S. Department of Labor State Entity: Department of Labor (GDOL) Corrective Action Plans: (1) Identity verification was not performed appropriately in eight instances. GDOL Response: The Georgia Department of Labor disagrees with these findings as it relates to identity verification. The auditors did not identify the type of identity verification procedures not performed or any identity verification procedures that GDOL was required to perform. There was not a mandatory requirement to complete identity verification at the time most of these applications were submitted as the majority of these claims were employer-filed claims (EFC). Identity requirements for EFCs were implemented at a later date. At the start of the pandemic, the identity proofing processes available were Social Security Administration (SSA) verification, Department of Driver Services (DDS) crossmatch and for non-citizens, Department of Homeland Security Systematic Alien Verification for Entitlement (SAVE). As applicable, these processes were performed on all initial regular and EFCs, which includes the eight instances. (2) Non-monetary determination was not performed in two instances. GDOL Response: Instance 1: A disqualifying non-monetary determination was released and disqualification was entered into the system. The system erroneously released a payment for the week in question. An overpayment was established in January 2023. Instance 2: Claim was processed but issue did not get added to the claim to address separation reasons. A non-monetary determination was released in November 2022 to allow benefits. All payable weeks have been processed. There was no detriment to the claimant as they were determined eligible nor was there any monetary loss to the State. (3) Proof of employment or self-employment or a valid offer to begin employment and proof of wages was not submitted by two Pandemic Unemployment Assistance (PUA) claimants. GDOL Response: The GDOL disagrees with the findings related to proof of employment or self-employment or a valid offer to begin employment and proof of wages was not submitted by two PUA claimants. Under the Coronavirus Aid, Relief, and Economic Security Act (CARES Act), claimants did not have to provide proof of employment or self-employment. It was not until Continued Assistance Act (CAA) was enacted December 27, 2020 that such proof was required. The disqualification could not be applied retroactively, as outlined in Unemployment Insurance Program Letter (UIPL) No. 16-20, Change 4. Instance 1: Claimants who established PUA entitlement at the minimum weekly benefit amount were instructed to submit their proof of wages by email. Under the CARES Act, if claimants did not submit proof, federal requirements only allowed for payment of the minimum weekly benefit amount and no disqualification of benefits. The claim cited was originally established and remains established for the minimum weekly benefit amount. In accordance with CAA rules, the claimant was notified to provide proof of employment and wages for weeks paid on or after 12/27/20. To date, no proof has been provided by the claimant. The claimant has been disqualified effective 12/27/20 and an overpayment was established in January 2023. Instance 2: Claimants who established PUA entitlement with a weekly benefit amount greater than the minimum was based on wages entered by the claimant and/or wages reported by the employer. CARES Act only required proof of wages to be submitted. If claimants did not submit proof, federal requirements only allowed for payment of the minimum weekly benefit amount and no disqualification of benefits. Claims established at a higher weekly benefit amount had to be reduced to the minimum amount if no proof was provided. To date, no proof has been provided by the claimant cited. The claim was established above the minimum amount; therefore, benefits were reduced to the minimum amount. In accordance with CAA rules, claimants were notified to provide proof of employment and wages for weeks paid on or after 12/27/20. The claimant has been disqualified effective 12/27/20 and an overpayment was established in November 2022 for weeks paid over the minimum amount under CARES and weeks paid after 12/27/20 under CAA/American Rescue Plan Act (ARPA). (4) Claimants did not self-certify for benefits in 18 instances. GDOL Response: The GDOL disagrees with the findings Claimants did not self-certify for benefits in 18 instances. Employer-Filed Claims (EFC) are submitted by employers on behalf of the claimant. The employer is responsible for attesting to the employment status and weekly earnings of the claimant for the EFC submitted. An affidavit certifying that the employer has obtained earnings from other employment as well as other requirements must be completed before EFCs can be entered or uploaded. Claimants for which EFCs are submitted are considered to be still attached to the employer and are exempt from the requirement to register for employment services per Georgia Employment Security Law Rule 300-2-4-.02. Such individuals are not required to be nor certify on a weekly basis to be able, available and actively seeking work. Additionally, USDOL encouraged states to waive work search requirements for all claimants during the pandemic. (5) Claimant and payment information did not exist in the system of record in one instance. GDOL Response: The identifying information the auditors provided for this claim does not match any claims in our system. Therefore, we are unable to validate the auditor?s finding. Summary The information above is provided for your consideration in dispelling some of the audit findings. GDOL took immediate action to establish the federal UI programs and comply with federal guidance and regulations. There was not a mandatory requirement to complete identity verification at the time most of these applications were submitted. At the start of the pandemic, the identity proofing processes available were Social Security Administration (SSA) verification, Department of Driver Services (DDS) crossmatch and for non-citizens, Department of Homeland Security Systematic Alien Verification for Entitlement (SAVE). As applicable, these processes were performed on all initial regular and employer-filed claims (EFC). Beginning January 2021, PUA applicants were required to complete additional identity verification processes. Beginning in December 2021, all applicants were required to complete identity verification prior to filing a claim for UI benefits. Effective December 6, 2021, the EFC process was revised to require individuals (employees) to complete an EFC profile to include a real-time identity verification before payments can be made. Employers are responsible for submitting the request for the payment to certify to the individual?s employment status, but the individuals must certify their identity and personal information for the claim to be processed. Employees are notified when a claim is filed on their behalf and provided instructions for their portion of completing the EFC process. Additionally, as system deficiencies were identified, changes were made as quickly as possible to mitigate risks of improper payments. Automation of PUA claims was suspended and reviews were handled manually by staff before a determination was released. GDOL established task forces to develop and implement strategies to address the ramped fraud attempts to bypass system and procedural safeguards. We regularly attended fraud meetings with various federal agencies and unemployment agencies from other states to share best practices for combatting fraud. As resources permitted, we did our best to implement these best practices and strategies. Prioritizing system changes was challenging with the time constraints, necessity to build a program based on an established program that operated manually in our state and the demands of all other federal UI programs; but GDOL made every attempt to maximize our system capacity to accommodate the guidelines of each program requirements. Georgia greatly appreciates your time and consideration of our response to the findings and welcome you to contact us if you have any questions. Estimated Completion Date: December 16, 2021 Contact Person: Crystal Singleton, Policy and Procedure Manager Telephone: 404-232-3183; E-mail: Crystal.Singleton@gdol.ga.gov

Corrective action plan: For the annual UI access review, TWC will monitor the annual CAPPS Systems Access Privileges Certification in CAPPS to ensure timely completion. For the code developer/promoter system roles, IT will implement a new quarterly review of developer roles to ensure no staff member has both roles assigned to ensure separation of duties in the system roles. We are also looking at potential technical solutions that would automate and prevent staff being assigned certain roles based on separation of duties. Implementation date(s): February 28,2023 Responsible Persons: Heather Hall, CIO

Finding 2022-002 - Eligibility - Significant Deficiency in Internal Control Over Compliance - Recommendation: We recommend the University amend procedures so in the event that packaging is done manually, there are added reviews over the student's aid awarded. - Corrective Action Plan: We accept Moss Adams' recommendation and if a situation arises where we must manually package a student, the procedure will include an additional review by another individual, either the Director or a Counselor, to review the package for accuracy. An internal review of FY22 indicated this was an isolated incident. - Anticipated Completion Date: Management will complete the Corrective Action Plan by June 30, 2023. - Individual Responsible: Oscar Jones, Director of Financial Aid.

2022-002 ALLOWABLE COSTS AND ALLOWABLE ACTIVITIES ? COVID-19 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS Recommendation: We recommend that the County include consideration of any expenditures that may be part of other federal programs as part of their review. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The County will review their procedures to ensure expenditures coded to federal grants are not already claimed by other grant programs. Name of the contact person responsible for corrective action plan: Deborah Erickson, Administrative Services Director Planned completion date for corrective action plan: December 31, 2023

2022-006 SPECIAL PROVISIONS ? STATE ADMINISTRATIVE MATCHING GRANTS FOR SUPPLEMENTAL NUTRITION ASSISTANCE PROGRAM (SNAP CLUSTER) Recommendation: We recommend that income verification be reviewed for each eligible case files. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The County will continue to work on training new staff on requirements, and continue to perform case file reviews. Name of the contact person responsible for corrective action plan: Deborah Erickson, Administrative Services Director Planned completion date for corrective action plan: December 31, 2023

FINDING 2022-004 Finding: Non-Public School: No documentation could be found to support non-public school students qualifying for Title I on the 2020-2021 and 2021-2022 Applications. These numbers determine equitable share distributions to these non-public schools. Contact Person Responsible for Corrective Action: Carrie McGuire Contact Phone Number: (574) 875-5161 Views of Responsible Official: We concur with the finding Description of Corrective Action Plan: Non public schools will be consulted prior to the initial Title I(a) application being submitted at the start of each grant cycle. Non-public school consultation forms and spreadsheet(s) for any equitable share calculations will be uploaded into the Title I application center as attachments. These will be verified by the corporation treasurer before the Title I application is submitted annually. Prior to the submission of the Title I application annually, the federal grants coordinator with consult with all non-public schools within our district boundaries as listed by the IDOE in the grant application portal. The signed consultation forms will be uploaded to the IDOE?s Title I Programs Application Center as attachments. The corporation treasurer will verify that all consultation forms are signed and uploaded in the Application Center before the initial grant application budget can be submitted for review. A form will be created so that when files are downloaded from the Child Nutrition Program (CNP) website and subsequently uploaded into Mealtime, there will be places for a signature of the person who downloaded the file, a signature for the person who uploaded the file, and a reviewer. Anticipated Completion Date: September 15, 2023

The Department of Human Services (DHS) agrees with the findings. DHS will reach out to the four (4) STAY DC payees to formally request the return of improper payments to the District of Columbia. This will be tracked to ensure the return is recorded against ERA within the District?s financial system. To address any documentation gaps, DHS introduced new Standard Operating Procedures (SOPs) for Family Rehousing and Stabilization Program (FRSP) in FY23. The new SOP implements stricter internal control procedures, regular audits, and streamlining the eligibility determination process. The District will reclass all identified errored payments off of the ERA fund to Local funding by the closeout of FY23, Sept. 30, 2023. DHS also completed a reconciliation of data reported to U.S. Treasury for ERA1 closeout reporting and ERA2 2023 Q2 reporting to ensure that no errored payments were included. See Corrective Action Plan for chart/table

Department: Health and Human Services Title: Internal control over P-EBT Food Benefits needs improvement Questioned Costs: Known: $61,507,558 Likely: None Status: Management?s opinion is that corrective action is not required Corrective Action: The Department disagrees with this finding and does not believe that corrective action is warranted. During the course of the audit, the Department provided the Office of the State Auditor (OSA) with the complete population of recipients as well as the supporting information necessary for OSA to conduct testing to verify compliance with federal program requirements. The only remaining action that is required is for OSA to perform their testing. Completion Date: N/A Agency Contact: Anthony Pelotte, Director, Office for Family Independence, DHHS, 207-624-4104

Condition Found: During audit fieldwork, the auditors spoke to City Staff about the Illinois Environmental Protection Agency (IEPA) Loan reimbursements the City had received during FY2022. The question was whether or not the expenditures we asked to be reimbursed for were eligible because the expense was incurred prior to the loan being approved. The expenditures in question had already been reimbursed to the City from the IEPA and were considered eligible expenditures. When the request from the auditors came for the account numbers that the expenditures had been paid out of, City Staff realized that the majority of these older invoices had been paid with proceeds from the 2015 GO Note issuance, and as such were not eligible to be reimbursed by the IEPA. City Staff relayed this discovery to the auditors and recorded an adjustment to reduce the receivable from the IEPA ($260,749.30) that were not eligible. The City has worked with the consultant managing the project at Baxter and Woodman, and the IEPA, to remedy the issue with a reduction to the City's next distribution. The IEPA loan has not been closed out as of this date, allowing for the reduction without significant impact. Corrective Action Plan: Going forward, the Public Works Department will forward the IEPA Loan draw requests to the Finance Department to be reviewed before being submitted to the IEPA for reimbursement. The Finance Department was not included in the draw request prior to this finding. By having the Finance Department review the draw requests, we can ensure that all items submitted for reimbursement are eligible. Staff at Baxter and Woodman, who package invoices for submittal to the IEPA on behalf of the City, will also be reviewing invoices more closely before submittal as an independent verification. Implementation Date: This change is effective immediately and the Finance Department has already started reviewing the next invoices being submitted to the IEPA for reimbursement.

The DHS and DHCF DCAS team agree with the findings noted in this report. DHS self-reported these findings as part of the Agencies ongoing effort to maintain integrity with all eligibility determinations. The root cause for each of the eleven (11) issues with the ADP system for SNAP varied. For bullet point #1 of the findings noted: ? Action/Phase: Request information from DCAS to determine the magnitude of the deficiency. Expected Outcome: Requested data/information is provided on the identified deficiency. ? Action/Phase: Review and Prioritization - Review data to define scope/magnitude/root cause(s) of deficiency. Expected Outcome: Magnitude of deficiency is determined, and management prioritizes deficiency. ? Action/Phase: Design and Development - Identify and develop corrective actions to address root cause of deficiency. Expected Outcome: Root cause of deficiency is verified, cross-functional team selects actions to resolve root cause(s) actions tested, as applicable. ? Action/Phase: Implement - Implement approved corrective actions and measure/metrics to monitor effectiveness of corrective action. Expected Outcome: Management approves actions, actions implemented along metrics/measures. ? Action/Phase: Monitor and Evaluation - Ensure the changes are successful. Expected Outcome: Once corrective actions are identified, a monitoring and evaluation plan will be developed and implemented to determine if the implemented actions substantially reduce/eliminate the deficiency from occurring. In March 2023, a request to run this report was made. The run took place in April 2023 and ultimately found that the report could not be derived. Ultimately the request/ticket below will be closed. For bullet point #2 of the findings noted: ? Action/Phase: Request information from DCAS to determine the magnitude of the deficiency. Expected Outcome: Requested data/information is provided on the identified deficiency. ? Action/Phase: Review and Prioritization - Review data to define scope/magnitude/root cause(s) of deficiency. Expected Outcome: Magnitude of deficiency is determined, and management prioritizes deficiency. ? Action/Phase: Design and Development - Identify and develop corrective actions to address root cause of deficiency. Expected Outcome: Root cause of deficiency is verified, cross-functional team selects actions to resolve root cause(s) actions tested, as applicable. ? Action/Phase: Implement - Implement approved corrective actions and measure/metrics to monitor effectiveness of corrective action. Expected Outcome: Management approves actions, actions implemented along metrics/measures. ? Action/Phase: Monitor and Evaluation - Ensure the changes are successful. Expected Outcome: Once corrective actions are identified, a monitoring and evaluation plan will be developed and implemented to determine if the implemented actions substantially reduce/eliminate the deficiency from occurring. DCAS system will be fixed no later than FY2024 Q3. For bullet point #3 of the findings noted: ? Action/Phase: Request information from DCAS to determine the magnitude of the deficiency. Expected Outcome: Requested data/information is provided on the identified deficiency. ? Action/Phase: Review and Prioritization - Review data to define scope/magnitude/root cause(s) of deficiency. Expected Outcome: Magnitude of deficiency is determined, and management prioritizes deficiency. ? Action/Phase: Design and Development - Identify and develop corrective actions to address root cause of deficiency. Expected Outcome: Root cause of deficiency is verified, cross-functional team selects actions to resolve root cause(s) actions tested, as applicable. ? Action/Phase: Implement - Implement approved corrective actions and measure/metrics to monitor effectiveness of corrective action. Expected Outcome: Management approves actions, actions implemented along metrics/measures. ? Action/Phase: Monitor and Evaluation - Ensure the changes are successful. Expected Outcome: Implementation of DCAS Release Part 2 was completed on March 26, 2023. The District requested FNS close this finding. Implementation of DCAS Release Part 2 was completed on March 2023. The District is requesting that this finding be closed. For bullet point #4 of the findings noted: ? Action/Phase: Request information from DCAS to determine the magnitude of the deficiency. Expected Outcome: Requested data/information is provided on the identified deficiency. ? Action/Phase: Review and Prioritization - Review data to define scope/magnitude/root cause(s) of deficiency. Expected Outcome: Magnitude of deficiency is determined, and management prioritizes deficiency. ? Action/Phase: Design and Development - Identify and develop corrective actions to address root cause of deficiency. Expected Outcome: Root cause of deficiency is verified, cross-functional team selects actions to resolve root cause(s) actions tested, as applicable. ? Action/Phase: Implement - Implement approved corrective actions and measure/metrics to monitor effectiveness of corrective action. Expected Outcome: Management approves actions, actions implemented along metrics/measures. ? Action/Phase: Monitor and Evaluation: Ensure the changes are successful. Expected Outcome: Once corrective actions are identified, a monitoring and evaluation plan will be developed and implemented to determine if the implemented actions substantially reduce/eliminate the deficiency from occurring. The data needed from DCAS to determine the scope/magnitude has not yet been provided. However, DCAS considers this as a high priority ticket for Releases 4 and 5. See Corrective Action Plan for chart/table

Reporting views of responsible officials and planned corrective actions Management will put in place procedures to ensure verification of tenant assets is done during recertification.

2022-002 Eligibility ? Maintain good standing or satisfactory academic progress Contact: Jeffrey C. Straits Title: Chief Financial Officer Phone Number: (202)885-8684 Anticipated Completion Date- Done Corrective Action Wesley Theological Seminary will ensure that students maintain a good standing or satisfactory academic progress in order to be eligible for Federal direct student loans per the OMB Compliance Supplement. Wesley acknowledges that before the outsourcing of our financial aid processing, there was a breakdown in the seminary following policies, procedures, and controls, which allowed this error. The Seminary will review all policies and procedures related to this control and develop ways to strengthen these controls. Wesley will also complete a review of all active federal loans for the fiscal year 2022 to identify if there are further processing errors allowing loans to students without maintaining good standing or satisfactory academic progress to be eligible for Federal direct student loans. Wesley management will also implement quarterly testing of randomly selected student loan transactions. The testing will include the verification of eligibility for aggregate loan totals, good standing, and satisfactory academic progress. The results of this testing will be reviewed by the CFO and maintained by Wesley?s management. Status as of November 2022 Wesley Theological Seminary outsourced our financial aid processing in January 2022. The error found was processed by our internal Financial Aid Director before the outsourcing of financial aid. Wesley has reviewed our policies and procedures related to this issue. We will add to the policies and procedures that the CFO will also approve all appeals approved by the Financial Aid Committee for lack of a student?s adequate satisfactory academic progress. The CFO?s approval will also be maintained with the appeal records of the Financial Aid Committee. We completed the review of all students who received Federal financial aid in the fiscal year 2022. There were no other students with inadequate satisfactory academic progress other than the one previously identified by BDO. Our outsourced financial aid processor will ensure the review of satisfactory academic progress prior to processing a loan, as required in our policies and procedures. To verify ongoing compliance of our outsourced financial aid processor with our financial aid policies, procedures, and controls, we are adding a requirement of quarterly random testing of students? records for the verification of eligibility for aggregate loan totals, good standing, and satisfactory academic progress. Wesley management has completed the fiscal year 2023 first quarter review of random students? transactions, and we did not find any errors. The testing results were reviewed by the CFO and maintained by Wesley?s management.

2022-001 Eligibility ? Aggregate Loan Limits for Subsidized and Unsubsidized Loans Contact: Jeffrey C. Straits Title: Chief Financial Officer Phone Number: (202)885-8684 Anticipated Completion Date- Done Corrective Action Wesley Theological Seminary will ensure that the loans disbursed by the Institution are within the loan limits prescribed in the OMB Compliance Supplement. Wesley acknowledges that before outsourcing our financial aid processing, there was a breakdown in the Seminary following policies, procedures, and controls within financial aid, which allowed these errors. The Seminary will review all policies and procedures related to this control. We will also complete a review of all active federal loans for the fiscal year 2022 to identify if there are further processing errors allowing loans above the aggregate loan limits. Wesley management will also implement quarterly testing of randomly selected student loan transactions. The testing will include the verification of eligibility for aggregate loan totals, good standing, and satisfactory academic progress. The results of this testing will be reviewed by the CFO and maintained by Wesley?s management. Status as of November 2022 Wesley Theological Seminary outsourced our financial aid processing in January 2022. Wesley will ensure the work prepared by outsourced personnel is reviewed properly and such review is documented properly. All of the errors found were processed by our internal Financial Aid Director before the outsourcing of financial aid processing. We completed the review of all students who received Federal financial aid in the fiscal year 2022. There were seven students with awards over the aggregate maximum (including those previously identified by BDO). The total amount awarded over the per-person aggregate limit was $79,159. Our outsourced financial aid processor will ensure the review of total student debt prior to processing a loan, as required in our policies and procedures. Wesley management has reviewed our policies and procedures related to this issue. To verify ongoing compliance of our outsourced financial aid processor with our financial aid policies, procedures, and controls, we are adding a requirement of quarterly random testing of students? records for the verification of eligibility for aggregate loan totals, good standing, and satisfactory academic progress. Wesley management has completed the fiscal year 2023 first quarter review of random students? transactions, and we did not find any errors. The testing results were reviewed by the CFO and maintained by Wesley?s management.

Recommendation: We recommend the District review the requirements of 2 CFR Section 200.213 and ensure that a review of the eligibility of potential vendors to participate in Federal assistance programs or activities is performed prior to disbursing funds to the vendor. Action taken: The district entered into a shared services agreement with Capital Region BOCES in March of 2022 for management of the School Nutrition program. It was assumed that this was a procedure they followed; however, documentation was not provided and the external auditors included it as a finding. Todd Barker is the new School Nutrition Director with BOCES and he will provide documentation to the district that due diligence has been done to meet this requirement. Anticipated completion date: 11/1/2022

Identifying Number: 2022-001 Finding: A student was improperly awarded and disbursed a TEACH grant. Corrective Actions Taken or Planned: In April 2021, Financial Aid Staff collected TEACH Grant counseling for two academic years (20-21 and 21-22) at the same time and awarded the grant for both academic years based on the GPA as of that date. The student was eligible for 20-21, but at the end of the 20-21 academic year, their GPA had dropped below the 3.25 requirement, making them ineligible for the grant in 21-22. The Financial Aid Staff did not double check the GPA after 20-21. The TEACH Grant was refunded to the Department on 6/30/22. An additional step was added to our manual that requires all TEACH Grants set up prior to the first origination will be double-checked to verify eligibility. Persons Responsible and Completion Date: Mark Freed, Director of Financial Aid, June 30, 2022

Views of Responsible Officials and Planned Corrective Action: Management agrees with this finding. As noted, a turnover in staff happened right at the time when the verification for FY22 was due and the new staff member did not realize the required verification had not occurred. The School followed proper procedures each year prior to FY22. The School identified the FY22 error at the beginning of the 2022-2023 school year prior to the audit. Immediate action was taken to ensure this error would not reoccur in the future when the School experienced a staffing change. In so doing, the School implemented a step-by-step tutorial of procedures, including reporting dates and deadlines. Necessary staff members have attended, and will continue to attend, training for items related to the application of Educational Benefits. The verification process was checked by a supervisor to ensure proper processes were followed for the 2022-2023 school year and they were.

CORRECTIVE ACTION PLAN To Whom It May Concern: This letter includes the corrective action plan in response to the audit finding from the Single Audit for the 2021-22 Award Year. Audit Finding 2022-001: Student received an incorrect amount of Pell award and was over awarded by $200. The amount was returned to the U.S. Department of Education in July 2022. Corrective Action Plan: This was an unusual case where a third disbursement was added manually late in the year due to a Professional Judgement appeal. In order to avoid an over-award in the future, the Financial Aid Office will implement the following: - The Financial Aid Office will request training from our Ellucian consultant on how best to add unusual disbursements. - Otherwise, staff should consistently use the Pell auto-package functionality within the Colleague system. - If a disbursement must be added manually due to a functionality error, the award change must be reviewed by a senior staff member. - The grant amounts will be audited at the end of the year. The contact person responsible for the corrective action is Cheryl Gillies, Executive Director, Financial Aid. The corrective action has been implemented as of July 31, 2022. Please let me know if you have any additional questions. Sincerely, Cheryl Gillies Executive Director, Financial Aid ArtCenter 1700 Lida St. Pasadena, CA 91103 626.396.2204

Finding 2021-004 Name of contact person: April Rollins, Income Maintenance Administrator II Corrective Action: Refresher training will be held for Medicaid staff on the topic of obtaining verifications, reading verifications, and entering complete and accurate documentation when determining and redetermining eligibility and entering said information verifications accurately in NC Fast. Second party reviews in excess of the state's mandated 98 will be conducted quarterly. Proposed completion date: 11/30/2022

Finding 2022-003 Name of contact person: April Rollins, Income Maintenance Administrator II Corrective Action: Refresher training will be held for Medicaid staff on the topic of timely reacting to notifications and obtaining verifications, reading verifications, and entering complete and accurate documentation when determining and redetermining eligibility and entering said information verifications accurately in NC Fast. Second party reviews in excess of the state's mandated 98 will be conducted quarterly. Proposed completion date: 11/30/2022

Finding 2022-002 Name of contact person: April Rollins, Income Maintenance Administrator II Corrective Action: Refresher training will be held for Medicaid staff on the topic of obtaining verifications, reading verifications, and entering complete and accurate documentation when determining and redetermining eligibility and entering said information verifications accurately in NC Fast. Second party reviews in excess of the state's mandated 98 will be conducted quarterly. Proposed completion date: 11/30/2022

Finding 2022-001 Name of contact person: April Rollins, Income Maintenance Administrator II Corrective Action: Refresher training will be held for Medicaid staff on the topic of obtaining verifications, reading verifications, and entering complete and accurate documentation when determining and redetermining eligibility and entering said information verifications accurately in NC Fast. Second party reviews in excess of the state's mandated 98 will be conducted quarterly. Proposed completion date: 11/30/2022