Corrective Action Plans

FINDING 2025-009 Finding Subject: Title I Grants to Local Educational Agencies - Eligibility Contact Person Responsible for Corrective Action: Regin Johnson, Title 1 Director Rae Lopez, Student Services Director Contact Phone Number and Email Address: rjohnson@chsnewtech.com rlopez@chsnewtech.com 219-838-1819 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The error causing this finding is within part of the annual student registration process. If a parent did not provide the socio-economic status (SES) data necessary to determine Title I eligibility, the student information system defaulted their SES to a former value. To correct this error, the collection of the SES data will be reviewed by the data manager to identify missing information. School registrars will request the parent/guardian provide any missing information. Students that have no current SES data by student count day will be automatically flagged as ineligible for the Title I count. This verified data will be what is submitted to the IDOE Data Exchange. Anticipated Completion Date: This revised process will be implemented for the 2026-2027 school year enrollment registration process. 58 INDIANA STATE BOARD OF ACCOUNTS 60

Finding Number: 2025-003 Condition: The project description in the grant award specified that activities would be performed within disadvantaged opportunity zones. However, during the period of performance, DWSD incurred $4.1 million in expenditures related to lead service line replacements that were performed outside of those designated zones. At the time the costs were incurred, DWSD did not have controls in place to ensure that project activities continued to align with the geographic requirements of the award or to promptly notify the granting agency when activities could not be performed as originally planned. Planned Corrective Action: DWSD has since implemented geographical verification controls that incorporate grant standards, aligned checklists and policy updates. Pre-expenditure approval process will be strengthened including training. Contact person responsible for corrective action: Istakur Rahman Anticipated Completion Date: 6/30/2026

Eligibility Documentation - Criteria: Eligible individuals are individuals who are at least 16 years of age, who are not enrolled or required to be enrolled in secondary school under state law, and who are basic skills deficient, do not have a secondary school diploma or its recognized equivalent and have not achieved an equivalent level of education, or are English language learners (29 USC 3272(4)). Condition: Students are required to fill out an application prior to being admitted to the program. The Center reviews the application and inputs the data into the Department of Elementary and Secondary Education (DESE) system, however does not maintain the applications to support that the students met the eligibility requirements. Context: For twenty-five student selections, there was no documentation maintained to support student age. Cause: Documentation was shredded due to personal information. Effect: Documentation was not maintained to support compliance with the standards. Questioned Costs: None. Repeat Finding: No. Recommendation: Documentation should be maintained to support all eligible students enrolled in the program. Contact: Vincent Rivers, Executive Director. Corrective Actions Taken or Planned: We have implemented a policy to scan and maintain all student applications on the network.

Dear Mr. Waguespack: The Louisiana Department of Health (LDH) acknowledges receipt of correspondence from the Louisiana Legislative Auditor (LLA) dated December 8, 2025, titled Noncompliance with Fee-for-Service Provider Revalidation Requirements. LDH appreciates the opportunity to provide this response to your office's findings. Finding: Noncompliance with Fee-for-Service Provider Revalidation Requirements. Recommendation: LDH should adequately monitor the contractor to ensure all providers are revalidated within the required timeframe in accordance with federal regulations. LDH Response: LDH concurs with the LLA's finding that 134 Durable Medical Equipment (DME) providers due for their three (3) year revalidation were not completed within the allowable timeframe and three (3) other providers due for their five (5) year revalidation were not completed timely. Corrective Action: In 2024, LDH identified upcoming revalidations for DME providers, who are required to revalidate every three years. To ensure timely execution, LDH established weekly "Revalidation" meetings with Gainwell Technologies, LDH's contracted vendor, and documented the process. Revalidation notifications were scheduled for distribution at the end of 2024 to give providers adequate time to meet their deadlines. However, Gainwell Technologies failed to complete the necessary system updates to support the revalidation effort. As a result, the notifications were not sent as committed. This failure caused direct delays in distributing revalidation invitation letters and emails. On December 30th, LDH also identified additional overdue revalidations that Gainwell had not addressed and immediately escalated the issue. The revalidation process has since been completed and LDH provided updated records reflecting the date providers completed revalidation after June 30, 2025, or were deactivated. LDH directed Gainwell Technologies to submit a Corrective Action Plan (CAP) outlining how they will prevent a recurrence of this failure. As part of the corrective action plan, Gainwell Technologies created a standard operating procedure (SOP) for the provider enrollment unit to ensure revalidation letters and emails are issued to all providers due for revalidation. The SOP includes quality checks to ensure appropriate tasks are completed by the appropriate team members regarding activities. Additionally, LDH is considering all appropriate options against Gainwell Technologies, including CAPs and potential fines. You may contact Seth Gold, Medicaid Executive Director, at (225) 219-7810 or via e-mail at Seth.Gold@la.gov or Brandon Bueche, Medicaid Deputy Director, at (225) 384-0460 or via e-mail at Brandon.Bueche@.la.gov with any questions about this matter.

Dear Mr. Waguespack: The Louisiana Department of Health (LDH) acknowledges receipt of correspondence from the Louisiana Legislative Auditor (LLA) dated January 27, 2026, titled Inadequate Internal Controls over Eligibility Determinations. LDH appreciates the opportunity to provide this response to your office's findings. Finding: Inadequate Internal Controls over Eligibility Determinations. Recommendation: LDH should ensure its employees follow procedures and federal regulations relating to eligibility determinations and redeterminations in the Medicaid and CHIP programs to ensure the case records support the eligibility decisions. LDH Response: LDH concurs in part with LLA's finding of inadequate internal controls over eligibility determinations. For the Medicaid finding noted as not accurately processing SNAP renewal, LDH concurs in part. The eligibility determination system accurately processed the SNAP renewal as an administrative renewal. The issue identified was limited to inaccurate automated case note language. This documentation issue did not impact eligibility outcomes and was corrected effective December 2024. For the 12 Medicaid findings noted as not obtaining required determinations prior to renewing eligibility, LDH concurs. • Seven (7) findings occurred during the effective period of the $0 income waiver under Section 1902(e) (14) (A), and the system applied waiver-approved income verification logic consistent with LDH policy. Following the expiration of the waiver, system logic was updated and completed in August 2025 to align with post-waiver renewal requirements. • For one (1) finding verification was provided but not reflected in the case record due to analyst execution. This was discussed with the analyst on October 15, 2025. • For three (3) findings the system retained existing resource information when external asset verification interfaces returned no results, consistent with LDH Asset Verification System (AVS) policy and procedures designed to prevent the introduction of unverifiable data. System logic was updated and completed in October 2025. • For one (1) finding the system renewed eligibility consistent with existing renewal processing rules. LDH has reviewed this scenario and will evaluate whether additional procedural or system safeguards are appropriate. For the seven (7) Medicaid findings noted as not obtaining required determinations prior to renewing eligibility which resulted in beneficiaries being invalidly enrolled, LDH concurs in part. • Six (6) findings resulted in case analysts failing to properly follow policy/procedures prior to determining or continuing eligibility. Ongoing training is in progress. • For the finding noted as not documenting school enrollment for the beneficiary over age 18 on Children's Choice Waiver, LDH does not concur. School enrollment is not a condition of eligibility; therefore, LDH is not required to not verify school enrollment when determining eligibility. Children's Choice and Support Waiver programs are initiated by the Office of Citizen's with Developmental Disabilities (OCDD) who determines the appropriate waiver program for the beneficiary. (OCDD) notifies LDH of the necessary action or updates to the service type when a transition of waiver services takes place. For the three (3) CHIP findings noted as not accurately processing SNAP renewal, LDH concurs in part. The eligibility determination system accurately processed the SNAP renewal as an administrative renewal. The issue identified was limited to inaccurate automated case note language. This documentation issue did not impact eligibility outcomes and was corrected effective December 2024. For the 10 CHIP findings noted as not obtaining required documentation prior to renewing eligibility, LDH concurs. • Seven (7) findings occurred during the effective period of the $0 income waiver under Section 1902(e) (14) (A), and the system applied waiver-approved income verification logic consistent with LDH policy. Following expiration of the waiver, system logic was updated in July 2025 to align with post-waiver renewal requirements. • Two (2) findings, the system completed renewals consistent with interface results available at the time of processing. The case record reflected unemployment income; however, interfaces returned no income found. • One (1) finding the analyst did not verify reported income in adherence with policy and procedures. For the 10 CHIP findings noted as not obtaining required documentation prior to renewing eligibility which resulted in beneficiaries being invalidly enrolled, LDH concurs in part. • Two (2) findings, the system completed renewals consistent with interface results available at the time of processing. The case record reflected unemployment income; however, interfaces returned no income found. This system enhancement is in progress. • Four (4) findings the analyst did not obtain required income verification in adherence with policy and procedures. Training is ongoing. • One (1) finding did not address unemployment income and household discrepancy. The system completed renewals consistent with interface results available at the time of processing. The case record reflected unemployment income; however, interfaces returned no income found. The clerical staff failed to remove a beneficiary from the household during data entry. Training is ongoing. • One (1) finding occurred during the effective period of the $0 income waiver under Section 1902(e) (14) (A), and the system applied waiver-approved income verification logic consistent with LDH policy. Following expiration of the waiver, system logic was updated in August 2025 to align with post-waiver renewal requirements. • For the two (2) findings noted as not counting all active income found in interfaces, LDH does not concur. The eligibility determination system utilized the highest income reported by LWC at the time of case processing, consistent with LDH policy. Corrective Actions: LDH will continue to utilize findings from internal case reviews, appeal outcomes, external audit, and other monitoring activities to perform root cause analysis. Where appropriate, LDH has requested system enhancements and will continue to assess system functionality in coordination with Policy, Procedures, and Legal to ensure alignment with program requirements and program integrity. To reduce recurrence of identified case processing trends, LDH will continue to: • Assess and update policy and procedures as needed. Provide refresher training for staff. • Conduct internal supervisory and quality assurance reviews. These actions are intended to strengthen internal controls while maintaining alignment with federal and state requirements. You may contact Seth Gold, Medicaid Director at (225) 219-7810 or via e-mail at Seth.Gold@la.gov or Camille Conaway, Executive Director Economic Independence via e-mail at Camille.Conaway@la.gov with any questions about this matter.

Dear Mr. Waguespack: The Department of Children and Family Services (DCFS) acknowledges receipt and concurs with the audit finding titled, “Noncompliance with and Control Weakness over Adoption Assistance Eligibility Requirements”. DCFS continually strives to enhance its internal processes and controls and remains committed to implementing corrective actions to ensure compliance with federal and state regulations. As part of our corrective action plan for this finding, DCFS is updating policy and practice to ensure that a copy of the completed home study is filed in the adoption subsidy case record. In addition, an adoption timeline checklist is being developed and will be incorporated into policy to support consistent documentation and timely completion of required adoption activities. DCFS will develop and implement training specifically for adoption staff. This training will address the proper completion of required forms as well as the expected timeframes for completing each step in the adoption process. Should you require additional information, please contact Brett Hanemann, Assistant Secretary of Child Welfare at (504)-439-1775 or Bret.Hanemann.DCFS@LA.GOV.

Dear Mr. Waguespack: The Department of Children and Family Services (DCFS) acknowledges receipt and concurs with the audit finding titled, “Noncompliance with and Control Weaknesses over Foster Care Requirements”. DCFS continually strives to enhance its internal processes and controls and remains committed to implementing corrective actions to ensure compliance with federal and state regulations. As part of our corrective action plan for this finding, DCFS is updating policy and practice to ensure that the retention of documentation associated with criminal records checks and the State Central Registry Clearances for foster/adoptive caregivers are clearly addressed in policy. Policy related to the retention of documentation related to these checks will be reviewed with all DCFS staff in the monthly policy meeting. DCFS will develop and implement training specifically for Home Development staff. This training will address the proper completion of required forms as well as the retention of criminal records checks and State Central Registry Clearances following closure of the foster/adoptive caregiver's home. The anticipated date of completion is June 30, 2026. DCFS is strengthening internal controls by modernizing the authorization process to require digital approvals. This system upgrade will mandate that service authorizations are finalized before services begin, ensuring all Foster Care payments align with federal and state eligibility requirements. Furthermore, the digital platform will centralize documentation tracking, ensuring continuity of records and compliance even during staff transitions or vacancies. Training will be provided to all Child Welfare administrative and professional-level staff on the new process. The anticipated date of completion is June 30, 2026. Should you require additional information, please contact Connie Guillory, Assistant Secretary of Child Welfare, at 337-793-0017 or Connie.Guillory.DCFS@LA.GOV.

Dear Mr. Waguespack: The Department of Children and Family Services (DCFS) acknowledges receipt and concurs with the audit finding titled, “Control Weakness over Temporary Assistance for Needy Families Eligibility Requirements”. DCFS continually strives to enhance its internal processes and controls and remains committed to implementing corrective actions to ensure compliance with federal and state regulations. Although the exceptions noted occurred during the prior period under DCFS, the Louisiana Department of Health (LDH) began administration of the Family Independence Temporary Assistance Program (FITAP) and Kinship Care Subsidy Program (KCSP) programs effective October 1, 2025, and proposed the following continuous corrective actions that include formal coaching and active monitoring through supervisory case reviews. LDH will conduct formal coaching to ensure staff are aware of their responsibilities. This formal coaching will be mandated for eligibility staff identified as inaccurately budgeting income or entering incorrect disability coding, emphasizing the importance of precise and accurate income budgeting and data entry. In addition to routine case reviews, LDH Supervisors will conduct three additional case reviews for three months as continuous monitoring and corrective measures. DCFS TANF Consultant will monitor LDH to ensure the corrective action plan is fully executed. Should you require additional information, please contact Charles Watkins, Assistant Secretary of Family Support at Charles.Watkins.DCFS@LA.GOV.

Finding Number: 2025-049 Finding: The Health Care Authority did not have adequate internal controls over and did not comply with Recovery Audit Contractor requirements for the Medicaid program. Program: 93.775 – State Medicaid Fraud Control Units 93.777 – State Survey and Certification of Health Care Providers and Suppliers 93.778 – Grants to States for Medicaid 93.778 – COVID-19 Grants to States for Medicaid Compliance Requirement: Special Tests and Provisions – Medicaid Recovery Audit Contractors (RACs) Questioned Costs: $0 Status: Corrective action complete Corrective Action: The Authority partially concurs with the finding. The Authority concurs it did not have a Recovery Audit Contractor (RAC) contract in place during fiscal year 2025 but does not concur with the auditor’s recommendation. The Authority signed a contract with its vendor on September 30, 2025. The work of the RAC contractor is one of many tools used by the Authority to identify and report fraud, waste, and abuse. The Authority has policies and procedures in place for claim reviews and recoveries, fraud referrals, and compliance with the Centers for Medicare and Medicaid Services reporting requirements. The work of the RAC contractor is intended to supplement the Authority’s Program Integrity work and will be incorporated into its current workflows. Prior Findings: None Completion Date: September 2025 Agency Contact: Kari Summerour, CPA External Audit Compliance Manager (360) 725-9586 Kari.Summerour@hca.wa.gov

Finding Number: 2025-039 Finding: The Health Care Authority did not have adequate internal controls over and did not comply with federal provider eligibility requirements for the Medicaid and Children’s Health Insurance Program. Program: 93.767 – Children’s Health Insurance Program 93.767 – COVID-19 Children’s Health Insurance Program 93.775 – State Medicaid Fraud Control Units 93.777 – State Survey and Certification of Health Care Providers and Suppliers 93.778 – Grants to States for Medicaid 93.778 – COVID-19 Grants to States for Medicaid Compliance Requirement: Special Tests and Provisions – Provider Eligibility (Screening and Enrollment) Questioned Costs: $641 Status: Corrective action in progress Corrective Action: The Authority partially concurs with the finding. Fingerprint based criminal background checks The Authority concurs that a fingerprint-based criminal background check process for high-risk providers was not implemented during the audit period. In coordination with the Centers for Medicare & Medicaid Services (CMS) and the Washington State Patrol, the Authority has developed the required process and is in the final stages of implementation. The program is expected to be launched by March 31, 2026, and will apply to all providers designated as high-risk. Updated license information in ProviderOne When a professional license on a provider record expires, ProviderOne automatically end-dates taxonomies associated with the provider. However, when a provider is enrolled with multiple agencies and only one associated license has expired, the system does not currently end-date the related taxonomies. Currently, 37 of 113,940 servicing-only providers are affected while none of the approximately 9,000 billing providers are impacted. The Authority submitted a system change request in March 2026 to ensure applicable taxonomies are automatically end-dated in these scenarios. In the interim, the Authority developed a weekly report and implemented a process to identify providers with applicable taxonomies that need manually end-dated until the system enhancement is deployed. ProviderOne did not deactivate providers timely ProviderOne is designed to automatically inactivate a provider’s domain when revalidation is not completed timely. Due to an operational issue, a limited number of providers were not deactivated as required. Currently, 50 of approximately 9,000 billing providers are impacted. The Authority submitted a system change request in March 2026 to remediate this issue and prevent recurrence. In the interim, the Authority will conduct weekly monitoring and manually inactivate affected provider domains until the system correction is implemented. Ownership disclosures The Authority does not concur with the determination that it is not in compliance with federal requirements governing ownership disclosures. The Authority’s process requires providers to review and attest to ownership disclosure information maintained by the Authority as part of the revalidation process. The Authority believes this process meets the requirements of 42 CFR 455.104 and appropriately balances regulatory compliance with administrative efficiency. The Authority submitted its procedures to CMS on February 23, 2026, and requested clarification and guidance to ensure continued alignment with federal expectations. Providers not revalidated or deactivated by the five-year deadline The Authority’s revalidation backlog totaled 792 providers in July 2024. Through focused operational improvements and targeted resource deployment, the backlog was substantially reduced to three providers as of June 30, 2025. The Authority remains committed to continuous process improvement to sustain timely revalidations and prevent future backlog growth. As of March 2026, the Authority began working on a daily report of providers nearing the revalidation deadline so they can be prioritized and revalidated timely. Prior Findings: The conditions noted in this finding were previously reported in findings 2024-075, 2023-074, 2022-055, 2021-047, 2020-046, 2019-048, 2018-042, 2017-033, and 2016-035. Completion Date: Estimated March 2026 Agency Contact: Kari Summerour, CPA External Audit Compliance Manager (360) 725-9586 Kari.Summerour@hca.wa.gov

Finding Number: 2025-034 Finding: The Department of Children, Youth, and Families improperly charged $9,980 to the Child Care and Development Fund. Program: 93.575 – Child Care and Development Block Grant 93.575 – COVID-19 Child Care and Development Block Grant 93.596 – Child Care Mandatory and Matching Funds of the Child Care and Development Fund Compliance Requirement: Eligibility Questioned Costs: $9,980 Status: Corrective action complete Corrective Action: The Department concurs that federal funds were incorrectly used for one client who should have been paid with state funds. As stated in the finding, all clients sampled for audit testing met the eligibility requirements for the Working Connections Child Care program, meaning they were deemed eligible for subsidy payment. However, one client that was determined to be eligible for state funding was paid with federal funds. This was the result of a system coding error in the Payment Allocation Model (PAM) process that led to the wrong source of funds being used for the client. In November 2025, the Department corrected the PAM coding to prevent further occurrences of this specific error. In February 2026, the Department: • Processed an accounting adjustment returning the federal funds that were paid by error to the Child Care and Development Fund grant. • Implemented a monthly quality assurance review process in collaboration with the Department of Social and Health Services where a sample of PAM allocations will be reviewed for accuracy. Prior Findings: None Completion Date: February 2026 Agency Contact: Stefanie Niemela External Audit Liaison (360) 725-4402 stefanie.niemela@dcyf.wa.gov

Finding Number: 2025-026 Finding: The Department of Social and Health Services did not have adequate internal controls to ensure only eligible clients received cash benefits under the Refugee and Entrant Assistance program and improperly charged $4,440 to the program. Program: 93.566 – Refugee and Entrant Assistance State/Replacement Designee Administered Programs Compliance Requirement: Eligibility Questioned Costs: $4,440 Status: Corrective action in progress Corrective Action: The Department concurs with the finding. As of October 2025, the Department requested the ESA Management Analytics and Performance Statistics (EMAPS) team to generate a report detailing all eligibility determinations made in the six weekly periods that were found to be lacking managerial review. As of November 2025, the Department submitted a formal EMAPS work request to develop a Refugee Cash Assistance (RCA) flagged eligibility caseload report. In addition to metrics already reviewed, this report includes a metric to flag cases where the “U.S. entry date” field has been modified. As of January 2026, the Department: • Developed, documented, and implemented a comprehensive process for managerial reviews of flagged eligibility caseload reports, including a backup process in the absence of the primary reviewer. • Developed and implemented a formal oversight process to monitor the completion and documentation of managerial reviews of all flagged eligibility caseload reports. This process will include a recurring check or log to ensure 100% compliance. • Revised the existing RCA desk aid to provide additional training and guidance to eligibility staff, clarifying the appropriate determination of the RCA eligibility period. The desk aid will specifically include instructions that staff are not to change the original date entered in the “U.S. entry date” field when a client leaves and reenters the country. As of March 2026, the Department reviewed the EMAPS reports to identify and correct any eligibility determination errors. By April 2026, the Department will develop and implement a tracking method to ensure all appropriate eligibility staff are trained on the revised RCA desk aid to ensure alignment with policy and procedures. If the grantor contacts the Department regarding the questioned costs identified in this finding, the Department will consult with the grantor to determine whether repayment is required. Prior Findings: None Completion Date: Estimated April 2026 Agency Contact: Richard Meyer External Audit Compliance Manager Richard.Meyer@dshs.wa.gov

Finding Number: 2025-012 Finding: The Employment Security Department did not have adequate internal controls over and did not comply with requirements to ensure it profiled all claimants under the Unemployment Insurance program to identify people likely to need reemployment services and ensure reports are reviewed before submission to the federal government. Program: 17.225 – Unemployment Insurance Compliance Requirement: Special Tests and Provisions – UI Reemployment Programs: Worker Profiling and Reemployment Services (WPRS) and Reemployment Services and Eligibility Assessments Questioned Costs: $0 Status: Corrective action in progress Corrective Action: In response to the finding and recommendations, the Department has taken the following actions: • In December 2025, reviewed the design of the Unemployment Tax and Benefits (UTAB) calculation and risk profile score and performed testing on its accuracy. • In January 2026: o Implemented additional internal controls to ensure claimants are profiled and prioritized for reemployment services based on their risk of exhausting unemployment benefits, in accordance with federal requirements. o Provided additional guidance to staff to ensure quarterly Employment and Training Administration (ETA) reports are completed accurately and submitted timely in accordance with ETA procedures. o Implemented a process to improve oversight in the reporting procedures to include adequate review and approval before submission to the grantor, and the proper retention of filed reports. The Department continues work to fully staff the unit and is working with the federal grantor and state partners regarding training and guidance on new accounting and reporting system changes. The Department partially concurs with the recommendation to reconcile the UTAB and Reemployment Appointment Scheduler (RAS) interface. There is currently a process in place to notify the RAS team if a record fails at the time of data transmission between UTAB and RAS. The Department is working on prioritizing resources to review the processes to verify that the complete UTAB exit file was successfully received by RAS. This work is anticipated to be completed in June 2026. Prior Findings: The conditions noted in this finding were previously reported in findings 2024-009 and 2023-010. Completion Date: Estimated June 2026 Agency Contact: Joshua Summers External Audit Manager (360) 529-6718 Joshua.Summers@esd.wa.gov

Finding Number: 2025-011 Finding: The Employment Security Department did not have adequate internal controls over the 2208A reporting requirements for the Unemployment Insurance program. Program: 17.225 – Unemployment Insurance Compliance Requirement: Reporting Questioned Costs: $0 Status: Corrective action complete Corrective Action: The Department notified our federal grantor when we became aware of the issue and submitted corrected reports for the periods in question. To improve internal controls, the Department: • Updated internal processes for reviewing reports and retaining all supporting documentation. • Implemented a new process to run a cumulative report to provide additional backup and to detect variances throughout the fiscal year. Prior Findings: None Completion Date: December 2025 Agency Contact: Joshua Summers External Audit Manager (360) 529-6718 Joshua.Summers@esd.wa.gov

Finding Number: 2025-008 Finding: The Department of Social and Health Services did not have adequate internal controls to ensure payments were allowable and made only to eligible beneficiaries for the Summer Electronic Benefits Transfer Program for Children. Program: 10.646 – Summer Electronic Benefits Transfer Program for Children Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs/Cost Principles Eligibility Questioned Costs: $55,454 Status: Corrective action in progress Corrective Action: The Department concurs with the finding. The improper payments identified by the auditors resulted from the challenges of a new program in its first year of implementation. Errors occurred when users from the Department and the Office of Superintendent of Public Instruction migrated data onto new templates and inadvertently included ineligible students and inaccurate dates of birth. The Department agrees that thorough data validation prior to issuance of benefits would have better identified systemic issues related to age and enrollment. Upon discovery, the Department promptly removed ineligible issuances to limit the state’s liability. The Department does not process overpayments on spent benefits based on 7 CFR 292.27(c)(2): “To the maximum extent practicable, Summer EBT agencies should limit claims against households to situations where there is evidence that the household knowingly obtained benefits through fraudulent activities.” In addition, the approved state plan with the federal grantor included a provision that the Department will not process overpayments for improper benefits unless there is evidence of fraud. By April 2026, the Department’s Community Services Division (CSD) will: • Implement a review process to verify age of applicants and address questionable data before submission to the contractor. • Amend the contract with the contractor to include specific reporting requirements for duplicate issuances and identification of ineligible participants. By July 2026, the Department’s CSD will: • Implement a mandatory data reconciliation process in which the contractor must provide full participant datasets, including dates of birth and eligibility status, to the CSD for review and approval prior to benefit issuance. • Request the contractor to complete an enhancement to its eligibility determination system to automatically flag participants under age one or over age 22 for further review. • Request the Electronic Benefits Transfer vendor to create a standard monthly report to show expenditures and expired benefits by client. If the grantor contacts the Department regarding the questioned costs identified in this finding, the Department will consult with the grantor to determine whether repayment is required. Prior Findings: None Completion Date: Estimated July 2026 Agency Contact: Richard Meyer External Audit Compliance Manager Richard.Meyer@dshs.wa.gov

The Office of Student Financial Services acknowledges the finding and will implement corrective actions to ensure full compliance regarding Year-Round Pell Grant eligibility. To address the issue, enhanced processes and internal controls will be established to ensure all eligible students are accurately identified for Summer Pell Grant disbursements. The Office of Student Financial Services will implement enhanced procedures to ensure all eligible students are properly identified for Year-Round Pell Grant awards. Each term, a review report will be generated to identify summer enrollees who received Pell Grant funding during the fall and/or spring terms. Financial aid staff will assess eligibility prior to disbursement by verifying enrollment intensity, cost of attendance, and remaining annual Pell eligibility. Written procedures will be updated to require a Pell eligibility review before processing any summer disbursements. The Director of Financial Aid will review the report each term to monitor compliance with these procedures.

Weatherization Assistance Program (ALN 81.042) Low-Income Home Energy Assistance (ALN 93.568) U.S. Department of Energy U.S. Department of Health and Human Services State of Vermont Agency of Human Services Finding 2025-003 Compliance Finding - Eligibility Views of Responsible Officials Management acknowledges the eligibility determination error involving a two-unit dwelling and agrees that eligibility verification procedures were not sufficiently applied in accordance with DOE requirements for multiunit properties. The Organization takes this finding seriously and is committed to strengthening controls to prevent recurrence. The Organization is actively working with the pass-through entity to resolve the questioned costs of $4,048.39 and will repay any disallowed costs as required. Corrective Action Plan 1. Multi-Unit Eligibility Control Protocol A new Multi-Unit Eligibility Determination Checklist has been implemented requiring: • Individual income verification for each unit • Calculation worksheet demonstrating compliance with: o 66% rule, OR o 50% rule (where applicable), OR o HUD categorical eligibility per WPN 22-5 • Written supervisory approval prior to job authorization No multi-unit property may proceed to audit or production until eligibility documentation is approved. 2. Pre-Service Supervisory Approval Requirement • All multi-unit eligibility determinations must be reviewed and signed by: o Will Eberle (Weatherization Director) • Documentation must be verified before work order issuance. This adds a preventive control prior to expenditure of funds. 3. Executive Oversight Review • Will Eberle (Weatherization Director) will receive a monthly eligibility compliance report. • Any exceptions will trigger immediate review. • Quarterly summary reporting will be presented to senior leadership. 4. Targeted Eligibility Training • Staff will complete focused training on: o DOE WAP multi-family eligibility requirements o Income documentation standards o HUD categorical eligibility • Training will be conducted within 45 days and annually thereafter. • Attendance logs and materials will be maintained by Scott Hall. 5. File Audit & Continuous Monitoring • Will Eberle (Weatherization Director) will conduct monthly random sampling of: o 100% of multi-unit approvals for the next 6 months o Minimum 20% thereafter • Findings will be documented and tracked. 6. Resolution of Questioned Costs • The Organization is in communication with the pass-through entity regarding the $4,048.39 in questioned costs. • Repayment will occur promptly if required. • A repayment tracking file will be maintained by finance and reviewed by Chris Locarno. Implementation Timeline Summary Action, Responsible Party, Completion Target: Multi-unit checklist implemented, Scott Hall, Completed Supervisory sign-off requirement, Scott Hall, Immediate Staff eligibility training, Scott Hall, Within 45 days Executive reporting framework, Chris Locarno Completed Monthly sampling audits, Will Eberle, Ongoig Resolution of questioned costs WX Finance / Chris Locarno, Within 90 days Statement of Commitment The Organization is committed to restoring and maintaining full compliance with all federal and state Weatherization program requirements. Leadership, including, but not limited to: Will Eberle (Weatherization Director), Scott Hall (Weatherization Associate Director), and Chris Locarno (Business Manager), has implemented structural safeguards, enhanced supervisory review, and reinforced a culture of compliance and accountability to ensure that these deficiencies do not recur. Management believes the corrective actions outlined above address both the immediate deficiencies and the underlying control weaknesses identified in the audit. Responsible Person: Will Eberle Date of Completion: April 1, 2026

Weatherization Assistance Program (ALN 81.042) Low-Income Home Energy Assistance (ALN 93.568) U.S. Department of Energy U.S. Department of Health and Human Services State of Vermont Agency of Human Services Finding 2025-001 Compliance Finding - Special Tests and Provisions Material Weakness in Internal Control Over Compliance Views of Responsible Officials Management acknowledges the deficiency identified in the Quality Control Inspection (QCI) process. While questioned costs were not identified, we recognize that the breakdown in controls represents a material weakness requiring immediate and sustained corrective action. Since the Office of Economic Opportunity (OEO) monitoring review, the Organization has undergone structural and cultural changes within the Weatherization Department. Leadership has taken decisive steps to reinforce compliance expectations, supervisory accountability, and documentation integrity. Corrective Action Plan 1. Immediate Structural Oversight Enhancement • Will Eberle (Weatherization Director) is designated as the primary responsible official for QCI program compliance. • Scott Hall (Weatherization Associate Director and Quality Control Lead) is responsible for direct oversight of all QCI staff and inspection standards. • Chris Locarno (Business Manager) will provide executive-level oversight and ensure crossdepartmental accountability and reporting to senior leadership and the Board. Effective immediately: • No weatherization unit may be reported or invoiced until: o QCI documentation is fully complete, o All required test results (blower door, combustion safety, final inspection) are included, o Client signature is present, o Secondary supervisory review is completed. 2. Secondary File Review Control A new Two-Tier Review Process has been implemented: Tier 1 - QCI Review (Performed by Certified BPI QCI) • Full compliance with Vermont Weatherization Program Standards • Documentation of all required final tests • Verification that QCI was not performed by supervising crew members or project participant Tier 2 - Supervisory File Review • Conducted by Scott Hall • Random sampling at minimum 25% of completed units monthly • Monthly summary report submitted to Will Eberle • Quarterly compliance summary reviewed with Chris Locarno No unit will be considered production-complete until Tier 2 review confirms documentation sufficiency. 3. Mandatory QCI Refresher Training • All QC I-certified staff will complete refresher training on: o DOE and HHS requirements o Vermont Weatherization Program Standards o Documentation standards o Independence requirements • Training will occur semi-annually at minimum. • Scott Hall will document attendance and maintain training logs. • Chris Locarno will verify annual compliance training completion as part of management review. Additionally, peer case reviews will be incorporated quarterly to reinforce quality standards. 4. Cultural and Performance Accountability • QCI compliance metrics will be incorporated into staff performance evaluations. • Repeated documentation failures will result in retraining or removal of QCI approval authority. • Monthly compliance meetings led by Scott Hall will include trend review and corrective tracking. 5. Monitoring & Reporting Timeline Action Two-tier review implemented, Will Eberle, Completed Refresher training session, Scott Hall, Within 60 Days Executive compliance review structure , Chris Locarno, Completed Quarterly internal audit sampling, Scott Hall / Will Eberle, Ongoing Responsible Person: Scott Hall Date of Completion: April 1, 2026

The District will add in another level of review to ensure that meals reported to DEW agree to the point-of-sale system CN-6 and CN-7 reports.

Finding 2025-003: Material Weakness in Internal Control over Compliance and Noncompliance – Eligibility Program: 64.055 Staff Sergeant Parker Gordon Fox Suicide Prevention Grant Program Planned Corrective Action: To address the identified material weakness and ensure future compliance with SSG Fox SPGP eligibility and documentation requirements, the organization has implemented the following systemic enhancements: • Standardized Eligibility Controls: The organization has developed and deployed a mandatory Case File Compliance Checklist for all program participants. This control ensures that all federally mandated documentation—including signed program agreements, grievance procedures, religious protections, individualized service plans, and all five required baseline mental health screenings—is present and verified for every file. • Enhanced Management Oversight: To ensure the effectiveness of these controls, the Department Director has implemented a Monthly Quality Assurance (QA) Review. On a monthly basis, the Director will perform a formal audit of active case files to verify compliance. This review will be documented via a formal sign-off, providing a clear audit trail of supervisory oversight. • Records Retention & Security: Management oversight has been expanded to include specific verification of Data Integrity and Retention. Monthly reviews will ensure that all required documentation is maintained in accordance with 2 CFR § 200 standards—ensuring records are secure, unalterable, and readily accessible for future audits. • Continuous Professional Development: The organization has institutionalized a Mandatory Training Curriculum. All relevant staff will undergo initial onboarding and recurring periodic training focused on SSG Fox SPGP compliance standards, participant eligibility, and rigorous documentation procedures. • Personnel Realignment: The organization has undergone a restructuring of the program staff to ensure that all personnel are fully aligned with the agency's internal control environment and commitment to federal compliance. Anticipated completion date: April 30, 2026 Contact Information: Louise Chikigak, Chief Financial Officer, (907) 222-4250

Management is reviewing and strengthening the Sliding Fee Discount Program (SFDP) to ensure compliance with regulatory and internal requirements. Corrective actions focus on clarifying income verification and documentation standards, enhancing staff training, and implementing periodic monitoring to ensure consistent application of the sliding fee scale. As part of these efforts, Clinica Romero conducted a robust and targeted staff training through the CMOAR Clinical & Administrative Operations Training on February 21 and February 28, 2026. The training included 74 staff members and covered SFDP eligibility, income verification, documentation requirements, and proper application of discounts in alignment with HRSA Program Requirement. Expected outcomes include improved consistency in SFDP application across departments, increased staff understanding of compliance requirements, fewer incomplete or unsupported applications, and stronger documentation and audit readiness. Clinica will monitor closely and supervise the perfect execution of the sliding fee scale application, and it will set accountability standards for the application of the sliding fee scale.

Annual performance reports will be submitted on time as required by the funding agency. Management has developed a comprehensive listing of all reporting requirements and will utilize this information to ensure all reporting requirements are met.

Management will provide additional resources to the Financial Aid department to include training and assistance and will implement verification procedures to ensure that amounts awarded are accurate.

Corrective Action Plan: The Authority acknowledges the finding. Corrective actions to address the deficiencies are underway and include: Updating internal policies and procedures related to Housing Choice Voucher (HCV) program compliance, including tenant eligibility, income verification, rent reasonableness, utility allowance calculations, and documentation requirements; Providing targeted staff training on HUD HCV program requirements, including proper file documentation, income calculation, and timely completion of annual and interim recertifications; Implementing a mandatory file checklist to ensure all required documentation is obtained, reviewed, and verified prior to finalizing tenant certifications and rent determinations; Establishing a formal quality control process in which supervisory staff perform periodic file reviews to ensure compliance with HUD requirements and internal policies; Conducting a comprehensive review and cleanup of all HCV tenant files to identify and correct missing or incomplete documentation, including income verification, inspections, and rent calculations; Maintaining an audit trail of all verification documentation to ensure proper retention and support for tenant eligibility and rent determinations; Implementing tracking tools and system reports to monitor recertification due dates, inspection schedules, and file completion status to ensure timely compliance; Continuing engagement with third-party service provider, Quadel, to assist with tenant file documentation compliance, backlog recertifications, and rent calculation accuracy; Hiring and/or assigning additional staff, including HCV program leadership and specialists, to strengthen oversight, ensure timely processing of recertifications, and maintain compliance with HUD requirements.

Cost of Attendance Calculation Inputs Auditor Description of Condition and Effect. During our testing of the College’s cost of attendance (COA) calculations, we identified inconsistencies between the COA component amounts recorded in the system and the amounts documented on the College’s COA calculation sheet. For instance, the College's tuition component was supposed to be based on credit intensity, but instead was being calculated using the student's enrollment status (e.g., full-time, half-time, etc.). Additionally, the College included direct loan fees in every students COA, even if they were not a direct loan receiving student. As a result, COA amounts used in awarding Title IV aid were being understated, preventing some students from potentially receiving additional aid they were entitled to. Auditor Recommendation. We recommend that the College establish and adhere to review procedures to ensure that all inputs used in the COA calculation are accurate, complete, and consistent with approved documentation. Corrective Action. Management is actively enhancing the College’s Cost of Attendance (COA) processes to ensure all inputs—particularly tuition, loan fees, and enrollment‑related components—accurately reflect approved documentation and federal requirements. The Financial Aid Office has reconfigured PowerFAIDS to calculate tuition based on credit intensity rather than enrollment status, and loan fees are now included only for students who actually borrow federal loans. An annual COA governance and approval process is now in place, requiring review and authorization by the Vice President of Finance and Administration before COA figures are built into the system. All COA entries in PowerFAIDS undergo an independent verification against the approved COA worksheet as part of a “build‑to‑proof” procedure. Spot checks are conducted at the start of each term to ensure accuracy across enrollment levels, and all mid‑year changes are documented using a formal change‑control log. Responsible Person. Jennifer Stimson, Director of Financial Aid Anticipated Completion Date. March 31, 2026