Corrective Action Plans

Satisfactory Academic Progress Planned Corrective Action: The SAP policy will be reviewed or created as needed and a procedure will be implemented based on that policy. Person Responsible for Corrective Action Plan: Lori Larsh, Vice President for Business Services Anticipated Date of Completion: 07/31/2026

Management has reviewed the finding regarding the documentation of program eligibility. We recognize the importance of maintaining clear, audit-ready files that explicitly demonstrate case ownership and supervisory approval. To ensure full alignment with 2 CFR § 200.300, we have drafted and instituted the following corrective actions: • Updated Internal Signature Policy: We have drafted a strict internal policy requiring the primary case manager-and any other staff actively working on a case-to sign and date all required enrollment documents. This explicitly includes signing intake forms and completing the interpreter sections, where applicable. This policy ensures there is never any ambiguity regarding who is handling the case. • Mandatory Supervisory Review: To enforce this new standard, our internal policy now requires Program Managers and Directors to systematically review each individual case file. Leadership must verify that all required staff signatures, interpreter sign-offs, and eligibility approvals are fully documented before a client's enrollment is considered complete. • Standardized Case Coversheet: To immediately resolve the issue of identifying case handlers, we are implementing a standardized enrollment coversheet for all new files. This document clearly assigns the primary case manager on day one and requires a final supervisory signature to formally authorize the eligibility review. • Targeted Training and Spot-Checks: We are conducting immediate refresher training for all program staff to clarify exactly which signatures are required on each document. Furthermore, leadership will conduct routine, random spot-checks of active case files each month to verify that staff are consistently adhering to this policy in real-time. By formalizing our signature requirements and mandating director-level reviews, we are confident this updated workflow establishes clear accountability and fully resolves the finding.

2024-003 SCDA Eligibility Material Weakness and Non-Material Noncompliance Corrective Action: We've hired competent staff that will maintain records of the 3 (Partner, Training and TEFAP) agreements that Agencies will sign annually for compliance. Person Responsible: Stephano Blake Email: SBlake@harvesthope.org Phone: 803-636-6635

To ensure the audit is submitted in a timely manner, and on time, we will begin at the beginning of the year.

Corrective Action Plan: Management concurs with the auditor's recommendations. Management will submit the necessary documentation to the U.S. Department of Housing and Urban Development (HUD) to request retroactive approval for the $4,700 withdrawal from the Residual Receipts Account made during the year ended December 31, 2024. To prevent recurrence, management has implemented additional internal controls to ensure that all future withdrawals from restricted accounts receive the required prior written HUD authorization. These controls include a formal review and approval process by the Property Manager and Corporate Accounting before any disbursements are made from restricted accounts. In addition, management has scheduled staff training on HUD regulatory requirements governing restricted accounts to reinforce understanding of program compliance and documentation standards. Management is committed to maintaining full compliance with HUD regulations and ensuring that all account activity is properly reviewed, authorized, and documented.

Finding 2024-004 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Housing Voucher Cluster, Public and Indian Housing Program, Public Housing Capital Fund Program, and Coronavirus Relief Fund Assistance Listing Numbers: 14.871, 14.879, 14.850, 14.872, and 21.019 Material Noncompliance Non Compliance Material to the Financial Statements: Yes Material Weakness in Internal Control over Compliance Criteria: The Authority must maintain complete and accurate accounts and other records for the program in accordance with HUD compliance requirements. Condition: The Authority did not maintain complete and accurate accounts and other records in accordance with HUD compliance requirements regarding Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Eligibility, Reporting, and Special Tests and Provisions. Context: The Authority was unable to provide requested documentation at the time of audit to properly test the HUD compliance requirements. Known Questioned Costs: Unknown Cause: There is a material weakness in internal controls over compliance related to the maintenance of tenant files, wait lists, inspection reports and other records. The Authority has not properly considered, designed, implemented, maintained and monitored a system of internal controls that reasonably assures the program is in compliance. Effect: The Housing Voucher Cluster and Public and Indian Housing Program are in material non- compliance with the compliance requirements of the program. Recommendation: We recommend that the Authority implement a process whereby Authority documents are stored and safeguarded to ensure compliance with the Uniform Guidance and the compliance supplement. View of Responsible Officials and Corrective Actions: The Authority experienced significant turnover in employees during the year and as a result certain source documents were misplaced or destroyed. Management agrees with the Auditors' finding and has hired a new Executive Director who will implement the required safeguards and ensure that the Authority follows its internal control over compliance processes and procedures related to the Housing Voucher Cluster, Public and Indian Housing Program and Public Housing Capital fund Program to remedy the aforementioned deficiencies. Bryant McClellan, CFO, will be responsible to implement this corrective action by December 31, 2025.

2024-005—Special Tests and Provisions—Sliding Fee Discount Program Corrective Action: Management acknowledges the finding. FCCH agrees that the claim in question did not reflect the appropriate sliding fee discount because the billing department was not notified that the patient submitted income documentation within the 30-day eligibility window. FCCH recognizes the importance of ensuring that all departments consistently follow established Sliding Fee Discount Program (SFDP) procedures. To address this issue, FCCH has implemented the following corrective actions: • Reinforce communication protocols between front desk/eligibility staff and the billing department to ensure that any income documentation received after the date of service is promptly communicated and documented. • Provide refresher training to front desk, eligibility, and billing staff on SFDP requirements, including the 30-day documentation rule and the process for updating patient classifications. • Initiated an internal review of a sample of medical claims to assess whether similar errors occurred and to confirm that corrective measures are effective. FCCH remains committed to full compliance with 42 CFR Part 51c.303(f) and its internal Sliding Fee Discount and Related Billing and Collections Program Policies and Procedures. Management will continue monitoring to ensure ongoing adherence and prevent recurrence. Person Responsible: Tammy Collins, Revenue Cycle Director Completion Date: September 30, 2026

Finding number: 2024-005 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063 Award year: 2024 Corrective Action Plan: The College experienced significant turnover during FY24. The College has updated standard operating procedures to include a compliance checklist and enhanced automated tracking and notification processes to ensure timely communication with students. Timeline for Implementation of Corrective Action Plan: Immediate Contact Person Loriann Weiss Interim Director of Financial Aid

Planned Corrective Action: The Division will design and implement a precise control to ensure that participants self-certify that they meet the grant eligibility requirements and maintain such evidence. Anticipated Completion Date: 9/30/2026 Responsible Contact Person: Al Agpoon, Golden State Division Controller

Finding No.: 2024-048 Eligibility Special Test and Provisions- Utilization Control Provider Eligibility (Screening and Enrolment) Provider Health and Safety Standards Responding Agency: Department of Public Health and Social Services (DPHSS) Responsible Personnel: Theresa Arriola, Director DPHSS agrees with this finding. To address the recommendation for a reconciliation process, DPHSS is in the process of forming a multi-agency technology initiative which will include: • Establishment of an Inter-Agency Data Hub: DPHSS, in collaboration with the Office of Technology (OTECH) and the Department of Administration (DOA), aims to establish a centralized Data Hub. This hub will facilitate real-time or scheduled data synchronization between the DPHSS medical management systems and DOA’s financial accounting records, which are managed in the Guam Financial Management Information System (GFMIS). The data hub is intended to ensure all claims paid are automatically after proper approvals and are then reconciled with the general ledger. • Inter-Agency Agreement and Coordination: DPHSS acknowledges that successful implementation of this Data Hub requires a unified commitment. DPHSS leadership is coordinating with the Director of DOA to discuss the technical requirements and administrative protocols. A formal Memorandum of Agreement (MOA) or a joint standard procedure will be sought, subject to the concurrence and approval by both Agency Directors. • Manual Interim Reconciliation: Until the Data Hub is fully operational, DPHSS will work with DOA to implement a monthly manual reconciliation process. This will involve a "crosswalk" review of claim batch totals against financial system postings to identify and resolve variances (such as voided checks or manual adjustments) in a timely manner. • Engagement with OTECH: Once the two directors agree on the framework, DPHSS will engage OTECH to design the data architecture necessary to ensure data integrity, security, and compliance with federal reporting standards. Estimated implementation timeframe: March 31, 2027

Finding No.: 2024-047 Special Test and Provisions Provider Eligibility (Screening and Enrolment) Responding Agency: Department of Public Health and Social Services (DPHSS) Responsible Personnel: Theresa Arriola, Director DPHSS agrees with this finding. DPHSS is aware that deficiencies exist with the Medicaid provider enrolment process. DPHSS’s response to this deficiency is addressed in its modernization plan, which will automate certain provider enrolment functions. In March 2024, DPHSS performed site visits for 21 providers, and since then has continued to perform site visits year-round. Memorandums regarding provider compliance topics have also been communicated to providers and published on the provider portal, including information regarding criminal background checks. DPHSS is currently contracted with a consultant that is assisting in the implementation of compliant provider enrolment operations, which includes policy revisions, updates to provider applications and disclosure forms, development of standard operating procedures, and training for both staff and providers. In addition, DPHSS is currently in the process of establishing a Medicaid Program Integrity Unit (PI Unit) with a mission to conduct independent and objective Medicaid program integrity functions adherent to federal and local laws. The PI Unit will also assist DPHSS in addressing and managing Medicaid related Corrective Action Plans.

Finding No.: 2024-045 Eligibility Responding Agency: Department of Public Health and Social Services (DPHSS) Responsible Personnel: Theresa Arriola, Director DPHSS agrees with this finding. The Bureau of Economic Security (BES) recognized the finding as an issue and in response, held a bureau-wide training for both front desk personnel and eligibility specialists on December 22 - 23, 2025. This training focused on application handling including the timeliness of eligibility determinations and proper documentation maintenance procedures. The training reinforced use of a standardized application checklist that was developed to support application completeness. Staff were also trained in the correct method for uploading documents into the OnBase system, the bureau’s digital record archive, for secure storage and efficient retrieval. In January 2026, BES conducted a Customer Email Standard Operating Procedure (SOP) training to reinforce staff compliance with documentation requirements, including the use of document imaging process (DIP) to ensure customer documentation received via email is uploaded into the OnBase system within two business days. In addition, DPHSS is preparing additional training sessions, which are currently being developed, on topics such as Medicaid Basics 101, Customer Service, and Medicaid Eligibility. To assess compliance with the training, Eligibility Specialist Supervisors were tasked with periodically reviewing random samples of applications across all three centers to verify application completeness, including required documents. BES will further reinforce timeliness compliance by incorporating 45-day timeliness checks and targeted reviews of higher-risk cases into supervisory case reviews. Findings from these reviews will be used to inform corrective action and retraining as needed. DPHSS is also revising the document verification list in the Public Application form to help clients clearly identify required documentation needed to support eligibility determination and reduce the risk of missing or incomplete case files.

Finding No.: 2024-041 Eligibility Responding Agency: Department of Public Health and Social Services (DPHSS) Responsible Personnel: Theresa Arriola, Director The Bureau of Child Care Services (BCCS) disagrees with this finding. Eligibility determinations were conducted in accordance with federal and local requirements. The exceptions noted are due to a subsequent request received by BCCS on January 20, 2026, and consequently responded to on January 29, 2026. Additional supporting documents were provided on February 9, 2026. Certain payment variances reflect allowable program exceptions.

Finding No.: 2024-022 Eligibility Responding Agency: Department of Administration (DOA) Responsible Personnel: Edward M. Birn, Director The Agency is reviewing its federal grants management to ensure robust handover and succession plans are in place of future programs.

Finding No.: 2024-018 Eligibility Responding Agency: Department of Administration (DOA) Responsible Personnel: Edward M. Birn, Director The Agency is reviewing the management of Federal Grants to ensure robust handover and succession plans are in place for future programs. The sudden passing of the ERA Program Coordinator directly impacted overall management of the program.

Finding No.: 2024-017 Eligibility Responding Agency: Department of Labor (DOL) Responsible Personnel: David M. Dell’Isola In June 2024, GDOL established a policy workgroup to modernize internal procedures. Consequently, the AJC-024-Selective Service Registration policy was updated and formally approved on August 12, 2024. This updated guidance was distributed to all American Job Center (AJC) staff and case managers on August 15, 2024, to ensure future consistency in documentation and eligibility overrides.

Eligibility Housing Voucher Cluster Material Weakness in Internal Control Material Noncompliance Condition: Out of an approximate population of 1,500 of Housing Voucher Cluster tenants we tested 11 tenants and the following deficiencies were noted: Five files did not have an annual recertification performed with 12 months of the previous certification Two files did not have inspection documentation during the period, One file did not have an annual recertification performed, One file did not have documentation to support HAP amount reported, One file used an incorrect payment standard, One file did not have dependency documentation for a dependent member of the household, One file was missing documentation to support income claimed during recertification, and One file will missing rent reasonableness documentation and approval. Auditor Recommendations: The Authority should reevaluate their established procedures and controls in place to ensure full compliance in regards to eligibility and the timeliness of recertifications. The Authority needs to correct the deficiencies noted in the tested files and consider the impact to the rest of the population of tenant files that were not selected as part of the auditor’s sample. Action Taken: The Houston Housing Authority agrees with this fining and related recommendations. During 2024 the voucher and public housing programs converted to a new software system. Yardi is not the principal operating system for both the voucher and public housing programs. This system conversion has required that work flows had to be modified. This modification and implementation of a new processing system did not allow staff to conduct the necessary reviews of existing files to make sure that the compliance related materials that should be found in each file were to be completed. This issue has been discussed and there will be an internal review conducted on file samples to determine what compliance deficiencies are prevalent. Corrective action steps will be implemented to address these issues designed to correct them. Additional training resources will be devoted to staff in these departments designed to improve quality control with these program areas.

93.767 Children's Health Insurance Program (CHIP) 93.778 Medical Assistance Program (Medicaid; Title XIX) 2024-023 Strengthen Controls to Ensure Compliance with Provider Eligibility Requirements of CHIP and the Medical Assistance Program DOM Response: Two instances of no documentation that required fee were collected. DOM Partially Concurs. After a review of the 2 files, DOM has found in one instance an application fee was collected and sent to DOM for processing; however, the receipt of the application fee was not indicated by comments in the system. DOM will work with Gainwell to ensure remedial training is conducted to reduce errors in the future. One (1) instance correlates to an application received before DOM began requiring the fee on October I, 2022. Thirty-eight instances of no documentation that provider's medical license was current and free of limitations. DOM Partially Concurs. After a review of the 38 files, DOM has found in thirty-one (31) instances the license from the board was attached and the checklist completed after the license was not verified by LexisNexis . Two (2) instances were applications approved prior to the Gainwell implementation; however, the licenses remain valid in SFY 2024 and reflect correct effective dates in the system. One (1) instance is a group and does not require license. Four (4) instances the license from the board was manually verified and attached after the license was not verified by LexisNexis; however, there were typographical errors or omissions in the license fields in the system. DOM will ensure Gainwell conducts remedial training to mitigate these errors in the future. Thirty-one instances of no documentation of review prior to approval of provider's application. DOM Does Not Concur. After a review of the 31 files, DOM has verified all applications identified within this finding as being approved by DOM without review have documented comments in the system of record to show a review of each application was conducted prior to approval. This would include Fifteen (15) instances with review notes, requests for missing information (if applicable), etc. entered by reviewers since the Gainwell Go-Live. Sixteen (16) instances with review notes, requests for missing information (if applicable), etc. entered by reviewers prior to the Gainwell Go-Live. Ten instances of no documentation of verified identity and exclusion status of providers using required federal databases prior to application approval. DOM Partially Concurs. After a review of the 10 files, DOM has found in five (5) instances the LexisNexis report indicated the NPI was verified. One (I) instance of the NPI not verified by LexisNexis, but the Gainwell Analyst performed a manual search in NPPES and attached the verification results on 11/14/24. Four (4) instances before Gainwell began processing applications. The provider was sent to Digital Harbor for screening. DOM's contractual relationship with Digital Harbor ended in 2016 and the data is no longer available. Agency began revalidation in 2017 by stratifying all providers; however, due to PHE all revalidations were paused. As a result, not all revalidations have been completed. At this time, revalidation dates have been assigned in alignment with CMS guidance and will be completed within CMS required timelines, i.e. 44 months from end of the PHE. One (I) instance has a note indicating revalidation occurred in 2017, but no documentation can be located in the system, which potentially could be attributed to data conversion from the legacy system to the new system. Four instances of no documentation of OIG exclusion checks prior to application approval. DOM Concurs. After a review of the 4 files, DOM has found in three (3) instances contain a comment within EDMS that verifies the providers were sent to Digital Harbor for screening. DOM's contractual relationship with Digital Harbor ended in 2016 and the data is no longer available. Please note: Agency began revalidation in 2017 by stratifying all providers, however due to PHE all revalidations were paused. As a result, not all revalidations have been completed. At this time, revalidation dates have been assigned in alignment with CMS guidance and will be completed within CMS required timelines, i.e., 44 months from end of the PHE. One (1) instance has a note indicating revalidation occurred in 2017, but no documentation can be located in the system, which potentially could be attributed to data conversion from the legacy system to the new system. Two instances of no documentation of collection of the provider's NPI. DOM Concurs. After a review of the 2 files, DOM has found all instances contain a comment within the system which verifies the provider was sent to Digital Harbor for screening. DOM's contractual relationship with Digital Harbor ended in 2016 and the data is no longer available. Eight instances of missing or incomplete documentation of required disclosure details. DOM Partially Concurs. After a review of the 8 files, DOM has found in two (2) instances where the individual provider's date of birth is in the system. Two (2) instances where the individual provider's date of birth is not available as it was not a required element at the time of application. DOM will ensure the date of birth is obtained from the provider and added to the system. Three (3) instances where the organizational provider has all required elements. One (1) instance where the organizational provider's address is not available as it was not a required element at the time of application. The missing data is now required and will be collected at the next revalidation. Four instances of no documentation required screening procedures in accordance with provider's designated risk level. DOM Partially Concurs. After a review of the 4 files, DOM has found in three (3) instances where the individual provider's file contains a comment within EDMS verifies provider was sent to Digital Harbor for screening. DOM's contractual relationship with Digital Harbor ended in 2016 and the data is no longer available. Please note: Agency began revalidation in 2017 by stratifying all providers, however due to PHE all revalidations were paused. As a result, not all revalidations have been completed. At this time, revalidation dates have been assigned in alignment with CMS guidance and will be completed within CMS required timelines, i.e., 44 months from end of the PHE. One ( l) instance the individual provider was screened, and a site visit was conducted (as this provider type was deemed moderate risk at that time) and the documentation is available in the system. DOM Corrective Action Plan: a. In response to the audit findings, the Division of Medicaid (DOM) will collaborate with its Fiscal Agent, Gainwell Technologies, to review all identified issues and implement corrective measures. As part of this effort, mandatory refresher and remedial training will be conducted for Gainwell Provider Enrollment staff. This training will emphasize the requirement for comprehensive and accurate documentation within provider files, including clear, detailed, and supportive comments that fully reflect all actions taken during the enrollment and maintenance processes. Additionally, DOM will implement enhanced oversight and quality assurance monitoring to ensure sustained compliance with documentation standards. DOM notes that certain discrepancies identified in the audit may predate the implementation of the MESA system and the transition to Gainwell Technologies as the Fiscal Agent. Due to system conversion constraints, data limitations, and the absence of complete historical documentation within the current system, DOM's ability to retrospectively validate or remediate these pre-implementation discrepancies is limited. As such, corrective actions will be applied prospectively, with a focus on ensuring accuracy, completeness, and compliance within the current MESA environment moving forward. b. Bill Hardin c. March 31, 2026

93.767 Children's Health Insurance Program (CHIP) 93.778 Medical Assistance Program (Medicaid; Title XIX) Eligibility 2024-021 Strengthen Controls to Ensure Compliance with Eligibility Requirements of the Children's Health Insurance Program (CHIP) and the Medical Assistance Program DOM Response: Use of Tax Return Resources Three MAGI beneficiaries - DOM did not verify self-employment income reported on tax return One of the 180 MAGI beneficiaries - reported self-employment income, DOM did not request a tax return DOM Does Not Concur. OSA compared eligibility data to state income tax returns. DOM is prohibited from accessing state income tax records per Mississippi Code Annotated 27-3-73 and currently, is not allowed to have access to federal income tax records. For eligibility, DOM asserts compliance with the CMS-approved state plan. During the audit period, the state used the CMS MAGI Based Verification plan to confirm income reports using all available electronic data sources according to CMS's reasonable compatibility standard. DOM must accept applicant information and use CMS-approved verification methods to check its accuracy. If self-employment income is not reported and DOM's tools do not detect it, DOM has met eligibility and compliance standards set by CMS. In addition, tax returns are considered outdated and not relevant to DOM. Six of the 180 MAGI beneficiaries - income was not verified through Mississippi Department of Employment Security DOM Partially Concurs. Four beneficiaries' income was not verified through Mississippi Department of Employment Security (MDES). DOM requested MDES on the identified beneficiaries and found no new information that would have affected the eligibility decision. DOM does not concur with two of the findings as MDES was requested on those beneficiaries. Each finding will be reviewed with the individual team members and additional communication has been provided to all Eligibility Team Members. Twelve of the 300 beneficiaries - the beneficiary's case file did not contain a completed application. DOM Concurs. DOM was unable to locate and provide the auditors the original application for the twelve beneficiaries. These documents do not impact the redetermination of eligibility. All redetermination decisions have been verified as accurate. Six of the 300 beneficiaries - DOM could not provide a case file. DOM Concurs. DOM was unable to locate and provide the auditors the case files for six beneficiaries. These documents do not impact the redetermination of eligibility. All redetermination decisions have been verified as accurate. One ABD beneficiary - resources were not verified through AVS at the time of redetermination. DOM Concurs. DOM has since requested AVS records for the beneficiary in question. No bank accounts were found, which indicates there was no impact to eligibility. The Eligibility Team Member will be coached to ensure appropriate processes are followed for all future cases. One hundred thirty-five beneficiaries were not included on all of the required quarterly Public Assistance Reporting Information System (PARIS) file transmissions for fiscal year 2024. DOM Partially Concurs. DOM does not concur with a number of these findings as they were appropriately absent from the PARIS request file because they were in a denied status, had retroactive coverage, or was absent due to the timing of the case approval. DOM concurs with some of the findings. Findings related to COE 29 - Family Planning were addressed in late 2023, which was after the approval of these cases. This issue was resolved in late 2023. There were findings that occurred due to the timing of the PARIS file. DOM has submitted a change request to submit the PARIS file based on the run date not based on the end of the previous month. All previously missed members were added to the 11/1/2025 PARIS outgoing data file, and this report was provided to the auditors. No eligibility decisions were affected by the 11/1/2025 returned PARIS file. DOM Corrective Action Plan: a. DOM submitted a change request to submit the PARIS file based on the eligibility end date of the previous quarter rather than the actual run date. This has been completed. All individual issues identified will be reviewed with the appropriate team member. b. Brian Whitmire c. March 31, 2026

Finding 2024 - 016: Ellglblllty Significant Defldency In Internal Control Over Compliance Criteria: Per 45 CFR 75.1356.21, .22 and .30, a title IV-E agency must determine eligibility of foster homes and foster children prior to providing foster care maintenance payments. Per 45 CFR 7S. 303(a), non-Federal entities expending HHS awards must establish and maintai n effective inte rnal contro ls over compliance with Federal states, regulat ions, and the terms and conditions of the Federal award. MDCPS policies and procedures require a two-level approval for child eligibility determinations . A Social Worker comp letes an eligibility packet for each child and signs of f before submitting the eligibility packet to the Eligibility department. An Eli gibility Worker reviews and approves the eligibility packets prior to submitt ingthe packet for the El i gibility Supervisor's review. The Eli gibility Supervisor makes the necessary adjustments prior to final approval. Condition: Our audit procedures over eligibility packets disclosed a lack of approval from the Social Worker and second-level approval from the Eligibility Supervisor. Perspective: Below are the exceptions noted in our testing of eligibility for proper approval of eligibility packets. The sample was not statistically valid. • Eleven of forty sample items did not have proper Social Worker sign off. • Twenty-eight of forty sample had only one level of approval documented. All eligibility determinations included at least one level of approval, but MCOPS's policies were not implemented consistently. Personnel Responsib le for Corrective Action: Name: Kristi Plotner Title: Deputy Commissioner of Care Management Email : Kristi .Pl otner@md cps.ms.gov Phone Number: 769-352-5532 Corrective Action Plan: MDCPS will enforce our policy requiring approval of eligibility packets to ensure all eligibility packets are complete and accurate. The Agency is also evaluating its existing policy to strengthen internal controls while improving operational efficiency. As part of this effort, we are reviewing eligibility determination procedures to determine whether to move to a single level of approval model. The objective is to ensure that eligibility determinations remain accurate, well-documented, and compliant with federal requirements, while aligning internal processes with best practices in risk­ based control design. Antidpated Completion Date: Policy enforcement completed as of March 31, 2026 Agency review of eligibility determination procedures to be completed as of Juty 1, 2027. Agency will continue to follow current policy in effect.

ELIGIBILTY ALN Number 93.558 Temporary Assistance for Needy Families (TANF) 202 -035 Strengthen Controls to Ensure Compliance With Eligibility Requirements of the Temporary Assistance for Needy Families (TANF) Program . Federal Award No. All Current Active Grants Response: MDHS has implemented a multi-tiered approach to address the audit findings from the Fiscal Year 2024 Single Audit. These efforts focus on strengthening eligibility controls and enhancing internal oversight. MDHS is required to adhere to specific eligibility and verification standards for the TANF program. including mandatory immunization checks, age limit monitoring. and proper authorization of work stipends. During the Fiscal Year 2024 Single Audit 16 instances were identified where these controls were not fully met. resulting in questioned costs of $2,592. MDHS has already taken steps to address the identified overpayments and documentation gaps. To correct these deficiencies, MDHS is strengthening its internal control processes within the Division of Economic Assistance and Eligibility (DEAE) to ensure that immunization records are verified within the required thirty (30) day window· and benefit adjustments for children reaching age eighteen (18) are processed promptly. Furthermore. MDHS is implementing case reviews to ensure all payments are approved by authorized personnel and that work stipends are supported by completed applications and accurate attendance records. MDHS has committed to ongoing staff training to prevent the recurrence of these eligibility and authorization errors. Corrective Action Plan: I. Child's current immunization status was not verified within thirty (30) days. A. DEAE provides policy guidelines via a weekly "Did You Know" email to all staff. Information regarding the immunization requirement will be included in this series by June I. 2026. Statewide TANF and TWP training will begin on June 1. 2026 B. Responsible Parties: Shauna Aguilar. Deputy Director- Economic Programs, Marilyn Williams, Deputy Division Director- Field Operations. Marshea Cooper, Deputy Division Director- State Operations C. Anticipated Completion Date: August I. 2026 2. TANF benefits were not reduced promptly once a dependent child reached 18 years old. resulting in overpayment. A. There is a report generated monthly that identifies children in households that will reach their 18th birthday one month prior to their 18th birthday. In addition, DEAE conducted training in February and March 2026 with regional directors. county directors. and supervisors that included information on using the above-mentioned report to prevent overpayment due to dependent children turning 18 B. Responsible Parties: Shauna Aguilar. Deputy Director- Economic Programs. Marilyn Williams. Deputy Division Director- Field Operations. Marshea Cooper. Deputy Division Director- State Operations C. Anticipated Completion Date: This corrective action has been implemented and completed. 3. TANF benefit payment \Vas approved by an unknown authorizer. A. This finding is due to a system issue that has been resolved. MIS identified that the system did not hold the names of employees who left the agency and replaced the name with “unknown authorizer” Cases now hold the authorizer’s name going forward from the fix. B. Responsible Parties: Shauna Aguilar. Deputy Director- Economic Programs. Marilyn Williams. Deputy Division Director- Field Operations. Marshea Cooper. Deputy Division Director- State Operations C. Anticipated Completion Date: This corrective action has been implemented and completed. 4. Transportation work stipend was overpaid based on the recipient's scheduled hours. A. DWD revie\vs cases monthly to identify errors. Statewide TANF and TWP training will begin on June 1. 2026 . B. Responsible Parties: Shauna Aguilar, Deputy Director- Economic Programs. Marilyn Williams. Deputy Division Director- Field Operations. Marshea Cooper. Deputy Division Director- State Operations C. Anticipated Completion Date: In progress and ongoing 5. Transitional work stipends were paid to recipients without completed applications on file. A. Statewide TANF and TWP training will begin on June 1·. 2026 . B. Responsible Parties: Shauna Aguilar. Deputy Director- Economic Programs. Marilyn Williams. Deputy Division Director- Field Operat ions. Marshea Cooper. Deputy Division Director- State Operations C. Anticipated Completion Date: August I. 2026 6. Transitional work stipend amounts paid to recipients were incorrect based on attendance records. A. The TANF Policy team will begin reviewing transition cases on May I. 2026. B. Responsible Parties: Shauna Aguilar. Deputy Director- Economic Programs. Marilyn Williams, Deputy Division Director- Field Operations. Marshea Cooper. Deputy Division Director- State Operations C. Anticipated Completion Date: Implementation May I. 2026 and ongoing process

Assistance Listing No. 17.258, 17.259, 17.278 and Workforce Innovation and Opportunity Act Cluster Type of Compliance Requirement: Eligibility Response: There is no disagreement with the audit finding. Corrective Action Plan: MDES agrees with the finding and will strengthen controls around WIOA eligibility to ensure documentation is complete and in order. Name(s) of the contact person(s) responsible for corrective actions: Contact person(s) responsible: Robert Bock Contact Phone number: 601-321-6478

The Department should review and enhance its procedures and internal controls to ensure that it charges expenditures to the program that are incurred within an award’s allowable period of performance. Response: The Department concurs with the finding and the need to enhance procedures and strengthen controls over processing expenditures to ensure compliance with the awards’ period of performance. Corrective Action: The program will enhance procedures and strengthen controls to ensure expenditures presented for payment are allowable and within the awards’ period of performance. Program leadership will develop and document an internal expenditure review process to ensure a complete review of presented expenditures for payment is completed prior to submission to the agency’s Accounts Payable Department for processing. Name of contact person responsible for the corrective action: Jameshyia Ballard Anticipated date for completion of corrective action: September 30, 2026

The Department should review and update its procedures and controls to ensure that only eligible participants receive benefits under the program. Eligibility documentation should be maintained and readily available for audit. Response: The Department concurs with the finding and the need to strengthen controls over eligibility processing to ensure required documentation is obtained and maintained for each participant to support program eligibility. Corrective Action: The program will develop an internal tracking and retention system to maintain eligibility documentation for participants to ensure accessibility when needed. Documentation will be maintained in accordance with program requirements. Name of contact person responsible for the corrective action: Jameshyia Ballard Anticipated date for completion of corrective action: September 30, 2026

Federal Program/ Assistance Listing Number (ALN) 84.268, 84.063, 84.007, 84.033 Finding Reference Number 2024-016 1. Finding Summary The auditor determined that Pell Grant funds were disbursed for summer enrollment without adequate documentation demonstrating that students met all required summer Pell eligibility criteria. As a result, the institution could not demonstrate compliance with federal requirements governing the award and disbursement of additional Pell Grant funds for summer terms. 2. Management's Position Management agrees with the finding. Management Explanation Management agrees with the finding and acknowledges that Pell Grant funds were disbursed for summer enrollment without consistently ensuring and documenting that all federal summer eligibility requirements were met prior to disbursement. 3. Root Cause Analysis The root cause of this finding resulted from insufficient supervisory review of summer Pell eligibility determinations and gaps in staff training regarding federal requirements for awarding and disbursing additional Pell Grant funds for summer enrollment. 4. Corrective Action(s) Management has added secondary review, implemented periodic internal monitoring, and conducted targeted staff training tied to updated procedures. Description of Corrective Actions The institution has added a required supervisory or secondary review to confirm summer Pell eligibility prior to processing or disbursement, implemented periodic internal monitoring and quality assurance reviews to verify ongoing compliance, and conducted targeted staff training aligned with updated summer Pell eligibility procedures. 5. Risk Mitigation (Required - Even if Disagreeing) These corrective actions reduce the risk of improperly awarding or disbursing Pell Grant funds for summer enrollment by strengthening supervisory oversight, improving staff understanding of summer eligibility requirements, and ensuring eligibility is reviewed and verified prior to disbursement. Ongoing monitoring and quality assurance reviews provide additional safeguards to identify and prevent future noncompliance. 6. Responsible Party • Office/Department: Office of Financial Aid • Title of Responsible Official: Director of Financial Aid • Name (optional): 7. Implementation Timeline • Corrective action implemented: Yes (No) • If not fully implemented, expected completion date: June 30, 2026 8. Status of Corrective Action (For Prior-Year or Repeat Findings) Fully implemented Partially implemented (Not yet implemented) Evidence of Implementation In progress, evidence is not yet available. 9. Monitoring and Sustainability Ongoing supervisory review and periodic internal monitoring will be conducted to ensure summer Pell eligibility requirements are consistently met and documented prior to disbursement. Continued staff training, standardized review procedures, and quality assurance checks will be maintained to support long-term compliance and timely identification and correction of any eligibility issues.