Corrective Action Plans

Condition: The Food Service Department did not perform its verification process by the date required by the state pass-through agency. Corrective Action Planned: No applications were submitted to be verified. The school district prompted caregivers on numerous occasions to return the forms without receiving any. Anticipated Completion Date: 2/17/2025 Contact: Peter Cushing, Assistant Superintendent

Condition: Free or reduced meals applications could not be provided. The Food Service Department did not process free or reduced priced meals applications for the 2022-2023 school year. Corrective Action Planned: The School District has hired a qualified leader for the School Nutrition Program in order to comply with the requirements of this program. Additionally, the school district has enrolled all but the Brooks Elementary School as Community Eligibility Provision (CEP) sites and we are no longer required to collect these forms. At the Brooks School, these forms were sent to families from the Brooks School during the FY24 school year. Despite the efforts of the school and Food Services Director, no forms were returned to the school. Presently the forms are not required for the Brooks as the CEP eligibility requirements were reduced from 40% to 25% for determination. Anticipated Completion Date: 2/15/2025 Contact: Peter Cushing, Assistant Superintendent

We concur with the finding. During the fiscal year 2024-2025, all participant files will be revised to include all missing documents referred to in the finding.

2023-004 Ineffective Internal Controls over Sliding Fee Revenues Health Center Program – CFDA #93.527 & 93.224 Condition: During the compliance testing of the Uniform Guidance “Special Tests and Provisions – Sliding Fee Applications” requirements, we noted the following exceptions: • Three (3) out of eighteen (18) sampled did not have the slide fee applied to the lab portion. • Two (2) out of eighteen (18) sampled were calculated incorrectly based on the sliding fee schedule (wrong sliding fee applied based on application). • Two (2) out of eighteen (18) sampled were missing applications. • One (1) out of eighteen (18) sampled were incorrectly in the system with a medical slide A on a dental charge. This patient was also one of the sampled items missing an application so it could not be determined if slide A would have been correct. Action Taken: • CHESI has implemented a new workflow process to ensure compliance with the program requirements of the sliding fee program. CHESI has developed a new sliding fee procedure and trained all staff to ensure the applications are complete and signed by the patient, income is verified, the proper discount is calculated based on the sliding fee schedule, the proper amount of discount is applied to the patient’s account, and the application is approved and signed by the CFO. All sliding fee applications will also be scanned into the patient’s chart once completed and approved. Anticipated Date of Completion and Name of Contact Person: December 31, 2023 – J.P. Champion, Chief Financial Officer

CAMcare has made significant changes to the patient payment collection process. Updates were made to the Patient Payments, Refusal to Pay, Waiver/Reduction of Charges Policy, Sliding Fee Scale Policy, and Patient Payments Policy, and a Patient Payments Policy was introduced. The new EMR system allows for individual Patient Service Representatives (front desk personnel) to monitor management's adherence to collection efforts.

Identification of federal programs 10.558 and 21.027 – Child and Adult Care Food Program (CACFP) and Child Care and Development Block Grant (ARPA) Condition The Organization did not retain eligibility documentation for each site noting the control process. Views of Responsible Officials: Management agrees with the finding and observation. Contact Person: Fendy Wogu, Finance Controller Proposed Completion Date: October 31, 2024

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Public and Indian Housing Program Federal Assistance Listing Numbers: 14.850 Noncompliance – N. Special Tests and Provisions – Public Housing Waiting List Non Compliance Material to the Financial Statements: Yes Material Weakness in Internal Control over Compliance for Special Tests and Provisions Finding 2023-005 (continued): Criteria: Selections from the Waiting List. The PHA must have written policies in its Admissions and Continued Occupancy Policy for selecting applicants from the waiting list and PHA documentation must show that the PHA follows these policies when selecting applicants from the waiting list. Except for as provided in 24 CFR section 982.203 (Special admission (non-waiting list), all families admitted to the program must be selected from the waiting list. “Selection” from the waiting list generally occurs when the PHA notifies a family whose name reaches the top of the waiting list to come in to verify eligibility for admission (24CFR sections 5.410, 982.54(d), and 982.201 through 982.207). Condition: Based upon inspection of the waiting list provided to us during the time of audit, the new move-in list and discussions with management, it could not be determined with any certainty that certain new move-ins to the Public and Indian Housing Program were selected from the wait list in an order that is in accordance with the Authority’s Admissions and Continued Occupancy Policy. Context: Of a sample size of nine (9) new move-ins, nine (9) could not be determined to be housed in proper order from the Authority's waiting list. Our sample size is statistically valid. Known Questioned Costs: $89,397 Cause: There is a material weakness in internal controls over the compliance for the special tests and provisions type of compliance related to the public housing waiting list. The Authority has not properly considered, designed, implemented, maintained and monitored a system of internal controls that assures the program is in compliance. Effect: The Public and Indian Program is in material non-compliance with the special tests and provisions type of compliance related to selection of applicants from the waiting list. Recommendation: We recommend the Authority design and implement internal control procedures that will assure compliance with the Uniform Guidance and the compliance supplement. Views of responsible officials and planned corrective action: The Authority accepts the recommendation of the auditor. The Authority will increase oversight on the maintenance of the waiting list and process of housing applicants to better monitor adequacy with compliance requirements. Kim Dolan, Chief Financial officer, will be responsible to implement this corrective action by December 31, 2024.

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Public and Indian Housing Assistance Listing Numbers: 14.850 Noncompliance – E. Eligibility – Tenant Files Non Compliance Material to the Financial Statements: Yes Material Weakness in Internal Control over Compliance for Eligibility Criteria: Tenant Files. The PHA must do the following: As a condition of admission or continued occupancy, require the tenant and other family member to provide necessary information, documentation, and releases for the PHA to verify income eligibility (24 CFR sections 5.230, 5.609, and 982.516). These files are required to be maintained and available for examination at the time of audit. Condition: Based upon inspection of the Authority’s files and on discussion with management, there were documents that were unavailable for examination at the time of audit. Finding 2023-004 (continued): Context: There are approximately 460 units. Of a sample size of seventeen (17) tenant files, the following was noted: • HUD 50058 annual recertification was not filed timely in 2 files • Original Application was missing in 1 file • Verification of income was missing in 3 files • Verification of assets was missing in 2 files Our sample size is statistically valid. Known Questioned Costs: $28,961 Cause: There is a material weakness in internal controls over the compliance for the eligibility type of compliance related to the maintenance of tenant files. The Authority has not properly considered, designed, implemented, maintained and monitored a system of internal controls that assures the program is in compliance. Effect: The Public and Indian Housing Program is in material non-compliance with the eligibility type of compliance related to the maintenance of tenant files. Recommendation: We recommend the Authority design and implement internal control procedures that will assure compliance with the Uniform Guidance and the compliance supplement. Views of responsible officials and planned corrective action: The Authority has recognized the material weakness in the Public and Indian Housing Program and will implement internal control procedures that will ensure compliance with federal regulations. Elizabeth Campbell, Interim Deputy Director, will be responsible to implement this corrective action by December 31, 2024.

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Section 8 Housing Choice Vouchers Program Federal Assistance Listing Numbers: 14.871 Noncompliance - N. Special Tests and Provisions - Selection from the Waiting List Non Compliance Material to the Financial Statements: Yes Material Weakness in Internal Control over Compliance for Special Tests and Provisions Criteria: Selections from the Waiting List. The PHA must have written policies in its Section 8 Administrative Plan for selecting applicants from the waiting list and PHA documentation must show that the PHA follows these policies when selecting applicants from the waiting list. Except for as provided in 24 CFR section 982.203 (Special admission (non-waiting list), all families admitted to the program must be selected from the waiting list. “Selection” from the waiting list generally occurs when the PHA notifies a family whose name reaches the top of the waiting list to come in to verify eligibility for admission (24CFR sections 5.410, 982.54(d), and 982.201 through 982.207). Condition: Based upon inspection of the waiting list provided to us during the time of audit, the new move-in list and discussions with management, it could not be determined with any certainty that certain new move-ins to the Section 8 Housing Choice Vouchers Program were selected from the wait list in an order that is in accordance with the Authority’s Section 8 Administrative Plan. Context: Of a sample size of thirteen (13) new move-ins, seven (7) could not be determined to be housed in proper order from the Authority's waiting list. Our sample size is statistically valid. Known Questioned Costs: $181,533 Cause: There is a material weakness in internal controls over the compliance for the special tests and provisions type of compliance related to selection from the waiting list. The Authority has not properly housed applicants in compliance with program requirements. Effect: The Section 8 Housing Choice Vouchers Program is in material non-compliance with the eligibility type of compliance related to selection from the waiting list. Recommendation: We recommend the Authority design and implement internal control procedures that will reasonably assure compliance with the Uniform Guidance and the compliance supplement. Finding 2023-006 (continued): Views of responsible officials and planned corrective action: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Section 8 Housing Choice Voucher Program to ensure that established internal control policies are being followed on a timely basis. Kim Dolan, Chief Financial officer, will be responsible to implement this corrective action by December 31, 2024.

Finding 2023-001: Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Housing Voucher Cluster - Section 8 Housing Choice Vouchers - Mainstream Vouchers - Emergency Housing Vouchers Assistance Listing Numbers: 14.871, 14.879, 14.EHV Noncompliance – E. Eligibility – Tenant Files Non Compliance Material to the Financial Statements: Housing Voucher Cluster - Section 8 Housing Choice Vouchers - Yes - Mainstream Vouchers - Yes - Emergency Housing Vouchers - No Finding 2023-001 (continued): Material Weakness and Significant Deficiency in Internal Control over Compliance for Eligibility Criteria: Tenant Files. The PHA must do the following: As a condition of admission or continued occupancy, require the tenant and other family member to provide necessary information, documentation, and releases for the PHA to verify income eligibility (24 CFR sections 5.230, 5.609, and 982.516). These files are required to be maintained and available for examination at the time of audit. Condition: Based upon inspection of the Authority’s files and on discussion with management, there were documents that were unavailable for examination at the time of audit. Context: There are approximately 2,434 units. Of a sample size of fifty-six (56) tenant files, the following was noted: • HUD form 9886 was unable to be provided in 4 files • Verification of income was unable to be provided in 5 files • Verification of assets was unable to be provided in 4 files • HUD 50058 annual recertification was not filed timely in 8 files • Original Application was unable to be provided in 12 files • Citizen Declaration Section 214 form was unable to be provided in 2 files • Lead based paint form was unable to be provided in 16 files • Signed lease was unable to be provided in 6 files • Our sample size is statistically valid. Known Questioned Costs: • 14.871 - Section 8 Housing Choice Vouchers - $65,025 • 14.879 - Mainstream Vouchers - $31,974 • 14.EHV - Emergency Housing Vouchers - $14,095 Cause: There is a material weakness in the Section 8 Housing Choice Vouchers and Mainstream Vouchers programs and a significant deficiency in the Emergency Housing Vouchers program in internal controls over the compliance for the eligibility type of compliance related to the maintenance of tenant files. The Authority has not properly considered, designed, implemented, maintained and monitored a system of internal controls that assures the program is in compliance. Effect: The Section 8 Housing Choice Vouchers and Mainstream Vouchers programs are in material non-compliance, and the Emergency Housing Vouchers program is in non-compliance with the eligibility type of compliance related to the maintenance of tenant files. Recommendation: We recommend the Authority design and implement internal control procedures that will assure compliance with the Uniform Guidance and the compliance supplement. Views of responsible officials and planned corrective action: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Housing Voucher Cluster to ensure that established internal control policies are being followed on a timely basis. Kathleen Wyatt, Director of Housing Operations, will be responsible to implement this corrective action by December 31, 2024.

The Houston Housing Authority agrees with this finding. The Houston Housing Authority has for the past several months undertaken a program to review all voucher files for purposes of getting all delinquent recertifications completed. During this process if other required documents are found to be missing steps are being taken to complete the missing documentation and make sure that the files are complete. This review is substantially completed with final completion expected in the third quarter of 2024. Procedures have been implemented with regards to preventing this situation from recurring. Where needed staff will be provided the necessary training to make sure that a HCVP staff have the skills needed to successfully complete their job tasks. To facilitate this training, the Houston Housing Authority has created a training center that is made available to not only Houston Housing Authority staff but also others to provide a wide variety of training classes. Current leadership at the Houston Housing Authority is committed to having a competent trained staff working in the HCVP as well as other departments with the agency. Because the file clean up work was being performed in calendar year 2024 we expected this finding would be present for the 2023 audit. This work is handled by the Voucher Program Operations department. The VP of this department and the Director of this department are primarily responsible for making sure the necessary corrections are made and the fill review is completed within the third quarter of 2024.

The Houston Housing Authority agrees with this finding. The Houston Housing Authority has for the past several months undertaken a program to review all voucher files for purposes of getting all delinquent recertifications completed. During this process if other required documents are found to be missing steps are being taken to complete the missing documentation and make sure that the files are complete. This review is substantially completed with final completion expected in the third quarter of 2024. Procedures have been implemented with regards to preventing this situation from recurring. Where needed staff will be provided the necessary training to make sure that a HCVP staff have the skills needed to successfully complete their job tasks. To facilitate this training, the Houston Housing Authority has created a training center that is made available to not only Houston Housing Authority staff but also others to provide a wide variety of training classes. Current leadership at the Houston Housing Authority is committed to having a competent trained staff working in the HCVP as well as other departments with the agency. Because the file clean up work was being performed in calendar year 2024 we expected this finding would be present for the 2023 audit. This work is handled by the Voucher Program Operations department. The VP of this department and the Director of this department are primarily responsible for making sure the necessary corrections are made and the fill review is completed within the third quarter of 2024.

The Houston Housing Authority agrees with this finding. The Houston Housing Authority has for the past several months undertaken a program to review all voucher files for purposes of getting all delinquent recertifications completed. During this process if other required documents are found to be missing steps are being taken to complete the missing documentation and make sure that the files are complete. This review is substantially completed with final completion expected during the final quarter of 2024. Procedures have been implemented with regards to preventing this situation from recurring. Where needed staff will be provided the necessary training to make sure that all HCVP staff have the skills needed to successfully complete their job tasks. To facilitate this training, the Houston Housing Authority has created a training center that is made available to not only Houston Housing Authority staff but also others to provide a wide variety of training classes. Current leadership at the Houston Housing Authority is committed to having a competent trained staff working in the HCVP as well as other departments with the agency. Because the file clean up work was being performed in calendar year 2024 we expected this finding would be present for the 2023 audit. This work is handled by the Voucher Program Operations department. The VP of this department and the Director of this department are primarily responsible for making sure the necessary corrections are made and the fill review is completed within the final quarter of 2024.

Finding 2023-002 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Section 8 Housing Choice Vouchers Program Federal Catalog Numbers: 14.871 Noncompliance – E. Eligibility - Tenant Files Non Compliance Material to the Financial Statements: No Significant Deficiency in Internal Control over Compliance for Eligibility Criteria: Tenant Files. The PHA must do the following: As a condition of admission or continued occupancy, require the tenant and other family member to provide necessary information, documentation, and releases for the PHA to verify income eligibility (24 CFR sections 5.230, 5.609, and 982.516). These files are required to be maintained and available for examination at the time of audit. Condition: Based upon inspection of the Authority’s files and on discussion with management, there were documents that were unavailable for examination at the time of audit. Context: Of a sample size of twenty-two (22) tenant files, the following information was unavailable for examination at the time of audit: • Biennial inspection reports were missing in two (2) files Our sample size is statistically valid. Known Questioned Costs: $21,520 Cause: There is a significant deficiency in internal controls over the compliance for the eligibility type of compliance related to the maintenance of tenant files. 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 Section 8 Housing Choice Vouchers program is in non-compliance with the eligibility type of compliance related to the maintenance of tenant files. Recommendation: We recommend the Authority design and implement internal control procedures that will reasonably assure compliance with the Uniform Guidance and the compliance supplement. Views of responsible officials and planned corrective action: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Section 8 Housing Choice Vouchers program to ensure that established internal control policies are being followed on a timely basis. Adam Bovilsky, Executive Director, is responsible for implementing this corrective action by March 31, 2024.

93.767 Children's Health Insurance Program (CHIP) 93.778 Medical Assistance Program (Medicaid; Title XIX) Eligibility 2023-024 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 Seven MAGI beneficiaries - DOM did not verify self-employment income reported on 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. DOM maintains that for determining eligibility, it has complied with the CMS-approved state plan. Using the approved CMS MAGI Based Verification plan in effect during the audit time period, the state sought to verify the reported income to the standard of reasonable compatibility, as defined by CMS, through all available electronic data sources. Further, DOM is required to accept the information provided by the applicant and utilize the available verification methods as detailed in the CMS-approved state plan to evaluate the accuracy of the information provided. If an applicant does not report self-employment income, and the tools available to DOM do not reveal such, DOM has performed its due diligence in the eligibility process and complied with the requirements of CMS, DOM's federal regulatory and oversight agency. Additionally, tax return information is outdated and not deemed applicable to DOM. Four of the 180 MAGI beneficiaries - Income was not verified through Mississippi Department of Employment Security DOM Concurs. This oversight was reviewed with the employees. Additionally, DOM Eligibility staff will be reminded of the MOES response time to ensure that when a MOES request is generated the adequate response time is waited prior to processing an application. Two of the 300 beneficiaries - The beneficiary's case file did not contain a completed application. DOM Concurs. This file could not be located. One of the 300 beneficiaries - DOM could not provide a case file. DOM Concurs. This file could not be located. Fifteen ABD beneficiaries - Resources were not verified through A VS at the time of redetermination. DOM Concurs. This was a previous finding that DOM concurred with. In June 2022, the eligibility system change request list was updated to include asset checks within the system processing workflow to eliminate the manual request process and facilitate asset verification through A VS. This process was implemented June of 2022 for redetermination contacts. Application contacts are a manual process. DOM did not perform resource verification through A VS for the beneficiaries in question prior to this implementation. However, after being notified DOM ran A VS for all applicants, which resulted in no change in the eligibility determination. One hundred ninety-five beneficiaries were not included on all of the required quarterly Public Assistance Reporting Information System (PARIS) me transmissions for fiscal year 2023. Of the 195 beneficiaries, one beneficiary was not included on any quarterly PARIS me transmissions during fiscal year 2023. DOM Does not Concur. PARIS jobs run on February 1, May 1, August 1, and November 1. PARIS will not be pulled on a beneficiary if the case is closed at the time the file is generated or if there is no SSN on file. Additionally, while the records are sent, not all the cases return a match. Our vendor confirmed that a PARIS request was sent for the open cases with SSN numbers on file with one exception. One case was in COE 29-Family Planning. The omission was identified in a previous audit and was corrected in late 2023. DOM Corrective Action Plan: a. All issues identified will be reviewed with regional office staff. Examples of these issues will be included in annual training sessions performed by Eligibility staff. Further, DOM is implementing an electronic storage system to house all documents associated with applicants/beneficiary files. b. Cindy Bradshaw c. December 31, 2024

2023-025 Response: Strengthen Controls to Ensure Compliance with Eligibility Requirements for the Emergency Rental Assistance Program (ERA). ALN# 21.023 We acknowledge the finding. The Mississippi Department of Finance and Administration was not appropriated funds for this program nor was the agency given any authority for the administration for the program. As such, DFA was not in a position to assess eligibility determinations or perform monitoring. DFA drew down funds on behalf of Mississippi Home Corp in light of an impending federal deadline. Mississippi Home Corporation had eligibility and fraud prevention policies in place for the ARPA programs. These policies included, but are not limited to, contracting with a third-party law firm to review all applications with a three-tier review system, monitoring with random sample selections for every 10% completed, employing an internal, qualitycontrol auditor, and reviewing any applications submitted that were greater than $10,000. As a result of their monitoring, MHC was able to identify suspicious applications and report them to the Mississippi Attorney General for investigation. MHC continues to report all expenditures directly to U.S. Treasury on a quarterly basis. It is also worth noting that the program stopped taking applications in September of 2022 which was prior to the issuance of the 2022 Single Audit Report that was released on July 31, 2023. Thus, policies and controls in place could not be changed for this. DFA is taking the position that corrective action is no longer necessary for these funds. Corrective Action: A. The Mississippi Department of Finance and Administration is taking the position that corrective action is no longer necessary. The program stopped taking applications in September of 2022, which is prior to the current 2023 single audit report dated November 21, 2024. Policies and controls in place could not be changed for this. B . N/A C. N/A D. The Emergency Rental Assistance program stopped taking applications September of 2022.

Reference Number: 2023-003 Prior Year Finding: No Federal Agency: U.S. Department of Labor State Agency: Mississippi Department of Employment Security Federal Program: WIOA Cluster Assistance Listing Number: 17.258, 17.259, 17.278 Award Number and Year: 7/1/22 – 6/30/23 Compliance Requirement: Eligibility Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Compliance – Per 20 CFR parts 680, 681, 682, and 683, state workforce agencies must ensure that individuals are eligible to participate in the program. Control – Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The Mississippi Department of Employment Security (MDES) was unable to provide documentation that the eligibility determination for a participant had been reviewed and approved. Context: Documentation for one of forty participants selected for testing did not contain a supervisor’s signature indicating that it had been reviewed and approved. Questioned costs: Undetermined. Cause: Internal controls were not sufficient to ensure that documentation supporting participant eligibility was reviewed and approved by a supervisor. Effect: Failure to ensure that all eligibility documentation is properly reviewed and approved could result in ineligible individuals participating in the program. Recommendation: MDES should review and enhance internal controls and procedures to ensure that participant eligibility documentation is properly reviewed and approved by a supervisor. Views of responsible officials: MDES Response MDES concurs with this finding and recommendation. These incidents were isolated and non-reoccurring. MDES will implement procedures to require a review of all eligibility documents for completeness. Corrective Action Plan: a. MDES Action Plan: MDES will require, as a compensating control for each file to contain a checklist of required documentation that will be reviewed and approved by the supervisor responsible for the respective job center. MDES will verify internal compliance with these procedures over the next quarter. b. Contact Person Responsible: Director of Grant Management. c. Anticipated Corrective Action Plan Completion Date: MDES will complete this corrective action on or before September 30, 2024.

Views of Responsible Officials: Prior to receiving this finding, HIPS was not in the practice of saving documentation of financial or programmatic reporting submission. Staff responsible for submissions are now documenting submission of reports as of 2024. Incorrect application of the de minimis rate was due to an error in the funder-provided spreadsheet. HIPS Finance Manager has been tasked with checking all spreadsheet calculations prior to submissions of financial reporting.

Brockwood Community Association 801 W. Washington Street Greenville, South Carolina 29601 CORRECTIVE ACTION PLAN March 20, 2024 U.S. Department of Housing and Urban Development Charles Bennett Federal Building 400 West Bay Street, Suite 1015 Jacksonville, Florida 32202 Brockwood Community Association respectively submits the following Corrective Action Plan for the year ended December 31, 2023. Bernard Robinson & Company, L.L.P. 1501 Highwoods Blvd., Suite 300 Post Office Box 19608 Greensboro, North Carolina 27419-9608 The finding from the year ended December 31, 2023 Schedule of Findings and Questioned Costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. FINDING - Federal Award Program Audit Finding 2023-001: U.S. Department of Housing and Urban Development, Mortgage Insurance for the Purchase or Refinancing of Existing Multifamily Projects (Section 223(f)/207) Recommendation: We recommend that the management ensure the required household members sign the HUD-50059 prior to submitting to HUD. Action Taken: We agree with Finding 2023-001 and the recommendation described in the accompanying schedule of findings and questioned costs. Management obtained the required signature on the HUD-50059. Management will ensure that all required signatures are obtained on all Form HUD-50059's prior to submitting to HUD going forward. If HUD has questions regarding this corrective action plan, please call (704) 771-1696. Sincerely yours, Claudia A Keene, CPA Controller Multifamily Select, Inc. Managing Agent

2023-004 Tenant File Documentation The Housing Authority of Okanogan County recognizes we had several oversights in our tenant file documentation. We will continue to review our tenant file documentation procedures to ensure compliance with HUD program requirements in the future. Subsequent to year-end, during April 2024, the Housing Authority of Okanogan County underwent a Section 8 Management Assessment Program review by the U.S. Department of Housing and Urban Development and received a final score of Standard. We have made several process and procedure improvements and anticipate full compliance during our subsequent audit.

Financial Reporting and Review Process Description of the Finding: BSEDC did not have a secondary review process over the required financial reporting to Federal EDA. The lack of a secondary review process allowed for errors and omissions to go undetected, thus resulting in omission of $3,614 of loan origination fee income and interest income from federal program income calculations. Planned Corrective Actions: BSEDC’s Senior Director of Finance and Director of Business Finance/Program Finance Director have implemented processes for the Senior Director of Finance to perform a secondary review of the required reporting to Federal EDA before it is submitted. Timeline for Completion: BSEDC implemented the secondary review process in October 2024 with the completion and submission of the FY24 annual report to Federal EDA. Responsible Person or Party: BSEDC’s Senior Director of Finance and Director of Business Finance/Program Finance Director are both responsible for ensuring that the secondary review is complete before submitting reporting to Federal EDA.

Finding No. 2023-001: Compliance with Single Audit Requirements Description of the Finding: Big Sky Economic Development Corporation, Inc. (BSEDC) did not engage to conduct a single audit for FY23 despite meeting the expenditure threshold, and the required audit report was not submitted within the prescribed due dates. This oversight necessitated the reissuance of the FY23 financial statement audit to complete and issue a single audit. Planned Corrective Actions: BSEDC’s Senior Director of Finance engaged with an independent auditor to complete the single audit for FY23 and re-issue the financial statement audit which was missed during the performance of the FY23 financial statement audit due to the Senior Director of Finance and the parties they engaged to perform the audit not having a clear understanding of the calculation for federal expenditures for the federal revolving loan fund. The Senior Director of Finance now has a clear understanding of the requirements for the calculation and reporting of federal expenditures in the Schedule Expenditures of Federal Awards as it relates to the federal revolving laon fund. Timeline for Completion: BSEDC engaged with an independent auditor to complete the single audit for FY23 and reissue the FY23 financial statement audit in June 2024. Expected completion is November 2024. Responsible Person or Party: BSEDC’s Senior Director of Finance is responsible for implementing the corrective action.

Finding 2023-004 Name of contact person: Corrective Action: Section III - Federal Award Findings and Question Costs (continued) Supervisors, will ensure staff complete all required trainings provided by the Division of Health Benefits. Supervisors will provide additional training, when needed to ensure staff have a good understanding of all current and new policy as policy continuously changes. Records will be reviewed internally to ensure cases provide proper documentation. Corrective Action (continued): Proposed completion date: Corrective Actions for Finding 2023-002, 2023-003, and 2023-004 also apply to State Award Findings. Section IV - State Award Findings and Question Costs Training will be provided the week of November 20, 2023 to review findings and corrective action items. Trainings will continue every week to review policy changes, NCFAST updates as well as common errors that may be found during second party reviews. Workers will be trained on the importance of ensuring files include, online verifications, documentation of resources and ensuring, documented resources and income match information entered in NCFAST. Documentation in files should provide clear steps taken by caseworkers to determine eligibility. Checklists have been established to include errors cited during audit. Checklists are to be completed at applications and recertifications, As policy changes and new recommendations are provided by the state, checklists are updated to ensure staff are aware of the most recent policy and procedures.

Finding 2023-003 Name of contact person: Corrective Action: Proposed completion date: Finding 2023-004 Name of contact person: Corrective Action: Section III - Federal Award Findings and Question Costs (continued) Supervisors, will ensure staff complete all required trainings provided by the Division of Health Benefits. Supervisors will provide additional training, when needed to ensure staff have a good understanding of all current and new policy as policy continuously changes. Records will be reviewed internally to ensure cases provide proper documentation. Amy Spring, Income Maintenance Administrator Training will be provided the week of November 20, 2023 to review findings and corrective action items. Trainings will continue every week, to review policy changes, NCFAST updates as well as common errors that may be found during second party reviews. Amy Spring, Income Maintenance Administrator Training will be provided the week of November 20, 2023 to review findings and corrective action items. Trainings will continue every week to review policy changes, NCFAST updates as well as common errors that may be found during second party reviews. Supervisors, will ensure staff complete all required trainings provided by the Division of Health Benefits. Supervisors will provide additional training, when needed to ensure staff have a good understanding of all current and new policy as policy continuously changes. Records will be reviewed internally to ensure cases provide proper documentation. Workers will be trained on the importance of ensuring files include, online verifications, documentation of resources and ensuring, documented resources and income match information entered in NCFAST. Documentation in files should provide clear steps taken by caseworkers to determine eligibility. Checklists have been established to include errors cited during audit. Checklists are to be completed at applications and recertifications, As policy changes and new recommendations are provided by the state, checklists are updated to ensure staff are aware of the most recent policy and procedures.

Finding 2023-002 Name of contact person: Corrective Action: Training will be provided the week of September 5, 2023 to review findigns of corrective action items. Trainings will continue every week to review policy changes, NCFAST updates, as well as common errors that may be found during second party reviews. Two applications cited in error were processed by temporary staff hired to assist with the volume of Crisis Intervention applications as well as the Low-Income Energy Assistance applications. Two applications cited in error were processed by an employee who has retired. Training will be provided to all temporary staff when hired to ensure applications are processed accurately and all necessary information is requested. Supervisor will be reviewing records internally to ensure accuracy of cases. Applications will be revieiwed and monitored on a rotation basis. Findings from second party reviews will be reviwed with the worker to monitor a pattern for errors and will review policy guidelines to ensure worker is knowledgeable of policy requirements. Training will also be provided to ensure all files include online verifications. Supervisors will provide training to ensure workers are aware of proper documentation required to support eligibilty decisions. Checklists have been established to include errors cited during the audit. Checklists are to be completed at all applications. Amy Spring, Income Maintenance Administrator Supervisors, will ensure staff complete all required trainings provided by the Division of Health Benefits. Supervisors will provide additional training, when needed to ensure staff have a good understanding of all current and new policy as policy continuously changes. Records will be reviewed internally to ensure cases provide proper documentation. Workers will be trained on the importance of ensuring files include, online verifications, documentation of resources and ensuring, documented resources and income match information entered in NCFAST. Documentation in files should provide clear steps taken by caseworkers to determine eligibility. Checklists have been established to include errors cited during audit. Checklists are to be completed at applications and recertifications, As policy changes and new recommendations are provided by the state, checklists are updated to ensure staff are aware of the most recent policy and procedures.