Corrective Action Plans

Finding 2023-004 Income Eligibility and Verification System Management Views MDHHS agrees with parts a., b., and d. of the finding. MDHHS disagrees with parts c. and e. of the finding. For part c., MDHHS disagrees that a process is not fully established to monitor the electronic notifications provided to county/district office caseworkers to ensure they utilized the Income Eligibility Verification System (IEVS) information to determine the recipients' eligibility. Although MDHHS did not implement the Bridges change to require an action comment before the county/district office caseworkers dispose of the electronic notifications until July 2023, MDHHS had policies and procedures in effect during fiscal year 2023 to help ensure monitoring of electronic notifications was taking place. Review of IEVS information is fully incorporated into the case read procedure governed by Bridges Administrative Manual 301 and detailed further in desk aids and reading guides. The Economic Stability Administration (ESA) provides regular direction and reminders of case read requirements via ESA Memos. For part e., MDHHS disagrees that IEVS information is required to be requested and obtained for modified adjusted gross income (MAGI) based recipients since eligibility is verified upon determination through the MAGI eligibility determination process and then granted for a 12-month continuous eligibility period. Requesting and obtaining IEVS information throughout the eligibility period would be irrelevant since eligibility is continuous. Planned Corrective Action For parts a. and b., MDHHS’s ESA will continue to provide training and policy support to ensure that the local office specialists appropriately utilize the IEVS interface information in determining recipients’ eligibility when applicable. ESA implemented a technical solution during July 2023 for applicable interfaces to ensure the IEVS information is being addressed timely and used correctly in eligibility determinations. For part d., MDHHS is collaborating with other work areas to facilitate the match process for the IEVS interfaces for recipients funded by Temporary Assistance for Needy Families (TANF) adoption subsidies. For parts c., and e., MDHHS disagrees with the finding and does not intend to take further action. Anticipated Completion Date a. and b. Ongoing c. Not applicable d. September 30, 2024 e. Not applicable Responsible Individual(s) a., b., and c. Veronica Maxson, MDHHS d. Kathonya Rice, MDHHS e. Logan Dreasky, MDHHS

Finding 2023-002 Bridges Security Management and Access Controls Management Views MDHHS agrees with the finding. Planned Corrective Action For parts a., c., and d., MDHHS implemented the Database Security Application (DSA) on October 2, 2023, which includes documenting incompatible role exception requests and user access request approvals. The DSA also includes semi-annual review of privileged users and annual review for all users. For parts b. and e., MDHHS will revise internal business processes to include an additional level of monitoring and review to ensure compliance with the existing directives related to monitoring and review requirements. Anticipated Completion Date a., c., and d. Completed b. and e. August 2024 Responsible Individual(s) a., c., and d. Deon Nelson, MDHHS b. and e. Veronica Maxson, MDHHS

Finding 2023-001 Bridges Interface Controls Management Views DTMB agrees with the finding. Planned Corrective Action DTMB applied a system fix on May 11, 2024, related to the coding issue to ensure the batch summary table control totals match the exceptions table. Anticipated Completion Date Completed Responsible Individual(s) Heather Frick, DTMB Nathan Buckwalter, DTMB

The two individuals determined to have incomes in excess of HOME Program limits were noted in our FY23 monitoring of properties assisted with HOME funds. The HOME Program allows for a unit to be occupied by a household who was initially eligible and whose income later increases, but requires that a comparable unit be designated as a HOME unit and leased to an eligible household when one is available. Owners of each property were made aware of the circumstance when City monitoring was completed. Each will designate comparable units to be HOME units when available and lease them to eligible households.

Finding 2023 - 001: Housing Choice Voucher Tenant Files - Eligibility - Internal Control over Tenant Files - Noncompliance and Material Weakness Corrective Action Plan: Training: Currently, we are having all HCV staff trained and refreshed on rent calculations through Nan McKay. Staff will also be trained in best practices for properly obtaining verification and following the verification hierarchy process. Also, we are hiring a Training and Development Specialist. Once filled, we will conduct monthly and quarterly training. We anticipate filling the position by July 2024. Quality Control: We conduct 100% quality control on all new hires', completed action files and 100% quality control on all contract files. Quality Control of 25% of all annuals and 25% of all interims completed monthly by all non­ provisional employees. Department Structure: The supervisors will quality-control any caseworkers with an error rate of 80% of their files. Once we fill all staff vacancies and complete the provisional period for all our new staff, we will audit up to 40% of all completed files. Anticipated Completion Date: The current staff is attending Nan McKay's rent calculations training on June 4-6, 2024. We anticipate completion of the plan by 12/31/2024. Person Responsible: Ms. Rhonda Jackson, Housing Program Manager II, and Ms. Malandria Watson, Housing Program Manager I, will review the Quality Control Report and error ratios monthly.

Finding No. 2023-002 Tenant Files: Eligibility Program: U.S. Department of HUD: Section 8 Housing Choice Vouchers (CFDA 14.871) Type of Finding: Material non-compliance and Material Weakness in Internal Control over Compliance This is a repeat finding of 2022-002 from September 30, 2022 (Originally reported as finding 2019-001 from September 30, 2019) Statement of Condition: Out of a total tenant population of approximately 1,142 vouchers, 25 files were selected for testing, and the following errors were discovered. • 1 tenant file had the following error: o The utility allowance was miscalculated by $32 (overstatement). The two-bedroom column utility rates were used when the 1-bedroom column utility rates should have been used. Correcting this error would cause which the HAP rent to decrease from $762 to $731. • 1 tenant file had the following error: o An EIV form was either not run or has been misplaced for the tenant’s annual recertification period. • 1 tenant file had the following error: o The utility allowance was miscalculated by $23 (understatement). The 2022 utility allowance schedule was used when the 2023 utility allowance schedule should have been used. Correcting this error would cause the HAP rent to increase from $494 to $517. • 1 tenant file had the following error: o The tenant did not check the checkbox on the 214-affidavit form indicating that they are a U.S. Citizen. However, based on the birth certificate the tenant is a U.S. citizen. • 1 tenant file had the following error: o An EIV form was either not run or has been misplaced for the tenant’s annual recertification period. • 1 tenant file had the following error: o The tenant’s asset income was miscalculated. Correcting this error would increase the HAP rent by $4. • 1 tenant file had the following error: o The 50058-form reported childcare income support of $6,000, however, the support for the childcare income showed $5,800. Correcting this error had no effect on the HAP rent. • 1 tenant file had the following error: o No support for the tenant’s wage income of $23,296 on the 50058 form. Appears to be reported correctly, since the EIV shows an amount that approximates the tenant’s wage income of $23,296. Nonetheless, there needs to be support in the tenant file for the wage income. o Missing HAP contract. • 1 tenant file had the following error: o The utility allowance was miscalculated by $19 (understatement). Correcting this error would cause the HAP rent to increase from $924 to $943. In addition to the above, we noted the following during our new admissions testing (out of a total of 161 new admissions, 17 files were selected for testing.): • 1 tenant file had the following error: o The tenant did not check the checkbox on the 214-affidavit form indicating that they are a U.S. Citizen. However, based on the birth certificate the tenant is a U.S. citizen. • 1 tenant file had the following error: o HAP contract was not executed timely (within 60 days). • 1 tenant file had the following error: o The voucher extension date was not documented on the voucher. • 1 tenant file had the following error: o The request for tenancy addendum was executed (dated) two days after the voucher extended due date. o The unit size on the voucher did not agree to the family voucher size on the 50058 and the wrong payment standard was applied to the tenant. Recommendation: The Authority should correct the deficiencies noted in the tested files and utilize an ongoing quality control review process on the entire tenant population to ensure proper compliance with the requirements related to tenant eligibility. Ongoing staff training and timely management reviews should be utilized to ensure staff is aware of acceptable procedures. In addition, the Authority should review staffing levels, skill sets and case load. Action Taken: The Authority concurs with this finding. The Authority has an established review, oversight and training process and will continue to improve its review, oversight, and training process to ensure proper procedures are being followed. All audit findings of the files tested have been corrected. The Authority has implemented a quality control system so that every file receives a quality review for appropriate third-party verification and upfront income, and assistance is determined. The agency has created a Family Worksheet and an HCV Computation Worksheet to help staff identify errors in calculations and to check for accuracy prior to completing Annual Reexaminations and Interim Recertifications. The agency has changed its filing system to enable staff to thoroughly review all forms prior to admission and during regular recertification and interim adjustment processing. The agency created an “Other Adult” packet to ensure 214 forms and other pertinent are completed for all adult household members. The HCV Counselor caseloads have been distributed equitably amongst Counselors to promote efficiency and accuracy while working on each HCV participant's file. The Counselor's caseload is divided alphabetically and assigned by multifamily developments to track and monitor counselors' strength and weaknesses and to determine if additional training and/or monitoring is needed. A Counselor has been assigned to only handle specialty vouchers (EHV, VASH, Homeownership, and FUP). The FSS Coordinator is responsible for the full management of HCV FSS participants. The Authority has hired an Intake Housing Counselor/Portability Specialist to focus on determining eligibility of new applicants pulled from the waitlist and to manage the waitlist. This Counselor also determines eligibility and compiles document packet for portability clients. Internal file reviews are being completed and management will continue to conduct a 10% review for each Counselor's processing of annual recertifications. This percentage may increase if work product indicates a need for more stringent review. To further ensure compliance and accuracy, the HCV Program Manager will review at least 1 out of every 5 intake files. All new admissions move-in files are now being to the Housing Programs Director for review prior to approval. A sample size of 15% is now being reviewed at the end of month by the Compliance Director and Housing Programs Director for compliance. The Authority has had a significant turnover in the HCV department over the past 24 months. All HCV Counselors, except the new Intake Counselor, have attended Voucher Specialist training and Nan McKay HCV Rental Calculation Certification training and successfully passed the certification exam. Effective Date: June 21, 2024 Contact Information Gwendolyn B. Dawson, CEO Ocala Housing Authority 1629 NW 4th Street Ocala, Florida 34475 (352) 369-2636

Corrective Action Plan For the Year Ended September 30, 2023 Section II - Financial Statement Findings None Reported Section III - Federal Award Findings and Questioned Costs Finding 2023-001 Name of Contact Person: Sara Potts, Executive Director Corrective Action: We concur. Management will review the internal control procedures as they relate to eligiblity and will implement procedures to ensure all documents are obtained during intake. Proposed Completion Date: Immediately.

Finding Reference Number: 2023-001 – Significant Deficiency – Lack of Documentation of Verification of Vendors Description of Finding: APA verified vendor was neither suspended nor debarred and staff confirmed as such in writing. However, they did not print and/or maintain a copy of the screenshot for files. This was inconsistent with APA written procedures. Statement of Concurrence (or Nonconcurrence): Management concurs that there was one instance wherein it did not print and maintain the verification screenshot for its files. Corrective Action: Management will review and update its procurement procedures to include a contract review checklist to be signed and dated by the preparer and approved by the contract signer (General Counsel, COO or CEO). Said checklist will include a specific reference to the date suspension and debarment were checked and will serve as primary documentary support which will be included in the vendor contract files. Contact Information: For further details or questions regarding this corrective action plan, please contact: Name: Steven Naugle

• Finding 2023-001 – The FEMA submission request was submitted by management in 2021, which occurred prior to management’s implementation of its corrective action plan to address Finding 2022-004. Management performed an independent review of the expenditure for FEMA eligibility as part of an iterative review process with its FEMA consultants and FEMA representatives. This review was also documented in management’s representation on the FEMA online portal when the submission was made. However, management’s process did not include internal documentation to evidence an independent review had occurred prior to submission. The process has been corrected for any future FEMA submissions in October 2022. o Responsible Party: Amanda Zentefis

Corrective Action Plan The University will establish processes and policies to pull attendance reports after census date of each term/semester for any students who receive Title IV aid and are identified as non-attendance. We will use this information to recalculate Federal Pell Grant and Federal Direct Student Loan awards based on enrollment or change in enrollment status. At the end of each term/semester, the University will review F/FA grades for any student who receives Title IV aid and will adjust their aid accordingly to comply with Title 34 of the Code of Federal Regulations, Part 690.80. In addition, we are currently reviewing F/FA grades for the 2023-2024 academic year. Anticipated Completion Date: June 2024 Contact Person(s): Alicia Bookout Associate Vice Chancellor, Financial Aid

Eligibility – Housing Voucher Cluster – Assistance Listing No. 14.871 Recommendation: CLA recommends management should designate one person to review a sample of the files that have been recertified each month. The purpose of the review is to determine if the tenant files were prepared in accordance with internal policies and verify the compliance deficiencies have been corrected. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: : Following CLA’s recommendation, SVP of Housing Choice will audit a random sample of 10 files on a monthly basis. Agency working with Human Resources contractor to fill open staff positions Name(s) of the contact person(s) responsible for corrective action: Janie Anderson, VP Housing Voucher Cluster Planned completion date for corrective action plan: September 30, 2023

Special Tests – Top of the Waiting List – Housing Voucher Cluster – Assistance Listing No. 14.871 Recommendation: We recommend that the Authority reviews their standard procedures to ensure requests for informal reviews are granted and notified to the applicant within 30 days of the receipt of the request. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Agency hired a dedicated Hearing Officer following last year’s audit. Unfortunately, during the period in question, the Hearing Officer went on maternity leave and then subsequently left the position resulting in a delay in completing hearings and reviews. The Agency has since contracted with a 3rd party to conduct hearings and reviews in a timely manner. Name(s) of the contact person(s) responsible for corrective action: Janie Anderson, VP Housing Voucher Cluster Planned completion date for corrective action plan: September 30, 2023

Finding 2023-003 Finding Summary: The Organization did not have adequate controls to document the review and approval of qualified invoices prior to payment. Responsible Individuals: CFO (Amanda Moon), CEO (Karen McCandless) Corrective Action Plan: Ensure that all invoices are approved as eligible program costs prior to issuing payment. Anticipated Completion Date: 7/1/2024

The University concurs with the auditors' finding. We are implementing measures to timely report student enrollment status changes to the National Student Loan Data System (“NSLDS”). The University of Alabama in Huntsville maintains records for each student’s enrollment status (full-time, three-quarter time, etc.) within our student information system. Each month, UAH transmits a data file containing updated enrollment statuses for all students to the National Student Clearinghouse (“Clearinghouse”). The Clearinghouse then reports the updated enrollment status to “NSLDS". Retirements of key personnel within the Registrar's Office impacted the ability to maintain consistent review of enrollment reporting. A new Registrar was hired on November 13. Additionally, a comprehensive procedural guide detailing the process for reviewing Clearinghouse errors and warning reports will be developed. This documentation will enable cross-training of other personnel to maintain the review process during staff absences or vacancies, upholding standardized practices and ensuring student enrollment status changes are reported timely. The University expects to complete this corrective action plan by December 2024. For follow-up questions or if you need any additional information, please feel free to contact, contact Patrick James, Associate VP for Student Affairs, at pgj0002@uah.edu who is responsible for this corrective action.

Corrective Action Plan Marygrove Nonprofit Housing Corp II, dba McGivney Bethune Apartments Project No. 044-EE011 Year Ended December 31, 2023 June 20, 2024 FEDERAL AWARD FINDINGS AND QUESTIONED COSTS 2023-001 – Eligibility - Tenant File Documentation Finding Type. Immaterial noncompliance; Significant deficiency in internal control over compliance (Eligibility) Federal programs U.S. Department of Housing and Urban Development  Supportive Housing for the Elderly (CFDA# 14.157) Condition. Out of a sample of 8 tenant files, it was noted: 1. One out of eight instances where a tenant EIV was not run within 90 days of move in; 2. One out of eight instances where a tenant's saving and checking accounts were not verified by a third party; 3. One out of eight instances where the incorrect balance was used to determine the tenant's checking account balance; 4. Two out of eight instances where a copy of the tenant's security deposit was not maintained in the tenant file; Effect. As a result of this condition, certain tenant files did not contain all required supporting documentation. Plan. Management agrees with finding 2023-001. All files are to be inspected in the current fiscal year to ensure compliance with HUD regulations. File maintenance will be competed following each move in and annual recertification. In addition to one-on-one training, the housing administrator has signed up for additional training including a WebEx on annual recertification and a basic EIV course. Additional training sessions are forthcoming. Contact Person Responsible for This Corrective Action: Laura Maisevich, Senior Housing Manager Anticipated completion date: June 30, 2024

CORRECTIVE ACTION PLAN Finding 2023-001 - Housing Choice Voucher Tenant File s - Eligibility - Int ernal Control over Tenant Files - Non compliance & Significant Deficiency - Housing Choice Voucher Program - ALN 14.871 CORRECTIVE ACTION PLAN: 1. All of Jonesboro HCV Specialists and HCV Manager took a Nan McKay Workshop, HCV and Public Housing Rent Calculation Course. The dates of this course were May 7, 2024 - May 9, 2024. 2. JHA has discussed the issues of the 13 files discovered during the audit and spoken to staff about making sure they know what to do. Additional training and discussion of the errors has been scheduled for next Wednesday, May 29, 2024. This was delayed due to JHA recently hiring a new full time HCV Specialist and JHA wanted to ensure all caseworkers were present and had proper training on the specific errors we incurred during the audit. 3. Peer Review - Janet Wiggins was the only one reviewing caseworker files. Janet reviews about 20 files per month. JHA has had discussion and will be expanding the number of files that are reviewed on a monthly basis. Janet Wiggins will still randomly select files as she has been doing, but each caseworker will also audit up to 5 random files from other caseworkers throughout the month to double the amount of files per month that are reviewed, which will also help us catch errors if they exist. PERSON RESPONSIBLE: N an M cKay / Paul G. Wright / Janet Wiggins ANTICIPATED COMPLETIO N DATE ( See Below ): 1. #l from above was Completed May 7, 2024 through May 9, 2024 by a Trainer from Nan McKay. 2. #2 was discussed in a staff meeting on May 29, 2024. I, Paul Wright, went over the 13 files with staff and discussed the importance of making sure that we ensure proper documentation is in the file whether full time status of children or EIV that is used to make a computation, we ensure that we are using the appropriate and proper amount of check stubs and that they are consecutive, we discussed making sure that our calculations themselves are correct if weekly, bi-weekly,monthly or annual income is used. We discussed making sure if working on a file that already has had an annual that we make sure any interim is inserted properly and we pay the correct amount on our HAP check run. 3. #3 was discussed during staff meeting on May 29, 2024 by Paul G. Wright and Janet Wiggins. I had previously spoken with HCV Manager, Janet Wiggins, and Assistant HCV Manager, Nora Schmidt, about increasing the number of files that we audit on a monthly basis. Janet examines each file when she performs a move or transfer, which is typically over 20 per month. All caseworkers will review 5 files per month from another caseworker for accuracy and make sure everything looks and is correct. This will about double the amount of files that are being reviewed on a monthly basis. This is being implemented currently and will continue moving forward. All the steps listed in the corrective action plan have been addressed and staff has been advised and trained. Peer review has begun and will continue moving forward to help increase the number of files that audited/ reviewed on a monthly basis. It is with these efforts that JHA hopes to reduce and hopefully eliminate the errors that we received during the 2023 Fiscal Year Audit.

The finding is a result of not correctly reviewing provided eligibility documents and ensuring the application corresponds to the documentation during the review process after the initial application was completed. To prevent this and other potential issues from happening in the future, the Corporation will conduct a review of all 2023-2024 student CACFP eligibility forms and applications to ensure the required eligibility documents match the selections made on the application. Staff will also verify that all applications are appropriately signed. This process will be included for future year eligibility calculations. Responsible Official: Paul Chapman, Chief Operating Officer Anticipated Implementation Date: July 2024

Auditor Description of Condition and Effect: Internal control procedures are required to ensure that the costs and activities are allowable under the grant. The County is required to have evidence that the costs and activities are reviewed and allowable. During our testing, all invoices tested did not have evidence they were reviewed to ensure they were for an allowable activity and cost. This condition is a result of the County not having tangible evidence that invoices are reviewed and in line with the allowable activities and costs of the grant. As a result of this condition, the County is exposed to an increased risk of having ineligible expenditures. Auditor Recommendation: The County should adjust their procedures to ensure there is tangible evidence expenditures are being reviewed to ensure they are in line with grant requirements. Corrective Action: We agree with the finding and will implement this procedure going forward.

Farmville Housing Authority Corrective Action Plan For the Year Ended September 30, 2023 Section II - Financial Statement Findings None Reported Section III - Federal Award Findings and Questioned Costs Finding 2023-001 Name of Contact Person: Wendy Ellis Executive Director Corrective Action: We will implement proper internal control procedures for the N/C S/R Section 8 program eligiblity requirements. Proposed Completion Date: Immediately

Management Response: Southeast Louisiana Legal Services Corporation has reviewed these concerns and is in agreement that it should obtain a signed retainer agreement and signed citizenship attestation form in accordance with the compliance requirements of the Legal Services Corporation. Corrective Action Plan To correct this problem, Southeast Louisiana Legal Services Corporation will require that all retainers and citizenship attestations be uploaded to the electronic case file in our case management system, Legal Server. Legal Server has the capability to send out retainers and citizenship attestations electronically to clients. These will automatically be uploaded to the e-signature log in the electronic client file. Hard copies of retainers with wet signatures can also be scanned and uploaded to the case management system. We will provide additional training to all staff on the requirement of obtaining retainers and citizenship attestations as well as how to send retainers and citizenship attestations electronically from Legal Server and how to upload scanned retainers and citizenship attestations to the case management system. The training will be recorded and circulated via email to all staff along with training materials. The training recording and materials will also be uploaded onto our internal “intranet” for all staff to access between quarterly training sessions. The training will also be incorporated into our adult learning management system. Contact Person Responsible for Corrective Action: Roxanne Newman, Deputy Director Southeast Louisiana Legal Services Corporation Ph. (985) 345-2130 x708 Anticipated Completion Date: Ongoing. Southeast Louisiana Legal Services Corporation already has written materials on how to send retainers electronically from Legal Server. We will develop additional written materials on how to send citizenship attestations from Legal Server and how to scan and upload retainers and citizenship attestations to Legal Server. Training materials will be completed by May 3, 2024 and training will take place on May 7, 2024 and be repeated quarterly on August 12, 2024; November 4, 2024; and February 10, 2025.

Finding 2023-003 – Reporting Cluster: Student Financial Assistance Federal Agency: Department of Education Assistance Listing Title and Number: 84.268 - Federal Direct Loan Program Award Year: Fiscal year 2023 Management concurs with the auditors’ finding. The academic year end date was reported incorrectly for Direct Loan borrowers enrolled in Law School. All affected records have been identified and were limited to students seeking professional degrees. All incorrectly reported dates have been corrected in the COD system as of June 13, 2024. Though the University had procedures in place to monitor the correctness of information submitted to the COD system, this error in one of our smallest student groups was overlooked during our office’s transition back to normal operations from COVID-19 procedures. To prevent a recurrence of this error, a separate review process will be added to our office workflow to annually ensure the accuracy of academic dates entered into the Banner student information system. Ronald Price, Associate Director, Student Financial Aid, Fiscal Operations and Loans of the University of Alabama (ronald.price@ua.edu), is responsible for implementing the corrective action planned. The University expects to complete this corrective action plan by July 31, 2024.

Finding 2023-002 – Timeliness of Enrollment Reporting Cluster: Student Financial Assistance Federal Agency: Department of Education Assistance Listing Title and Number: 84.268 - Federal Direct Loan Program Award Year: Fiscal year 2023 Management concurs with the auditors’ finding. The University began discussions with the National Student Clearinghouse (“Clearinghouse”) in February 2024 concerning graduation reporting, and changes have been made to the process of reporting student graduations. Per the recommendation of the Clearinghouse, a “Graduates Only” file will now be reported by the University in addition to the Clearinghouse’s “Degree Verify” files. Management has verified with the Clearinghouse that this change will eliminate the occurrence of records not being properly applied and provides easier identification and resolution of any errors. This new method of reporting was implemented on June 10, 2024, with the reporting of Spring 2024 graduates. For the remaining status change issues, management has collaborated with the Clearinghouse on the University’s schedule of future enrollment reporting submissions to prevent any further timing issues with NSLDS reporting. Daniel Strickland, Associate University Registrar (daniel@ua.edu) completed this corrective action plan on June 10, 2024.

Planned Corrective Action: The Seattle Indian Health Board has adopted a sliding fee program that provides discounts to eligible patients and Indian tribes. To address the auditors' concerns and further strengthen our internal controls, we are implementing a comprehensive corrective action plan. Firstly, we will ensure that all personnel involved in eligibility checks, including front desk staff and benefits specialists, are fully trained and aware of federal regulations and internal policies. This will be achieved through comprehensive training sessions and the development of a detailed training manual outlining eligibility criteria, documentation requirements, and procedural steps. Periodic refresher training sessions will reinforce adherence to these policies. Secondly, we will establish a robust internal audit system to regularly review and verify compliance with eligibility requirements. This includes integrating a monthly audit of eligibility determinations into the month-end reporting process, conducted by the clinical operations team. The clinical operations team will use a standardized checklist during these audits to ensure consistency and thoroughness. They will document findings and follow up on any issues or discrepancies with the relevant personnel to ensure timely corrections and adherence to procedures. Management believes that we have adequate internal control systems to safeguard the organization's assets and comply with federal and local regulations. However, we remain committed to further strengthening our controls and processes where necessary. Name of Responsible Party: Zecharias Mesgane, CMA, Director of FP&A Anticipated Completion Date: September 30, 2024

CORRECTIVE ACTION PLAN Oversight Agency for Audit: U.S. Department of Elementary and Secondary Education The Old Colony Regional Vocational Technical High School respectfully submits the following corrective action plan for the year ended June 30, 2023. Name and address of independent public accounting firm: Powers & Sullivan, LLC 100 Quannapowitt Parkway, Suite 101 Wakefield, MA 01880 Audit period: July 1, 2022 through June 30, 2023 The finding from the June 30, 2023, schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAMS AUDITS U.S. DEPARTMENT OF EDUCATION Passed through Massachusetts Department of Elementary and Secondary Education Special Education Cluster Special Education Grants to States – Federal Assistance Listing Number 84.027 2023-001 – Controls for Monitoring Payroll Charged to the Grant Views of Responsible Officials and Planned Corrective Actions: Management agrees with the findings and for the school year 2023-2024, the District will ensure that all payroll expenditures charged to the special education grant are supported with documentation regarding the eligibility of the employees paid out of the grant, as well as documentation that payroll charged to the grant was time spent on accomplishing grant objectives (i.e. time and effort certifications).

Finding 2023-002 – Preparation and Maintenance of Equipment Population The single audit report included the following recommendation: To address the Condition identified above, we recommend Amtrak to continue integration of the systems in such a way that appropriate funding source would be tagged to each asset automatically and that required property records would automatically be consolidated into one system of record and updated in that system. Ensure that adequate IT interface and business process application controls over the completeness, accuracy, validity, confidentiality, and availability of transactions and data during application processing (input, processing, output, etc.) are in place. Additionally, management should consider breaking out large purchase orders containing multiple items of equipment and tools under one purchase request, by creating separate level 2 WBSE codes in order to distinguish between different types of items being acquired, in order to be able to provide more appropriate classification. Identification as a repeat finding: Not a repeat finding Management Response/Status of Action Plans: Amtrak will implement the following to mitigate the finding related to the equipment population. 1. To prevent errors regarding the mapping of grant funding to equipment, the Capital Accounting Department will be implementing additional procedures and validations in the preparation and approval of the equipment review population file. This will include additional cross checks to validate mappings from fund sources to equipment and an additional review by EAMDT. The additional review and approval steps will be formalized with documented steps before September 2024. 2. To prevent errors related to missing asset numbers, the Capital Accounting Department, in coordination with EAMDT, has implemented an additional review of the single audit eligible indicator and inclusion of an asset unit number at the time the equipment asset is recorded in the fixed asset ledger. Additionally, EAMDT and Capital Accounting are now utilizing automated reporting that allows real time review of single audit equipment additions and data fields from the Company’s systems. This reporting allows for a timely view of key data fields from the related systems including Asset Equipment Description, Asset Unit Number, Single Audit Flag, Last Audit Date and Conditions. All equipment with missing asset unit numbers will be investigated and corrected. If any equipment marked as single audit eligible appears as not being eligible, Capital Accounting will investigate and resolve. The contacts for this item are Carol Hanna, VP Controller and Michele Millsaps, Assistant Controller, Capital and Inventory Accounting. Amtrak anticipates that changes above will remediate this finding in the fiscal year ending September 30, 2024 and beyond.