Corrective Action Plans

Finding Number: 2023-002 Planned Corrective Action: We are confident that our ESSER expenditures align with the allowable purposes and intents of the grant application that was submitted in the CCIP. We also stand by the integrity of our identification of expenses in total in the American Rescue Plan ESSER Federal Grant Program despite differences identified between grant years. The FER process and the reallocation of funds by grant year was confusing. However, as in the response above, we recognize the responsibility to adhere to the strict timelines was our responsibility. All ESSER funds have now been expended and we are confident they are allowable expenses per the guidelines provided. The Treasurer, Superintendent, and Federal Funds Coordinator agree to work more collaboratively to ensure our expenditures are within the grant timeframes prior to FER submissions. Anticipated Completion Date: 03/08/2024 Responsible Contact Person: Lance A. Erlwein, Treasurer

US Department of Housing and Urban Development Federal Financial Assistance Listing #14.157 Supportive Housing for the Elderly (Section 202) Finding Summary: As a result of management transition, supporting documentation for expense transactions and tenant eligibility were destroyed and were unable to be recreated. The organization was lacking appropriate internal controls to ensure records were retained for the required period of time. Responsible Individual: Dawn Helmowski, Finance Director Corrective Action Plan: Subsequent to the audit period under review, the affiliated entity of Luther Social Services of North Dakota has been replaced with Beyond Shelter, Inc. Upon this change, the new LSS Jamestown Housing, Inc. Board of Directors, implemented a Document Retention and Destruction Policy that includes retention or required documents for the required time periods that will ensure documents are retained. This policy was put into place on April 19, 2023. Anticipated Completion Date: April 2023

March 27, 2024 2023-002: Material Weakness in Internal Control/Material Noncompliance- Eligibility Condition: The Consortium did not provide documentation of eligibility for each participant selected for testing. Corrective Action: We agree with the finding. The consortium recognizes the importance of having support documentation for all eligibility determinations. During COVID-19 staff were allowed to work from home, as a result two staff were not following document saving protocol and saved vital documentation on their local drive (desktop). Upon the transition back into the office, those individuals did not follow protocol and ensure all files were backed up/saved to the networked database. Once of the individuals no longer worked for MWSE and the other employee as well as their manager both were made aware of the issue. After further conversations with the manager, management was assured this will not happen again. A process for spot checking and compliance sign-off by managers has been implemented to work to ensure this issue does not arise again. Contact Person: Shamar Herron: Sherron@mwse.org Anticipated Completion Date: Completed January 2024 Respectfully, Shamar Herron

Views of Responding Officials: The Department agrees with the finding and will implement corrective action. Corrective Action Taken or Planned: The Supplemental Nutrition and Assistance Program office has worked with Statewide Branch and Staff Development offices to address refresher training associated with budget calculations including the documentation and input of all data correctly. The Department is also in process of finalizing the new eligibility system – Benefit Eligibility Solution – slated to rollout statewide by late October 2024. As a condition of system rollout, all staff will be required to go through system training which will include a reinforcement of data entry practices and documentation requirements as a condition of eligibility determination. Expected Completion Date: October 31, 2024 Responding Officials: Ginet Hayes, Supplemental Nutrition and Assistance Administrator

Views of Responding Officials: The Department agrees with the finding and will implement corrective action. Corrective Action Taken or Planned: Fiscal Management Office will work with OIT to create a report to assist with reconciling the fiscal agent’s daily reports. Expected Completion Date: June 30, 2024 Responding Officials: Joey Wong, Fiscal Management Office Accountant

Views of Responding Officials: The Department agrees with the finding and will implement corrective action, however, notes the following: Letter dated April 29, 2022 was sent to ACF notifying of the temporary amendment to the Hawaii TANF State Plan, Part B, Section 10.1, suspending the interview requirement for TANF applications and annual recertification. The temporary suspension of the interview requirement aligned with the waiver granted by the Food and Nutrition Service for the Supplemental Nutrition Assistance Program (“SNAP”). The letter also informed ACF the interview requirement will resume for new TANF applications by July 31, 2022. No date was provided as to when the interview requirement will resume for annual recertifications. The Department received a letter dated May 9, 2022 from ACF that acknowledged the temporary amendment to the Hawaii TANF State Plan. A subsequent letter dated March 16, 2023 was sent to inform ACF that the suspended interview resumed for TANF applications effective July 1, 2022, however, will continue to be suspended for annual eligibility recertifications for TANF recipients. The Department received a letter dated March 29, 2023 from ACF that acknowledged the temporary State Plan amendment. A letter dated July 25, 2023 informed ACF that TANF will continue to align with SNAP and extend its suspended interview requirement for annual recertifications until May 31, 2024. The Department received a letter dated August 3, 2023 from ACF that acknowledged the extended temporary amendment to the State Plan. The Department did not need guidance from ACF on whether a particular action is allowable under program requirements. Pursuant to section 402 of the Social Security Act, ACF has the authority to determine whether a state’s TANF State Plan is complete but does not have the authority to approve or disapprove a plan. ACF acknowledged the temporary amendments made to the Hawaii TANF State Plan and expressed no concerns or determined that the temporary amendments were not allowable. Corrective Action Taken or Planned: No corrective action. The temporary amendment to the Hawaii TANF State Plan will end effective June 1, 2024, as noted in the July 25, 2023 letter to ACF. Expected Completion Date: Not applicable Responding Officials: Catherine Scardino, Temporary Assistance for Needy Families Program Administrator

Views of Responding Officials: The Department agrees with the finding and will implement corrective action. Hawaii implemented an upfront work participation requirement as a condition of eligibility for TANF applicants beginning 2009. The purpose of the upfront work participation is to prepare applicant families to engage in the TANF work program. Our state temporarily amended its TANF State Plan in response to the COVID 19 pandemic, suspending the upfront work participation requirements, described in Part B, section 15.1, effective March 27, 2020. This suspension coupled with relaxed administrative policies for all means-tested programs which included TANF, Supplemental Nutrition Assistance Program, and our state-funded General Assistance and Aid to the Aged, Blind and Disabled, and operational changes statewide allowed the Department to process applications expeditiously ensuring eligible families have access to their financial assistance benefits quickly. In March 2020, Hawaii’s unemployment rate was as low as 2.2% (seasonally adjusted) but it increased considerably to 22.6% in April 2020 following the state’s first shut-down due to the COVID 19 pandemic. The state’s TANF caseload increased by about 177%, from March 2020 with 3,969 recipient families to 7,040 families in December 2020 following the state’s second shut-down. While the upfront work program participation was suspended as a condition of eligibility for TANF applicants, Hawaii still required recipients to participate with the work program after they were determined eligible for TANF benefits. The good cause provision was exercised judiciously and to the extent allowable under TANF federal regulations and Hawaii administrative rules. Our TANF work program extended its services to provide families the opportunities to receive additional support such as case management and counseling services; to access information and referrals to community resources such as housing assistance and food distribution events; and to receive assistance in navigating through programs, benefits, and services that our department and other government agencies have available during this period of economic downturn resulting from the health emergency. It was not until March 25, 2022, when then Governor David Y. Ige ended the state’s emergency proclamation relating to COVID 19. The Department continued to suspend the upfront work participation requirements through May 31, 2023, allowing a transition period to adjustour operations. The upfront work participation requirement as a condition of eligibility was reinstated for families who applied for TANF financial assistance benefits beginning June 1, 2022, with only four months remaining in the fiscal year. Other administrative policies that were temporarily suspended or amended in response to the pandemic were reinstated effective July 1, 2022. The public health emergency and heightened period of COVID 19 restrictions forced the Benefit, Employment and Support Services Division (“BESSD”), who oversees the TANF and other means-tested public assistance programs, to immediately modify its operations statewide, ensuring the continuity of its programs and services and making them more accessible to the public. It was important to provide BESSD a transition period to review its policies and operational procedures and allow its staff of over 650 employees to adjust after two years of operating programs and services in a manner that was unprecedented for the division. On January 17, 2024, the TANF program office met with the Statewide Branch Administration (“SBA”), who oversees the state First To-Work (“FTW”) program staff, to discuss the concerns regarding the work participation rates, active TANF recipients who were referred to FTW but not yet participating in the program, and strategies to address the concerns. Subsequently, on January 25, 2024, SBA held a meeting with the state FTW unit supervisors to share the concerns raised on the work participation rates and to solicit comments and suggestions. TANF program administrator and lead program specialist were in attendance to notate comments and suggestions. Corrective Action Taken or Planned: Pursuant to 45 CFR 262.5, the Department requested consideration for reasonable cause from the Administration for Children and Families (“ACF”), for not meeting the two parent work participation rate for fiscal year 2022. Response and determination from ACF is pending. The FTW unit supervisors were instructed, during the January 25, 2024 meeting, to invite and schedule the active TANF recipients, who were referred but not yet participating, to attend a work program orientation as soon as possible. It is expected that remaining active TANF recipients will be invited to the FTW program by March 31, 2024. TANF program office is exploring the suggestions received during the January 25, 2024 meeting with SBA and FTW unit supervisors. For example, it was suggested that the FTW program provide additional supportive service payments to participants, who are in countable non employment related work activities, to incentivize them to maintain their program engagement. However, this suggestion has a fiscal impact and will require the FTW program administrative rules to be amended before it can be implemented. The TANF program office plans to require both parents of two parent households to participate in the FTW program. Due to capacity issues of both state and contract staff, only one parent is required to participate and meet work program requirements for the TANF recipient household. The TANF caseloads have declined; therefore, capacity is no longer a concern. Expected Completion Date: March 31, 2025 Responding Officials: Catherine Scardino, Temporary Assistance for Needy Families Program Administrator

Views of Responding Officials: The Department agrees with the finding and will implement corrective action. Corrective Action Taken or Planned: Subawards will be entered into the FSRS within the appropriate timeframe following the execution of the contract. Expected Completion Date: Not applicable as reporting of federal subawards is an ongoing requirement. Responding Officials: Catherine Scardino, Temporary Assistance for Needy Families Program Administrator

Views of Responding Officials: The Department agrees with the finding and will implement corrective action, however, notes the following: The referrals to the Child Support Enforcement Agency (“CSEA”) are done through an interface between the HAWI eligibility and CSEA’s KEIKI systems. When a recipient is determined noncompliant by CSEA, the information is sent via the interface from KEIKI to HAWI in the form of a system-generated alert. This process worked well when application processing and maintenance of recipient cases were done in a case management method (e.g., each eligibility worker assigned to process applications and/or maintain a caseload of active cases). Using this method, eligibility workers managed their caseloads and checked for incoming alerts for cases assigned to them; these alerts included the CSEA noncompliant alerts coming from the KEIKI system. Workers were able to take appropriate and timely action in response to the alerts received. However, necessary changes were made to how applications and active cases are managed. The division stopped the case management method and converted to “task-oriented” processing statewide. Workers are no longer assigned to caseloads but are assigned to “tasks” such as processing applications, incoming documents/verifications, reported changes, six month review and annual recertifications, etc. A case is not reviewed and worked in HAWI until a worker is prompted to do so, e.g., six-month review, annual recertification or a change was reported by the household. It is until such action occurs when an eligibility worker, who picks up the task, will check for alerts for the case. Aside from that, recipient cases will not be reviewed during their certification period. So how the “alerts” were developed in HAWI no longer works for the way we currently process applications and maintain recipient cases. We are unable to modify the HAWI system because we are currently developing a new eligibility system that will replace HAWI. The new eligibility system is scheduled to go into production in late 2024. Corrective Action Taken or Planned: As an interim solution until the new eligibility system rolls out into production, a shared folder is being created where CSEA will place the monthly reports of non cooperating TANF cases so designated TANF staff members, who are granted access to the shared folder, will be able to retrieve the reports. TANFPO will review the identified TANF cases. Individual lists will be forwarded to the Section Administrators to instruct the affected Processing Centers to take appropriate action (i.e., TANF case closure due to noncompliance with CSEA). Expected Completion Date: July 1, 2024 Responding Officials: Catherine Scardino, Temporary Assistance for Needy Families Program Administrator

Views of Responding Officials: The Department does not agree with this finding. According to 45 CFR section 205.55, it states, “…the State agency will request through the IEVS…”. However, the policy does not specify the State agency must “properly use IEVS information to evaluate benefit amounts…” as notated in this finding under “Effect.” Unless IEVS provides the necessary information for the applicable benefit month(s) used to determine a TANF applicant’s or recipient’s (“client”) eligibility, information obtained will only validate whether a household received an income source, after the fact, but will not verify the dollar amount. Hard-copy verification is obtained from the client to verify income source and dollar amount, for the applicable benefit months, to determine eligibility in accordance with §17 676 51, Hawaii Administrative Rules. For example, if a client applied for TANF on January 31, 2024, and the Department processes the application on February 29, 2024 (current month), verification of the household’s income received in January 2024 and received thus far in February 2024, must be obtained to determine eligibility for the month of application (January 2024) and subsequent months (based on projected income). Data obtained from IEVS are not current. For example, wage information through SWICA becomes available on a quarterly basis. The most current SWICA information available would have been for quarter ending December 31, 2023, for an application that was processed on February 29, 2024. Eligibility determination would have been improperly made if SWICA information was applied. Corrective Action Taken or Planned: The Department will continue to conduct IEVS check and utilize information obtained to determine eligibility if the information is applicable, otherwise, IEVS information will continue to be used to validate any source of income. Expected Completion Date: Ongoing Responding Officials: Catherine Scardino, Temporary Assistance for Needy Families Program Administrator

Views of Responding Officials: The Department agrees with the finding and will implement corrective action. Corrective Action Taken or Planned: 1. Child Welfare Service (“CWS”) staff will be informed of the audit findings, the importance of diligent compliance of policies and procedures, records maintenance and this corrective action plan. 2. Unit staff (Licensing, CWS, and FPPEU) who manage cases identified with errors in this audit will be retrained, ensuring familiarity with grant requirements and related policies and procedures. • Staff will be given coaching/supervisory support to correctly complete documentation. 3. Case specific audit findings and corrective action taken will be noted in each record where there was a finding. • Secure a copy of the missing modified guardianship/permanency assistance agreement, demonstrating support for the monthly assistance paid. • Document the qualifying need for Difficulty of Care (“DOC”) determination for the records, showing how DOC was calculated. • Investigate whether the child who attained the age of 14 was consulted regarding the kinship guardianship agreement. Discuss this with the youth and document. • Locate missing clearances or re run them if not located, placing note in record about audit re run. Note: Not all clearances are secured prior to placement; FBI clearances come later and are NOT required prior to placement in a “provisionally licensed” home. • Secure documentation for case regarding continuation of monthly subsidy payments after the child’s 18th birthday. 4. The identified errors and the related corrective action steps proposed above will be reviewed by CWS Administrators, staff supervisors, and the Management Information Compliance Unit (“MICU”) within 90 days to ensure missing documentation has been secured and/or properly noted in record. 5. MICU staff will audit records with findings to ensure errors have been documented and corrected. • MICU will work with Branch Administrators, Social Services Assistants (“SSA”), and program personnel to ensure file updates with completion of missing information. 6. As CWS implements this corrective action plan and monitors the results, the action steps proposed in 1 – 5 may be modified, based on input from CWS Administrators or exploration groups with line staff who complete this documentation. Expected Completion Date: May 31, 2024 and on-going Responding Officials: Kisha C. Raby, Social Services Division, Child Welfare Services Program Development Office, Administrator

Views of Responding Officials: The Department agrees with the finding and will implement corrective action; however, notes the following: Adoption Assistance is an incentive program with payment beginning prior to the finalization of an adoption. The adoption decree is not required for payment as the Adoption Assistance Agreement must be entered into prior to the finalization of an adoption. Corrective Action Taken or Planned: 1. Child Welfare Service (“CWS”) staff will be informed of the audit findings, the importance of diligent compliance of policies and procedures, records maintenance and this corrective action plan. 2. Unit staff (Licensing, CWS, and FPPEU) who manage cases identified with errors in this audit will be retrained, ensuring familiarity with grant requirements and related policies and procedures. • Staff will be given coaching/supervisory support to correctly complete documentation. 3. Case specific audit findings and corrective action taken will be noted in each record where there was a finding. • Research/review and document why licensing approval was granted to a household with an individual who was convicted of spousal abuse. i. If review determines that Adoption Assistance Agreement (“AAA”) was inappropriately authorized, provide family with an adverse action notice discontinuing the AAA and explaining the appeals process. • Investigate whether supporting documentation regarding whether the State determined that the child cannot or should not be returned to the home of his or her parents can be located and added to the record. • Secure a copy of the missing adoption decree, although adoption assistance is an incentive program with payment beginning prior to the finalization of an adoption. • Document the qualifying need for Difficulty of Care (“DOC”) determination for the records, showing how DOC was calculated. • Document how income eligibility was verified. • Secure missing modified adoption agreements. • Locate missing clearances or re run them if not located. Note: Not all clearances are secured prior to placement; FBI clearances come later and are NOT required prior to placement in a “provisionally licensed” home. 4. The identified errors and the related corrective action steps proposed above will be reviewed by CWS Administrators, staff supervisors, and the Management Information Compliance Unit (“MICU”) within 90 days to ensure missing documentation has been secured and/or properly noted in record. 5. MICU staff will audit records with findings to ensure errors have been documented and corrected. • MICU will work with Branch Administrators, Social Services Assistants (“SSA”), and program personnel to ensure file updates with completion of missing information. 6. As CWS implements this corrective action plan and monitors the results, the action steps proposed in 1 – 5 may be modified, based on input from CWS Administrators or exploration groups with line staff who complete this documentation. Expected Completion Date: May 31, 2024 and on going Responding Officials: Kisha C. Raby, Social Services Division, Child Welfare Services Program Development Office, Administrator, and Tonia Mahi, Social Services Division, Child Welfare Services Program Development Office, Assistant Branch Administrator

Views of Responding Officials: The Department agrees with the finding and will implement corrective action. Corrective Action Taken or Planned: 1. Child Welfare Service (“CWS”) staff will be informed of the audit findings, the importance of diligent compliance of policies and procedures, records maintenance and this corrective action plan. 2. Unit staff (Licensing, CWS, and FPPEU) who manage cases identified with errors in this audit will be retrained, ensuring familiarity with grant requirements and related policies and procedures. • Staff will be given coaching/supervisory support to correctly complete documentation. 3. Case specific audit findings and corrective action taken will be noted in each record where there was a finding. • Locate Police Protective Custody form, Voluntary Foster Custody Agreement, or other documentation which clarifies whether the child was removed as part of a voluntary placement agreement or judicial determination. • Locate missing clearances or re-run them if not located, placing note in record about audit re run. Note: Not all clearances are secured prior to placement; FBI clearances come later and are not required prior to placement in a “provisionally licensed” home. • Document the qualifying need for Difficulty of Care (“DOC”) determination for the records, showing how DOC was calculated. • Review resource caregiver licensing status and locate missing license or reissue license. • Investigate the case where the Judicial Determination was missing and therefore did not support the removal of the child was contrary to the welfare of the child, if the Department made reasonable efforts to prevent removal and finalize the permanency plan, and if the determination was within 60 days from removal. i. Locate court order documenting “contrary to welfare” language, verifying timelines, place in record and document findings. • Locate missing Imua Kakou minutes or secure additional documentation validating monthly meeting requirement was met. 4. The identified errors and the related corrective action steps proposed above will be reviewed by CWS Administrators, staff supervisors, and the Management Information Compliance Unit (“MICU”) within 90 days to ensure missing documentation has been secured and/or properly noted in record. 5. MICU staff will audit records with findings to ensure errors have been documented and corrected. • MICU will work with Branch Administrators, Social Services Assistants (“SSA”) and program personnel to ensure file updates with completion of missing information. 6. As CWS implements this corrective action plan and monitors the results, the action steps proposed in 1 – 5 may be modified, based on input from CWS Administrators or exploration groups with line staff who complete this documentation. Expected Completion Date: May 31, 2024 and on-going Responding Officials: Kisha C. Raby, Social Services Division, Child Welfare Services Program Development Office, Administrator

Ref. No. Compliance and Internal Control over Compliance Findings 2023-006 Allowable Costs – Significant Deficiency Recommendation We recommend the County follow their internal control process to ensure that adequate documentation supports the accumulation of costs charged to the Program as required by 2 CFR §200 Subpart E. View of Responsible Officials and Planned Corrective Action Management agrees with this finding. The Department of the Prosecuting Attorney’s office has reviewed and agreed a detailed line item report and Payment Request/Approval form did not accompany the respective RFF. The Department has already corrected these deficiencies to ensure each expense has an Expense Approval form with justification and that each RFF is accompanied with a detailed line item report and backup documentation for each expense being requested for reimbursement. Each payroll and non-payroll monthly invoices submitted clearly shows the breakdown. With each invoice submitted, it will state, as an example, “VOCA-SNAP 21-V2-01 Report & Attachments MM/YY”. A sample of this was submitted on March 25, 2024 with response. In short, the necessary back-up requested going forward is and will be available to submit for future audits or reviews. Anticipated Completion Date: 3/27/2024 Responding Person(s): Robert Nadal Grant Management Specialist Phone No. 808-270-7608

St. Francis School District has taken steps to ensure all transactions expensed to district funds including federal and state funds are properly reviewed by appropriate parties with knowledge of allowable costs and the specific expense incurred. Prior to Items being purchased with grant funds all requests are to be approved by the budget manager who oversees the specific funds. Orders may only be placed once approval is received from the budget manager and the Director of Finance. Payment of an invoice is not to be made until service has been rendered complete or item has been received in full. Budget managers approve all invoices prior to Director of Finance reviewing for final approval of payment.

April 1, 2024 Finding Number 50000 (2023-001) Noncompliance and Internal Control over Federal Compliance Federal Program – Child Care and Development Fund Cluster – Assistance Listing 93.575 and 93.576, Federal Alternative Payment Corrective Action Plan: Anticipated Completion Date April 30, 2024 Prior to Mono County Office of Education (MCOE) taking over this program, another agency was responsible for the original eligibility determinations and special tests and provisions, including the files selected for this audit. After discussion about the audit findings, MCOE investigated further, and it was noted that the staff at the time were not following the procedures and forms that were in place. Items were either not completed or filled out correctly in many instances. Since this discovery, MCOE has developed a corrective action plan as follows to adhere to the program’s requirements: • MCOE will ensure that existing and new staff are trained to adhere to the policies and procedures for the program. • MCOE will be conducting annual reviews of all service providers and children served to ensure MCOE is maintaining the required documents on file. • MCOE has developed a double-check procedure to ensure that staff is keeping the required documentation on file for both providers and children served moving forward. I, Jennifer Weston, CBO, will be responsible for the implementation and monitoring of the corrective action plan. Sincerely, Jennifer Weston Chief Business Officer Mono County Office of Education

Finding No. 2023-013 Department(s): New York City Administration for Children’s Services and New York City Human Resources Administration Program(s): Assistance Listing Number 93.575, Child Care and Development Block Grant Corrective Action(s): ACS: ACS will work with other agencies to promote compliance and internal controls going forward. HRA: In response to the findings, HRA made the following training requests to address the specific findings identified in this audit: 1. Training ID 2344 - Childcare liaisons and Childcare Review Team (CCRT) require training for the appropriate documentation necessary for the approval and provision of childcare. Audit findings confirmed that the staff charged with approval and authorizing childcare will take refresher training about the appropriate documentation requirements (i.e., CS-274w, LDSS 4699, LDSS 4700, etc.). The training will emphasize the requirement that any approved childcare must have support underlying employment/education documentation to justify the provision of the childcare. Childcare is a supportive service, so any childcare must have employment/engagement/education as a condition precedent. 2. Training ID 2343 - The training will include information about the client's employment, rate of pay, frequency of pay, and getting the appropriate documentation into the case records. Audits confirmed that 1) when the agency budgeted income and approved supportive services (i.e., childcare), the record did not have supporting income and employment related documents; 2) training will include the process for budgeting the earned income and applied any earned income disregards. Anticipated Completion Date: April 2024 and ongoing Person(s) Responsible for Implementation: ACS: Rahel Getachew, Associate Commissioner (212)-676-8818. HRA: Ramon E. Flores, Deputy Commissioner, Family Independence Administration (FIA) floresra@hra.nyc.gov

Finding No. 2023-016 Department(s): New York City Housing Preservation & Development Program(s): Assistance Listing Number 14.871, Housing Voucher Cluster: Section 8 Housing Choice Vouchers Corrective Action(s): During the pandemic, HPD adopted HUD CARES Act waivers, intended to minimize health and safety risks to applicants, participants, owners and staff, and which included the temporary suspension of adverse actions. Although HPD continued to request recertification packages during the period of the waivers until today, from February 2020 through December 2021, HPD did not penalize families who did not submit complete recertification packages. Additionally, HPD is among the City agencies that experienced a staff retention crisis, with attrition rates among its Rental Subsidy Program administrative teams swelling from 12 percent in 2020 to 27 percent in 2022. During the audit period, HPD was experiencing its highest vacancy rate. This meant standard recertifications were delayed because participants did not respond to recertification packages they were asked to complete, HPD did not have the capacity to revoke subsidies for those who did not comply, and the agency had significant backlog as a result of staff vacancies. Though HPD’s vacancy rate improved, it takes significant time to train and prepare staff to do the work. Finally, even though HPD’s COVID-era policies involving adverse action have ceased and normal processes are now in effect, due process requires intensive tracking and follow up to ideally have participants comply with requirements but if necessary to terminate assistance for those who do not comply. Therefore, there will be a significant lag between the re-implementation of HPD’s policy to take enforcement actions when recertification packages are not completed or missing and HPD’s actually terminating assistance. Corrective Action(s): 1. Build on existing systems to more closely track recertifications that are mailed and not returned. 2. Develop more robust digital operations that were started during the pandemic leading to reporting capabilities that will help with tracking overdue recertifications. 3. Work more closely with Community Based Organizations that can assist participants complete and return recertification package. 4. Continue close coordination to implement the Housing Access and Stability staffing plan and identify priority hires to onboard critically needed staff timely. 5. Invest in a training team to meet the training needs of new staff. Anticipated Completion Date: April 2025 Person(s) Responsible for Implementation: Dinsiri Fikru, Assistant Commissioner, Division of Program Policy and Innovation, Office of Housing Access and Stability FIKRUD@hpd.nyc.gov

Finding No. 2023-015 Department(s): New York City Housing Preservation & Development Program(s): Assistance Listing Numbers: 14.249, Section 8 Project-Based Cluster: Section 8 Moderate Rehabilitation Single Room Occupancy 14.856, Section 8 Project-Based Cluster: Lower Income Housing Assistance Program – Section 8 Moderate Rehabilitation Corrective Action(s): These deficiencies result from HPD adopting HUD CARES Act waivers, intended to minimize health and safety risks to applicants, participants, owners and staff, and which included the temporary suspension of inspections and adverse actions. HPD conducted limited inspections and did not take enforcement action during the waiver period of 2/1/2020 through 12/31/2021. These waivers ended in 2022 in the midst of a significant HPD staffing shortage. HPD is among the City agencies that experienced a staff retention crisis, with attrition rates among its Housing Maintenance Code inspection team that mirrored the 27 percent experienced in HPD’s rental subsidy program administration team. Although HPD’s COVID-era policies have ceased, and normal processes are now in effect, it will take a significant period of time for full standard operations to resume. Corrective Action(s): 1. Develop a detailed tracking process for routine inspection scheduling. 2. Prioritize inspections for units that are upcoming or those that have gone the longest without an inspection. 3. Develop a detailed tracking and follow up process for enforcing failed inspections. 4. Make every effort to ensure staff vacancy rates are addressed through in house recruitment or other means as needed. Anticipated Completion Date: April 2025 Person(s) Responsible for Implementation: Dinsiri Fikru, Assistant Commissioner, Division of Program Policy and Innovation, Office of Housing Access and Stability FIKRUD@hpd.nyc.gov

Finding No. 2023-014 Department(s): New York City Housing Preservation & Development Program(s): Assistance Listing Numbers: 14.249, Section 8 Project-Based Cluster: Section 8 Moderate Rehabilitation Single Room Occupancy 14.856, Section 8 Project-Based Cluster: Lower Income Housing Assistance Program – Section 8 Moderate Rehabilitation Corrective Action(s): During the pandemic, HPD adopted HUD CARES Act waivers, intended to minimize health and safety risks to applicants, participants, owners and staff, and which included the temporary suspension of adverse actions. Although HPD continued to request recertification packages during the period the waivers, February 2020 through December 2021, HPD did not penalize families who did not submit complete recertification packages at that time until more recently. Additionally, HPD is among the City agencies that experienced a staff retention crisis, with attrition rates among its Rental Subsidy Program administrative teams swelling from 12 percent in 2020 to 27 percent in 2022. During the audit period, HPD was experiencing its highest vacancy rate. This meant standard recertifications were delayed because participants did not respond to recertification packages they were asked to complete, HPD did not have the capacity to revoke subsidies for those who did not comply, and the agency had significant backlog as a result of staff vacancies. Though HPD’s vacancy rate improved, it takes significant time to train and prepare staff to do the work. Finally, even though HPD’s COVID-era policies involving adverse action have ceased and normal processes are now in effect, due process requires intensive tracking and follow-up to ideally have participants comply with requirements (but if necessary to terminate assistance for those who do not comply). Therefore, there will be a significant lag between the re-implementation of HPD’s policy to take enforcement actions when recertification packages are not completed or missing and HPD’s actually terminating assistance. Corrective Action(s): 1. Build on existing systems to more closely track recertifications that are mailed and not returned. 2. Develop more robust digital operations that were started during the pandemic leading to reporting capabilities that will help with tracking overdue recertifications. 3. Work more closely with Community Based Organizations that can assist participants complete and return recertification package. 4. Continue close coordination to implement the Housing Access and Stability staffing plan and identify priority hires to onboard critically needed staff timely. 5. Invest in a training team to meet the training needs of new staff. Anticipated Completion Date: April 2025 Person(s) Responsible for Implementation: Dinsiri Fikru, Assistant Commissioner, Division of Program Policy and Innovation, Office of Housing Access and Stability FIKRUD@hpd.nyc.gov

Finding No. 2023-002 Department(s): New York City Human Resources Administration Program(s): Assistance Listing Number 14.239, HOME Investment Partnerships Program Corrective Action(s): This FY23 audit was conducted on the heels of the FY22 audit where the questioned cost finding is a similar error type but significantly decreased to $296 from over $18,000. Included in the FY22 recommended Corrective Action was the onboarding of the Executive Director to shepherd the charge with strengthening the teams’ internal governance, appropriate monitoring and future compliance. Adversely, the onboarding of the executive director was lengthy and only recently finalized in the 2nd quarter of FY24. HRA agrees to strengthen internal controls and the new Executive Director is working with the team to ensure they are intentional in appropriately applying the correct formula for calculating allowable cost, particularly the inclusion of “gross” and not “net” income. The Quality Assurance Tool has been updated including specific sub-items to ensure allowable cost is correctly calculated as well as the other deliverables. Corrective Action(s) • Strengthen internal governance and future compliance. • Executive Director for the Home-TBRA now on board. • Update the Quality Assurance tool that includes sub-items information that supports improved review and approval. • Provide refresher training for staff involved with TBRA to improve performance and outcomes. Anticipated Completion Date: June 30, 2024 and ongoing Person(s) Responsible for Implementation: Dori Hopkins-Figeroux, Director - HTBRA hopkinsfigerouxd@hra.nyc.gov 929-252-6089 Jordan Worrell, Executive Director RAP/HTBRA worrellj@hra.nyc.gov 929-252- 5403 Dwana Abraham, Assistant Deputy Commissioner abrahamd@hra.nyc.gov 929-221-6726

University of Maryland Medical System Corporation and Subsidiaries Corrective Action Plan Year Ended June 30, 2023 University of Maryland Medical System Corporation and Subsidiaries (the Corporation) respectfully submits the following corrective action plan for the year ended June 30,2023. Audit period: July 1, 2022 to June 30, 2023 MATERIAL WEAKNESS IN INTERNAL CONTROL OVER COMPLIANCE 2023-002 Reporting of Schedule of Expenditures of Federal Awards Assistance Listing Number 97.036 – COVID-19 – Disaster Grants – Public Assistances (Presidentially Declared Disasters) Recommendation: The Corporation’s policy and procedures should be designed to ensure expenditures are reported on the Schedule based on the date on which the expenditures are incurred as required by the Uniform Guidance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: Management will continue to refine internal procedures and practices. The COVID-19 pandemic grant programs included evolving expectations which did not follow the typical grant process. We will enhance procedures to review related report submissions, obligated worksheets, and incurred expenditures in conjunction with review of the Schedule to verify completeness and accuracy. Planned completion date for corrective action plan: September 30, 2024 Name(s) of the contact person(s) responsible for corrective action: Jeff Chadwick, Financial Reporting Director, jeff.chadwick@umm.edu

Finding 2023-003 Finding Summary: Management is responsible for establishing and maintaining an effective system of internal control over financial reporting. Ensuring accruals and expenses are recorded in the appropriate time period and meet the criteria for recognition is a key component of effective internal control over financial reporting. Certain expenses were not recorded in the correct financial reporting period. Responsible Individuals: Mike Maxfield, Controller Corrective Action Plan: Acknowledged. Payroll accruals, which have in the past been immaterial, are being accrued on a monthly basis in fiscal year ending June 30, 2024. Anticipated Completion Date: Ongoing

Finding 2023-002 Finding Summary: Internal controls should be in place to provide reasonable assurance that protects iFoster, Inc. from errors or omissions. iFoster, Inc. internal control system did not require consistent approval of grant expenditures as well as properly allocating costs within the accounting program. Responsible Individuals: Mike Maxfield, Controller Corrective Action Plan: Acknowledged. Due to the compressed timeframe between initial single audits, corrective action could not be implemented. All grant expenditures now require approval and QuickBooks will be used to allocate costs in fiscal year ending June 30, 2024 rather than using Excel. Anticipated Completion Date: April 20, 2024

Finding 2023-001 Finding Summary: Management is responsible for establishing and maintaining an effective system of internal control over financial statement reporting. One of the components of an effective system of internal control over financial reporting is the preparation of full disclosure financial statements that do not require adjustment as part of the audit process. A second component is that reconciliations and transactions are properly reviewed and approved by the appropriate personnel. As auditors, we were requested to draft the financial statements and accompanying notes to the financial statements. Certain reconciliations and journal entries were not reviewed and approved. Responsible Individuals: Mike Maxfield, Controller Corrective Action Plan: Acknowledged. Due to the compressed timeframe between initial single audits, corrective action could not be implemented. All journal entries are now approved as a part of our month end close process. Although we anticipate the auditor to continue to prepare the financial statements, we believe addressing the internal control noted above will address any material errors noted. Anticipated Completion Date: Ongoing