Corrective Action Plans

FEDERAL AWARD PROGRAMS AUDIT FINDING Material Weakness in Internal Control over Compliance Finding (2022-003) Recommendation: We recommend the Association continue to design and implement controls, including levels of review, to ensure reporting is prepared using accurate financial information and in accordance with reporting requirements. Planned Corrective Action: The Association will ensure the appropriate grouping of Medicaid supplemental payments when calculating Total Revenue/Net Charges from patient care. One of the supplemental payments is related to the hospital's eligibility to receive the associated payment under the Medicaid Rural Disproportionate Share Hospital (ROSH) Program or the Rural Financial Assistance Program (RFAP). The RFAP is based upon a fixed sum of money. Therefore, the annual RFAP distribution received by a hospital represents an amount proportional to the hospital's contribution for providing indigent and Medicaid care as compared to all other RFAP eligible rural hospitals and is calculated in accordance with Florida statute. In addition, the Directed Payment Program (OPP}, as approved by the Florida legislature in 2021, provides funding for hospitals that provide inpatient and outpatient services to Medicaid managed care enrollees. This program is intended to address the shortfall to hospitals by collecting Intergovernmental Transfers (IGTs) and Local Provider assessments (LP) to draw down Federal Medicaid Matching dollars.

FINDING 2022-003 Finding Subject: COVID-19 - Education Stabilization Fund - Reporting Summary of Finding: An effective internal control system was not designed, nor implemented at the School Corporation to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirements. The annual Elementary and Secondary School Emergency Relief (ESSER) Data Collection reports were complied, prepared and submitted by three different staff members; however, this process was not properly designed or implemented to prevent, or detect and correct, errors. The School Corporation completed and submitted three annual Data Collection reports (Reports) for the ESSER grants. For two of the three reports tested, the report was not supported by the unit’s records. The financial information provided did not agree to the data submitted in the Reports, therefore we could not determine their accuracy. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Contact Person Responsible for Corrective Action: Matthew Miles, CFO Contact Phone Number and Email Address: 317-423-8380 mattmiles@msdlt.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The School District will work to ensure the ESSER report amounts tie to the accounting records and will improved record keeping of supporting documentation. If the amounts do not match, District will document support for all claims. Anticipated Completion Date: The School District will implement changes described in the Corrective Action Plan in February 2024.

The organization has implemented controls in the subsequent period to make sure that the financials records are closed, reviewed and incomplaince with U,S GAAP.

Material Weakness in Internal Control over Compliance: See findings 2022-2, 2022-3, 2022-4, 2022-5, 2022-6, 2022-7, 2022-9, 2022-10

Material Weaknesses in Internal Control over Compliance: See findings 2022-2, 2022-3, 2022-4, 2022-5, 2022-7, and 2022-9

2022-004 Noncash Federal Awards Criteria: Organizations are responsible for adjusting their financial statements, including recording grant related noncash contributed capital assets. Condition/Context: During the audit process, we noted the contributed capital for noncash federal awards was not recorded as revenue. We consider the deficiency described to be a material weakness. Corrective Action Plan: The District will review the project status for IDOT projects at least annually and record the capital asset additions and related contributed capital revenue. Contact Person Responsible for Corrective Action: Edith Guerrero Administrative Director Waukegan National Airport 2601 Plane Rest Drive Waukegan, IL 60087 (847) 244-0055 eguerrero@waukeganport.com Anticipated Completion Date: Changes have either already been instituted or will be instituted immediately.

The finding was corrected. The payer of the Concessionaire, which has access to the system, was appointed. According to internal procedure, she does not issue payments until she is sure that the account has a budget.

The Municipality's Finance Department staff will be instructed to safeguard properly, all the fiscal supporting documents related to the disbursement process. In addition, we will improve our procedures and internal control controls over the filing and safeguarding of documents, payment vouchers and all related supporting documentation of the disbursement cycle.

Views of responsible officials and planned corrective action: The Authority experienced significant turnover in employees during the year and as a result certain processes were not followed and source documents were misplaced or destroyed. Management agrees with the Auditors' finding and has hired a new Executive Director who will implement the required safeguards and ensure that the Authority follows it’s the Regulatory Agreements related to the Mortgage Insurance for the Purchase or Refinancing of Existing Multifamily Projects and the HUD compliance requirements to remedy the aforementioned deficiencies. Leonard Spicer, Executive Director, is responsible for implementing this corrective action by December 31, 2023.

Views of responsible officials and planned corrective action: The Authority experienced significant turnover in employees during the year and as a result certain processes were not followed and source documents were misplaced or destroyed. Management agrees with the Auditors' finding and has hired a new Executive Director who will implement the required safeguards and ensure that the Authority follows its Section 8 Administrative Plan and the HUD compliance requirements to remedy the aforementioned deficiencies. Leonard Spicer, Executive Director, is responsible for implementing this corrective action by December 31, 2023.

Reference Number 2022-004, 2022-005, and 2022-006 Finding summary: These three findings all related to specific provider relief fund reporting of lost revenues by the Medical Center. The Medical Center experienced turnover in key accounting staff during the start of 2023 which resulted in the updated option iii reporting for lost revenues. To be modified. The current staff modified the method of calculating loss revenues from the Phase 1 reporting and were unaware of the potential impact on previously reported funding. Errors were also noted in the accumulation of data and in the reporting which was due to inadequate control processes surrounding the review and approval of the computation by someone independent of the calculation process. Corrective Action Plan: We do not anticipate having to complete a future provider relief fund reporting submission. However, for any future federal grant reporting requirements we will implement a process to have an independent individual review the reporting information along with supporting documentation prior to submission of the grant reporting form. The independent review will be documented in writing as to the date and time of the review and approval. Anticipated Completion Date: This will be implemented with the next federal grant reporting.

Reference Number 2022-004, 2022-005, and 2022-006 Finding summary: These three findings all related to specific provider relief fund reporting of lost revenues by the Medical Center. The Medical Center experienced turnover in key accounting staff during the start of 2023 which resulted in the updated option iii reporting for lost revenues. To be modified. The current staff modified the method of calculating loss revenues from the Phase 1 reporting and were unaware of the potential impact on previously reported funding. Errors were also noted in the accumulation of data and in the reporting which was due to inadequate control processes surrounding the review and approval of the computation by someone independent of the calculation process. Corrective Action Plan: We do not anticipate having to complete a future provider relief fund reporting submission. However, for any future federal grant reporting requirements we will implement a process to have an independent individual review the reporting information along with supporting documentation prior to submission of the grant reporting form. The independent review will be documented in writing as to the date and time of the review and approval. Anticipated Completion Date: This will be implemented with the next federal grant reporting.

Reference Number 2022-004, 2022-005, and 2022-006 Finding summary: These three findings all related to specific provider relief fund reporting of lost revenues by the Medical Center. The Medical Center experienced turnover in key accounting staff during the start of 2023 which resulted in the updated option iii reporting for lost revenues. To be modified. The current staff modified the method of calculating loss revenues from the Phase 1 reporting and were unaware of the potential impact on previously reported funding. Errors were also noted in the accumulation of data and in the reporting which was due to inadequate control processes surrounding the review and approval of the computation by someone independent of the calculation process. Corrective Action Plan: We do not anticipate having to complete a future provider relief fund reporting submission. However, for any future federal grant reporting requirements we will implement a process to have an independent individual review the reporting information along with supporting documentation prior to submission of the grant reporting form. The independent review will be documented in writing as to the date and time of the review and approval. Anticipated Completion Date: This will be implemented with the next federal grant reporting.

Statement of Condition: The Department of Health and Human Services Appropriations Act 2022 restricts the amount of salary to Executive Level II of the Federal Executive pay scale for a full time 12 months total compensation for the grant period from March 2022 to February 2023. Correction Action Planned for 2022-006: The salary of our executive director has consistently adhered to established limits, and our Program and Director of Finance, underscoring the effectiveness of our internal controls, swiftly identified any anomaly. Anticipated Completion Date June 2023

Statement of Condition: The Municipality’s disbursement test, we tested 113 vouchers and found 2 disbursements without System Award Management number or not active. Correction Action Planned for 2022-005: To forestall similar situations in the future, we are actively reviewing and fortifying our supplier’s selection processes while implementing robust contractual measures. It is important to underscore that this response was an exceptional one to address non-compliance, and we are steadfast in our commitment to avoiding such occurrences in the future. Anticipated Completion Date JUNE 2023

Statement of Condition: The Municipality did not submit the required Financial Reports to the US Housing and Urban Development of fiscal year ending June 30, 2022, during the required period. The unaudited Financial Report was not submitted on or before August 31, 2022, also, the audited Financial Report was not submitted on or before September 30, 2022. Correction Action Planned for 2022-004: For the upcoming fiscal year, we are actively seeking a company to provide guidance and assistance in reporting issuance, aiming to streamline and address these processes effectively. Anticipated Completion Date JUNE 2023

Statement of Condition: Preliminary Financial reports and programs financial information were available on August 22, 2023, to prepare the Single Audit Reporting Package. Correction Action Planned for 2022-003: We are actively seeking a company to provide guidance and assistance in report issuance, aiming to streamline and address these processes effectively. Anticipated Completion Date JUNE 2023

Finding 2022-065: Reporting. The Nevada Division of Public and Behavioral Health (DPBH) did not maintain underlying documentation to support the amounts reported in annual and midyear Performance Progress Reports (PPR). Nevada Division of Public and Behavioral Health response: The Nevada Division of Public and Behavioral Health accepts this finding and will initiate corrective action as described below. Corrective Action: The Bureau of Behavioral Health, Wellness, and Prevention (BBHWP) developed a document retention system to ensure subgrantee grant reports and supporting documentation is saved and is easily accessible for each award period. This new system will remove unnecessary barriers for accessing reports moving forward. Date of Completion: BBHWP: December 2023 Responsible Party: BBHWP State Opioid Response Unit: Breanne Van Dyne, Health Program Manager II If you have any questions, please contact Kitty DeSocio, Administrative Services Officer IV at 775-684-3481 or by email at kdesocio@health.nv.gov.

Program: U.S. Department of Health and Human Services Children’s Health Insurance Program (CHIP), 93.767 Eligibility Material Weakness in Internal Control over Compliance Finding Number: 22-059 Finding: Individuals were deemed eligible but were placed in an incorrect aid category or did not have supporting documentation available for review. Individuals may receive benefits that they are not entitled to or not receive benefits for which they are entitled to. The Division did not have adequate internal controls to ensure aid categories were accurate or applications for CHIP were maintained. Prior year finding 2021-056. Corrective Action Taken: HOH UPI XXXXX2000/CHILD UPI XXXXX9100 – Worker failed to complete re-evaluation for higher aid code (REHA function) to obtain correct eligibility. Corrective Action: REHA function was completed on 9/27/2021 to obtain correct eligibility. HOH UPI XXXXX6100/CHILD UPI XXXXX6100 – The Division of Welfare and Supportive Services (Division) did not have adequate internal controls to maintain supporting documentation available for review. Corrective Action: The Division has revised scanning procedures across the state, which includes routing more documents to our vendor for scanning, rather than being retained in each district office. The Division also utilizes an internal team, Records Management Unit (RMU), that assists with Quality Assurance of all scanned documents. HOH UPI XXXXX8000/CHILD UPI XXXXX3200 – The Division did not have adequate internal controls to maintain supporting documentation available for review. Corrective Action: The Division has revised scanning procedures across the state, which includes routing more documents to our vendor for scanning, rather than being retained in each district office. The Division also utilizes an internal team, Records Management Unit (RMU), that assists with Quality Assurance of all scanned documents. Future Corrective Action: The Division will collaborate with all appropriate parties to move from an annual mandatory REHA training to a semiannual mandatory REHA training (every 6 months), for field staff. A new Quality Assurance tip to field staff was provided on 11/10/2022 and an updated mandatory REHA training was administered with a required completion date for all field staff of 02/2023. The next REHA training is scheduled for January/February of 2024. The Division will also continue to follow the updated process for scanning of documents and utilize the RMU for increased Quality Assurance of documents. The Eligibility and Payments (E&P) and Program Operations, Support & Targeted Outreach (POST) teams will work closely with the Internal Controls and Audit team within the Division to ensure internal controls are strengthened. The Division anticipates the internal controls to be updated within two months to reflect the release of a semi-annual REHA training, along with a new annual Quality Assurance REHA tip. Agency Response Does the Agency agree With the findings: Yes If No or Partial, please explain reason(s) why: N/A Individual Responsible for Corrective Action Plan: Name, Title: Tonya Stevens, Social Services Chief III, Eligibility and Payments Phone Number: 775-684-0553 Email: tstevens@dwss.nv.gov Name, Title: Shelly Aguilar, Social Services Chief III, Program Operations, Support & Targeted Outreach Phone Number: 702-631-2337 Email: saguilar@dwss.nv.gov Reviewed and Approved Tonya Stevens, Chief III, Eligibility and Payments

Program: U.S. Department of Health and Human Services Foster Care - Title IV-E, CFDA 93.658 Corrective Action Plan Finding Number: 2022-057 Finding: Required subaward information was not reported in the FFATA Subaward Reporting System (FSRS). Corrective Action Taken or To Be Taken: Internal controls have been reviewed and updated to ensure subaward information is submitted in accordance with FFATA. If already taken, date of completion: Internal control updated in SFY23. If to be taken, estimated date of completion: Agency Response Does the Agency agree with this finding? The Nevada Division of Child and Family Services agrees with this finding. If no or partial, please explain reason(s) why: Additional comments: Prior year finding 2021-055 Division Responsible for Corrective Action Name, Title: Kelsey McCann-Navarro, Social Services Chief III Address: 4126 Techonology Way City, State, Zip Code: Carson City, NV 89706 Phone Number: 775-684-4431 Email: kelsey.navarro@dcfs.nv.gov Reviewed and Approved Tiffany Greenameyer, Deputy Administrator

Audit Finding: 2022-051 Low-Income Home Energy Assistance: 93.568 Reporting Material Weakness in Internal Control over Compliance and Material Noncompliance Summary: Required subaward information was not reported per the Federal Funding Accountability and Transparency Act (FFATA). FFATA requires direct recipients of certain federal awards to report subaward information by the end of the month following the month in which the prime awardee obligates a subgrant award equal to $30,000. Recommendation: Implement internal controls to ensure subaward information is submitted in accordance with FFATA. Agency Response: The Nevada Housing Division (“Division”) agrees with the finding. The Division also acknowledges this is a prior year finding. The Division would like to note, and be given consideration for, the substantive fact of the context of the time period in a pandemic, a once in a lifetime crisis that was impacting daily work and personal lives of all Nevadans, including Division staff. Corrective Action: The Division will establish an internal audit and compliance committee to enhance oversight of existing policies for assessing risk (which include verifying suspension or debarment), monitoring and sharing best practices across its business. The internal audit and compliance committee will be responsible for reviewing internal controls and policies on an annual basis, following up on any audit findings and ensuring follow-through of corrective action plans. Adoption of Corrective Action: January 2024 Division Contact and Corrective Action Plan Lead: Christine Hess, Chief Financial Officer Nevada Housing Division 775-687-2249 chess@housing.nv.gov

U.S. Department of Health and Human Services Low Income Home Energy Assistance, 93.568 Finding Number: 2022-048 – Eligibility Material Weakness in Internal Control over Compliance Finding: Supervisor case reviews were not performed in accordance with the State Plan. Corrective Action Taken or To Be Taken: During the review period there were vacancies in both supervisory positions in the Energy Assistance Program. The Division filled these positions during the review period. The supervisory case reviews began for July 2022. In addition, the LIHEAP State Plan has been amended to allow additional staff members to review case work for new staff. The changes were approved at the June 29, 2023, Public Hearing. These changes have been included in the FFY 2024 LIHEAP State Plan to address staff shortages if they arise again. If to be taken, estimated date of completion Corrective Actions are already in place. Agency Response Does the Agency agree with finding: Yes X No Partially Individual Responsible for Corrective Action Plan: Name, Title: Maria Wortman-Meshberger, Chief Employment and Support Services Phone Number: 775-684-0506 Email: mrwortman@dwss.nv.gov Reviewed and Approved Robert H. Thompson, Administrator Date December 19, 2023

Finding number: 2022-050 – Reporting Material Weakness in Internal Control over Compliance Finding: The projected unobligated balance (carryover amount) did not agree to the underlying actual unobligated balance and there was no underlying documentation or support to support the variance. Corrective Action Taken or To Be Taken: Due to multiple staff vacancies, a written procedure for the reporting of Carryover Funds was delayed. Upon completion of those updated procedures in August 2023 in response to prior finding 2021-048, the reporting process for the projected unobligated balance is better understood and the tighter internal controls will ensure adequate documentation and review as required. If to be taken, estimated date of completion: These procedures were implemented August 14, 2023. Agency Response Does the Agency agree With finding: Yes If No or Partial, please Explain reason(s) why: Individual Responsible for Corrective Action Plan: Name, Title: Brooke Barlow, Chief of Fiscal Phone Number: 775-684-0659 Email: bebarlow@dwss.nv.gov Reviewed and Approved: Crystal Buscay, CFO

AUDIT FINDING 2022-062 Finding: U.S. Department of Health and Human Services Medicaid Cluster: State Medicaid Fraud Control Units, 93.775 State Survey and Certification of Health Care Providers and Suppliers (Title XVIII) Medicare, 93.777 Medical Assistance Program (Medicaid; Title XIX), 93.778 Reporting Material Weakness in Internal Control over Compliance and Material Noncompliance The OMB Compliance Supplement requires that reports submitted to the federal awarding agency include all activity of the reporting period, are supported by underlying accounting information, and are presented in accordance with program requirements. The Nevada Division of Health Care Financing and Policy (DHCFP) is required to submit Quarterly Medicaid Statement of Expenditures for the Medical Assistance Program (CMS-64) reports based on actual recorded expenditures (42 CFR 430.30). Amounts reported on the CMS-64 were not supported by the underlying accounting information. DHCFP did not have adequate internal controls to ensure CMS-64 reports were accurate or supporting documentation for reconciling items was maintained. Inaccurate information may be reported to the federal awarding agency. A nonstatistical sample of two CMS-64 reports out of a population of four was selected for testing. DHCFP has manual adjustments to key line items within the CMS-64 from the general ledger. DHCFP did not maintain a record of any of the manual adjustments and we were unable to verify whether the manual adjustment was appropriate. In total, there were $91,007,519 in manual adjustments in the December 31, 2021 CMS-64 report and $121,971,786 in the March 31, 2022 CMS-64 report that we were unable to verify. Recommendation: We recommend DHCFP enhance internal controls to ensure CMS-64 reports are accurate and supporting documentation is maintained. Agency Response Does the Agency Agree with Finding?: Yes Additional Comments: None Corrective Action Taken or To Be Taken Action: The Division will enhance internal controls to ensure CMS-64 reports are accurate and supporting documentation is reviewed, reconciled, and maintained. The Division is actively filling vacancies and training staff to ensure reconciliations are perfomred to ensure the integrity of data and reports are correct. Date of Completion or Estimated Completion: December 2024 Department or Agency Responsible for Corrective Action Plan Agency: Department of Healthcare Financing and Policy Contact: Russ Steele, Audit Manager 1000 E William St., Suite 110 Carson City, NV 89701 (775) 684-3609 rsteele@dhcfp.nv.gov Reviewed and Approved 12/15/2023 Signature of Ashwini Prasad, Date Administrative Services Officer 4

CORRECTIVE ACTION PLAN FOR AUDIT FINDING AUDIT FINDING 2022-061 Finding: U.S. Department of Health and Human Services Children's Health Insurance Program (CHIP), 93.767 Medicaid Cluster: State Medicaid Fraud Control Units, 93.775; State Survey and Certification of Health Care Providers and Suppliers (Title XVIII) Medicare, 93.777 Medical Assistance Program (Medicaid; Title XIX), 93.778 Eligibility Material Weakness in Internal Control over Compliance Title 42 Public Health section 435.403 State Residence provides that the State must provide Medicaid to eligible residents of the State, including residents who are absent from the State, except in cases where another state has determined that the person is a resident there for purposes of Medicaid. The Medicaid State Plan provides that the State has an eligibility determination system for data matching through the Public Assistance Reporting Information System (PARIS). The information that is requested is to be exchanged with states and other entities legally entitled to verify Title XIX applications and individuals eligible for covered Title XIX services consistent with applicable PARIS agreements. The State will transmit and receive data quarterly (February, May, August, and November). The State enrolls beneficiaries on a mandatory basis into managed care entities (managed care organizations and/or primary care case managers) in the absence of certain allowable waivers. The State contracts with managed care organizations and reimburses them for capitation payments. PARIS data was not utilized by the Division of Health Care Financing and Policy (DHCFP) or the Division of Welfare and Supportive Services (DWSS) to monitor residency changes to determine when managed care benefits needed to be terminated because the beneficiary was a resident of another state for Medicaid purposes. DHCFP and DWSS did not have internal controls in place to effectively communicate the PARIS data between the two agencies to ensure managed care benefits were terminated when appropriate. Individuals are enrolled in Medicaid (and CHIP) plans in multiple states and benefits are not being terminated timely. Therefore, the State of Nevada is paying capitation payments to managed care organizations, when the benefits should have been terminated. Projected questioned costs are $12,743,890 for Medicaid and $186,062 for CHIP. No sampling was used. The PARIS data was obtained and examined in total. The PARIS data included 56,892 participants with dual enrollment. Of those 56,892 participants, 9,722 participants were enrolled in another state after the State of Nevada. The projected questioned costs were estimated by performing the following: • Identifying individuals who enrolled in another state after they had enrolled in Nevada (termination date for Nevada). • Estimating a weighted average capitation payment based on demographics that determine the payment amount. • Applying the weighted average capitation payments from the termination date through June 30, 2022 to determine the total projected questioned costs. • The total projected questioned costs were then allocated between Medicaid and CHIP using participant counts in each plan between the ages of 0-18. Participants older than 18 were allocated to Medicaid. The allocated projected questioned costs were then multiplied by a weighted average Federal Medical Assistance Percentage (FMAP) to determine the final projected federal questioned costs. Recommendation: We recommend DHCFP and DWSS implement internal controls to effectively communicate the PARIS data between each other and to ensure managed care benefits are terminated when appropriate. Agency Response Does the Agency Agree with Finding?: Yes Additional Comments: None. Corrective Action Taken or To Be Taken Action: The Division is in the process of updating its policies and procedures for its Public Assistance Reporting Information System (PARIS) data matching process, which occurs on a quarterly basis (i.e., once every February, May, August, and November). Currently, the process is primarily a manual caseworker process conducted by caseworker staff at DWSS. However, in many states; this activity is an automated process and considered a program-integrity function of the Medicaid program rather than an eligibility function. Nevada agrees with this practice and intends to implement an automated process, while transitioning the PARIS data matching process to its program-integrity unit at the Division. To do this, the Division will be procuring a vendor to establish a Surveillance and Utilization Review section (SUR) data system, which will include the PARIS data matching process, with new federal funds from the American Rescue Plan Act (ARPA). DHCFP has started the Request for Proposal (RFP) process for this new SUR Data System. DHCFP anticipates a contract start date of January 1, 2024 and an estimated implementation date of December 31, 2024. By automating and streamlining this process in the future, Nevada Medicaid aims to increase the state's capacity to act more quickly on eligibility redeterminations that stem from a PARIS data match finding. In return, this will allow the program to adjust enrollment and payments to managed care plans, more quickly. This adjustment process is fully automated in the Division's Medicaid Management Information System (MMIS) which was certified by CMS in May of 2019. Date of Completion or Estimated Completion: December 31, 2024 Department or Agency Responsible for Corrective Action Plan Agency: Contact: Department of Healthcare Financing and Policy Russ Steele, Audit Manager 1000 E William St., Suite 110 Carson City, NV 89701 (775) 684-3609 rsteele@dhcfp.nv.gov Signature of Sandie Ruybalid, Deputy Administrator