Corrective Action Plans

Rural Rental Housing Loans - Assistance Listing No 10.415 Material Weaknesses: See Findings 2022-001, 2022-002, 2022-003

Program: Emergency Rental Assistance Program Assistance Listing No.: 21.023 Federal Agency: U.S. Department of the Treasury Passed-through: Direct Award Award Year: 2021/2022 Compliance Requirement: Reporting Type of Finding: Material Weakness Views of Responsible Officials: We concur with the finding. Corrective Action Plan: The Emergency Rental Assistance Program (ERAP) was an emergency program that was implemented during the height of the COVID-19 pandemic. As ERAP is closed, the County cannot revise its processes to include this recommendation but will do so should any similar programs be administered by the County or a County subrecipient in future. Responsible Individual(s): Anne Putney, Principal Management Analyst Anticipated Completion Date: N/A

Program: Temporary Assistance for Needy Families Program Assistance Listing No.: 93.558 Federal Agency: U.S. Department of Health and Human Services Passed-through: California Department of Social Services Award Year: 2021/2022 Compliance Requirement: Allowable Costs, Eligibility and Special Tests and Provisions Type of Finding: Material Weakness, Instances of Noncompliance Views of Responsible Officials: We concur with the finding. Corrective Action Plan: Finding Part 1: Two (2) out of 60 cases tested were missing the annual redetermination for the reevaluation of their benefits and eligibility requirements. Solano County has policies and procedures as well as systematic processes set up to ensure that redeterminations are processed annually. It is Solano County?s policy that the SAWS 2 Plus, Rights and Responsibilities and the Child Support Questionnaire and Notice and Agreements be processed which require workers to: ? Conduct a telephone interview with the recipient, print the forms, and document the County Use Section which requires worker?s signature and date. ? Mail the forms to the recipient for signature ? Upon return, review the SAWS 2 Plus and additional forms for completeness ? Initiate the required case action based upon information provided on the forms A redetermination of eligibility of the recipient shall be completed at least once every twelve (12) months. The annual CalWORKs Redetermination requires a face-to-face or telephone interview with the parent or person responsibility for the child or the person having responsibility for the care and control of the child. The Division Managers implemented a Quality Assurance Unit of lead workers to conduct 2-3 case reviews per month for all workers. Case reviews are a valuable tool in assessing case accuracy and recognizing quality casework. The case reviews are used to develop and strengthen worker and supervisory skills, provide structure for measuring results, identify, correct and prevent errors, and strengthen accountability to the programs and services we delivery as an agency. Specific corrective actions are outlined below to prevent these errors in the future: ? The CalWORKs Program Specialist will work with Hiring and Staff Development to strengthen the eligibility redetermination handbook with verbiage to emphasize the following: o The renewal be authorized only after required forms are received by the county and scanned into the document imaging system. o Ensure that redetermination dates are correct in the system at application and renewal. o Highlight these requirements when training this topic ? The CalWORKs Program Specialist will discuss the findings and redetermination requirements in the following ways: o Monthly Program Support Forum conducted with managers, supervisors, and lead workers o Issue a reminder memorandum to all staff o Written material will be published in the Monthly Program Support Newsletter to all staff Finding Part 2: In 31 out of 60 cases, we found that the review of the IEVS was not documented during the application or annual re-determination applicable to the fiscal year. However, we found that the related recipients/cases were eligible. It is Solano County?s policy to maintain program integrity. All CalWORKs (TANF) cases are required to be reviewed to assist with the eligibility determination using the Income and Eligibility Verification System (IEVS) at application and annual redetermination. ? IEVS is a computer cross match of State wage data, Unemployment Insurance Benefit data, wage data maintained by the Social Security Administration, and unearned income data maintained by the Internal Revenue Services and/or Franchise Tax Board. ? Staff is required to initiate the required case action and notices based on information received from the report, which includes generating adequate and timely notice. ? IEVS is system-generated at application. Effective February 2021, the CalWIN system auto-generates IEVS at least 15 days prior to the beginning of the redetermination due month. Specific corrective actions are outlined below to prevent these errors in the future: ? An ad-hoc report will be developed to generate monthly to help ensure the reports are reviewed and signed off by workers. A process will be put in place to ensure supervisors and lead workers follow up with the completion of these reports. ? The CalWORKs Program Specialist will work with Hiring and Staff Development to strengthen the eligibility handbook sections for Application, Annual Redetermination, and IEVS Interfaces. ? The CalWORKs Program Specialist will discuss the findings and IEVS requirements in the following ways: o Monthly Program Support Forum conducted with managers, supervisors, and lead workers o Issue a reminder memorandum to all staff o Written material will be published in the Monthly Program Support Newsletter to all staff Responsible Individual(s): Daniel Horel, Employment and Eligibility Services Manager Thomas West, Employment and Eligibility Services Manager Anticipated Completion Date: June 30, 2023

Program: Epidemiology and Laboratory Capacity for Infectious Diseases Assistance Listing No.: 93.323 Federal Agency: U.S. Department of Health and Human Services Passed-through: California Department of Public Health Award Year: 2021/2022 Compliance Requirement: Reporting Type of Finding: Material Weakness Views of Responsible Officials: We concur with the finding. Corrective Action Plan: County internal control procedures require report preparation by fiscal team staff, followed by manager review and approval. In instances where procedures were impacted by staff shortages, the report was submitted by the manager based on documentation provided by fiscal staff. Although the procedures were followed, the County did not document this procedure was done. The County will modify current procedures to include documentation, i.e. initials or signatures, indicating the procedure was followed. Responsible Individual(s): Nina Delmendo, Policy and Financial Manager Anticipated Completion Date: April 1, 2023

Program: WIA/WIOA Cluster Assistance Listing No.: 17.258, 17.259, 17.278 Federal Agency: U.S. Department of Labor Passed-through: State of California Employment Development Department (EDD) Award Year: 2021/2022 Compliance Requirement: Reporting Type of Finding: Material Weakness, Instance of Noncompliance Views of Responsible Officials: We concur with the finding Corrective Action Plan: The Workforce Development Board had transition of fiscal directors in FY2021-22. As a result, the fiscal director at the time of the reports in question was not fully aware of the fiscal reporting requirements. However, this has been addressed and a new procedure for fiscal reporting in the state?s system has been established. This new procedure has been in effect since July 1, 2022. Responsible Individual(s): Heather Henry, President/Executive Director, Workforce Development Board of Solano County Anticipated Completion Date: July 1, 2022

Program: Section 8 Housing Choice Vouchers Assistance Listing No.: 14.871 Federal Agency: U.S. Department of Housing and Urban Development Passed-through: n/a ? direct award Award Year: 2021/2022 Compliance Requirement: Reporting Type of Finding: Material Weakness, Material Noncompliance Views of Responsible Officials: We concur with the finding. Corrective Action Plan: The County agrees that the Housing Voucher program is subject to the requirements of 2 CFR Part 170 and will complete Federal Funding Accountability and Transparency Act (FFATA) reporting as soon as the County is able. The County is continuing to make attempts at reporting through the FFATA Subaward Reporting System (FRS). The local HUD office and the FRS helpdesk have been unable to provide the necessary assistance, the County will continue to make attempts to report. Responsible Individual(s): Terry Schmidtbauer Anticipated Completion Date: July 2023

Finding 2022-004 ? Child Nutrition Cluster - Reporting Contact Person Responsible for Corrective Action: Melissa Dempsey Contact Phone Number: 812-546-2000 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The School Lunch reimbursement claims will be reviewed by a secondary individual prior to submission to IDOE and signed off on to document the review. Anticipated Completion Date: April 2023

Finding 2022-003 ? Child Nutrition Cluster - Activities Allowed or Unallowed, Allowable Costs/Cost Principles Contact Person Responsible for Corrective Action: Melissa Dempsey Contact Phone Number: 812-546-2000 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The School Corporation will establish a documented review of all Child Nutrition Cluster account payable claims before they are paid. Additionally, the School Corporation will transfer funds to replenish the school lunch fund. Anticipated Completion Date: June 2023

Subject: Hennepin County?s 2022 Corrective Action Plan Finding# 2022-004?Eligibility Program: Medical Assistance Program (ALN 93.778) Type of Finding: Material Weakness in Internal Control over Compliance; Other Matter Compliance Finding Condition: During our testing, we noted the following instances of noncompliance in the sample of 120 case files tested: ? One MAXIS case file had assets greater than their applicable household size asset limit. While beneficiaries may reduce their assets to continue to qualify, there was no documentation in the case notes showing the applicant reduced their assets subsequent to renewal in order to continue to qualify for benefits. ? One MAXIS case file had different bases of eligibility in MAXIS and MMIS where MAXIS indicated the beneficiary was ?EX? (age 65 or older) while MMIS indicated the beneficiary was ?DX? (disabled). ? One METS case file included documentation of verification of income that did not match the information entered into METS. ? One METS case file did not have a SSN entered at either the initial application date nor any of the subsequent renewal dates. No exemptions to the requirement to submit a SSN was noted in the case within METS. In addition, the County does not have effective internal controls over eligibility of the Medicaid program: ? The County does not have a formalized supervisory case file review process in place to ensure accuracy and completeness of inputs into the MAXIS and METS systems. ? We were not able to review and test the automated application controls and the related ITGCs within the MAXIS, METS and MMIS systems, all of which are state systems that are administered by the state and required to be used by the County, to determine whether the system controls are adequately designed and implemented and operating effectively for the determination of eligibility. Hennepin County?s Corrective Action Planned in Response to Finding: Program staff will design internal controls to ensure eligibility inputs are correctly entered, and information required by contract is retained. Hennepin County Employee Responsible for the CAP: Jackie Poidinger Planned Completion Date for CAP: December 31, 2023 Hennepin County will encourage the State to provide an independent audit of the design and implementation of MAXIS, METS, and MMIS system controls for the benefit of all counties. Hennepin County Employee Responsible for the CAP: Andra Roethler Planned Completion Date for CAP: December 31, 2023

Reference Number: 2022-003 Description: Lack of Written Procedures for Federal Awards Corrective Action Plan: The Society will develop written procedures for federal awards received. Anticipated Corrective Action Plan Completion Date: ongoing Contact Information: For additional information regarding this finding, please contact Larry Gaffey, General manager at 262-723-3228.

Finding Number: 2022-013 ? SEFA Preparation Corrective Action Plan: In 2022, the office had downsized due to turnover in staff. While a process was in place for reconciling, a secondary review was not performed to verify accuracy of the residual value calculations. To strengthen the oversight of financial management in the School, Academica Nevada, the School?s management company, has filled all the open positions and realigned staff responsibilities to reduce individual workloads and provide additional oversight and review. The grant manager will reconcile all grants to ensure proper cutoff, with a secondary review performed by a member of management. Responsible Individuals: Nachum Golodner, Director of Accounting Anticipated Completion Date: June 30, 2023

The District will carefully review any and all compliance requirements when using federal funding for future projects. Responsible person - Nicholas Kaiser. Anticipated completion date - ongoing.

The District will continue to file reimbursement for all meals served in the fiscal year.

Finding Number: 2022-002 Planned Corrective Action: The Treasurer/CFO is currently working on a federally funded project and has already reached out to the attorney and the contracts regarding the submittal of the payrolls for the projects. The attorney will review and confirm that they are following the Davis-Bacon Act rules and regulations. Anticipated Completion Date: December 31, 2023 Responsible Contact Person: Kevin Simons

Finding Number: 2022-004 Condition: The notifications related to the direct loan borrowers did not include information on the right to cancel or instructions on how to cancel the loans. Planned Corrective Action: The University?s new financial aid module does not have the capability to send emails. That functionality does exist in the University?s new student information system. Consequently, effective for Fall 2022 semester, the Office of Financial Aid partnered with Office of the Controller ? Student Accounts to generate emails on a weekly basis to any student who receives a disbursement of Title IV funds. By May 1, 2023 the University will create similar procedures to identify disbursements of Parent PLUS loans and then coordinate with Office of the Controller - Student Accounts to leverage the student information system to send notifications to parent borrowers. Contact person responsible for corrective action: Marshall Rumsey, Senior Associate Director, Office of Financial Aid Anticipated Completion Date: Completed September 8, 2022 (student), to be completed May 1, 2023 (parent)

Finding Number: 2022-005 Condition: The University awarded incorrect Pell awards to certain students based on the Pell Payment and Disbursement Schedule. Planned Corrective Action: The University?s new financial aid module was modified to use the census date for Pell recalculation rather than an arbitrary number of days into the term that did not match the University policy. The correction for this finding was implemented prior to aid being disbursed for the Fall 2022 semester. Contact person responsible for corrective action: Cheryl Whitman, Associate Director, Office of Financial Aid Anticipated Completion Date: Completed August 31, 2022

Finding Number: 2022-003 Condition: The University used incorrect or incomplete data in the return of Title IV calculations. Planned Corrective Action: The new financial aid management database made incorrect R2T4 calculations and prevented manual adjustments to the calculations. The calculations are now done externally to the system and fixes and workarounds have been implemented to allow for the correct processing of R2T4 calculations. As of the Fall 2022 semester R2T4 calculations were being performed in the required timeframe. University personnel were not aware there was a shorter deadline (30 days versus 45 days) to return funds if the student had not begun attendance. Therefore, effective March 15, 2023, funds were being returned within 30 days for students for whom there is no confirmed attendance. Beginning with the fall 2022 semester, the Registrar?s Office has initiated procedures to confirm attendance/academic activity for courses that are dropped. This allows the University to identify whether adjustments need to be made to Pell grants before an R2T4 calculation is performed, and to determine if an R2T4 calculation is required or if all aid is to be returned for non-attendance. The withdrawal process itself has been modified to more clearly identify the withdrawal date. Contact person responsible for corrective action: Matthew Lyth, Financial Aid Officer Anticipated Completion Date: Completed March 15, 2023

Finding Number: 2022-001 Condition: The University did not report certain students' status to the NSLDS in an accurate and timely manner during the fiscal year. Planned Corrective Action: The University implemented a new administrative database for student academic records. The provided tool for extracting enrollment data did not perform as expected and hampered the school?s ability to provide the required data to the National Student Clearinghouse. The Registrar?s Office resolved its data collection issues and is now submitting the data to NSLDS via the Clearinghouse on the required timeline. Contact person responsible for corrective action: Becky Keogh, Senior Associate Registrar Anticipated Completion Date: Completed November 15, 2022

Finding Number: 2022-004 Condition: The University did not file accurate and timely reports throughout the fiscal year. Planned Corrective Action: 1. The 9/30/21 HEERF institutional report was posted on the University?s website 10 days late. This was due to the staff member responsible going out on medical leave and miscommunication within the area on required filings. There were no additional quarterly reports to be filed so no further controls were put in place for this reporting. The annual report was filed timely. 2. The 9/30/21 institutional report has been removed from the University website as it indicated a duplicate expense that was reported on the 6/30/21 quarterly report. The 06/30/21 report has been marked as the final institutional report. 3. The Student Financial Aid (SFA) office agrees that the March 31, 2022, student website report did not include language regarding eligible students, and the reported student count was incorrect. SFA will amend the March 31, 2022, quarterly student report to reflect the correct number, add language regarding eligible students, and send the correction to the appointed HEERF email address by June 1, 2023. The Associate Director of Compliance and Training will perform a secondary review of any future reports to ensure the completeness and accuracy of the information. 4. The Student Financial Aid (SFA) office agrees that the 2021 annual report included the incorrect number of part-time graduate students who received an award, impacting the total number of students reported. The error was due to incorrectly inputting the information from the supporting data onto the annual report. SFA will amend the 2021 annual report by correcting the number of part-time graduate students by March 24, 2023. The Associate Director of Compliance and Training will perform a secondary review of the data on the annual report and compare it with the supporting documentation. 5. As indicated in the report, the University did comply with earmarking requirements. However, the categories used to report the expenditures on the 12/31/21 annual report were not the specific earmarked categories. The 12/31/21 annual report filed through the Department of Education website has just recently been made active again and the University will make necessary category reporting corrections. As the 12/31/21 annual report was the final report for institutional expenses no additional actions are required. Contact person responsible for corrective action: Colleen Scarff, Assoc VP for Business and Finance and Lana Greaves, Senior Associate Director, Student Financial Services Anticipated Completion Date: 3/24/23

Finding Number: 2022-003 Condition: The University did not return funds in accordance with 34 CFR 668.22 which states, when a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV aid earned by the student as of the student?s withdrawal date. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student or on his or her behalf as of the date of the institution?s determination that the student withdrew, the difference must be returned to the Title IV programs. Planned Corrective Action: The Student Financial Aid (SFA) office agrees with the finding that all the funds calculated to be returned for a student were not billed back. Management acknowledges that the deficiency was due to an oversight. The isolated occurrence was corrected on 01-13-2023. The unsubsidized loan amount of $3,558 was returned, and the change was reflected in COD. SFA awarded the student institutional aid of $3,558 to compensate for the error. In addition, the 60% withdrawal date was corrected, R2T4 calculations were performed, the funds were returned, and SFA awarded the students institutional aid to compensate for the errors. Step-by-step procedure for calculating the R2T4 60% withdrawal date were created and before the beginning of each aid year, Client Services and the Associate Director of Compliance will determine the 60% withdrawal dates for each term. Contact person responsible for corrective action: Lana Greaves, Senior Associate Director, Student Financial Services Anticipated Completion Date: 04/15/2023

Finding Number: 2022-002 Condition: The University initiated certain returns of Title IV funds after the required timing. Planned Corrective Action: The Student Financial Aid (SFA) office agrees with the finding that certain Return of Title IV funds were initiated after the required time. SFA evaluated its R2T4 procedures in May 2022 and strengthened its internal controls by: 1. Reviewing reports of withdrawn students on a daily basis. 2. Weekly reporting of R2T4 and LDA students and calculations with two levels of approvals. 3. Holding weekly meetings and performing self-assessments to verify completion and accuracy of R2T4 calculations. Contact person responsible for corrective action: Lana Greaves, Senior Associate Director, Student Financial Aid Anticipated Completion Date: 10/23/2022

Finding 2022-001: Allowable costs - material weakness in internal controls over compliance and compliance finding- timesheet and GL mismatch. CCGD will perform an audit of the existing setup of its HRIS-PayCom system to determine what is causing the mismatch between timesheets and payroll GL. If required, CCGD will re-implement PayCom with the required setup or change vendors to assure that all internal control requirements are addressed. This action will be followed by a quarterly audit of timesheets and payroll GL to ensure that there are no more mismatches. Additionally, management will perform a time study audit on a quarterly basis to ensure that individual performances comply.

FINDING 2022-006 Contact Person Responsible for Corrective Action: Andrew Nicodemus Contact Phone Number: 765-362-2342 Views of the Responsible Official: We agree with the finding. Description of Corrective Action Plan: Crawfordsville Community School Corporation plans to review all internal control procedures, including the control procedures over the Reporting for ESSER. After this review, we will implement a system to ensure that all reports are properly reviewed and have the adequate supporting documentation kept on file. Anticipated Completion Date: We expect this Corrective Action to be implement by the end of April 2023 to allow for a full review of all internal control processes and procedures.

FINDING 2022-005 Contact Person Responsible for Corrective Action: Andrew Nicodemus Contact Phone Number: 765-362-2342 Views of the Responsible Official: We agree with the finding. Description of Corrective Action Plan: Crawfordsville Community School Corporation plans to review all internal control procedures, including the control procedures over the Assessment System Security. After this review, we will implement a system to ensure that all compliance requirements are being met. We will implement a certification process for each building administrator to certify the training completed for their employees. Anticipated Completion Date: We expect this Corrective Action to be implement by August 2023 to allow for a full review of all internal control processes and procedures.

FINDING 2022-004 Contact Person Responsible for Corrective Action: Andrew Nicodemus Contact Phone Number: 765-362-2342 Views of the Responsible Official: We agree with the finding. Description of Corrective Action Plan: Crawfordsville Community School Corporation plans to review all internal control procedures, including the control procedures over the Annual Report Card, High School Graduation Rates. After this review, we will implement a system to ensure that all students that were removed from the cohorts are properly documented and appropriate approvals are obtained prior to student removal from the cohort. We also will implement a process to ensure that the reason for removal is consistent with the documentation. Anticipated Completion Date: We expect this Corrective Action to be implement by the end of April 2023 to allow for a full review of all internal control processes and procedures.