Corrective Action Plans

2022-004 Special Tests and Provisions ? CARES Act Funding Material Weakness / Material Noncompliance The Housing Authority completed modifications to the main office building with CARES Act funding. The Section 8 specialist employees work in the main office building with the administrative staff of the Housing Authority. Prior to COVID, the Section 8 specialists were working in cubicles which were not compliant with the CDC guidelines of distance. CARES Act funding was used to build separate offices and install an air filtration system. The rest of the main office was only modified to stay uniform with the other modifications such as painting and new flooring. The amount of the total project charged to the HCV program was in relation to what improvements were made as well as which employees were occupying the space. Effective July 2022, Section 8 is leasing this section of the main office, which was approved by HUD QAD. This finding has been corrected. The Comptroller, Jennifer Yager, worked with the outside auditors as well as the CFO consultant to resolve the posting errors. Jennifer can be reached at 203-596-2640.

CORRECTIVE ACTION PLAN YEAR ENDED DECEMBER 31, 2022 Finding No. 2022-002: Incomplete Schedule of Expenditures of Federal Awards- Material Weakness and Material Noncompliance Finding: During our audit, we identified a grant that is required to comply with the applicable requirements of 2 CFR Part 200 and thus should have been included in the Schedule of Expenditures of Federal Awards. Once this grant was properly included, the Organization exceeded $750,000 in qualifying federal expenditures thus meeting the requirement for a Uniform Guidance audit to be conducted. Corrective Actions Taken or Planned: Management has hired a Director of Grants Financial Management who is heading a team to ensure effective management and compliance with all awards in the agency. In addition, management has acquired an award management system and implemented new processes to identify Federal awards. These processes consist of (1) clearly identifying Federal awards on the new Grant Code Form, (2) conducting new award kick-off meetings within the Awards Management, Budget, and Compliance team, and (3) tracking all awards on an award and contracts matrix, as well as in the new awards management software system. For each new award, a Grant Code Form is created. The form allows the Awards Management, Budget, and Compliance team to direct the Accounting team to create a grant code for tracking purposes in the accounting financial system. When the Awards Management and Budget team complete the form, the grant will be clearly identified as a federal grant. In addition, when KIND receives a new award, the Awards Management, Budget, and Compliance team conduct kick-off meetings within the team to discuss award financial, programmatic and compliance requirements. During this meeting the team completes an awards summary template that clearly identifies an award as a Federal award and any related compliance and other requirements. In addition to the processes mentioned, the Awards Management, Budget and Compliance team has created a new contracts and awards tracking matrix. The awards tracking matrix identifies Federal grants, along with any related award requirements and other identifying information. This matrix is maintained and updated by the Awards Management, Contracts and Compliance Officer and reviewed by the Director, Grants Financial Management on a regular basis. The review includes existing procedures related to awards management and monitoring of processes. This is on-going and already in progress. In addition to the above-mentioned processes KIND will do the following: continuously review existing processes around clearly identifying Federal awards and make adjustments to strengthen internal controls as needed; review and discuss with the awards management software vendor, additional improvements that can be made to the system to better identify and report Federal awards and review the current awards matrix and make additional improvements that will better identify and track Federal awards. Name and Person Responsible: Rochelle Quillman, Director of Grants Financial Management Expected Completion Date: October 31, 2023

FINDING 2022-003 Contact Person Responsible for Corrective Action: Shannon Fritz, Corporation Treasurer, Cathy Rowe, Superintendent Contact Phone Number: 219-567-9161 Views of Responsible Official: We concur with the audit findings. We have initiated corrective action as referenced below. Description of Corrective Action Plan: The district will be soliciting a capital assets tracking vendor that will ensure all capital assets are tracked and updated. Anticipated Completion Date: March 15, 2023 Cathy Rowe, Superintendent Shannon Fritz, Corporation Treasurer Date: 2-27-23 Date: 2-27-23

FINDING 2022-002 Contact Person Responsible for Corrective Action: Shannon Fritz, Corporation Treasurer Cathy Rowe, Superintendent Contact Phone Number: 219-567-9161 Views of Responsible Official: We concur with the audit findings. We have initiated corrective action as referenced below and will strive to ensure a proper system of internal controls. Description of Corrective Action Plan: The treasurer and superintendent will both review and sign all federal financial reports prior to submission. Anticipated Completion Date: January 1, 2023 Cathy Rowe, Superintendent Shannon Fritz, Corporation Treasurer Date: 2-27-23 Date: 2-27-23

FINDING 2022-004 Contact Person Responsible for Corrective Action: Shannon Fritz, Corporation Treasurer Contact Phone Number: 219-567-9161 Views of Responsible Official: We concur with the audit findings. We have initiated corrective action as referenced below. Description of Corrective Action Plan: Monthly sponsor claims will be reviewed by the corporation treasurer after being prepared by the food service director. Anticipated Completion Date: Completed as of February 22, 2023 Cathy Rowe, Superintendent Shannon Fritz, Corporation Treasurer Date: 2-27-23 Date: 2-27-23

Finding Number: 2022-001 Planned Corrective Action: The district will improve internal controls to make sure clauses concerning prevailing wage rates are within construction projects and that contractors must submit copies of payroll and certify that prevailing wages were paid. Anticipated Completion Date: 6/1/2023 Responsible Contact Person: Adam Quirk, Treasurer

The University agrees with the finding and acknowledges the finding was also reported in the previous fiscal year. Despite high staff turnover, the Director of the Financial Aid Office and in collaboration with the Associate Director for Enrollment Systems the issue is being addressed and rectified for FY 2023.

The University agrees with the finding and to ensure compliance with the federal requirements that disbursement data be reported within the 15-calendar window, the Financial Aid Director is in the process of developing a new Policy that will address the review of rejected or denied Pell Disbursement. Any Pell Award that is disbursed but rejected or denied on COD will be cancelled off student accounts while the Financial Aid Office resolves the reason why a Pell Grant disbursement was rejected or denied. Some situations cannot be resolved within the 15-day window. It is therefore prudent for the University to remove the Pell disbursement and resolve the issue before re-disbursing the award. The new Policy will also include a pre-disbursement authorization process to confirm that the disbursement once requested will be accepted on COD, therefore reducing the risk of the University disbursing a Pell Award that will be rejected on COD. The University has also contracted with a PeopleSoft consultant to address the manual processes and develop a more automated business process.

Charter Schools ? AL #84.282 Education Stabilization Fund ? AL #84.425C, 84.425D & 84.425U 2022-001 Risk Assessment Process Related to Compliance Requirements (Repeat Finding 2021-001) Material Weakness Recommendation: The Auditor recommended additional resources be allocated to federal award compliance to review federal award provisions and requirements, evaluate risks of noncompliance, and respond to such risks through internal controls. The process should include methods to identify and communicate changes to federal award requirements to all key individuals within the Organization and to verify internal controls are implemented correctly and are operating effectively. Planned Corrective Action: As the organization has grown, compliance of federal programs has become decentralized. We agree that additional resources need to be added to ensure compliance with all state and federal awards. The Organization is adding additional capacity to the Business Office to centralize the compliance and reporting responsibilities. The Organization has recently had the opportunity to redesign the job description of the Controller. To allow the Controller more capacity for compliance and reporting responsibilities, an accounts payable position will be added by the end of Fiscal Year 2023. The Controller will attend appropriate trainings to ensure a full understanding of all requirements. This should be fully implemented by mid-2023.

Finding 2022-004 The Authority agrees with the finding and responds stating that our project is relatively small with only one administrative staff. The board has reviewed this issue and determined there are no additional procedures which can reasonably be done to eliminate these deficiencies and accepts them.

Finding 2022-002: Allowable Costs Section 202 Capital Advance, 14.157 Material Weakness I agree with the finding. The previous management did not submit budget for the year 2021-2022. Although I submitted a budget for the year, HUD only renewed the previous budget on file as they needed to complete approval by 5-1-2022 of the New Management Agent. HUD approval effectively locked in the budget for the period 7/1/2022 -6/30/23. A revised budget has been submitted and approved by the Board of Directors for the period 7/1/2022 ? 6/30/2023. A budget will be prepared and submitted to both the Board and HUD for the period 7/1/2023 ? 6/30/2024.

The School District will implement internal controls to ensure that all contractors working on federally funded projects for which wage rate requirements apply, are notified and the School District will obtain necessary documentation to verify compliance. In addition, the School District will implement internal controls to ensure the necessary language is included in all future solicitations for quotes or bids for which prevailing wage requirements apply.

FINDING 2022-004 Contact Person Responsible for Corrective Action: Wendy Marples, County Auditor Contact Phone Number: 812-338-2142 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: All future reporting of the Coronavirus State and Local Fiscal Recovery Funds will be reviewed for accuracy by a second staff member of the Auditor?s office prior to submission. The report will be signed and dated by both the preparer and reviewer. All documentation will be maintained to help prevent any future inconsistencies. Anticipated Completion Date: April 2024

CORRECTIVE ACTION PLAN For the Year Ended June 30, 2022 SECTION II ? FINDINGS - FINANCIAL STATEMENTS AUDIT No matters were reported SECTION III ? FINDINGS AND QUESTIONED COSTS - MAJOR FEDERAL AWARD PROGRAMS AUDIT 2022-001 Filing of Single Audit Report Material Weakness & Noncompliance Name of contact person: Patti Tototzintle, Executive Director Corrective Action: The Organization transitioned to a contract accountant in June 2022 who closed the books in October for 2022 for the year ended June 30, 2022 and plans to have the books closed in a timely manner going forward. The Organization is also actively working with their auditing firm to improve communication during the audit so a future break-down in communication does not occur. This transition and this new plan were not implemented until after the end of fiscal year 2022, so a repeat finding is expected for the filing of the 2022 audit, but the issue will be mitigated for the 2023 audit. Completion Date: The Organization has already adopted this corrective action.

Corrective Action Plan The City of Buena Vista, Virginia respectfully submits the following corrective action plan for the year ended June 30, 2022. Name and address of independent public accounting firm: Robinson, Farmer, Cox Associates 10 Hedgerow Drive Staunton, VA 24401 Audit Period: July 1, 2021 to June 30, 2022 The findings from the June 30, 2022 schedule of findings and questioned costs is discussed below. The findings are numbered consistently with the number assigned in the schedule. Financial Statement Findings 2022-001 Material Weakness Responsible Person, Title: Jason Tyree, City Manager; Charles Clemmer, Finance Director Audit Finding: The City's financial statements required several material adjusting entries by the Auditor to ensure such statements complied with Generally Accepted Accounting Principles. Auditor Recommendation: Management should review the current year adjusting entries and consider whether or not they apply during the next fiscal year. Anticipated Completion Date: 02-15-2023 City's Response: Concur Corrective Action Planned: Management will review current year adjusting entries and determine whether or not they apply during the next fiscal year. In addition, management will closely review financial statements so material adjusting entries by Auditor will not be necessary. Federal Award Findings and Questioned Costs 2022-002 Material Weakness and Compliance Finding Responsible Person, Title: Dr. Francis, Superintendent; Denise Fitzgerald, Grant Coordinator; Sandra Mohler, Finance Audit Finding: During a test of disbursements, we observed that an invoice was submitted for reimbursement to Virginia Department of Education under the Education Stabilization Fund (ESSER) as well as under the Coronavirus Tate and Local Fiscal Recovery Funds to Support HVAC Replacement. Under the terms of the Coronavirus State and Local Fiscal Recovery Funds to Support HVAC Replacement, there is a 100% local match required, which could be funded with ESSER funding. The School Board's total HVAC project was $224,856 and the School Board received reimbursement in the amount of $424,856 ($224,856 under ESSER and $200,000 under ARPA HVAC). Auditor Recommendation: The School Board should thoroughly review the terms and conditions of federal awards before submitting reimbursement to ensure compliance with federal programs. Anticipated Completion Date: 02-15-2023 City's Response: Concur Corrective Action Planned: Amendments were completed in a timely manner with the advice and guidance from VDOE Directors- Lynn Sodat and Susan Dandridge. These amendments reflect the necessary changes for the BVCPS to be in compliance with both grants. Both have received final approval from VDOE. Moving Forward BVCPS will continue to review on an ongoing basis of all approved expenditures by Denise Fitzgerald and Sandra Mohler in order to maintain proper financial records for future audits and accountability to the VDOE guidelines. This information will be shared monthly with our Core Committee, which consists of the following SBO personnel: Dr. Miller, Dr. Francis, Denise Fitzgerald, Juli Gibson, Robin Williams, Sherrie Wheeler and Sandra Mohler. Any questions regarding this corrective action plan can be addressed by Charles Clemmer, City Finance Director at 540-261-8602.

View of Responsible Officials and Corrective Action Plan ? The Academies have procedures in place requiring review and approval. Management believes that it was a limited number of items that may not have had written approval from a school administrator or the controller. Management will ensure that review and approval is properly documented by signature or an electronic approval.

Views of Responsible Officials and Planned Corrective Actions: Staffing turnover limited ability for portfolio property managers to effectively manage tenant files at each building location. Inglis has contracted with an external expert regarding implementation and process training for Yardi, the new property management system. Once fully implemented there are several key internal controls within the system that will alert property management team to tenant issues regarding rent and recertifications. Items such as documenting extenuating circumstances in TRACS and updating the form 50059 will occur more timely once Inglis has successfully implemented Yardi property management system for each property.

2022-025 Improve Controls over Transparency Act Reporting Federal Agency: U.S. Department of Health and Human Services State Entity: Department of Behavioral Health and Developmental Disabilities (DBHDD) Corrective Action Plans: The Department will continue refining the capabilities of the Regulatory Reporting Database such that it contains all of the necessary reporting data elements required for timely and accurate Federal Funding Accountability and Transparency Act (FFATA) reporting. The Department will develop documentation requirements of each subaward to ensure the appropriate data elements; the reporting guidelines associated with the subawards are properly followed. DBHDD will update the internal controls related to Transparency Act Reporting no later than June 30, 2023. Estimated Completion Date: June 30, 2023 Contact Person: Kenneth Ward, Director of Internal Audit Telephone: 404-884-5486; E-mail: kenneth.ward@dbhdd.ga.gov

2022-023 Strengthen Controls over Eligibility Records Federal Agency: U.S. Department of Health and Human Services State Entity: Department of Human Services (DHS) Corrective Action Plans: ? The Program will work with the Community Action Agencies (CAAs) and the third party to modify the data system and establish a Community Services Block Grant (CSBG) Eligibility Date and Federal Poverty Level percentage or categorical eligibility status within the data system with each application. ? This modification will clearly identify the date that the household was eligible for CSBG services and ensure compliance with 42 U.S.C. ? 9902 (defining "low-income" and "poverty line"). The Household will be eligible for CSBG services for 90 days. At the 90-day marker, the Agency must re-determine eligibility to continue CSBG services. The services will end at the end of the current Federal Fiscal Year Contract and must be reestablished annually. ? For community events or indirect services aimed at assisting low-income communities, in accordance with 42 U.S.C. ? 9901 (objectives and purposes of the CSBG program), the CAAs will flag these events in the data system as "Community Event" and document the event's purpose, attendance, and any relevant eligibility information for participants. This approach will help demonstrate the services? validity and ensure compliance with the CSBG program's objectives. ? DHS will provide the reconciliation parameters and methodology to the CAAs for their quarterly reconciliation. ? The Program will update the CSBG Policy Manual and distribute to the network. The Program will provide training and guidance to the network to ensure that policies and procedures are consistently enforced and operating effectively. Estimated Completion Date: August 1, 2024 Contact Person: Cynthia Bryant, Unit Director Telephone: 470-259-8188; E-mail: cynthia.bryant@dhs.ga.gov

2022-011 Improve Controls over Transparency Act Reporting Federal Agency: U.S. Department of Education State Entity: Department of Education Corrective Action Plans: The Department of Education concurs with this audit finding. We hired additional staff during June 2022 to complete Federal Funding Accountability and Transparency Act (FFATA) reporting to ensure the reports are submitted timely and accurately moving forward. Estimated Completion Date: June 30, 2023 Contact Person: Metsehet Ketsela, Assistant Director Telephone: 678-472-7898; E-mail: metsehet.ketsela@doe.k12.ga.us

2022-032 Improve Controls over Employer-Filed Claims Federal Agency: Various Federal Agencies: U.S. Department of Homeland Security U.S. Department of Labor State Entity: Department of Labor (GDOL) Corrective Action Plans: The Georgia Department of Labor disagrees with this finding. The Employer Filed (Partial) Claims (EFC) program originated in the late 1960?s and was designed to allow employers with short term, temporary periods of lack of work for their employees to retain their workforce when work resumes. This is a program that many large manufacturers in Georgia rely on when they have temporary plant shutdowns and have for decades. When GDOL has attempted in the past to limit this program, we have met strong resistance from Georgia?s manufacturers. This program optimizes our ability to process and pay mass numbers of claims more quickly, such as what occurred at the beginning of the pandemic. EFCs may be filed by an employer with respect to any complete pay-period week during which an otherwise full-time employee works less than full-time, due to lack of work only, and earns an amount not exceeding his/her unemployment insurance weekly benefit amount. Such claims shall not be submitted or allowed for vacation days regardless of whether such vacation days were requested by the employee or established by the employer. Effective March 19, 2020, a temporary, Emergency Rule 300-2-4-05(1), containing Rule 300-2-4-.09(1) was signed which required employers to electronically submit EFCs on behalf of their employees whenever it is necessary to temporarily reduce work hours or there was no work available for a short period of time. Employers were allowed to file such claims for full and part time employees whose earnings had been reduced. In July 2020, the Rule was sunset and employers were no longer required to file EFCs. EFCs may be filed online by single entry or upload or paper. An employer may submit EFCs for regular state unemployment insurance programs including available extended benefits programs with the same eligibility requirements as regular UI, such as Pandemic Emergency Unemployment Compensation (PEUC) and State Extended Benefits (SEB), given all regular UI entitlement is exhausted. By electing to submit EFCs on behalf of the individuals, the employer is responsible for attesting to the employment status and weekly earnings of the individual for the EFC submitted. An affidavit certifying that the employer has obtained earnings from other employment as well as other requirements must be completed before EFCs can be entered or uploaded. Individuals for which EFCs are submitted are considered to be still attached to the employer and are exempt from the requirement to register for employment services per Georgia Employment Security Law Rules 300-2-4-.02. Such individuals are not required to be nor certify on a weekly basis to be able, available and actively seeking work. The GDOL disagrees that we would not provide the requested information to the auditors. The data requested relates to an ongoing federal criminal investigation. GDOL did not provide the data with concerns that dissemination of the data to a third party could jeopardize the ongoing criminal investigation and create legal risk for GDOL. GDOL stated that the auditors should obtain permission from the United States Department of Justice as a condition to dissemination of the data. GDOL did not receive any confirmation that the auditors had discussed the matter or coordinated with the US Department of Justice. Even though there have been some publicized indictments, the US Department of Justice has confirmed to GDOL that the investigation is ongoing and future indictments are anticipated. Notwithstanding, GDOL reiterates it would be happy to share the relevant data in its possession with assurances that the auditors will not publicize or disseminate any of the audit data without first consulting with the US Department of Justice. GDOL is also happy to cooperate with the auditors and provide information relating to how GDOL discovered the methods and schemes used by the fraudsters; however, GDOL has serious concerns about any publication of such information or of any other specific vulnerabilities in GDOL?s systems that would serve to encourage or perpetuate additional unemployment insurance fraud. Summary When we identified employer fraud schemes, we followed the guidance issued by United States Department of Labor (USDOL) and collaborated with the United States Department of Labor Office of Inspector General (OIG) to investigate these cases. Effective December 6, 2021, the EFC process was revised to require individuals (employees) to complete an EFC profile to include a real-time identity verification before payments can be made. Employers are responsible for submitting the request for the payment to certify to the individual?s employment status, but the individuals must certify their identity and personal information for the claim to be processed. Employees are notified when a claim is filed on their behalf and provided instructions for their portion of completing the EFC process. The MyUI Customer Portal dashboard provides all the EFC correspondence sent to the individual as well as a status of the profile set up and identify verification. Prior to the implementation of the EFC profile requirement, GDOL utilized the Social Security Administration (SSA) crossmatch and Systematic Alien Verification for Entitlement (SAVE) verification processes to verify the identity of claimants where employers submit claims on their behalf. GDOL has no plans to stop utilizing the EFC program as it is an effective and popular program among employers with a successful 60-year track record. GDOL greatly appreciates the feedback and recommendations and will consider this information in future endeavors to modernize and update system and business processes. Estimated Completion Date: December 6, 2021 Contact Person: Crystal Singleton, Policy and Procedure Manager Telephone: 404-232-3183; E-mail: Crystal.Singleton@gdol.ga.gov

2022-030 Strengthen Controls over the Summary Schedule of Prior Audit Findings Federal Agency: U.S. Department of Labor State Entity: Department of Labor (GDOL) Corrective Action Plans: As Georgia progressed towards addressing and pursuing efforts to resolve outstanding Coronavirus Aid, Relief, and Economic Security Act (CARES Act) matters, impediments such as limited workforce and system restrictions hindered progress. Such factors, imposed upon the intents to make system changes, corrections and enhancements. We have taken the following corrective actions in an ongoing effort to bring these findings to full resolution: 2020- 036 Improve Controls Over Eligibility Determinations In addition to steadily reviewing and determining eligibility of responses providing proof of Pandemic Unemployment Assistance (PUA) employment and wages, a task force has been established to assist with this effort. An ongoing campaign is in progress to onboard additional resources to increase the cadence of addressing these items. Claimants who fail to provide adequate proof are manually reconsidered and overpayments established appropriately. Since this process is manually reviewed by staff rather than by system automation, we anticipate this effort will take approximately 60 weeks to complete. When there are indications of potential fraud, additional investigation is pursued to determine if fraud penalties should be imposed. 2021-036 ? Improve Controls over Employer-Filed Claims Effective December 6, 2021, the Employer-Filed Claims (EFC) process was revised to require individuals (employees) to complete an EFC profile to include a real-time identity verification before payments can be made. Employers are responsible for submitting the request for the payment to certify to the individual?s employment status but the individuals must certify their identity and personal information for the claim to be processed. Employees are notified when a claim is filed on their behalf and provided instructions for their portion of completing the EFC process. The MyUI dashboard provides all the EFC correspondence sent to the individual as well as a status of the profile set up and identify verification. Summary We are currently seeking funding to modernize our UI benefits system which will incorporate and improve the controls cited. GDOL will develop and implement procedures to ensure the status of each prior audit finding is reported in an accurate manner. GDOL will ensure staff responsible for submitting the status of prior period audit findings are trained and understand their responsibilities associated with the Summary Schedule of Prior Audit Findings under the Uniform Guidance. Estimated Completion Date: December 6, 2021 Contact Person: Racquel Robinson, Unemployment Policy and Procedures Chief Telephone: 404-232-3190; E-mail: Racquel.Robinson@gdol.ga.gov

2022-029 Improve Controls over the Identification, Recording, and Reporting of Overpayments Federal Agency: U.S. Department of Labor State Entity: Department of Labor (GDOL) Corrective Action Plans: The Georgia Department of Labor did not maintain adequate controls over the identification, recording, and reporting of benefit overpayments associated with the Unemployment Insurance programs. GDOL Response: The Georgia Department of Labor disagrees with this finding. USDOL provides guidance and recommended procedures for crossmatches but does not dictate a frequency or cadence for performing them. The crossmatch process is conducted using third party software which runs a systematic check against weeks in a quarter for which benefits are paid and wages are reported during the same quarter. Although the program may detect weeks paid and wages reported, this alone is not indicative of an overpayment. Therefore, the process involves verification correspondence being sent to both the claimant and the employer, as applicable, to verify the status of employment, the wages earned as well as the weeks in which an individual worked and earned the wages. Based on responses, an assessment is made to determine if an overpayment exists and subsequent actions are taken accordingly. We are prohibited from assuming a match is an overpayment. It is not an overpayment until we have completed a full investigation and provided due process to all parties. The audit report indicates misinterpretation of the data reflected on the federal reports, specifically the ETA 227. The ETA 227 is for reporting of overpayment detection and recovery activities that the Agency performed in a quarter. It is not for reporting the amount of benefits overpaid for specific weeks during that quarter. A federal reporting team was created to accurately identify and track overpayments. The Department is taking necessary actions to complete the overpayment reconciliation for the ETA 227 and 902 reports. Federal regulations require an actual person to review and establish fraudulent overpayments. Due to the volume of claims and the number of cross matches to be performed on all state and federal pandemic programs, it would require multiple GDOL staffing levels to review all cross matches, requiring increased levels of state and federal funding. Summary GDOL has developed an aggressive plan to complete all remaining state and pandemic program cross matches. We have filled all of our budgeted positions for the Overpayment Unit and are utilizing non-overpayment staff to assist with identification and overpayment investigations. Additionally, we are utilizing temp agency staff to perform some clerical duties; however, federal regulations prohibit non-merit staff from adjudicating and releasing overpayment decisions. In early 2022, we started to freeze the overpayment data at the end of every month so that we can conduct periodic reconciliation of the overpayment records. GDOL is coordinating with USDOL to ensure the timely and accurate identification, tracking and reporting of overpayments. GDOL greatly appreciates the feedback and recommendations and will consider this information in future endeavors to modernize and update system and business processes. Estimated Completion Date: January 1, 2022 Contact Person: Crystal Singleton, Policy and Procedure Manager Telephone: 404-232-3183; E-mail: Crystal.Singleton@gdol.ga.gov

2022-028 Improve Controls over Eligibility Determinations Federal Agency: U.S. Department of Labor State Entity: Department of Labor (GDOL) Corrective Action Plans: (1) Identity verification was not performed appropriately in eight instances. GDOL Response: The Georgia Department of Labor disagrees with these findings as it relates to identity verification. The auditors did not identify the type of identity verification procedures not performed or any identity verification procedures that GDOL was required to perform. There was not a mandatory requirement to complete identity verification at the time most of these applications were submitted as the majority of these claims were employer-filed claims (EFC). Identity requirements for EFCs were implemented at a later date. At the start of the pandemic, the identity proofing processes available were Social Security Administration (SSA) verification, Department of Driver Services (DDS) crossmatch and for non-citizens, Department of Homeland Security Systematic Alien Verification for Entitlement (SAVE). As applicable, these processes were performed on all initial regular and EFCs, which includes the eight instances. (2) Non-monetary determination was not performed in two instances. GDOL Response: Instance 1: A disqualifying non-monetary determination was released and disqualification was entered into the system. The system erroneously released a payment for the week in question. An overpayment was established in January 2023. Instance 2: Claim was processed but issue did not get added to the claim to address separation reasons. A non-monetary determination was released in November 2022 to allow benefits. All payable weeks have been processed. There was no detriment to the claimant as they were determined eligible nor was there any monetary loss to the State. (3) Proof of employment or self-employment or a valid offer to begin employment and proof of wages was not submitted by two Pandemic Unemployment Assistance (PUA) claimants. GDOL Response: The GDOL disagrees with the findings related to proof of employment or self-employment or a valid offer to begin employment and proof of wages was not submitted by two PUA claimants. Under the Coronavirus Aid, Relief, and Economic Security Act (CARES Act), claimants did not have to provide proof of employment or self-employment. It was not until Continued Assistance Act (CAA) was enacted December 27, 2020 that such proof was required. The disqualification could not be applied retroactively, as outlined in Unemployment Insurance Program Letter (UIPL) No. 16-20, Change 4. Instance 1: Claimants who established PUA entitlement at the minimum weekly benefit amount were instructed to submit their proof of wages by email. Under the CARES Act, if claimants did not submit proof, federal requirements only allowed for payment of the minimum weekly benefit amount and no disqualification of benefits. The claim cited was originally established and remains established for the minimum weekly benefit amount. In accordance with CAA rules, the claimant was notified to provide proof of employment and wages for weeks paid on or after 12/27/20. To date, no proof has been provided by the claimant. The claimant has been disqualified effective 12/27/20 and an overpayment was established in January 2023. Instance 2: Claimants who established PUA entitlement with a weekly benefit amount greater than the minimum was based on wages entered by the claimant and/or wages reported by the employer. CARES Act only required proof of wages to be submitted. If claimants did not submit proof, federal requirements only allowed for payment of the minimum weekly benefit amount and no disqualification of benefits. Claims established at a higher weekly benefit amount had to be reduced to the minimum amount if no proof was provided. To date, no proof has been provided by the claimant cited. The claim was established above the minimum amount; therefore, benefits were reduced to the minimum amount. In accordance with CAA rules, claimants were notified to provide proof of employment and wages for weeks paid on or after 12/27/20. The claimant has been disqualified effective 12/27/20 and an overpayment was established in November 2022 for weeks paid over the minimum amount under CARES and weeks paid after 12/27/20 under CAA/American Rescue Plan Act (ARPA). (4) Claimants did not self-certify for benefits in 18 instances. GDOL Response: The GDOL disagrees with the findings Claimants did not self-certify for benefits in 18 instances. Employer-Filed Claims (EFC) are submitted by employers on behalf of the claimant. The employer is responsible for attesting to the employment status and weekly earnings of the claimant for the EFC submitted. An affidavit certifying that the employer has obtained earnings from other employment as well as other requirements must be completed before EFCs can be entered or uploaded. Claimants for which EFCs are submitted are considered to be still attached to the employer and are exempt from the requirement to register for employment services per Georgia Employment Security Law Rule 300-2-4-.02. Such individuals are not required to be nor certify on a weekly basis to be able, available and actively seeking work. Additionally, USDOL encouraged states to waive work search requirements for all claimants during the pandemic. (5) Claimant and payment information did not exist in the system of record in one instance. GDOL Response: The identifying information the auditors provided for this claim does not match any claims in our system. Therefore, we are unable to validate the auditor?s finding. Summary The information above is provided for your consideration in dispelling some of the audit findings. GDOL took immediate action to establish the federal UI programs and comply with federal guidance and regulations. There was not a mandatory requirement to complete identity verification at the time most of these applications were submitted. At the start of the pandemic, the identity proofing processes available were Social Security Administration (SSA) verification, Department of Driver Services (DDS) crossmatch and for non-citizens, Department of Homeland Security Systematic Alien Verification for Entitlement (SAVE). As applicable, these processes were performed on all initial regular and employer-filed claims (EFC). Beginning January 2021, PUA applicants were required to complete additional identity verification processes. Beginning in December 2021, all applicants were required to complete identity verification prior to filing a claim for UI benefits. Effective December 6, 2021, the EFC process was revised to require individuals (employees) to complete an EFC profile to include a real-time identity verification before payments can be made. Employers are responsible for submitting the request for the payment to certify to the individual?s employment status, but the individuals must certify their identity and personal information for the claim to be processed. Employees are notified when a claim is filed on their behalf and provided instructions for their portion of completing the EFC process. Additionally, as system deficiencies were identified, changes were made as quickly as possible to mitigate risks of improper payments. Automation of PUA claims was suspended and reviews were handled manually by staff before a determination was released. GDOL established task forces to develop and implement strategies to address the ramped fraud attempts to bypass system and procedural safeguards. We regularly attended fraud meetings with various federal agencies and unemployment agencies from other states to share best practices for combatting fraud. As resources permitted, we did our best to implement these best practices and strategies. Prioritizing system changes was challenging with the time constraints, necessity to build a program based on an established program that operated manually in our state and the demands of all other federal UI programs; but GDOL made every attempt to maximize our system capacity to accommodate the guidelines of each program requirements. Georgia greatly appreciates your time and consideration of our response to the findings and welcome you to contact us if you have any questions. Estimated Completion Date: December 16, 2021 Contact Person: Crystal Singleton, Policy and Procedure Manager Telephone: 404-232-3183; E-mail: Crystal.Singleton@gdol.ga.gov

Responsible Individual: Matthew Zern, Financial Officer Corrective Action Plan: The Greater Johnstown Area Vocational Technical School currently has procedures in place for cash monitoring to ensure compliance with U.S. Department of Education Federal Student Aid guidelines which are similar to the requirements for the HEERF funds. Due to unfamiliarity with the HEERF guidelines during the COVID-19 pandemic, these funds were drawn down in the G5 system earlier than needed. In the future, GJCTC will follow existing procedures to ensure compliance with cash management. Anticipated Completion Date: June 30, 2023.