Corrective Action Plans

FINDING 2022-005 Contact Person Responsible for Corrective Action: Laura Martin Contact Phone Number: 765-584-3149 Views of Responsible Official: Agree with the finding Description of Corrective Action Plan: The Auditor will document the reviewing and approving of project and expenditures report. Anticipated Completion Date: April 30, 2023

Corrective Action Plan September 26, 2023 Little Buns, Inc. (the "Organization") respectfully submits the following corrective action plan ("CAP") for the year ended December 31, 2022. Independent Public Accounting Firm Pettit & Company, LLC 3725 E. Southport Rd., Suite A Indianapolis, IN 46227 Period covered by the audit: Year ended December 31, 2022 The findings from the December 31, 2022 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Finding 2022-001 Financial Close Process Type of Finding: Material Weakness in Internal Control over Financial Reporting Condition and Context: The financial statements provided by management did not include all of the activity of the Organization. There was another bank account and loan that was not recorded on the financial statements that were provided to the auditor. Corrective Action(s) Taken or Planned: In order to fully engage with non-profit regulation, Little Buns, Inc. will create transparency of all non-profit accounts, including fundraising, investment and grant streams by creating a Board of Directors that has knowledge of non-profit regulations. All decisions regarding Little Buns, Inc will flow through the Board of Directors.

Finding 2022-002 Internal Control Over Activities Allowed or Unallowable (ALN# 59.008 COVID-19 Disaster Assistance Loans) Type of Finding: Material Weakness in Internal Control Over Compliance Condition and Context: During the year ended December 31, 2022, the Executive Director was paid a one-time payment in the amount of $60,000 and another $50,000 was paid to an LLC that is owned by the Executive Director?s daughter. There were no services provided to support these payments. Action(s) taken or planned on the finding: Little Buns, Inc. will provide oversight with a paid position of a CPA controller to oversee the fundraising efforts for compliance with all non-profit regulations. In order to fully engage with non-profit regulation, Little Buns, Inc. will create transparency of all non-profit accounts, including fundraising, investment and grant streams. All funds deemed inappropriate will be paid back by the Executive Director. If there are any questions regarding this plan, please call the undersigned at 317-663-8276. Sincerely, Maxine Jeglum, Director

Finding No. 2022-001 Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. Condition: SAH selected option I to calculate lost revenue, which consists of a comparison of actual results during the period of availability to the base calendar year of 2019. For all periods reported in SAH?s Period 2 submission, the reported patient service revenue amounts did not agree to the underlying internal financial statements. Furthermore, SAH did not report actual revenue for Quarter 3 2021 and Quarter 4 2021. Planned Corrective Action: Management will continue to refine processes to more diligently review the lost revenue calculation to ensure such amounts are in accordance with the terms and conditions of the federal award. However, SAH incurred and reported eligible expenses and lost revenue that had the errors in the lost revenue calculation been identified and corrected prior to reporting, SAH would have satisfactorily incurred eligible expenses and lost revenue in excess of the PRF funds received, including interest earned on such funds. Planned Completion Date: Ongoing Person Responsible: Karrie Beach, VP of Finance

FINDING 2022-001 Contact Person Responsible for Corrective Action: Lori Phillips, Clerk Treasurer Contact Phone Number: 260-726-9395 x 224 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Moving forward, management will implement a stronger internal controls system over Federal Grants. This includes segregation of duties for proper oversight and approval. More specifically, management will receive and review all certified payrolls from the contractor to verify that the Wage Rate Requirements are being adhered to. Anticipated Completion Date: 8/28/2023

Procurement Policy Failure: Compliance Requirement: Procurement We have a standard operating procedure stating that for micro purchases not exceeding $3,000, purchasers should use a micro purchase order. Purchaser should have contracts and purchase orders on file for EVERY PURCHSE. We have a new Modernization Coordinator on staff, who has already implemented all SOPs. We also have a new E.D. who checks and approves every purchase order. The proper controls are now in place.

Finding Number: 2022-001 Condition: The Corporation?s controls in place for reporting submissions did not identify that guidelines were not followed related to the reporting of expenses. Planned Corrective Action: The Corporate Controller will request all Portal Submission Documents from the subsidiaries after their completion. The Corporate Controller and VP of Reimbursement will reconcile the portal submission documents completed by the subsidiaries to the documentation provided by our FEMA claims partner to ensure accuracy. If any discrepancies are noted, we will notify the subsidiary CFOs of the irregularities and request they edit the submission with the correct information. Once completed by the subsidiary CFOs, the updated submission documents will be re-reviewed to ensure accuracy. This process will continue until the portal submission documents are accurate. Contact person responsible for corrective action: Brian Balutanski, Vice President and Corporate Controller. Anticipated Completion Date: 06/01/2023

Section III: Finding 2022 ? 003 Deposit Collateralization Agree with finding. The Authority will contact its financial institution and other area financial institutions to meet the proper depository requirements and have depository agreement signed by financial institution.

Section III: Finding 2022-002 Internal Control Structure Material Weakness ? Eligibility, Reporting and Special Tests and Provisions, Repeat Finding 2022-001 Agree with finding. The Authority is relatively small with limited administrative staff. Further, the Board of Commissioners is a volunteer oversight board and not a managing board and does not have the time or expertise to provide the necessary services to correct the internal control deficiencies noted. The Board has reviewed the issue and determined that there are no additional procedures which can be reasonably done to eliminate the deficiencies and accepts them.

Finding 2022-002: Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Housing Voucher Cluster - Section 8 Housing Choice Vouchers - Mainstream Vouchers Federal Catalog Numbers: 14.871, 14.879 Noncompliance ? E. Eligibility ? Tenant Files Non Compliance Material to the Financial Statements: Yes Material Weakness in Internal Control over Compliance for Eligibility Criteria: Tenant Files. The PHA must do the following: As a condition of admission or continued occupancy, require the tenant and other family member to provide necessary information, documentation, and releases for the PHA to verify income eligibility (24 CFR sections 5.230, 5.609, and 982.516). These files are required to be maintained and available for examination at the time of audit. Condition: Based upon inspection of the Authority?s files and on discussion with management, there were documents that were unavailable for examination at the time of audit. Context: There are approximately 2,313 units. Of a sample size of forty-five (45) tenant files, the following was noted: - HUD 9886 Form was missing in 1 file - Verification of income was missing in 2 files - Verification of assets was missing in 1 file - HUD 50058 annual recertification was missing in 4 files - Original Application was missing in 5 files Our sample size is statistically valid. Known Questioned Costs: $215,596 Cause: There is a material weakness in internal controls over the compliance for the eligibility type of compliance related to the maintenance of tenant files. The Authority has not properly considered, designed, implemented, maintained, and monitored a system of internal controls that assures the program is in compliance. Effect: The Housing Voucher Cluster is in material non-compliance with the eligibility type of compliance related to the maintenance of tenant files. Recommendation: We recommend the Authority design and implement internal control procedures that will assure compliance with the Uniform Guidance and the compliance supplement. Finding 2022-002 (continued): Authority Response: MHA agrees with the findings that some tenant file documents were essentially unavailable for examination at the time of the audit and that a system of consistent document filing, and regular file reviews are necessary. The ?missing? documents were subsequently found but in various electronic locations, thereby making them not easily accessible to the auditors. There were also timing issues, in that a recertification was begun in 2022 but not completed or made effective until 2023 once all documents had been received. ? The tenant documents will now be filed in one place, in Yardi as attachments to the Family Detail Info (FDI) screen in the proper subfolder depending upon subject (e.g. Assets, Income, Member). MHA is working to create and label the subfolders needed for this purpose. ? The contractor and internal staff will receive detailed instructions on how to file all documents, from the receipt of documents from the tenant to the commemoration of the transaction in a HUD Form 50058. All will be required to sign a confirmation they received such instructions. ? All new staff responsible for collecting documents, processing transactions and creating 50058s will obtain training in the correct system of filing such documents as part of their on-boarding packet of trainings. ? MHA will institute a quality control procedure for the regular review of random sample files at least quarterly to ensure that the filing system is being followed and the documents are complete and readily found. Views of responsible officials and planned corrective action: Susanne Joyce, HCV Program Manager, is responsible for implementing this corrective action by December 31, 2023.

Finding 2022-003: Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Public and Indian Housing Federal Catalog Numbers: 14.850 Noncompliance ? E. Eligibility ? Tenant Files Non Compliance Material to the Financial Statements: Yes Material Weakness in Internal Control over Compliance for Eligibility Criteria: Tenant Files. The PHA must do the following: As a condition of admission or continued occupancy, require the tenant and other family member to provide necessary information, documentation, and releases for the PHA to verify income eligibility (24 CFR sections 5.230, 5.609, and 982.516). These files are required to be maintained and available for examination at the time of audit. Condition: Based upon inspection of the Authority?s files and on discussion with management, there were documents that were unavailable for examination at the time of audit. Context: There are approximately 456 units. Of a sample size of seventeen (17) tenant files, the following was noted: - HUD 50058 annual recertification was missing in 1 file - Original Application was missing in 2 files - Citizenship Declaration was missing in 1 file Our sample size is statistically valid. Known Questioned Costs: $27,341 Cause: There is a material weakness in internal controls over the compliance for the eligibility type of compliance related to the maintenance of tenant files. The Authority has not properly considered, designed, implemented, maintained and monitored a system of internal controls that assures the program is in compliance. Effect: The Public and Indian Housing Program is in material non-compliance with the eligibility type of compliance related to the maintenance of tenant files. Recommendation: We recommend the Authority design and implement internal control procedures that will assure compliance with the Uniform Guidance and the compliance supplement. Authority Response: MHA agrees with the findings that some tenant file documents were essentially unavailable for examination at the time of the audit and that a system of consistent document filing, and regular file reviews are necessary. The ?missing? documents were subsequently found but in various electronic locations, thereby making them not easily accessible to the auditors. There were also timing issues, in that a recertification was begun in 2022 but not completed or made effective until 2023 once all documents had been received. ? The tenant documents will now be filed in one place, in Yardi as attachments to the Family Detail Info (FDI) screen in the proper subfolder depending upon subject (e.g. Assets, Income, Member). MHA is working to create and label the subfolders needed for this purpose. ? The contractor and internal staff will receive detailed instructions on how to file all documents, from the receipt of documents from the tenant to the commemoration of the transaction in a HUD Form 50058. All will be required to sign a confirmation they received such instructions. ? All new staff responsible for collecting documents, processing transactions and creating 50058s will obtain training in the correct system of filing such documents as part of their on-boarding packet of trainings. ? MHA will institute a quality control procedure for the regular review of random sample files at least quarterly to ensure that the filing system is being followed and the documents are complete and readily found. Views of responsible officials and planned corrective action: Nick Zhou, Chief Financial Officer, is responsible for implementing this corrective action by December 31, 2023.

2022-001 Income Certifications Name of contact person ? Angela Riley, CFO Corrective action ? The Corporation agrees with the finding, and has continued to implement strategies to address these issues throughout 2021 and 2022, including: assembled and deployed a team of external consultants and temporary workers to assist site staff in completing tenant recertifications, hired a team of 6 additional roving property management/compliance teams to cover open property management positions and to support site staff in completing tenant recertifications, developed a new training program to onboard site staff, and developed a monitoring program to set expectations and hold employees accountable to those expectations. Proposed completion date ? Management has begun the corrective action and is expected to have additional internal controls and training done by December 31, 2023.

93.767 Children's Health Insurance Program (CHIP) 93.778 Medical Assistance Program (Medicaid; Title XIX) Eligibility 2022-025 Strengthen Controls to Ensure Compliance with Eligibility Requirements of the Children's Health Insurance Program (CHIP) and the Medical Assistance Program DOM Response: DOM acknowledges OSA's concern regarding the initial review of case files and the prompt action to select and provide a new sample of cases. Historically, DOM has provided a hardcopy of the actual beneficiary case files to OSA. Since those cases were active, an inventory control process, which included a notation in the electronic beneficiary file of the request to send the physical folder to the central office, was implemented. Likewise, upon arrival in the central office, notation of receipt of the files are added to the system prior to providing said files to the auditor. Occasionally, there are multiple files depending on the office with whom a beneficiary communicates, and multiple individual files associated with a family case. Additionally, cases in the sample may also be undergoing redetermination. To ensure that OSA has all the documentation needed for their case review, DOM staff reviews the files prior to sending them to central office. If an adverse eligibility determination is discovered, DOM has an obligation to correct at the time of discovery. As such, changes to the files are noted in the case history, which is available to the auditors. DOM will be transitioning to a paperless environment, which should alleviate any concerns during future audits. Use of Tax Return Resources DOM Does Not Concur. OSA compared eligibility data to state income tax returns. DOM is prohibited from accessing state income tax records per Mississippi Code Annotated ?27-3-73 and currently, does not have access to federal income tax records. DOM maintains that for determining eligibility, it has complied with the CMS-approved state plan. Using the approved CMS MAGI Based Verification plan in effect during the audit time period, the state sought to verify the reported income to the standard of reasonable compatibility, as defined by CMS, through all available electronic data sources. Further, DOM is required to accept the information provided by the applicant and utilize the available verification methods as detailed in the CMS-approved state plan to evaluate the accuracy of the information provided. If an applicant does not report self-employment income, and the tools available to DOM do not reveal such, DOM has performed its due diligence in the eligibility process and complied with the requirements of CMS, DOM's federal regulatory and oversight agency. OSA questioning DOM's determinations based on information that DOM was not provided nor have access to is shortsighted and does not align with the federal regulations that are imposed on this agency. While DOM is only required to use tax return information in certain circumstances, the agency continues to pursue the authority to review state and/or federal tax return information. To date, DOM has not been provided statutory authority to access Mississippi Department of Revenue tax information and is still awaiting IRS approval of the Safeguard Security Risks document. DOM plans to continue to follow the approved federal/state plan for eligibility determinations and will utilize additional resources as they become available. One MAGI beneficiary - DOM did not use taxable unearned income reported on tax return DOM Concurs. The application on file states neither parent has earned income. Although, the unearned income was not included in the initial calculation, adding it did not result in the beneficiary being ineligible. One MAGI beneficiary - self-employment income was reported to MDOM, but MDOM did not request a tax return from the beneficiary. DOM Concurs. The tax return was not requested for this particular beneficiary. This was an oversight, and the issue has been corrected. Two of the 180 MAGI beneficiaries - income was not verified through Mississippi Department of Employment Security DOM Concurs. There were multiple transactions associated with each of the beneficiaries identified. As a result, DOM's eligibility vendor is investigating to determine the reason the MDES search was not performed. One of the 180 MAGI beneficiaries - the beneficiary's case file did not contain an application or verification of income. DOM Concurs. This file could not be located. One of the 300 beneficiaries - auditors were unable to verify that any eligibility redeterminations have been performed since 2018. DOM Does not Concurs. A redetermination was not completed prior to the PHE. During the PHE, DOM was not allowed to performed redeterminations, which would have allowed DOM to update this file. Nine instances - resources were not verified through AVS at the time of redetermination. DOM Does not Concur. This is a prior finding from OSA 2021-041. Please note that all redeterminations in question occurred prior to the OSA audit period (FY22) and were suspended due to the public health emergency from March 2020 to June 2023. The eligibility system was updated in June 2022, after finding 2021-041, to include automatic asset checks within the system processing workflow to eliminate the manual request process and facilitate asset verification through AVS. Again, each instance identified above occurred prior to this implementation. In addition, AVS was checked on the 9 instances OSA sited, which resulted in no change in the eligibility determination. One instance - the beneficiary's case file did not contain a current level of care decision. DOM Does not Concur. DOM disagrees with this finding as redeterminations for the category of eligibility in question were suspended due to the public health emergency from March 2020 to June 2023. The date in question is from July 2021, which falls within this timeframe, and the child would have been eligible regardless. Seventy-three beneficiaries were not included on all of the required quarterly Public Assistance Reporting Information System (PARIS) file transmissions for fiscal year 2022. Of the 73 beneficiaries, six beneficiaries were not included on any quarterly PARIS file transmissions during fiscal year 2022. DOM Does not Concur. Per an amendment to DOM's CMS-approved State Plan, DOM is only required to verify Title XIX applicants and individuals eligible for covered Title XIX services. The above members were covered in Family Planning, which is not considered Title XIX, and did not receive Title XIX services. Therefore, these members should not have been included on any of the PARIS file transmissions. DOM Corrective Action Plan: a. All issues identified will be reviewed with regional office staff. Further, examples of these issues will be included in annual training sessions performed by Eligibility. DOM will continue to work with the vendor to ensure that income is verified through MOES, as applicable, and to implement controls that will limit this issue in the future. Further, DOM is implementing an electronic storage system to house all documents associated with applicants/beneficiary files. b. Cindy Bradshaw c. December 31, 2024

SUBRECIPIENT MONITORING ALN Number 93.558 Temporary Assistance for Needy Families (TANF) 93.575, 93.596 Child Care Development Fund (CCDF) 2022-017 Strengthen Controls over Subrecipient Monitoring for the Child Care Development Fund (CCDF) and Temporary Assistance for Needy Families (TANF) Programs to conform with Uniform Guidance. Response: MDHS concurs that it needs to strengthen controls over subrecipient monitoring for the Child Care Development Fund (CCDF) and Temporary Assistance for Needy Families (TANF) programs to conform with Uniform Guidance. Corrective Action Plan: 1. Please refer to MDHS response in 2022-018 for measures already taken and ongoing by MDHS and all future corrective actions. 2. Responsible Parties: Kameron Harris, Chief Compliance Officer, Director of Monitoring, Laketha Gilmore 3. Anticipated Completion Date: This corrective action has been implemented and is ongoing.

SUBRECIPIENT MONITORING ALN Number 93.568 Low Income Home Energy Assistance (LIHEAP) 2022-018 The Mississippi Department of Human Services Should Strengthen Controls Over Onsite Monitoring for the Low-Income Home Energy Assistance Program (LIHEAP). Response: MDHS Concurs that controls should be strengthened over On-Site monitoring for the LIHEAP Program. MDHS also concurs with the following specific recommendations of the OSA and incorporates those recommendations as the foundation for the MDHS Corrective Action Plan (CAP) related to this finding. Corrective Action Plan: 1. Strengthen controls over the subrecipient monitoring process: A. The Office of Compliance, Division of Monitoring has made significant strides in strengthening controls over the subrecipient monitoring process. The Division continues to review and update the processes and procedures as necessary to ensure processes are adequate and effective. Staff are constantly notified/trained on updates to policies, procedures, and regulations to ensure continued compliance with monitoring the agency's subgrant agreements. B. Responsible Party: Kameron Harris, Chief Compliance Officer, Director of Monitoring, Laketha Gilmore C. Completion Date: This corrective action has been implemented and is ongoing. 2. Ensure subgrants are monitored timely and the Report of Findings is issued in a timely manner: A. The Office of Compliance, Division of Monitoring continues to improve upon the monitoring review process. The Division has implemented timeliness requirements to ensure the Agency's compliance with the monitoring process. B. Responsible Parties: Kameron Harris, Chief Compliance Officer, Director of Monitoring, Laketha Gilmore C. Anticipated Completion Date: This corrective action has been implemented. 3. Maintain all supporting monitoring tools, reports, and correspondence in the monitoring file: A. The Division of Monitoring has implemented a quality control measures to ensure all required documentation is included in the monitoring file. B. Responsible Parties: Kameron Harris, Chief Compliance Officer, Director of Monitoring, Laketha Gilmore C. Anticipated Completion Date: This corrective action has been implemented.

84.010 Title I-Grants to Local Education Agencies 84.367 Title II - Supporting Effective Instruction 84.425 Education Stabilization Fund Reporting 2028-028 Strengthen Controls to Ensure Compliance with Federal Funding Accountability and Transparency Act (FFATA) requirements Response: The MDE does not concur with this finding. The MDE maintains a process to repo1i FFATA information timely. The MDE is hampered in its reporting, however, by known issues to the FFATA reporting system. For example, if the MDE needs to revise a report it must submit a request to the FSRS Helpdesk to delete the previously-uploaded report before it can upload a revised repo1i. This revised report is required when entities DUNS/UEI became valid and/or when allocations were revised. In these instances, the repo1iing date will be the date of the revised repo1i, rather than the original report. The MDE made good faith effo1is to upload this information in a timely manner. Unfortunately, the FSRS system cannot provide the transactions on each federal award to show when an original file was uploaded into the system or provide a report on the end-user activity in the system. In addition, the FSRS system experiences frequent system errors that prevent the MOE from uploading its repo1is in a timely fashion. Thus, the MDE is unable to demonstrate exactly when the file was initially submitted to the FSRS system or upload files that are timely prepared. These common reporting and system issues are known by and affect all users. Until these issues are corrected, the MDE may continue to experience difficulty in uploading reports. All current reports have been uploaded and are visible within the FSRS system. Corrective Action Plan: A. The MDE will maintain a copy of the PDF file of the upload for the initial submission and will electronically provide a date stamp on the document indicating its upload. This process was implemented on June 30, 2023, and is monitored by Elisha Campbell, Executive Director.

21.023 COVID-19 Emergency Rental Assistance (ERA) Eligibility 2022-031 Strengthen Controls to Ensure Compliance with Eligibility Requirements for the Emergency Rental Assistance Program Response: DFA was simply a pass-through agency of the funds and was required to draw down the funds in light of an impending federal deadline. It is not possible for DFA to assess and conduct eligibility determinations as it has not been appropriated any funds nor does it have the personnel or other resources to do so. Corrective Action Plan: A. Mississippi Home Corporation has eligibility and fraud prevention policies in place; however, this grant program is no longer accepting applications. B. N/A C. N/A

ALN Number 17.225 ? Unemployment Insurance 2022-022 ? Strengthen Controls to Ensure Compliance with Reporting Requirements for Unemployment Insurance. Cat ? L, Finding Type, A, C2 (MW, IMNC) MDES Response: During the pandemic emergency, MDES relied upon the procedures encoded in ReEmployMS to generate the non-emergency tasks. Currently, the Policy and Compliance staff conduct random reviews and tests of both files and reports for accuracy validation using samples identified by the US DOL. The ReEmployMS system generates and stores flat files containing the specific individual records to create the ETA reports. When an error occurs in the generated reports, the staff receive alerts to review the data and reconcile the report. If the system does not generate an error, the information passes as accurate and verification occurs later upon the generation of test samples. Corrective Action Plan: After the relative subsidence of the COVID-19 crisis and review of our activities, MDES better appreciates the value of ensuring that appropriate staff review reports and of maintaining documentation for each examination. Moreover, MDES currently has procedures in place to ensure the review of all reports and to document such activities.

ALN Number 17.225 ? Unemployment Insurance 2022-020 ? Strengthen Controls to Ensure Compliance with Special Tests ? Program Integrity ? Overpayments Requirements for Unemployment Insurance. Cat ? N, Finding Type, A, C1 (MW, MNC) MDES Response: MDES respectfully disagrees with this finding because the flexibility to present its interpretations of federal guidance as impacted by state law to DOL for approval remains a cornerstone of the federal-state dynamic of the unemployment insurance system. In addition, the federal pandemic programs that Congress required MDES to institute involved broad, complex, and overlapping processes. MDES worked tirelessly to ensure that we followed all federal guidelines to the best of our ability while promptly enacting the pandemic program. In addition, DOL issued many updates to the federal guidelines including program changes via UIPLs. These UIPLs also referenced prior UIPLs and guidelines creating a high level of complexity when the pandemic demanded swift decisions and rapid implementation of program changes to provide vital assistance to Mississippi?s citizens suddenly thrust into unemployment. MDES will continue to work with DOL regarding its interpretations of federal program guidance as affected by state law. MDES maintains an on-going review of these programs to determine proper and timely payments and offsets under each program and will make necessary programmatic changes to ensure we properly issue payments and make offsets in compliance with federal and state guidelines. On June 19, 2023, MDES implemented an updated process to adjust the offset percentages for these programs.

Finding 2022-003 Federal Agency Name: National Endowment for the Arts Program Name: Promotion of the Arts Partnership Agreement CFDA # 45.025 Finding Summary: The Organization has a process for allocating employee wages based on hours worked, however, retroactive pay adjustments, bonus allocation for one employee, and one pay period for one employee did not follow this process. The controls in place did not operate as designed and failed to detect errors in the allocation of employee pay to the grants. Responsible Individuals: Anne Romens, Vice President and Emily Anderson, Chief Administrative Officer Corrective Action Plan: Arts Midwest uses Paylocity, a third-party payroll provider, for employee time tracking and payroll processing. Salary and benefit allocations to departments and grants are based on labor distribution reports generated by Paylocity. The Finance Team will review and verify report parameters and details to ensure they are accurate before the payroll costs are imported into the accounting system. In addition, the finance and operations teams will verify any one-time pay adjustments are correctly calculated and allocated based on related period of hours worked. With the start of a new Chief Financial Officer, this will be a priority for the first quarter of 2023. Estimated Completion Date: March 31, 2023

Corrective Action Plan For the year ended December 31, 2022 U.S. Department of Housing and Urban Development: The Lehigh County Housing Authority respectfully submits the following corrective action plan for the year ended December 31, 2022. Auditor: Novogradac & Company, LLP Certified Public Accountants 1144 Hooper Avenue, Suite 203 Toms River, New Jersey 08753 The findings from the December 31, 2022 schedule of findings and responses are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Financial Statement Findings There were no findings relating to the financial statements which are required to be reported in accordance with Government Auditing Standards. Federal Award Findings and Questioned Costs Finding 2022-001: Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Section 8 Housing Choice Vouchers Program Federal Catalog Numbers: 14.871 Noncompliance ? N. Special Tests and Provisions ? Housing Quality Standards Non Compliance Material to the Financial Statements: Yes Material Weakness in Internal Control over Compliance for Special Tests and Provisions Criteria: Housing Quality Standards Inspections. The PHA must inspect the unit leased to a family at least biennially to determine if the unit meets the Housing Quality Standards (HQS) and the PHA must conduct quality control re-inspections. The PHA must prepare a unit inspection report (24 CFR sections 982.158(d) and 982.405(b)). Condition: Based upon inspection of the Authority?s files and on discussion with management, there were units that were not reinspected within the biennial reinspection period of two (2) years. Finding 2022-001: (continued) Context: There are approximately 1,043 Section 8 Housing Choice Vouchers units. Of a sample size of twenty-three (23) tenant files, five (5) biennial inspections were not completed in a timely manner. Our sample size is statistically valid. Known Questioned Costs: $42,870 Cause: There is a material weakness in internal controls over the compliance for the special tests and provisions type of compliance related to HQS inspections. The Authority has not properly performed HQS inspections in compliance with program requirements following the expiration of HUD waivers as a result of a software error. Effect: The Section 8 Housing Choice Vouchers Program is in material non-compliance with the special tests and provisions type of compliance related to HQS inspections. Recommendation: We recommend the Authority design and implement a corrective action plan that will assure compliance with the Uniform Guidance and the compliance supplement. Authority Response: The Authority accepts the recommendation of the auditor, and will make the several changes to its inspection process to ensure enforcement of Housing Quality Standards (or any subsequent replacement). Views of responsible officials and planned corrective action: Helen Khouli, HCV Program Coordinator, is responsible for implementing this corrective action by December 31, 2023.

Mississippi Valley Fair respectfully submits the following corrective action plan for the year ended August 31, 2022. Name and address of the public accounting firm: Olsen Thielen & Co., Ltd. 300 Prairie Center Drive, Suite 300 Eden Prairie, MN 55344 Current Findings on the Schedule of Findings, Questioned Costs, and Recommendations Finding No. 2022 -001 COVID-19 Shuttered Venue Operators Grant Program Recommendation ? The Organization should continue to monitor expenditures to ensure they are recorded in the correct period and incorporate monitoring for unusual transactions, in addition they should monitor and incorporate procedures to ensure controls are in place and operating effectively. Comments on the Recommendation - Management acknowledges the material weakness and is in the process of creating written control policy and procedures that will be in place if they ever receive federal awards in the future. Action Taken ? Management is in the process of creating written internal control policies and procedures and expects to have this process completed by April 1st 2023. Corrective Action Plan prepared by: Name: Shawn Loter Position: General Manager Telephone Number: 563-326-5338

Finding No. 2022-002 Material Weakness Personnel Responsible for Corrective Action: Archdiocesan Finance Office, Marilisa Heiderscheid (Controller) Anticipated Completion Date: March 31, 2023 Corrective Action Plan: Management will implement procedures to assure that all costs charged to the Provider Relief Fund are reviewed by a competent individual, and those reviews will be documented.

The Auditor discovered that two weekly reports for September 2021 lacked documentation. Compared to the number of tests reported overall in 2021-2022, the number of unverified tests constitute a finding for non-compliance and indicative of issues surrounding record keeping. It has since come to light that some tests were inconclusive but were not identified as such leading to a higher test count versus negative/positive counts. No program specific corrective action steps shall be instituted as this is not an on-going program. However, it will be important to laboriously work out the details prior to an agreement and specify the need for clerical support in future agreements. In addition, the district will review its records and verify alignment with reports submitted to the Los Angeles COE.

October 29, 2022 Schedule of Findings and Questioned Costs Corrective Action Plan For: 2022-001 ? Excess Fund Balance in Food Service Condition: As of year-end the District had a fund balance in the non-profit food service fund in excess of three months? operating expenses by approximately $213,867.22. Corrective Action to Be Taken: The District is updating their Spenddown Plan for the excess fund balance. The Food Service Director and the Assistant Superintendent have already identified areas where there are needs for upgrades or enhancements needed. Over the next few months the Excess Fund Balance will get used to improve the Food Service Program. Responsible Parties for Implementation of Corrective Action: Food Service Director with follow up by the Assistant Superintendent. Date of Anticipated Completion of Corrective Action: The corrective action plan was immediately implemented during the fall of 2022. Sarah M. Glann Assistant Superintendent