Corrective Action Plans

Names of Responsible Individuals: Brian Emery, Associate Director Financial Aid and Chad Wick, Director Financial Aid Corrective Action: During the 2023 and 2024 fiscal years, the Financial Aid office experienced several staffing changes, including the termination of the Financial Aid Director. The newly hired staff did not receive the proper training to perform their roles effectively. This led to errors in verifying certain data when performing verification. The previous Financial Aid Director was terminated before the prior corrective action plan could be completed. In March 2023, a consultant firm was engaged to assist with the 2024 fiscal year. The Financial Aid office will implement a Quality Assurance two-step verification process. The financial aid advisor will work with the student to gather necessary documents and perform the original verification. The Associate Director of Financial Aid will review these verifications and update them in Colleague to be transmitted to COD for corrections if needed. The Financial Aid office will run a report to identify all students selected for verification for 2023- 2024 and review them for accuracy. If any corrections are needed they will be updated and awards will be adjusted as needed. Anticipated Completion Date: June 30, 2024.

Names of Responsible Individuals: Chad Wick, Director Financial Aid and Brian Emery, Associate Director Financial Aid Corrective Action: The University will transition from a manual awarding process to an automated process. The Financial Aid office was awarding this manually which led to mistakes when ISIR data changed or other awards were added or removed. FSEOG funds were used to assist students to pay off balances allowing them to register for the next semester. During the 2023 and 2024 fiscal years the Financial Aid office experienced several staffing changes including the termination of the Financial Aid Director. In March 2023, a consultant firm was engaged to assist with the 2024 fiscal year. The Financial Aid office will review all 2023-2024 FSEOG awards to ensure that student aid is calculated, awarded and disbursed correctly. The Financial Aid office will run a Fund Management Report to obtain a list of all students who were awarded FSEOG and compare that to the Pell Fund Management Report. This will ensure that all students who received FSEOG funds were also awarded Pell. The Financial Aid office will then review the amounts of the FSEOG awards to make sure no one was awarded more than the maximum threshold. The Financial Aid office will review the COA calculation for each student awarded FSEOG to verify that it was calculated correctly. For 2024-2025 the Financial Aid office has modified the packaging rules to automate the packaging of FSEOG which will eliminate any manual changes to the award. This should ensure that only students eligible for the award receive it and the amount is correct. The Financial Aid office has also modified the setup of their Student Information System for 2024-2025 so that the COA will be automatically calculated which should eliminate the need for any manual calculating of COA and eliminate improperly calculated COAs. Anticipated Completion Date: June 30, 2024

Finding Number: 2023-002 Planned Corrective Action: Cleveland Play House had extensive turnover during the 2022 and 2023 fiscal years which resulted in several vacancies, including the Director of Finance position, for a significant portion of the year. As a result, many of the reports that are standard practice in our organization were not being completed. In addition, the filing of certain documentation to support expenditures was not being done consistently. The Director of Finance position was not filled until November 2022. As a result, documentation of allowable expenditures is being addressed for the fiscal 2023 audit. In addition to turnover, the organization transitioned to a new general ledger system with a new chart of accounts in fiscal year 2022. As a result of this transition and the vacancies mentioned above, certain data pertaining to the federal programs was not being captured. Management has informed all staff of the requirements to track federal programs within the general ledger accounts. Anticipated Completion Date: September 30, 2024 Responsible Contact Person: Erica Tkachyk, Director of Finance

Charter School Program - Assistance Listing No. 84.282 Recommendation: We recommend the School ensure policies and procedures for payroll expenditures for grant programs be charged to the federal grant based on approved hours worked in the program. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Options Schools, Inc. will implement policies and procedures for payroll expenditures charged to federal grant programs that track approved time worked. Name(s) of the contact person(s) responsible for corrective action: Jack Colwell Planned completion date for corrective action plan: July 1, 2023

This was noted in last year's audit but was identified late in the fiscal year. The time required to do the due diligence and implementation was part of our timesheet review system was not fixed until after June 2023. As noted in last year's goal, Sewall administration completed a review of payroll companies and committed on a new system that began in October 2023. Along with that, we have organized a new internal system of tracking staff's time given the complexities of the many blended funding sources. We have also implemented a regular review and supervision of time sheet allocations.

Special Education Cluster – Assistance Listing No. 84.IDEA Recommendation: We recommend management implement procedures to ensure that salaries charged to the grant are appropriate and are supported by the required time and effort support and that a consistent policy is applied. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Moving forward all Time & Efforts Records for federal grant funded positions will be on a single schedule (December and June) of each calendar year and tracked by each program department with support from administrative assistants. All forms will be collected electronically and remain on file in one central location in the Finance Department through Grants. Name(s) of the contact person(s) responsible for corrective action: Shelly Chin – Administrator of Communications, Grants, Partnerships & Strategy Planned completion date for corrective action plan: This will be an ongoing procedure that will be implemented immediately.

CORRECTIVE ACTION PLAN January 22, 2024 U.S. Department of Education Richmond Area Multi-Services, Inc. (RAMS) respectfully submits the following corrective action plan for the year ended June 30, 2023 Name and address of independent public accounting firm: Lindquist, von Husen & Joyce, LLP 301 Howard Street Suite 850 San Francisco, CA 94105 Audit period: July 1, 2022 to June 30, 2023 The findings from the December 20, 2023 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers in the schedule. FINDING - FEDERAL AWARD PROGRAMS AUDIT CA DEPARTMENT OF REHABILITATION Finding no. 2023-001: Allowable Cost Criteria: Title 2 U.S. Code Part 200.430(i)(1)(vii) requires that there is documentation of personnel expenses charged to the grant, including support to reflect the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one award. Condition: Certain salary amounts billed to the grant were incorrectly allocated, hence overstating the salary billed to the grant. One employee’s salary was allocated 25% to the major program (AL #84.126) from their date of hire in April 2023. Through June 2023, whereas the allocation should have been 2.5% resulting in a $3, 227 over-charge. Another employee hired in June 2023 worked 80.23% for the same major program, but the program was billed for 100% of their salary, resulting in $865 over-charge. Cause: RAMS miscalculated the salary amount that should be charged to the grant which caused the overstatement of their cost-reimbursement billing due to using incorrect time allocation. Effect: Salary costs charged to the program that were unsupported in accordance with allowable cost principles. Questioned Costs: The total amount of salary tested during the audit was $66,576, representing approximately 10% of salary charges to the major program. The amount of questioned costs identified above in relation to the total amount sampled was 6.15% Auditor’s Recommendation: RAMS should consider creating appropriate procedure to monitor salary allocation calculations and ensure that all costs billed are supported by adequate documentation. Action Taken: Subsequent to year-end, RAMS changed its billing procedure to prevent over-billing or inaccurate allocation of payroll costs by adapting a cost allocation method based on the actual hours reported by employee and not the estimated ours used in preparation of the budget. On July 24, 2023, the program manager, division director, billing specialist and finance manage met to review and implement new billing procedure. The effective date of this change was July 1, 2023. If the U.S. Department of Education has questions regarding this plan, please call Eduard Agajanian at 408-394-8778. Sincerely yours, Eduard Agajanian, CFO Richmond Area Multi-Services, Inc.

The City has studied its existing procedures and Information Technology (IT) resources in relation to the three noted exceptions. We have identified how the City’s procedures for inspectors lead to the exceptions and the conditions that allowed for the documentation and evidence of resolved inspection failures to be insufficient: • Since 2017, the City has served as a demonstration agency for what is now HUD’s final National Standards for the Physical Inspection of Real Estate (NSPIRE). The purpose of the demonstration was to conduct Housing Quality Standards (HQS) inspections and inspections under the test protocol simultaneously, with some inspectors using HQS and some inspectors using the test standards. The test standards were conducted using electronic devices so the inspection results could be communicated to HUD, and the HQS inspections continued to be documented using HUD Form 52580. • Utilizing two methodologies for inspection documentation over a time span of greater than five years lead to inconsistent training of new staff, and inconsistent methods and expectations for documenting failed inspection results and follow up. • This condition was exacerbated in Calendar Year 2021 and 2022 when the City began the “catch-up” inspections required by HUD after the COVID-19 inspection waivers. To resolve these issues and correct the conditions going forward, the City will: • Design and implement an inspection application (app) to be used on the inspectors’ mobile devices. The app will be based on HUD’s new NSPIRE Inspection Tool and Checklist. This document has not been assigned a HUD Form number, but is available for review on HUD’s NSPIRE website. The app will be functional on mobile devices even when there is no cellular signal or WiFi connectivity by storing the data, which will be downloaded by the inspector. • The app will include the following features to ensure that documentation is completed properly and timely: - An electronic signature will be required for all inspections, regardless of whether the inspection passed or failed. - An auto-generated summary report of the day’s failed inspections will be emailed to the Supervisors and to the inspector who completed the failed inspection. The report will include the family and owner name, the unit address, identification of the failed items, to whom the responsibility for resolving the failed item is assigned (either family or owner), and the deadline by which the failed items must be resolved. - An auto-generated letter to the family and owner will be mailed and/or emailed within 2 business days of the completed inspection. The letter will include the family and owner name, the unit address, identification of the failed items, to whom the responsibility for resolving the failed item is assigned (either family or owner), the deadline by which the failed items must be resolved, and the potential date of termination if the failed inspection is not resolved. This letter will replace the Failed Inspection Memo which is currently being used by the City to communicate inspection failures. - The app will send email notifications to the Supervisors and inspector beginning 10 days in advance of the repair deadline reminding them that the inspection has not been resolved. - The inspector will use the app to document the resolution of the inspection by indicating what evidence the inspector used to demonstrate the repaired/resolved item. - The inspector will use the app to assign an extension of the deadline when necessary and appropriate. - If a failed inspection has not passed by the deadline or extension, the app will alert the inspector and Supervisor to either document the resolved inspection items or begin the termination process. The City believes that automating these aspects of the failed inspection procedures will prevent the conditions noted in the audit findings by streamlining documentation for the inspectors, alerting supervisors of failed inspections, and providing a consolidated report across all inspectors that can be reviewed regularly. The City has already started the inspection app design process with the IT department, capitalizing and expanding on an existing app that inspectors use for scheduling inspections. When the inspection app is ready to test, the lead inspector, Sylvia Coombs, will begin using it immediately and communicate any feedback to Elizabeth Durham, Rebecca Lane and the IT department. The City anticipates the app will be ready for testing by March 31, 2024. When the app has been tested and refined, Sylvia Coombs and Elizabeth Durham will train the staff in its use and communicate the requirement and expectation that the app is replacing the paper HUD Form 52580 and the Failed Inspection Memo. This change will be implemented by April 30, 2024. Elizabeth Durham and Rebecca Lane will be responsible for monitoring the results of these changes. Responsible Party: Elizabeth Durham Acting Manager Housing and Community Services Department Rebecca Lane Program Specialist Housing and Community Services Department Anticipated Implementation Date: April 30, 2024

Corrective action plan: • On the first Friday of each month, the Housing Choice Voucher Program staff meets to discuss program policies and procedures for training purposes. At each meeting, specific aspects of administering the program are reviewed, along with the related HUD policies. Staff members are given the opportunity to ask any questions on any procedures or policies they may not understand. Activities from the Nan McKay Rent Calculation training are passed out to staff to complete individually. After staff completes the activity, the answers are reviewed as a group. Other activities take place which involve the staff answering questions regarding various case studies of situations that may occur in the daily activities of administering the HCV Program. • January 9th – 11th, all HCV and PBV Specialist received Combo HCV/LIPH Rent Calculation training with HOTMA updates from Nan McKay and Associates. • Review and update Administrative Plan/SOP with Policies and Procedures to ensure all staff is familiar with policies and procedures. • Staff restructuring • In-service meetings with Compliance Specialist as staff challenges some write ups of deficiencies to ensure that there are mutual understandings of policies. • HCV/Occupancy Specialists have been instructed to triple check all certifications for accuracy to mitigate the possibility for careless errors PERSONS INVOLVED HCV Case Management Staff Asset Manager RAD Project Based Voucher Community Manager Compliance Specialist Compliance Supervisor HCV Program Director Occupancy Specialist MONITORING The Compliance Supervisor and Specialist will continue to monitor files. The Compliance Supervisor and Specialist will begin adding the CFR Regulation and or Administrative Plan Policy and page number to each deficiency write-up to assist staff in understanding the error so that staff will not make consistent errors. The Compliance Supervisor will provide to staff recommendations for improvement. It is hopeful that a greater number of participant files will be audited throughout the year for both the HCV Program and for the PBV communities. On the first Friday of each month, the Housing Choice Voucher Program staff meets to discuss program policies and procedures for training purposes. During these meetings specific aspects of administering the program are reviewed, along with the related HUD policies. Staff members are given the opportunity to ask any questions on procedures or policies they may not understand. During many meetings, activities from the Nan McKay Rent Calculation training are passed out to staff to complete individually. After staff completes the activity, the answers are reviewed as a group. Staff also answers questions regarding various case studies that may occur in the daily activities of administering the HCV Program. We also have NRHA’s Compliance staff provide training to review common errors and to discuss any areas staff may have that are gray with audited files. Staff has also gone through an intensive training on the common errors per NRHA’s Compliance Department. Quarterly Quality Control trainings are held with caseworkers lead by the NRHA Compliance Department to address concerns and common errors. The Admission and Continued Occupancy Policies (ACOP) and Administrative Plan policies and procedures are reviewed to ensure that all staff has a clear understanding of the proper ways of calculating income, applying allowances, using proper payment standards, and approvals of lease ups and completion of certifications. A departmental quality control team was established to ensure there is consistency of policies and procedures and that when new procedures are implemented the processes are properly documented and disseminated to all staff. A departmental quality control sub-team was formed after the audit to include the actual custodians of program participant files comprised of:  1 Tax Credit PBV Property Manager  1 LIPH Property Manager  1 Compliance Specialist  1 Occupancy Specialist  1 Senior HCV Specialist  1 Tax Credit Administrative Assistant NRHA Caseworkers and Administrative Staff have been instructed to triple check all certifications for accuracy to mitigate the possibility for careless errors. The NRHA Compliance Department continues to audit files for the HCV Program to ensure that files are being processed properly; income calculated correctly, verifications are in the file, HAP payments issued are correct, and that units are inspected timely. Findings are noted and must be corrected by the Case Worker or Administrative Staff and the file is reevaluated by the Compliance Department to ensure findings were corrected. NRHA Caseworkers and Administrative Staff have been instructed to triple check all certifications for accuracy to mitigate the possibility for careless errors. The NRHA Compliance Department continues to audit files for the HCV Program to ensure that files are being processed properly; income calculated correctly, verifications are in the file, HAP payments issued are correct, and that units are inspected timely. Findings are noted and must be corrected by the Case Worker or Administrative Staff and the file is reevaluated by the Compliance Department to ensure findings were corrected. NRHA will continue to investigate the possibility of increasing the number of program participant files reviewed by the Compliance Department. NRHA has begun contract negotiations with a new software vendor. It is the feeling of the agency that with a different software platform the errors being made will lessen as the information gathered to perform rent calculations will be in a more automated form. It is anticipated that this will lessen staff time needed to enter the information and thus allow for more time to be spent verifying accuracy of information. The timeline for implementation is for the software to be live at the beginning of the 2026 fiscal year. This over-riding strategy is to be done in conjunction with the steps outlined below to mitigate this situation.

Higher Education Institutional Aid – Fostering Inclusive Excellence for STEM Achievement – Assistance Listing No. 84.031C Recommendation: We recommend the University calculate the indirect costs when the direct cost is incurred instead of claiming the amount per the budget to ensure indirect costs are consistently calculated and allocated throughout the grant term. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to the finding: The Finance department implemented a quarterly process aimed at accurately calculating indirect costs, ensuring their recognition period when expenses are incurred. Name(s) of the contact person(s) responsible for corrective action: Shalini Patel, Controller Planned completion date for a corrective action plan: April 1, 2024

Federal Supplemental Educational Opportunity Grant; Federal Work Study Program; Federal Pell Grant Program; Federal Direct Student Loans – Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend the University review its policies and procedures related to Title IV outstanding checks to ensure they are being returned to the Department of Education after 240 days. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Student Accounts initiated a thorough review with Finance and Financial Aid to ensure timely return of Title V funds to the Department of Education of uncashed refund checks exceeding 240 days. This includes documenting new procedures in our Policies and Procedures manual and providing staff training. Planned Completion Date for Corrective Action Plan: June 30th, 2024 Name(s) of the contact person(s) responsible for corrective action: Mariela Henriques, Director of Student Accounts

FINDING NO. 2023-002 Statement of Condition: Management only made nine (9) of the twelve (12) monthly required reserve deposits, leaving the account underfunded by $4,053 at June 30, 2022; for the year ended june 30, 2023, only $2,702 of the required $16,212 in deposits were made, leaving the account behind schedule by another $13,510, for a total deficiency of $17,563. Auditor Recommendation: Management agrees with the finding, and has taken corrective actions which include communication with the Project Accountant and Regional Manager. All future deposits the replacement reserve will be made as required in the regulatory agreement. Action Taken: Senior management has discussed the deficiency with the Project Accountant and Regional Manager. All future deposits the replacement reserve will be made as required in the regulatory agreement assuming there is sufficient cash in the operating account to make the deposit. -

Department staff has reviewed the Legislative Audit Bureau’s (LAB) interim audit memo for Finding 2023-300: Eligibility for the Children’s Health Insurance Program. This is the department’s Corrective Action Plan. Recommendation (2023-300): Eligibility for the Children’s Health Insurance Program We recommend the Wisconsin Department of Health Services work with the federal government to resolve these improper payments, including the determination of the total amount of improper payments, and return these amounts to the federal government, as appropriate. Wisconsin Department of Health Services Planned Corrective Action: The Division of Medicaid Services (DMS) acknowledges that we maintained eligibility under the Children’s Health Insurance Program (CHIP) for individuals who had turned age 19, including SCHIP participants. It was our overarching policy to not terminate health care coverage upon certain changes in circumstances for Medicaid participants during the federal public health emergency (PHE). To comply with this policy, DHS made system changes at the beginning of the pandemic to maintain eligibility for all participants. After CMS provided additional information specific to SCHIP, DHS considered whether to make the necessary system changes to terminate SCHIP participants who turned 19 during the public health emergency. Because of the system limitation and DHS’s overarching goals to maintain continuous coverage, amongst other reasons, DHS decided to temporarily keep all CHIP participants enrolled until the public health emergency ended. DMS leaders met with CMS leaders on May 11, 2022, to discuss this compliance issue and related systems limitations. During that meeting, CMS indicated that they understood the system and communication challenges of having a single program that combines Medicaid and CHIP. CMS also acknowledged that the federal public health emergency was likely to end at any time, so making the required system changes would not be prudent. CMS said they would follow up with Wisconsin if they determined that further state action was needed, but they did not communicate to us after the meeting that they felt the compliance issue needed to be addressed. This confirmed the Medicaid Director’s decision to not pursue costly systems changes to support a change that might only be needed for a short period of time. After the PHE ended, DHS took proactive steps to identify aged-out CHIP participants and ensure that their eligibility was redetermined in the first two months of unwinding. In contrast to the rest of the CHIP and Medicaid population, whose renewals were distributed over a 12-month period from June 2023 through May 2024, these members’ renewals were accelerated to June and July 2023, so that their CHIP coverage would end as soon as possible after the end of the PHE. While we agree conceptually with the finding, the questioned costs identified do not consider that many (if not most) of the ineligible members would have been eligible for Medicaid as childless adults upon aging out of the CHIP program. We will discuss this likelihood with CMS and if necessary, use data available in our CARES eligibility system to assess how many of these members did retain eligibility as childless adults or in other categories of Medicaid after completing renewals in June and July. Anticipated Completion Date: March 31, 2024 Person responsible for corrective action: Jori Mundy, Director Bureau of Eligibility and Enrollment Policy, Division of Medicaid Services jori.mundy@dhs.wisconsin.gov. Rebuttal from the Wisconsin Legislative Audit Bureau - As stated in the finding, and as acknoledged by DHS, DHS maintained continous eligibility for SCHIP participants who were over age 19. This eligibility requirement continue through the public health emergency. Since CHIP and MEDICAID are separate programs, consideration of whether these participants could have been eligible for the Medicaid program would not have been part of our audit. Payments to providers for these participants were funded by SCHIP and not the medicaid program.

I am writing to you in response to the finding 2023-500: Coronavirus State and Local Fiscal Recovery Funds. I agree with the finding and recommendation that was identified during the audit. Please see our below action plan that was conducted as soon as we were made aware of the issue: Corrective Action Plan Finding 2023-500: Coronavirus State and Local Fiscal Recovery Funds—Unallowable Costs Planned Corrective Action: Communication was sent out on October 2nd, 2023, to the Division of State Patrol on what classifications were deemed allowable for reimbursement to prevent future unallowable costs. On October 9th, 2023, a journal was completed for $2,173.12 to remove the unallowable costs from the grant. Lastly, on October 10th, the process of reviewing and approving the expenditures being submitted for reimbursement are now completed in three different organizational areas in the Department to ensure compliance with the MOA. Anticipated Completion Date: Completed on October 10th, 2023 Person responsible for corrective action: Cody Castillo, WisDOT Controller Division of Business Management, Bureau of Financial Management Cody.Castillo@dot.wi.gov

Department staff has reviewed the Legislative Audit Bureau’s (LAB) interim audit memo for Finding 2023-309: Coronavirus State and Local Fiscal Recovery Funds – Unallowable Costs. This is the department’s Corrective Action Plan.  Recommendation (2023-309): Coronavirus State and Local Fiscal Recovery Funds – Unallowable Costs We recommend the Wisconsin Department of Health Services ensure it retains documentation to support the costs charged to the Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) program, and work with the Department of Administration and the U.S. Department of the Treasury to resolve the questioned costs we identified. Wisconsin Department of Health Services Planned Corrective Action: As CSLFRF programs have matured, DHS has continued to review and revise our processes. DHS will take this opportunity to ensure that procedures surrounding approving of invoices, storing of documentation, and comprehension of the period of performance are updated and understood by our grant administrators. DHS will work with DOA and US Treasury to resolve the questioned costs. Anticipated Completion Date: June 30, 2024 Person responsible for corrective action: Natalie Easterday, Director Office of Preparedness and Emergency Health Care, Division of Public Health natalie.easterday@dhs.wisconsin.gov

Department staff has reviewed the Legislative Audit Bureau’s (LAB) interim audit memo for Finding 2023-307: Coronavirus State and Local Fiscal Recovery Funds – Unallowable Costs. This is the department’s response.  Recommendation (2023-307): Coronavirus State and Local Fiscal Recovery Funds – Unallowable Costs We recommend the Wisconsin Department of Health Services: • Review its current procedures for approving invoices related to the Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) program to ensure the steps required for approving invoices are appropriate and documented, and that documentation is maintained either in STAR or in a central location accessible in the event of employee turnover; • Take additional steps to ensure that expenditures charged to the CSLFRF program are within the period of performance; • Provide training to staff responsible for approving invoices to ensure staff understand what documentation is required to support approvals and the required period of performance for the CSLFRF; and • Work with the Wisconsin Department of Administration and the U.S. Department of the Treasury to resolve the questioned costs related to the CSLFRF program. Wisconsin Department of Health Services Planned Corrective Action: As CSLFRF programs have matured, DHS has continually reviewed and revised our processes. We will take this opportunity to ensure that procedures surrounding approving of invoices, storing of documentation, and comprehension of the period of performance are updated and understood by our grant administrators, including providing training as necessary. DHS will work with DOA and US Treasury to resolve the questioned costs. Anticipated Completion Date: September 30, 2024 Person responsible for corrective action: Christina Isenring, Director Bureau of Operations, Division of Public Health christinam.isenring@dhs.wisconsin.gov

Finding 2023-105: Coronavirus State and Local Fiscal Recovery Funds—Unallowable Costs Auditor Recommendation: We recommend the Wisconsin Department of Administration ensure only allowable costs are charged to federal grant programs, and work with the U.S. Department of the Treasury to resolve the questioned costs we identified related to the Coronavirus State and Local Fiscal Recovery Funds program. Planned Corrective Action: The Wisconsin Department of Administration (Department) resolved the Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) costs questioned by the auditors by recouping from the school district the amount of the overpayment and obtaining from the local law enforcement agencies documentation of additional eligible expenses in amounts not less than the overpayments. The Department will continue to ensure only allowable costs are charged to federal grant programs. Anticipated Completion Date: December 18, 2023 Person responsible for corrective action: Colleen Holtan, Director Bureau of Financial Management Division of Enterprise Operations colleen.holtan@wisconsin.gov

Finding 2023-104: Homeowner Assistance Fund—Documentation to Support Applicant Eligibility and Benefit Payments Auditor Recommendation: Revise its procedures to ensure the Department of Administration completes a sufficient review to ensure adequate supporting documentation is included in the Homeowner Assistance Fund program’s computer system prior to an approval of the benefit payment. Planned Corrective Action: The Wisconsin Department of Administration (Department) will revise its procedures to ensure it completes a sufficient review to ensure adequate supporting documentation is included in the Homeowner Assistance Fund program’s computer system prior to an approval of the benefit payment. Auditor Recommendation: Provide training or other technical assistance to the community action agencies on the adequacy of supporting documentation agencies are to obtain, evaluate, and enter into the Homeowner Assistance Fund program’s computer system. Planned Corrective Action: The Department will provide additional training and technical assistance to the community action agencies on the adequacy of supporting documentation agencies are to obtain, evaluate, and enter into the Homeowner Assistance Fund program’s computer system, the requirements for which are as contained in its Wisconsin Help for Homeowners (WHH) Program Manual. Training and technical assistance will be provided through communications with program administrators and during program monitoring. The Department further notes that, after providing nearly $70 million in assistance to help prevent foreclosure through mortgage, tax, and utility payments to more than 8,600 Wisconsin households facing pandemic-related financial hardship, the WHH Program closed to new applications on March 8, 2024.Anticipated Completion Date: June 30, 2024. Persons responsible for corrective action: David Pawlisch, Administrator Division of Energy, Housing and Community Resources david.pawlisch@wisconsin.gov

Finding 2023-102: Emergency Rental Assistance Program—Documentation to Support Applicant Eligibility and Benefit Payments Auditor Recommendation: Obtain required documentation for the four applicants we identified or seek to recoup improper benefit payments it made to these applicants. Planned Corrective Action: The Wisconsin Department of Administration (Department) requested and received from the auditors the four applicants they identified. The Department has reviewed available documentation in its eligibility and benefit determination system and will work with the responsible community action agencies and Energy Services, Inc. (ESI) to obtain required documentation supporting the applicants’ eligibility to receive Wisconsin Emergency Rental Assistance (WERA) Program benefits. Should the Department determine that it provided WERA Program benefits to ineligible recipients, it will seek to recoup the payments made. Auditor Recommendation: Provide additional training and technical assistance to the community action agencies and Energy Services, Inc. (ESI) on the adequacy of supporting documentation that is to be obtained and entered into Home Energy (HE) Plus by the community action agencies and ESI. Planned Corrective Action: The Department will provide additional training and technical assistance to the community action agencies and ESI on the adequacy of supporting documentation obtained and entered into Home Energy (HE) Plus, its eligibility and benefit determination system, based on its monitoring of accepted documentation. Anticipated Completion Date: June 30, 2024. Persons responsible for corrective action: David Pawlisch, Administrator Division of Energy, Housing and Community Resources david.pawlisch@wisconsin.gov

CORRECTIVE ACTION PLAN February 15, 2024 The Tor Project, Inc. (the Organization) respectfully submits the following corrective action plan for the year ended June 30, 2023. Name and address of independent accounting firm: CohnReznick LLP 350 Granite Street, Suite 1200 Braintree, MA 02184 Audit period: July 1, 2022 – June 30, 2023 The findings from the June 30, 2023 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Federal Award Findings and Questioned Costs Significant Deficiency Item #2023-001 - Subrecipient Monitoring International Programs to Support Democracy Human Rights and Labor – 19.345 Issue: The Organization did not fully monitor the subrecipients to ensure the subaward was used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Recommendation: Management should monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved per 2 CFR 200.332. Action Taken: Subsequent to fiscal year end, the Agency implemented additional internal controls over subrecipient monitoring and retroactively performed these compliance procedures. The Tor Project, Inc. sampled monthly invoice periods for each active sub-recipient, per grant, in the period of the FY23 annual external audit. The Tor Project reviewed all supporting documentation for the cost reimbursements of the sample to ensure accuracy and completeness of all reimbursed costs. For all sub-recipients, The Tor Project performed the internal audit procedure selecting a sample of monthly invoices at random per sub-recipient, per grant, per year to verify the completeness and accuracy of all reimbursed costs. If there are any questions regarding this plan, please call Susan Abt at 781-307-8651.

Identifying Number: 2023-001: Adjustments to Project Rental Assistance Payments Condition/Finding: During our review of eligibility testing support, we noted that for the tenant’s annual reexaminations and certifications under HUD Project Rental Assistance Contract Number FL29-S951-006, the incorrect amount of contract rent was being utilized on the forms to calculate the projects tenant assistance payment. The Project incorrectly double counted the utility allowance of $51 and was using a gross rent rate of $833 to calculate the tenant rental assistance payment when it should have only used a gross rent rate of $782 per the contact. This resulted in the Project requesting a tenant rental assistance payment that was $51 more than what it should have been for each tenant on the Housing Owner’s Certification and Application for Housing Assistance Payments (HAP) for 3 months of fiscal year 2023. Upon the Project’s analysis, it was determined that the total amount of the error, net of vacancies, was $14,724. Corrective Action Taken or Planned: Management has established procedures to ensure that there is a better process to check the amounts of contract rent being approved on the re-examinations and certifications of tenants. This includes, but is not limited to, an additional review step and control for confirmation of the correct contracted and billed amounts. These additional procedures also include processes with more closely reviewed monthly HAP forms by the appropriate personnel to ensure that the amounts being requested of HUD are in line with the appropriate contract rates. Corrective action has been implemented with all corrections approved by and reconciled with HUD. This has already been fully implemented at the organization as of the date of this letter. The primary designated official is the Chief Financial Officer. With our best regards, Paul Dennison Chief Financial Officer

The outsourced accounting firm will create and execute a year-end process that will analyze all payments made during the 60 days following the fiscal year-end to ensure that expenses are recorded in the correct fiscal year. This process will ensure the Schedule of Expenditures of Federal Awards (SEFA) is reported properly. The grant program manager will ask vendors to submit their invoices for services rendered through the fiscal year end to Cure HHT within 30 days of the fiscal year end. Each grant contract year differs from the Cure HHT fiscal year. Cure HHT will create and execute a grant reconciliation process that involves financial reporting from the outsourced accounting firm, members of the outsourced accounting team, Cure HHT grant managers, and Cure HHT management to validate that all cost reimbursable grants recognize revenue as costs are incurred. All parties will ensure appropriate accounting processes and controls are in place on an ongoing basis. The reconciliation process will take place monthly and at fiscal year-end.

This error occurred during a time of transition from one outsourced accounting firm and accounting system to another. The new outsourced accounting systems were not fully in place or automated at the time of the reporting error and there was no internal review process. The outsourced accounting firm is now fully transitioned, all systems are fully integrated with the accounting software, and the accounting team provides the program managers and organization managers with the reports needed to prepare drawdown requests. Cure HHT has developed and fully implemented a corrective action plan. The organization has communicated with the cognizant agency and all expenses eligible for submission for payment through grant funding will be submitted to and paid from the overdrawn funds. Once these funds are depleted, the organization will resume monthly draw submissions for all eligible expenses. The organization will reconcile all eligible expenses prior to requesting grant funds to avoid future duplicate and/or incorrect requests for grant funds. In addition, pending proper internal approvals of all submitted expenses, grant funds received will be dispersed within 3-7 business days from the date received.

Views of responsible officials and planned corrective action: The Authority has recognized the material weakness in the Section 8 Housing Choice Vouchers and Mainstream Vouchers programs and will implement internal control procedures that will ensure compliance with federal regulations. Melissa Beadle, Deputy Director, will be responsible for implementing this corrective action by June 30, 2024. CMHA is aware that the HAB/MRI software does not store waitlist reports by date processed and since then, CMHA has been saving Excel files of the waitlist reports. The applicants that were selected for the audit were applicants that had preference points. All applicants with preference points were contacted at the same time to be informed that they were eligible for a voucher. The CMHA waitlists were ran by preference points and time/date of application. Once those applicants were pulled the waitlist was not saved to Excel. The preference point list was then sorted alphabetically for sign in purposes and tracking of applicant documentation. This is the list that was provided to the auditor.

Views of responsible officials and planned corrective action: The Authority has recognized the material weakness in the Section 8 Housing Choice Vouchers and Mainstream Vouchers programs and will implement internal control procedures that will ensure compliance with federal regulations. Michael McDougle, HCV Manager, will be responsible to implement this corrective action by June 30, 2024. CMHA has been working diligently over the past IO months to implement this corrective action with the current two CMHA employee inspectors that are following up on the life and safety 24 hour inspections and also the 30 day follow ups. When landlords have informed CMHA that they are unable to find contractors to complement the maintenance failed items, CMHA is making a note on the inspection forms and tenant file as landlords inform CM HA that they are in need of additional time. The inspection reports under this audit were completed by the contractor, Inspection Group and have since then been corrected. To date, all of the failed inspections have been reinspected and passed.