Corrective Action Plans

2022-002 Student Financial Assistance Cluster ? Assistance Listing No. Various Recommendation: We recommend the University review the procedures surrounding PELL and TEACH awarding to ensure the proper cost of attendance is used so that amounts awarded do not exceed calculated financial need and awards are proper. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University returned the ineligible Pell and Teach funds to ED. The University has implemented new processes, which include, but are not limited to, a second review of all student packages for the aid year. Prior to the start of each semester, the student package will be reviewed for subsequent ISIRS, grade level, and enrollment statuses, to ensure the Pell and Direct Loan eligibility is awarded correctly. Prior to awarding TEACH grants, the student package will be checked for the ATS (agreement to serve) and counseling. For continuing students, we will check the cumulative GPA from the prior year to ensure students are meeting the cumulative GPA of 3.25 to receive TEACH for the subsequent award year. Additionally, we have added new TEACH aid components to our student information system (SIS) to include the ATS (agreement to serve) and counseling. Student(s) will not receive any TEACH grant until they have met all three requirements. Lastly, campus based funds will be reviewed once a semester for need, and eligibility requirements. Name(s) of the contact person(s) responsible for corrective action: Lisa Stone, Director of Financial aid, Sean Corcoran, Associate Director of Financial Aid and Joyce Hatch, Financial Aid advisor. Planned completion date for corrective action plan: Fall 22

2022-004 Procurements, Suspension and Debarment Material Weakness/Material Non-compliance For any amounts above the Petty Cash ceiling, but not exceeding $250,000 in accordance with revisions to 2CFR 200.67 and 2 CFR 200.88, the NBHA may use small purchase procedures. Under small purchase procedures, the NBHA shall obtain a reasonable number of quotes (preferably three); however, for purchases of less than $10,000, per NDAA Section 806 also known as Micro Purchases, only one quote is required provided the quote is reasonable. Auditee?s Response and Planned Corrective Action: The two vendors identified were for T & T Complete Landscaping, LLC and One Stop Electronics. T&T Complete Landscaping: The total of $187,285 paid to the vendor consisted of three separate projects: REAC preparedness: $27,300 Asphalt paving: $68,500 General Landscaping (grass/brush) $91,485 While individual quotes were procured via meetings or phone calls, the NBHA cannot produce the alternative notes to document. One stop electronics: There were 9 procurements for a total of $53,422 paid to the vendor for appliances. Due to supply chain issues, availability in addition to price varied across major retailers of appliances. The logistics clerk called each major vendor to procure the necessary quantity and best price on each occasion, but did not retain record of competitive prices. Other vendors included Home Depot, Lowes and HD supply. NBHA will maintain a file of phone quotes for future documentation. NBHA will implement sufficient policies and procedures which provides for compliance with the Procurement, Suspension, and Debarment requirements of the Uniform Guidance. Planned Implementation Date of Corrective Action: Immediate Person Responsible for Corrective Action: Director of Operations, Logistics Clerk, Director of Finance - (860)225-3534

FINDING 2022-002: CHILD NUTRITION PROGRAM - MEAL COUNTS (CODE 30000) Name of contact person: Becky MacQuarrie Corrective Action: The District will ensure the computations in our excel forms are correct and accurate. One site secretary will be in charge of creating and tallying the meal count excel document, and the second site secretary will ensure the numbers are accurate when entered into the CNIPS platform. Proposed Completion Date: March 8, 2023, immediately

Grants Good Samaritan Housing, Inc. respectfully submits the following Corrective Action Plan for the year ended December 31, 2022. Name and address of the independent public accounting firm who conducted the related audit: Comer, Nowling And Associates, P.C. 10475 Crosspoint Boulevard, Suite 200 Indianapolis, Indiana 46256 Finding 2022-001 Corrective Action Planned ? A retroactive suspension of deposits has been submitted to HUD for the period June 1, 2022 through November 30, 2022. If the retroactive suspension of deposits is not approved by HUD, management will continue to deposit R4R funds during the current R4R suspension until $11,652 is deposited into replacement reserve. This should be by 5/2023. Contact Person(s) Responsible ? Darren Wilde, Controller Anticipated Completion Date ? March 2023 Auditee Disagreements ? N/A This corrective action plan was prepared by California Commercial Investment Group, Inc., the management company, on behalf of Grants Good Samaritan Housing, Inc.. _______________________________ Darren Wilde, Controller California Commercial Investment Group, Inc. 4530 East Thousand Oaks Blvd., Suite 100 Westlake Village, CA 91362 805-495-8400

"See Corrective Action Plan for chart/table"The District relied on hard-coded indirect rates that were present in the iGrants claiming system, without the knowledge that OSPI is not able to update indirect rates in iGrant claim system for multi-year grants. To correct this issue, the Grants Specialist will review indirect rates at the time claims are processed and base the indirect claims on the posted indirect rates, not the hard-coded rate in the iGrants claim system. All grant claims are reviewed by the Director. As part of this review process, the Director will compare the indirect rates on the claims with the actual posted indirect rates, not the rates hard-coded in the iGrants claim system, to ensure accuracy. This issue is fully resolved as of April 1, 2023.

Corrective Action Plan - FEDERAL AWARD FINDINGS AND QUESTIONED COSTS FA 2022-001 Improve Controls over Federal Expenditures Compliance Requirement: Activities Allowed or Unallowed Allowable Costs/Cost Principles Procurement and Suspension and Debarment Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education Assistance Listing Number and Title: COVID-19 - 84.425D - Elementary and Secondary School Emergency Relief Fund COVID-19 - 84.425U - American Rescue Plan Elementary And Secondary School Emergency Relief Fund Federal Award Number: S425D200012 (Year: 2020), S425D210012 (Year: 2021) S45U210012 (Year: 2021) Questioned Costs: $221,797 Repeat of Prior Year Finding: None Description: The policies and procedures of the School District were insufficient to provide adequate internal controls over expenditures as it relates to the Elementary and Secondary School Emergency Relief Fund program. Corrective Action Plans: Newton County Board of Education will amend contracts with appropriate vendors to ensure that the proper verbiage is contained for us of federal funds. The School District will monitor contracts to ensure that all expenditures meet compliance requirements for the ESSER federal program. Estimated Completion Date: June 30, 2023 Contact Person: Erica Robinson Telephone: 770-787-1330 Email: robinson.erica@newton.k12.ga.us

Menorah Park Center for Senior Living CORRECTIVE ACTION PLAN YEAR ENDED December 31, 2022 Identifying Number: Finding Number 2022-001 Finding: Menorah Park could not provide invoice support for two charges that were allocated to the major federal program selected for testing. Corrective Actions Taken or Planned: The errors occurred during the early stages of our conversion to a new software platform (SAGE). We were in beginning our conversion from paper files to fully paperless files. In the new SAGE process, every expense inside our AP system requires document backup. This back up is attached within the system. This will prevent document retrieval errors in the future. Date of corrective action: 10/1/2020 Person Responsible: Lisa Johnson, Accounts Payable Supervisor

Corrective Action Plan for finding 2022-001 Staff is in receipt of the Findings Required to be Reported by the Uniform Guidance, specifically finding 2022-001 regarding activities allowed or unallowed, allowable costs/cost principles, and eligibility. Corrective Actions Already Taken Place: Management acknowledges this finding. Program staff have thoroughly reviewed the existing procedures to determine where improvements could be made. As part of this process staff identified language to be added to a Quality Assurance Index (QAI) Worksheet, designed to ensure all requirements are present to make appropriate eligibility determinations. Training and implementation with appropriate staff will begin no later than April 30, 2023. The Human Services Department will also reinforce procedures to ensure eligibility determinations are verified by a Casework Supervisor or higher-level position prior to program participants receiving financial assistance/benefits. View of Responsible Officials and Timeline for Implementation: Responsible Person?s: Susan Hallett, Deputy Human Services Director, Sonja Spell, ERA Program Coordinator. The planned corrective action will be in effect by May 1, 2023, through completion of the ERA Program. Monitoring Plan: A 10% sample of completed cases will be audited by the Casework Supervisor monthly. Any concerns will be brought to the attention of the Deputy Director for immediate correction, staff development and process improvement.

AUDIT PERIODS: 7/1/21 TO 6/30/22 - A. COMMENTS ON FINDINGS AND RECOMMENDATIONS - FINDING 2022-001 - OVERAWARDED FEDERAL DIRECT SUBSIDIZED LOAN: DURING THE AUDIT, IT WAS NOTED THAT ONE STUDENT WAS OVERAWARDED A SUBSIDIZED LOAN. IT WAS RECOMMENDED THAT THE SCHOOL RETURN $762 IN SUBSIDIZED LOAN TO THE DEPARTMENT. THE INSTITUTION AGREES WITH THE FINDING. B. ACTIONS TAKEN OR PLANNED FINDING 2022-001 - STUDENTS ARE MANUALLY PACKAGED. ALTHOUGH THE CORRECT AMOUNT OF LOAN WAS PACKAGED $2,825, THE FACT THAT THE STUDENT WAS IN THE FINAL SEMESTER OF HIS PROGRAM WAS MISSED AND THE LOAN WASN'T PRORATED. THE LOAN WAS REALLOCATED IN THE CORRECT AMOUNTS OF $2,062 FEDERAL SUBSIDIZED LOAN AND $763 FEDERAL UNSUBSIDIZED LOAN THE SAME DAY WE WERE MADE AWARE OF THE ERROR. LOAN DISBURSEMENT REPORTS WILL CONTINUE TO BE MONITORED FOR STUDENTS - WITH SPECIAL EMPHASIS ON THOSE WHO ARE IN THE FINAL SEMESTER OF THEIR PROGRAM TO CONFIRM THAT THE LOAN ALLOCATION IS CORRECT.

Finding ref number: 2022-003 Finding caption: The District overcharged indirect costs to the program and did not have adequate internal controls for ensuring compliance with wage rate requirements. Name, address, and telephone of District contact person: Paula Bailey, Executive Director of Business Services P.O. Box 8 Silverdale, WA 98383 (360) 662-1650 Corrective action the auditee plans to take in response to the finding: To ensure correct indirect rate charges, the District will create a grant tracking sheet that will list all information needed to fill in the SEFA. The Grant tracking sheet will include: ? Grant Title ? Grant year ? Grant number ? Grant amount ? ALN number ? Granting agency ? Federal agency name ? Approved Indirect Rate In order to ensure compliance of wage rate requirements the district will ensure: 1. Weekly collection and review of Certified Payroll Reports (CPRs) with compliance statements for all active projects will be incorporated into the Capital Projects accounts payable process. 2. The CPRs collected will be accessible to all Capital Project staff members in electronic format as well as a newly created control document verifying the date of review and reviewer of each CPR submitted. 3. Requests for CPRs will be made to all contractors or subcontracts missing reports through the period for which work has been performed. 4. Monthly invoices and pay applications will not be processed until CPRs for the billing period are collected and reviewed. 5. CPR procedures will be included in the Pre-Construction Meeting Agenda for all projects with emphasis given to weekly CPR submittals. 6. Contracts will be reviewed to ensure applicable laws and regulations are included. 7. Ongoing contracts will be amended to include required federal language as required by Title 29 CFR, Section 5.5 Anticipated date to complete the corrective action: 8/31/2023

Finding 2022-001 ? Reporting The District concurs with the finding 2022-001. Corrective Action: The District will implement quality control procedures that will verify and confirm that monthly meal reimbursements and counts are correct prior to submission in CNMS Contact Person: Michael Brennan, Business Manager (518) 758-7575 ext 3009 mbrennan@ichabodcrane.org

Name of auditee: Fairmount Park Senior Housing, Inc. HUD auditee identification number: 074-EE030-WAH Name of audit firm: Dauby O'Connor & Zaleski, LLC Period covered by the audit: Year ended June 30, 2022 CAP prepared by Name: Eric Lynner Position: President Telephone number: 515-243-8300 Current Findings on the Schedule of Findings, Questioned Costs, and Recommendations Statement of condition #2022-001: For the year ended June 30, 2022, management fees were overpaid by $2,179. Recommendation: The management agent should calculate and pay management fees on a monthly basis in accordance with the Management Agent Certification. The management agent should repay $2,179 to the Property's operating cash account. Action(s) taken or planned on the finding: Management repaid the Property on September 13, 2022.

Finding Number: 2022-004 Condition: The billing procedures review process did not ensure charges to federal awards were incurred prior to billing the grantor. Planned Corrective Action: Management understands the importance of incurring costs that are charged to federal awards. Management will follow its existing policy to ensure that expenditures charged to grants accurately reflect the costs incurred. In addition, management will return the overage amount to the awarding agency no later than July 31, 2023. Contact person responsible for corrective action: James D. Hagestad Anticipated Completion Date: July 31, 2023

Management's views: When Amistad was notified by the City of El Paso about the error in January of 2022, management immediately started addressing the concern and made various steps to ensure solutions and best practices were being implemented. The auditor has a copy of the timeline and all steps that were taken. Amistad was able to recover $876,464, from all utility companies, the City approved the revisions to the application, and there was no negative impact to the agency. Amistad pledged to assist all customers that were impacted. Proposed corrective action: In regard to the corrective action plan, the process to address the issue started in January of 2022. A detailed timeline and corrective action plan were provided to SBNG. Amistad made several changes immediately such as identify ing and separating homeowners from renters, modified the application, added the Eligibility Verification Checklist and included a section for the Supervisor to review. Based on the feedback from the Audit, Amistad will continue to improve the process of reviewing new grant contracts so we can identify gray areas of compliance from the very beginning. For each new grant, management will make sure experienced members of the staff will evaluate the design of the program's procedures before the program rolls out. Also, for eligibility screening, we will continue to have a dual review of participant files to assist with identifying inconsistencies on the application. The $1,386.92 that was identified as an exception has been identified as ERA II funds. The City of El Paso has approved Amistad to use the $1,386.92, for the utility assistance program to assist renters. Anticipated correction date: As stated earlier, the corrective action plan started in January of 2022. Staff have received multiple trainings and will continue to receive trainings regarding best practices and contracts, along with implementation of programs. The recommendations that the auditor has provided have already been in process and will continue to be addressed through training and quality assurance checks. In regard to the one exception noted, the City of El Paso has approved Amistad to use the $ 1,386.92, for the utility assistance program to assist renters during FY2023. Responsible Official: Andrea Ramirez, Chief Executive Officer.

Corrective Action Plan ? 9/26/2023 Responsible Party: Donna Crutchfield, Director of Revenue Cycle Finding: During audit review of the COVID 19 HRSA testing and treatment payments received in 2022, two claims were discovered incorrectly charged to the COVID uninsured grant. Comments on the Finding and Recommendation Management is in agreement with this finding. Action(s) Taken or Planned on the Finding ? Build already existed in Epic to stop any uninsured patients that met COVID guidelines at time of service for review. This also includes build that stops claims if HRSA plan added later in the process for review. Expanded Plan on Actions Taken ? 09/26/2023 1. Actions planned on one claim found in audit. Refund will be issued for $122.69 for TIN 710236856 NPI 1043240682. 2. Actions planned for additional claim found in audit. Refund will be issued for $74.20. TIN 710236856 NPI 1174553796. 3. Refund process - Current credit balance policy is attached. Note all government payers are due to be reviewed and worked within a 60-day timeline. This is current as of 4/10/2023. 4. Note that auditors listed an extrapolated figure under projected costs based off the two claims found in the sample audit. The two claims found will be refunded. Missed other insurance information was due to patients? lack of presentation of insurance info at the time of service. 5. Going forward to ensure all meet credit guidelines. If there is a HRSA credit on a claim, it will be worked within policy guidelines. 6. As mentioned in previous plan, initial build exists (as of May 2020) in Epic to stop any uninsured patients that met COVID guidelines at time of service for review. This review allows to check for other coverage. There is also build that stops coverage if HRSA coverage is added later on in the process for a second review. Insurance coverage can be retroactively assigned after HRSA is filed. In this event, this would show as a credit if another payment was received and then be refunded by policy. In summary: ? Patient visit is set to review and confirm no active coverage is present, insurance coverage discovery was run, patient's visit was associated with COVID related service. ? HRSA coverage added and patent is keyed to HRSA portal for member ID to file claim. HRSA also checks insurance verification on their side and will notify if HRSA found active coverage not located by us. 5. Contact information for additional Questions: Donna.Crutchfield@baptist-health.org or 501-202-6440.

Views of Responsible Officials and Planned Corrective Action Management has engaged a 3rd party to review, recommend and implement improvements to the current billing and month end closing processes. This will include improved documented processes and procedures along with the needed training to be effectively implemented and continued. Responsible Official: Michael Nowlan, Interim EVP/CFO

Finding 2022-003: Internal control deficiency and noncompliance over reporting of expenses attributable to coronavirus in the HRSA PRF Reporting Portal. Since the start of the Covid-19 pandemic, Ochsner LSU Health has coordinated efforts across multiple divisions throughout the organization to ensure compliance with the Provider Relief Fund that included leveraging publicly available information, outside consultants, and an internal review prior to management sign off. An additional level of review will be implemented whereby Ochsner?s Internal Audit Department will preview the preliminary HRSA PRF Report from the PRF Reporting Portal prior to submission to ensure expenses are not duplicated. In addition, Ochsner LSU Health will work with HRSA to understand the most appropriate manner to correct this issue within the Provider Relief Fund Portal. Responsible Official: Lauri Walton, Ochsner LSU Assistant Vice President of Accounting and Steven Stiles, Ochsner Vice President of Reimbursement Anticipated Implementation Date: September 30, 2023

agreement. View of Responsible Officials A. We concur with this finding. The Department utilized an internally available copy of the Management Log, which lists vendor?s determinations. This is a copy of the log, not the original, official copy. There is a delay in updating this copy from the original, and incorrect information had been initially entered. The Department is moving this log to software which allows all Department employees to view the same log, while limiting the number of individuals who have access to make changes. Implementation has been completed as of March 2023. B. We concur with this finding. However, we believe this was an isolated incident as the TANF CFDA number (93.558) used was very similar to correct CFDA number (93.778) that should have been documented. C. 200.332 requirements a. We do not concur with this finding. The contract for Mt Prospect became effective 8/4/21, prior to the 4/22 inception of the UEI. The DUNS number, as in effect at that time, is noticed in Exhibit J of the contract. b. We concur with three of the four findings. Two of the four contracts pre-date the template update requiring the notice an indirect cost rate. Indirect cost rate for federal awards (including if the de minimis rate is charged per 2 CFR section 200.414) were added to Exhibit C of the Department?s contracts in April 2020. One of the contracts did not indicate an indirect cost rate as required. One of the contracts notes the indirect cost rate in the Notes of their financial details. c. One of the two contracts pre-dates the template update requiring the notice the identification of R&D. R&D identifications for federal awards were added to Exhibit C of the Department?s contracts in April 2020 One of the two contracts did not identify whether the contract was R&D as required. D. Subrecipient Risk Assessment ? We concur with the finding. We consider the finding to be fully resolved through Department policy Department policy and Department wide implementation. However, it should be noted full compliance will not be achieved for one to two contact cycles due to timing. The Department began addressing the issue of Subrecipient Monitoring issue in June 2017 when the first Grants Administrator was hired. The Department finalized the Subrecipient Monitoring Policy, which encompasses the financial and programmatic risk assessments as well as the subrecipient monitoring, on June 1, 2018. The Department provided user training on the subject in February and September 2018, training over one hundred forty-six staff. However, only brand new procurements utilized this policy during the initial roll out of this policy. The Department hired a new Grants Administrator in May 2019. The full Subrecipient Monitoring policy rolled out to all procurements, including sole source, amendments, and renewals, effective August 1, 2020. The Contracts Unit received specialized subrecipient monitoring training on May 13 and October 28, 2020. Department wide training to all staff occurred weekly between September 8 and November 3, 2020. The Grants Office provided additional targeted training to Program staff through team meetings. Over one hundred fifty Program and Finance staff received training. Annual training will be held in September each year. Refresher training or training for new staff is available upon request from the Grants Office. The Grants Office website offers Program, Finance, and Contracts Bureau staff access to the subrecipient monitoring policy, as well as training modules, slides, and tools. The training has also been recorded and is available on this site. The Subrecipient Monitoring Policy requires Program to determine whether any vendor which receives funds in exchange for goods or services is a Contractor or Subrecipient. Determined subrecipients receive a Management Questionnaire, which includes a ten question questionnaire and requirements for submitting financial data. This information is used to populate the Risk Assessment Tool, which shows any risks pertinent to a subrecipient and the subaward. Based on the risks shown, Program chooses monitoring activities to mitigate the risks and the Contracts Bureau memorializes these choices in the contract. The Grants Office continues to work closely with the Contracts Bureau to ensure compliance with the Subrecipient Monitoring policy. C. and D. It is also important to note that between April 2020 and June 2022 the Department was involved in the State?s strategic response to the COVID-19 pandemic. During this time, New Hampshire was under a state of emergency (Executive Order 2020-04), processes were rapidly converted to fully digital overnight, the State?s standard approval processes were suspended and non-standard templates, which did not include the required notifications under 200.332, were utilized to respond to the COVID-19 pandemic. The Department worked with other State Departments and the National Guard to create a record number of amendments, contracts, and other agreements (approximately 200% more than standard). The Department is in the process of instituting a new contract life cycle management solution that will utilize conditional logic to include the required notifications for agreements involving federal funds in order to ensure compliance. Implementation is anticipated to be complete in July 2023. As the COVID-19 pandemic strategic response has wound down, the Department has not suspended its regular standard approval or subrecipient risk assessment and monitoring processes and has not used non-standard templates to award federal funding. E. We concur there was no formal documentation of any monitoring activity. Due to staff turnover a new administrator has been hired and unable to furnish the monitoring that took place during FY22. However, a program site review during FY23 was performed and financial monitoring of invoices has also taken place. Anticipated Completion Date: July, 2023 Contact Person: Melissa Kelleher, Administrator Rejoinder As documented above in Bullet B of the condition found, the Department did not properly communicate all required award information to the subrecipient. Once aware of the noncompliance, the Department should have timely communicated this information to its subrecipients.

View of Responsible Officials Condition A We concur. The department received the notice of non-cooperation on 9/14/21 and did not enter the non-cooperation until 9/29/21, which was beyond the 10-day time frame. The case should have then been confirmed to impose the sanction on or before 9/24/21. This resulted in the client being over issued by approximately $222.37. Condition B We concur. The sanction for non-cooperation with Child Support was entered in error as Child Support did not issue a non-compliance. This resulted in the client being under issued by approximately $446.50 Follow-up We will be informing all supervisors of the specific errors found during the audit. We will also require supervisors to include these topics at their next staff meeting. In addition, individual emails will be sent to the staff involved with the errors and provide guidance. Anticipated Completion Date: N/A Contact Person: Karyl Provost

2022-002 Return to Title IV Recommendation: We recommend the University review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are using the correct amount of term days and are completed accurately. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Report is being created that will allow staff to compare R2T4 manual data entries against source data. Discrepancies will be researched and corrected within 5 business days. Report will be generated weekly and reviewed by the manager over this area. Name(s) of the contact person(s) responsible for corrective action: Brenda Clark, Director of Financial aid Planned completion date for corrective action plan: Implementation of new quality control R2T4 report planned for October 24, 2022.

The corrective action for Finding 2022-001 is below: Due to employee turnover at the end of Fiscal Year 2022, the process of ensuring revenue being matched with expenses required additional attention. Going forward, the Financial Controller will monitor expenses to ensure recording in the proper period via periodic spot checks of general ledger recording, quarterly balance sheet reviews, and increased communication with department leaders. In addition, the process for grants is under review to ensure a more timely claims request and reimbursement to avoid last minute purchases.

Finding Reference Number: 2022-001 Federal Agency: U.S. Department of Labor Program Name: WIOA Cluster Assistance Listing Number: 17.258, 17.259, 17.278 Responsible Official: Patricia Rogers, Executive Director Views of Responsible Individuals: Based on the discussion we had with you regarding COPIC audit draft report, we have a plan of action moving forward to ensure these issues do not continue: ? COPIC (Josh) and Schmidt Associates (Mary) will work together to do monthly reconciliation of the tracker to the general ledger and staff billing reports. ? The spreadsheet you provided will be used as the reconciliation "tool" and will be available for your review when performing the audit. ? This will provide a monthly, program status of revenue versus expenditures as backup to the CPR submitted to the CWDB. ? The accrued vacation will be subtracted out each month as a line item on the staff billing invoice and a line will be added showing the amount transferred between the leave account and the regular checking account. This should clarify and resolve duplication of accrued vacation expenses. ? The workers compensation for work experience participants has been added back to the tracker and will only be recorded when premiums are paid. ? A line item has been added to the staff billing invoice to show the amount of employee health insurance being deducted from the employee checks each month. To clarify the amount paid by COPIC and the amount paid by the employee. ? The monthly reconciliation to be conducted, using the spreadsheet you provided, should eliminate audit adjustments and ensure the Payment Tracker, the General Ledger and the CPR match each month.

The Brookline Housing Authority (BHA) takes seriously all audit deficiencies. Immediate corrective action has and will be taken after Marcum LLP notified the BHA of this issue during the FY ?22 audit process. Specific details of how the BHA intends to address this finding are detailed below. 2022-001 ? Procurement, Suspension & Debarment For procurements of $10,000 or more, there shall be maintained a written record which includes the contract and any amendments to the contract. If a contract is awarded pursuant to a formal solicitation, the written record shall also include the invitation for bids or request for proposals, the public notices and advertisements, the bids or proposals submitted and written evaluation of proposals. All written documentation required by this Section shall be maintained for a period of six years from the date of final payment under the contract. (Brookline Housing Authority Procurement Policy) As a result of not adequately documenting the procurement decision, the Authority has not complied with their procurement policy and cannot ensure that it is receiving the most competitive prices or rates for services that have been procured. Auditee?s Response and Planned Corrective Action The BHA made strides during FY 2022 and strives to continue to prioritize contract and procurement practices that comply with applicable state (M.G.L 30B) and federal regulations. There was one issue, with one particular vendor that gave rise to this finding. The BHA Board of Commissioners approved an updated procurement policy as recommended by the Executive Director in the 1st quarter of FY 2022. This policy is compliant with both state and federal procurement guidelines but also contains additional controls on spending thresholds to ensure competitive contracting beyond regulatory requirements. The BHA already maintained records for six or more years from the date of final procurement for procurements $10,000 or larger. However, it did not have consistent record retention of small vendors that were used repeatedly under this $10,000 threshold and where bids could be solicited without an RFP. Going forward these records will be retained for repeatedly used vendors. The Director of Maintenance and Modernization has already been systematically re-procuring trades like electrical and painting in late FY 2022 and throughout FY 2023 where this was an issue and within a calendar year should fully re-procure all applicable services. The BHA is also planning to make the following immediate corrective actions and changes to internal controls: 1. The Director of Operations and Director of Maintenance and Modernization have both become certified Procurement Officers for the Brookline Housing Authority. 2. The Director of Operations, Director of Finance, and Executive Director will periodically review expenditures for frequently recurring transactions that could exceed competitive procurement thresholds. 3. The Director of Operations, Director of Finance, and Executive Director will periodically compare the contract register against frequently used vendors. 4. The BHA already retains a contract register and procurement details for competitive procurements over $10,000. The BHA will require all staff to retain solicitation records and materials used to make a procurement decision for smaller contracts and enter recurring contractors into the contract log. Planned Implementation Date of Corrective Action: November 28, 2022. Persons Responsible for Corrective Action: Michael Alperin, Executive Director, Lisa Brown, Director of Operations, Chris Devoll, Director of Maintenance and Modernization and John Kelley, Director of Finance. (617)-277-2022

2022-002 ? Procurement, Suspension, and Debarment Auditee?s Response and Planned Corrective Action The Authority has implemented a complete comprehensive contract register to track past and current contracts and awards. The Authority will run monthly vendor reports to determine those vendors who have frequently occurring transactions and are over or close to the competitive procurement thresholds. The Authority will compare periodically, no less than monthly, to compare the register against frequently used vendors. The authority will solicit bids and prices on all transactions to assure price reasonableness over the micro threshold and competitively procure contracts on all other services and frequent material purchases. Documentation will be maintained supporting all procurement decisions and contracts awarded. Planned Implementation Date of Corrective Action: December 21, 2022 Person Responsible for Corrective Action: Stuart MacDonald, CFO (401)-847-0185

Finding Number: 2022-001 Condition: Controls in place did not identify a portion of expenditures, related to summer school stipends, incurred in fiscal year 2023 that were applied to the federal award in fiscal year 2022. Planned Corrective Action: The error was the result of a misunderstanding with the pass-through entity regarding the reimbursement process. Going forward, a review will be performed to ensure federal revenue is recorded in the same period as the corresponding expense. Contact person responsible for corrective action: Chief Executive Officer Anticipated Completion Date: Effective Immediately