Corrective Action Plans

Memorandum of Understanding Billing Recommendation: We recommend that the organization implement procedures to ensure that reimbursement requests are based on actual invoices. Explanation of disagreement with audit findings: there is no disagreement with the audit findings. Action taken in response to finding: Once this deficiency was identified, PVARF immediately contacted VA Portland Health Care System to determine if invoicing would the forthcoming. When it was made clear that there was no forthcoming invoicing, the sponsor was contacted to determine refund steps. Ultimately, the funds were returned to the agency that was inappropriately billed. Action Plan: In addition to ensuring effective communication between the stakeholders, PVARF implemented standard follow-up protocols to make certain VAPORHCS is invoicing PVARF timely, PVARF is in the process of implementing a project management platform that will effectively and efficiently manage major milestones such as invoicing for grants, contracts, and clinical trials. It was also made clear to PVARF administrative staff that there will be no billing ahead of receipt of invoices on any agreements, and that doing so is a breach of the executed contract. Name(s) of the contact people responsible for correction action: Admin Staff Team Plan completion date for corrective action plan: July 31, 2023

CFSA concurs with the findings as stated. For bullet point #1 of the findings noted: This appears to be a data entry error that occurred during the eligibility team?s preparation for the single audit. The room & board costs that occurred during the erroneous ?Eligible Not Reimbursable? period on the redetermination form were claimed to title IV-E in real time during CFSA?s quarterly claiming process. The Supervisory Eligibility Specialist has already begun a 10% quarterly quality review process of all eligibility determinations. For bullet point #2 of the findings noted: The youths in question were enrolled in high school at the start of the school year (and reflected as such in the FACES system) but were actually chronically truant. CFSA?s Business Services Administration and the Office of Youth Empowerment have implemented a joint quarterly review of the educational/employment/incapacity status of 18-to-21-year-old youth who are IV-E eligible to ensure that they meet federal requirements to support IV-E claims on their behalf. For bullet point #3 of the findings noted: The issues with background checks pertained to ?other adults residing in the home? who were not the licensed foster parents. The corrective action going forward is to produce source documentation during the audit that identifies the household composition of the foster family home so that the auditors have a clear picture of those who are adults and therefore require evidence that background checks were completed satisfactorily for IV-E eligibility purposes. CFSA will include the sections of the applications/re-applications for foster family home licensure, as appropriate, into the digital catalogue of readily available licensure documentation available for audit retrieval. These documents corroborate household composition for the purpose of identifying who, within the household, requires background checks. See Corrective Action Plan for chart/table

Department of Human Services (DHS)/Economic Security Administration (ESA) concur with the findings. DHS Division of Program Operations (DHS/DPO) have embarked on a partnership with Office of Information Systems (OIS) and the Division of Innovation and Change (DICM) to create a unique identifier in DC Access System (DCAS) which will be utilized to properly associate case documents with the appropriate Integrated Case number in DIMS. This process will reduce and/or eliminate unassociated documents in DIMS. In addition, DPO/ESA and OIS will partner to conduct refresher training for staff on how to properly scan and tag case documents as well as how to conduct searches for case documents in DIMS. See Corrective Action Plan for chart/table

Finding #2022-001 Comments on Findings and Recommendation: At December 31, 2022, deposits to the reserve for replacements account of $3,846 had not been made. Management should transfer $3,846 from the operating account to the reserve for replacements account. Action(s) taken or planned on the finding: Management concurs with the finding and recommendation and transferred $3,846 on March 22, 2023 to the reserve for replacements account.

DICKINSON SENIOR HOUSING, INC. HUD PROJECT NO. 094-EE006 CORRECTIVE ACTION PLAN YEAR ENDED JUNE 30, 2022 DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT Dickinson Senior Housing, Inc. respectfully submits the following corrective action plan for the year ended June 30, 2022. Name and address of independent public accounting firm: Hinrichs & Associates, Ltd. 1000 Shelard Parkway, Suite 110 Minneapolis, MN 55426 Audit Period: June 30, 2022 The findings from the June 30, 2022 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Section A of the schedule, Summary of Audit Results, does not include findings and is not addressed. FINDINGS - FINANCIAL STATEMENT AUDIT NONE FINDINGS - FEDERAL AWARD PROGRAMS AUDIT DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT FINDING 2022-001: SECTION 202, ASSISTANCE LISTING NUMBER 14.157 The Project paid the expense of another project under common management. Recommendation: The Project should carefully review invoices before payment to make sure it pays the correct amount. Action Taken: The Project agrees with the finding. The accounts payable staff will be reminded to be careful when entering invoices for payment. If the Department of Housing and Urban Development has questions regarding this plan, please call Chuck Reuter at 651-645-7271.

Finding 2022-004 Criteria or Specific Requirement: CFDA 14.850; US Department of Housing and Urban Development; Public and Indian Housing; annual contributions contract number FW-7097; fiscal year ending March 31, 2022.Allowable costs/cost principals in accordance with 24 CFR 200, the PHA Annual Contributions Contract, and PHA Internal Control Policy. Recommendation for Corrective Action: Establish and enforce controls over Board of Commissioners and Managements review and supervision of purchasing procedures. Specific internal control and budgetary procedures should be implemented to ensure all costs are reasonable and necessary for the economical operation of the project for the purpose of serving families of low-income status in accordance with 24 CFR section 200. Views of Responsible Officials: We will review existing policies, implementing control procedures to correct these deficiencies. We will also provide increased supervision and training over this area. Planned Corrective Action/Action Taken: We will review existing policies, implementing control procedures to correct these deficiencies. We will also provide increased supervision and training over this area. We anticipate a complete resolution of this type of error by December 31, 2022. Anticipated Completion Date: We will have this resolved by December 31, 2022 Auditors Evaluation of Auditee Comments: Management?s comments in relation to its corrective action plan appear reasonable, valid, and supported with sufficient, appropriate evidence.

ASI CLARK COUNTY, INC. HUD PROJECT NO. 125-HD069 CORRECTIVE ACTION PLAN YEAR ENDED JUNE 30, 2022 DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT ASI - Clark County, Inc. respectfully submits the following corrective action plan for the year ended June 30, 2022. Name and address of independent public accounting firm: Hinrichs & Associates, Ltd. 1000 Shelard Parkway, Suite 110 Minneapolis, MN 55426 Audit Period: June 30, 2022 The findings from the June 30, 2022 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Section A of the schedule, Summary of Audit Results, does not include findings and is not addressed. FINDINGS - FINANCIAL STATEMENT AUDIT NONE FINDINGS - FEDERAL AWARD PROGRAMS AUDIT DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT FINDING 2022-001: SECTION 811, ASSISTANCE LISTING NUMBER 14.181 The Project paid the expense of another project under common management. Recommendation: The Project should carefully review invoices before payment to make sure it pays the correct amount. Action Taken: The Project agrees with the finding. The accounts payable staff will be reminded to be careful when entering invoices for payment. If the Department of Housing and Urban Development has questions regarding this plan, please call Chuck Reuter at 651-645-7271.

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

2022-020 Improve Controls over the NCCI Medically Unlikely Edits Process Federal Agency: U.S. Department of Health and Human Services State Entity: Department of Community Health (DCH) Corrective Action Plans: DCH has made changes to ensure proper record keeping and approval is maintained. The changes made to Medically Unlikely Edits (MUEs) occurred in 2017, several years prior to the audit in 2022. Moving forward, policy compliance specialists for Durable Medical Equipment (DME) will be required to sign an employee attestation that acknowledges and ensures they understand the Standard Operating Procedure (SOP) as outlined in the Centers for Medicare & Medicaid Services? (CMS) technical guidance manual in section 7.4. This change will be implemented on June 30, 2023. CMS approval of all MUE changes are maintained through the Georgia Medicaid Management Information System (GAMMIS) Georgia Interactive Portal. Upon approval from CMS to deactivate a MUE, the program policy specialist initiates a change order through the Georgia Interactive Portal requesting the current MUE edits to be deactivated and then modified per CMS approval. The approval from CMS is submitted as part of the request. The change order needs to be approved by management before changes can be made in GAMMIS. This process went into effect after the MUE changes made in 2017 in November of 2018. Estimated Completion Date: June 30, 2023 Contact Person: Lynnette Rhodes, MAP Executive Director Telephone: 404-656-7513; E-mail: lrhodes@dch.ga.gov

2022-017 Improve Controls over Medicaid Capitation Payment Rates Federal Agency: U.S. Department of Health and Human Services State Entity: Department of Community Health (DCH) Corrective Action Plans: The Department acknowledges that some of the capitation rates in Georgia Medicaid Management Information System (GAMMIS) were inaccurate. The Department will implement the following procedures to ensure capitation rates are accurate: (1) review all capitation rates in GAMMIS from July 1, 2021, to current date, (2) correct all inaccurate capitation rates in GAMMIS, (3) test rates in GAMMIS for accuracy prior to production and (4) re-process Per Member Per Month (PMPM) payments to correct over/under payments. The Department will implement capitation rate adjustments as they are approved by Centers for Medicare & Medicaid Services? (CMS) in conjunction with our Actuaries. The Department will implement this process immediately. Estimated Completion Date: June 30, 2023 Contact Person: Lynnette Rhodes, MAP Executive Director Telephone: 404-656-7513; E-mail: lrhodes@dch.ga.gov

2022-016 Improve Controls over Medicaid Capitation Payments for Managed Care Recipients Federal Agency: U.S. Department of Health and Human Services State Entity: Department of Community Health (DCH) Corrective Action Plans: Third party vendor corrected the error that led to the duplicate capitation payment issue on a single Georgia Medicaid Management Information System (GAMMIS) ID on 9/16/22. Additional research is required to identify if other instances of duplicate payments to Managed Care Organizations (MCOs) exist and to determine if funds should be recovered. We will also establish a plan to monitor the duplicate member files and address the issue on an ongoing basis. This should be completed by August 2023. Estimated Completion Date: August 31, 2023 Contact Person: Lynnette Rhodes, MAP Executive Director Telephone: 404-656-7513; E-mail: lrhodes@dch.ga.gov

2022-015 Improve Controls over Medicaid Capitation Payments for Medicare Members Federal Agency: U.S. Department of Health and Human Services State Entity: Department of Community Health (DCH) Corrective Action Plans: This correction was put into production on 7/1/2022. The recoupments began April 1, 2023, to coincide with the termination of the continuous coverage requirement of the Public Health Emergency (PHE). Estimated Completion Date: April 1, 2023 Contact Person: Lynnette Rhodes, MAP Executive Director Telephone: 404-656-7513; E-mail: lrhodes@dch.ga.gov

2022-014 Improve Controls over Payments for Home and Community Based Services Federal Agency: U.S. Department of Health and Human Services State Entity: Department of Community Health Corrective Action Plans: Centers for Medicare & Medicaid Services? (CMS) approval of Appendix K: Emergency Preparedness and Waiver form allowed for some payments to go through to ensure continuity of services during the Public Health Emergency (PHE). The Medical Assistance Plan program continues to evaluate these payments to determine if the appropriate documents were filed under this exemption. This evaluation should be completed by June 30, 2023. Estimated Completion Date: June 30, 2023 Contact Person: Lynnette Rhodes, MAP Executive Director Telephone: 404-656-7513; E-mail: lrhodes@dch.ga.gov

2022-013 Improve Controls over Medicaid Payments after Date of Death Federal Agency: U.S. Department of Health and Human Services State Entity: Department of Community Health (DCH) Corrective Action Plans: Modifications to the date of death process in Georgia Medicaid Management Information System (GAMMIS) have been completed. Mass adjustments # 700, 702, and 720 are pending to correct the claims that require a recoupment. The mass adjustments should be completed by June 30, 2023. Estimated Completion Date: June 30, 2023 Contact Person: Lynnette Rhodes, MAP Executive Director Telephone: 404-656-7513; E-mail: lrhodes@dch.ga.gov

2022-024 Improve Controls over Period of Performance Federal Agency: U.S. Department of Health and Human Services State Entity: Department of Behavioral Health and Developmental Disabilities (DBHDD) Corrective Action Plans: The Department will continue to improve the internal controls to ensure that expenditures are liquidated within 90 days of the end of the period of performance as required. The Department will update processes and procedures associated with period of performance requirements and provide training that outlines close-out processes associated with the specific grant awards. DBHDD will update the internal controls related to period of performance no later than June 30, 2023. Estimated Completion Date: June 30, 2023 Contact Person: Kenneth Ward, Director of Internal Audit Telephone: 404-884-5486; E-mail: kenneth.ward@dbhdd.ga.gov

2022-021 Improve Controls over Expenditures Federal Agency: U.S. Department of Health and Human Services State Entity: Department of Human Services (DHS) Corrective Action Plans: ? The Low-Income Household Water Assistance Program (LIHWAP) State Office Unit implemented a $5,000 maximum amount on the total benefit per household. ? Any benefit over $3,500 requires review and approval from the LIHWAP State Office with a LIHWAP Waiver Request Form and provide a copy of the form to the Community Action Agency (CAA). ? The State Office will require that each LIHWAP Waiver Request Form approval be submitted with the Agency?s Monthly Expenditure Report packet and retained in the file. ? The Community Action Agency will be required to submit a monthly checklist and supporting documents for all applications in which the household had a leak and/or benefit amount over $3,500. ? The State Program Office will update and distribute the LIHWAP State Policy to the CAAs. The Program will provide training and guidance to the network to ensure that policies and procedures are consistently enforced and operating effectively. Estimated Completion Date: August 1, 2023 Contact Person: Cynthia Bryant, Unit Director Telephone: 470-259-8188; E-mail: cynthia.bryant@dhs.ga.gov

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

Corrective action plan: The formula error was identified, corrected and reallocations are now correct. Also, the outdated reallocation journal tool is no longer used. The new journal reallocation tool includes edits to identify discrepancies before a reallocation journal is posted. As an additional verification step, which began with March 2022 reallocations, a new verification report (Fund Source Allocation Compare Report) is run that compares the date the factor was updated to the date the reallocation journal was entered to ensure no changes have been made to the factor. HHSC Accounting will work with Chief Financial Officer (CFO) Operation Support to establish an automated process to strengthen existing verifications. Implementation date(s): August, 31, 2023 Responsible persons: Director, Funds Management

2022-002 Reporting Deadlines Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Assistance Listing #93.498) Recommendation: We recommend that Comprehend management review all grant funding for reporting deadlines and coordinate this responsibility with the respective program directors. Action Taken: Management concurs with this finding and agrees with the finding and has put in place processes to ensure that all required data reporting related to grants is done within the state required deadlines. Due to significant turnover in the finance and accounting department during the 2021 fiscal year when this grant was received, the CFO and/or CEO did not receive any communication from HRSA regarding the reporting. Management has and continues following the repayment status of HRSA Funding. The process was put into place December 2022. Donna Hicks, CFO, is the contact person responsible for the corrective action.

Finding 2022-002 - Eligibility - Significant Deficiency in Internal Control Over Compliance - Recommendation: We recommend the University amend procedures so in the event that packaging is done manually, there are added reviews over the student's aid awarded. - Corrective Action Plan: We accept Moss Adams' recommendation and if a situation arises where we must manually package a student, the procedure will include an additional review by another individual, either the Director or a Counselor, to review the package for accuracy. An internal review of FY22 indicated this was an isolated incident. - Anticipated Completion Date: Management will complete the Corrective Action Plan by June 30, 2023. - Individual Responsible: Oscar Jones, Director of Financial Aid.

See Corrective Action Plan for chart/table

Finding: 2022-001 Considered a significant deficiency in internal control/immaterial non-compliance. Program: ALN 93.959 Block Grants for Prevention and Treatment of Substance Abuse (Treatment) Criteria: As detailed by 2 CFR 200.402, the total cost of a Federal award is the sum of the allowable direct and allocable indirect costs less any applicable credits. Condition: During testing of amounts charged to the grants it was noted that provider stabilization payments were charged to the Treatment grant but were not authorized by the grants. Cause/Effect: This condition appears to be the result of a misunderstanding of costs allowed under this grant. These costs were not in compliance with 2 CFR 200.402. Questioned Cost: $199,598 Recommendation: We recommend that the Entity review all grant agreements to gain a thorough understanding of allowable costs and then establish/modify internal controls to assure that only allowable costs are charged to the grant View of Responsible Official: Management is in agreement with this recommendation. Corrective Action Plan: SWMBH's provider stability committee will review SWMBH's COVlD-19 Provider Stability plan. Along with the review of the plan, SWMBH will fully understand and execute request in accordance with the SWMBH COVlD-19 Provider Stability plan. Payments of an approved provider stability request will only be funded by Medicaid and Healthy Michigan. Responsible Party: Garyl L. Guidry Jr., MBA Chief Financial Officer Date of completion: August 1, 2023

2022-002 ALLOWABLE COSTS AND ALLOWABLE ACTIVITIES ? COVID-19 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS Recommendation: We recommend that the County include consideration of any expenditures that may be part of other federal programs as part of their review. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The County will review their procedures to ensure expenditures coded to federal grants are not already claimed by other grant programs. Name of the contact person responsible for corrective action plan: Deborah Erickson, Administrative Services Director Planned completion date for corrective action plan: December 31, 2023

Management is aware and understands the importance of compliance with the federal requirements and will ensure the wage requirements are met in the future.

Response and Corrective Action Plan: The District will update the annual calculation to include a comparison of the base used for the indirect cost adjustment. Sarah Kautz, June 30, 2023.