Corrective Action Plans

Galindez LLC Urb. Perez Morris, 19 Ponce St. San Juan, PR 00917 Dear CPA Marcos Claudio: In connection with the Schedule of Findings and Questioned Cost of Administracion de Servicios Medicos de Puerto Rico (ASEM) for the year ended June 30, 2022, below please find our comments, and planned corrective actions for Finding identified. Finding No. 2022-001 Eligible Uses Providing Premium Pay to Eligible Workers As more fully explained to your representative during the audit, the Administrator of this Premium Pay Program was the Health Department of Puerto Rico (HD) who was in charge of developing the program to all Public Hospital in Puerto Rico, among them, the Administracion de Servicios Medicos de Puerto Rico (ASEM). At all times, ASEM followed the instructions provided by the HD. Furthermore, we provided the HD with the list of possible eligible employees, including the information of the requirements established by them. The salary $40,000.00's limit was not a requirement to be considered. After the review done by HD, they provided ASEM with the authorized list of employees eligible for the benefit which ASEM used for the payment. Accordingly, it was never the intention of ASEM to pay this benefit to not eligible beneficiaries, it was only a matter of not providing ASEM with the actual requirements from the Program's Administrator. Should you have any question, please call at your convenience. Paul Barreras Diaz, CPA Finance & Budget Director

IN REGARDS TO COVID-19 EDUCATION STABILIZATION FUND - ASSISTANCE LISTING NO. 84.425C, 84.425D, 84.425U, 84.425W; GRANT PERIOD -- YEAR ENDED JUNE 30, 2022 THE DISTRICT WILL IMMEDIATELY PUT MEASURES IN PLACE TO ENSURE THAT ALLOWABLE COSTS ARE CHARGED TO THE GRANT. THIS WILL BE COMPLETED TODAY NOVEMBER 14, 2022.

Name of Auditee: Walnut Grove Non-Profit Housing FHA Auditee Identification Number: 126-EE045 Period Covered by the Audit: Year ended December 31, 2022 CAP provided by: Name: Andrea Bean Position: Director of Property Management Telephone Number: 360-694-2501 Finding 2022-001: 1. Statement of Condition: One of the tenant files selected for review did not perform the annual recertification for 2022. 2. Cause: No annual recertification was done for one tenant file in 2022 due to staff turnover. 3. Actions Taken on the Finding: Site staff are currently working with the resident to complete missing AR and will make any necessary adjustments to the resident ledger. Management?s corrective action plan includes processing monthly outstanding AR reporting from our Management software by our Compliance Specialist. These monthly reports will be provided to our Housing Portfolio Managers and reviewed with site staff to ensure that AR?s are completed timely and provide additional monitoring to prevent AR?s being missed in the future.

Management?s Response to Known Questions Cost Non-Major Federal Programs with Known Questioned Costs in Excess of $25,000 2022-001--Allowable Costs/Cost Principles Federal Agency: U.S. Department of Health and Human Services Federal Program: ALN 93.575 - Child Care and Development Block Grant - Passed through New York State Office of Children and Family Services. Grant/Pass through Number: A-11279 Grant Period: Year ended April 30, 2022 Condition: The Organization expended Child Care Stabilization Grant funds on the resurfacing of a parking lot. Criteria: In accordance with Child Care and Development Block Grant regulations (45 CFR 95.56(b)(1)) no funds shall be expended for the purchase or improvement of land, or for the purchase, construction, or permanent improvement of any building or facility. 45 CFR 98.2 defines ?facility? to include real property used for a childcare program. Cause: The Organization relied on preliminary information provided by the grantor in its decision to use the grant funds to increase accessibility to the childcare center by resurfacing the parking lot. The federal program was not initially identified by the grantor or verified by the Organization prior to the Organization expending the funds. Context: The condition was identified through other audit procedures undertaken during the audit of the financial statements and was not identified as part of a statistically valid sample. The condition was not identified in other audit testing and appears to be an isolated incident. Effect: The Organization was not in compliance with federal allowable cost principles and the related costs may need to be returned. Questioned Costs: $66,830 Recommendation: Procedures should be put in place to ensure that the Organization has confirmed the source of grants funds, as well as any limitation on allowable costs, prior to expending the funds. Managements Response: At the time of our decision, we be believed this cost to be allowable. This based on a webinar by New York State Head Start Collaboration office on the Stabilization Grant on 9/13/2021. During this webinar the question was asked about a parking lot, and it was indicated that we need to get 3 quotes and ensure prevailing wages are paid. At the time the frequently asked question from the state dated 7/20/2021 did not directly address resurfacing a parking lot. This was done to fill several potholes for children and building safety. The parking lot was done in November of 2021. On 4/19/22 the New York States frequently asked question were updated to specifically noting that resurfacing a parking lot was not an allowable use of funds. While we believe our decision was based on information that indicated the cost was allowable at the time of the decision we have since updated our policies and procedures to strengthen them. The Executive Director Janett Rodriguez (jrodriguez@hseoc.org) and Finance Director Sam Breyer(sbreyer@hseoc.org) are responsible for get board approval during the November 1, 2022 meeting and implementation of the below adjustment to our policies and procedure. 1. HSEOC has updated our policy FIS-30-0106 Procurement procedures to include a. HSEOC will get in writing where practical for funding not under covered under 45 CFR part 75. b. HSEOC will also get conformation from the nontraditional funding sources. 2. HSEOC training plan has been updated to include training for additional nontraditional funding sources for the Executive Director, Finance Director, and any Service Area Manager that may manage the funds when these funds are awarded. 3. Filling out of a purchase order process has been updated to include funding source that are not traditional to allow to allowability as a check point. Executive Director, Janett Rodriguez (jrodriguez@hseoc.org) 845-422-8379, and Finance Director, Sam Breyer (sbreyer@hseoc.org) 845-613-3089 are responsible for the implementation of the corrective action plan. Sincerely, Samuel A. Breyer Finance Director

Name of auditee: Lil Jackson Senior Community HUD auditee identification number: 122-EE032 Name of audit firm: Dauby O'Connor & Zaleski, LLC Period covered by the audit: Year ended September 30, 2022 CAP prepared by Name: Mary Grace Crisostomo Position: Asset Manager Telephone number: (818) 247-0420 Current Findings on the Schedule of Findings, Questioned Costs, and Recommendations Finding 2022-001: Comments on the Finding and Each Recommendation During the year ended September 30, 2022, management made duplicate withdrawals from the reserve for replacements account totaling $857. The reserve for replacements account was not reimbursed for these duplicate withdrawals. Management should transfer funds of $857 from the operating cash account to the reserve for replacements account. Action(s) taken or planned on the finding Management concurs with the finding and the auditor's recommendation. Management intends to transfer $857 from the operating cash account to the reserve for replacements account.

Responsible Party: Felicia Milton, CFO Anticipated Completion Date: March 30, 2023 ELC Management will make sure that measures are in place to monitor and ensure that the Coalition will remain in compliance with grantor administrative expense requirements.

Item 2022-005 Condition: During the process of identifying expenses and capital costs that were incurred to prevent, prepare for or respond to the coronavirus pandemic, management included capital items for which there was a lack of supporting documentation. Planned Corrective Action: Management agrees with the noted finding. However, the Hospital had also incurred sufficient unreimbursed expenses that if the noted questioned costs had not been reported, the Hospital would have satisfactorily incurred eligible expenses in excess of the PRF funds received, including interest earned on such funds. Management will continue to refine processes to more diligently review expenses to ensure that expenses are not being utilized for reimbursement from multiple sources. Contact Person: Amanda Davidson, Chief Financial Officer Anticipated Completion Date: Ongoing

Item 2022-004 Condition: During the process of identifying expenses that were incurred to prevent, prepare for or respond to the coronavirus pandemic, certain expenses that were reported in the PRF submission were not reduced by amounts reimbursed by other sources. Planned Corrective Action: Management agrees with the noted finding. However, the Hospital had also incurred sufficiency lost revenue that if the noted questioned costs had not been reported, the Hospital would have satisfactorily incurred eligible expenses in excess of the PRF funds received, including interest earned on such funds. Management will continue to refine processes to more diligently review expenses to ensure that expenses are not being utilized for reimbursement from multiple sources. Contact Person: Amanda Davidson, Chief Financial Officer Anticipated Completion Date: Ongoing

Finding No. 2022-002 Program: U.S. DEPARTMENT OF EDUCATION Passed through the Commonwealth of Massachusetts?Department of Elementary and Secondary Education Material Weakness 2022-002: Special Education Cluster ? SPED Grants to States, IDEA, Part B (Assistance Listing #84.027) Pass-through program number: 0240-577419-2022-0645; Fiscal year ending June 30, 2022 Auditor?s Recommendation: The District should review currently established policies and procedures for maintenance of time and effort certifications as established within adopted grants manual. Personnel should review established policies and procedures on a routine basis to ensure the District?s compliance with all aspects of the District?s established policies and procedures as well as individual requirements pursuant to OMB. Established policies and procedures should be reviewed on an annual basis to ensure continued compliance with ever changing federal compliance and other financial reporting requirements. Action Taken: As indicated by the auditor, the budgeting for the 240 SPED allocation grant in fiscal year 2023 has been changed to exclude personnel costs (salaries & wages) subject to the ?time & effort? certifications. Therefore, ?time & effort? requirements will no longer be associated with this program. District personnel will continue to review established grants policies and procedures manual with current federal awards administration.

ASI - FREEPORT SENIOR HOUSING, INC. HUD PROJECT NO. 071-EE224 CORRECTIVE ACTION PLAN YEAR ENDED JUNE 30, 2022 DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT ASI - Freeport 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 overpaid management fees to the management company. Recommendation: The management company should repay the $3,454 to the Project. Action Taken: The Project agrees with the finding. The management company will repay the overpaid management fees as soon as possible. If the Department of Housing and Urban Development has questions regarding this plan, please call Les Russo at 847-424-5601.

For future disasters, the City will discuss with all vendors exactly what documentation will be required before work begins.

This lapse was a result of delay in submission and approval of time charged by a consultant (operated outside of our automated time sheet controls). We will ensure the allocation is done after the actual time charge is made. We will monitor more closely and train the finance staff in our subsidiary for charging depreciation to the projects.

Finding Summary: 36 out of 60 expenditures tested lacked timely approval of employees? actual time spent on the program. 5 out of 60 expenditures tested lacked employee signatures for certification of actual time spent on the program. 6 out of 60 expenditures tested were based on estimated fringe benefits. When compared to actual fringe benefits incurred, the amounts allocated to the program exceeded actual costs incurred Responsible Individuals: Program Directors, Director of Management Reporting Corrective Action Plan: Procedures will be established to ensure employee time charged to federal grants is documented, signed by employees, and reviewed and signed by program directors before each drawdown. Only actual fringe benefits will be charged to federal grants. Anticipated Completion Date: June 30, 2023

The management company should reimburse the project for overpaid management fee in the amount of $9,652 and will implement procedures to ensure that the management fee paid does not exceed the amount determined in accordance with the management agreement. On September 13, 2022, the management company repaid Comunidad del Retiro in the amount of $9,652.

All employees paid by Cost Allocation will be charged to the programs based on time sheets, this was fully implemented June 15, 2022

March 2, 2023 Shenandoah Area Agency on Aging respectfully submits the following corrective action plan for the year ended September 30, 2022. Name and address of independent public accounting firm: Brown, Edwards & Company, L.L.P. 1909 Financial Drive Harrisonburg, Virginia 22801 Audit period: September 30, 2022 The findings from the September 30, 2022 Schedule of Findings and Questioned Costs (the "Schedule") are discussed below. The findings are numbered consistently with the number assigned in the Schedule. FINDINGS - FINANCIAL STATEMENT AUDIT 2022-004: Authorized Signer for Bank Accounts Condition: Four bank confirmations signed by the executive director were sent to financial institutions holding SAAA assets as part of our audit were denied due to being signed by an unauthorized individual. Criteria: As part of management's responsibility to safeguard assets, the authorized signer for bank accounts should be documented. Cause: Management was unaware the listing of authorized check signers had not been updated by the bank as requested. Effect: It is critical for an entity to be able to access its cash deposits held by financial institutions. When a listing of authorized signers is not updated, the entity opens itself to opportunities for loss. Terminated employees may still have access to organizational assets or the organization may be prohibited from accessing their accounts at financial institutions if there is no perceived authority to access the funds. FINDINGS-FINANCIAL STATEMENT AUDIT (Continued) 2022-004: Authorized Signer for Bank Accounts (Continued) Recommendation: Management or governance should determine who has access to bank accounts and ensure only the appropriate parties maintain ongoing access for the safekeeping of the organization's assets. Planned Corrective Action: This finding was caused by the bank not updating its signature cards as requested by the Agency. This finding was immediately corrected once identified by the auditors. 2022-005: Material Audit Adjustments Condition: During the audit, we detected one material misstatement in the trial balance presented to us to begin our audit that was considered a material audit correction. Criteria: Generally accepted auditing standards dictates that detection of errors in an audit is a strong indicator of a significant deficiency or material weakness. Accordingly, we are required to communicate this finding as such. Cause: Financial information was missing or inaccurate. Effect: Assets and liabilities were overstated. Recommendation: We recommend that management implement a process to ensure accuracy of balance sheet and statement of activity accounts. Planned Corrective Action: Management agrees with the finding. During the last quarter of the fiscal year, the finance department experienced a vacancy. As a result, we were short-handed. There was one account that was not reconciled in a timely manner. After the year end, the position has since been filled. All significant balance sheets will be reconciled in a timely manner as in previous years. FINDINGS AND QUESTIONED COSTS- MAJOR FEDERAL AWARD PROGRAM AUDIT 2022-001: Cost Sharing Fees, ALN 93.045 Special Programs for the Aging - Title III, Part Cl - Nutrition services and Special Programs for the Aging-Title III, Part C2 - Nutrition services, Program income Condition: Individuals receiving Title III-C funded services for home delivered meals were charged cost sharing fees. Criteria: Agencies providing services funded under the Title III-C programs may not charge cost sharing fees for the Title 111-C services under Title III-C per 42 U.S. Code? 3030 c-2(a)(2). Cause: No controls or processes were in place to prevent cost sharing fees being charged to individuals receiving services provided under Title III-C programs. Effect: The cost sharing fees for Title III-C services are not allowed under federal guidelines and therefore these fees are considered a questioned cost. Questioned Cost Amount: $4,400 Perspective Information: Noted two fees were charged for Title 111-C services out of a sample of twenty-five cost sharing fees. Recommendation: Cost sharing fees are not allowed to be charged for Title III-C services provided to individuals. Only voluntary contributions may be made for these services. Management should implement procedures to ensure these fees do not continue to be charged. Planned Corrective Action: Management agrees with the finding. As noted in finding 2022-005, the vacant position, which has now been filled, was responsible for compliance review. Additional procedural reviews and corrected report formatting have been implemented to prohibit cost-sharing fees from being charged to the program. FINDINGS AND QUESTIONED COSTS - MAJOR FEDERAL AWARD PROGRAM AUDIT (Continued) 2022-002: Unallowable Costs, ALN 93.053 Nutrition Services Incentive Program, Allowable Costs Condition: Administrative expenditures were improperly classified as expenditures funded by the Nutrition Services Incentive Program (NSIP). Criteria: NSIP funds may only be used to purchase domestic foods as outlined under Title 7 U.S. Code of Federal Regulations Part 250.68, Nutrition Services Incentive Program. Grant funding received through NSIP may not be used to pay for administration or other services. Cause: Unallowable costs were improperly classified to the financial records supporting NSIP expenditures and allowable costs were improperly allocated to other projects. Effect: Financial records supporting costs expensed under the NSIP award do not reflect the nature of the expenditures requested for reimbursement. Expenditures were misclassified within the financial records to improper programs and thus are considered a questioned cost. Questioned Cost Amount: $98,327 Perspective Information: Noted in one out of a sample of twenty-five expenditures charged to the Aging Cluster. Two of the items in the sample were expenditures charged to NSIP. We reviewed the list of the remaining expenditures charged to NSIP and confirmed the sample was representative of the entire population. Recommendation: It is critical for the underlying financial records to support an organization's claims for costs reimbursements under federal award programs with adequate documentation. Staff must allocate costs appropriately for allowable costs under each federal program and ensure expenditures charged to the federal programs are for appropriate purposes and are properly classified in the records to avoid noncompliance with federal regulations and program requirements. Planned Corrective Action: Management partially agrees with the finding. We agree that certain amounts were misapplied to the NSIP account. However, the funds did purchase food as required by the grant. We believe this to be a reporting error and not a misuse of grant funds. With the vacant position recently filled, we have added additional review procedures to prevent any reoccurrence of misapplication. FINDINGS AND QUESTIONED COSTS- MAJOR FEDERAL AWARD PROGRAM AUDIT (Continued) 2022-003: Annual Reporting to VDARS, ALN 93.044 Special Programs for the Aging- Title III, Part B- Grants for Supporting Services and Senior Centers, ALN 93.045 Special Programs for the Aging - Title III, Part Cl - Nutrition Services, ALN 93.053 Nutrition Services Incentive Program, Reporting Condition: The 13th Aging Monthly Report required by the pass through agency, Virginia Department of Aging and Rehabilitative Services (VDARS) was not submitted timely and contained inaccurate revenue and expenditure data. Criteria: VDARS requires the annual I3th Month Aging Monthly Report to be submitted by November 15t?h The report must contain complete and accurate information as a restating of the monthly reporting for the fiscal year. Cause: The 131 Aging Monthly Report was not reconciled to underlying financial records, resulting in unexplained differences between the report and trial balance provided as part of the audit. Additionally, the report was not submitted by November 15, 2022. Effect: The submission of the 13th AMR was not performed timely and included data that did not agree to underlying financial records. This should have been caught during the course of a review process before submission. Therefore, it is considered a significant deficiency of internal controls over compliance. Recommendation: Ensure reporting is submitted timely by the deadline stated by VDARS. Implement a review process for each monthly submission, including documentation of the review. Reconcile the federal, state and local totals reported in the Aging Monthly Report to the underlying financial records as stated in the financial system to ensure accuracy before submission to VDARS. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. The AMR report was not filed in a timely manner. As noted in finding 2022-0005, the vacated position during the last quarter of the year was responsible for submittals. We note that the report has since been filed. With the position being filled, we believe the 13th AMR will be filed in a timely and accurate manner as in previous years. If the Federal Audit Clearinghouse has questions regarding this plan, please call Cindy Donaldson, Director of Finance at 540-635-7141. Sincerely yours,

March 2, 2023 Shenandoah Area Agency on Aging respectfully submits the following corrective action plan for the year ended September 30, 2022. Name and address of independent public accounting firm: Brown, Edwards & Company, L.L.P. 1909 Financial Drive Harrisonburg, Virginia 22801 Audit period: September 30, 2022 The findings from the September 30, 2022 Schedule of Findings and Questioned Costs (the "Schedule") are discussed below. The findings are numbered consistently with the number assigned in the Schedule. FINDINGS - FINANCIAL STATEMENT AUDIT 2022-004: Authorized Signer for Bank Accounts Condition: Four bank confirmations signed by the executive director were sent to financial institutions holding SAAA assets as part of our audit were denied due to being signed by an unauthorized individual. Criteria: As part of management's responsibility to safeguard assets, the authorized signer for bank accounts should be documented. Cause: Management was unaware the listing of authorized check signers had not been updated by the bank as requested. Effect: It is critical for an entity to be able to access its cash deposits held by financial institutions. When a listing of authorized signers is not updated, the entity opens itself to opportunities for loss. Terminated employees may still have access to organizational assets or the organization may be prohibited from accessing their accounts at financial institutions if there is no perceived authority to access the funds. FINDINGS-FINANCIAL STATEMENT AUDIT (Continued) 2022-004: Authorized Signer for Bank Accounts (Continued) Recommendation: Management or governance should determine who has access to bank accounts and ensure only the appropriate parties maintain ongoing access for the safekeeping of the organization's assets. Planned Corrective Action: This finding was caused by the bank not updating its signature cards as requested by the Agency. This finding was immediately corrected once identified by the auditors. 2022-005: Material Audit Adjustments Condition: During the audit, we detected one material misstatement in the trial balance presented to us to begin our audit that was considered a material audit correction. Criteria: Generally accepted auditing standards dictates that detection of errors in an audit is a strong indicator of a significant deficiency or material weakness. Accordingly, we are required to communicate this finding as such. Cause: Financial information was missing or inaccurate. Effect: Assets and liabilities were overstated. Recommendation: We recommend that management implement a process to ensure accuracy of balance sheet and statement of activity accounts. Planned Corrective Action: Management agrees with the finding. During the last quarter of the fiscal year, the finance department experienced a vacancy. As a result, we were short-handed. There was one account that was not reconciled in a timely manner. After the year end, the position has since been filled. All significant balance sheets will be reconciled in a timely manner as in previous years. FINDINGS AND QUESTIONED COSTS- MAJOR FEDERAL AWARD PROGRAM AUDIT 2022-001: Cost Sharing Fees, ALN 93.045 Special Programs for the Aging - Title III, Part Cl - Nutrition services and Special Programs for the Aging-Title III, Part C2 - Nutrition services, Program income Condition: Individuals receiving Title III-C funded services for home delivered meals were charged cost sharing fees. Criteria: Agencies providing services funded under the Title III-C programs may not charge cost sharing fees for the Title 111-C services under Title III-C per 42 U.S. Code? 3030 c-2(a)(2). Cause: No controls or processes were in place to prevent cost sharing fees being charged to individuals receiving services provided under Title III-C programs. Effect: The cost sharing fees for Title III-C services are not allowed under federal guidelines and therefore these fees are considered a questioned cost. Questioned Cost Amount: $4,400 Perspective Information: Noted two fees were charged for Title 111-C services out of a sample of twenty-five cost sharing fees. Recommendation: Cost sharing fees are not allowed to be charged for Title III-C services provided to individuals. Only voluntary contributions may be made for these services. Management should implement procedures to ensure these fees do not continue to be charged. Planned Corrective Action: Management agrees with the finding. As noted in finding 2022-005, the vacant position, which has now been filled, was responsible for compliance review. Additional procedural reviews and corrected report formatting have been implemented to prohibit cost-sharing fees from being charged to the program. FINDINGS AND QUESTIONED COSTS - MAJOR FEDERAL AWARD PROGRAM AUDIT (Continued) 2022-002: Unallowable Costs, ALN 93.053 Nutrition Services Incentive Program, Allowable Costs Condition: Administrative expenditures were improperly classified as expenditures funded by the Nutrition Services Incentive Program (NSIP). Criteria: NSIP funds may only be used to purchase domestic foods as outlined under Title 7 U.S. Code of Federal Regulations Part 250.68, Nutrition Services Incentive Program. Grant funding received through NSIP may not be used to pay for administration or other services. Cause: Unallowable costs were improperly classified to the financial records supporting NSIP expenditures and allowable costs were improperly allocated to other projects. Effect: Financial records supporting costs expensed under the NSIP award do not reflect the nature of the expenditures requested for reimbursement. Expenditures were misclassified within the financial records to improper programs and thus are considered a questioned cost. Questioned Cost Amount: $98,327 Perspective Information: Noted in one out of a sample of twenty-five expenditures charged to the Aging Cluster. Two of the items in the sample were expenditures charged to NSIP. We reviewed the list of the remaining expenditures charged to NSIP and confirmed the sample was representative of the entire population. Recommendation: It is critical for the underlying financial records to support an organization's claims for costs reimbursements under federal award programs with adequate documentation. Staff must allocate costs appropriately for allowable costs under each federal program and ensure expenditures charged to the federal programs are for appropriate purposes and are properly classified in the records to avoid noncompliance with federal regulations and program requirements. Planned Corrective Action: Management partially agrees with the finding. We agree that certain amounts were misapplied to the NSIP account. However, the funds did purchase food as required by the grant. We believe this to be a reporting error and not a misuse of grant funds. With the vacant position recently filled, we have added additional review procedures to prevent any reoccurrence of misapplication. FINDINGS AND QUESTIONED COSTS- MAJOR FEDERAL AWARD PROGRAM AUDIT (Continued) 2022-003: Annual Reporting to VDARS, ALN 93.044 Special Programs for the Aging- Title III, Part B- Grants for Supporting Services and Senior Centers, ALN 93.045 Special Programs for the Aging - Title III, Part Cl - Nutrition Services, ALN 93.053 Nutrition Services Incentive Program, Reporting Condition: The 13th Aging Monthly Report required by the pass through agency, Virginia Department of Aging and Rehabilitative Services (VDARS) was not submitted timely and contained inaccurate revenue and expenditure data. Criteria: VDARS requires the annual I3th Month Aging Monthly Report to be submitted by November 15t?h The report must contain complete and accurate information as a restating of the monthly reporting for the fiscal year. Cause: The 131 Aging Monthly Report was not reconciled to underlying financial records, resulting in unexplained differences between the report and trial balance provided as part of the audit. Additionally, the report was not submitted by November 15, 2022. Effect: The submission of the 13th AMR was not performed timely and included data that did not agree to underlying financial records. This should have been caught during the course of a review process before submission. Therefore, it is considered a significant deficiency of internal controls over compliance. Recommendation: Ensure reporting is submitted timely by the deadline stated by VDARS. Implement a review process for each monthly submission, including documentation of the review. Reconcile the federal, state and local totals reported in the Aging Monthly Report to the underlying financial records as stated in the financial system to ensure accuracy before submission to VDARS. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. The AMR report was not filed in a timely manner. As noted in finding 2022-0005, the vacated position during the last quarter of the year was responsible for submittals. We note that the report has since been filed. With the position being filled, we believe the 13th AMR will be filed in a timely and accurate manner as in previous years. If the Federal Audit Clearinghouse has questions regarding this plan, please call Cindy Donaldson, Director of Finance at 540-635-7141. Sincerely yours,

FEDERAL AWARDS FINDINGS AND QUESTIONED COSTS 2022-001: Material weakness in compliance and internal control over compliance: Allowable Costs/Cost Principles: AL 09.610090 Legal Services Corporation Recommendation: We recommend that the Organization assess the current level of staff needed by the Finance Department to ensure grant activity is recorded properly and in compliance with the grant requirements. The allocation of indirect expenses should be reviewed on a regular basis to determine the appropriateness of the allocations throughout the year. As a result of the audit process, management has altered the manner in which indirect costs are allocated, and, if applied properly and consistently, this revised method should resolve the issues associated with indirect cost allocations for 2023. Action Taken: CCLA Management agrees that the timeliness of information is imperative to the preparation and completion of the year-end audit. The staffing levels are being evaluated including the analysis of the appropriate staff categories. Management of the Organization is working on developing a more effective methodology to track grants and the allocation of indirect costs. The new fiscal year budget will include the recruitment of an experienced Contracts & Grant Manager to provide the department with accurate reporting of grant funding. As indicated below, the project to restructure the financial and administrative operations of CCLA is well under way. CCLA?s plan is to complete the implementation of key components of the plan in 2023, in time to completely resolve the issues raised in the 2022 audit and complete the 2023 audit with no material weaknesses or questioned costs. Major Milestones Planned Completion Status Project Start 2/1/23 Done Interim Project Review #1 to CCLA Board 2/15/23 Done Begin Stakeholder Interviews 3/1/23 Done Complete Stakeholder Interviews 4/1/23 Done Interim Project Update #2 to CCLA Board 4/19/23 Done Update Mayuris Pimentel: LSC 4/25/23 Done Completion of Project Assessment Process 5/31/23 Complete First Draft of Plan 6/7/23 Project Presentation to CCLA Board 6/14/23 Written Final Report Delivered to CCLA 6/21/23 Final Report Forwarded to Legal Services Corp. 7/1/23

Finding ref number: 2022-001 Finding caption: The District did not have adequate internal controls in place to ensure accurate reporting of its Schedule of Expenditures of Federal Awards Name, address, and telephone of District contact person: Leslie Oliver, ESD Business Manager, PO Box 367, Keller WA 99140 (509) 725-1481 Corrective action the auditee plans to take in response to the finding: The District recognizes and acknowledges deficiencies and errors by the District and its financial management contractor in collecting and reporting data pursuant to its Impact Aid application to the Federal Department of Education. While it has not been possible to identify how these originated, they appear to have been in place for a number of years, perhaps more than a decade, related to Washington State?s broad school choice policies and, not identified in previous audits by either Federal or State agencies. Regardless, the District has satisfactorily resolved outstanding data collection and reporting issues with the Department and has put in place administrative controls via training and oversight to comply with requirements. In the past ten months since the deficiencies were identified, the District has taken the following steps to address those and to come into compliance. The District Superintendent, District Secretary and Chair of the School Board were tasked with communicating and negotiating with Department officials. In a series of Zoom meetings, trainings and phone calls, the District team was made aware of the deficiencies, provided with guidance of strategies to correct those and with guidance on addressing the effects of Washington State?s school choice policies on Impact Aid. As a result of that guidance, the District corrected its data collection and validation methodology, proposed and negotiated tuition agreements with three adjoining Districts, proposed and negotiated repayment agreements with those Districts and the Department. Future data collection and validation will be reviewed by the District?s financial management contractor, Education Service District 101. District administration and Board will send representatives to attend the annual conference of the National Association of Federally Impacted Schools in Washington, DC, and to meet with Department staff to review the application and its data. The District will take part in any relevant training opportunities offered by the Department or by the Office of the Superintendent of Public Instruction. Anticipated date to complete the corrective action: immediate action in 2023

2022-002 ? Student Financial Aid Cluster ? (a) Federal Supplemental Educational Opportunity Grants (b) Federal Work Study Program (c) Federal Perkins Loan Program ? Federal Capital Contributions (d) Federal Pell Grant Program (e) Federal Direct Student Loans (f) Teacher Education Assistance for College and Higher Education (TEACH), Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.038 (d) 84.063 (e) 84.268 (f) 84.379 ? Year Ended June 30, 2022 Condition: The University did not properly return loan funds subsequent to the R2T4 calculation for no passing grades withdrawal students for 1 out of the 12 students tested (8.3%) due to failing to return the required PLUS loans based on the calculation. Further, the amount of direct student loan funds returned was later disbursed to the student again due to lack of documentation in the University?s system of the unofficial withdrawal. We consider this to be an instance of noncompliance in relation to Special Tests and Provisions. Statistical sampling was not used. Management Response: The error identified above was made on a student?s record who did not officially withdraw from the University. As required by federal regulation, an ?all F?s? report is pulled at the end of each term and a determination is made for all students included on the report whether or not they attended classes until the end of the term. The student identified by the auditors was determined to have not attended the full Fall term. A return of title IV calculation was promptly processed by the Associate Director on the Department of Education?s website. The R2T4 calculation could not be processed via the SIS since the student did not have an official withdrawal date entered. The student loans were returned timely, however, the parent PLUS loan was missed in returning the funds. Subsequently the student contacted our office to challenge the withdrawal date and claimed he had attended classes all term and earned all of the loan funds that were disbursed for the term. There was no documentation in our SIS so the loans were reinstated in error. Corrective Action Plan: R2T4 procedures were updated to include a secondary confirmation of the return of loan funds according to the calculation. This secondary review will be scheduled at the time the R2T4 calculation is processed. Further, the procedure was updated to include entry of notes on the student?s electronic record to avoid reversal if challenged by the student. Responsible Person: Chilwana Thompson, Associate Director Implementation Date: August 1, 2022

2022-001 ? Student Financial Aid Cluster ? (a) Federal Supplemental Educational Opportunity Grants (b) Federal Work Study Program (c) Federal Perkins Loan Program ? Federal Capital Contributions (d) Federal Pell Grant Program (e) Federal Direct Student Loans (f) Teacher Education Assistance for College and Higher Education (TEACH), Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.038 (d) 84.063 (e) 84.268 (f) 84.379 ? Year Ended June 30, 2022 Condition: In three of the 40 student files tested (7.5%), Subsidized and Unsubsidized Direct loans were not properly awarded. The University under awarded one student $1,000 in Subsidized loans and over awarded the student by $1,000 in Subsidized loans. A second student was under awarded $2,560 in Subsidized loans and over awarded $2,560 in Unsubsidized loans. The third student was under awarded $862 in Unsubsidized loans. Management Response: All of the errors identified by the auditors were a direct result of manual miscalculation of loan eligibility. In two of the instances cited, the students had previous additional unsubsidized loans issued as a result of parent PLUS loan denials. When we received ISIR data these students were flagged with a reject due to aggregate loan limits. In order to calculate each student?s loan eligibility, a manual review of loan information via the U.S. Department of Education?s Common Origination and Disbursement (COD) portal is necessary. The additional unsubsidized loans disbursed as a result of PLUS denial, were manually removed from each student?s loan total to determine current year eligibility. In both instances, the total loan eligibility was correct, however the manual calculation of the subsidized versus unsubsidized split of the loan funds were miscalculated. In the last instance a student was under awarded $862 in unsubsidized loans, the miscalculation occurred due to receipt of an outside scholarship. In the Fall term the scholarship check was received with documentation indicating the disbursement was to be applied to the Fall term in it?s entirety and the Spring disbursement would follow. The outside scholarship caused the student to be over awarded and the student loans were adjusted to remain within cost of attendance limits. Subsequently the Spring term disbursement of the scholarship was received for $862 less than the Fall disbursement. At that time, the student should have been offered the additional $862 in unsubsidized loan funds to bring their total aid back up to cost of attendance. The staff person entering the scholarship payment on the student?s account failed to notify the loan coordinator an adjustment was warranted. Corrective Action Plan: The loan coordinator who made the errors has been in the position for just over a year. In order to prevent future issues in calculating a student?s loan limits and eligibility, the employee attended a loan regulation and processing overview course produced by the National Association of Financial Aid Administrators (NASFAA). Further, a form was developed to help calculate aggregate limits when an ISIR reject occurs in order to avoid missed steps in the calculation process. 2022-001 ? Student Financial Aid Cluster ? (a) Federal Supplemental Educational Opportunity Grants (b) Federal Work Study Program (c) Federal Perkins Loan Program ? Federal Capital Contributions (d) Federal Pell Grant Program (e) Federal Direct Student Loans (f) Teacher Education Assistance for College and Higher Education (TEACH), Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.038 (d) 84.063 (e) 84.268 (f) 84.379 ? Year Ended June 30, 2022 (Continued) As a result of the outside scholarship error, our procedures for entering an scholarship payment have been adjusted to include a final review of all outside scholarship disbursements entered by the loan coordinator. Responsible Person: Lynette Lambert, Assistant Director/Loan Coordinator Implementation Date: August 1, 2022

Finding 2022-002 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Section 8 Housing Choice Vouchers Programs Federal Catalog Numbers: 14.871 Noncompliance ? N. Special Tests and Provisions - Housing Quality Standards Non Compliance Material to the Financial Statements: No Significant Deficiency in Internal Control over Compliance for Special Tests and Provisions Criteria: Housing Quality Standards Inspections. The PHA must inspect the unit leased to a family at least annually to determine if the unit meets the Housing Quality Standards (HQS) and the PHA must conduct quality control re-inspections. The PHA must prepare a unit inspection report (24 CFR sections 982.158(d) and 982.405(b)). For units that fail inspection the PHA must correct all life threatening HQS deficiencies within 24 hours and all other deficiencies within 30 days. Condition: Based upon inspection of the Authority?s files and on discussion with management, there was a failed inspection that did not pass reinspection within 30 days without penalty. Context: There are approximately 5,068 units. Of a sample size of twenty-five (25) failed inspections, one failed inspection did not pass reinspection within 30 days. HAP was not abated nor was the tenant evicted. Our sample size is statistically valid. Known Questioned Costs: $10,276 Cause: There is a significant deficiency in internal controls over the compliance for the special tests and provisions type of compliance related to HQS inspections. The Authority has not properly performed HQS inspections in compliance with program requirements following the expiration of HUD waivers as a result of insufficient staffing . Effect: The Section 8 Housing Choice Vouchers Program is in non-compliance with the special tests and provisions type of compliance related to HQS inspections. Recommendation: We recommend the Authority design and implement a corrective action plan that will assure compliance with the Uniform Guidance and the compliance supplement. Views of responsible officials and planned corrective action: The Authority accepts the recommendation of the auditor. Following the expiration of the COVID-19 HUD regulatory waivers, the Authority experienced higher than usual rates of staff turnover and other staff capacity challenges related to the pandemic. Authority management is in the process of updating procedures and practices related to inspections and HAP abatement. Aaron Pomeroy, Finance Director, will be responsible to implement this corrective action by June 30, 2023.

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. Findings ? Federal Award Program Audit Finding 2022-001 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Section 8 Housing Choice Vouchers and Mainstream Vouchers Programs Federal Catalog Numbers: 14.871 and 14.879 Noncompliance ? E. Eligibility ? Tenant Files Non Compliance Material to the Financial Statements: No Significant Deficiency in Internal Control over Compliance for Eligibility Criteria: Tenant Files. The PHA must do the following: As a condition of admission or continued occupancy, require the tenant and other family member to provide necessary information, documentation, and releases for the PHA to verify income eligibility (24 CFR sections 5.230, 5.609, and 982.516). These files are required to be maintained and available for examination at the time of audit. Condition: Based upon inspection of the Authority?s files and on discussion with management, there were documents that were unavailable for examination at the time of audit. Context: There are approximately 5,068 units. Of a sample size of fifty-nine (59) tenant files, the following was noted: - HUD 9887 Form was missing in 4 files - Annual HUD 50058 recertification form and verification of income and assets was missing in 1 file - Lead based paint disclosure form was missing in 1 file Our sample size is statistically valid. Known Questioned Costs: $59,947 Cause: There is a significant deficiency in compliance for the eligibility type of compliance related to the maintenance of tenant files. The Authority has not properly maintained tenant files in compliance with program requirements following the expiration of HUD waivers as a result of insufficient staffing. Effect: The Section 8 Housing Choice Vouchers and Mainstream Vouchers Programs are in non-compliance with the eligibility type of compliance related to the maintenance of tenant files. Recommendation: We recommend the Authority design and implement a corrective action plan that will assure compliance with the Uniform Guidance and the compliance supplement. Views of responsible officials and planned corrective action: The Authority accepts the recommendation of the auditor. Following the expiration of the COVID-19 HUD regulatory waivers, the Authority experienced a large backlog of reexaminations along with higher than usual rates of staff turnover and other staff capacity challenges related to the pandemic. Authority management has developed and implemented a plan to rapidly work through the backlog, bringing the program into compliance. Current HUD SEMAP data reflects that 96% of reexaminations have been completed in a timely manner, which is high enough to provide full points for this SEMAP indicator. Authority management will continue to monitor and strive towards 100% timely recertifications by the end of this fiscal year. Aaron Pomeroy, Finance Director, will be responsible to implement this corrective action by June 30, 2023.

Finding Number: 2022-003 Condition: The Corporation repaid approximately $188,000 of owner advances without HUD?s approval resulting in an unauthorized use of operating cash. Planned Corrective Action: The related party has repaid the Corporation by returning the $188,000 that was paid to the related parties without HUD approval. Contact person responsible for corrective action: Tanya Hahn Anticipated Completion Date: March 27, 2023

Finding Reference 2022-009 Contact Person: Gerald Moench, Interim CFO (or Emily Buckley, VP of Advancement) Views of Responsible Officials and Planned Corrective Action: In including the questioned indirect cost as a HEERF expense, management only considered the per unit cost threshold, rather than both the per unit cost and the expected life of the items. The audit clarified the regulations and Donnelly promptly notified our program officer, posted a corrected quarterly report and refunded the funds to the Department of Education. Anticipated Completion Date: October 2022