Corrective Action Plans

Department of Health and Human Services Response/Corrective Action Plan The Department of Health and Human Services agrees with the recommendation. HHS has begun the process of recoupment and will work to receive full repayment, to date the balance remaining was $5,000 and a payment plan has been sent up to recoup the remaining amount. The Accounts Payable team will collaborate with OMB to implement additional processes within Peoplesoft to verify payment information in the future. Currently, we are working to add display options in the Mass Voucher Approval screen to allow for tallying of the totals of vouchers in range. This addition will enhance the review step to ensure payments are consistent with Program totals for a secondary check before approval of payments are made. Contact Person: Karol Riedman, Assistant CFO Ann Scott, AP Accounting Manager Anticipated Completion Date: 06/30/2025

Department of Health and Human Services Response/Corrective Action Plan The Department of Health and Human Services agrees with the recommendation. The department will monitor expenses within the budget and grant period based on guidance from the federal agency to ensure that the date of expenditures are not claimed before grant funds are received. Contact Person: Eric Haas, Assistant CFO Anticipated Completion Date: December 2024

Department of Health and Human Services Response/Corrective Action Plan The Department of Health and Human Services agrees with the recommendation. To address this, the department will run quarterly reports from AWARE to identify any payments charged to the incorrect period of performance. Grant guidance has been updated to ensure items with unique service dates are properly reviewed. Additionally, during the three-month liquidation period, a monthly review of all expenditures will be conducted to verify they are applied to the correct period of performance. These actions will strengthen oversight and ensure compliance with grant requirements. Contact Person: Eric Haas, Assistant CFO Anticipated Completion Date: December 2024

Department of Health and Human Services Response/Corrective Action Plan The Department of Health and Human Services agrees with the recommendation. During review of audit found two overpayment errors as a result of outdated supporting documents. Refunds have been requested. HHS provides ongoing training with eligibility and supervisory staff regarding document and eligibility requirements with staff. HHS actively monitors application quality and provides ongoing quality control reviews ensuring consistent adherence to best practices. Contact Person: Jessica Thomasson, Executive Policy Director Anticipated Completion Date: October 2024

Department of Health and Human Services Response/Corrective Action Plan The Department of Health and Human services agrees with the recommendation. WIC special formula distribution costs from August 2022 were invoiced in January 2023, exceeding the 120-day closeout period for the FFY22 grant. HHS has addressed the issue with the vendor and will follow up to ensure future invoices are received promptly and aligned with the correct fiscal year. Contact Person: Karol Riedman, Assistant CFO Anticipated Completion Date: August 28, 2024

Department of Public Instruction Response/Corrective Action Plan: We agree with the finding. The issue has already been corrected as stated in the finding. Contact Person: Jamie Mertz, CFO Anticipated Completion Date: The issue has already been corrected.

2024-001 Eligibility Material Weakness/Material Noncompliance CFDA#:14.850 – Public Housing Operating Fund This finding was corrected as of June 30, 2024. Tenants were reimbursed for their excess rental payments during the fiscal year ending June 30, 2024. In addition, a policy was established to review the utility allowances for the Public Housing program every January and to review the Section 8 program every October. The Comptroller, Jennifer Yager, confirms that this new policy was in place effective June 30, 2024 and that tenants were reimbursed for the excess rental payments as of June 30, 2024. Jennifer can be reached at 203-596-2640.

Unallowed Costs

xx

Recommendation - We recommend that the Administrative Offices review all reimbursement requests submitted to the Louisiana Governor’s Office of Homeland Security and Emergency Preparedness and return funding received in error back to the State of Louisiana.

Management’s Response - The Administrative Offices will work with its third party consultant to review reimbursement requests submitted for Hurricane Ida to the Louisiana Governor’s Office of Homeland Security and Emergency Preparedness and return funding received in error back to the State of Louisiana.

Contact Person Responsible for the Corrections - Director of Accounting.

Anticipated Completion Date - April 30, 2025.

Gabriel Linares, Director of Community Development, will enhance the department’s HOME assistance rules to ensure the value of the HOME-assisted property after rehabilitation will not exceed 95 percent of the median purchase price for the area starting Quarter 4, FY2024 -25. Personnel Responsible for Implementation: Gabriel Linares Position of Responsible Personnel: Director of Community Development Expected Date of Implementation: June 30, 2025

1. The District has consulted with the Arkansas Division of Elementary and Secondary Education, Child Nutrition Unit (DESE, CNU) for guidance and technical assistance. 2. Per CNU guidance, the District is in the process of submitting an amended claim for October 2023 to correct the $552 discrepancy. We anticipate acceptance of this claim, resolving the issue. 3. The District has fully implemented the required CEP compliance procedures and has trained personnel to ensure future claims adhere to federal and state regulations. 4. Standard Operating Procedures (SOP) for the Child Nutrition Program have been updated to prevent recurrence of this issue. The Earle School District is committed to ensuring full compliance with all federal and state regulations regarding Child Nutrition reimbursement claims. We appreciate the guidance provided by DESE, CNU and will continue to implement measures that strengthen our oversight and accountability.

View of Responsible Officials: IW has implemented enhanced procedures for capital expenditures allocated to Federal awards. These procedures include an additional compliance review before the capital cost is incurred to ensure adherence to all applicable rules and regulations, including obtaining a written prior approval from a granting agency. To further strengthen IW internal controls over Federal award management, IW has instituted regular quarterly meetings to review projected expenses to be charged to the Federal awards and discuss specific award compliance requirements applicable to these projected expenditures.

Office of Administration (OA) – SSBG: The Bureau of Financial Operations (BFO) will continue conducting during-the-award subrecipient monitoring for the SSBG based on the results of the documented risk assessment. As it relates to the cash management portion of the finding, given the relatively small amount of funds involved and the number of counties affected, DHS has determined that it is not economically feasible to change the payment methodology at this time. Anticipated Completion Date: 06/30/2025 Contact Name: Kelly Graham, Director, Division of Financial Policy and Operations

DHS: New Directions, Cash Grants The DHS Office of Income Maintenance (OIM) has implemented fiscal onsite monitoring starting October 1, 2024, which will be part of its regular program monitoring going forward. Anticipated Completion Date: 06/30/2025 Contact Name: Joel O’Donnell, Dir., Bureau of Prog. Support, OIM Alternatives to Abortion Despite repeated attempts and efforts by the DHS Office of Policy Development (OPD) to engage this subrecipient in monitoring activities, they were uncooperative and unresponsive to the requests and therefore regular monitoring was not completed. Effective December 31, 2023, the grant agreement with this subrecipient ended and was not renewed. Anticipated Completion Date: Completed Contact Name: Louie Marven, Executive Policy Specialist, OPD L&I: TANF Youth Development Program (TANF YDP) operations transitioned from the Bureau of Workforce Development Administration (BWDA) to the Bureau of Workforce Partnerships and Operations (BWPO) in January 2023. Due to this transition, BWPO did not conduct on-site monitoring of the TANF YDP program in program year 2023. BWPO did begin onsite monitoring in program year 2024 on a limited basis as a pilot with 3 local areas in September of 2024. BWPO plans to expand monitoring efforts in 2025 by aligning TANF YDP monitoring with the onsite WIOA Data Validation schedule. Larger areas will be monitored annually with smaller areas monitored on a 3-year rotating schedule concurrent with WIOA Data Validation which is expected to commence late summer or early fall 2025. BWPO intends to also facilitate exit meetings with each area monitored and provide a written communication within 45 days post monitoring to issue results, concerns, recommendations, and corrective actions as needed. The goal of monitoring activities is to ensure that TANF YDF funding is used for authorized purposes by subrecipients, in compliance with Federal statutes and regulations. Also, that the TANF YDP program is being implemented in accordance with current L&I policies and procedures. Anticipated Completion Date: 11/30/2025 Contact Name: Dorraine Rauch, Division Chief

A new monitoring component, consisting of fifteen measurable elements, has been developed to actively monitor compliance of the 52 Area Agencies on Aging (AAA) subrecipients through a revised Phase IX monitoring tool. The revised tool, used by three (3) Fiscal Field Representatives, includes questions regarding invoice verification, on-site monitoring, and checks that the monitoring tool the AAAs utilize adheres to all requirements. Citation documents point to the specific Chapter and Section of the Aging Service Policy and Procedure Manual for ease of reference. 1. Recognizing the need to formally document the process of monitoring, PDOA has drafted a AAA Fiscal Monitoring process map. 2. Actively working with Deloitte Consulting to finalize the process map with additional input by the Fiscal Field Representatives responsible for executing the annual requirement. 3. With the use of a monitoring log, PDOA has been working with the AAAs to correct reporting in preparation of the next round of monitoring. 4. A risk assessment has been developed to evaluate each subrecipient’s risk of noncompliance to proactively address any weaknesses in internal controls over Federal programs. 5. Pointed questions regarding the organization are included to gauge management’s ability to follow all terms and conditions of the contract. 6. General policies will be reviewed for adherence to all Federal and State regulations and the competence of personnel administering the programs. 7. Since multiple Federal funding streams are involved, a fiscal component will also be administered to review internal controls for financial issues. 8. The Risk Assessment tool has been distributed across the entire AAA Network and evaluations have been completed. 9. Performance Improvement Plans have been distributed to those found not in compliance. 10. The Comprehensive Aging Performance Evaluation (CAPE) is a new approach to PDOA’s evaluation of aging services provided by AAAs. It includes a review of programs such as Caregiver Support, OPTIONS, and Protective Services. A fiscal component is now included in the review which includes key fiscal performance measures. Part of the fiscal review is conducted virtually to evaluate the performance measures that can’t be completed off-site. 11. Performance Check-Ins previously launched in April 2024 as part of a Statewide Comprehensive Monitoring as a new form of regulatory measure to observe compliance with Older Adults Protective Services Act (OAPSA, 35 P.S. §§10225.101, et seq.), related 6 Pa. Code Chapter 15. regulations, and OAPSA Documentation Procedure Manual, Aging & Disability (A&D). Specific Fiscal components will relate to APD 05-01-09, APD 24-01-01, and the Cooperative Block Grant 2021-25 Agreement. 12. Despite PDOA recognizing time and insufficient staffing as a barrier to achieving the goal of performing a risk assessment for every AAA, we have surpassed our expectation of reaching half at a minimum by conducting a full assessment of all 52. 13. Follow-up procedures resulting from this finding will be reviewed and adjusted as needed to deliver optimal outcomes. Preliminary procedures will be directed to the agency’s audit review committee for resolution of completeness. 14. In the event the audit review committee determines additional steps beyond the monitoring efforts outlined above are insufficient, additional efforts will be communicated to the AAA network. Anticipated Completion Date: 06/30/2025 Contact Name: Jennifer Cave, Fiscal Management Specialist, PDOA Audit Liaison

L&I has taken the following steps to resolve the finding: - The system issue which caused the lack of denials was fixed in December 2024. - Maximum potential overpayment amount was estimated by getting a list of all those union hiring hall members since the launch of the new system and then removing the following from the list: - Those who registered for work. - Those exempt for other reasons. - Those denied benefits for other reasons. - Those with no payments for weeks beyond the 4th week of the claim. - The remaining individuals’ payments for the fifth week of the claim and later were totaled in January 2025: - 3,481 individuals - $22,597,596.92 - These amounts are described as “maximum” because only an individual review of each claim would reveal if the person was truly not properly registered and if weeks of benefits should be overpaid. - The Department is choosing to waive these individuals’ requirement to register based on UC law section 401(b)(6): The department may waive or alter the requirements of this subsection in cases or situations with respect to which the secretary finds that compliance with such requirements would be oppressive or which would be inconsistent with the purposes of this act. Since the individuals would currently be told of requirements they needed to meet in the past and, as a result, given debts to repay, this is oppressive in nature and inconsistent with the purpose behind the registration requirement. Anticipated Completion Date: Completed Contact Names: Stacy Walter, Management Analyst 2, Special Projects, Office of UC Service Centers; Rick Plesnarski, Management Supervisor, Special Projects Unit & Quality Assurance, Office of UC Service Centers

PDOA: 1. Designing a means to follow-up and ensure timely action of deficiencies through an audit tracking log to monitor reporting submissions, document when they were received, initiated, findings requiring follow-up, and subsequent steps to finalize the audit. 2. Management decisions for applicable findings will be issued and tracked. 3. Improvements have been made with regards to regularity in reporting to more effectively monitor activities of subrecipients consistently with respect to Federal statutes and regulations. 4. PDOA is looking to fill a vacant position with a focus of tracking subrecipient expenditures in the aggregate and tracking single audit submissions on a Commonwealth-wide basis since the Aging Cluster program is material and has material sub-granted expenditures in NSIP and Title III. 5. It is PDOA’s impression that having increased oversight of the SEFA will allow for timely dissemination of management decision letters (MDL) in the six-month timeframe for making a management decision for federal award findings. 6. Discussions have started regarding considerations to take enforcement action against noncompliance by building language into the terms and conditions of the Cooperative Block Grant Agreements to exercise ability to withhold funding as approved in the Cost Allocation Plan. 7. PDOA has reached out to the BAFM to verify all outstanding audit items for PDOA since action is required within six months of receipt. 8. Follow-up procedures resulting from this finding will be reviewed and adjusted as needed to deliver optimal outcomes. Anticipated Completion Date: 06/30/2025 Contact Name: Jennifer Cave, Fiscal Management Specialist, PDOA Audit Liaison PDA: PDA has added a Financial Management Specialist 1 (FMS1) to its complement with the primary duty of agency audit liaison. The FMS1 will report to the PDA’s Budget Office. This is a new position and role within the department and has training and certification requirements to complete which will allow the position to: 1. Evaluate single audit report submissions received from BAFM to determine program purpose acceptability by verifying, at a minimum, that all agency-funded programs are properly included on the applicable financial schedules; that findings affecting the agency contain sufficient information to facilitate a management decision; and that the subrecipient has submitted an adequate corrective action plan. 2. Issue management decisions relative to audit findings and crosscutting findings assigned to the agency for resolution, as required by 2 CFR §200.521. If responsible for the resolution of crosscutting findings, notify the affected agency or agencies upon resolution of such findings. 3. Impose or coordinate the imposition of remedial action in accordance with 2 CFR Part 200.339 and Management Directive 325.08 Amended, Remedies for Recipient Noncompliance with Audit Requirements, when subrecipients fail to comply with the provisions of Subpart F. The new FMS1 will help ensure effective and efficient audit resolutions. This newly created position will also be responsible for the department wide audit tracking log that is in development. Anticipated Completion Date: 06/30/2025 Contact Name: Nichole Nedinsky, Fiscal Management Specialist, PDA Audit Coordinator PDE: The PDE Audit Section is working with divisions to develop processes to ensure timely responses. A training will be conducted by April 2025 on audit procedures, best practices, and federal regulations governing single audit management decisions. Anticipated Completion Date: 04/30/2025 Contact Names: Clayton P. Carroll II, Audit Coordinator; Jessica Sites, Director, Bureau Financial Operations DEP: DEP has updated the concur subrecipient letter to include the specific language related to the management decision that was previously in our non-concur letters. This ensures whichever template is used, the management decision and related finding information will be included in the subrecipient letter. Revised letters were sent to both subrecipients, in which DEP was the lead agency and had findings for in the audited timeframe. Staff are reviewing all the steps of our standard operating procedures to ensure we will be in compliance regardless of whether DEP is or is not the lead agency and regardless of whether we are preparing a concur or non-concur letter for the subrecipient. Anticipated Completion Date: 06/30/2025 Contact Names: Jennifer Brandt, Senior Fiscal Mgmt. Specialist; Kristen Szwajkowski, Lead Fiscal Mgmt. Specialist DHS: As stated in the DHS finding response, this was the result of human oversight, and not a systemic issue with internal controls. We have reminded staff to make sure that a management decision is timely communicated to subrecipients at the time of making the management decision. Anticipated Completion Date: Completed Contact Names: David Bryan, Mgr., Audit Res. Section; Alexander Matolyak, Dir., Div. of Audit & Rev.

DHS: TANF – Child Care All applicable federal Notice of Awards (NOAs), which include the Federal Award Identification Number, will be emailed to the grantees both prior to the spending period and as they become available for the spending as indicated on the NOA. They will also be included in the annual Audit Guidelines. Anticipated Completion Date: Completed Contact Names: Nia Harris, Dir, Bur. of Early Learning Res. Center Ops.; Adrienne Smyth, Human Service Prgm. Executive; Paula Piasecky, Human Serv. Prgm. Rep. TANF – Other The DHS Office of Policy Development (OPD) will perform risk assessments for all grantees annually. Anticipated Completion Date: 06/30/2025 The DHS Office of Income Maintenance (OIM) reestablished the completion of risk assessments in the fall of 2024 and has provisionally completed them for all subrecipients, including TANF – Other, for FY23-24. The risk assessments seek to test various financial controls of subrecipients based on their risk assessment scores and will also assist in ranking subrecipients across the risk continuum. Anticipated Completion Date: Completed Contact Names: Louie Marven, OPD, Exec. Policy Splst.; Sheldon Marcus, OIM, Dir., Div. of Mgmt. & Bgt.; Ron Seliga, OIM, Mgr., Fin. Planning; Judy Alfaro, OIM, Mgr., Financial Accountability; Laura Schlagnhaufer, OIM, Dir., Div. of Contr. Progs. & Sys. Social Services Block Grant (SSBG) OPD will provide all grantees receiving federal funding with a letter identifying federal award information and applicable requirements. OPD will provide this letter annually. Anticipated Completion Date: Completed Contact Name: Louie Marven, OPD, Exec. Policy Specialist DOH: DOH planned to develop and implement a robust subrecipient monitoring program which included establishing a new section within the Budget Office. The PA Legislature did not approve a budget with funding that could accommodate a new section. Alternatively, a consulting firm was engaged to perform a review of policies and procedures across the agency, including providing a gap analysis to determine compliance. A recommendation report is to be provided to DOH by March 31, 2025. DOH will initiate a comprehensive training plan for department staff based on the recommendation report. DOH will then develop training materials with an anticipated completion of June 30, 2025, with a goal to conduct training across the department by September 30, 2025. Anticipated Completion Date: 09/30/2025 Contact Name: Andrea Race, CFO PDA: PDA’s Bureau of Food Assistance (BFA) will develop a process to evaluate each subrecipient’s risk of noncompliance with federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring. The evaluation will be based on Key Performance Indicators, such as leadership tenure; prior incidents of food spoilage; or qualitative feedback from clients served. If the evaluation determines that additional monitoring tools beyond the routine performance of on-site reviews of the subrecipient’s program operations are necessary, such conditions will be laid out in a separate letter communication to the sub-awardee. PDA will also develop and implement a system to document the evaluation of each subrecipients risk of noncompliance. Anticipated Completion Date: 09/30/2025 Contact Name: Caryn Long Earl, Director, Bureau of Food Assistance PDOA: Concerning the evaluation of each Subrecipient’s Risk of Noncompliance, PDOA has developed a new monitoring component, consisting of fifteen measurable elements, to actively monitor compliance of the 52 Area Agencies on Aging (AAA) subrecipients through a revised Phase IX monitoring tool. The revised tool, used by three Fiscal Field Representatives, includes a review of Program and Procurement, Contract Monitoring, Record Retention and Environmental Modifications. • Timelines have been established to evaluate each subrecipients risk of noncompliance with Federal statutes, regulations and the terms and conditions of their subaward. - The Bureau of Finance coordinated with the Bureau of Quality Assurance to ensure schedules do not conflict and become burdensome to the AAA network. - The Fiscal Representatives plan to follow-up on any Performance Issues identified within the succeeding 6-9 months as identified in the approved Cost Allocation Plan. - Prior to the start of a new State Fiscal Year, the Risk Assessment surveys are distributed to adequately evaluate each subrecipient’s risk of noncompliance timely. • PDOA has drafted a AAA Fiscal Monitoring process map to formally document the monitoring process which highlights the requirement to disseminate Risk Assessments. • PDOA has been working with the AAAs to correct reporting in preparation of the next round of monitoring to ensure accuracy of Financial Reporting requirements and Line-Item Budgets on record. • To avoid future deficiencies in compliance, revised risk assessments have been developed to evaluate each subrecipient’s risk of noncompliance to proactively address any weaknesses in internal controls over Federal programs. • Despite PDOA recognizing time and insufficient staffing as a barrier to achieving the goal of performing a risk assessment for every AAA, we have surpassed our expectation of reaching half at a minimum by conducting a full assessment of all 52 for fiscal year ending June 30, 2024. • PDOA confirmed the Comprehensive Aging Performance Evaluation (CAPE) approach to evaluations of aging services provided by AAAs a success and shifted it out of pilot status which features a fiscal component. • To best review internal controls for financial issues concerning the Aging Cluster, a fiscal component will be administered since multiple Federal funding streams are involved. • This finding has aided in our approach to the subrecipient section of contract language as the Cooperative Block Grants are actively being developed. The proposed policy addresses Subrecipient requirements in the Admin Chapter as opposed to the appendix as a result. Anticipated Completion Date: 06/30/2025 Contact Name: Jennifer Cave, Fiscal Management Specialist, PDOA Audit Liaison DDAP: DDAP understands the need to develop policies to ensure all required federal award information is disseminated to all subrecipients at the time of the subaward. DDAP currently includes the following federal award information in its grant agreements to subrecipients: • Subaward Period of Performance Start and End Date • Total amount of Federal funds obligated to the subrecipient • Total amount of the Federal award committed to the subrecipient • Name of Federal awarding agency, pass-through entity, and contact information for awarding official of pass-through entity • Assistance Listings Number (ALN) and title However, not all the required information is available at the time the grant agreements are executed, such as the Federal Award Identification Number (FAIN) and the Federal award date. To ensure subrecipients are compliant with the Uniform Guidance in 2 CFR Section 200 and other applicable federal regulations, DDAP will develop policies to ensure notification is sent to all subrecipients that includes all required federal award information once the information has been received through the Notice of Award from the Substance Abuse and Mental Health Services Administration (SAMHSA). • First draft of P&P and proposed letter to subrecipients: Person responsible - Ellie Stache and Tia Roebuck: Anticipated completion date - 03/28/2025 • Review of first draft and letter by Bureau Director: Person responsible - Marie Plumer, Director, Bureau of Administration: Anticipated completion date - 04/11/2025 • Revision to first drafts: Person responsible - Ellie Stache: Anticipated completion date - 04/25/2025 • Review of second drafts by Executive staff: Person responsible - Kelly Primus, Deputy Secretary: Anticipated completion date - 05/09/2025 • Revisions to second drafts: Person responsible - Ellie Stache: Anticipated completion date - 05/23/2025 • Final review by Bureau Director and Executive staff: Person responsible - Marie Plumer and Kelly Primus: Anticipated completion date - 06/06/2025 • Submission to auditor: Person responsible - Tia Roebuck: Anticipated completion date - 06/30/2025 Anticipated Completion Date: 06/30/2025 Contact Names: Tia Roebuck, Director, Division of Budget and Procurement; Ellie Stache, Section Chief, Fiscal Planning and Contractual Operations L&I: Once L&I’s Bureau of Workforce Development Administration (BWDA) identified that the incorrect funding source was listed on the Notice of Obligation (NOO) associated with the TANF Youth Development Program contract, BWDA updated the list of funding sources in the Commonwealth Workforce Development System to encompass ALN 93.558. This update was implemented on February 20, 2025, and the updated NOOs were disseminated through CWDS. This change ensures that all NOOs created under ALN 93.558 now and in the future will have the correct funding source listed for the subrecipient. Anticipated Completion Date: Completed Contact Names: Brenda Duppstadt, Director; Gordon Zook, Division Chief

PDA, BFA has already or will put the following steps in place to address this deficiency and noncompliance finding. 1. Upon identification of this finding, BFA directed our Field Representatives to immediately complete reviews of the 47 identified soup kitchens. As of 2/20/25, 18 of these soup kitchen reviews have been completed and 8 of these reviews are in-process or pending final review approval. 2. BFA Field Representatives have been advised that Soup Kitchen reviews must be completed once every four years, just like other TEFAP agencies with which we have direct agreements. This requirement is also being added to the Field Representative work manual. Anticipated Completion Date: 06/30/2025 Contact Name: Caryn Long Earl, Director, Bureau of Food Assistance

Office of Income Maintenance (OIM) Bureau of Operations (BOO): BOO will take the following actions to address the finding: 1. All CAOs and district offices will be reminded of the EBT Coordinators’, alternates’, pinners’, and card makers’ responsibilities. The BOO will ensure users in the EBT Card Tracking Database know their responsibilities and segregation of duties. 2. The BOO will ensure offices know EBT cards are only to be made during business hours. BOO will work with the EBT Project Office to update the OIM EBT Procedure Manual for clarification. This will occur by April 1, 2025. 3. All CAOs and district offices will be reminded to update the EBT card tracking database within 24 hours of an individual’s status change. Clarification will be sent to the Area Managers to distribute to staff. This will occur by April 1, 2025. 4. All EBT Coordinators will be reminded to review the updates/changes to the OIM EBT Procedure Manual quarterly. Anticipated Completion Date: 04/01/2025 Contact Name: Jeanette Coulston, Staff Assistant to Director of Bureau of Operations OIM Bureau of Program Support (BPS)/EBT Project Office: BPS will take the following actions to address the finding: 1. The EBT Project Office will provide clarification and make updates to the OIM EBT Procedure Manual, in the Staff Security Section, for removing individuals from the EBT card tracking database. The updates will include screenshots for easier comprehension. This is expected to be completed by April 1, 2025. 2. The EBT Project Office will make updates to the OIM EBT Procedure Manual, in the EBT Security for Over the Counter (OTC) Card Mailing Section, to include “CAOs should not print OTC EBT Cards outside of normal business hours”. This is expected to be completed by April 1, 2025. 3. The OIM EBT Procedure Manual is updated quarterly. An email notification is sent to all EBT Coordinators, via a distribution list, notifying them of the updates/changes. This is expected to be completed by April 1, 2025. Anticipated Completion Date: 04/01/2025 Contact Name: Tonya Holloway, Division Director OIM Bureau of Program Evaluation (BPE)/Division of Corrective Action (DCA): BPE will take the following actions to address the finding: The Bureau of Program Evaluation, Division of Corrective Action conducts EBT Card Security reviews at every CAO and District Office that issues EBT cards. These reviews are completed on a three-year rotation to ensure compliance in the execution of documented policies and procedures. When needed, BPE/DCA will adjust the review criteria to incorporate any procedural changes implemented in the OIM EBT Procedure Manual. Annually, BPE/DCA EBT Headquarters staff provide training to DCA Income Maintenance Examiners in both field offices, to ensure awareness of any policy or procedure changes, prior to the start of the EBT reviews. The current rotation schedule spans FFY 2025- FFY 2027. The new three-year schedule began October 2024. Anticipated Completion Date:Completed Contact Name: Amira S. Milikin, Division Director

The district will ensure supporting documentation for payroll charges are used with the use of a time sheet for each employee charged to the grant.