Corrective Action Plans

March 22, 2024 Corrective Action Plan SHAWL II, Senior Housing of Montague Finding: 2023-001 Condition: The Organization overpaid management fees by $250 for the year ended December 31, 2023. Regarding finding 2023-001 we will pay back the $250 that is owed to the organization in 2024. Moving forward we will make sure that the HUD-prescribed percentage of rental and other receipts used to calculate management fees are adjusted after changes to rent rates to ensure that the management fees charged are under the per-unit-per-month amount outlines in the management agent certification. Alex Valean, CPA Finance Supervisor, Affordable Living 40

Finding: 2023-001 – Federal Funding Accountability and Transparency Act (FFATA) Reporting Auditor Description of Criteria, Condition, and Effect: Under the requirements of the Federal Funding Accountability and Transparency Act direct recipients of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Direct recipients must report key data elements by registering through the FSRS and reporting subaward data through that system. Direct recipients that are awarded a federal grant are required to file a FFATA sub-award report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. The County did not submit the required key data elements through the FSRS reporting system as required by the Uniform Guidance. As a result, the County did not follow federal requirements for FFATA reporting through the FSRS and as a result has not completed the appropriate sub-award reporting that is required for direct recipients. Auditor Recommendation: We recommend that the County review its procedures for FFATA reporting through FSRS and ensure that all key data elements are reported timely moving forward. Corrective Action: The County will ensure that its procedures for FFATA reporting on all required grants are updated to ensure future compliance with this requirement. Responsible Person: Ellis Johnson II, Finance and Operations Manager (Office of Community and Economic Development) Anticipated Completion Date: December 31, 2024

2023‐002 Coronavirus State and Local Fiscal Recovery Funds U.S. Department of Treasury Assistance Listing Number: 21.027 Recommendation: We recommend that the City design processes and procedures to ensure that all reports are submitted timely as required by grant agreements. We recommend the City develop an internal compliance checklist that includes required reports and due dates to be maintained for tracking and record keeping purposes to assist in monitoring compliance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: A checklist is already in place and the City will evaluate and work with the Department of Treasury for ways to overcome the technical issues encountered, and acknowledged by the Department, that restricts the filing of reports in a timely manner. Quarterly filings with the Department will continue to be closely monitored. Name(s) of the contact person(s) responsible for corrective action: Mark C. Mason, CPA, Financial Services Director; Crystal S. Feast, MBA, Deputy Financial Services Director Planned completion date for corrective action plan: April 25, 2024

Management is cognizant of the Agency’s internal control structure and continues to evaluate cost effective opportunities to further improve segregation of duties. The Agency has strengthened the internal control structure in recent years by revising the roles and responsibilities of multiple positions within the accounting department. The Agency continues to identify and implement effective mitigating controls when possible. Current Agency procedures for journal entries include one position that is primarily responsible for preparation of journal entries and posting. The Agency is working on implementing procedures that involve program personnel assisting with preparation and/or review of journal entries. Name of responsible official: Nick Curran, Director of Business Operations Expected completion date: Ongoing, no formal expected completion date.

Name of contact person – Angela Riley, CFO Corrective action – The Corporation agrees with the finding and CommonBond Communities should return the excess distributions as soon as possible. Employees should be reminded of the procedures in place to ensure there is sufficient surplus cash to make distributions. Proposed completion date – Management has begun the corrective action and is expected to complete additional training and CommonBond will return the excess distributions in 2024.

Name of contact person – Angela Riley, CFO Corrective action – The Corporation agrees with the finding and should return the incentive performance fee to the organization. Employees should be reminded of the M2M program requirements and conditions for making incentive performance fee payments. Proposed completion date – Management has begun the corrective action and the incentive performance fee has been repaid to the Organization as of March 22, 2024.

Subject: Finding 2023-001 – Financial Close and Reporting and Delay in Reporting – Significant Deficiency Management agrees with the recommendation to strengthen existing policies and procedures surrounding financial close and reporting. Through the merger, effective October 1, 2023, CommuniCare Health Centers has adopted stronger close processes to ensure the timeliness and accuracy of reporting. CommuniCare Health Centers has adopted policies from the surviving entity, OLE Health, which include: - Month-end check lists that ensure completeness of general ledger transactions - Month-end, quarter-end and year-end deadlines that ensure timeliness of financial reporting - Additional oversight, through the hiring of an Accounting Manager, that ensures accuracy of GAAP reporting

CORRECTIVE ACTION PLAN April 23, 2024 Goodwill Industries of Michiana, Inc. respectfully submits the following corrective action plan for the year ended 2023. Audit Period: Year Ended December 31, 2023 SIGNIFICANT DEFICIENCY FINDING – FEDERAL AWARDS 2023-001 ALLOWABLE COSTS An employee requested expense reimbursement through payroll which was default coded to the grant. The expense was for a different grant and noted as such in the description. The unallowed cost was charged to the incorrect grant and reimbursed by the grantor. Recommendation: Management should implement a review process to ensure payroll reimbursements are accurately allocated to the correct grant for reimbursement. Action Taken: The payroll expense reimbursement process has been reviewed and steps added to ensure expenses are being charged to the correct grants. This includes reviewing the notes included in the expense reimbursement submission. Correcting entries will be made when needed to ensure expenses are charged to the correct grant. Contact Person: Karman Eash, CFO keash@goodwill-ni.org Effective Date: April 23, 2024

Management acknowledges noncompliance in the current fiscal year and has taken measures to improve internal controls over compliance. Management will monitor security deposit refunds in order to ensure refunds meet the Regulatory Agreement requirements.

The audit finding noted one Consultative Examination (CE) provider where the qualified provider review was not completed timely and this was an oversight on the part of the Department of Labor and Workforce Development’s Division of Disability Services (DDS) due to attrition of staff. Going forward, each DDS Professional Relations Officer will be responsible for reviewing eight to 10 CE provider’s qualifications each month until the yearly review is completed for each vendor. The Chief of Professional Relations will submit a monthly report to the DDS Assistant Director detailing how many sites were visited that month and any findings that may have occurred. Each month, the report will detail how many reports remain outstanding in order to complete the yearly reviews. COMPLETION DATE/ CONTACT PERSON & PHONE# April 9, 2024 Theresa Vallely (609) 984-1779 Theresa.Vallely@dol.nj.gov

There is no change to the prior year corrective action plan provided by the Department of Human Services, Division of Medical Assistance and Health Services (DMAHS) as corrective actions have been fully implemented as of January 2023. Current Managed Care Organization (MCO) contracts no longer contain the language requiring an audit conducted specifically in accordance with generally accepted accounting principles and generally accepted auditing standards and now specify that AUP reports are acceptable. Section 7.25.1(B) of the MCO Contract was updated effective January 2023 and removed the language requiring audits in accordance with generally accepted accounting principles and generally accepted auditing standards, and specifies that an AUP report is acceptable per guidance provided under Medicaid and CHIP Managed Care Final Rule (CMS-2390-F) Frequently Asked Question number Q10. COMPLETION DATE/ CONTACT PERSON January 2023 Robert Durborow (609) 775-7298 Robert.Durborow@dhs.nj.gov

The Department of Community Affairs (DCA) Low-Income Home Energy Assistance Program (LIHEAP) staff have been fully trained to coordinate with the Applied Public Policy Research Institute for Study and Evaluation (APPRISE) and the federal U.S. Department of Health and Human Services (HHS) to ensure that all required reports are submitted timely. DCA has created a schedule of required reports that includes corresponding submission due dates and the process is designed to ensure adequate time is available to accommodate the necessary back and forth communications between DCA and APPRISE required to complete all reporting timely. COMPLETION DATE/ CONTACT PERSON April 30, 2024 Fidel Ekhelar (609) 815-3905 Fidel.Ekhelar@dca.nj.gov

The Division of Aging Services (DoAS) implemented the FFATA reporting process in June 2023; however, DoAS fell behind on timely submission of FFATA reports due to staffing constraints. To address this issue, the DoAS plans to hire a fiscal analyst dedicated to managing FFATA reporting. DoAS is planning to be up-to-date on FFATA reporting and timely submission within 90 days. COMPLETION DATE/ CONTACT PERSON June 30, 2024 Hetal Bhatt (609) 438-4586 Hetal.Bhatt2@dhs.nj.gov Dennis McGowan (609) 438-4739 Dennis.McGowan@dhs.nj.gov

The New Jersey Department of Education (NJDOE) Office of Grants Management (OGM) understands the need to be compliant with FFATA reporting in accordance with the Uniform Guidance. Internal controls and processes are in place to ensure NJDOE’s FFATA reporting process is working efficiently and timely. This noncompliance finding is not due to a lack of controls within NJDOE but lies squarely on system issues at SAM.gov and the FFATA Subaward Reporting System (FSRS) sites and until the issues listed below are corrected on these federal system sites, NJDOE will continue to be noncompliant with timely FFATA reporting. Issues with the SAM.gov and FSRS sites: • SAM.gov has approved NJDOE’s local education agency (LEA) registrations without a ZIP+4, but FSRS reporting system for FFATA uploads requires ZIP+4 for each LEA. The two systems use the same database, which means information registered on SAM.gov feeds directly into the FSRS system. However, because FSRS batch uploads require a ZIP+4, those LEAs that were approved by SAM.gov without a ZIP+4 during the registration process, are rejected from the FFATA report batch upload. There is an option to manually load each LEA and their details into the system, but the process becomes incredibly time consuming, given the 700+ LEAs in the state, the number of federal awards granted, and the steps for identifying & removing rejected LEAs from the batch upload. • Issues NJDOE has with SAM.gov and FSRS have been shared with the federal helpdesk and a USED representative without avail, as the systematic issue remains unresolved and continues to delay our FFATA reporting process. • There are several rural LEAs in the state that do not have a ZIP+4. These LEAs will continue to be rejected from the batch upload, delaying our FFATA reporting process, if SAM.gov and FSRS do not come up with a viable solution. • There were a number of LEAs that were continuously rejected from the upload by FSRS for no obvious reasons. The error message received was the same exact error we receive for incorrect zip codes. After spending much time investigating the cause with the helpdesk support, it was identified that FSRS did not update their system to reflect the Congressional District code changes during New Jersey’s redistricting process. • The FSRS system rejects batch uploads if a single lower-case SAM UEIs is entered in the batch file. However, SAM.gov search box and the FSRS manual uploads are not case sensitive. Batch uploads are the only place where SAM UEIs are case sensitive. Further, this information is not included in any of the FSRS User Guides or manuals. I have shared this with the FSRS helpdesk, but no solution was provided. Again, this discrepancy in their system affects and delays our FFATA reporting processes. NJDOE dedicated personnel, including the director of OGM, continuously work with SAM.gov, FSRS system, and both system sites’ help desks, to bring to light the issues mentioned above in order to express the urgent need for corrective actions at the federal system sites to allow for timely FFATA reporting. In addition internal controls and procedures are in place at NJDOE related to FFATA reporting and corrective actions are constantly performed in real time to perform the below NJDOE Internal Controls and Procedures. Some of these procedures include reviewing internal SAM applications and troubleshooting with NJDOE’s local education agencies (LEAs) to correct data in the application and resubmit to the federal reporting system sites with more detail included below. NJDOE Internal Controls and Procedures: • Due to the large number of LEAs in the state (700+), each FFATA report must be submitted via batch upload, which saves an enormous amount of time it takes to input data manually for every single LEA, for every grant. To address this need and to expedite the process, our vendor has created a reporting tool that generates a FFATA batch report. • We have been contacting the federal helpdesk to address the issues on their sites and asking for support. Some of those tickets were closed without providing any support and most were not helpful. • We have created and implemented an in-house System for Award Management (SAM) application, mandatory for all of our federal grant recipients. This was done specifically for FFATA reporting purposes to ensure data in these applications are directly tied to the FFATA batch reports. • The SAM applications go through a thorough review process, where data entered by the districts is compared with the data registered with SAM.gov (applicants are required to upload a copy of their Entity Overview Record, issued by SAM.gov). • SAM applications are returned for changes whenever an applicant has entered data that is inconsistent with data on SAM.gov (i.e.. Incorrect SAM UEI, incorrect zip code, incorrect zip+4, incorrect City name). • We have asked many of our districts to contact SAM.gov and update their physical address information to include the full 9-digit zip code, which was SAM.gov reviewers’ oversight. Our school districts have commented that this process can take months. • We are communicating with our districts/applicants on a daily basis through the review summary checklist, outlining the changes that must be made, as well as by email and phone. • We have implemented an automatic messaging system, where applicants are reminded to update their SAM registration expiration date, multiple times a month leading up to their expiration date. Due to the system discrepancy in the FSRS system’s batch upload, we had to create a workaround pertaining to the district’s SAM UEIs. As stated above, SAM UEIs, in batch FFATA reports, are case sensitive while not case sensitive anywhere else in the two system sites. We have updated our instructions in NJDOE’s SAM application and have added another layer of application review, to ensure that all UEIs entered are in all capital letters. Because the federal helpdesk has ignored this discrepancy and did not resolve the issue, we are obligated to take additional steps and spend additional time on FFATA batch reports. COMPLETION DATE/ CONTACT PERSON Indeterminate – Completion based on federal implementation of fixes to SAM.gov and FSRS portal as noted in views. Martin Egan, Director NJDOE Office of Grants (609) 376-9089 Martin.Egan@doe.nj.gov

The Department of Labor and Workforce Development (DLWD), as the prime recipient of the federal awards, will ensure that all first-tier subawards made to entities totaling $30,000 or greater will be entered timely into the FSRS in accordance with FFATA reporting requirements. The audit sample selections in question were based on manual DLWD notice of awards that were not communicated correctly to staff who are responsible for entering the required subaward information into FSRS. Going forward, DLWD staff who are responsible for entering data into the FSRS will be copied on all emails containing the manual notice of award(s) once the notice is signed by the DLWD Commissioner. These email communications will trigger the information to be entered into the FSRS. COMPLETION DATE/ CONTACT PERSON April 4, 2024 Michael Varga (609) 351-3000 Michael.Varga@dol.nj.gov

The Department of Labor and Workforce Development (DLWD) continues to monitor all first payment and non-monetary time lapse figures in order to meet the established USDOL Acceptable Levels of Performance (ALP). As workloads return to normal levels after the increased activity from the COVID-19 pandemic related claims, greater emphasis will continue to be placed on meeting all ALPs. Specifically relating to first payments and the previously discussed issues with claimants verifying their identity before any payments can be made, the DLWD has made some internal changes to how returned verified IDs from our ID verification partner (ID.me) are handled. These modifications to the internal process used to clear verified IDs are expected to have a positive impact on overall time lapse numbers as verified claimants will not be delayed longer than they previously were under the old process. The month of April starts the new reporting year for these figures to USDOL and New Jersey expects to see significant increases to first payment and non-monetary time lapse figures by the third quarter of calendar year 2024. COMPLETION DATE/ CONTACT PERSON September 2023 Theresa Vallely (609) 984-1779 Theresa.Vallely@dol.nj.gov

The security deposit was refunded to the tenant on the 44th day subsequent to their move-out. Management has taken measures to improve internal controls over compliance related to tenant security deposit refunds.

Management acknowledges noncompliance in the current fiscal year and has addressed all of the health and safety issues as of April 18, 2023

Contact Person Responsible for Corrective Action: Assistant Director of Finance, Ryan Gaddy Corrective Action: Reports from the automated timecard system company have been identified to which provide exceptions for overrides made. Anticipated Completion Date: Completed Corrective Action: Work with automated timecard system company to designate a department head who does not have access to overrides in the timecard system to approve all time worked. Time entered will be first approved by the employee, secondly by the department timekeeper, and finally by the department manager/director. Timekeepers are unable to edit their own time; only the department manager/director will have the ability to edit the timekeeper’s time. Anticipated Completion Date: May 31, 2024 Corrective Action: Overtime will no longer be manually input into timecard system; overtime will only be calculated by the timecard system. Anticipated Completion Date: Completed

Federal Agency: Department of Housing and Urban Development Federal Program Title: Section 8 Housing Choice Vouchers Assistance Listing Number: 14.871 Award Period: January 1, 2023 – December 31, 2023 Compliance Requirement Section: Special Provisions Type of Finding: Significant Deficiency in Internal Control Over Compliance Recommendation: We recommend that the HRA keep a list of properties that have inspections and complete the required re-inspections. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management will ensure the necessary re-inspections are completed.

HARTFORD VILLAGE HUD PROJECT NO. 044-38023 CORRECTIVE ACTION PLAN Hartford Village respectfully submits the following corrective action plan for the year ended December 31, 2023. Auditor: Maner Costerisan 2425 E. Grand River Avenue, Suite 1 Lansing, MI 48912 Audit Period: Year ended December 31, 2023 Corporation Contact Person: Bruce Blalock, Director at Management Agent The findings from the December 31, 2023 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the number assigned in the schedule. Finding – Federal Award Findings and Questioned Costs Finding 2023-001: Considered a significant deficiency in internal control over compliance. Recommendation: The HUD-prescribed percentage of rental and other receipts used to calculate management fees should be adjusted after changes to rent rates to ensure that the management fees charged are under the per-unit-permonth amount outlines in the management agent certification. Action to be Taken: The Organization concurs with the facts of this finding, and will pay back the $8,928 to the organization in the 2024 audit year.

We recently completed the transition and onboarding of departmental staff which would allow the University to fully enact its plan to ensure both the financial aid and the Registrar's office will perform prompt review of processing University withdrawals. The Registrar's office will develop process and procedures documentation as an internal control measuring tool to ensure that Administrative Withdrawals (AW) and Withdrawals for lack of attendance (WA) that affect student emollment are identified immediately. Staff in the Financial Aid and the Registrar's office will actively take part in training workshops and webinars provided by the Depatiment of Education and NASF AA for continuing education to stay abreast of new developments and best practices in the industry.

Finding:  2023‐006:  Significant Deficiency over Eligibility  Name of Contact Person: Daphine Little, Director of Bertie County Department of Social Services Corrective Action/Management's Response: Recommended Improvement:  Immediate re‐training of specific policy on child support  Post eligibility training after application disposition on child support procedures  ACTS data is viewed on all parent‐child cases at recertification and application  Make sure all single parent cases with children have compliance addressed with child support  Make sure all child support referrals are done at all applicable recertifications of determining eligibility and post eligibility for applications  Make sure on how to do referral for child support by job aid through NC Fast help Goal:  Decrease technical errors with child support by 100%  Request online data for ACTS at all recertifications and applications  Recheck all evidences on dashboard pertaining to child support enforcement for accuracy  Supervisors  and  Caseworkers  retain  all  Fast  Help,  Learning  Gateway  Trainings,  Administrative  Letter,  Change Notices, and Medicaid Manual Information to properly complete their job requirements Training Information:  Medicaid Manual and Policy Training (MA‐3365 Child Support)  Child Support Post Eligibility (MA‐3205 Post Eligibility Verification)  DHB  Administrative  Letter  No:  2‐20,  Child  Support  Guidance  Eligibility  Verification  During  COVID‐19(Guidance During This Audit)  DHB‐22000 Absent Parent Information Form  Current Guidance Child Support During CCU. DHB Administrative Letter No: 13‐23, Child Support Cooperation and Applying For Other Monetary Benefits Post Eligibility Benefits During The CCU Period  Child Support (IV‐D) Referrals for MA, CA, & MAGI Cases (Job Aid from NC Fast Help) Corrective Action Plan  Additional Training on Child Support Policy and Procedures for Recertification and Applications  Additional Training on Child Support Referral Job Aid and How to Complete it in NC Fast System  Staff training will be conducted monthly during staff conferences which will include child support training on child support referrals and how to key them in the NC Fast system  Sign in sheet for caseworkers attending training and staff conference Proposed Completion Date: February 29, 2024

Finding: 2023‐005: Significant Deficiency over Activities Allowed and Unallowed and Allowable Costs/Cost Principles Name of Contact Person: Daphine Little, Director of Bertie County Department of Social Services Corrective Action/Management's Response: DSS agrees that there were some discrepancies found in two out of twenty‐three employee daysheets vs. timesheets resulting in more program time reported on the daysheets than the approved timesheets. Supervisors  are  responsible  for  ensuring  that  time  reported  on  employee  daysheets  matches  the  timesheets.  Bertie  County DSS utilizes an Excel spreadsheet provided by Bertie County Government that is completed by each employee monthly to report time worked. As it is the Supervisor’s responsibility to verify and approve the accuracy of employee daysheets, the Supervisor is expected to reconcile time reported on employee daysheets to time reported on employee timesheets. Plan of Action:  Provide  employees  with  a  copy  of  Power  Point  Training ‐Day  Sheets:  Time  Reporting  and  Reimbursement  for County DSS (2022).  Reiterate the importance of employees reporting the same amount of time on the daysheet vs. the timesheet.  Communicate with Supervisors the importance of reconciling employee daysheets vs. timesheets. Proposed Completion Date:  March 1, 2024

Management acknowledges noncompliance in the current fiscal year and has addressed all of the health and safety issues as of May 19. 2023.