Corrective Action Plans

Identifying Number: 2022-002: Special Test ? Wage Rate Requirement Finding: Nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements (which still may be referenced as the Davis-Bacon Act) a provision that the contractor or subcontract comply with those requirements and the DOL regulations (29 CFR Part 5, Labor Standards Provisions Applicable to Contacts Governing Federally Financed and Assisted Construction). This includes a requirement for the contractor or subcontractor to submit to the nonfederal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls) (29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(i)(5)); OMB Circular A-110 (2 CFR Part 215, Appendix A, Contract Provisions); 2 CFR Part 176, Subpart C; and 2 CFR section 200.326). The School Board did not have adequate internal controls in place to verify this compliance requirement for this particular award prior to funds being spent. School Board employees were unaware the Wage Rate Requirement was applicable for this program. Corrective Action Taken or Planned: The policy on the Uniform Grant Guidance for federal grants will be updated to be more clear on the requirements. Also, the CFO will communicate the requirements to ensure all employees responsible for federally sourced funds are adequately trained. Anticipated Implementation Date: March 1, 2023 Responsible person: Cheryl Mast

The Family Health Council of Central PA Inc. sent each provider a confirmation of all state and federal funds paid to them, which included the CFDA number, source of funds, description, contract number, and amount paid. Before finalized the FY 2023 sub-awards, fiscal staff reviewed the sub-awards and met with management and contract compliance staff to ensure that FHCCP?s FY 2023 sub-awards are in compliance with the Uniform Guidance.

Audit Finding Reference: Finding 2022-002 Planned Corrective Action: Easter Seals New Jersey agrees with the auditor?s findings. We are establishing new procedures that will strengthen communication between Finance and Program staff and have adopted controls with regards to obtaining, providing, and reporting subaward reporting requirements in accordance with 2 CFR Chapter 1, Part 170. Name of Contact Person: Aleisha Hart, Chief Financial Officer, ahart@nj.easterseals.com, 732-955-8374 Anticipated complete date: Summer of 2023

Corrective Action Plan: The Department will continue its work to ensure the data provided to the USED and other entities is timely and accurate. This includes communication to subrecipients through CCIP notes, reminder emails, reporting dashboard information and guidance documents on the time period for reporting and expectations. Going forward, the Department will also include a training webinar and open office hours. In addition, the Department will revise its process for annual reporting ESSER expenditures to the USED to ensure the Department?s survey to collect ESSER expenditure data from subrecipients has a validation/error test against OAKS payments for a given reporting period. If the data does not align with the expenditure data in OAKS, the subrecipient will have to undergo data correction to ensure accurate reporting. Data correction will vary depending on the organization and any previous expenditures reported to USED. Anticipated Completion Date for Corrective Action: July 2023 Contact Person Responsible for Corrective Action: Corey Fronk, Director of Audits and Risk Management, Ohio Department of Education 25 South Front Street, 7th floor, Columbus, Ohio, 43215 Phone Number: 614-644-7812, E-Mail Address: Corey.Fronk@education.ohio.gov

Corrective Action Plan: The Department?s Office of Federal Programs (OFP) will follow up with the Local Education Agency (LEA) that did not submit a Corrective Action Plan for the ESSER issue in the consolidated compliance system to determine if the issue has been resolved. This follow up review will take place outside of the normal process and system given system limitations. In addition, OFP will update the ESSER monitoring review process to ensure it aligns with the steps already established in the comprehensive compliance monitoring process, which includes obtaining a corrective action plan and performing a follow-up desk review to ensure the corrective action plan was implemented timely and properly. Anticipated Completion Date for Corrective Action: June 2023 Contact Person Responsible for Corrective Action: Corey Fronk, Director of Audits and Risk Management, Ohio Department of Education 25 South Front Street, 7th floor, Columbus, Ohio, 43215 Phone Number: 614-644-7812, E-Mail Address: Corey.Fronk@education.ohio.gov

Corrective Action Plan: The Department will update its manual to include a process for performing and documenting a supervisory review and a reconciliation of subaward information entered into the FSRS website to USASpending.gov. In addition, the Department will reconcile all subaward reporting from June 2022 through February 2023 to ensure proper reporting during this timeframe. This reconciliation will include a supervisory review to help ensure accuracy. Anticipated Completion Date for Corrective Action: June 2023 Contact Person Responsible for Corrective Action: Corey Fronk, Director of Audits and Risk Management, Ohio Department of Education 25 South Front Street, 7th floor, Columbus, Ohio, 43215 Phone Number: 614-644-7812, E-Mail Address: Corey.Fronk@education.ohio.gov

Corrective Action Plan: FFATA State Errors: ? Submission Error o The Office of Fiscal and Monitoring Services (OFMS) will work to ensure the UEI numbers are fully registered in SAMS.gov. If the UEI# is not registered, OFMS will notify the program office so they can contact the sub-recipient/owner to update their registration. ? Timeliness Error o OFMS will work with program areas to ensure FFATA information is received by the deadline to report in FSRS timely. ? Key Element Support Error o OFMS will work with program areas to ensure FFATA awards amounts are accurate and match the contract grant agreements in the Contract Acquisition Tracking System (CATS) as well as the OAKS Cost Distribution PO spreadsheet. OFMS will prepare a checklist for the program areas to follow prior to sending FFATA info for submission. Checklist will include Director's signature date, submission date to OFMS (must be at least one week prior to deadline), correct UEI# for each subaward, accurate award amount, no blanks in the submission file. FFATA County Errors: County Timeliness errors (4). We disagree with this finding due to the fact that the FSRS does not always show full report history of the Award/FAIN #?s. ODJFS maintains that the sub award data listed under the Award/FAIN#?s for the reporting month audited were all reported on-time. These awards were reported in FSRS no later than the last day of the month following the month in which the subaward/subaward amendment obligation was made. For the November 2021 FFATA Subaward Reporting-Grant Distributed by Sub Grantee in (October 2021), there were 23 Award/FAIN#?s entered in the FSRS by the county senior financial analyst; 20/23 of these awards all show that the information was reported within the month of November. Three of these awards do not show the full report history, as they were awards with the most sub awardee data to report and was data that was requested by the AOS audit team in the prior ODJFS FFATA audit completed in 2021-2022. It is important to note that the FSRS does not have a mechanism in place where you can scroll to see the complete reporting and review history of an award. For example, if you have an award/FAIN# that you re-open and/or update frequently, you may not see that full report history of the award. ODJFS has taken the steps to verify this position further by attempting to contact FSRS (via e-mail 2/10/23 and 2/13/23 as well as by phone) to see if we can get the submission history of the sub awardee data under these three Award/FAIN#?s in the FSRS for this reporting period to prove that these three awards were submitted timely. As of this date, we are still waiting for a response back from FSRS. County errors related to FSRS that the screenshots were not provided and therefore, cannot test for key elements or timeliness of submission (2). We disagree with this error; reason; the agencies Unique Entity Identification (UEI#) that they applied for in SAM.gov were not accepted in the FSRS and needed to be resolved. ODJFS did not obtain an acceptable UEI # from these counties during this reporting period; therefore, we could not enter their sub awardee data for this reporting month in the FSRS. It is important to note that this reporting period was the changeover reporting month going from the DUNS Number to the UEI#. It is the county agency?s responsibility to obtain and provide an acceptable UEI # and provide that number to the State. Until the county agencies resolved the issue in obtaining their UEI# in SAM.gov, (ODJFS) could not report the data information in the FSRS. This information was listed on the April 2022 report that the AOS Team had for the audit prior to listing this as an error. Once the counties the resolved their issues and received their UEI#, we were able to enter their sub awardee data information in the FSRS. Anticipated Completion Date for Corrective Action: March 2023 Contact Person Responsible for Corrective Action: FFATA State Errors: Nahshon Moore, Financial Manager, Ohio Department of Job and Family Services 30 East Broad St., 37th floor, Columbus, Ohio 43215 Phone Number: 614-728-2898, E-Mail Address: Nahshon.Moore@jfs.ohio.gov FFATA County Errors: Kathleen Leadingham, Financial Analyst Supervisor, Ohio Department of Job and Family Services 30 East Broad St., 37th floor, Columbus, Ohio 43215 Phone Number: 614-728-1480, E-Mail Address: Kathleen.Leadingham@jfs.ohio.gov

Corrective Action Plan: 1. For one of 60 (1.7%) regular Unemployment benefit payments selected for testing, the claimant was paid FPUC benefits of $300 a week for several weeks of benefits which were already paid in state fiscal year 2021. As a result, we will question all duplicate FPUC payments made to this claimant during the audit period, totaling $4,800. a. A defect has been documented and an application development project will be created to remedy the concern. It will be prioritized amongst all of the other efforts currently in progress or planned for OJI. Timelines associated to the remediation is currently unknown. We currently don?t understand the root cause problem and what it will take to resolve it. 2. For eight of nine (88.9%) regular Unemployment benefit claims identified in an OJI system data match as potentially exceeding the maximum allowable amount per week, the claimants were paid $300 in FPUC benefits twice during the same benefit week. As a result, we will question costs for all FPUC payments over the allowable amount to these claimants during the audit period, totaling $17,640. a. A defect has been documented and an application development project will be created to remedy the concern. It will be prioritized amongst all of the other efforts currently in progress or planned for OJI. Timelines associated to the remediation is currently unknown. We currently don?t understand the root cause problem and what it will take to resolve it. 3. Two of two (100%) PUA claims identified in a uFACTS system data match exceeded the maximum allowable number of weeks (79): one by four weeks and the other by two weeks. As a result, we will question the PUA payments exceeding the maximum allowable number of weeks, totaling $1,656. a. A process adjustment has been made to ensure that when adjusting claim for proper payment, that we overpay the appropriate weeks as well. In some cases, that didn?t take place. This was a problem that was quickly identified, and a new process was created to deter this from happening again. We missed the correction on claim, and we have adjusted it. From a system perspective, if previous weeks are subsequently reversed back to paid, causing weeks to be over 79, a process will be identified to potentially mitigate the adjustment. 4. For eight of 60 (13.3%) PUA / FPUC payments selected for testing, the claimant was not eligible to receive benefits for the weeks claimed, was overpaid, or was underpaid, as follows: a. The finding for overpaid or underpaid claims was due to the tsunami of claims/workload the agency faced during the Pandemic as well as unknowledgeable new hires brought on to assist with the massive workload. At this time initial benefits adjudication is timely in its workload however we are still facing a high backlog of cases which have alleged fraud. Benefits adjudication will process claims after a thorough fraud review has been completed. Due to the backlog all of these cases will be late and have a possible under or overpayment. The benefits adjudication team will have any cases/determinations made within 21 days of receipt from BPC fraud dept. Anticipated Completion Date for Corrective Action: June 2024 Contact Person Responsible for Corrective Action: Valerie Shuster, Field Operations District Coordinator, Ohio Department of Job and Family Services 209 West 4th Street, Lorain, OH 44052 Phone Number: 440-244-7802, E-Mail Address: Valerie.Shuster@jfs.ohio.gov

Corrective Action Plan: The Office of Community Development (OCD) is in the process of implementing a new timeline for ESGP funding to be compliant with federal regulations. The following steps of the corrective action have already been completed. 1. Since the OHTF account balance is now in the position to allow OCD to commit funds earlier within the program year, the HCRP timelines can be adjusted to meet HUD?s 60-day requirement. 2. OCD must handle this change cautiously as HCRP serves Ohio?s most vulnerable population, the homeless, and our most vulnerable grantees, non-profit organizations. Interruptions in services and operating support would be detrimental to both. Both are dependent upon the continuity of OCD?s programs? timing. Therefore, a series of meetings have been scheduled with grantees to strategize about the most seamless way to implement this change with the least disruption in services and support. The first meeting was held on February 24, 2023. The second one is scheduled for March 31, 2023. 3. OCD will discuss this topic with the Supportive Housing Advisory Group in the fall of 2023. This meeting is part of Ohio?s Consolidated Planning Process to gather stakeholders input to create Ohio?s Annual Action Plan to submit to HUD for approval. A public comment period is built into the process as well, so additional feedback may be gathered to consider. Finally, the new timeline will be approved by HUD within the Annual Action Plan. 4. While OCD is having meetings and gathering feedback, staff will be working on the internal impact this change may create. System requirement changes and delays they may cause; report deadline shifts and alignment with other homeless reporting systems; and staff workload balance in coordination with other programs are a few we are aware of at this point. Also, the program planning begins far in advance to the grantee application submission. Therefore, timelines get set and approved early on. There are times when our allocation amounts are released from HUD late which delays our application process. There are times when HUD issues our grant agreement late which will require OCD to hold all grantees? agreements until ours is executed. Either one will cause a disruption in services after the program period is changed to an earlier start date. All these factors must be carefully considered prior to making this transition, so that surprises and delays are kept to a minimum. In some cases, a back-up plan will be required. Anticipated Completion Date for Corrective Action: September 2024 Contact Person Responsible for Corrective Action: Talia D. Givens-Gore, Program Operations Manager, Ohio Department of Development 77 South High Street, 26th floor, Columbus, Ohio 43215 Phone Number: 614-728-8140, E-Mail Address: Talia.Givens-Gore@development.ohio.gov

Corrective Action Plan: To correct the issue of reporting in a timely manner, the following strategies will be employed: 1. Monthly encumbrance report - The Grant Strategy Manager will run an encumbrance report (PO-006 Open Purchase Order Encumbrance Report through Cognos BI reporting system) during the first week of each month to identify all new encumbrances for each federal grant, new awards and contracts made with federal grant funds. The Grant Strategy Manager will report all new subgrant awards that are made each month to the FSRS website, except for specific large grant programs that will be delegated to the program division as described below. 2. Delegate large reports to program divisions ? Some federal grants have multiple subgrantees who receive funds for numerous programs. The larger and more complex grants are managed by the Community Services Division (CSD). This includes grants for CDBG, CSBG, ESG, HEAP, HWAP, and HOME programs. Transparency reports for these programs will be assigned to staff members in CSD for data entry to the FSRS website. The Grant Strategy Manager will sort the encumbrance report by grant and assign the reporting task to CSD staff members for completion by the end of the month following the award. CSD staff members will notify the Grant Strategy Manager when data entry for the month is complete. The Grant Strategy Manager will then review the reports for accuracy and submit the reports in a timely manner before the end of the month after the subaward is made as required. 3. Training ? The Grant Strategy Manager will provide training for CSD staff members about Transparency Act reporting, how to use the FSRS website, how to enter data, and the schedule for reporting. To correct the issue of internal controls, the following strategies will be employed: 1. Monthly Review ? For Transparency reports prepared by the Grant Strategy Manager, the report will be sent to the Senior Financial Program Manager (or designee) for review and accuracy check prior to submission on the FSRS website. For Transparency reports completed by CSD staff, the reports will be reviewed by the Grant Strategy Manager for review and accuracy check. The accuracy check in both cases will include: ? Review the Encumbrance Report spreadsheet showing subgrantees and encumbrance amounts and compare to the Transparency Report for accuracy. ? Check a sample of data from the Transparency Report for accuracy with subgrant agreements and contracts as they appear in Salesforce or other programs. 2. Training - The Grant Strategy Manager will provide training for Finance Division and CSD staff about the Transparency reporting and review process and how to check reports for accuracy. Finance Department staff members will be cross-trained to complete the Transparency reporting function as well in cases where the Grant Strategy Manager is absent. Anticipated Completion Date for Corrective Action: April 2023 Contact Person Responsible for Corrective Action: Keith McCormish, Grants Strategy Manager, Ohio Department of Development 77 South High St., 27th floor, Columbus, Ohio 43215 Phone: 614-466-8396, Email Address: Keith.McCormish@development.ohio.gov

Finding Number: 2022-001 Program Name/Assistance Listing Title: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Contact Person: Tyler Moore, Chief Financial Officer Anticipated Completion Date: June 30, 2023 Planned Corrective Action: Higley Unified School District #60 has updated the procurement policies to align with Federal rules to verify vendors are not suspended or debarred. ? Applicable finance staff have been trained on the additional rules and regulations regarding federal funding. ? For the vendors that have reached the Federal grant threshold of $25,000 or meet certain other criteria as specified in 2 CFR ?180.220; a binder has been created alphabetically listing their SAM.GOV documentation. ? In addition, Federal grant account codes are checked bi-monthly for reaching the Federal grant threshold.

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE ? U.S. DEPARTMENT OF THE TREASURY, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS ? FEDERAL ALN 21.027 2022-003 Internal Controls Over Compliance With Subrecipient Monitoring Requirements Finding Summary 2 CFR ? 200.332 requires the District as a pass-through entity, to have written subrecipient monitoring policies and procedures that include a written risk assessment of each subrecipient and documentation of the District?s monitoring of the subrecipient. Additionally, as a pass-through entity, the District is required to verify that every subrecipient is audited as required by 2 CFR ? 200 Subpart F when it is expected that the subrecipient?s federal awards expended during the respective fiscal year equaled or exceeded the threshold for a federal single audit. During our audit, we noted that the District did not have documented written controls to ensure compliance with the U.S. Office of Management and Budget?s Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) subrecipient monitoring requirements. The District did not maintain documentation of their evaluation of each subrecipient?s risk of noncompliance with federal statutes, regulations, and the terms and conditions of the sub-award, nor did the District maintain documentation of the results of the subrecipients? single audit, if any, for purposes of determining the appropriate subrecipient monitoring. Corrective Action Plan Actions Planned ? The District is in the process of reviewing and updating its written policies and procedures relating to subrecipient monitoring for its federal programs to ensure compliance with the Uniform Guidance in the future. Official Responsible ? The District?s Finance Supervisor, Janet Doman. Planned Completion Date ? June 30, 2023. Disagreement With or Explanation of Finding ? The District agrees with this finding. Plan to Monitor ? The District?s Finance Supervisor, Janet Doman, will assure appropriate internal controls and procedures are updated and in place to ensure compliance with subrecipient monitoring requirements.

Corrective Action Plan: The Ohio Department of Job and Family Services (ODJFS), in coordination with the Ohio Department of Medicaid (ODM), the Department of Administrative Services (DAS), and our vendor teams will continue to work to address system design weaknesses by identifying and prioritizing system changes and updates that impact eligibility determinations and benefit amounts as well as alert volume and processing improvements. Weekly problem review meetings will continue to be held to identify reported system issues and track any needed updates through the normal prioritization and slotting process. These changes will be delivered according to the agreed upon release cadence based on business priority and impact. Upon delivery of such system changes, the team will monitor production to determine if the desired outcome was achieved. ODM and ODJFS continue to meet to analyze the alerts in Ohio Benefits and the group presents recommendations to our vendor team for overall system alert improvements; these recommendations were prioritized and corrected in our normal release cadence through calendar year 2022, with the most recent release occurring in February 2022. The next alert centered release is scheduled for April 2023. Comprehensive alert reduction efforts thus far have reduced the overall ~29 million backlog alerts and drove a ~22 million annual reduction in new arrival of alerts. A system release specific to IEVSs enhancements is planned for R4.6.1 (April 2023) which will streamline the process for county staff to process IEVS matches from the IRS Unearned Income interface. There will be both E-Verify enhancements and a change in the match logic which will result in a reduction in the volume of IRS records that are flagged as IEVS matches. Caseworker time spent on processing IRS IEVS matches is expected to reduce; remaining time spent on IRS IEVS matches is expected to have more value by allowing caseworkers to focus time on matches with an eligibility impact or potential for benefit recovery. Periodic and timely review of IEVS will be completed as follows: ? Each state Fraud Control Specialist is assigned designated county agencies to provide technical assistance and training, as well as to monitor certain reports to ensure compliance with state and federal regulations. The counties will be monitored monthly and those not showing improvement will be offered training and technical assistance as appropriate. When a Fraud Control Specialist notices a county agency falling short of a required threshold, contact is made with county officials and the offer of assistance will be made. Once the number of alerts becomes manageable by the county agency, a Continuous Improvement Plan (CIP) may be required of the county agency if the issue continues over a four-month period of continuous contact and assistance. This type of CIP may be initiated outside the scope of Fraud Control Triad Review. ? The Fraud Control Section will conduct follow-up on Continuous Improvement Plans (CIPs) as part of the Triad Review process. When the county agency responds with a CIP, it is reviewed for clarity, action, and desired outcomes. Once approved, the Fraud Control Section will issue a closure letter for the Triad Review; however, a CIP may remain open for a longer period of time if warranted. We are in the process of creating a procedure and a closure letter for CIPs alone. This procedure will be implemented by June 30, 2023. ? Supervisory Reviews are monitored as part of the Triad Review process. Currently, the question is posed to the county supervisor about conducting random supervisory reviews. We are in the process of creating a procedure within the Triad Review process to be provided a list of IEVS matches that were reviewed by the supervisor. This procedure will be communicated statewide through the Fraud Control Training Program and enforced and verified during the Triad Review process.To continue to support the county caseworker staff, the Ohio Benefits Program provides training materials and promotes ongoing learning about related business processes without requiring in-person training. For each major system release or system enhancement that impacts the end user, updated training materials are produced and disseminated. These materials may take the form of job aids that are posted to the project website, train-the-trainer sessions, and video conferences where system users can ask live questions about the system. In addition to system support and training, the Ohio Department of Job and Family Services (ODJFS) in coordination with the Ohio Department of Medicaid (ODM) continue to provide the following methods by which training and system guidance is provided to CDJFS employees: 1. New Worker Training (NWT): A 12-week, comprehensive Policy and Systems training for new users (or refresher training for existing users) in the Ohio Benefits Worker Portal (OBWP) has been developed. The courses cover Policy and Systems overview, TANF, SNAP, Cash and Case Maintenance, along with the primary Medicaid programs (MAGI & ABD). The training is comprised of multiple, self-guided, Web Based Training (WBT) modules and virtual Instructor Led Training (vILT) sessions that provides `hands on? instruction. 2. Monthly Statewide County Conference: Monthly statewide webinars to cover general OFA updates for SNAP and Cash. These meetings include OFA?s Policy and TA staff, Outcomes and Analysis, Data Reporting, Quality Control, Automated Systems Training and the OB-IMS Help Desk. All areas share information on both refresher topics and emerging policy as well as systems issues where additional training is needed. The meetings are facilitated by the Program & Policy Services area within the Policy section of OFA and provides input on issues needing additional training and guidance. AST provides copies of job aids and other training documents during these support meetings. Recording of statewide training sessions are made available for counties to access on demand. 3. Operational Support Webinars: Bi-weekly webinars are delivered jointly by ODJFS and ODM, to counties for systems-based information and instruction on emerging topics and training related issues. Topics for the webinar are identified through a coordinated effort with the OB-IMS Help Desk, the weekly PBI/Defect Closure meetings and On Demand System Inquiries (received via email), to review any issues or concerns discovered by the Help Desk during the previous week. Counties are also able to submit questions and request topics in advance of the webinars to be reviewed and covered as part of the webinar agenda. 4. Ohio Benefits System Release Webinars: These are delivered jointly by ODJFS and ODM to inform counties about updates and enhancements made in each Ohio Benefits system release. During these webinars, counties are provided information regarding proper systems operation based on the items included in the release and target items that no longer require a workaround by the county worker. 5. Job Aids Available on the Innerweb: Automated Systems Training (AST) routinely provides systems-related job aids for county use that target specific topics and pain points for the counties. On the average, one to two new job aids are either created or updated each week and the Innerweb training pages are routinely referenced during New Worker Training, Operational Support, and Ohio Benefits system release webinars. 6. Quarterly Regional County Operational Support Meetings: Both the Automated Systems Training (AST) and the OB-IMS Help Desk participate in these regionally based, quarterly meetings, along with ODM Operations, Systems, and Policy staff. They provide guidance and system instruction on emerging systems issues and/or where additional training is needed. The meetings are facilitated by the Program & Policy Services area within the Policy section of OFA and provides input on issues needing additional training and guidance. AST provides copies of job aids and other training documents during these support meetings. 7. Quarterly Work Activity Round Table Meetings: Automated Systems Training (AST) and the OB-IMS Help Desk participate in these regionally based, quarterly meetings to provide guidance and system instruction related to TANF Work Activities. The meetings are facilitated by the Outcomes & Analysis area within the Policy section of OFA and provides input on issues needing additional training and guidance. 8. On Demand Systems Inquiries: Automated Systems Training (AST) maintains an email box where counties can submit inquiries about correct data entry and system functionality within the OBWP. Timely responses are provided to these inquiries frequently providing Help Desk confirmed instructions in a timely manner. Many of these inquiries are shared at the meetings and communications channels listed above. 9. System Support for Targeted Policy Training: Automated Systems Training (AST) provides system related content to support targeted Policy training topics to provide a holistic view of the application of policies within OBWP. The targeted training is delivered via virtual meetings and/or WBT modules. Some topic examples include `Expedited SNAP,? `Delayed Processing? and `Early Denial.? Recording of statewide trainings are made available for counties to access later.Interagency Agreement An Interagency Agreement is entered into by the Ohio Department of Job and Family Services (ODJFS) and the Ohio Department of Administrative Services (DAS). This Agreement is entered into for the purpose of setting forth the roles and responsibilities, budget methodology and payment terms, data sharing restrictions, security protocols, and compliance requirements for the Ohio Benefits Program. DAS and ODJFS has completed extensive policy, program, and legal reviews and the final Agreement is in circulation to secure DAS and ODJFS Director?s signatures.

Corrective Action Plan: Each state Fraud Control Specialist is assigned designated county agencies to provide technical assistance and training, as well as to monitor certain reports to ensure compliance with state and federal regulations. The counties will be monitored monthly and those not showing improvement will be offered training and technical assistance as appropriate. When a Fraud Control Specialist notices a county agency falling short of a required threshold, contact is made with county officials and the offer of assistance will be made. Once the number of alerts becomes manageable by the county agency, a Continuous Improvement Plan (CIP) may be required of the county agency if the issue continues over a four-month period of continuous contact and assistance. This type of CIP may be initiated outside the scope of Fraud Control Triad Review. The Fraud Control Section will conduct follow-up on CIPs as part of the Triad Review process. When the county agency responds with a CIP, it is reviewed for clarity, action, and desired outcomes. Once approved, the Fraud Control Section will issue a closure letter for the Triad Review; however, a CIP may remain open for a longer period of time if warranted. We are in the process of creating a procedure and a closure letter for CIPs alone. This procedure will be implemented by June 30, 2023. Supervisory Reviews are monitored as part of the Triad Review process. Currently, the question is posed to the county supervisor about conducting random supervisory reviews. We are in the process of creating a procedure within the Triad Review process to be provided a list of IEVS matches that were reviewed by the supervisor. This procedure will be communicated statewide through the Fraud Control Training Program and enforced and verified during the Triad Review process. Anticipated Completion Date for Corrective Action: ? The Ohio Benefits system improvement work and IEVS alert training ? Completed and continuing in fiscal year 2023 ? IEVS enhancement system release - April 2023 ? Triad Review closure letter procedures ? June 2023 Contact Person Responsible for Corrective Action Chris Dickens, Fraud Control Section Chief, Ohio Department of Job and Family Services 30 E. Broad Street, 37th Floor, Columbus, OH 43215 Phone Number: 614-387-5499, E-Mail Address: Chris.Dickens@jfs.ohio.gov

Corrective Action Plan: ? The program office will reach out to the county to advise of the error and ensure it has been corrected. ? The county will be reminded of the proper income entry and explain their plan to ensure it doesn?t happen again. ? The county will need to confirm they have started the overpayment process for any benefit overissued. Anticipated Completion Date for Corrective Action: February 2023 Contact Person Responsible for Corrective Action: Betsy Suver, Bureau Chief, Ohio Department of Job and Family Services 30 East Broad Street, Columbus OH 43215 Phone Number: 614-387-8302, E-Mail Address: Betsy.Suver@jfs.ohio.gov

Corrective Action Plan: Alerts - The Ohio Department of Administrative Services (DAS) in coordination with the Ohio Department of Medicaid (ODM), the Ohio Department Job and Family Services (ODJFS), and our vendor partners will continue to work to address system design weaknesses by identifying and prioritizing system changes and updates that impact eligibility determinations and benefit amounts as well as alert volume and processing improvements. Weekly problem review meetings will continue to be held to identify reported system issues and track any needed updates through the normal prioritization and slotting process. These changes will be delivered according to the agreed upon release cadence based on business priority and impact. Upon delivery of such system changes, the Ohio Benefits Program Team will monitor production to determine if the desired outcome was achieved. The Ohio Benefits Program Team continued to analyze system alerts during FY2021 and FY2022 and presented recommendations to the vendor partners for overall system alert improvements; these recommendations were prioritized, and strategic modifications were implemented in our normal release cadence through calendar year 2022, with the most recent release occurring in February 2022. Comprehensive alert reduction efforts thus far have reduced by approximately 29 million the overall number of backlog alerts and have resulted in approximately 22 million fewer new alert generations. The next alert-centered release, R4.6.1, is scheduled for April 2023. This release, specific to IRS IEVS enhancements will streamline the work for County Caseworkers to process IRS IEVS matches from the IRS Unearned Income interface. There will be both E-Verify enhancements and a change in the match logic which will result in a reduction in the volume of IRS records that are flagged as IRS IEVS matches. County Caseworker time spent processing IRS IEVS matches is expected to reduce; remaining time spent on IRS IEVS matches is expected to have more value by allowing County Caseworkers to focus time on matches with an eligibility impact or potential for benefit recovery. Interagency Agreements - An Interagency Agreement is entered into by the Ohio Department of Job and Family Services (ODJFS) and the Ohio Department of Administrative Services (DAS). A second Interagency Agreement is entered into by the Ohio Department of Medicaid (ODM) and the Ohio Department of Administrative Services (DAS). Each of these Agreements are entered into for the purpose of setting forth the roles and responsibilities, budget methodology and payment terms, data sharing restrictions, security protocols, and compliance requirements for the Ohio Benefits Program. DAS, ODM, and ODJFS have completed extensive policy, program, and legal reviews and the final Agreement is in circulation to secure DAS, ODM, and ODJFS Director?s signatures. Data Governance - A well-designed, mature, data governance program typically includes a governance team, a steering committee that acts as the governing body, and a group of data stewards. They work together to create the standards and policies for governing data, as well as implementation and enforcement procedures that are primarily carried out by the data stewards. The Ohio Benefits Program Data Governance Team meets monthly since September 2022. The team, led by ODJFS as one of the primary data owners, is working to complete its initial objectives which include: ? Address and Remediate Concerns about Reporting Cleanliness. o Develop an improved process for report intake, development, and delivery. ? Enhance Automatic Reporting and Monitoring. o Develop oversight reports to examine key areas of the business that are used to monitor for compliance. ? Evaluate EDMS? Audit Accessibility. o Understand the audit process and make recommendations on how to organize and display data to assist with future audits. ? Address Additional Priorities as determined by the data governance committee (in conjunction with the steering committee and other stakeholders). o The team will continue to establish key objectives to monitor and improve. DAS follows DAS Policy 2100-04 for Data Classification. The Ohio Benefits Program systems store data in a consistent manner, with shared data understanding for making program eligibility determinations based on quality data. As a collector and processor of the data, DAS acts as a DATA STEWARD for the agency DATA OWNERS. Per state data classification policy (2100-04, point 5.4), "? a data owner is responsible for establishing data use guidelines. An information owner shall not be a data or system administrator, but rather the head of a business or program area?? DAS customers are responsible for classifying their data and for informing DAS as to its levels of confidentiality and criticality." Since the DAS Ohio Benefits Program team has not been given data ownership and data classification information, the DAS Ohio Benefits Program team treats all data as "Confidential Personal Information". Some data may be further classified as Federal Tax Information (FTI) or Health Insurance Portability and Accountability Act (HIPAA) information, with the corresponding data access restrictions, monitoring and reporting requirements. As a Data Steward, the DAS Ohio Benefits Program team is responsible for carrying out data usage and security policies and meeting state and federal regulations for data contained on the Ohio Benefits Program systems and storage. Anticipated Completion Date for Corrective Action: ? Alerts ? April 2023 ? Interagency Agreements ? Completed ? Data Governance - Completed Contact Person Responsible for Corrective Action: Kristina Hagberg, Deputy State Chief Information Officer, Ohio Department of Administrative Services 30 East Broad Street, Columbus, Ohio 43215 Phone: 614-644-9245, E-mail Address: Kristina.Hagberg@das.ohio.gov

Allowable Costs ? COVID 19 Federal Emergency Management Agency Disaster Grants ? Public Assistance, Assistance Listing Number 97.036, Department of Homeland Security Condition A cost item was submitted twice within the applications of FEMA funds and funded by FEMA. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding. FEMA was notified about the cost item and provided the College with instruction related to the return of funds. In addition, all future applications will be reviewed by a second staff member to prevent submission of a duplicate item. Responsible Official: Kathleen McGuire, Vice President for Financial Services Expected Completion Date: December 1, 2022 Summary Schedule of Prior Audit Findings None noted.

Finding No.: 2022-002 Condition: The District's expenditure report filed for June 30, 2022 included expenditures paid in August 2022. These amounts were not reported as committed or obligated. Plan: Grant expenditure reports will be prepared on the cash basis and obligations reported. The liquidation of the obligations will be reported on subsequent liquidation reports. Anticipated Date of Completion: June 1, 2023 Name of Contact Person: Dale Heidbreder, Superintendent Management Response: There is no disagreement with this finding and management will monitor all future federal reimbursement requests. Committed and obligated expenditures will be reported appropriately, and will be paid within 90 days after project completion.

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Shelton School District No. 309 September 1, 2021 through August 31, 2022 This schedule presents the corrective action the District is planning to take for findings included in this report in accordance with Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Finding ref number: 2022-01 Finding caption: The District did not have adequate internal controls for ensuring compliance with allowable activities and costs, procurement and restricted purpose requirements. Name, address, and telephone of District contact person: Brenda Trogstad, Assistant Superintendent of Finance & Operations Shelton School District No. 309 700 South 1st Street Shelton, WA 98584 Corrective action the auditee plans to take in response to the finding: Shelton School District does not concur with the audit finding being issued by the State Auditor?s Office. The district does agree that internal controls and processes could be improved. It is the district?s understanding the almost every district in Washington State that received this grant has an audit finding. The district believes there was not clear guidance on processes and requirements. The school district did not receive any of the federal funds directly. The vendors that we purchased the laptops, hotspots, and bus wi-fi were responsible for applying for the funds from the federal government directly. The district is being held accountable for the actions of the vendor which we did not have control over. The district does not agree that these should be questionable costs since the district did not apply for or receive any funds directly. The ECF laptops were procured using the USAC site and procedures. The district filed a form 370 indicating the devices we wanted and we received quotes from two vendors. One vendor?s quote was related to a cooperative purchasing agreement contract. The district chose to purchase from that vendor as they included a white glove service to place asset tags on the devices, enroll them in our admin console and they also came with an extended warranty that includes accidental damage protection. The district?s IT Operations Manager was working with school principals to come up with the best method to determine high need students in a fair and equitable manner. The laptops will be distributed early in the 2023-24 school year once the plan is in place and all parties agree with the process. Anticipated date to complete the corrective action: Prior to January 1, 2024.

FINDING 2022-009 Contact Person Responsible for Corrective Action: Danica Houze, Chief Financial Officer Contact Phone Number: 812-274-8001 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: In the future when we have construction projects being paid from federal funds we will request the contractor to submit payroll logs weekly to the Director of Facilities. We will also require them to include weekly payroll reports in the pay applications. Anticipated Completion Date: 2/13/23

FINDING 2022-008 Contact Person Responsible for Corrective Action: Danica Houze, Chief Financial Officer Contact Phone Number: 812-274-8001 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Documentation will be kept to ensure evidence of preparation, review, and approval of the Grant Reporting. Two individuals will sign off on all future reports and documentation will be kept on file. Anticipated Completion Date: 2/13/2023

FINDING 2022-004 Contact Person Responsible for Corrective Action: Janet McCreary, Director of Curriculum, Instruction, & Assessments Contact Phone Number: 812-274-8001 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The high school will create procedures for tracking enrollments, removals, transfers, expulsion, and graduation numbers. Beginning in FY23, a cohort review is administered three times yearly (September, February, and June) by administration and school counselors. Student Services clerk reviews the withdrawal file for any student marked unknown or undetermined to obtain any necessary documentation and/or signatures. After review and confirmation of the appropriate mobility code and documentation, administration will work with the district technology team to correct errors in data exchange. Anticipated Completion Date: 2/13/2023

FINDING 2022-003 Contact Person Responsible for Corrective Action: Janet McCreary, Director of Curriculum, Instruction, & Assessments Contact Phone Number: 812-274-8001 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The Data Management Specialist will save all reports submitted to the DOE. This will ensure that supporting documentation is kept that will be used determine Eligibility for Title I. The Title I Compliance Specialist/Grants & Compliance Specialist will verify the information for accuracy and keep documentation of the review. Anticipated Completion Date: 2/13/2023

FINDING 2022-006 Contact Person Responsible for Corrective Action: Judy Brooks, Food Service Coordinator Contact Phone Number: 812-274-8001 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The Food Service Coordinator will follow our procurement procedures for all purchases. Food Service Coordinator will document that vendors for the BID are not suspended or debarred from participation in federal programs before purchasing also vendors used through the Wilson Center. The Deputy Treasurer will verify procurement and suspension and debarment documentation is on file before payment is made. When we are checking the vendors on the sams.gov website and there are no results founds then we will also request the vendor to submit a suspended and debarred form. Anticipated Completion Date: 2/13/2023

FINDING 2022-005 Contact Person Responsible for Corrective Action: Vonessia Harmon, Business Manager Contact Phone Number: 765-569-4195 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Due to the unexpected COVID19 pandemic along with the addition of new ESSER & CARES grants & their various reporting requirements, the Business Manager failed to obtain review and signature from the Superintendent for the annual data collection reports. Effective immediately, in addition to the monthly reimbursement requests, the Superintendent will also properly review & sign off on all State & Federal grant reporting documents prepared & submitted by the Business Manager. Audit Evidence: Superintendent Signature & Date In the NCP Business Office Handbook; under Grants; the following has been added: ?The Superintendent will properly review and sign off on each reporting requirement to ensure accuracy.? Anticipated Completion Date: Effective immediately