Corrective Action Plans

Proposed Completion Date: June 30, 2023

2022-004. Finding: Insufficient Controls over Review and Approval of Cash Drawdowns ? Carbondale Campus Response: Implemented. We agree we did not have a consistent procedure in place during the audit period. Corrective Action Plan: We have since addressed the weakness by establishing segregation of duties in the performance of the drawdown procedure. Also, we have implemented measures to ensure that approvals are now documented appropriately prior to processing drawdowns. Contact Person: Ashley Matzenbacher (Office of Sponsored Projects Administration) Anticipated completion date: December 2022

2022-002. Finding: Inadequate Procedures for Ensuring Compliance with Earmarking Requirements for the Student Support Services Program - Carbondale Campus Response: We agree and have implemented corrective actions. Ongoing changes at the university continue to impact the potential for enrollment growth of minority students, which directly impacts the success of the program. Corrective Action Plan: Realignment of support services has structured Trio programs in an area with other similar programs that serve students that meet the criteria of the program. This realignment of services is already producing positive results. We believe this upward trend will continue for the university and program. To ensure earmarking requirements are met, applications are monitored daily. Other actions that have been taken include: ? The project director has been appointed to committees that directly impact the recruitment, selection, and retention of this population of students. ? The director also participates in recruitment activities that focuses on increasing underrepresented minority populations. ? Under the newly structured unit, a retention team has been established to improve support services and mitigate challenges to enrollment and retention of the population of students. The current status of program is mentioned in tabular form in corrective action plan. The Trio currently meets earing marking requirements. The requirements will be documented in the upcoming Annual Performance Report once submitted to the US Department of Education for AY 2022-2023 (May 2023). We hope to sustain this progress as enrollment at the university continues to trend upward. Contact Person: Renada Greer (SIUC Assistant Dean & Director TRIO) Anticipated completion date: May 2, 2023

2022-007 Finding: Exit Counseling Not Completed ? Edwardsville Campus Response: We agree. SIUE Student Financial Aid has reintroduced a Banner process which runs simultaneously with the current bi-monthly process, in order to notify students of exit counseling requirements at the earliest possible time. Corrective Action Plan: Implemented. Specifically, we are running exit counseling reports more frequently and comparing exit requirements from Banner process to in-house process to create a job that runs exit counseling through production control. We will continue to work with the appropriate office for assistance on how to ensure the appropriate flag gets checked to ensure the proper results. Contact Person: Jeremy Baker (SIUE Student Financial Aid Associate Director) Anticipated completion date: October 31, 2022

Managers will be informed of the federal suspension and debarment policy and encouraged to hold operations staff accountable to implementing the policy more consistently.

Corrective Action Plan The Union College Economic department chose to change the Classification of Instructional Programs (CIP) code to more accurately reflect the degree requirements of this particular major. The CIP code change process is typically applied at the start of a new academic year, but in this case, the College felt that it was necessary to do so immediately. The National Student Clearinghouse (NSC) was consulted to be sure that students would, in fact, graduate in the new CIP code without negative impact to their program. As a result of this late semester change, a number of Economics majors were manually corrected in the NSC and reported as graduated with the new CIP code. In the future, Union will adhere to its standard timelines and processes for curricular changes, as the ?ad-hoc? nature of such changes are difficult to manage. Upon further pressure for resolution, the NSC has now provided instructions regarding how to resolve the students reporting issues. A new file will be transmitted to the National Student Loan Data System (NSLDS) in early March, once further updates are received and processed by the NSC. Union College will review the NSLDS database to confirm accurate reporting once the file has been submitted. Union College will also perform self-audits to ensure our processes are efficiently capturing enrollment changes and that the NSC and NSLDS reports agree and are accurate beginning with the March 2023 enrollment period.

Finding: 2022-001 Name of contact person: Rick Tipton, DSS Director Corrective Action: Medicaid Programs Supervisor at Yancey DSS oversees the second party review process. Second party reviews are conducted by supervisors and lead workers on Adult Medicaid and Family & Children?s Medicaid cases on a quarterly basis in accordance with policy. The date of review, program type, and any issues found are documented on the DHB-7078 form, which is subsequently attached on the case in NC FAST. Quarterly training is conducted to address any identified issues and is documented. Yancey DSS will begin keeping a spreadsheet with a list of the cases on which second party reviews are conducted beginning July 1, 2022 and going forward. This will further demonstrate the agency?s compliance with the second party review requirement. The spreadsheet will be completed with cases that have been reviewed July 2022 through February 2023 for FY 2022-23 by March 6, 2023. Cases will be added as reviews are completed each quarter. Proposed Completion Date: March 6, 2023

Recommendation: We recommend that the University continue to review their reporting policies and procedures to ensure accurate and timely reporting. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: SOU has updated our processing timeline and our policies to reflect the need for reporting in accordance with Department of Education regulations. Name of the contact person responsible for corrective action Agnes Maina, Director of Business Services & Controller Planned completion date for corrective action plan: June 30, 2023.

Corrective Action Plan - FEDERAL AWARD FINDINGS AND QUESTIONED COSTS FA 2022-001 Improve Controls over Federal Expenditures Compliance Requirement: Activities Allowed or Unallowed Allowable Costs/Cost Principles Procurement and Suspension and Debarment Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education Assistance Listing Number and Title: COVID-19 - 84.425D - Elementary and Secondary School Emergency Relief Fund COVID-19 - 84.425U - American Rescue Plan Elementary And Secondary School Emergency Relief Fund Federal Award Number: S425D200012 (Year: 2020), S425D210012 (Year: 2021) S45U210012 (Year: 2021) Questioned Costs: $221,797 Repeat of Prior Year Finding: None Description: The policies and procedures of the School District were insufficient to provide adequate internal controls over expenditures as it relates to the Elementary and Secondary School Emergency Relief Fund program. Corrective Action Plans: Newton County Board of Education will amend contracts with appropriate vendors to ensure that the proper verbiage is contained for us of federal funds. The School District will monitor contracts to ensure that all expenditures meet compliance requirements for the ESSER federal program. Estimated Completion Date: June 30, 2023 Contact Person: Erica Robinson Telephone: 770-787-1330 Email: robinson.erica@newton.k12.ga.us

Finding 2022-004 Activities Allowed or Unallowed and Allowable Costs/Cost Principles ? Significant Deficiency in Internal Control Over Compliance Planned Corrective Actions: The Association will ensure that the proper internal control procedures over timesheets review and approval process are in place before the timesheets are submitted to payroll for processing. Individual(s) Responsible for Corrective Action Plan Angela Joule HR Director 907-442-7899 Anticipated Completion Date: March 31, 2023

2022-001 - Internal Control over Compliance and Compliance with Reporting Contact Name: Kristeena Song Position: Controller Telephone Number: (202) 796 2500 Corrective Action Plan ? Management is developing a formal written policy and procedures regarding FFATA reporting requirements to ensure reports are submitted accurately and in a timely manner. Estimated Completion ? August 2023

View of Responsible Officials We concur with the finding. Corrective Action: Condition A The Bureau of Employment Supports has been undergoing massive programmatic changes over the past 2 to 3 years. As part of those changes, there has been an updated Work Verification Plan submitted which will help to address some areas where errors have occurred. Keeping in mind that for a period of close to 2 years, due to the COVID pandemic, NHEP was not holding participants accountable for not returning signed employment plans to NHEP staff. The focus for that time was to ensure that families were housed, fed and safe, therefore, services focused on their immediate needs. Participants who entered the NHEP program during that time were not held accountable to returning a signed employment plan therefore it did not become part of their routine with NHEP. While COVID restrictions have been lifted, participants seem to have needed some time to reintegrate into the NHEP program and the mandatory expectations. NHEP staff and leadership will continue to remind participants and become more diligent in ensuring that signed employment plans are on the forefront of their daily responsibilities. It should be noted that in a couple of instances, employment plans were created as part of a Service Determination Appointment and very quickly after the participant was deemed exempt from the Work Program (NHEP) so the employment plan was not necessary and became a moot point. A Director?s Memo will be sent out by the end of this week which will allow Employment Plans to be acknowledged and accepted by the participant in multiple ways (not just with a wet signature) thereby increasing the likelihood of participants returning accepted employment plans to NHEP staff. Making this shift will mitigate the difficulties that are causing participants to not return their signed employment plans to NHEP staff and will decrease instances where there is not an accepted employment plan on file. NHEP leadership will hold a state wide mandatory staff training where ways to prioritize the monitoring and obtainment of accepted employment plans will be outlined and discussed. Field Support Managers will continue to monitor their staff on a quarterly basis, however, will add a monthly check on having accepted employment plans to their responsibilities. Condition B Part of the changes that NHEP has implemented have included a new Activity Tracking form which has made tracking hours more efficient and easier for the participant as well as the Employment Counselor. We believe that this activity tracker as well as the decrease in mandatory forms will allow for more accuracy and fewer errors moving forward. Uploading documents into the e-folder was found to be error prone, therefore, on March 1, 2023, NHEP leadership provided guidance and training on a specific process of indexing and scanning documents to ensure that moving forward the Employment Counselors are checking their e-folder?s to ensure that documents are properly uploaded and visible. This process was initially sent out to the field as a suggestion in 9/2022, however, on 3/1/23 this process was sent out as an expected process moving forward. Also, through cursory investigations, we believe that this new process, combined with the new Activity Tracking form, has already shown to be effective in improving the accuracy of supporting and recording hours. NHEP leadership has also been working with the NEW HEIGHTS system to streamline the process of uploading documents to further decrease the potential for errors. A change request form was submitted approximately one year ago. Also during the time period of this audit, NHEP was requiring pay stubs from employed participants and completing ?overrides? of the number of work hours that a participant worked during the week if that number was different than what was auto-populating based on information obtained by and entered by eligibility. NHEP discontinued that practice. NHEP no longer requires pay stubs from participants as that is a function of eligibility. NHEP utilizes the number of hours worked per week based on the number of hours entered by eligibility. This change will ensure that employment hour errors no longer occur. In order to address issues of audit findings, within the next 90 days, NHEP leadership is holding a state wide mandatory staff training where more in-depth information on the audit process will be shared including audit ?tests?, ?questions? and ?corrective action plans?. Historically in NH, the audit process was not shared with the NHEP staff making them unaware of the expectations and/or findings of the audit. NHEP staff were trained to complete certain processes and enter particular data but were never able to connect that back to anything. While we have been introducing this process more and more to our staff, we intend to hold a training to help them more thoroughly understand why they are doing what they are doing and remind them that what they do is reviewed for accuracy as part of the federal audit process. We believe that this transparency will create buy-in from the staff to put systems in place for themselves and to self-monitor more. Anticipated Completion Date: December 31, 2023 Contact: Brigitte Bowmar, Program and Workforce Administrator III

View of Responsible Officials The Department partially concurs as follows: The Department?s position is that it maintains compliance with the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 110-252, hereafter referred as the ?Transparency Act? that are codified in 2 CFR Part 170, recipients (i.e., 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). The Department agrees that during the year ended June 30, 2022, not all of the tested FFATA reports were deemed complete and accurate due to internal control considerations. The Department will review current practices regarding the internal control of financial information included in the G&C PDF?s which are the basis of the FFATA reporting with the objective of accurately reporting the specific amounts of Federal Funding content by FAIN so as to facilitate the accurate and timely reporting of FFATA in accordance with the Act. Anticipated Completion Date: September 30, 2023 Contact Person: PJ Nadeau, Administrator

agreement. View of Responsible Officials A. We concur with this finding. The Department utilized an internally available copy of the Management Log, which lists vendor?s determinations. This is a copy of the log, not the original, official copy. There is a delay in updating this copy from the original, and incorrect information had been initially entered. The Department is moving this log to software which allows all Department employees to view the same log, while limiting the number of individuals who have access to make changes. Implementation has been completed as of March 2023. B. We concur with this finding. However, we believe this was an isolated incident as the TANF CFDA number (93.558) used was very similar to correct CFDA number (93.778) that should have been documented. C. 200.332 requirements a. We do not concur with this finding. The contract for Mt Prospect became effective 8/4/21, prior to the 4/22 inception of the UEI. The DUNS number, as in effect at that time, is noticed in Exhibit J of the contract. b. We concur with three of the four findings. Two of the four contracts pre-date the template update requiring the notice an indirect cost rate. Indirect cost rate for federal awards (including if the de minimis rate is charged per 2 CFR section 200.414) were added to Exhibit C of the Department?s contracts in April 2020. One of the contracts did not indicate an indirect cost rate as required. One of the contracts notes the indirect cost rate in the Notes of their financial details. c. One of the two contracts pre-dates the template update requiring the notice the identification of R&D. R&D identifications for federal awards were added to Exhibit C of the Department?s contracts in April 2020 One of the two contracts did not identify whether the contract was R&D as required. D. Subrecipient Risk Assessment ? We concur with the finding. We consider the finding to be fully resolved through Department policy Department policy and Department wide implementation. However, it should be noted full compliance will not be achieved for one to two contact cycles due to timing. The Department began addressing the issue of Subrecipient Monitoring issue in June 2017 when the first Grants Administrator was hired. The Department finalized the Subrecipient Monitoring Policy, which encompasses the financial and programmatic risk assessments as well as the subrecipient monitoring, on June 1, 2018. The Department provided user training on the subject in February and September 2018, training over one hundred forty-six staff. However, only brand new procurements utilized this policy during the initial roll out of this policy. The Department hired a new Grants Administrator in May 2019. The full Subrecipient Monitoring policy rolled out to all procurements, including sole source, amendments, and renewals, effective August 1, 2020. The Contracts Unit received specialized subrecipient monitoring training on May 13 and October 28, 2020. Department wide training to all staff occurred weekly between September 8 and November 3, 2020. The Grants Office provided additional targeted training to Program staff through team meetings. Over one hundred fifty Program and Finance staff received training. Annual training will be held in September each year. Refresher training or training for new staff is available upon request from the Grants Office. The Grants Office website offers Program, Finance, and Contracts Bureau staff access to the subrecipient monitoring policy, as well as training modules, slides, and tools. The training has also been recorded and is available on this site. The Subrecipient Monitoring Policy requires Program to determine whether any vendor which receives funds in exchange for goods or services is a Contractor or Subrecipient. Determined subrecipients receive a Management Questionnaire, which includes a ten question questionnaire and requirements for submitting financial data. This information is used to populate the Risk Assessment Tool, which shows any risks pertinent to a subrecipient and the subaward. Based on the risks shown, Program chooses monitoring activities to mitigate the risks and the Contracts Bureau memorializes these choices in the contract. The Grants Office continues to work closely with the Contracts Bureau to ensure compliance with the Subrecipient Monitoring policy. C. and D. It is also important to note that between April 2020 and June 2022 the Department was involved in the State?s strategic response to the COVID-19 pandemic. During this time, New Hampshire was under a state of emergency (Executive Order 2020-04), processes were rapidly converted to fully digital overnight, the State?s standard approval processes were suspended and non-standard templates, which did not include the required notifications under 200.332, were utilized to respond to the COVID-19 pandemic. The Department worked with other State Departments and the National Guard to create a record number of amendments, contracts, and other agreements (approximately 200% more than standard). The Department is in the process of instituting a new contract life cycle management solution that will utilize conditional logic to include the required notifications for agreements involving federal funds in order to ensure compliance. Implementation is anticipated to be complete in July 2023. As the COVID-19 pandemic strategic response has wound down, the Department has not suspended its regular standard approval or subrecipient risk assessment and monitoring processes and has not used non-standard templates to award federal funding. E. We concur there was no formal documentation of any monitoring activity. Due to staff turnover a new administrator has been hired and unable to furnish the monitoring that took place during FY22. However, a program site review during FY23 was performed and financial monitoring of invoices has also taken place. Anticipated Completion Date: July, 2023 Contact Person: Melissa Kelleher, Administrator Rejoinder As documented above in Bullet B of the condition found, the Department did not properly communicate all required award information to the subrecipient. Once aware of the noncompliance, the Department should have timely communicated this information to its subrecipients.

Finding Number: 2022-005 Program: COVID-19 ? Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) Award Number and Year: ELC08CHW (3/1/2021 ? 2/28/2022) Compliance Requirement: Reporting Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Compliance: Per Maryland Department of Health, subgrantees are required to submit Monthly Status Reports by the 10th of the month they are reporting on. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: Prince George?s County (County) did not file Monthly Status Reports in a timely manner. Cause: The County?s procedures and controls were not sufficient to ensure that Monthly Status Reports were filed timely. Resolution: The Health Department will review and enhance internal controls and procedures to ensure that Monthly Status Reports are filed timely. Specifically, the Health Department will update the routing reporting deliverables matrix that documents all grant reporting requirements and frequency to ensure we are in compliance with the reporting requirements. In addition, we will update our internal grant guidance document to include all control requirements per 2 CFR section 200.303, by adding language to establish and maintain effective internal controls over the Federal award. We will hold a meeting with the fiscal team once the internal grant guidance document is updated to ensure compliance with guidance in standards for internal control in the Federal Government. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Responsible Party: Sezelle Gabriel Banwaree, Associate Director of Administration Anticipated corrective action plan completion date: The Health Department will continue to follow the established procedures and reporting requirements for a non-Federal entity to ensure we comply with the monthly status report requirements by the 10th of the month we are reporting on. We will have our reporting calendar and grant requirements document updated by no later than Friday, April 28, 2023.

Finding 2022-001 Grantor: Department of Health and Human Services Federal Program: Various Assistance Listing #: Various Pass-through Grantor Pass-Through Award Number Pass-through Award Period None None None Award Year: Fiscal year 2022 1/1/2022 ? 12/31/2022 Award Number: None Management agrees with the recommendation. Management will implement the following changes to Time and Effort practices. Corrective Action Plan and Anticipate Completion Date Management agrees with the recommendation. ? Review suspension and debarment? Management will review the monthly third-party vendor screening results. Management will retain documentation of the review and supporting documents used in the review. ? Reconciliation ? Management will implement a process to reconcile the number of vendor files sent to the third-party screening vendor with the number screened. Management will memorialize this reconciliation. ? Accuracy ? Management will implement a process to verify the accuracy of the results produced by the third-party vendor. Management will memorialize this review. Responsible Person: Kathleen Dunn, JD ? VP and Chief Compliance Officer Effective Date: October 1, 2023 Management?s corrective action plan includes: ? Initial screening ? Management will implement a process to ensure that supporting documentation of the initial screening process is maintained. Responsible Person: Mary Beth Colatruglio, CPA ? Director of Accounting Effective Date: October 1, 2023

Finding 2022-003 Grantor: Department of Agriculture and Department of Health and Human Services Federal Program: Various Assistance Listing #: Various Title: Schedule of Expenditures of Federal Awards Award Year: Fiscal year 2021 1/1/2022 ? 12/31/2022 Award Number: Various Management agrees with the recommendation. Management will implement the following changes to the management of the Schedule of Expenditures. Corrective Action Plan and Anticipate Completion Date Management?s corrective action plan includes: ? Review and validate that grants are listed under the correct cluster. Responsible Person: Aaron Ufferman, Director, Sponsored Projects, Natasha Collins, Director of Research Accounting Completion Date: December 31, 2023

Item 2022-002 ? Cash Management Contact person: Marc Nicholas, Dean of Business Affairs Management?s Response ? The College will strengthen the controls in place to provide assurance that all grant revenues are accurately and completely reconciled between G5 and the general ledger. The Dean of Business Affairs will be responsible for this corrective action and anticipates completion of corrective action will be taken before 1/31/23.

Item 2022-001 ? Reporting Contact person: Marc Nicholas, Dean of Business Affairs Management?s Response ? The College will strengthen the controls in place to provide assurance that proper review and approval of reports? accuracy and completeness is obtained on required grant reports prior to submission to the grantor. The Dean of Business Affairs will be responsible for this corrective action and anticipates completion of corrective action will be taken before 1/31/23.

FINDING 2022-0006 Contact Person Responsible for Corrective Action: Chris Richie Contact Phone Number: 219-987-4711 ext. 1113 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Construction contracts in excess of $2,000 financed by federal assistance must pay wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL) to their laborers and mechanics. Future construction contracts, subject to the Wage Rate Requirements, will include a provision that the contractor or subcontractor comply with these requirements and the DOL regulations. Contractors will be required to submit weekly pay statements. Statements will be reviewed by 2 corporation staff members to ensure compliance. Individuals will initial and date a hard copy of final the report. Anticipated Completion Date: March 31, 2023

FINDING 2022-0005 Contact Person Responsible for Corrective Action: Chris Richie Contact Phone Number: 219-987-4711 ext. 1113 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Before submissions, grant reports will be reviewed by someone other than the preparer of the report to ensure the information submitted was accurate. Individuals will initial and date a hard copy of final the report acknowledging the accuracy and submission of the report. Anticipated Completion Date: March 31, 2023

FINDING 2022-0004 Contact Person Responsible for Corrective Action: Chris Richie Contact Phone Number: 219-987-4711 ext. 1113 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: In the future, the treasurer will maintain a list of capital assets that includes serial number or other identification number, the source of funding for the property (including the federal award identification number), who holds title, the acquisition date, cost of the property, percentage of federal participation in the project costs for the federal award under which the property was acquired, the location, and the use and condition of the property. The list will be verified by a central office employee each December and June. Individuals will initial and date a hard copy of final the report. Anticipated Completion Date: June 30, 2023

FINDING 2022-003 Corrective Action Plan: CPS will implement a policy to verify practitioner credential records twice a year with the IL HFS and Federal Healthcare and Human Services (HHS) OIG websites as outlined in the LEA handbook. The Medicaid team will document the verification and obtain review and approval from the Medicaid Director. CPS will start the verification process in April, 2023 after the policy and procedure are finalized. Contact person: Patrick T. Alforque, Controller

FINDING 2022-002, 2021-001 ? Repeat finding: Corrective Action Plan: Based on the prior year recommendation to the FY21 finding, dated December 15, 2021, in April, 2022, CPS revised the policies in the Procurement Manual to reflect the current standard. The Oracle procurement module was tested and upgraded to implement further controls to require the collection of three quotes for any purchase using federal grant funds between $2,000.01 and $25,000 in value. In addition, communication and reenforcement of the procurement policies in the CPS Procurement Manual at the program and school level has been completed through the mandatory training and district wide announcement. On May 9, 2022, US department of Education issued the determination letter concluding this finding resolved and closed. Contact person: Patrick T. Alforque, Controller

Finding Reference Number: 2022-001 Federal Agency: U.S. Department of Labor Program Name: WIOA Cluster Assistance Listing Number: 17.258, 17.259, 17.278 Responsible Official: Patricia Rogers, Executive Director Views of Responsible Individuals: Based on the discussion we had with you regarding COPIC audit draft report, we have a plan of action moving forward to ensure these issues do not continue: ? COPIC (Josh) and Schmidt Associates (Mary) will work together to do monthly reconciliation of the tracker to the general ledger and staff billing reports. ? The spreadsheet you provided will be used as the reconciliation "tool" and will be available for your review when performing the audit. ? This will provide a monthly, program status of revenue versus expenditures as backup to the CPR submitted to the CWDB. ? The accrued vacation will be subtracted out each month as a line item on the staff billing invoice and a line will be added showing the amount transferred between the leave account and the regular checking account. This should clarify and resolve duplication of accrued vacation expenses. ? The workers compensation for work experience participants has been added back to the tracker and will only be recorded when premiums are paid. ? A line item has been added to the staff billing invoice to show the amount of employee health insurance being deducted from the employee checks each month. To clarify the amount paid by COPIC and the amount paid by the employee. ? The monthly reconciliation to be conducted, using the spreadsheet you provided, should eliminate audit adjustments and ensure the Payment Tracker, the General Ledger and the CPR match each month.