Corrective Action Plans

The Town concurs with the finding; however, it will be corrected as the Town will have fully spent the funds by the next filing due March 31, 2024.

Views of responsible officials and planned corrective actions: The County does not have available funding to hire a grant compliance officer, however, the County plans to seek training resources for current staff responsible for grant administration

Finding: 2023-004 Name of Contact Person: Amia Massey, Director, Human Resources Criteria: In accordance with 45 CFR 304 and the Division of Social Services Fiscal Manual, management should have an adequate system of internal control procedures in place to ensure that salaries are being paid at the approved rate in accordance with the county pay plan. Recommendation: Require the Human Resources Department and County Program Directors to implement procedures to ensure that pay rates are properly entered into the payroll processing system at the time the pay rate is established. Corrective Action/Management’s Response: Management concurs with this finding and will adhere to the Corrective Action Plan in this audit report. The County will pursue the automation of the Personnel Action Form (PAF) in Munis. As this will take several months to complete, the county has implemented the following temporary measures: • HR staff responsible for entering new hires or any other pay changes into the county’s personnel system will be required to give the processed paper PAF to their supervisor prior to the end of each pay period • The supervisor will review the PAF, comparing it to Munis to ensure the hourly rate in the personnel system matches the submitted PAF • If correct, the supervisor will then sign off on the PAF and return it to the entering HR staff member for inclusion in the employee’s personnel file • If the supervisor detects an error, they will indicate as such to the entering employee, so the error can be corrected • This process must be completed prior to the end of each applicable pay period to ensure pay changes are correct for that pay period and/or any errors are corrected prior to payroll processing • It will be the entering HR staff member’s responsibility to ensure they have received all PAFs back from their supervisor prior to the end of each applicable pay period Proposed Completion Date: Management will implement the temporary measures immediately. Completion of the automation of the PAF in Munis should take six (6) to nine (9) months (5/21/2023 to 8/21/2023).

Finding: 2023-001 Name of Contact Person: Angela Karchmer, Social Services Director Criteria: In order for costs to be allowable for purposes of reimbursement they must be allowable in accordance with 45 CFR section 1356.60 and the NC Division of Social Services Manual. All County Department of Social Services employees which provide direct services must maintain daysheets in accordance with the NC Department of Social Services Information System Policy. Recommendation: Require the County Program Directors to implement procedures to ensure that daysheets are properly supported by documentation of time charged to each program. Corrective Action/Management’s Response: Management concurs with this finding and will adhere to the Corrective Action Plan in this audit report. The County has implemented the following process: Daysheet/Documentation Reviews: • QA are conducting random checks bi-weekly to ensure daysheets and documentation are coded correctly. • QA maintains a log of all audits completed. • Audit results are sent to supervisors and social workers for review of the findings. If errors are found discussion takes place regarding how to correct errors. • Supervisors conduct random checks of daysheets and discuss finding during supervision. • All new staff are required within 30 days to watch the state webinar on daysheet entry and take a quiz to insure comprehension. • Daysheet trainings are conducted twice a year for all staff. • DSS Management will work with the Gaston County IT department to upgrade the current daysheet system to allow for better tracking of employee daysheets. • Children and Family Services supervisors will be required to conduct 1 intensive daysheet review per worker each month, attaching eligibility determination paperwork, narratives verifying the work, and ensuring the appropriate funding code is used in daysheets. This paperwork will be reviewed by the program coordinator and administer via an electronic system (Polimorphic). • Supervisors will ensure daysheets are current within 7 days, minimizing errors, and ensuring accuracy. Proposed Completion Date: Management and the Board will implement the above procedures immediately.

Upon learning of the possibility of frauduelent activity, the University began an internal audit review and all activity on the grant was stopped. Throughout the process, the University coordinated with the Ohio Department of Development. The internal audit procedures led to the determination that $209,101 was incorrectly reported by the program advisor and was not detected by the program director. These funds were returned to the Ohio Department of Development on October 11, 2023. The program has been termianted and program income returned. The individuals involved with this program are no longer employees of the University. The University is in the process of seeking reimbursement from the former employee. An internal controls questionnaire was prepared and reviewed for the other Small Business Development Center (SBDC) program noting no areas of concern. The FY24 internal audit plan will include additional review of the remaining SBDC program as well as review of controls within the department which previously managed the program noted in the finding. In addition, training related to roles and responsibilities for supervisors/approvers will be provided in FY24 to emphasize the guidance provided in the grants manual. Contact person responsible for the corrective action: Mark Polatajko, Senior Vice President for Finance and Administration.

Consortium’s Fiscal Agent will ensure that supporting documentation will be maintained for all expenditures to ensure that each expenditure charged to the program is for an allowable activity/cost.

Consortium’s Fiscal Agent shall maintain all invoices and proof of payment for all financial transactions and records should be maintained in an orderly manner to support all transactions.

Criteria: Regulations require that the Organization must submit the single audit data collection form and reporting package within the earlier of 30 calendar days after receipt of the auditor’s report or 9 months after the end of the audit period, to comply with 2 CFR § 200.512(a)(1). Condition: The Organization submitted their 2021 Single Audit Data Collection form on September 7, 2023, which was 20 months after the end of the audit period. Effect: The Organization did not comply with 2 CFR § 200.512(a)(1). Per 2 CFR § 200.516(a)(2), this results in material noncompliance with the provisions of Federal statues, regulations and terms and conditions of Federal awards related to major programs. Cause: The Organization failed to submit their 2021 Single Audit Data Collection form before the end of September 2022 – the 9 month post-audit period ending deadline. Recommendations: We recommend management finalize and submit their single audit data collection forms within the 9 month window moving forward. Views of Responsible Officials: The Organization agrees with the finding and will work to implement the recommendations.

As more fully described above, additional internal control procedures and practices will be implemented effective July 1, 2024, to ensure that underlying cost documentation is adequate, reasonable, and complete in accordance with 2 CFR and other regulatory requirements. More specifically, vendor invoices and the like will be scanned and electronically saved on QBO, as incurred. On the other hand, contractors were engaged to perform certain tasks and were not constrained by hours. If the subject service required on-site intervention by the contractor with a POF client at 3 AM, then the contractor was expected to and had agreed to deliver. The contractor would report any such encounters at the subsequent weekly meetings with certain contractors present. Consistent with IRS employer guidelines, POF did not supervise contractors or dictate work habits or work schedules. Instead, POF defined what each contractor was expected to do or deliver. It was incumbent upon the contractor to determine how best to accomplish the assigned and agreed upon duties defined in their jointly signed agreement. POF’s contractors were and are professionals with state credentials, degrees, or certifications which permit them to serve other NPOs or customers as independent contractors. In many cases, their work products were summarized during the previously mentioned POF weekly meetings and transmitted to Wright State University (now the Ohio State University) where the data were aggregated independently by these contracted third parties and made available to POF’s funders. Effective July 1, 2024, copies pf these weekly report summaries will be routinely saved to provide further evidence of POF’s monitoring of contractors’ activities and adherence to contract terms.

Year Ended December 31, 2022 Contact – Randy Willard, New Director of Finance Telephone Number – (410)-733-9113 Completion Date – First Quarter of 2024 Information on Federal Program(s) U.S. Department of State Name of Program: Program to End Modern Slavery Assistance Listing Number: 19.019 Grant Award Number: S-SJTIP-17-CA-1018/S-SJTIP-18-CA-1014/ S-SJTIP-18-CA-3035 Grant Award Period: October 1, 2017 to June 30, 2022, October 1, 2018 to December 31, 2022, October 1, 2021 to September 30, 2024 Management’s Corrective Action Plan: The financial impropriety was within a subrecipient organization that affected numerous projects/donor funding and not only the PEMS2 funds. GFEMS completed the necessary reporting to the Office of the Inspector General (OIG) for the Department of State. There were no costs or loss sustained from the incident because GFEMS subtracted the misappropriated amount, $4,979.75, from the final disbursement to the subrecipient. GFEMS will continue to apply its existing due diligence and subgrantee monitoring procedures to minimize risk of fraud and non-compliance of subgrants awarded. This will include review of subgrantees policies, procedures, vouchers, receipts, and audit reports as well as desk and site visit financial monitoring, as appropriate.

(B) The Department will review and revise, as necessary, its taxi claim billing requirements and rates to ensure that they are consistent. In addition, the Department will devise controls to ensure that taxi claims are paid in accordance with established requirements and rates and explore controls to ensure that only permitted providers bill as a taxi. The Department is working on reductions in the max fee and unit limits for taxi claim billing codes, which it will have completed by the end of October 2021. In addition, the Department is considering systematically pricing the code at each taxi provider?s specific Public Utilities Commission (PUC) rate. This change, if pursued, will require a system change request, which will take a year or more, which is why the Department has selected an implementation date of December 2022. If this proves infeasible, alternate controls will be implemented. HCPF has met with DORA PUC. The Department is trying to establish a process to decide if the PUC taxi rate still applies or an internal rate can be created. Because of these discussions and needed system changes the implementation date has been moved to December 2023. (D) The Department intends to define in rule the types of documentation that NEMT providers must keep on hand and make clear that they must furnish records to the Department upon request. The July 2022 date will allow for the completion of formal rulemaking. The Department further intends to develop and implement a process to perform regular risk-based provider file reviews with a focus on noncompliant providers. These reviews will ensure, at a minimum, that the providers? paid claims are supported with appropriate documentation and represent the least costly option appropriate to meet each recipient?s needs. The Department met with the RAC team on February 22, 2023 to come up with a process to perform small audits for claims from providers that are outside the Intelliride service area. New systems will be implemented which has pushed the anticipated completion date to December 2023. (E) The Department will amend its contract with its NEMT broker by adding a mandatory annual audit so that it can reconcile trip scheduling data with paid claims data. This will help ensure that the Department pays accurately, pays for NEMT services, and pays for the least costly transportation option appropriate for each recipient. The Department chose July 2022 to add the audit through its annual contract amendment and renewal processes. The contract amendment was completed and signed June 30, 2022 that included a clause for an annual audit of claims. (F) The Department will develop a data review process to reconcile interChange data on NEMT trip claims to interChange data on Medicaid medical claims. This process will entail periodic reviews of NEMT claims to see if members have corresponding medical claims on those dates. If they do not, the Department will follow up with the appropriate NEMT provider to investigate. The July 2022 implementation date reflects the potential need for system changes. This is implemented, the Department has been pulling claims data and where corresponding medical claims are not found HCPF is investigating on a case by case basis to find the cause. (G) Department staff will work with the Department?s Program Integrity (PI) staff on processes to investigate and recover, as appropriate, the overpayments and inappropriate payments that the audit identified as known or likely questioned costs, and repay the federal portion, as appropriate. The December 2022 implementation date reflects the time needed to investigate and when appropriate, recover any overpayments. This has been implemented and the federal portion has been returned to CMS. (H) The Department will develop a process to track staff time and productivity to ensure that it has sufficient staff assigned to oversee and administer NEMT. This process will include documenting time spent each week on various tasks to get a sense of where help is needed, and which tasks take up the most staff resources. Based on its findings, the Department will explore staffing options, as needed. The Department selected the July 2022 implementation date to allow for data collection through the end of State Fiscal Year 2021-22. This has been implemented. New NEMT staff was hired November 1, 2022 to act as the liaison to the counties and clients in the 55 counties outside of the Intelliride service area.

Management Response and Corrective Action: HACLA administers the third largest Housing Choice Voucher program in the United States with an allocation of 52,646 vouchers and 44 percent of all HACLA certificate and voucher resources are housing formerly homeless individuals and families. The average income of all program participants is $19,815 per annum while the rents in Los Angeles are high. These participants have extremely low incomes, are at-risk households, living in a high-rent market, and without the subsidy would not be able to afford decent, safe, and sanitary housing. Further, the program is a valuable resource because in any given night there are more than 75,000 unsheltered residents in the Los Angeles area. HACLA?s highest priority is to house individuals which without the assistance of the program would be unable to pay rent and fall into homelessness or forced back to homelessness. With that said, program compliance is also a high priority for HACLA. As stated in Title 24 Code of Federal Regulations (24 CFR) ?982.516(a) the public housing authority must conduct a reexamination of family income and composition at least annually. Given HACLA?s very large program and the population it serves it is impossible to complete the annual reexamination within 12 months for 100% of the participants. Due to extenuating circumstances such as health issues, the death of the head of household and other challenges the family may be facing, it is impossible to have 100% compliance with this CFR. The housing authority must provide flexibility and extensions. The alternative would be for the housing authority to move forward with terminating the assistance in order to be fully compliant with the CFR--a position that HACLA does not take lightly given the humanitarian crisis in Los Angeles. The CFR is simply no longer in line with the realities of administering the program, and the expectation of the community. HACLA believes that HUD recognizes this in its monitoring practices for SEMAP. Nonetheless, HACLA?s goal is to complete all annual reviews within 12 months and will strike an appropriate balance to do so. These audit findings will assist HACLA in further advocating with HUD to adjust the regulatory requirement on annual reexamination completion time periods to be more in line with the reality of the homeless families that HACLA serves. HACLA?s Section 8 Department has the controls in place to ensure annual reexaminations are completed timely. Management will continue to proactively work with staff on an ongoing basis to ensure that participant families submit documentation timely or begin the intent to terminate process. This is a fine line, however, as HACLA is in the business of housing not terminating families. In line with HACLA?s Vision Plan, Executive Management is committed to improve processes across business lines. In mid-2022, HACLA contracted with Guidehouse, Inc., a consulting firm that works with housing authorities across the country such as the largest--the New York City Housing Authority, to identify and implement process improvements to simplify operations, meet regulatory requirements more efficiently and provide better customer services to applicants, participants and landlords. Guidehouse is in the process of that analysis and it is HACLA?s expectation that there will be an improvement and associated training in the annual reexamination completion process through better monitoring reports and dashboards to be provided in a shift to a better housing program platform as they have recommended. Person Responsible: Director of Section 8

As a corrective measure, along with additional staff training, Vanderbilt will be implementing a quality control step to ensure that the notifications are properly made. This step will essentially do a sweep of students whose financial aid awards have been finalized (but prior to the actual disbursement of funds) but have not yet received the required financial aid notification letter. This process will be executed on a weekly basis. Vanderbilt University expects to have this process in place by November 2022. For follow-up questions and information, please contact Brent Tener, Executive Director of Student Financial Aid and Scholarships at Vanderbilt University.

Program: AL 21.023 ? COVID-19 Emergency Rental Assistance ? Allowability & Eligibility Corrective Action Plan: N/A Contact: Lee Will Anticipated Completion Date: N/A

Views of Responsible Officials: We have streamlined and consolidated the payroll allocation file so that such manual errors will not occur in the future. We will also institute a monthly review process of employee timesheets, and the Executive Director will review and approve timesheets on a quarterly basis.

CAP for Finding: 2022-704 Finding 2022-704: Research and Development Cluster?Unallowable Costs Planned Corrective Action: We agree with the condition that expenditures noted by the auditors were posted to federal awards in error. Our institution has robust policies and procedures in place along with multiple levels of review for transactions that post to awards. However, there may be rare instances where a transaction posts to an award for which it is not allowable or allocable. As noted by the auditors, they sampled from a population of $86.9 million from certain expenditure codes and only questioned $650 in costs. These expenditures have now been transferred off the awards to non-sponsored funding. To help Research Administrators manage Research and Development Awards, RSP (Research and Sponsored Programs) offers a variety of tools. RSP maintains a website that houses policies and procedures related to all relevant Research Administration topics. In addition to this, the RSP website has FAQ (Frequently Asked Questions) pages on a variety of Research Administration topics. RSP also offers a comprehensive training program called RED (Research Education Development). We offer courses that include topics such as a basic introduction to research administration, closeout of awards, cost-share, cost-transfers, and many others. We will remind administrators and their staff of all the relevant information our website houses and that they should take any pertinent RED. Lastly, we will remind staff that they can retake courses if they haven?t taken them recently and want to refresh their knowledge. Anticipated Completion Date: 5/31/23 Person responsible for corrective action: Kyle Everard, Manager of NSF-DOE Team Research and Sponsored Programs Kyle.Everard@rsp.wisc.edu

CAP for Finding: 2022-301 DATE: March 21, 2023 TO: Lisa Kasel, Assistant Financial Audit Director Legislative Audit Bureau FROM: Barry Kasten, Director Bureau of Fiscal Services Department of Health Services SUBJECT: Corrective Action Plan ? Medical Assistance Program ? Home and Community-Based Services Unallowable Costs Department staff has reviewed the Legislative Audit Bureau?s (LAB) interim audit memo for Finding 2022-301: Medical Assistance Program ? Home and Community-Based Services Unallowable Costs. This is the department?s Corrective Action Plan. ? Recommendation (2022-301): Medical Assistance Program ? Home and Community-Based Services Unallowable Costs We recommend the Wisconsin Department of Health Services: ? work with the fiscal employer agency that improperly approved the payment we identified to determine how this payment was made, assess whether changes to current processes are needed, document its assessment, and implement corrective actions, as appropriate. Wisconsin Department of Health Services Planned Corrective Action: Based on the LAB findings, the DMS Bureau of Quality and Oversight (BQO) will implement a Corrective Action Plan (CAP) with the IRIS Fiscal Employer Agent (FEA), iLIFE. A review of the LAB findings indicates that iLIFE inadvertently issued a payment to an IRIS participant-hired worker (PHW) based on a service authorization associated with a participant that the PHW did not support. The IRIS provider agreement indicates that FEA?s are responsible for verifying invoices, timesheets, and other claims for payment for services and periods of time authorized by participants? service plans. iLIFE indicated their system?s optical character recognition (OCR) misread a PHW?s employee identification number causing the payment to be sent to the wrong PHW resulting in an overpayment. iLIFE will be required to fix their OCR and review process to complete the CAP. BQO will issue a CAP notification to iLIFE by March 27, 2023. BQO will work with iLIFE to ensure the system errors are corrected to prevent further occurrences and anticipates the CAP will remain open for approximately 6 months. Anticipated Completion Date: September 2023 Person responsible for corrective action: Ann Lamberg, Deputy Director Bureau of Quality and Oversight, Division of Medicaid Services ann.lamberg@dhs.wisconsin.gov

Corrective Action Plan Finding No.: 2022- 001 Condition: Per review of the District's inventory listing containing devices purchased with the Emergency Connectivity Fund Program funding, 876 devices of the 6,000 devices purchased were not distributed to students. This indicates that amounts purchased and requested for reimbursement exceeded the "one device per student or staff member" requirement. The District was unable to provide supporting documentation for the 876 devices to support compliance with the "Special Tests, Restricted Purposes" compliance requirement that states there must be an "unmet need" and that there are "per-user limitations." Plan: When the Emergency Connectivity Fund Program (?ECF?) became available, the district estimated that we needed 6,000 devices in order to meet the needs of students and school staff who would otherwise lack access to connected devices and broadband connections sufficient to engage in remote learning. This estimate was based on the population of students and staff at the time. The estimate also included a provision to address the district?s mobility rate of 13.6% (many students who transferred out of the district did so without returning the resources they had been provided). Additionally, approximately 20%+ of the devices in the past would be returned with damage or would not be returned at all and families were unable to pay for them. It was never the intention of the district to over-order devices. Instead, we had a reasonable expectation (based on the factors listed above), that additional units would be necessary to ensure that no student is left without access to a device so that the district can continue to meet the educational and social-emotional needs of ALL students. As of the date of this response, of the original 876 devices that were not assigned, the district now has only 719 of those devices remaining and fully anticipates the remaining devices to be assigned by the beginning of the 2023-2024 school year (September 2023). Anticipated Date of Completion: September 1, 2023 Name of Contact Person: Jennifer Brumback, Chief Academic Officer Management Response See Above

Views of responsible officials and planned corrective action: Management agrees with the above finding. Management plans to report their 2022 fiscal year appropriately using the correct reporting deadlines for 2022, and improve internal controls over program reporting requirements accordingly. Management will inquire with their CDFI representative regarding any additional actions needed for their 2021 reporting components submitted in the prior period.

Single Audit Report: Corrective Action Plan Year ending June 30, 2022 Finding 2022-001 Allowable Costs Grant Program/ALN#: Disaster Grants ? Public Assistance (Presidentially Declared Disasters) 97.036 Federal Agency: Department of Homeland Security Contact person responsible for corrective action: Joshua Repac Corrective Action: Meritus Medical Center, Inc. identified that the report used to identify contract nursing costs related to nurses that had treated COVID-19 patients was incorrectly including certain costs that were not related to COVID-19. As a result, management updated the report parameters, which resulted in the identification of $572,189 of expenses originally submitted and received that were not allowable costs. The corrective action has been implemented and completed prior to the release of the audit report for June 30, 2022. Report parameters were updated to include only COVID-19 specific infections. The report parameters were reviewed, approved, and additional samples were selected by management to ensure that the allowability criteria were met. In addition, the Company?s internal audit department used the revised submissions to independently select a random sample for testing, this will be done for future submissions as well.

Community Consolidated School District 21 05-016-0210-04 CORRECTIVE ACTION PLAN FOR CURRENT YEAR AUDIT FINDINGS Year Ending June 30, 2022 Corrective Action Plan Finding No.: 2022- 003 Condition: During our audit testing we noted that the District submitted a claim through SPI invoicing for 2,200 laptops ($858,814 in equipment) that exceeded the allowable amount of equipment for reimbursement through the Emergency Connectivity Fund to satisfy the District's unmet need. Plan: Management will develop a process with the Information Services Department to determine that the District is meeting all grant requirements, including measuring unmet need, in order to fully comply with the terms and conditions of a funding vehicle. Anticipated Date of Completion: 6/30/2023 Assistant Superintendent of Finance & Operations/CSBO Management Response: See above

Views of Responsible Officials, Corrective Action Plans, and Contact Information For the 2021-22 school year, the Food Services Division used federal waivers to support students and families by providing meals under multiple programs. Starting August 2021, COVID concerns resulted in the district discontinuing breakfast in the classroom. USDA waivers permitted the distribution of breakfast and supper meals to students as they left campus for consumption at home. As the school year progressed, the after-school supper program was reinstated for a small group of students at some schools, and this group of students was given a breakfast to take home. Additionally, we distributed weekend meals comprising of supper and snacks. Lastly, the district requested Food Services to serve a morning snack (at the District?s expense) for hungry students. The snacks were tracked manually for reimbursement from ESSER funds by the district. Each meal service required a different form to count meals and multiple sheets for the same meal period depending on how the meal bags were distributed (exit gate vs. classroom). The managers had many forms that had to be put together and summed up to come up with the reimbursable counts. Manually compiling and uploading the information is the reason for the variances. Each time there was a change in the operation, the Food Service team had to create a new training module for the change in operation, which created additional forms leading to the errors seen in the audit review. We want to state respectfully that our error rate for meal counts was 0.4% which, given the multiple food distribution channels to support students, is understandable. To address the audit findings, Food Services will review and modify our procedures and be stringent in monitoring our existing systems and procedures: 1. Food Services Division will add steps to our current meal claiming procedures to ensure accuracy of claims. a. Food Service Manager will utilize the Meal Count Consolidation Form for meal periods that have more than one meal count sheet. b. Food Service Manager will input meal counts into CMS based on information from the Consolidation Form. c. Food Service Manager will run a weekly Meal Counts Report generated from CMS. d. Food Service Manager will compare daily meal count documents to the five-day Meal Count Report for accuracy. e. Area Food Services Supervisors (AFSS) will randomly check meal counts entered in CMS and compare them with the numbers entered in daily meal count sheets. Each school will have a random review every 2-3 months, and where errors are found there will be additional follow up. 2. Food Services will follow the review steps as indicated in Corrective Action Response #1 and confirm the claim for accuracy prior to submission to CNIPS. a. Food Services Central Office Staff will provide a daily meal count report to all Supervisors for review to identify any inputting errors. b. Food Service Managers will review and adjust meal counts prior to the CNIPS claim submission, based on AFSS feedback. The target date for the implementation of the above corrective action plan is by the end of February 2023. Name: Manish Singh Title: Director, Food Services Division Telephone: (213) 241-2993

Corrective Action Plan The University will update written procedures to include an additional manual process, which identifies and updates withdrawals within the National Student Clearinghouse with a higher frequency. These procedures are targeted for the summer term, in which the current year lapse was identified. This will ensure that no one is reported outside of the 60 day window.

U. S. Department of Housing and Urban Development (Pass-through from Virginia Office of Community Planning and Development) Assistance Listing #14.267 Finding: 2022-003 Known Questioned Costs for a Federal Program Not Audited as a Major Program Criteria: In accordance with 2 CFR 200.516(a)(4) known questioned costs that are greater than $25,000 for a program that is not audited as a major program must be reported as an audit finding in the federal awards section of the schedule of findings and questioned costs. In September 2022, the U. S. Department of Housing and Urban Development, identified $1,463 of unallowed expenditures and a deficit of $27,464 in the required cash match under the Continuum of Care program for the year ended December 31, 2021, as a result of monitoring. Rapid Rehousing Requirements: Criteria: 24 CFR 578.51; 24 CFR 578.57 Condition: The Federal awarding agency has determined, in accordance with 24 CFR 578.51; 24 CFR 578.57; $1,463 of allowable HMIS expenses were not documented and that in accordance with 2 CFR 200.1; 2 CFR 200.103(a)(11); 2 CFR 200.306; 24 CFR 578.73 the grantee failed to match $27,464 on its Continuum of Care rapid rehousing project. Corrective Action Plan: The CFO will ensure that the HMIS expenses are being captured in financial documents be setting up a new account code in the financial software. Staff members that have HMIS hours will also record those hours separately on their timesheets each pay period. NRCA will be submitting copies of timesheets which record data entry by line item as further documentation of the HMIS expenses submitted in answers to the monitoring report. While NRCA respects the position of the Department of HUD, NRCA also believes management followed the grant agreement as submitted. NRCA sees resolution to this matter with the Department of HUD and is currently seeking counsel to ensure this resolution in an acceptable and appropriate manner. Persons Responsible: Michelle Cox, Chief Financial Officer and Krystal Thompson, Chief Executive Officer Timing for Implementation: Immediate

Prairie-Hills Elementary School District 144 07-016-1440-02 CORRECTIVE ACTION PLAN FOR CURRENT YEAR AUDIT FINDINGS21 Year Ending June 30, 2022 Corrective Action Plan Finding No.: 2022- 002 Condition: The District reported the wrong month of meal counts for March 2022. As a result, the March 2022 claim for meals served did not match the March 2022 meal counts retained by the District. The February 2022 meal counts were submitted once in February 2022 and then again for the March 2022 reporting period. Plan: Prior to reports being transmitted, the District Project Coordinator (as a third set of eyes) will review the meal count report for each month. An additional review of the meal count before transmission will avoid incorrect meal counts being reported. Anticipated Date of Completion: 11/30/2022 Name of Contact Person: Terry O?Brien; Chief School Business Official