Corrective Action Plans

Finding: The Department of Health did not have adequate internal controls over and did not comply with requirements to ensure payments to providers were allowable, met cost principles, and were within the period of performance for the Immunization Cooperative Agreements program. Questioned Costs: Assistance Listing # 93.268 93.268 COVID-19 Status: Corrective action in progress Corrective Action: The Department partially agrees with the finding. The Department agrees that internal controls can be strengthened over provider payments to ensure funds are allowable and spent within the period of performance. The following actions were taken: ? Required payments to providers contain adequate support in line with the A19 matrix and subrecipients? risk assessments. ? Provided additional training to staff in the immunization unit responsible for reviewing invoices. ? Developed tracking sheets which enable staff to record details from backup documentation reviews and payment approvals. The Department will review the control weaknesses identified in the audit related to the consolidated contract payment process and will determine if changes need to be made. The Department disagrees with the audit exceptions and questioned costs identified in the finding. The Department will work with the federal grantor to resolve any questioned costs. Completion Date: Estimated December 2023 Agency Contact: Jeff Arbuckle External Audit Manager PO Box 47890 Olympia, WA 98504-7890 (360) 701-0798 Jeff.Arbuckle@doh.wa.gov

Finding: The University of Washington did not have adequate internal controls over and did not comply with federal requirements to ensure subrecipients of the Global AIDS program received required single or program-specific audits, and that it followed up on findings and issued management decisions. Questioned Costs: Assistance Listing # 93.067 93.067 COVID-19 Amount $0 Status: Corrective action in progress Corrective Action: The University maintains that there are adequate internal controls to ensure the Global AIDS program complies with the requirements for pass-through entities as outlined in Uniform Guidance 2 CFR ? 200.332 and the university policy incorporated in Grants Information Memorandum 8. As noted in the finding, the University uses a certification process to obtain information and documentation needed, such as audited financial statements, from each subrecipient and perform a risk assessment using standard risk criteria. For the one exception identified by the auditors, the University misinterpreted the response provided by the subrecipient regarding whether it expended $750,000 or more in federal awards during the fiscal year. Although the single or program specific audit report was not obtained and reviewed, a risk assessment was performed on the subrecipient. With a medium risk rating, the subrecipient was subject to monitoring at the program level throughout the project during the period in question, in accordance with University policy. The University will: ? Update the certification process with all subrecipients to confirm if federal expenditures during a fiscal year exceed the $750,000 threshold to require a single or program-specific audit. ? Issue written management decisions for all applicable audit findings. ? Ensure subrecipients develop and perform acceptable corrective actions to address all audit recommendations, if applicable. Completion Date: Estimated September 2023 Agency Contact: Erick Winger Controller 4300 Roosevelt Way NE Seattle, WA 98195 (206) 543-5322 erickw@uw.edu

Finding: The University of Washington did not establish adequate internal controls to ensure payments to contractors and subrecipients for the Global AIDS program were allowable, properly supported and within the period of performance. Questioned Costs: Assistance Listing # 93.067 93.067 COVID-19 Amount $0 Status: Corrective action complete Corrective Action: The University partially concurs with the finding. The University disagrees with the auditors? assertion that internal controls were inadequate to ensure payments to contractors and subrecipients of the Global AIDS program were allowable, properly supported, and within the period of performance. Payments to country offices The University administers the program through its International Training and Education Center for Health (I-TECH), a center in the University?s Department of Global Health, with staff in various locations worldwide. I-TECH country offices are not contractors but are an extension of the University. The audit identified one of 58 payments in the test sample (1.7 percent) that did not meet the approval requirements set forth in I-TECH?s standard operating procedures. Based on the error percentage, the University disagrees with this part of the finding. Payments to contractors The University?s current payment process to contractors has multiple approval requirements. Upon receipt, program/budget manager reviews and approves individual invoices prior to input into the University?s procurement system by the I-TECH accounts payable administrator. The system requires compliance approval from the account payable supervisor or other manager, as well as funding approval from the budget manager prior to payment. Approvals of Budget Activity Reports (BARS) are not part of the approval process for contractor payments, but are post-payment reviews by budget managers of monthly expenses posted to the budget to ensure they are within expectations. The University disagrees with the exceptions identified in the finding related to payments to contractors. The exceptions noted were payments made to country offices instead of contractors, the supporting approvals of which were provided to the auditors on April 26, 2023, prior to the completion of fieldwork. Subrecipient reimbursements Contract managers review each subrecipient invoice for reasonableness, allowability and allocability, and require approval by both budget managers and principal investigators (PI) prior to payment in the University?s procurement system. The auditors reviewed and verified PI approvals for each selected subrecipient with no exception identified. It should be noted that approvals of BARS are also not part of the approval process for payments to subrecipients. The University acknowledges that documentation related to BARS reviews by budget managers was not available for 52 of the transactions tested and agrees that improvement is needed for retaining documentation of monthly reviews. In response to the finding, the University has started saving BARS review documentation on the server to ensure the documents are readily available. Completion Date: April 2023 Agency Contact: Erick Winger Controller 4300 Roosevelt Way NE Seattle, WA 98195 (206) 543-5322 erickw@uw.edu

2022-002 Special Tests and Provisions - SEMAP Housing Voucher Cluster Other matter required to be reported in accordance 2 CFR 200.516(a) Condition: During our audit of the Authority?s SEMAP submission and discussion with the Authority staff, we noted that the Authority did not have proper documentation to support the selections made for the Authority?s annual SEMAP submission. Auditor?s Recommendations: The Authority should prepare and keep documentation to clearly outline the testing performed as a part of the SEMAP submission and the conclusion of each testing items. Action Taken: Effective July 3 the Authority has required the HCV manager to take steps to ensure the documentation is maintained that clearly outlines the testing performed as part of the SEMAP submission.

Condition: The District overstated expenditures on the ESSER I June 30, 2021 expenditure report. Plan: Grant expenditures should be reviewed and reconciled back to the accounting records prior to submitting final reports; ISBE grants division should be contacted regarding this discrepancy. Anticipated Date of Completion: 6/30/2023 Name of Contact Person: Thomas Akers, Superintendent Management's response: The District agrees that the expenditures claimed on the June 30, 2021 expenditure report was overstated by $10,678 and in the future will review and reconcile the expenditure reports to the accounting records before submitting to ISBE.

Project Legal Name: Geneva Avenue Elderly Housing, Inc. HUD Project No.: 023-EE-110 Audit Firm: Cohnreznick LLP Period covered by the audit: 7/1/2021 ? 6/30/2022 Corrective Action Plan prepared by: Name: Amy Lawton Position: Regional Manager Telephone Number: 617-209-5266 The following is a recommended format to be followed by the auditee for preparing a corrective action plan: A. Current Findings on the Schedule of Findings, Questioned Costs and Recommendations 1. Finding 2022-001 a. Comments on the Finding and Each Recommendation Management agrees with the finding and the recommendation in the finding. b. Action(s) Taken or Planned on the Finding In order to verify that all EIV reports are being run in accordance with HUD regulations, an internal audit will be performed on a routine basis. This audit will be conducted by a Senior Manager, a Regional Manager, or by a member of the Compliance Department. This internal audit will be performed at the end of each fiscal quarter. B. Status of Corrective Actions on Findings Reported in the Schedule of the Status of Prior Year Findings, Questioned Costs and Recommendations N/A

The County Administrator worked with the Department of Accounts to submit a corrected report for the period ending December 2021 which satisfied the full grant amount.

Finding No.: 2021-013 AL Program: 93.354 Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response Area: Procurement Suspension and Debarment Questioned Costs: $79,194 Contact Person(s): Program Administrator, Director of DGFI and Chief Financial Officer Corrective Action Plan: CHCC concurs with the compliance finding concerning the absence of documented, contemporaneous suspension and debarment verification but respectfully disagrees with the questioned costs of $79,194. Under 2 CFR 200.516(b)(5), the effect of an audit finding should establish a clear and logical link between the identified condition and its actual or potential impact. Although CHCC did not retain evidence that the vendors’ exclusion status was verified before entering into the covered transactions, the historical SAM.gov Exclusions reports confirm that this vendor was not suspended, debarred, or otherwise excluded during the relevant procurement periods. Accordingly, the procedural deficiency did not result in an award to an ineligible vendor. Additionally, 2 CFR 200.516(b)(6) requires questioned costs to be identified and their computation explained. The $79,194 represents the total expenditure under the seven covered transactions rather than costs demonstrated to be unallowable, unsupported, unreasonable, or incurred with an excluded vendor. The expenditures were supported, incurred for authorized program purposes, and resulted in goods or services received by CHCC. CHCC Division Grants and Financial Integrity (DGFI), updated our Suspension and Debarment procedure to comply with 2 CFR 180.300. Responsible Official: Director of Procurement and Supply, Director of DGFI and Chief Financial Officer Proposed Completion Date: 09/30/2026

Finding No.: 2021-011 AL Program: 93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) Area: Procurement Suspension and Debarment Questioned Costs: $352,470 Contact Person(s): Program Manager, Procurement, DGFI Corrective Action Plan: CHCC concurs with the compliance finding concerning the absence of documented, contemporaneous suspension and debarment verification but respectfully disagrees with the questioned costs of $352,470. Under 2 CFR 200.516(b)(5), the effect of an audit finding should establish a clear and logical link between the identified condition and its actual or potential impact. Although CHCC did not retain evidence that the vendors’ exclusion status was verified before entering into the covered transactions, the historical SAM.gov Exclusions reports confirm that none of the vendors were suspended, debarred, or otherwise excluded during the relevant procurement periods. Accordingly, the procedural deficiency did not result in an award to an ineligible vendor. Additionally, 2 CFR 200.516(b)(6) requires questioned costs to be identified and their computation explained. The $352,470 represents the total expenditure under the seven covered transactions rather than costs demonstrated to be unallowable, unsupported, unreasonable, or incurred with an excluded vendor. The expenditures were supported, incurred for authorized program purposes, and resulted in goods or services received by CHCC. CHCC Division Grants and Financial Integrity (DGFI), updated our Suspension and Debarment procedure to comply with 2 CFR 180.300. Responsible Official: Director of Procurement and Supply, Director of DGFI and Chief Financial Officer Proposed Completion Date: 09/30/2026

Finding No.: 2021-005 AL Program: 15.875 Economic, Social, and Political Development of the Territories Area: Procurement and Suspension and Debarment Questioned Costs: $304,590 Contact Person(s): Director of Procurement and Supply and Chief Financial Officer, Division of Grants and Financial Integrity Corrective Action Plan: CHCC concurs with the compliance finding concerning the absence of documented, contemporaneous suspension and debarment verification but respectfully disagrees with the questioned costs of $304,590. Under 2 CFR 200.516(b)(5), the effect of an audit finding should establish a clear and logical link between the identified condition and its actual or potential impact. Although CHCC did not retain evidence that the vendors’ exclusion status was verified before entering into the covered transactions, the historical SAM.gov Exclusions reports confirm that neither vendor was suspended, debarred, or otherwise excluded during the relevant procurement periods. Accordingly, the procedural deficiency did not result in an award to an ineligible vendor. Additionally, 2 CFR 200.516(b)(6) requires questioned costs to be identified and their computation explained. The $304,590 represents the total expenditure under the two covered transactions rather than costs demonstrated to be unallowable, unsupported, unreasonable, or incurred with an excluded vendor. The expenditures were supported, incurred for authorized program purposes, and resulted in goods or services received by CHCC. This finding is substantially the same as the suspension and debarment findings reported in CHCC’s FY2020 Single Audit. The U.S. Department of the Interior, Office of Insular Affairs, subsequently reviewed CHCC’s corrective-action documentation and determined that CHCC had provided sufficient and appropriate evidence to resolve Finding 2020-005, which included questioned costs of $551,917 Responsible Official: Director of Procurement and Supply, Director of DGFI and Chief Financial Officer Proposed Completion Date: 09/30/2026

Planned Corrective Action : Fiscal Agent will ensure that supporting documentation is maintained for all expenditures to ensure that each expenditure charged to the program is for an allowable activity/cost. In addition, Fiscal Agent will complete corrective action for 2021-003. Anticipated Completion Date: March 31, 2024 Responsible Contact Person: Crystal Keaton

Planned Corrective Action : Fiscal Agent will ensure that supporting documentation is maintained for all expenditures to ensure that each expenditure charged to the program is for an allowable activity/cost. In addition, the Fiscal Agent will complete corrective action for 2021-003. Anticipated Completion Date: March 31, 2024 Responsible Contact Person: Crystal Keaton

Finding 2021-005 Activities Allowed and Unallowed, Allowable Costs, Period of Performance – Material Weakness in Internal Control over Compliance and Noncompliance Name of Contact Person: James Wilson, Borough Manager Corrective Action Plan: The Borough is currently undergoing an upgrade in record retention policies and procedures. Completion Date: December 2023