Finding Number: 2022-003 Prior Year Finding Number: N/A Compliance Requirement: Reporting Program: U.S. Department of Agriculture Child Nutrition Cluster ALN: 10.553, 10.555, 10.559 and 10.582 Award #: 1DC300302 Award Year: 10/01/2021 ? 09/30/2022 Government Department/Agency: District of Columbia Public Schools (DCPS) Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. 7 CFR Section 210.8 Claims for Reimbursement states: (a) Internal controls. The school food authority shall establish internal controls which ensure the accuracy of meal counts prior to the submission of the monthly Claim for Reimbursement. At a minimum, these internal controls shall include: an on-site review of the meal counting and claiming system employed by each school within the jurisdiction of the school food authority; comparisons of daily free, reduced price and paid meal counts against data which will assist in the identification of meal counts in excess of the number of free, reduced price and paid meals served each day to children eligible for such meals; and a system for following up on those meal counts which suggest the likelihood of meal counting problems. (1) ?On-site reviews. Every school year, each school food authority with more than one school shall perform no less than one on-site review of the counting and claiming system and the readily observable general areas of review cited under Section 210.18(h), as prescribed by FNS for each school under its jurisdiction. The on-site review shall take place prior to February 1 of each school year. Further, if the review discloses problems with a school's meal counting or claiming procedures or general review areas, the school food authority shall: ensure that the school implements corrective action; and, within 45 days of the review, conducts a follow-up on-site review to determine that the corrective action resolved the problems. Each on-site review shall ensure that the school's claim is based on the counting system authorized by the State agency under Section 210.7(c) of this part and that the counting system, as implemented, yields the actual number of reimbursable free, reduced price and paid meals, respectively, served for each day of operation.? Condition ? DCPS conducted 158 on-site reviews in fiscal year 2022. We selected a sample of sixteen (16) on-site reviews and noted that DCPS is unable to provide evidence to support that a review took place on two (2) of the samples where DCPS assessed that the schools passed the on-site review. These on-site reviews are the main control of DCPS to ensure that the meal counts reported and eventually claimed for reimbursement to the Office of the State Superintendent of Education (OSSE) is accurate. Questioned Costs ? Not determinable. Context ? This is a condition identified per review of DCPS? compliance with specified requirements using a statistically valid sample. Effect ? DCPS did not comply with the reporting requirements of the Child Nutrition Cluster. Cause ? DCPS does not have a fully effective internal controls over record keeping of on-site review process. Recommendation ? We recommend DCPS to continue to enhance its controls over reporting to ensure compliance with the requirements of the Child Nutrition Cluster. This should include policies and procedures relating to record keeping of support for any on-site review conducted and enhance monitoring controls to ensure all supporting documentation over the on-site review are filed and available for inspection at any time. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? DCPS agrees with the conditions and recommendations of this finding. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-024 Prior Year Finding Number: N/A Compliance Requirement: Data Collection Form and Single Audit Reporting Package Programs: ALN: 10.551, 10.561 Supplemental Nutrition Assistance Program Cluster ALN: 10.553, 10.555, 10.559, 10.582 Child Nutrition Cluster ALN: 10.558 Child and Adult Care Food Program ALN: 14.218 Community Development Block Grants/Entitlement Grants Cluster ALN: 21.023 COVID-19 ? Emergency Rental Assistance Program ALN: 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Relief Funds ALN: 84.027, 84.173 Special Education Cluster ALN: 84.126 Rehabilitation Services - Vocational Rehabilitation Grants to States ALN: 84.425 COVID-19 ? Education Stabilization Fund ALN: 93.268 Immunization Cooperative Agreements ALN: 93.498 COVID-19 ? Provider Relief Fund ALN: 93.558 Temporary Assistance for Needy Families ALN: 93.568 Low Income Home Energy Assistance ALN: 93.569 Community Services Block Grant ALN: 93.658 Foster Care ? Title IV-E ALN: 93.775, 93.777, 93.778 Medicaid Cluster ALN: 93.914 HIV Emergency Relief Project Grants ALN: 97.036 Public Assistance - Presidentially Declared Disaster Criteria - The Uniform Guidance in 2 CFR Section 200.512, Report Submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor?s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Condition ? The District did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended September 30, 2022. Questioned Costs ? None. Context ? This is a condition identified per review of the District?s compliance with the specified requirements. Effect ? The District could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Cause ? The District did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe. Recommendation ? We recommend that the District closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? The District concurs with the auditor?s findings and recommendations. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-001 Prior Year Finding Number: 2021-001 Compliance Requirement: Special Tests and Provisions ? ADP System for SNAP Program: U.S. Department of Agriculture Supplemental Nutrition Assistance Program Cluster (SNAP) ALN: 10.551, 10.561 Award #: Various Award Year: 10/01/2021 ? 09/30/2022 Government Department/Agency: Department of Human Services (DHS)/ Department of Health Care Finance (DHCF) DC Access System (DCAS) Program Management Administration Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR Section 272.10(a), ?All State agencies are required to sufficiently automate their SNAP operations and computerize their systems for obtaining, maintaining, utilizing, and transmitting information concerning SNAP.? Per 2 CFR Section 272.10(b), ?In order to meet the requirements of the Act and ensure the efficient and effective administration of the program, a SNAP system, at a minimum, shall be automated in each of the following program areas (1) Certification and (2) Issuance Reconciliation and Reporting. Under Certification ? States agencies must determine eligibility and calculate benefits or validate the eligibility worker?s calculations by processing and storing all casefile information necessary for the eligibility determination and benefit computation (including but not limited to all household members? names, addresses, dates of birth, social security numbers, individual household members? earned and unearned income by source, deductions, resources and household size). Also, State agencies must redetermine or revalidate eligibility and benefits based on notices of change in households? circumstances.? Condition ? The District is self-reporting findings it noted from its ongoing efforts to resolve issues with the ADP system for SNAP. The issues identified and the estimated impact follows: 1. The SNAP net and gross income tests are applied to households who are categorically eligible through receipt or authorization to receive non-cash benefits under the District?s Temporary Assistance for Needy Families (TANF) program operated to meet 7 CFR 273.2(j)(2)(i)(C). As a result, SNAP applications are being improperly denied for failing the net or gross income test. The cost of this underpayment is currently unknown. 2. The SNAP gross income test is applied to applicants that contain an elderly or disabled member. As a result, SNAP applications are being improperly denied for failing the gross income test. The cost of this underpayment is currently unknown. 3. SNAP benefits are issued for the initial month of the certification period if the prorated amount is less than $10. As a result, SNAP benefits are being improperly overissued to some households. The cost of this overpayment is $48,592. 4. The Federal minimum SNAP benefit is not issued to eligible one or two person households unless those households are categorically eligible. As a result, one or two person households that are not categorically eligible will not receive benefits they are entitled to. The cost of this underpayment is currently unknown. 5. Certain allowable medical expenses are not configured in DCAS to allow a medical expense deduction. As a result, certain households with elderly or disabled members are not receiving a medical expense deduction. The cost of this underpayment is currently unknown. 6. DCAS is excluding retirement benefits from ?Civil Service Retirement and Disability? as unearned income when determining eligibility and benefits levels. As a result, some households may be determined eligible even if these retirement benefits would make them ineligible and some households will receive overpayments for failing to include these retirement benefits in the SNAP benefit calculation. The cost of this overpayment is $126,574. 7. Certain SNAP applicants/household members verified as students but not meeting a student exemption are included as household members. As a result, ineligible students are included in SNAP households resulting in overpayments. The cost of this overpayment is $57,785. 8. ESA is not providing the mandatory homeless shelter deduction for SNAP households experiencing homelessness with allowable shelter costs that do not opt to claim an excess shelter deduction. The cost of this underpayment is currently unknown. 9. ESA is not terminating customers who refuse to cooperate with the District Quality Control (QC) reviewers. The District?s interviews with QC staff and examples of recent cases referred by QC to ESA for termination revealed that in two instances, a request to terminate a SNAP household was not acted on by ESA, and in one instance, a request to terminate a SNAP household was acted on but ESA issued a termination notice with an incorrect termination reason. The cost of this overpayment is currently unknown. 10. ESA is not acting on Electronic Disqualified Recipient System (eDRS) matches at initial application or when a new household member is added. The cost of this overpayment is currently unknown. 11. SNAP does not have a systemic way to identify SNAP customers subject to the Able-Bodied Adult Without Dependents (ABAWD) work requirements. The cost of this overpayment is currently $18,500 per month or $222,000 for fiscal year 2022. These amounts represent 0.09% of the total amounts paid by DHS in claims for beneficiary payments. DHS paid a total of $506,630,102 in beneficiary payments to all SNAP beneficiaries in fiscal year 2022. Questioned Costs ? Known amount is $454,951. Context ? This is a condition identified per review of DHS? compliance with specified requirements resulting from a system implementation. Effect ? Without an effectively designed and operated system in place, ineligible beneficiaries may receive benefits under the SNAP grant and DHS may make payments on behalf of those beneficiaries resulting in noncompliance with the eligibility requirements. Inaccurate beneficiary allotment payments could result in participants receiving benefits that they are not entitled to receive under the program. Cause ? DHS did not effectively design and operate the ADP system for SNAP which resulted to inaccurate benefit payments. Recommendation ? We recommend that DHS continue to evaluate and improve the new ADP system for SNAP to ensure that it addresses all the administration requirements of the SNAP program. Related Noncompliance ? Material noncompliance. Views of Responsible Officials and Planned Corrective Actions ? The DHS and DHCF DCAS team agree with the findings noted in this report. DHS self-reported these findings as part of the Agencies ongoing effort to maintain integrity with all eligibility determinations. The root cause for each of the eleven (11) issues with the ADP system for SNAP varied. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-002 Prior Year Finding Number: 2021-002 Compliance Requirement: Special Tests and Provisions ? EBT Card Security Program: U.S. Department of Agriculture Supplemental Nutrition Assistance Program Cluster (SNAP) ALN: 10.551, 10.561 Award #: Various Award Year: 10/01/2021 ? 09/30/2022 Government Department/Agency: Department of Human Services (DHS)/ Office of the Chief Financial Officer/Office of Finance and Treasury (OCFO/OFT) Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 7 CFR Section 274.8(b)(3), As an addition to or component of the Security Program required of Automated Data Processing (ADP) systems, the State agency shall ensure that the following electronic benefits transfer (EBT) security requirements are established: (i) Storage and control measures to control blank unissued EBT cards and PINs, and unused or spare POS devices; (ii) Measures to ensure communication access control. Communication controls shall include the transmission of transaction data and issuance information from POS terminals to work-stations and terminals at the data processing center; (iii) Message validation; (iv) Administrative and operational procedures; (v) A separate EBT security component shall be incorporated into the State agency Security Program for ADP systems. The periodic risk analyses required by the Security Program shall address the following items specific to an EBT system ? (B) Completeness and timeliness of the reconciliation system; and (vi) The State agency shall incorporate the contingency plan approved by FNS into the Security Program. Condition ? OCFO/OFT for DHS are required to maintain adequate security over, and documentation/records for EBT cards, to prevent their theft, embezzlement, loss damage, destruction, unauthorized transfer, negotiation, or use. OCFO/OFT have contracted with Fidelity National Information Service (FIS) for the issuance and security of the EBT cards; however, it is OCFO/OFT?s ultimate responsibility to ensure the contractor has controls in place to maintain adequate security over, and documentation/records of EBT cards. During our tests of the design and implementation of internal controls, we noted the following issues: ? For five (5) out of the 60 samples, although both EBT Balance Sheets reconciled with the EBT Card Issuance Logs included in the package, we noted the following deficiencies: o For one (1) of the samples, we noted that for at least one (1) customer the client signature was missing from the EBT Intake Form. o For three (3) of the samples, we noted that for at least one (1) customer on the UPO EBT Intake Form, the ID type for identification purposes was missing. o For one (1) of the samples, we noted that for at least one (1) customer the identification type was noted as referral on the EBT Intake Form, but no referral form was attached. Questioned Costs ? None. Context ? This is a condition identified per review of DHS? compliance with specified requirements using a statistically valid sample. Effect ? Without adequate internal controls to ensure compliance with EBT Card Security requirements, there is an increased risk that the inventory of EBT cards will not be properly maintained and accounted for. Cause ? OCFO/OFT for DHS does not have adequate policies and procedures in place to ensure adequate safeguarding, documentation over issuance and monitoring of EBT cards. Recommendation - We recommend that OCFO/OFT for DHS strengthen formal policies and procedures to maintain adequate security over, and documentation/records for EBT Cards. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? The OCFO/OFT for DHS concurs with this finding. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-024 Prior Year Finding Number: N/A Compliance Requirement: Data Collection Form and Single Audit Reporting Package Programs: ALN: 10.551, 10.561 Supplemental Nutrition Assistance Program Cluster ALN: 10.553, 10.555, 10.559, 10.582 Child Nutrition Cluster ALN: 10.558 Child and Adult Care Food Program ALN: 14.218 Community Development Block Grants/Entitlement Grants Cluster ALN: 21.023 COVID-19 ? Emergency Rental Assistance Program ALN: 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Relief Funds ALN: 84.027, 84.173 Special Education Cluster ALN: 84.126 Rehabilitation Services - Vocational Rehabilitation Grants to States ALN: 84.425 COVID-19 ? Education Stabilization Fund ALN: 93.268 Immunization Cooperative Agreements ALN: 93.498 COVID-19 ? Provider Relief Fund ALN: 93.558 Temporary Assistance for Needy Families ALN: 93.568 Low Income Home Energy Assistance ALN: 93.569 Community Services Block Grant ALN: 93.658 Foster Care ? Title IV-E ALN: 93.775, 93.777, 93.778 Medicaid Cluster ALN: 93.914 HIV Emergency Relief Project Grants ALN: 97.036 Public Assistance - Presidentially Declared Disaster Criteria - The Uniform Guidance in 2 CFR Section 200.512, Report Submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor?s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Condition ? The District did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended September 30, 2022. Questioned Costs ? None. Context ? This is a condition identified per review of the District?s compliance with the specified requirements. Effect ? The District could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Cause ? The District did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe. Recommendation ? We recommend that the District closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? The District concurs with the auditor?s findings and recommendations. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-001 Prior Year Finding Number: 2021-001 Compliance Requirement: Special Tests and Provisions ? ADP System for SNAP Program: U.S. Department of Agriculture Supplemental Nutrition Assistance Program Cluster (SNAP) ALN: 10.551, 10.561 Award #: Various Award Year: 10/01/2021 ? 09/30/2022 Government Department/Agency: Department of Human Services (DHS)/ Department of Health Care Finance (DHCF) DC Access System (DCAS) Program Management Administration Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR Section 272.10(a), ?All State agencies are required to sufficiently automate their SNAP operations and computerize their systems for obtaining, maintaining, utilizing, and transmitting information concerning SNAP.? Per 2 CFR Section 272.10(b), ?In order to meet the requirements of the Act and ensure the efficient and effective administration of the program, a SNAP system, at a minimum, shall be automated in each of the following program areas (1) Certification and (2) Issuance Reconciliation and Reporting. Under Certification ? States agencies must determine eligibility and calculate benefits or validate the eligibility worker?s calculations by processing and storing all casefile information necessary for the eligibility determination and benefit computation (including but not limited to all household members? names, addresses, dates of birth, social security numbers, individual household members? earned and unearned income by source, deductions, resources and household size). Also, State agencies must redetermine or revalidate eligibility and benefits based on notices of change in households? circumstances.? Condition ? The District is self-reporting findings it noted from its ongoing efforts to resolve issues with the ADP system for SNAP. The issues identified and the estimated impact follows: 1. The SNAP net and gross income tests are applied to households who are categorically eligible through receipt or authorization to receive non-cash benefits under the District?s Temporary Assistance for Needy Families (TANF) program operated to meet 7 CFR 273.2(j)(2)(i)(C). As a result, SNAP applications are being improperly denied for failing the net or gross income test. The cost of this underpayment is currently unknown. 2. The SNAP gross income test is applied to applicants that contain an elderly or disabled member. As a result, SNAP applications are being improperly denied for failing the gross income test. The cost of this underpayment is currently unknown. 3. SNAP benefits are issued for the initial month of the certification period if the prorated amount is less than $10. As a result, SNAP benefits are being improperly overissued to some households. The cost of this overpayment is $48,592. 4. The Federal minimum SNAP benefit is not issued to eligible one or two person households unless those households are categorically eligible. As a result, one or two person households that are not categorically eligible will not receive benefits they are entitled to. The cost of this underpayment is currently unknown. 5. Certain allowable medical expenses are not configured in DCAS to allow a medical expense deduction. As a result, certain households with elderly or disabled members are not receiving a medical expense deduction. The cost of this underpayment is currently unknown. 6. DCAS is excluding retirement benefits from ?Civil Service Retirement and Disability? as unearned income when determining eligibility and benefits levels. As a result, some households may be determined eligible even if these retirement benefits would make them ineligible and some households will receive overpayments for failing to include these retirement benefits in the SNAP benefit calculation. The cost of this overpayment is $126,574. 7. Certain SNAP applicants/household members verified as students but not meeting a student exemption are included as household members. As a result, ineligible students are included in SNAP households resulting in overpayments. The cost of this overpayment is $57,785. 8. ESA is not providing the mandatory homeless shelter deduction for SNAP households experiencing homelessness with allowable shelter costs that do not opt to claim an excess shelter deduction. The cost of this underpayment is currently unknown. 9. ESA is not terminating customers who refuse to cooperate with the District Quality Control (QC) reviewers. The District?s interviews with QC staff and examples of recent cases referred by QC to ESA for termination revealed that in two instances, a request to terminate a SNAP household was not acted on by ESA, and in one instance, a request to terminate a SNAP household was acted on but ESA issued a termination notice with an incorrect termination reason. The cost of this overpayment is currently unknown. 10. ESA is not acting on Electronic Disqualified Recipient System (eDRS) matches at initial application or when a new household member is added. The cost of this overpayment is currently unknown. 11. SNAP does not have a systemic way to identify SNAP customers subject to the Able-Bodied Adult Without Dependents (ABAWD) work requirements. The cost of this overpayment is currently $18,500 per month or $222,000 for fiscal year 2022. These amounts represent 0.09% of the total amounts paid by DHS in claims for beneficiary payments. DHS paid a total of $506,630,102 in beneficiary payments to all SNAP beneficiaries in fiscal year 2022. Questioned Costs ? Known amount is $454,951. Context ? This is a condition identified per review of DHS? compliance with specified requirements resulting from a system implementation. Effect ? Without an effectively designed and operated system in place, ineligible beneficiaries may receive benefits under the SNAP grant and DHS may make payments on behalf of those beneficiaries resulting in noncompliance with the eligibility requirements. Inaccurate beneficiary allotment payments could result in participants receiving benefits that they are not entitled to receive under the program. Cause ? DHS did not effectively design and operate the ADP system for SNAP which resulted to inaccurate benefit payments. Recommendation ? We recommend that DHS continue to evaluate and improve the new ADP system for SNAP to ensure that it addresses all the administration requirements of the SNAP program. Related Noncompliance ? Material noncompliance. Views of Responsible Officials and Planned Corrective Actions ? The DHS and DHCF DCAS team agree with the findings noted in this report. DHS self-reported these findings as part of the Agencies ongoing effort to maintain integrity with all eligibility determinations. The root cause for each of the eleven (11) issues with the ADP system for SNAP varied. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-002 Prior Year Finding Number: 2021-002 Compliance Requirement: Special Tests and Provisions ? EBT Card Security Program: U.S. Department of Agriculture Supplemental Nutrition Assistance Program Cluster (SNAP) ALN: 10.551, 10.561 Award #: Various Award Year: 10/01/2021 ? 09/30/2022 Government Department/Agency: Department of Human Services (DHS)/ Office of the Chief Financial Officer/Office of Finance and Treasury (OCFO/OFT) Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 7 CFR Section 274.8(b)(3), As an addition to or component of the Security Program required of Automated Data Processing (ADP) systems, the State agency shall ensure that the following electronic benefits transfer (EBT) security requirements are established: (i) Storage and control measures to control blank unissued EBT cards and PINs, and unused or spare POS devices; (ii) Measures to ensure communication access control. Communication controls shall include the transmission of transaction data and issuance information from POS terminals to work-stations and terminals at the data processing center; (iii) Message validation; (iv) Administrative and operational procedures; (v) A separate EBT security component shall be incorporated into the State agency Security Program for ADP systems. The periodic risk analyses required by the Security Program shall address the following items specific to an EBT system ? (B) Completeness and timeliness of the reconciliation system; and (vi) The State agency shall incorporate the contingency plan approved by FNS into the Security Program. Condition ? OCFO/OFT for DHS are required to maintain adequate security over, and documentation/records for EBT cards, to prevent their theft, embezzlement, loss damage, destruction, unauthorized transfer, negotiation, or use. OCFO/OFT have contracted with Fidelity National Information Service (FIS) for the issuance and security of the EBT cards; however, it is OCFO/OFT?s ultimate responsibility to ensure the contractor has controls in place to maintain adequate security over, and documentation/records of EBT cards. During our tests of the design and implementation of internal controls, we noted the following issues: ? For five (5) out of the 60 samples, although both EBT Balance Sheets reconciled with the EBT Card Issuance Logs included in the package, we noted the following deficiencies: o For one (1) of the samples, we noted that for at least one (1) customer the client signature was missing from the EBT Intake Form. o For three (3) of the samples, we noted that for at least one (1) customer on the UPO EBT Intake Form, the ID type for identification purposes was missing. o For one (1) of the samples, we noted that for at least one (1) customer the identification type was noted as referral on the EBT Intake Form, but no referral form was attached. Questioned Costs ? None. Context ? This is a condition identified per review of DHS? compliance with specified requirements using a statistically valid sample. Effect ? Without adequate internal controls to ensure compliance with EBT Card Security requirements, there is an increased risk that the inventory of EBT cards will not be properly maintained and accounted for. Cause ? OCFO/OFT for DHS does not have adequate policies and procedures in place to ensure adequate safeguarding, documentation over issuance and monitoring of EBT cards. Recommendation - We recommend that OCFO/OFT for DHS strengthen formal policies and procedures to maintain adequate security over, and documentation/records for EBT Cards. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? The OCFO/OFT for DHS concurs with this finding. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-024 Prior Year Finding Number: N/A Compliance Requirement: Data Collection Form and Single Audit Reporting Package Programs: ALN: 10.551, 10.561 Supplemental Nutrition Assistance Program Cluster ALN: 10.553, 10.555, 10.559, 10.582 Child Nutrition Cluster ALN: 10.558 Child and Adult Care Food Program ALN: 14.218 Community Development Block Grants/Entitlement Grants Cluster ALN: 21.023 COVID-19 ? Emergency Rental Assistance Program ALN: 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Relief Funds ALN: 84.027, 84.173 Special Education Cluster ALN: 84.126 Rehabilitation Services - Vocational Rehabilitation Grants to States ALN: 84.425 COVID-19 ? Education Stabilization Fund ALN: 93.268 Immunization Cooperative Agreements ALN: 93.498 COVID-19 ? Provider Relief Fund ALN: 93.558 Temporary Assistance for Needy Families ALN: 93.568 Low Income Home Energy Assistance ALN: 93.569 Community Services Block Grant ALN: 93.658 Foster Care ? Title IV-E ALN: 93.775, 93.777, 93.778 Medicaid Cluster ALN: 93.914 HIV Emergency Relief Project Grants ALN: 97.036 Public Assistance - Presidentially Declared Disaster Criteria - The Uniform Guidance in 2 CFR Section 200.512, Report Submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor?s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Condition ? The District did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended September 30, 2022. Questioned Costs ? None. Context ? This is a condition identified per review of the District?s compliance with the specified requirements. Effect ? The District could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Cause ? The District did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe. Recommendation ? We recommend that the District closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? The District concurs with the auditor?s findings and recommendations. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-003 Prior Year Finding Number: N/A Compliance Requirement: Reporting Program: U.S. Department of Agriculture Child Nutrition Cluster ALN: 10.553, 10.555, 10.559 and 10.582 Award #: 1DC300302 Award Year: 10/01/2021 ? 09/30/2022 Government Department/Agency: District of Columbia Public Schools (DCPS) Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. 7 CFR Section 210.8 Claims for Reimbursement states: (a) Internal controls. The school food authority shall establish internal controls which ensure the accuracy of meal counts prior to the submission of the monthly Claim for Reimbursement. At a minimum, these internal controls shall include: an on-site review of the meal counting and claiming system employed by each school within the jurisdiction of the school food authority; comparisons of daily free, reduced price and paid meal counts against data which will assist in the identification of meal counts in excess of the number of free, reduced price and paid meals served each day to children eligible for such meals; and a system for following up on those meal counts which suggest the likelihood of meal counting problems. (1) ?On-site reviews. Every school year, each school food authority with more than one school shall perform no less than one on-site review of the counting and claiming system and the readily observable general areas of review cited under Section 210.18(h), as prescribed by FNS for each school under its jurisdiction. The on-site review shall take place prior to February 1 of each school year. Further, if the review discloses problems with a school's meal counting or claiming procedures or general review areas, the school food authority shall: ensure that the school implements corrective action; and, within 45 days of the review, conducts a follow-up on-site review to determine that the corrective action resolved the problems. Each on-site review shall ensure that the school's claim is based on the counting system authorized by the State agency under Section 210.7(c) of this part and that the counting system, as implemented, yields the actual number of reimbursable free, reduced price and paid meals, respectively, served for each day of operation.? Condition ? DCPS conducted 158 on-site reviews in fiscal year 2022. We selected a sample of sixteen (16) on-site reviews and noted that DCPS is unable to provide evidence to support that a review took place on two (2) of the samples where DCPS assessed that the schools passed the on-site review. These on-site reviews are the main control of DCPS to ensure that the meal counts reported and eventually claimed for reimbursement to the Office of the State Superintendent of Education (OSSE) is accurate. Questioned Costs ? Not determinable. Context ? This is a condition identified per review of DCPS? compliance with specified requirements using a statistically valid sample. Effect ? DCPS did not comply with the reporting requirements of the Child Nutrition Cluster. Cause ? DCPS does not have a fully effective internal controls over record keeping of on-site review process. Recommendation ? We recommend DCPS to continue to enhance its controls over reporting to ensure compliance with the requirements of the Child Nutrition Cluster. This should include policies and procedures relating to record keeping of support for any on-site review conducted and enhance monitoring controls to ensure all supporting documentation over the on-site review are filed and available for inspection at any time. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? DCPS agrees with the conditions and recommendations of this finding. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-024 Prior Year Finding Number: N/A Compliance Requirement: Data Collection Form and Single Audit Reporting Package Programs: ALN: 10.551, 10.561 Supplemental Nutrition Assistance Program Cluster ALN: 10.553, 10.555, 10.559, 10.582 Child Nutrition Cluster ALN: 10.558 Child and Adult Care Food Program ALN: 14.218 Community Development Block Grants/Entitlement Grants Cluster ALN: 21.023 COVID-19 ? Emergency Rental Assistance Program ALN: 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Relief Funds ALN: 84.027, 84.173 Special Education Cluster ALN: 84.126 Rehabilitation Services - Vocational Rehabilitation Grants to States ALN: 84.425 COVID-19 ? Education Stabilization Fund ALN: 93.268 Immunization Cooperative Agreements ALN: 93.498 COVID-19 ? Provider Relief Fund ALN: 93.558 Temporary Assistance for Needy Families ALN: 93.568 Low Income Home Energy Assistance ALN: 93.569 Community Services Block Grant ALN: 93.658 Foster Care ? Title IV-E ALN: 93.775, 93.777, 93.778 Medicaid Cluster ALN: 93.914 HIV Emergency Relief Project Grants ALN: 97.036 Public Assistance - Presidentially Declared Disaster Criteria - The Uniform Guidance in 2 CFR Section 200.512, Report Submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor?s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Condition ? The District did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended September 30, 2022. Questioned Costs ? None. Context ? This is a condition identified per review of the District?s compliance with the specified requirements. Effect ? The District could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Cause ? The District did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe. Recommendation ? We recommend that the District closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? The District concurs with the auditor?s findings and recommendations. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-024 Prior Year Finding Number: N/A Compliance Requirement: Data Collection Form and Single Audit Reporting Package Programs: ALN: 10.551, 10.561 Supplemental Nutrition Assistance Program Cluster ALN: 10.553, 10.555, 10.559, 10.582 Child Nutrition Cluster ALN: 10.558 Child and Adult Care Food Program ALN: 14.218 Community Development Block Grants/Entitlement Grants Cluster ALN: 21.023 COVID-19 ? Emergency Rental Assistance Program ALN: 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Relief Funds ALN: 84.027, 84.173 Special Education Cluster ALN: 84.126 Rehabilitation Services - Vocational Rehabilitation Grants to States ALN: 84.425 COVID-19 ? Education Stabilization Fund ALN: 93.268 Immunization Cooperative Agreements ALN: 93.498 COVID-19 ? Provider Relief Fund ALN: 93.558 Temporary Assistance for Needy Families ALN: 93.568 Low Income Home Energy Assistance ALN: 93.569 Community Services Block Grant ALN: 93.658 Foster Care ? Title IV-E ALN: 93.775, 93.777, 93.778 Medicaid Cluster ALN: 93.914 HIV Emergency Relief Project Grants ALN: 97.036 Public Assistance - Presidentially Declared Disaster Criteria - The Uniform Guidance in 2 CFR Section 200.512, Report Submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor?s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Condition ? The District did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended September 30, 2022. Questioned Costs ? None. Context ? This is a condition identified per review of the District?s compliance with the specified requirements. Effect ? The District could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Cause ? The District did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe. Recommendation ? We recommend that the District closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? The District concurs with the auditor?s findings and recommendations. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-024 Prior Year Finding Number: N/A Compliance Requirement: Data Collection Form and Single Audit Reporting Package Programs: ALN: 10.551, 10.561 Supplemental Nutrition Assistance Program Cluster ALN: 10.553, 10.555, 10.559, 10.582 Child Nutrition Cluster ALN: 10.558 Child and Adult Care Food Program ALN: 14.218 Community Development Block Grants/Entitlement Grants Cluster ALN: 21.023 COVID-19 ? Emergency Rental Assistance Program ALN: 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Relief Funds ALN: 84.027, 84.173 Special Education Cluster ALN: 84.126 Rehabilitation Services - Vocational Rehabilitation Grants to States ALN: 84.425 COVID-19 ? Education Stabilization Fund ALN: 93.268 Immunization Cooperative Agreements ALN: 93.498 COVID-19 ? Provider Relief Fund ALN: 93.558 Temporary Assistance for Needy Families ALN: 93.568 Low Income Home Energy Assistance ALN: 93.569 Community Services Block Grant ALN: 93.658 Foster Care ? Title IV-E ALN: 93.775, 93.777, 93.778 Medicaid Cluster ALN: 93.914 HIV Emergency Relief Project Grants ALN: 97.036 Public Assistance - Presidentially Declared Disaster Criteria - The Uniform Guidance in 2 CFR Section 200.512, Report Submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor?s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Condition ? The District did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended September 30, 2022. Questioned Costs ? None. Context ? This is a condition identified per review of the District?s compliance with the specified requirements. Effect ? The District could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Cause ? The District did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe. Recommendation ? We recommend that the District closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? The District concurs with the auditor?s findings and recommendations. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-024 Prior Year Finding Number: N/A Compliance Requirement: Data Collection Form and Single Audit Reporting Package Programs: ALN: 10.551, 10.561 Supplemental Nutrition Assistance Program Cluster ALN: 10.553, 10.555, 10.559, 10.582 Child Nutrition Cluster ALN: 10.558 Child and Adult Care Food Program ALN: 14.218 Community Development Block Grants/Entitlement Grants Cluster ALN: 21.023 COVID-19 ? Emergency Rental Assistance Program ALN: 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Relief Funds ALN: 84.027, 84.173 Special Education Cluster ALN: 84.126 Rehabilitation Services - Vocational Rehabilitation Grants to States ALN: 84.425 COVID-19 ? Education Stabilization Fund ALN: 93.268 Immunization Cooperative Agreements ALN: 93.498 COVID-19 ? Provider Relief Fund ALN: 93.558 Temporary Assistance for Needy Families ALN: 93.568 Low Income Home Energy Assistance ALN: 93.569 Community Services Block Grant ALN: 93.658 Foster Care ? Title IV-E ALN: 93.775, 93.777, 93.778 Medicaid Cluster ALN: 93.914 HIV Emergency Relief Project Grants ALN: 97.036 Public Assistance - Presidentially Declared Disaster Criteria - The Uniform Guidance in 2 CFR Section 200.512, Report Submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor?s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Condition ? The District did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended September 30, 2022. Questioned Costs ? None. Context ? This is a condition identified per review of the District?s compliance with the specified requirements. Effect ? The District could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Cause ? The District did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe. Recommendation ? We recommend that the District closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? The District concurs with the auditor?s findings and recommendations. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-004 Prior Year Finding Number: 2021-004 Compliance Requirement: Eligibility Program: U.S. Department of the Treasury COVID-19 ? Emergency Rental Assistance (ERA) Program ALN: 21.023 Award #: N/A Award Year: 12/27/2020 ? 09/30/2025 Government Department/Agency: Department of Human Services Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. The Treasury Department ERA FAQ 8-25-21, question 1, states that grantees must require all applications for assistance to include an attestation from the applicant that all information included is correct and complete. The Treasury Department ERA FAQ 8-25-21, question 4, states that the statutes establishing ERA1 and ERA2 limit eligibility to households based on certain income criteria. For purposes of ERA1, the area median income for a household is the same as the income limits for families published by the Department of Housing and Urban Development (HUD) in accordance with 42 U.S.C. 1437a(b)(2), available under the heading for ?Access Individual Income Limits Areas? at https://www.huduser.gov/portal/datasets/il.html. If a grantee in ERA1 uses a household?s monthly income to determine eligibility, the grantee should review the monthly income information provided at the time of application and extrapolate over a 12-month period to determine whether household income exceeds 80 percent of area median income. For example, if the applicant provides income information for two months, the grantee should multiply it by six to determine the annual amount. If a household qualifies based on monthly income, the grantee must redetermine the household income eligibility every three months for the duration of assistance. Grantees in ERA1 and ERA2 must have a reasonable basis under the circumstances for determining income. A grantee may support its determination with both a written attestation from the applicant as to household income and also documentation available to the applicant, such as paystubs, W-2s or other wage statements, tax filings, bank statements demonstrating regular income, or an attestation from an employer. In appropriate cases, grantees may rely on an attestation from a caseworker or other professional with knowledge of a household?s circumstances to certify that an applicant?s household income qualifies for assistance. Under categorical eligibility, if an applicant?s household income has been verified to be at or below 80 percent of the area median income (for ERA1) or if an applicant?s household has been verified as a low-income family as defined in section 3(b) of the United States Housing Act of 1937 (42 U.S.C. 1437a(b)) (for ERA2) in connection with another local, state, or federal government assistance program, grantees are permitted to rely on a determination letter from the government agency that verified the applicant?s household income or status as a low-income family, provided that the determination for such program was made on or after January 1, 2020. The Treasury Department ERA FAQ 8-25-21, question 5, states grantees must obtain, if available, a current lease, signed by the applicant and the landlord or sublessor, that identifies the unit where the applicant resides and establishes the rental payment amount. If a household does not have a signed lease, documentation of residence may include evidence of paying utilities for the residential unit, an attestation by a landlord who can be identified as the verified owner or management agent of the unit, or other reasonable documentation as determined by the grantee. In the absence of a signed lease, evidence of the amount of a rental payment may include bank statements, check stubs, or other documentation that reasonably establishes a pattern of paying rent, a written attestation by a landlord who can be verified as the legitimate owner or management agent of the unit, or other reasonable documentation as defined by the grantee in its policies and procedures. Condition ? During testing over rental and utility beneficiary eligibility for the Emergency Rental Assistance Program, we noted that the District Department of Human Services, Family Services Agency (FSA) (?the Agency?) was unable to provide sufficient documentation to support the beneficiaries? determination for rent paid and utility payments during the fiscal year 2022 audit. Specifically, out of a sample of 60 transactions tested, we noted the following exceptions: ? For one (1) participant, in the participant?s second application, the Agency paid $4,011 in rental assistance for the months from October to December 2021. Per further review of the applicant?s history, in the initial application, the Agency paid rent for eight months (April to November 2021) with rent ranging from $610 to $1,360. The approval of the second application resulted in improper double payment for the months of October and November 2021 totaling $2,674, representing known questioned costs. ? For one (1) participant, the amount the Agency paid for rental assistance did not agree to the documentation provided. The rental agreement of $1,635 did not match the payment of $1,798 per month for three months. The total payment not supported totaled $489, representing known questioned costs. ? For one (1) participant, in the initial application, the Agency paid rent for October 2021 totaling $1,600, which was not supported by the agreement which was $1,327. Per further review of the participant?s history, we noted under a second application, the Agency paid $3,297 in rent for the months of November and December 2021, however, per the rent agreement the rent amount supported was $2,654. For the months of October through December 2021, the amount paid for rental assistance totaled $4,897, however the rent amount supported totaled $3,981. The total amount not supported totaled $916, representing known questioned costs. ? For one (1) participant, the amount the Agency paid for utility did not agree to the documentation provided. The utility payment of $1,622 did not agree to the supported amount of $1,509. The total amount not supported totaled $113, representing known questioned costs. ? For six (6) participants, the Agency did not follow their documented policies and procedures such that the rental calculation worksheets were not provided, or these were not signed by the participants or by the housing support provider. During our tests of completeness for the eligibility population we noted payments that were labeled as duplicate payments and payments sent to the wrong recipients, that have not been refunded. Given that the Agency noted that these payments were sent in error, they should not have been included in the schedule of expenditures of federal awards. The total payments sent in error during 2022 totaled $315,572, representing known questioned costs. The DC Department of Human Services, Family Services Agency, lacks a quality control oversight system to ensure that eligibility documentation is maintained to support eligibility decisions. Questioned Costs ? $319,764. Context ? This is a condition identified per review of the Agency?s compliance with specified requirements using a statistically valid sample. Effect ? Lack of supporting documentation for program services and noncompliance with program requirements could result in disallowances of costs and participants could be receiving benefits that they are not entitled to receive under the program. Cause ? The Agency did not appear to adhere to internal control procedures to ensure that applications are properly completed and retained. Recommendation ? We recommend that the Agency strictly implement internal control procedures to ensure that documentation is maintained to support the beneficiary determinations. Related Noncompliance ? Material noncompliance. Views of Responsible Officials and Planned Corrective Actions ? The Department of Human Services (DHS) agrees with the findings that for four (4) STAY DC participants, the amount paid was not fully supported by lease or utility arrears documentation, resulting in improper payments totaling $4,192. DHS will reach out to the payees to formally request the return of improper payments to the District of Columbia. This will be tracked to ensure the return is recorded against ERA within the District?s financial system. DHS agrees with the finding that six (6) participants were missing rental subsidy calculation worksheets or were missing signatures on their rental calculation worksheet. These participants were enrolled in the Family Rehousing and Stabilization Program (FRSP), also known as Rapid Re-housing (RRH). FRSP is a key program within the District?s continuum of care to support families who are experiencing homelessness or are at imminent risk of experiencing homelessness. The rental calculation worksheet is used to determine the amount an FRSP household contributes towards monthly rent based on household income and makeup. The remaining monthly rent is covered by a subsidy, paid out of ERA funds. Gaps in rental subsidy calculation worksheet documentations were due to rapidly expanding caseloads during the pandemic and new safety protocols that required certain changes to case management protocols. To address any documentation gaps, DHS introduced new Standard Operating Procedures (SOPs) for FRSP in fiscal year 2023. The new SOP implements stricter internal control procedures, conducting regular audits, and streamlining the eligibility determination process. DHS agrees with the finding that $315,572 in STAY DC payments were sent in error during 2022. In Jan. 2023, DHS conducted an in-depth review of the STAY DC program comparing every rental assistance payment made via the District?s financial management system to applications approved for payment by the STAY DC program. This process reviewed $120.1M in fiscal year 2022 STAY DC rental assistance payments and identified $315.6K of payments made in error that were not later refunded to the District. The District will reclass all identified errored payments off of the ERA fund to Local funds by the closeout of fiscal year 2023, Sept. 30, 2023. DHS also completed a reconciliation of data reported to U.S. Treasury for ERA1 closeout reporting and ERA2 2023 Q2 reporting to ensure that no errored payments were included in reported data. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-005 Prior Year Finding Number: 2021-005 Compliance Requirement: Reporting Program: U.S. Department of the Treasury COVID-19 ? Emergency Rental Assistance (ERA) Program ALN: 21.023 Award #: N/A Award Year: 12/27/2020 ? 09/30/2025 Government Department/Agency: Department of Human Services Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR Section 200.328 Financial Reporting: ?Unless otherwise approved by OMB, the Federal awarding agency must solicit only the OMB-approved governmentwide data elements for collection of financial information (at time of publication the Federal Financial Report or such future, OMB-approved, governmentwide data elements available from the OMB-designated standards lead. This information must be collected with the frequency required by the terms and conditions of the Federal award, but no less frequently than annually nor more frequently than quarterly except in unusual circumstances, for example where more frequent reporting is necessary for the effective monitoring of the Federal award or could significantly affect program outcomes, and preferably in coordination with performance reporting. The Federal awarding agency must use OMB-approved common information collections, as applicable, when providing financial and performance reporting information.? The 2022 Compliance Supplement outlines the Special Reports required under the Emergency Rental Assistances program, and the key data elements, and the submission requirements. The Reporting Guidance is located on the Treasury?s website for the ERA program. Monthly Special Reports were required to be submitted on a monthly basis, beginning in April 2021 for ERA1 and June 2021 for ERA2, generally by the 15th of the following month unless otherwise specified within the Reporting Guidance. As outlined in the 2022 Compliance Supplement, the key data elements for the monthly reports included (1) the total number of participant households that received ERA assistance of any kind and (2) the total amount of ERA funds expended by the ERA grantee to or for participating households on behalf of eligible households. The program also requires ERA recipients to certify the reports submitted. As outlined in the 2022 Compliance Supplement, the key data elements for the quarterly reports included (1) the cumulative amount obligated by the grantee; and (2) the cumulative amount expended by the grantee. The program also requires ERA recipients to certify the reports submitted. Condition ? We noted the following for one of nine quarterly and monthly reports tested: ? For one quarterly report (the ERA1 Quarter 1 2022 Report), the key data elements (1) the cumulative amount obligated by the grantee; and (2) the cumulative amount expended by the grantee were not included in the quarterly report. Questioned Costs ? None. Context ? This is a condition identified per review of the Department of Human Services? compliance with specified requirements using a statistically valid sample. Effect ? Without proper internal controls and policies and procedures in place, the required financial and special reports are either not submitted or not submitted with accurate information. Cause ? Per discussion with management, it was noted that at the time the report was submitted they didn?t have access to key data elements to be input into the quarterly report. However, BDO could not verify that this was the case as there was no documentation around the same. Management did not establish controls to make sure that all the required information as noted in the compliance supplement was submitted to the Treasury Department. Recommendation ? We recommend that the Department of Human Services fully implement its current corrective action plan to deploy policies and procedures and controls to ensure reports are submitted with accurate information. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? The Department of Human Services (DHS) concurs with the finding that we could not substantiate that cumulative expenditure and obligation data were included in the ERA1 Quarter 1 2022 Report, which was submitted on April 15, 2022 in the U.S. Department of the Treasury?s COVID-19 Relief Hub reporting portal. DHS believes that updates in the reporting format and fields caused this issue. U.S. Treasury Reporting staff has confirmed that when new fields are added or changed to reports within the reporting portal, these changes override prior submitted reports. In response to a similar finding for the fiscal year 2021 ERA single audit where original submission data was overridden by formatting updates, DHS began saving screen shots of reported data within Treasury?s reporting portal. This practice began in June 2022 and will continue for the duration of the ERA program, through ERA2 closeout reporting. This will ensure that even if Treasury reporting portal functionality changes in the future, there is clear supporting documentation of the information submitted. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-024 Prior Year Finding Number: N/A Compliance Requirement: Data Collection Form and Single Audit Reporting Package Programs: ALN: 10.551, 10.561 Supplemental Nutrition Assistance Program Cluster ALN: 10.553, 10.555, 10.559, 10.582 Child Nutrition Cluster ALN: 10.558 Child and Adult Care Food Program ALN: 14.218 Community Development Block Grants/Entitlement Grants Cluster ALN: 21.023 COVID-19 ? Emergency Rental Assistance Program ALN: 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Relief Funds ALN: 84.027, 84.173 Special Education Cluster ALN: 84.126 Rehabilitation Services - Vocational Rehabilitation Grants to States ALN: 84.425 COVID-19 ? Education Stabilization Fund ALN: 93.268 Immunization Cooperative Agreements ALN: 93.498 COVID-19 ? Provider Relief Fund ALN: 93.558 Temporary Assistance for Needy Families ALN: 93.568 Low Income Home Energy Assistance ALN: 93.569 Community Services Block Grant ALN: 93.658 Foster Care ? Title IV-E ALN: 93.775, 93.777, 93.778 Medicaid Cluster ALN: 93.914 HIV Emergency Relief Project Grants ALN: 97.036 Public Assistance - Presidentially Declared Disaster Criteria - The Uniform Guidance in 2 CFR Section 200.512, Report Submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor?s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Condition ? The District did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended September 30, 2022. Questioned Costs ? None. Context ? This is a condition identified per review of the District?s compliance with the specified requirements. Effect ? The District could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Cause ? The District did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe. Recommendation ? We recommend that the District closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? The District concurs with the auditor?s findings and recommendations. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-006 Prior Year Finding Number: N/A Compliance Requirement: Reporting Program: U.S. Department of the Treasury COVID-19 ? Coronavirus State and Local Fiscal Recovery Funds ALN: 21.027 Award #: N/A Award Year: 10/01/2021 ? 09/20/2022 Government Department/Agency: Office of the Chief Financial Officer (OCFO) Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. The Uniform Guidance in 2 CFR Section 2 CFR Section 200.302(a), Financial Management, states that each state must expend and account for the federal award in accordance with state laws and procedures for expending and accounting for the state?s own funds. In addition, the state?s and the other non-federal entity?s financial management systems, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award. Condition ? Certain grant expenditures related to the PAY-AS-You-Go (PAYGO Capital) program, amounting to approximately $36.4 million, had erroneously been reflected as expenditures under assistance listing number 21.027, COVID-19 - Coronavirus State and Local Fiscal Recovery Funds. Subsequently, OCFO adjusted the SEFA to reflect the actual amount of expenditures incurred for the program. Questioned Costs ? None. Context ? This is a condition identified per review of the OCFO?s compliance with the specified requirements. Effect ? OCFO is not in compliance with the stated provisions. Failure to properly review and support expenditures can result in noncompliance with laws and regulations along with loss of funding. Cause ? OCFO did not appear to have adequate policies and procedures in place to ensure accuracy of the SEFA. Recommendation ? We recommend that OCFO adhere to instituted policies and procedures to ensure the accuracy of the SEFA. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? OCFO concurs with the finding. In the compilation and reconciliation of the SEFA, the PAYGO ARPA Local Revenue Replacement expenditures component was inadvertently included in the draft District fiscal year 2022 SEFA presented to the external auditors. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-024 Prior Year Finding Number: N/A Compliance Requirement: Data Collection Form and Single Audit Reporting Package Programs: ALN: 10.551, 10.561 Supplemental Nutrition Assistance Program Cluster ALN: 10.553, 10.555, 10.559, 10.582 Child Nutrition Cluster ALN: 10.558 Child and Adult Care Food Program ALN: 14.218 Community Development Block Grants/Entitlement Grants Cluster ALN: 21.023 COVID-19 ? Emergency Rental Assistance Program ALN: 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Relief Funds ALN: 84.027, 84.173 Special Education Cluster ALN: 84.126 Rehabilitation Services - Vocational Rehabilitation Grants to States ALN: 84.425 COVID-19 ? Education Stabilization Fund ALN: 93.268 Immunization Cooperative Agreements ALN: 93.498 COVID-19 ? Provider Relief Fund ALN: 93.558 Temporary Assistance for Needy Families ALN: 93.568 Low Income Home Energy Assistance ALN: 93.569 Community Services Block Grant ALN: 93.658 Foster Care ? Title IV-E ALN: 93.775, 93.777, 93.778 Medicaid Cluster ALN: 93.914 HIV Emergency Relief Project Grants ALN: 97.036 Public Assistance - Presidentially Declared Disaster Criteria - The Uniform Guidance in 2 CFR Section 200.512, Report Submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor?s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Condition ? The District did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended September 30, 2022. Questioned Costs ? None. Context ? This is a condition identified per review of the District?s compliance with the specified requirements. Effect ? The District could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Cause ? The District did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe. Recommendation ? We recommend that the District closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? The District concurs with the auditor?s findings and recommendations. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-024 Prior Year Finding Number: N/A Compliance Requirement: Data Collection Form and Single Audit Reporting Package Programs: ALN: 10.551, 10.561 Supplemental Nutrition Assistance Program Cluster ALN: 10.553, 10.555, 10.559, 10.582 Child Nutrition Cluster ALN: 10.558 Child and Adult Care Food Program ALN: 14.218 Community Development Block Grants/Entitlement Grants Cluster ALN: 21.023 COVID-19 ? Emergency Rental Assistance Program ALN: 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Relief Funds ALN: 84.027, 84.173 Special Education Cluster ALN: 84.126 Rehabilitation Services - Vocational Rehabilitation Grants to States ALN: 84.425 COVID-19 ? Education Stabilization Fund ALN: 93.268 Immunization Cooperative Agreements ALN: 93.498 COVID-19 ? Provider Relief Fund ALN: 93.558 Temporary Assistance for Needy Families ALN: 93.568 Low Income Home Energy Assistance ALN: 93.569 Community Services Block Grant ALN: 93.658 Foster Care ? Title IV-E ALN: 93.775, 93.777, 93.778 Medicaid Cluster ALN: 93.914 HIV Emergency Relief Project Grants ALN: 97.036 Public Assistance - Presidentially Declared Disaster Criteria - The Uniform Guidance in 2 CFR Section 200.512, Report Submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor?s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Condition ? The District did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended September 30, 2022. Questioned Costs ? None. Context ? This is a condition identified per review of the District?s compliance with the specified requirements. Effect ? The District could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Cause ? The District did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe. Recommendation ? We recommend that the District closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? The District concurs with the auditor?s findings and recommendations. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-024 Prior Year Finding Number: N/A Compliance Requirement: Data Collection Form and Single Audit Reporting Package Programs: ALN: 10.551, 10.561 Supplemental Nutrition Assistance Program Cluster ALN: 10.553, 10.555, 10.559, 10.582 Child Nutrition Cluster ALN: 10.558 Child and Adult Care Food Program ALN: 14.218 Community Development Block Grants/Entitlement Grants Cluster ALN: 21.023 COVID-19 ? Emergency Rental Assistance Program ALN: 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Relief Funds ALN: 84.027, 84.173 Special Education Cluster ALN: 84.126 Rehabilitation Services - Vocational Rehabilitation Grants to States ALN: 84.425 COVID-19 ? Education Stabilization Fund ALN: 93.268 Immunization Cooperative Agreements ALN: 93.498 COVID-19 ? Provider Relief Fund ALN: 93.558 Temporary Assistance for Needy Families ALN: 93.568 Low Income Home Energy Assistance ALN: 93.569 Community Services Block Grant ALN: 93.658 Foster Care ? Title IV-E ALN: 93.775, 93.777, 93.778 Medicaid Cluster ALN: 93.914 HIV Emergency Relief Project Grants ALN: 97.036 Public Assistance - Presidentially Declared Disaster Criteria - The Uniform Guidance in 2 CFR Section 200.512, Report Submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor?s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Condition ? The District did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended September 30, 2022. Questioned Costs ? None. Context ? This is a condition identified per review of the District?s compliance with the specified requirements. Effect ? The District could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Cause ? The District did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe. Recommendation ? We recommend that the District closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? The District concurs with the auditor?s findings and recommendations. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-024 Prior Year Finding Number: N/A Compliance Requirement: Data Collection Form and Single Audit Reporting Package Programs: ALN: 10.551, 10.561 Supplemental Nutrition Assistance Program Cluster ALN: 10.553, 10.555, 10.559, 10.582 Child Nutrition Cluster ALN: 10.558 Child and Adult Care Food Program ALN: 14.218 Community Development Block Grants/Entitlement Grants Cluster ALN: 21.023 COVID-19 ? Emergency Rental Assistance Program ALN: 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Relief Funds ALN: 84.027, 84.173 Special Education Cluster ALN: 84.126 Rehabilitation Services - Vocational Rehabilitation Grants to States ALN: 84.425 COVID-19 ? Education Stabilization Fund ALN: 93.268 Immunization Cooperative Agreements ALN: 93.498 COVID-19 ? Provider Relief Fund ALN: 93.558 Temporary Assistance for Needy Families ALN: 93.568 Low Income Home Energy Assistance ALN: 93.569 Community Services Block Grant ALN: 93.658 Foster Care ? Title IV-E ALN: 93.775, 93.777, 93.778 Medicaid Cluster ALN: 93.914 HIV Emergency Relief Project Grants ALN: 97.036 Public Assistance - Presidentially Declared Disaster Criteria - The Uniform Guidance in 2 CFR Section 200.512, Report Submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor?s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Condition ? The District did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended September 30, 2022. Questioned Costs ? None. Context ? This is a condition identified per review of the District?s compliance with the specified requirements. Effect ? The District could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Cause ? The District did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe. Recommendation ? We recommend that the District closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? The District concurs with the auditor?s findings and recommendations. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-024 Prior Year Finding Number: N/A Compliance Requirement: Data Collection Form and Single Audit Reporting Package Programs: ALN: 10.551, 10.561 Supplemental Nutrition Assistance Program Cluster ALN: 10.553, 10.555, 10.559, 10.582 Child Nutrition Cluster ALN: 10.558 Child and Adult Care Food Program ALN: 14.218 Community Development Block Grants/Entitlement Grants Cluster ALN: 21.023 COVID-19 ? Emergency Rental Assistance Program ALN: 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Relief Funds ALN: 84.027, 84.173 Special Education Cluster ALN: 84.126 Rehabilitation Services - Vocational Rehabilitation Grants to States ALN: 84.425 COVID-19 ? Education Stabilization Fund ALN: 93.268 Immunization Cooperative Agreements ALN: 93.498 COVID-19 ? Provider Relief Fund ALN: 93.558 Temporary Assistance for Needy Families ALN: 93.568 Low Income Home Energy Assistance ALN: 93.569 Community Services Block Grant ALN: 93.658 Foster Care ? Title IV-E ALN: 93.775, 93.777, 93.778 Medicaid Cluster ALN: 93.914 HIV Emergency Relief Project Grants ALN: 97.036 Public Assistance - Presidentially Declared Disaster Criteria - The Uniform Guidance in 2 CFR Section 200.512, Report Submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor?s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Condition ? The District did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended September 30, 2022. Questioned Costs ? None. Context ? This is a condition identified per review of the District?s compliance with the specified requirements. Effect ? The District could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Cause ? The District did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe. Recommendation ? We recommend that the District closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? The District concurs with the auditor?s findings and recommendations. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-024 Prior Year Finding Number: N/A Compliance Requirement: Data Collection Form and Single Audit Reporting Package Programs: ALN: 10.551, 10.561 Supplemental Nutrition Assistance Program Cluster ALN: 10.553, 10.555, 10.559, 10.582 Child Nutrition Cluster ALN: 10.558 Child and Adult Care Food Program ALN: 14.218 Community Development Block Grants/Entitlement Grants Cluster ALN: 21.023 COVID-19 ? Emergency Rental Assistance Program ALN: 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Relief Funds ALN: 84.027, 84.173 Special Education Cluster ALN: 84.126 Rehabilitation Services - Vocational Rehabilitation Grants to States ALN: 84.425 COVID-19 ? Education Stabilization Fund ALN: 93.268 Immunization Cooperative Agreements ALN: 93.498 COVID-19 ? Provider Relief Fund ALN: 93.558 Temporary Assistance for Needy Families ALN: 93.568 Low Income Home Energy Assistance ALN: 93.569 Community Services Block Grant ALN: 93.658 Foster Care ? Title IV-E ALN: 93.775, 93.777, 93.778 Medicaid Cluster ALN: 93.914 HIV Emergency Relief Project Grants ALN: 97.036 Public Assistance - Presidentially Declared Disaster Criteria - The Uniform Guidance in 2 CFR Section 200.512, Report Submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor?s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Condition ? The District did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended September 30, 2022. Questioned Costs ? None. Context ? This is a condition identified per review of the District?s compliance with the specified requirements. Effect ? The District could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Cause ? The District did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe. Recommendation ? We recommend that the District closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? The District concurs with the auditor?s findings and recommendations. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-007 Prior Year Finding Number: 2021-008 Compliance Requirement: Equipment and Real Property Management Program: U.S. Department of Education COVID-19 ? Education Stabilization Fund Elementary and Secondary School Emergency Relief (ESSER) Fund ALN: 84.425D Award #: S425D210034 Award Year: 01/05/2021 ? 09/30/2022 COVID-19 ? Education Stabilization Fund American Rescue Plan - Elementary and Secondary Schools Emergency Relief Fund (ARP-ESSER) ALN: 84.425U Award #: S425U210034-21A Award Year: 03/24/2021 ? 09/30/2023 Government Department/Agency: District of Columbia Public Schools Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Additionally, per the Uniform Guidance in 2 CFR Section 200.313, Equipment, property records must be maintained that include a description of the property, a 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, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property. Further, a physical inventory of the property must be taken and the results reconciled with the property records at least once every two years (2 CFR section 200.313(d)(2)). Condition ? We noted that DCPS has a policy to track and maintain a list of equipment purchased using federal funds with a single unit cost of $200 or more; and to conduct periodic equipment inventory count twice a year. Of the 56 out of 60 samples tested for equipment real property management requirements, we noted that: (1) Equipment purchased using federal funds with a single unit cost of $200 or more is tracked in the TIPWeb-IT system; however, there is no linkage between assets tracked in TIPWeb-IT and the funding source or Purchase Order. As a result, we were not able to verify that the equipment purchased using federal funds was being tracked in the TIPWeb-IT system. (2) There is no separate listing of equipment purchased using federal funds being maintained. (3) No physical inventory count was performed for equipment purchased using federal funds in 2022. Questioned Costs ? Not determinable. Context ? This is a condition identified per review of District of Columbia Public School (DCPS)?s compliance with the specified requirements using a statistically valid sample. Effect ? There is a risk that inadequate recordkeeping of equipment could lead to misappropriation of assets and noncompliance with Federal regulations resulting in a return of Federal awards received. Cause ? Due to a lack of linkage between procurement systems and asset management systems and COVID related concerns, DCPS was unable to adequately support compliance with its policies and procedures regarding monitoring of equipment acquired with Federal funds. Recommendation ? We recommend that DCPS implement policies, procedures and controls that will ensure that equipment purchased using federal funds are tracked and maintained, in order to adhere to Federal regulations related to equipment and its related maintenance. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? The District of Columbia Public School (DCPS) agrees with the conditions and recommendations of this finding. While DCPS has implemented and follows stringent asset procurement and management policies, we have adopted separate systems to track the purchasing, receiving, and the lifecycle of assets. The Procurement and ERP systems, PASS/SOAR are used to track purchases of assets, while the Warehouse receiving system captures a record of assets received by DCPS. The DCPS?s Asset Management System, TIPWeb tracks a device throughout its lifecycle (deployment/assignment, condition, location, disposal, etc.). This split system functionality contributes to the conditions noted in the audit findings. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-024 Prior Year Finding Number: N/A Compliance Requirement: Data Collection Form and Single Audit Reporting Package Programs: ALN: 10.551, 10.561 Supplemental Nutrition Assistance Program Cluster ALN: 10.553, 10.555, 10.559, 10.582 Child Nutrition Cluster ALN: 10.558 Child and Adult Care Food Program ALN: 14.218 Community Development Block Grants/Entitlement Grants Cluster ALN: 21.023 COVID-19 ? Emergency Rental Assistance Program ALN: 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Relief Funds ALN: 84.027, 84.173 Special Education Cluster ALN: 84.126 Rehabilitation Services - Vocational Rehabilitation Grants to States ALN: 84.425 COVID-19 ? Education Stabilization Fund ALN: 93.268 Immunization Cooperative Agreements ALN: 93.498 COVID-19 ? Provider Relief Fund ALN: 93.558 Temporary Assistance for Needy Families ALN: 93.568 Low Income Home Energy Assistance ALN: 93.569 Community Services Block Grant ALN: 93.658 Foster Care ? Title IV-E ALN: 93.775, 93.777, 93.778 Medicaid Cluster ALN: 93.914 HIV Emergency Relief Project Grants ALN: 97.036 Public Assistance - Presidentially Declared Disaster Criteria - The Uniform Guidance in 2 CFR Section 200.512, Report Submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor?s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Condition ? The District did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended September 30, 2022. Questioned Costs ? None. Context ? This is a condition identified per review of the District?s compliance with the specified requirements. Effect ? The District could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Cause ? The District did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe. Recommendation ? We recommend that the District closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? The District concurs with the auditor?s findings and recommendations. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-008 Prior Year Finding Number: 2021-010 Compliance Requirement: Reporting Program: U.S. Department of Education COVID-19 ? Education Stabilization Fund Higher Education Emergency Relief Fund (HEERF) Student Aid Portion ALN #: 84.425E Award #: P425E201913 - 20B Award Year: 04/24/2020 ? 06/30/2023 COVID-19 ? Education Stabilization Fund HEERF Institutional Aid Portion ALN: 84.425F Award #: P425F202580 - 20B Award Year: 05/07/2020 ? 06/30/2023 COVID-19 ? Education Stabilization Fund HEERF Historically Black Colleges and Universities (HBCUs) ALN: 84.425J Award #: P425J200098 - 20C Award Year: 05/01/2020 ? 06/30/2023 Government Department/Agency: University of the District of Columbia Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. There are three components to reporting for HEERF: 1) public reporting on the (a)(1) Student Aid Portion; 2) public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Reporting Form), as applicable; and 3) the annual report. The CARES Act 18004(e) and the Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA) 314(e) requires an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such time in such a manner as the secretary may require. While ARP does not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, Education Department exercises this reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329. Condition ? During our testing of the quarterly public reporting requirements for HEERF Student Aid Portion and HEERF Institutional Portion, we noted the following: ? For three (3) out of six (6) reports, University of the District of Columbia (UDC) was not able to provide evidence of the timely posting of the quarterly public reports to the UDC website because the webmaster?s web posting audit log, which expires after 60 days, had not been retained by UDC. ? For three (3) out of six (6) reports, UDC was not able to provide evidence that the quarterly public reports were reviewed prior to posting to the UDC website because the evidence had not been retained by UDC. UDC implemented its corrective action plan on June 30, 2022, and the exceptions identified above relate to reporting transactions made prior to the above-mentioned implementation date. We also examined one report made post the above-mentioned implementation date and we noted that UDC had kept all evidence of review of the report and the evidence of the report being published in the UDC website. Questioned Costs ? None. Context ? This is a condition identified per review of UDC?s compliance with specified reporting requirements related to the program using a statistically valid sample. Effect ? Without adequate controls in place to ensure that reports are posted timely and proof that the reports were reviewed leads to noncompliance of the reporting requirements under the program. Cause ? UDC does not have adequate controls in place to ensure that documents are maintained related to the review and the timely posting of reports to the UDC website. Recommendation ? We recommend for UDC to continue to maintain documentation of the timely submission of reports and proof of review of reports as required to ensure compliance with reporting requirements. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? UDC OCFO agrees with the conditions and recommendations of this finding. As noted in the condition above, UDC implemented corrective action to remediate the conditions and recommendations reported in the prior year when findings were issued. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-024 Prior Year Finding Number: N/A Compliance Requirement: Data Collection Form and Single Audit Reporting Package Programs: ALN: 10.551, 10.561 Supplemental Nutrition Assistance Program Cluster ALN: 10.553, 10.555, 10.559, 10.582 Child Nutrition Cluster ALN: 10.558 Child and Adult Care Food Program ALN: 14.218 Community Development Block Grants/Entitlement Grants Cluster ALN: 21.023 COVID-19 ? Emergency Rental Assistance Program ALN: 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Relief Funds ALN: 84.027, 84.173 Special Education Cluster ALN: 84.126 Rehabilitation Services - Vocational Rehabilitation Grants to States ALN: 84.425 COVID-19 ? Education Stabilization Fund ALN: 93.268 Immunization Cooperative Agreements ALN: 93.498 COVID-19 ? Provider Relief Fund ALN: 93.558 Temporary Assistance for Needy Families ALN: 93.568 Low Income Home Energy Assistance ALN: 93.569 Community Services Block Grant ALN: 93.658 Foster Care ? Title IV-E ALN: 93.775, 93.777, 93.778 Medicaid Cluster ALN: 93.914 HIV Emergency Relief Project Grants ALN: 97.036 Public Assistance - Presidentially Declared Disaster Criteria - The Uniform Guidance in 2 CFR Section 200.512, Report Submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor?s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Condition ? The District did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended September 30, 2022. Questioned Costs ? None. Context ? This is a condition identified per review of the District?s compliance with the specified requirements. Effect ? The District could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Cause ? The District did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe. Recommendation ? We recommend that the District closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? The District concurs with the auditor?s findings and recommendations. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-008 Prior Year Finding Number: 2021-010 Compliance Requirement: Reporting Program: U.S. Department of Education COVID-19 ? Education Stabilization Fund Higher Education Emergency Relief Fund (HEERF) Student Aid Portion ALN #: 84.425E Award #: P425E201913 - 20B Award Year: 04/24/2020 ? 06/30/2023 COVID-19 ? Education Stabilization Fund HEERF Institutional Aid Portion ALN: 84.425F Award #: P425F202580 - 20B Award Year: 05/07/2020 ? 06/30/2023 COVID-19 ? Education Stabilization Fund HEERF Historically Black Colleges and Universities (HBCUs) ALN: 84.425J Award #: P425J200098 - 20C Award Year: 05/01/2020 ? 06/30/2023 Government Department/Agency: University of the District of Columbia Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. There are three components to reporting for HEERF: 1) public reporting on the (a)(1) Student Aid Portion; 2) public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Reporting Form), as applicable; and 3) the annual report. The CARES Act 18004(e) and the Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA) 314(e) requires an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such time in such a manner as the secretary may require. While ARP does not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, Education Department exercises this reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329. Condition ? During our testing of the quarterly public reporting requirements for HEERF Student Aid Portion and HEERF Institutional Portion, we noted the following: ? For three (3) out of six (6) reports, University of the District of Columbia (UDC) was not able to provide evidence of the timely posting of the quarterly public reports to the UDC website because the webmaster?s web posting audit log, which expires after 60 days, had not been retained by UDC. ? For three (3) out of six (6) reports, UDC was not able to provide evidence that the quarterly public reports were reviewed prior to posting to the UDC website because the evidence had not been retained by UDC. UDC implemented its corrective action plan on June 30, 2022, and the exceptions identified above relate to reporting transactions made prior to the above-mentioned implementation date. We also examined one report made post the above-mentioned implementation date and we noted that UDC had kept all evidence of review of the report and the evidence of the report being published in the UDC website. Questioned Costs ? None. Context ? This is a condition identified per review of UDC?s compliance with specified reporting requirements related to the program using a statistically valid sample. Effect ? Without adequate controls in place to ensure that reports are posted timely and proof that the reports were reviewed leads to noncompliance of the reporting requirements under the program. Cause ? UDC does not have adequate controls in place to ensure that documents are maintained related to the review and the timely posting of reports to the UDC website. Recommendation ? We recommend for UDC to continue to maintain documentation of the timely submission of reports and proof of review of reports as required to ensure compliance with reporting requirements. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? UDC OCFO agrees with the conditions and recommendations of this finding. As noted in the condition above, UDC implemented corrective action to remediate the conditions and recommendations reported in the prior year when findings were issued. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-024 Prior Year Finding Number: N/A Compliance Requirement: Data Collection Form and Single Audit Reporting Package Programs: ALN: 10.551, 10.561 Supplemental Nutrition Assistance Program Cluster ALN: 10.553, 10.555, 10.559, 10.582 Child Nutrition Cluster ALN: 10.558 Child and Adult Care Food Program ALN: 14.218 Community Development Block Grants/Entitlement Grants Cluster ALN: 21.023 COVID-19 ? Emergency Rental Assistance Program ALN: 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Relief Funds ALN: 84.027, 84.173 Special Education Cluster ALN: 84.126 Rehabilitation Services - Vocational Rehabilitation Grants to States ALN: 84.425 COVID-19 ? Education Stabilization Fund ALN: 93.268 Immunization Cooperative Agreements ALN: 93.498 COVID-19 ? Provider Relief Fund ALN: 93.558 Temporary Assistance for Needy Families ALN: 93.568 Low Income Home Energy Assistance ALN: 93.569 Community Services Block Grant ALN: 93.658 Foster Care ? Title IV-E ALN: 93.775, 93.777, 93.778 Medicaid Cluster ALN: 93.914 HIV Emergency Relief Project Grants ALN: 97.036 Public Assistance - Presidentially Declared Disaster Criteria - The Uniform Guidance in 2 CFR Section 200.512, Report Submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor?s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Condition ? The District did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended September 30, 2022. Questioned Costs ? None. Context ? This is a condition identified per review of the District?s compliance with the specified requirements. Effect ? The District could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Cause ? The District did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe. Recommendation ? We recommend that the District closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? The District concurs with the auditor?s findings and recommendations. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-008 Prior Year Finding Number: 2021-010 Compliance Requirement: Reporting Program: U.S. Department of Education COVID-19 ? Education Stabilization Fund Higher Education Emergency Relief Fund (HEERF) Student Aid Portion ALN #: 84.425E Award #: P425E201913 - 20B Award Year: 04/24/2020 ? 06/30/2023 COVID-19 ? Education Stabilization Fund HEERF Institutional Aid Portion ALN: 84.425F Award #: P425F202580 - 20B Award Year: 05/07/2020 ? 06/30/2023 COVID-19 ? Education Stabilization Fund HEERF Historically Black Colleges and Universities (HBCUs) ALN: 84.425J Award #: P425J200098 - 20C Award Year: 05/01/2020 ? 06/30/2023 Government Department/Agency: University of the District of Columbia Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. There are three components to reporting for HEERF: 1) public reporting on the (a)(1) Student Aid Portion; 2) public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Reporting Form), as applicable; and 3) the annual report. The CARES Act 18004(e) and the Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA) 314(e) requires an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such time in such a manner as the secretary may require. While ARP does not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, Education Department exercises this reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329. Condition ? During our testing of the quarterly public reporting requirements for HEERF Student Aid Portion and HEERF Institutional Portion, we noted the following: ? For three (3) out of six (6) reports, University of the District of Columbia (UDC) was not able to provide evidence of the timely posting of the quarterly public reports to the UDC website because the webmaster?s web posting audit log, which expires after 60 days, had not been retained by UDC. ? For three (3) out of six (6) reports, UDC was not able to provide evidence that the quarterly public reports were reviewed prior to posting to the UDC website because the evidence had not been retained by UDC. UDC implemented its corrective action plan on June 30, 2022, and the exceptions identified above relate to reporting transactions made prior to the above-mentioned implementation date. We also examined one report made post the above-mentioned implementation date and we noted that UDC had kept all evidence of review of the report and the evidence of the report being published in the UDC website. Questioned Costs ? None. Context ? This is a condition identified per review of UDC?s compliance with specified reporting requirements related to the program using a statistically valid sample. Effect ? Without adequate controls in place to ensure that reports are posted timely and proof that the reports were reviewed leads to noncompliance of the reporting requirements under the program. Cause ? UDC does not have adequate controls in place to ensure that documents are maintained related to the review and the timely posting of reports to the UDC website. Recommendation ? We recommend for UDC to continue to maintain documentation of the timely submission of reports and proof of review of reports as required to ensure compliance with reporting requirements. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? UDC OCFO agrees with the conditions and recommendations of this finding. As noted in the condition above, UDC implemented corrective action to remediate the conditions and recommendations reported in the prior year when findings were issued. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-024 Prior Year Finding Number: N/A Compliance Requirement: Data Collection Form and Single Audit Reporting Package Programs: ALN: 10.551, 10.561 Supplemental Nutrition Assistance Program Cluster ALN: 10.553, 10.555, 10.559, 10.582 Child Nutrition Cluster ALN: 10.558 Child and Adult Care Food Program ALN: 14.218 Community Development Block Grants/Entitlement Grants Cluster ALN: 21.023 COVID-19 ? Emergency Rental Assistance Program ALN: 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Relief Funds ALN: 84.027, 84.173 Special Education Cluster ALN: 84.126 Rehabilitation Services - Vocational Rehabilitation Grants to States ALN: 84.425 COVID-19 ? Education Stabilization Fund ALN: 93.268 Immunization Cooperative Agreements ALN: 93.498 COVID-19 ? Provider Relief Fund ALN: 93.558 Temporary Assistance for Needy Families ALN: 93.568 Low Income Home Energy Assistance ALN: 93.569 Community Services Block Grant ALN: 93.658 Foster Care ? Title IV-E ALN: 93.775, 93.777, 93.778 Medicaid Cluster ALN: 93.914 HIV Emergency Relief Project Grants ALN: 97.036 Public Assistance - Presidentially Declared Disaster Criteria - The Uniform Guidance in 2 CFR Section 200.512, Report Submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor?s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Condition ? The District did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended September 30, 2022. Questioned Costs ? None. Context ? This is a condition identified per review of the District?s compliance with the specified requirements. Effect ? The District could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Cause ? The District did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe. Recommendation ? We recommend that the District closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? The District concurs with the auditor?s findings and recommendations. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-024 Prior Year Finding Number: N/A Compliance Requirement: Data Collection Form and Single Audit Reporting Package Programs: ALN: 10.551, 10.561 Supplemental Nutrition Assistance Program Cluster ALN: 10.553, 10.555, 10.559, 10.582 Child Nutrition Cluster ALN: 10.558 Child and Adult Care Food Program ALN: 14.218 Community Development Block Grants/Entitlement Grants Cluster ALN: 21.023 COVID-19 ? Emergency Rental Assistance Program ALN: 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Relief Funds ALN: 84.027, 84.173 Special Education Cluster ALN: 84.126 Rehabilitation Services - Vocational Rehabilitation Grants to States ALN: 84.425 COVID-19 ? Education Stabilization Fund ALN: 93.268 Immunization Cooperative Agreements ALN: 93.498 COVID-19 ? Provider Relief Fund ALN: 93.558 Temporary Assistance for Needy Families ALN: 93.568 Low Income Home Energy Assistance ALN: 93.569 Community Services Block Grant ALN: 93.658 Foster Care ? Title IV-E ALN: 93.775, 93.777, 93.778 Medicaid Cluster ALN: 93.914 HIV Emergency Relief Project Grants ALN: 97.036 Public Assistance - Presidentially Declared Disaster Criteria - The Uniform Guidance in 2 CFR Section 200.512, Report Submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor?s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Condition ? The District did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended September 30, 2022. Questioned Costs ? None. Context ? This is a condition identified per review of the District?s compliance with the specified requirements. Effect ? The District could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Cause ? The District did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe. Recommendation ? We recommend that the District closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? The District concurs with the auditor?s findings and recommendations. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-007 Prior Year Finding Number: 2021-008 Compliance Requirement: Equipment and Real Property Management Program: U.S. Department of Education COVID-19 ? Education Stabilization Fund Elementary and Secondary School Emergency Relief (ESSER) Fund ALN: 84.425D Award #: S425D210034 Award Year: 01/05/2021 ? 09/30/2022 COVID-19 ? Education Stabilization Fund American Rescue Plan - Elementary and Secondary Schools Emergency Relief Fund (ARP-ESSER) ALN: 84.425U Award #: S425U210034-21A Award Year: 03/24/2021 ? 09/30/2023 Government Department/Agency: District of Columbia Public Schools Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Additionally, per the Uniform Guidance in 2 CFR Section 200.313, Equipment, property records must be maintained that include a description of the property, a 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, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property. Further, a physical inventory of the property must be taken and the results reconciled with the property records at least once every two years (2 CFR section 200.313(d)(2)). Condition ? We noted that DCPS has a policy to track and maintain a list of equipment purchased using federal funds with a single unit cost of $200 or more; and to conduct periodic equipment inventory count twice a year. Of the 56 out of 60 samples tested for equipment real property management requirements, we noted that: (1) Equipment purchased using federal funds with a single unit cost of $200 or more is tracked in the TIPWeb-IT system; however, there is no linkage between assets tracked in TIPWeb-IT and the funding source or Purchase Order. As a result, we were not able to verify that the equipment purchased using federal funds was being tracked in the TIPWeb-IT system. (2) There is no separate listing of equipment purchased using federal funds being maintained. (3) No physical inventory count was performed for equipment purchased using federal funds in 2022. Questioned Costs ? Not determinable. Context ? This is a condition identified per review of District of Columbia Public School (DCPS)?s compliance with the specified requirements using a statistically valid sample. Effect ? There is a risk that inadequate recordkeeping of equipment could lead to misappropriation of assets and noncompliance with Federal regulations resulting in a return of Federal awards received. Cause ? Due to a lack of linkage between procurement systems and asset management systems and COVID related concerns, DCPS was unable to adequately support compliance with its policies and procedures regarding monitoring of equipment acquired with Federal funds. Recommendation ? We recommend that DCPS implement policies, procedures and controls that will ensure that equipment purchased using federal funds are tracked and maintained, in order to adhere to Federal regulations related to equipment and its related maintenance. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? The District of Columbia Public School (DCPS) agrees with the conditions and recommendations of this finding. While DCPS has implemented and follows stringent asset procurement and management policies, we have adopted separate systems to track the purchasing, receiving, and the lifecycle of assets. The Procurement and ERP systems, PASS/SOAR are used to track purchases of assets, while the Warehouse receiving system captures a record of assets received by DCPS. The DCPS?s Asset Management System, TIPWeb tracks a device throughout its lifecycle (deployment/assignment, condition, location, disposal, etc.). This split system functionality contributes to the conditions noted in the audit findings. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-024 Prior Year Finding Number: N/A Compliance Requirement: Data Collection Form and Single Audit Reporting Package Programs: ALN: 10.551, 10.561 Supplemental Nutrition Assistance Program Cluster ALN: 10.553, 10.555, 10.559, 10.582 Child Nutrition Cluster ALN: 10.558 Child and Adult Care Food Program ALN: 14.218 Community Development Block Grants/Entitlement Grants Cluster ALN: 21.023 COVID-19 ? Emergency Rental Assistance Program ALN: 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Relief Funds ALN: 84.027, 84.173 Special Education Cluster ALN: 84.126 Rehabilitation Services - Vocational Rehabilitation Grants to States ALN: 84.425 COVID-19 ? Education Stabilization Fund ALN: 93.268 Immunization Cooperative Agreements ALN: 93.498 COVID-19 ? Provider Relief Fund ALN: 93.558 Temporary Assistance for Needy Families ALN: 93.568 Low Income Home Energy Assistance ALN: 93.569 Community Services Block Grant ALN: 93.658 Foster Care ? Title IV-E ALN: 93.775, 93.777, 93.778 Medicaid Cluster ALN: 93.914 HIV Emergency Relief Project Grants ALN: 97.036 Public Assistance - Presidentially Declared Disaster Criteria - The Uniform Guidance in 2 CFR Section 200.512, Report Submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor?s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Condition ? The District did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended September 30, 2022. Questioned Costs ? None. Context ? This is a condition identified per review of the District?s compliance with the specified requirements. Effect ? The District could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Cause ? The District did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe. Recommendation ? We recommend that the District closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? The District concurs with the auditor?s findings and recommendations. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-024 Prior Year Finding Number: N/A Compliance Requirement: Data Collection Form and Single Audit Reporting Package Programs: ALN: 10.551, 10.561 Supplemental Nutrition Assistance Program Cluster ALN: 10.553, 10.555, 10.559, 10.582 Child Nutrition Cluster ALN: 10.558 Child and Adult Care Food Program ALN: 14.218 Community Development Block Grants/Entitlement Grants Cluster ALN: 21.023 COVID-19 ? Emergency Rental Assistance Program ALN: 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Relief Funds ALN: 84.027, 84.173 Special Education Cluster ALN: 84.126 Rehabilitation Services - Vocational Rehabilitation Grants to States ALN: 84.425 COVID-19 ? Education Stabilization Fund ALN: 93.268 Immunization Cooperative Agreements ALN: 93.498 COVID-19 ? Provider Relief Fund ALN: 93.558 Temporary Assistance for Needy Families ALN: 93.568 Low Income Home Energy Assistance ALN: 93.569 Community Services Block Grant ALN: 93.658 Foster Care ? Title IV-E ALN: 93.775, 93.777, 93.778 Medicaid Cluster ALN: 93.914 HIV Emergency Relief Project Grants ALN: 97.036 Public Assistance - Presidentially Declared Disaster Criteria - The Uniform Guidance in 2 CFR Section 200.512, Report Submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor?s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Condition ? The District did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended September 30, 2022. Questioned Costs ? None. Context ? This is a condition identified per review of the District?s compliance with the specified requirements. Effect ? The District could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Cause ? The District did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe. Recommendation ? We recommend that the District closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? The District concurs with the auditor?s findings and recommendations. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-024 Prior Year Finding Number: N/A Compliance Requirement: Data Collection Form and Single Audit Reporting Package Programs: ALN: 10.551, 10.561 Supplemental Nutrition Assistance Program Cluster ALN: 10.553, 10.555, 10.559, 10.582 Child Nutrition Cluster ALN: 10.558 Child and Adult Care Food Program ALN: 14.218 Community Development Block Grants/Entitlement Grants Cluster ALN: 21.023 COVID-19 ? Emergency Rental Assistance Program ALN: 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Relief Funds ALN: 84.027, 84.173 Special Education Cluster ALN: 84.126 Rehabilitation Services - Vocational Rehabilitation Grants to States ALN: 84.425 COVID-19 ? Education Stabilization Fund ALN: 93.268 Immunization Cooperative Agreements ALN: 93.498 COVID-19 ? Provider Relief Fund ALN: 93.558 Temporary Assistance for Needy Families ALN: 93.568 Low Income Home Energy Assistance ALN: 93.569 Community Services Block Grant ALN: 93.658 Foster Care ? Title IV-E ALN: 93.775, 93.777, 93.778 Medicaid Cluster ALN: 93.914 HIV Emergency Relief Project Grants ALN: 97.036 Public Assistance - Presidentially Declared Disaster Criteria - The Uniform Guidance in 2 CFR Section 200.512, Report Submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor?s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Condition ? The District did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended September 30, 2022. Questioned Costs ? None. Context ? This is a condition identified per review of the District?s compliance with the specified requirements. Effect ? The District could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Cause ? The District did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe. Recommendation ? We recommend that the District closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? The District concurs with the auditor?s findings and recommendations. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-009 Prior Year Finding Number: 2021-011 Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs/Cost Principles Program: U.S. Department of Health and Human Services Immunization Cooperative Agreements ALN: 93.268 Award #: 1 NH23IP922596-02-02 to NH23IP922596-02-11 Award Year: 08/01/2019 ? 06/30/2024 Government Department/Agency: Department of Health (DC Health) Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR Section 200.430 Compensation ? Personal Services: ?Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the establish written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities; (2) Follows an appointment made in accordance with a non-Federal entity?s laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, Standards for Documentation of Personnel Expenses, when applicable.? 2 CFR Section 200.430(i): ?Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity?s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; (vi) [Reserved] (vii) Support the distribution of the employee?s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards.? Condition ? We noted that the District Department of Health (DC Health) continued to allocate payroll expenditures to the Immunization Cooperative Agreements (ICA) program during fiscal year 2022 based on budgeted percentages. These percentages were entered into the PeopleSoft Human Resources/Payroll System (PeopleSoft) at the beginning of the fiscal year and were based on management?s estimate of the respective employee?s level of effort for each program. PeopleSoft calculated the payroll costs every payroll cycle for each employee and program based on the predetermined percentage, and reported it through the Labor Distribution Report (485 Report). However, management did not perform a periodic comparison of actual costs to the budgeted costs and make any necessary adjustment as required by 2 CFR Section 200.430. Specifically, 11 out of 60 sampled payroll items tested for the ICA grant were recorded based on estimated hours and not actual hours. Questioned Costs ? Not determinable. Context ? This is a condition identified per review of DC Health?s compliance with specified requirements using a statistically valid sample. Payroll costs including fringe benefits, for the ICA program in fiscal year 2022 were $2,646,210. Effect ? DC Health was unable to demonstrate that the payroll expenditures charged to the ICA grant accurately reflected the time incurred on the program and were properly supported in accordance with 2 CFR Part 200.430 time and effort reporting requirements. Cause ? DC Health did not have policies and procedures in place to review and reconcile the estimated amounts of payroll expenditures charged to the ICA program to the actual expenditures incurred. Per corrective action plans and status updates submitted by DC Health to BDO in fiscal year 2022, significant milestones have been achieved however due to several change management tasks, the corrective action plan is still progressing into fiscal year 2023 and is expected to fully implement by September 30, 2023. Recommendation ? We recommend that DC Health fully implement its current corrective action plan to deploy policies and procedures to periodically compare employees? estimated hours per the 485 Report to the actual hours incurred, and make any necessary adjustments as required by 2 CFR 200.430. Related Noncompliance ? Material noncompliance. Views of Responsible Officials and Planned Corrective Actions ? The District Department of Health (DC Health) concurs with the finding, causes and recommendations cited in the fiscal year 2022 single audit for the Immunization Cooperative Agreements (ICA) program. The current corrective action plan (CAP), originating from the prior year's finding had been actively implemented in fiscal year 2022 and reached significant milestones. DC Health asserts that while a process was implemented to obtain a regular schedule of payroll and budget- to-actual data for personnel, and supervisors were provided a tool and process for delivering ?time and effort certifications?, there were still some errors and omissions. DC Health concurs with the auditor on the need to continue implementation of the current CAP, but DC Health will modify processes and tools to ensure that there is the required periodic comparison of actual costs to the budgeted costs of personnel per the requirements of 2 CFR 200.430. Contributing factors were delays in distributing and receiving the required certifications, provision of technical assistance and training, and managing manual errors. Additionally, there were missing certifications due to a large turnover of staff, including many supervisors assigned to complete time and effort certification forms. In fiscal year 2022, reporting templates and reporting repositories were being revised and further developed and continued in fiscal year 2023. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-024 Prior Year Finding Number: N/A Compliance Requirement: Data Collection Form and Single Audit Reporting Package Programs: ALN: 10.551, 10.561 Supplemental Nutrition Assistance Program Cluster ALN: 10.553, 10.555, 10.559, 10.582 Child Nutrition Cluster ALN: 10.558 Child and Adult Care Food Program ALN: 14.218 Community Development Block Grants/Entitlement Grants Cluster ALN: 21.023 COVID-19 ? Emergency Rental Assistance Program ALN: 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Relief Funds ALN: 84.027, 84.173 Special Education Cluster ALN: 84.126 Rehabilitation Services - Vocational Rehabilitation Grants to States ALN: 84.425 COVID-19 ? Education Stabilization Fund ALN: 93.268 Immunization Cooperative Agreements ALN: 93.498 COVID-19 ? Provider Relief Fund ALN: 93.558 Temporary Assistance for Needy Families ALN: 93.568 Low Income Home Energy Assistance ALN: 93.569 Community Services Block Grant ALN: 93.658 Foster Care ? Title IV-E ALN: 93.775, 93.777, 93.778 Medicaid Cluster ALN: 93.914 HIV Emergency Relief Project Grants ALN: 97.036 Public Assistance - Presidentially Declared Disaster Criteria - The Uniform Guidance in 2 CFR Section 200.512, Report Submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor?s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Condition ? The District did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended September 30, 2022. Questioned Costs ? None. Context ? This is a condition identified per review of the District?s compliance with the specified requirements. Effect ? The District could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Cause ? The District did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe. Recommendation ? We recommend that the District closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? The District concurs with the auditor?s findings and recommendations. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-009 Prior Year Finding Number: 2021-011 Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs/Cost Principles Program: U.S. Department of Health and Human Services Immunization Cooperative Agreements ALN: 93.268 Award #: 1 NH23IP922596-02-02 to NH23IP922596-02-11 Award Year: 08/01/2019 ? 06/30/2024 Government Department/Agency: Department of Health (DC Health) Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR Section 200.430 Compensation ? Personal Services: ?Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the establish written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities; (2) Follows an appointment made in accordance with a non-Federal entity?s laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, Standards for Documentation of Personnel Expenses, when applicable.? 2 CFR Section 200.430(i): ?Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity?s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; (vi) [Reserved] (vii) Support the distribution of the employee?s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards.? Condition ? We noted that the District Department of Health (DC Health) continued to allocate payroll expenditures to the Immunization Cooperative Agreements (ICA) program during fiscal year 2022 based on budgeted percentages. These percentages were entered into the PeopleSoft Human Resources/Payroll System (PeopleSoft) at the beginning of the fiscal year and were based on management?s estimate of the respective employee?s level of effort for each program. PeopleSoft calculated the payroll costs every payroll cycle for each employee and program based on the predetermined percentage, and reported it through the Labor Distribution Report (485 Report). However, management did not perform a periodic comparison of actual costs to the budgeted costs and make any necessary adjustment as required by 2 CFR Section 200.430. Specifically, 11 out of 60 sampled payroll items tested for the ICA grant were recorded based on estimated hours and not actual hours. Questioned Costs ? Not determinable. Context ? This is a condition identified per review of DC Health?s compliance with specified requirements using a statistically valid sample. Payroll costs including fringe benefits, for the ICA program in fiscal year 2022 were $2,646,210. Effect ? DC Health was unable to demonstrate that the payroll expenditures charged to the ICA grant accurately reflected the time incurred on the program and were properly supported in accordance with 2 CFR Part 200.430 time and effort reporting requirements. Cause ? DC Health did not have policies and procedures in place to review and reconcile the estimated amounts of payroll expenditures charged to the ICA program to the actual expenditures incurred. Per corrective action plans and status updates submitted by DC Health to BDO in fiscal year 2022, significant milestones have been achieved however due to several change management tasks, the corrective action plan is still progressing into fiscal year 2023 and is expected to fully implement by September 30, 2023. Recommendation ? We recommend that DC Health fully implement its current corrective action plan to deploy policies and procedures to periodically compare employees? estimated hours per the 485 Report to the actual hours incurred, and make any necessary adjustments as required by 2 CFR 200.430. Related Noncompliance ? Material noncompliance. Views of Responsible Officials and Planned Corrective Actions ? The District Department of Health (DC Health) concurs with the finding, causes and recommendations cited in the fiscal year 2022 single audit for the Immunization Cooperative Agreements (ICA) program. The current corrective action plan (CAP), originating from the prior year's finding had been actively implemented in fiscal year 2022 and reached significant milestones. DC Health asserts that while a process was implemented to obtain a regular schedule of payroll and budget- to-actual data for personnel, and supervisors were provided a tool and process for delivering ?time and effort certifications?, there were still some errors and omissions. DC Health concurs with the auditor on the need to continue implementation of the current CAP, but DC Health will modify processes and tools to ensure that there is the required periodic comparison of actual costs to the budgeted costs of personnel per the requirements of 2 CFR 200.430. Contributing factors were delays in distributing and receiving the required certifications, provision of technical assistance and training, and managing manual errors. Additionally, there were missing certifications due to a large turnover of staff, including many supervisors assigned to complete time and effort certification forms. In fiscal year 2022, reporting templates and reporting repositories were being revised and further developed and continued in fiscal year 2023. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-024 Prior Year Finding Number: N/A Compliance Requirement: Data Collection Form and Single Audit Reporting Package Programs: ALN: 10.551, 10.561 Supplemental Nutrition Assistance Program Cluster ALN: 10.553, 10.555, 10.559, 10.582 Child Nutrition Cluster ALN: 10.558 Child and Adult Care Food Program ALN: 14.218 Community Development Block Grants/Entitlement Grants Cluster ALN: 21.023 COVID-19 ? Emergency Rental Assistance Program ALN: 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Relief Funds ALN: 84.027, 84.173 Special Education Cluster ALN: 84.126 Rehabilitation Services - Vocational Rehabilitation Grants to States ALN: 84.425 COVID-19 ? Education Stabilization Fund ALN: 93.268 Immunization Cooperative Agreements ALN: 93.498 COVID-19 ? Provider Relief Fund ALN: 93.558 Temporary Assistance for Needy Families ALN: 93.568 Low Income Home Energy Assistance ALN: 93.569 Community Services Block Grant ALN: 93.658 Foster Care ? Title IV-E ALN: 93.775, 93.777, 93.778 Medicaid Cluster ALN: 93.914 HIV Emergency Relief Project Grants ALN: 97.036 Public Assistance - Presidentially Declared Disaster Criteria - The Uniform Guidance in 2 CFR Section 200.512, Report Submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor?s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Condition ? The District did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended September 30, 2022. Questioned Costs ? None. Context ? This is a condition identified per review of the District?s compliance with the specified requirements. Effect ? The District could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Cause ? The District did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe. Recommendation ? We recommend that the District closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? The District concurs with the auditor?s findings and recommendations. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-024 Prior Year Finding Number: N/A Compliance Requirement: Data Collection Form and Single Audit Reporting Package Programs: ALN: 10.551, 10.561 Supplemental Nutrition Assistance Program Cluster ALN: 10.553, 10.555, 10.559, 10.582 Child Nutrition Cluster ALN: 10.558 Child and Adult Care Food Program ALN: 14.218 Community Development Block Grants/Entitlement Grants Cluster ALN: 21.023 COVID-19 ? Emergency Rental Assistance Program ALN: 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Relief Funds ALN: 84.027, 84.173 Special Education Cluster ALN: 84.126 Rehabilitation Services - Vocational Rehabilitation Grants to States ALN: 84.425 COVID-19 ? Education Stabilization Fund ALN: 93.268 Immunization Cooperative Agreements ALN: 93.498 COVID-19 ? Provider Relief Fund ALN: 93.558 Temporary Assistance for Needy Families ALN: 93.568 Low Income Home Energy Assistance ALN: 93.569 Community Services Block Grant ALN: 93.658 Foster Care ? Title IV-E ALN: 93.775, 93.777, 93.778 Medicaid Cluster ALN: 93.914 HIV Emergency Relief Project Grants ALN: 97.036 Public Assistance - Presidentially Declared Disaster Criteria - The Uniform Guidance in 2 CFR Section 200.512, Report Submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor?s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Condition ? The District did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended September 30, 2022. Questioned Costs ? None. Context ? This is a condition identified per review of the District?s compliance with the specified requirements. Effect ? The District could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Cause ? The District did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe. Recommendation ? We recommend that the District closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? The District concurs with the auditor?s findings and recommendations. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-010 Prior Year Finding Number: N/A Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs/Cost Principles Program: U.S. Department of Health and Human Services Temporary Assistance for Needy Families (TANF) ALN: 93.558 Award #: Various Award Year: 10/01/2021 ? 09/30/2022 Government Department/Agency: Department of Human Services (DHS)/Economic Security Administration (ESA) Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR Section 200.430 Compensation ? Personal Services: ?Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the establish written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities; (2) Follows an appointment made in accordance with a non-Federal entity?s laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, Standards for Documentation of Personnel Expenses, when applicable.? 2 CFR Section 200.430(i): ?Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity?s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; (vi) [Reserved] (vii) Support the distribution of the employee?s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards.? Per District Personnel Issuance No. 2019-07 (Approval Required - page 10) ? ?Overtime work must be officially ordered and approved in advance. Agency heads and their designees are authorized to order and approve overtime work provided the agency has sufficient funding available. Overtime should be approved using DCSF No. 11B-12, Request for Authorization of Overtime Work. However, when responding to an immediate operational need, pre-approval may be memorialized in any written form, such as e-mail, and followed-up with the official overtime approval. Completed overtime forms and any supporting documentation should be submitted to the employee?s timekeeper for processing.? Condition ? We noted that for three (3) out of a sample of 25 employees tested, although the employee's timesheet was approved by the supervisor, DHS/ESA was unable to provide documentation that the overtime hours worked by the employee during the selected payperiods were preapproved. Questioned Costs ? Not determinable. Context ? This is a condition identified per review of DHS/ESA?s compliance with specified requirements using a statistically valid sample. Payroll costs including fringe benefits, for the TANF program in fiscal year 2022 were $15,092,248. Effect ? DHS/ESA was unable to demonstrate that overtime charged to the federal program was approved in advanced in accordance with the internal policies and procedures of the agency. Cause ? DHS/ESA did not follow its own internal controls and policies and procedures to ensure that authorization forms evidencing the preapproval of overtime are obtained and maintained. Recommendation ? We recommend that DHS/ESA follow its own policies, procedures and controls to ensure that pre-authorization of overtime are obtained and maintained. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? DHS concurs with the finding. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-011 Prior Year Finding Number: 2021-014 Compliance Requirement: Eligibility Program: U.S. Department of Health and Human Services Temporary Assistance for Needy Families (TANF) ALN: 93.558 Award #: Various Award Year: 10/01/2021 ? 09/30/2022 Government Department/Agency: Department of Human Services (DHS)/Economic Security Administration (ESA) Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. For TANF, per 45 CFR Section 205.60 (a), ?The State agency will maintain or supervise the maintenance of records necessary for the proper and efficient operation of the plan, including records regarding applications, determination of eligibility, the provision of financial assistance, and the use of any information obtained under Section 205.55, with respect to individual applications denied, recipients whose benefits have been terminated, recipients whose benefits have been modified, and the dollar value of these denials, terminations and modifications. Under this requirement, the agency will keep individual records which contain pertinent facts about each applicant and recipient. The records will include information concerning the date of application and the date and basis of its disposition; facts essential to the determination of initial and continuing eligibility (including the individual's social security number, need for, and provision of financial assistance); and the basis for discontinuing assistance.? For the Pandemic Emergency Assistance Fund (PEAF), per TANF-ACF-IM-2022-01 (Guidance for Use of the Pandemic Emergency Assistance Fund Appropriated in the American Rescue Plan (ARP) Act of 2021 (Pub. L. 117-2); Accompaniment to ACF-IOAS-DCL-22-01) ?For the purposes of the Pandemic Emergency Assistance Fund, Non-Recurrent, Short Term (NRST) benefits mean cash payments or other benefits that meet the regulatory definition (45 CFR 260.31(b)(1)), but are limited to those that fall into the specific expenditure reporting category mentioned in the legislation (line 15 of the ACF-196R (PDF), the state financial reporting form for the TANF program). In other words, for this fund, NRST benefits, like all NRSTs under TANF, must: ? be designed to deal with a specific crisis situation or episode of need; ? not be intended to meet on-going needs; and ? not extend beyond four months. And (as explained in the instructions for reporting on line 15 of the ACF-196R) NRSTs paid for with PEAF funds: ? must only include expenditures such as emergency assistance and diversion payments, emergency housing and short-term homelessness assistance, emergency food aid, short-term utilities payments, burial assistance, clothing allowances, and back-to-school payments; and ? may not include tax credits, childcare, transportation, or short-term education and training. In addition, ?The recipients of PEAF-funded NRSTs must be needy families with children but they do not necessarily have to be eligible for TANF cash assistance. A grantee has the flexibility to determine what needy means for each NRST and may wish to set a higher standard than it does for TANF cash assistance, such as aligning with SNAP or Medicaid income eligibility criteria.? Condition ? During our testing over beneficiary eligibility compliance requirements of the Temporary Assistance for Needy Families (TANF) program, we selected a sample of 60 beneficiaries in fiscal year 2022 to test DHS? compliance with TANF eligibility requirements. We noted the following: ? For one (1) out of 60, we noted that the application/recertification submitted on April 19, 2022, as identified in DCAS, could not be located in DIMS. We were therefore unable to test the following: o There was a completed and signed application that agreed to the information in DCAS: household composition, income, proof of residency, and Social Security Numbers for all individuals included on the application. o The family included a minor child who lives with a parent or other adult caretaker relative, or pregnant woman. o The family met state?s income requirements to be considered eligible as financially ?needy?. Only the financially ?needy? are eligible for services, benefits, or ?assistance?. Financially ?needy? for TANF and MOE purposes means financial deprivation, i.e., lacking adequate income and resources. For example, a needy family or a needy parent is one who is financially eligible according to the State's quantified financial eligibility criteria. o Assistance was not provided to an individual who was under age 18, was unmarried, had a minor child at least 12 weeks old, and had not successfully completed high school or its equivalent unless the individual either participates in education activities directed toward attainment of a high school diploma or its equivalent, or participates in an alternative education or training program approved by the District. o Assistance was not provided to an unmarried individual under 18 caring for a child, if the minor parent and child are not residing with a parent, legal guardian, or other adult relative, unless one of the statutory exceptions applies (42 USC 608(a)(5)). o Assistance was not provided for a minor child who had been or was expected to be absent from the home for a period of 45 consecutive days or, at the option of the State, such period of not less than 30 and not more than 180 consecutive days unless the State grants a good cause exception, as provided in its State Plan. o Assistance was not provided for an individual who was a parent (or other caretaker relative) of a minor child who fails to notify the State agency of the absence of the minor child from the home, as in paragraph e. immediately above, within five days of the date that it becomes clear to that individual that the child will be absent for the specified period of time (42 USC 608(a)(10)(C)). o That cash assistance was not provided to an individual during the 10-year period that began on the date the individual was convicted in Federal or State court of having made a fraudulent statement or representation with respect to place of residence in order to simultaneously receive assistance from two or more States under TANF, Title XIX, or the Food Stamp Act of 1977, or benefits in two or more States under the Supplemental Security Income program under Title XVI of the Social Security Act. o Assistance was not provided to any individual who was fleeing to avoid prosecution, or custody or confinement after conviction, for a felony or attempt to commit a felony, or who is violating a condition of probation or parole imposed under Federal or State law. o An individual convicted under Federal or State law of any offense which is classified as a felony and which involves the possession, use, or distribution of a controlled substance (as defined the Controlled Substances Act (21 USC 802(6)) is ineligible for assistance if the conviction was based on conduct occurring after August 22, 1996. A State shall require each individual applying for TANF assistance to state in writing whether the individual or any member of their household has been convicted of such a felony involving a controlled substance. However, a State may by law enacted after August 22, 1996, exempt any or all individuals from this prohibition or limit the time period that this prohibition applies to any or all individuals 21 USC 862a). o Qualified aliens, as defined at 8 USC 1641b (unless exempt) entering the United States on or after August 22, 1996, who were not eligible for Federal public benefits, as defined in 8 USC 1611(c), for a period of five years beginning on the date of the alien?s entry into the United States, unless they met an exception at 8 USC 1612(b)(2) or 1613 did not receive benefits. o Verified that for any TANF recipient that received subsidized child care, the District ensured that a completed application was submitted by the applicant prior to receiving the child care subsidy. ? For ten (10) out of 60, DHS was unable to provide support that would allow us to test that cash assistance was not provided to an individual during the 10-year period that began on the date the individual was convicted in Federal or State court of having made a fraudulent statement or representation with respect to place of residence in order to simultaneously receive assistance from two or more States under TANF, Title XIX, or the Food Stamp Act of 1977, or benefits in two or more States under the Supplemental Security Income program under Title XVI of the Social Security Act. In addition, for two (2) of these samples, DHS was unable to provide support that would allow us to test that assistance was not provided to any individual who was fleeing to avoid prosecution, or custody or confinement after conviction, for a felony or attempt to commit a felony, or who is violating a condition of probation or parole imposed under Federal or State law. ? For one (1) out of 60, we noted that the application consisted of a household comprised of 1 adult and 2 children but the amount paid was only $452 (not $665). Further review shows that it is an only child case (as one child did not meet school attendance requirement); however, the household was paid $452 instead of $418. DHS/ESA was unable to determine why the amount reported did not agree with the maximum amount for one individual. The questioned costs for the above issues amounted to $44,067, which represent 14.7% of the total eligibility amounts tested related to the 60 sampled items of $299,727. In addition, during our testing over beneficiary eligibility compliance requirements of the PEAF program for TANF, we selected a sample of 60 beneficiaries in fiscal year 2022 to test DHS? compliance with PEAF eligibility requirements (50 of the TANF Eligibility sample customers that received PEAF and 10 additional sample customers that received PEAF). We noted the following for the 50 samples already tested for TANF: ? For one (1) out of 50, we noted that DHS/ESA was unable to locate the correct TANF application. We were therefore unable to test the following: o A completed and signed application existed and agreed the information in DCAS for: household composition, income, proof of residency, and Social Security Numbers for all individuals included on the application, and o Whether the family met state's income requirements to be considered eligible as financially "needy". Only the financially ?needy? are eligible for services, benefits, or ?assistance?. Financially ?needy? for TANF and MOE purposes means financial deprivation, i.e., lacking adequate income and resources. For example, a needy family or a needy parent is one who is financially eligible according to the State?s quantified financial eligibility criteria. We noted the following for the additional 10 samples tested for PEAF: ? For one (1) out of 10, we noted that per review of DCAS the client tested was identified as ineligible for TANF for 11/1/2020 to 11/1/2022 as household had no eligible members; however, we noted that the PEAF payment of $1,038 was made to the customer during fiscal year 2022. DHS ESA was unable to support how eligibility was determined. The questioned costs for the above issues for PEAF amounted to $2,076, which represent 3.33% of the total eligibility amounts tested related to the 60 sampled items of $62,288. Questioned Costs ? Known amount is $46,143. Context ? This is a condition identified per review of DHS? compliance with specified requirements using a statistically valid sample. Effect ? Without properly maintaining documentation to support eligibility determinations, ineligible beneficiaries may receive benefits under the TANF grant and DHS may make payments on behalf of those beneficiaries resulting in noncompliance with the eligibility requirements. Cause ? DHS did not consistently adhere to its established policies and procedures requiring it to maintain documentation supporting participant eligibility. Recommendation - We recommend that DHS strengthen its existing policies and procedures over the review and maintenance of appropriate documentation to ensure compliance with eligibility requirements. Related Noncompliance ? Material noncompliance. Views of Responsible Officials and Planned Corrective Actions ? DHS/ESA concur with the findings. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-012 Prior Year Finding Number: 2021-017 Compliance Requirement: Reporting; Special Tests and Provisions ? Penalty for Failure to Comply With Work Verification Plan Program: U.S. Department of Health and Human Services Temporary Assistance for Needy Families (TANF) ALN: 93.558 Award #: Various Award Year: 10/01/2021 ? 09/30/2022 Government Department/Agency: Department of Human Services (DHS)/ Economic Security Administration (ESA) Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 45 CFR Section 261.60 (a), ?A State must report the actual hours that an individual participates in an activity, subject to the qualifications in paragraphs (b) and (c) of this section and Section 261.61(c). It is not sufficient to report the hours an individual is scheduled to participate in an activity. (b) For the purposes of calculating the work participation rates for a month, actual hours may include the hours for which an individual was paid, including paid holidays and sick leave. For participation in unpaid work activities, it may include excused absences for hours missed due to a maximum of 10 holidays in the preceding 12-month period and up to 80 hours of additional excused absences in the preceding 12-month period, no more than 16 of which may occur in a month, for each work-eligible individual. Each State must designate the days that it wishes to count as holidays for those in unpaid activities in its Work Verification Plan. It may designate no more than 10 such days. In order to count an excused absence as actual hours of participation, the individual must have been scheduled to participate in a countable work activity for the period of the absence that the State reports as participation. A State must describe its excused absence policies and definitions as part of its Work Verification Plan, specified at Section 261.62. (c) For unsubsidized employment, subsidized employment, and OJT, a State may report projected actual hours of employment participation for up to six months based on current, documented actual hours of work. Any time a State receives information that the client's actual hours of work have changed, or no later than the end of any six-month period, the State must re-verify the client's current actual average hours of work, and may report these projected actual hours of participation for another six-month period. (d) A State may not count more hours toward the participation rate for a self-employed individual than the number derived by dividing the individual's self-employment income (gross income less business expenses) by the Federal minimum wage. A State may propose an alternative method of determining self-employment hours as part of its Work Verification Plan. (e) A State may count supervised homework time and up to one hour of unsupervised homework time for each hour of class time. Total homework time counted for participation cannot exceed the hours required or advised by a particular educational program.? Per 45 CFR Section 261.61 (a), ?A State must support each individual?s hours of participation with documentation in the case file. In accordance with Section 261.62, a State must describe in its Work Verification Plan the documentation it uses to verify hours of participation in each activity.? According to the DC State Verification Plan, the D.C. Department of Human Services (DHS), Department of Human Services Monitoring Unit reviews and audits all documentation submitted by vendors reflecting the activities of recipients in TANF Employment program. This documentation includes time sheets, activity logs, school records, pay stubs, and verification of employment, work experience and on-the-job training. The Monitoring Unit completes this audit process to determine if sufficient documentation exists to substantiate reported time and attendance data, to warrant a payment to TANF Employment program vendors, and submission of countable hours for federal reporting purposes. The District projects hours of participation in unsubsidized, self-employment for six months or until the recipient's next scheduled recertification, whichever is sooner. Per 45 CFR Section 265.7 (a)-(c), ?Each State?s quarterly reports (the TANF Data Report, the TANF Financial Report (or Territorial Financial Report), and the SSP-MOE Data Report) must be complete and accurate and filed by the due date.? For disaggregated data report, `a complete and accurate report? means that: (1) The reported data accurately reflect information available to the State in case records, financial records, and automated data systems, and include correction of the quarterly data by the end of the fiscal year reporting period; (2) The data are free from computational errors and are internally consistent (e.g., items that should add to totals do so); (3) The State reports data for all required elements (i.e., no data are missing); (4)(i) The State provides data on all families; or (ii) if the State opts to use sampling, the State reports data on all families selected in a sample that meets the specification and procedures in the TANF Sampling Manual (except for families listed in error); and (5) Where estimates are necessary (e.g., some types of assistance may require cost estimates), the State uses reasonable methods to develop these estimates. For an aggregated data report, ?a complete and accurate report? means that: (1) The reported data accurately reflect information available to the State in case records, financial records, and automated data systems; (2) The data are free from computational errors and are internally consistent (e.g., items that should add to totals do so); (3) The State reports data on all applicable elements; and (4) Monthly totals are unduplicated counts for all families (e.g., the number of families and the number of out-of-wedlock births are unduplicated counts).? 45 CFR Section 265.7 (f) states that ?States must maintain records to adequately support any report, in accordance with Section 75.361 through 75.370 of this title.? Condition ? During our test work over a sample of 60 participants for Special Tests and Provisions - Penalty for Failure to Comply with Work Verification Plan and Reporting, we noted: ? For eight (8) instances, we noted that although the hours reported met or exceeded the required work participation hours, and the customer met the requirement, DHS/ESA was unable to provide documentation to support the hours reported. Therefore, we were unable to confirm that approved hours were properly supported. ? For two (2) instances, we noted that although the hours reported met or exceeded the required work participation hours, the customer did not meet the requirement, and the hours reported did not agree with the recalculated hours. ? For eleven (11) instances, we noted that although the hours reported met or exceeded the required work participation hours, the hours reported did not agree with the projected hours for unsubsidized employment for the customer. ? For one (1) instance, we noted that although the participant had no recorded participation hours in CATCH and a medical letter of patient admission dated two months prior to the month selected stating the customer?s inability to work, DHS/ESA was unable to provide documentation to support the hours reported on the ACF-199 report. ? For one (1) instance, we noted that the participant had no recorded participation hours in CATCH and had a child under one making her exempt from the work requirement. We noted we noted that although the hours reported met or exceeded the required work participation hours. The information tested in our sample represents the underlying data used in Reporting for the 1st and 3rd quarters of fiscal year 2022. Consequently, DHS incorrectly reported data in the ACF-199 report for the 1st and 3rd quarters of fiscal year 2022. Questioned Costs ? Not determinable. Context ? This is a condition identified per review of DHS? compliance with specified requirements using a statistically valid sample. Effect ? Data within the ACF-199 report may not be complete and accurate. Specifically, if the work participation data is not substantiated, or inconsistencies are noted, it may result in inaccurate data being reported and may lead to an incorrect ACF-199 report and could result in an incorrect allocation of Federal Funds to the state. Cause ? Controls are not operating effectively over the documentation of work participation data to ensure that adequate evidence of the work participation is maintained. Recommendation - We recommend that DHS enforce existing policies and procedures and implement additional controls to ensure that adequate documentation is maintained to substantiate the work participation data reported in the ACF-199 report in accordance with the District of Columbia Work Verification Plan. We also recommend that DHS implement policies, procedures and controls that will enable an accurate reconciliation between the data sources used in the preparation of the ACF-199 report to ensure proper reporting of data elements. Related Noncompliance ? Material noncompliance. Views of Responsible Officials and Planned Corrective Actions ? DHS agrees with the findings and will work with the DCAS and the Division of Innovation and Change Management (DICM) teams to mitigate the causes of the findings. These findings are mostly residual issues with the tables in DHS/ESA DCAS system. ? For the eight (8) cases, where DHS/ESA was unable to provide documentation to support the hours reported, customer participation hours were not updated/closed when employment ended so there were no supporting documents in DIMS. Customer did not have participation hours in CATCH however shown in DCAS. ? For the two (2) instances, where the hours reported did not agree with the recalculated hours, this is intentional, as it ?preserves? caped federal hours. DHS is updating the work verification plan to document this. ? For the eleven (11) cases where the hours reported did not agree with the projected hours for unsubsidized employment for the customer. These were DCAS hours that were not updated timely in the employment record. Customer participation hours were not updated/closed when employment ended so there were no supporting documents in DIMS. ? For the one (1) instance, where DHS/ESA was unable to provide documentation to support the hours reported on the ACF-199 report. This was also a DCAS issue because the income evidence was not end dated once the employment evidence was end dated. ? For the one (1) instance where a customer had a child under one making her exempt from the work requirement. However, the hours reported met or exceeded the required work participation hours. Customer had participation hours in ACF when employed. Customer was exempt due to pregnancy for the report month/year however the employment hours were not end dated in the ACF. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-013 Prior Year Finding Number: 2021-016 Compliance Requirement: Special Tests and Provisions ? Income Eligibility and Verification System Program: U.S. Department of Health and Human Services Temporary Assistance for Needy Families (TANF) ALN: 93.558 Award #: Various Award Year: 10/01/2021 ? 09/30/2022 Government Department/Agency: Department of Human Services (DHS)/ Economic Security Administration (ESA) Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 45 CFR Section 205.56(a)(1)(i), ?The State agency shall review and compare the information obtained from each data exchange against information contained in the case record to determine whether it affects the applicant?s or the recipient?s eligibility or the amount of assistance.? Per 45 CFR Section 205.60 (a), ?The State agency will maintain or supervise the maintenance of records necessary for the proper and efficient operation of the plan, including records regarding applications, determination of eligibility, the provision of financial assistance, and the use of any information obtained under Section 205.55, with respect to individual applications denied, recipients whose benefits have been terminated, recipients whose benefits have been modified, and the dollar value of these denials, terminations and modifications. Under this requirement, the agency will keep individual records which contain pertinent facts about each applicant and recipient. The records will include information concerning the date of application and the date and basis of its disposition; facts essential to the determination of initial and continuing eligibility (including the individual's social security number, need for, and provision of financial assistance); and the basis for discontinuing assistance.? For the Pandemic Emergency Assistance Fund (PEAF), per TANF-ACF-IM-2022-01 (Guidance for Use of the Pandemic Emergency Assistance Fund Appropriated in the American Rescue Plan (ARP) Act of 2021 (Pub. L. 117-2); Accompaniment to ACF-IOAS-DCL-22-01) ?We remind grantees that the Income Eligibility Verification System (IEVS) does apply to the PEAF, as it is funded under Title IV-A; however, tribes are not subject to the IEVS requirements.? Condition ? During our test work of 60 cases selected to test the Special Tests and Provisions ? Income Eligibility and Verification Systems (IEVS) for TANF, we noted that DHS was unable to provide sufficient documentation to support all eligibility determinations tested during the fiscal year 2022 audit. Specifically, out of the 60 beneficiary disbursements tested, we noted the following exceptions: ? For three (3) out of 60, DHS was unable to provide evidence of use of IEVS to determine eligibility. ? For one (1) out of 60, DHS did not provide evidence that Social Security monthly disability payment of $758, was considered when determining eligibility and the related eligibility payments. Furthermore, DCAS sent request to the Social Security Administration and received a termination payment status code, however no reduction in benefit amount was made. In addition, during our test work of 60 cases selected to test the Special Tests and Provisions ? Income Eligibility and Verification Systems (IEVS) for PEAF, we noted that DHS was unable to provide sufficient documentation to support all eligibility determinations tested during the fiscal year 2022 audit. Specifically, out of the 60 beneficiary disbursements tested, we noted the following exception: ? For three (3) out of 60, DHS did not provide evidence of use of IEVS to determine eligibility. Questioned Costs ? Not determinable. Context ? This is a condition identified per review of DHS? compliance with specified requirements using a statistically valid sample. Effect ? The District is not in full compliance with its policies and with Federal program compliance requirements surrounding records maintenance. Further, ineligible TANF beneficiaries may receive benefits under the TANF grant and the District may make payments on behalf of those beneficiaries. Cause ? Controls are not adequate to ensure that the District adheres to its established policies and procedures requiring it to maintain documentation supporting participant eligibility. Recommendation - We recommend that DHS enforce existing policies and procedures and implement additional policies and procedures for maintaining and monitoring case record documentation to ensure that Income Eligibility and Verification System requirements are complied with. Related Noncompliance ? Material noncompliance. Views of Responsible Officials and Planned Corrective Actions ? DHS agrees with the finding in this report. DHS in collaboration with DHCF DCAS project teams is taking efforts to address the issues identified. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-024 Prior Year Finding Number: N/A Compliance Requirement: Data Collection Form and Single Audit Reporting Package Programs: ALN: 10.551, 10.561 Supplemental Nutrition Assistance Program Cluster ALN: 10.553, 10.555, 10.559, 10.582 Child Nutrition Cluster ALN: 10.558 Child and Adult Care Food Program ALN: 14.218 Community Development Block Grants/Entitlement Grants Cluster ALN: 21.023 COVID-19 ? Emergency Rental Assistance Program ALN: 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Relief Funds ALN: 84.027, 84.173 Special Education Cluster ALN: 84.126 Rehabilitation Services - Vocational Rehabilitation Grants to States ALN: 84.425 COVID-19 ? Education Stabilization Fund ALN: 93.268 Immunization Cooperative Agreements ALN: 93.498 COVID-19 ? Provider Relief Fund ALN: 93.558 Temporary Assistance for Needy Families ALN: 93.568 Low Income Home Energy Assistance ALN: 93.569 Community Services Block Grant ALN: 93.658 Foster Care ? Title IV-E ALN: 93.775, 93.777, 93.778 Medicaid Cluster ALN: 93.914 HIV Emergency Relief Project Grants ALN: 97.036 Public Assistance - Presidentially Declared Disaster Criteria - The Uniform Guidance in 2 CFR Section 200.512, Report Submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor?s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Condition ? The District did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended September 30, 2022. Questioned Costs ? None. Context ? This is a condition identified per review of the District?s compliance with the specified requirements. Effect ? The District could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Cause ? The District did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe. Recommendation ? We recommend that the District closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? The District concurs with the auditor?s findings and recommendations. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-014 Prior Year Finding Number: N/A Compliance Requirement: Eligibility Program: U.S. Department of Health and Human Services Low Income Home Energy Assistance ALN: 93.568 Award #: Various Award Year: 10/01/2021 ? 09/30/2022 Government Department/Agency: Department of Energy and Environment (DOEE) Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. The OMB Compliance Supplement states that ?Grantees may provide assistance to (a) households in which one or more individuals are receiving Temporary Assistance for Needy Families (TANF), Supplemental Security Income (SSI), Supplemental Nutrition Assistance Program (SNAP) benefits, or certain needs-tested veterans? benefits; or (b) households with incomes which do not exceed the greater of 150 percent of the state?s established poverty level, or 60 percent of the state median income. Grantees may establish lower income eligibility criteria, but no household may be excluded solely on the basis of income if the household income is less than 110 percent of the state?s poverty level (42 USC 8624(b)(2)). Grantees must give priority to those households with the highest home energy costs or needs in relation to income and household size (42 USC 8624(b)(5)).? Per 42 U.S. Code Section 8624(b)(2): ?The chief executive officer of each State shall certify that the State agrees to make payments under this subchapter only with respect to: (A) Households in which 1 or more individuals are receiving: (i) Assistance under the State program foundered under part A of the title IV of the Social Security Act; (ii) supplemental security income payments under title XVI of the Social Security Act; (iii) supplemental nutrition assistance program benefits under the Food and Nutrition Act of 2008; or (iv) payments under section 1315, 1521, 1541, or 1542 of title 38, or under section 306 of the Veterans? and Survivors? Pension Improvement Act of 1978; or (B) Households with incomes which do not exceed the greater of: (i) An amount equal to 150 percent of the poverty level for such State; or (ii) An amount equal to 60 percent of the State median income.? Condition ? During our review of 60 eligibility samples, we noted the following exceptions: ? For two (2) samples, the benefit paid to the participant was more than the actual benefit amount allowed per the benefit table. This was due to an error in the program database system, which resulted in the incorrect income being reported by the system. ? DOEE is not performing review of all individual?s application. DOEE?s policy is to perform secondary reviews of a minimum of 25% of all applications each fiscal year, as well as supervisors will conduct detailed reviews of 5 applications per processor per month, however, there is no documentation how these policies and procedures were actually implemented. Questioned Costs ? Not determinable. Context ? This is a condition identified per review of DOEE?s compliance with specified requirements using a statistically valid sample. Effect ? Without proper review, inaccurate benefit amount is paid to the beneficiary which resulted in higher payment made. Cause ? It appears that DOEE?s internal controls were not operating effectively over the eligibility household income calculation process which resulted in accurate amount being paid. Recommendation ? We recommend that DOEE strengthen their existing policies and procedures to ensure the review of the initial application household information including household incomes, household sizes, etc. are correctly recorded into the system based on supporting documentation. Further, proper supporting documentation should be put in place to document the department?s control over review of applicant?s benefit application. Related Noncompliance ? Material noncompliance. Views of Responsible Officials and Planned Corrective Actions ? DOEE agrees with the conditions and recommendations of this finding. DOEE is committed to operating an efficient and effective LIHEAP program in the District. DOEE notes that out of 60 samples reviewed, the eligibility criteria stated above was met as none of the households reviewed had incomes that exceeded 60 percent of the State median income per 42 U.S Code Section 8624(b)(2). Vendor agreements are in place that require the refund of a benefit amount if the benefit cannot be applied to the account (due to moving, death, conversion to other heating or cooling source, or a payment made in error). DOEE has requested a refund from utilities of the two (2) samples in question. The two (2) samples in question were a result of a database error generated after a benefit payment batching and not the result of inaccurate income input by the processor. It is standard practice for DOEE to perform 1st level reviews of individual applications before, during and after certification. Twenty-five percent of secondary reviews are conducted by staff who did not process the application and are performed after the first review and captured by signature on one form within the database. Supervisory level reviews of 5 applications per processor per month is documented in our Operations Manual. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-015 Prior Year Finding Number: N/A Compliance Requirement: Matching, Level of Effort, Earmarking Program: U.S. Department of Health and Human Services Low Income Home Energy Assistance ALN: 93.568 Award #: Various Award Year: 10/01/2021 ? 09/30/2022 Government Department/Agency: Department of Energy and Environment (DOEE) Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per Compliance Supplement on earmarking requirement, a. Planning and Administrative Costs, (1) No more than 10 percent of a state?s LIHEAP funds for a federal fiscal year may be used for planning and administrative costs, including both direct and indirect costs. This limitation applies, in the aggregate, to planning and administrative costs at both the state and subrecipient levels. This cap may not be exceeded by supplementing with other federal funds (42 USC 8624(b)(9)(A); 45 CFR section 96.88(a)). Energy Need Reduction Services ? No more than 5 percent of the LIHEAP funds may be used to provide services that encourage and enable households to reduce their home energy needs and, thereby, the need for energy assistance. Such services may include needs assessments, counseling, and assistance with energy vendors (42 USC 8624(b)(16)). Condition ? During our review of two (2) samples, although DOEE met the earmarking requirement, there was no evidence of review was performed. Questioned Costs ? Not determinable. Context ? This is a condition identified per review of DOEE?s compliance with specified requirements for earmarking calculations. Effect ? Without proper internal controls and policies and procedures in place to monitor and review, DOEE was not in compliance with the earmarking requirements. Cause ? DOEE does not have adequate controls in place to ensure that earmarking requirements are being properly reviewed and the required documentation is being maintained to evidence compliance with the requirements. Recommendation ? We recommend that DOEE strengthen their existing policies and procedures to ensure the review of the earmarking calculations are performed. Further, proper supporting documentation should be put in place to document the department?s control over review of such calculations. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? DOEE agrees with the conditions and recommendations of this finding. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-024 Prior Year Finding Number: N/A Compliance Requirement: Data Collection Form and Single Audit Reporting Package Programs: ALN: 10.551, 10.561 Supplemental Nutrition Assistance Program Cluster ALN: 10.553, 10.555, 10.559, 10.582 Child Nutrition Cluster ALN: 10.558 Child and Adult Care Food Program ALN: 14.218 Community Development Block Grants/Entitlement Grants Cluster ALN: 21.023 COVID-19 ? Emergency Rental Assistance Program ALN: 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Relief Funds ALN: 84.027, 84.173 Special Education Cluster ALN: 84.126 Rehabilitation Services - Vocational Rehabilitation Grants to States ALN: 84.425 COVID-19 ? Education Stabilization Fund ALN: 93.268 Immunization Cooperative Agreements ALN: 93.498 COVID-19 ? Provider Relief Fund ALN: 93.558 Temporary Assistance for Needy Families ALN: 93.568 Low Income Home Energy Assistance ALN: 93.569 Community Services Block Grant ALN: 93.658 Foster Care ? Title IV-E ALN: 93.775, 93.777, 93.778 Medicaid Cluster ALN: 93.914 HIV Emergency Relief Project Grants ALN: 97.036 Public Assistance - Presidentially Declared Disaster Criteria - The Uniform Guidance in 2 CFR Section 200.512, Report Submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor?s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Condition ? The District did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended September 30, 2022. Questioned Costs ? None. Context ? This is a condition identified per review of the District?s compliance with the specified requirements. Effect ? The District could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Cause ? The District did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe. Recommendation ? We recommend that the District closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? The District concurs with the auditor?s findings and recommendations. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-014 Prior Year Finding Number: N/A Compliance Requirement: Eligibility Program: U.S. Department of Health and Human Services Low Income Home Energy Assistance ALN: 93.568 Award #: Various Award Year: 10/01/2021 ? 09/30/2022 Government Department/Agency: Department of Energy and Environment (DOEE) Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. The OMB Compliance Supplement states that ?Grantees may provide assistance to (a) households in which one or more individuals are receiving Temporary Assistance for Needy Families (TANF), Supplemental Security Income (SSI), Supplemental Nutrition Assistance Program (SNAP) benefits, or certain needs-tested veterans? benefits; or (b) households with incomes which do not exceed the greater of 150 percent of the state?s established poverty level, or 60 percent of the state median income. Grantees may establish lower income eligibility criteria, but no household may be excluded solely on the basis of income if the household income is less than 110 percent of the state?s poverty level (42 USC 8624(b)(2)). Grantees must give priority to those households with the highest home energy costs or needs in relation to income and household size (42 USC 8624(b)(5)).? Per 42 U.S. Code Section 8624(b)(2): ?The chief executive officer of each State shall certify that the State agrees to make payments under this subchapter only with respect to: (A) Households in which 1 or more individuals are receiving: (i) Assistance under the State program foundered under part A of the title IV of the Social Security Act; (ii) supplemental security income payments under title XVI of the Social Security Act; (iii) supplemental nutrition assistance program benefits under the Food and Nutrition Act of 2008; or (iv) payments under section 1315, 1521, 1541, or 1542 of title 38, or under section 306 of the Veterans? and Survivors? Pension Improvement Act of 1978; or (B) Households with incomes which do not exceed the greater of: (i) An amount equal to 150 percent of the poverty level for such State; or (ii) An amount equal to 60 percent of the State median income.? Condition ? During our review of 60 eligibility samples, we noted the following exceptions: ? For two (2) samples, the benefit paid to the participant was more than the actual benefit amount allowed per the benefit table. This was due to an error in the program database system, which resulted in the incorrect income being reported by the system. ? DOEE is not performing review of all individual?s application. DOEE?s policy is to perform secondary reviews of a minimum of 25% of all applications each fiscal year, as well as supervisors will conduct detailed reviews of 5 applications per processor per month, however, there is no documentation how these policies and procedures were actually implemented. Questioned Costs ? Not determinable. Context ? This is a condition identified per review of DOEE?s compliance with specified requirements using a statistically valid sample. Effect ? Without proper review, inaccurate benefit amount is paid to the beneficiary which resulted in higher payment made. Cause ? It appears that DOEE?s internal controls were not operating effectively over the eligibility household income calculation process which resulted in accurate amount being paid. Recommendation ? We recommend that DOEE strengthen their existing policies and procedures to ensure the review of the initial application household information including household incomes, household sizes, etc. are correctly recorded into the system based on supporting documentation. Further, proper supporting documentation should be put in place to document the department?s control over review of applicant?s benefit application. Related Noncompliance ? Material noncompliance. Views of Responsible Officials and Planned Corrective Actions ? DOEE agrees with the conditions and recommendations of this finding. DOEE is committed to operating an efficient and effective LIHEAP program in the District. DOEE notes that out of 60 samples reviewed, the eligibility criteria stated above was met as none of the households reviewed had incomes that exceeded 60 percent of the State median income per 42 U.S Code Section 8624(b)(2). Vendor agreements are in place that require the refund of a benefit amount if the benefit cannot be applied to the account (due to moving, death, conversion to other heating or cooling source, or a payment made in error). DOEE has requested a refund from utilities of the two (2) samples in question. The two (2) samples in question were a result of a database error generated after a benefit payment batching and not the result of inaccurate income input by the processor. It is standard practice for DOEE to perform 1st level reviews of individual applications before, during and after certification. Twenty-five percent of secondary reviews are conducted by staff who did not process the application and are performed after the first review and captured by signature on one form within the database. Supervisory level reviews of 5 applications per processor per month is documented in our Operations Manual. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-015 Prior Year Finding Number: N/A Compliance Requirement: Matching, Level of Effort, Earmarking Program: U.S. Department of Health and Human Services Low Income Home Energy Assistance ALN: 93.568 Award #: Various Award Year: 10/01/2021 ? 09/30/2022 Government Department/Agency: Department of Energy and Environment (DOEE) Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per Compliance Supplement on earmarking requirement, a. Planning and Administrative Costs, (1) No more than 10 percent of a state?s LIHEAP funds for a federal fiscal year may be used for planning and administrative costs, including both direct and indirect costs. This limitation applies, in the aggregate, to planning and administrative costs at both the state and subrecipient levels. This cap may not be exceeded by supplementing with other federal funds (42 USC 8624(b)(9)(A); 45 CFR section 96.88(a)). Energy Need Reduction Services ? No more than 5 percent of the LIHEAP funds may be used to provide services that encourage and enable households to reduce their home energy needs and, thereby, the need for energy assistance. Such services may include needs assessments, counseling, and assistance with energy vendors (42 USC 8624(b)(16)). Condition ? During our review of two (2) samples, although DOEE met the earmarking requirement, there was no evidence of review was performed. Questioned Costs ? Not determinable. Context ? This is a condition identified per review of DOEE?s compliance with specified requirements for earmarking calculations. Effect ? Without proper internal controls and policies and procedures in place to monitor and review, DOEE was not in compliance with the earmarking requirements. Cause ? DOEE does not have adequate controls in place to ensure that earmarking requirements are being properly reviewed and the required documentation is being maintained to evidence compliance with the requirements. Recommendation ? We recommend that DOEE strengthen their existing policies and procedures to ensure the review of the earmarking calculations are performed. Further, proper supporting documentation should be put in place to document the department?s control over review of such calculations. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? DOEE agrees with the conditions and recommendations of this finding. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-024 Prior Year Finding Number: N/A Compliance Requirement: Data Collection Form and Single Audit Reporting Package Programs: ALN: 10.551, 10.561 Supplemental Nutrition Assistance Program Cluster ALN: 10.553, 10.555, 10.559, 10.582 Child Nutrition Cluster ALN: 10.558 Child and Adult Care Food Program ALN: 14.218 Community Development Block Grants/Entitlement Grants Cluster ALN: 21.023 COVID-19 ? Emergency Rental Assistance Program ALN: 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Relief Funds ALN: 84.027, 84.173 Special Education Cluster ALN: 84.126 Rehabilitation Services - Vocational Rehabilitation Grants to States ALN: 84.425 COVID-19 ? Education Stabilization Fund ALN: 93.268 Immunization Cooperative Agreements ALN: 93.498 COVID-19 ? Provider Relief Fund ALN: 93.558 Temporary Assistance for Needy Families ALN: 93.568 Low Income Home Energy Assistance ALN: 93.569 Community Services Block Grant ALN: 93.658 Foster Care ? Title IV-E ALN: 93.775, 93.777, 93.778 Medicaid Cluster ALN: 93.914 HIV Emergency Relief Project Grants ALN: 97.036 Public Assistance - Presidentially Declared Disaster Criteria - The Uniform Guidance in 2 CFR Section 200.512, Report Submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor?s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Condition ? The District did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended September 30, 2022. Questioned Costs ? None. Context ? This is a condition identified per review of the District?s compliance with the specified requirements. Effect ? The District could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Cause ? The District did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe. Recommendation ? We recommend that the District closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? The District concurs with the auditor?s findings and recommendations. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-024 Prior Year Finding Number: N/A Compliance Requirement: Data Collection Form and Single Audit Reporting Package Programs: ALN: 10.551, 10.561 Supplemental Nutrition Assistance Program Cluster ALN: 10.553, 10.555, 10.559, 10.582 Child Nutrition Cluster ALN: 10.558 Child and Adult Care Food Program ALN: 14.218 Community Development Block Grants/Entitlement Grants Cluster ALN: 21.023 COVID-19 ? Emergency Rental Assistance Program ALN: 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Relief Funds ALN: 84.027, 84.173 Special Education Cluster ALN: 84.126 Rehabilitation Services - Vocational Rehabilitation Grants to States ALN: 84.425 COVID-19 ? Education Stabilization Fund ALN: 93.268 Immunization Cooperative Agreements ALN: 93.498 COVID-19 ? Provider Relief Fund ALN: 93.558 Temporary Assistance for Needy Families ALN: 93.568 Low Income Home Energy Assistance ALN: 93.569 Community Services Block Grant ALN: 93.658 Foster Care ? Title IV-E ALN: 93.775, 93.777, 93.778 Medicaid Cluster ALN: 93.914 HIV Emergency Relief Project Grants ALN: 97.036 Public Assistance - Presidentially Declared Disaster Criteria - The Uniform Guidance in 2 CFR Section 200.512, Report Submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor?s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Condition ? The District did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended September 30, 2022. Questioned Costs ? None. Context ? This is a condition identified per review of the District?s compliance with the specified requirements. Effect ? The District could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Cause ? The District did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe. Recommendation ? We recommend that the District closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? The District concurs with the auditor?s findings and recommendations. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-016 Prior Year Finding Number: N/A Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs/Cost Principles Program: U.S. Department of Health and Human Services Foster Care ? Title IV-E ALN: 93.658 Award #: Various Award Year: 10/01/2021 ? 09/30/2022 Government Department/Agency: Child and Family Services Agency (CFSA) Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Based on CFSA?s Human Resources Administration Issuance: HR-06-1 dated May 12, 2006, staff must seek and receive advance written approval prior to working overtime. It also indicate that in emergency situations requiring an immediate response, the employee shall make every reasonable attempt to obtain advance approval by an appropriate manager or supervisor. Condition ? During our review of the payroll process regarding the review and approval of time and attendance, we noted that the Agency was unable to provide documentation supporting the preapproval of overtime for three (3) employees. Questioned Costs ? Not determinable. Context ? This is a condition identified per review of CFSA?s compliance with specified requirements using a statistically valid sample. Effect ? Without proper internal controls and policies and procedures in place to ensure maintenance of records increase the risk of disagreements between employer and employee regarding the employee?s correct payment. Cause ? CFSA did not have proper internal controls and policies and procedures in place to ensure that authorization forms evidencing the preapproval of overtime are maintained. Recommendation - We recommend that CFSA strengthen its policies, procedures and controls to ensure that pre-authorization of overtime is maintained. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? CFSA concurs with the finding as stated. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-017 Prior Year Finding Number: 2021-018 Compliance Requirement: Eligibility Program: U.S. Department of Health and Human Services Foster Care ? Title IV-E ALN: 93.658 Award #: Various Award Year: 10/01/2021 ? 09/30/2022 Government Department/Agency: Child and Family Services Agency (CFSA) Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. 45 CFR Section 92.20(b)(2), ?Accounting records, "Grantees and sub grantees must maintain records which adequately identify the source and application of funds provided for financially assisted activities. These records must contain information pertaining to grant or subgrant awards and authorizations, obligations, unobligated balances, assets, liabilities, outlays or expenditures, and income.? 45 CFR Section 1356.30(a) states, ?The Title IV-E agency must provide documentation that criminal records checks have been conducted with respect to prospective foster and adoptive parents.? 42 U.S. Code Section 671(a)(20)(A), ?In order for a State to be eligible for payments under this part, it shall have a plan approved by the Secretary which provides procedures for criminal records checks of national crime information databases for any prospective foster or adoptive parent before the foster or adoptive parent may be finally approved for placement of a child regardless of whether foster care maintenance payments or adoption assistance payments are to be made on behalf of the child under the State plan.? Furthermore, per 45 CFR Section 1356.21(a), ?Statutory and regulatory requirements of the Federal foster care program, To implement the foster care maintenance payments program provisions of the title IV-E plan and to be eligible to receive Federal financial participation (FFP) for foster care maintenance payments under this part, a Title IV-E agency must meet the requirements of this section, 45 CFR 1356.22, 45 CFR 1356.30, and Parts 472, 475(1), 475(4), 475(5), 475(6).? Condition ? During our audit we noted that in fiscal year 2022, the Foster Care program had total disbursements of $2,851,787 for 3,754 maintenance payments. We selected a sample of 60 participants representing disbursed federal funds totaling $47,395, we noted the following deficiencies: ? For one (1) of 60 samples, the redetermination form provided indicated that claim billed and included in the population and samples selected included amounts with eligibility status of ?Eligible Not Reimbursable?. ? For two (2) of 60 samples, CFSA was unable to provide documentation supporting that a child over the age of 18 was enrolled as a full-time student expected to complete secondary schooling or equivalent vocational or technical training. ? For seven (7) of 60 samples, CFSA did not always provide complete evidence of background checks such as criminal record checks and fingerprint-based checks from the national crime information databases. These deficiencies represent 15% of the total disbursements tested. Questioned Costs ? Known amount is $7,249. Context ? This is a condition identified per review of CFSA?s compliance with specified requirements using a statistically valid sample. Effect ? CFSA was not in compliance with the eligibility requirements of the Foster Care program. Cause ? CFSA does not have adequate controls in place to ensure that eligibility files are being properly reviewed and the required documentation is being maintained to evidence compliance with eligibility requirements. Recommendation - We recommend CFSA reevaluate and strengthen its existing policies and procedures over the review and maintenance of appropriate documentation to ensure compliance with eligibility requirements in accordance with the program. Related Noncompliance ? Material noncompliance. Views of Responsible Officials and Planned Corrective Actions ? CFSA concurs with the findings as stated. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-018 Prior Year Finding Number: N/A Compliance Requirement: Reporting Program: U.S. Department of Health and Human Services Foster Care ? Title IV-E ALN: 93.658 Award #: Various Award Year: 10/01/2021 ? 09/30/2022 Government Department/Agency: Child and Family Services Agency (CFSA) Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Condition ? During our review and reconciliation of program expenditures charged to the grant, we noted that certain expenditures were inaccurately reported in fiscal year 2022. Per review of the general ledger, it was discovered that $32,325 incurred from February 2018 through September 2020 were incorrectly reported in the SEFA. Questioned Costs ? Not determinable. Context ? This is a condition identified per review of CFSA?s compliance with specified requirements. Effect ? Without proper internal controls and policies and procedures in place to ensure that costs were properly reported in the SF-425, the Foster Care program expenditures were overstated. Lack of proper internal controls over the review of the financial report may lead to incorrect reporting of financial data. Cause ? CFSA overstated expenditures reported as a result of the inclusion of transactions that were incurred outside of the grant award reporting period. Thus, management did not have proper internal controls and policies and procedures in place to ensure that the SF-425 was properly reviewed prior to approval. Recommendation - We recommend that CFSA strengthen its policies, procedures and controls to ensure the amounts reported in the SF-425 annual report are properly review prior to approval and submission to the federal agency. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? CFSA concurs with the finding as stated. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-024 Prior Year Finding Number: N/A Compliance Requirement: Data Collection Form and Single Audit Reporting Package Programs: ALN: 10.551, 10.561 Supplemental Nutrition Assistance Program Cluster ALN: 10.553, 10.555, 10.559, 10.582 Child Nutrition Cluster ALN: 10.558 Child and Adult Care Food Program ALN: 14.218 Community Development Block Grants/Entitlement Grants Cluster ALN: 21.023 COVID-19 ? Emergency Rental Assistance Program ALN: 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Relief Funds ALN: 84.027, 84.173 Special Education Cluster ALN: 84.126 Rehabilitation Services - Vocational Rehabilitation Grants to States ALN: 84.425 COVID-19 ? Education Stabilization Fund ALN: 93.268 Immunization Cooperative Agreements ALN: 93.498 COVID-19 ? Provider Relief Fund ALN: 93.558 Temporary Assistance for Needy Families ALN: 93.568 Low Income Home Energy Assistance ALN: 93.569 Community Services Block Grant ALN: 93.658 Foster Care ? Title IV-E ALN: 93.775, 93.777, 93.778 Medicaid Cluster ALN: 93.914 HIV Emergency Relief Project Grants ALN: 97.036 Public Assistance - Presidentially Declared Disaster Criteria - The Uniform Guidance in 2 CFR Section 200.512, Report Submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor?s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Condition ? The District did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended September 30, 2022. Questioned Costs ? None. Context ? This is a condition identified per review of the District?s compliance with the specified requirements. Effect ? The District could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Cause ? The District did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe. Recommendation ? We recommend that the District closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? The District concurs with the auditor?s findings and recommendations. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-019 Prior Year Finding Number: N/A Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs/Cost Principles Program: U.S. Department of Health and Human Services Medicaid Cluster ALN 93.775, 93.777, 93.778 Award #: Various Award Year: 10/01/2021 ? 09/30/2022 Government Department/Agency: Department of Human Services (DHS) Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR Section 200.430 Compensation ? Personal Services: ?Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the establish written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities; (2) Follows an appointment made in accordance with a non-Federal entity?s laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, Standards for Documentation of Personnel Expenses, when applicable.? 2 CFR Section 200.430(i): ?Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity?s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; (vi) [Reserved] (vii) Support the distribution of the employee?s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards.? Condition ? During our review of 15 payroll transactions totaling $84,519, we noted that for 1 of the 15 payroll transactions, the hourly and annual employee pay amount was not supported by the Personnel Action Form or the People Soft payroll system. Department personnel could not explain the difference in pay between the amount noted on the Personnel Action form and the PeopleSoft Human Resources/Payroll System. In addition, management did not perform a reconciliation between the payroll amount in the PeopleSoft payroll system and the actual amount being paid to the employee. Questioned Costs ? Not determinable. Context ? This is a condition identified per review of DHS? compliance with specified requirements using a statistically valid sample. Payroll costs including fringe benefits, for the Medicaid Program in fiscal year 2022 were $48,126,394. Effect ? DHS was unable to provide support for the payroll expenditure charged to the Medicaid Program for fiscal year 2022. Cause ? DHS did not have policies and procedures in place to review and reconcile payroll expenditures posted in the People Soft system with the pay amount identified in the Personnel Action Form. In addition, the payroll expenses charged to the Medicaid program were not accurately stated for fiscal year 2022. Recommendation - We recommend that DHS implement policies and procedures to support payroll expenses charged to the Medicaid program. In addition, we recommend that DHS perform reconciliations of the employee?s pay noted on their Personnel Action Form to the payroll amount posted in the PeopleSoft payroll system. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? DHS agrees with the finding that for one payroll transaction, the hourly and annual employee pay amount was not supported by the Personnel Action Form of the PeopleSoft payroll system. DHS agrees with the finding that DHS did not perform a reconciliation between the payroll amount in PeopleSoft payroll system and the actual amount being paid to the employee. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-020 Prior Year Finding Number: 2021-020 Compliance Requirement: Eligibility Program: U.S. Department of Health and Human Services Medicaid Cluster ALN: 93.775, 93.777, 93.778 Award #: Various Award Year: 10/01/2021 ? 09/30/2022 Government Department/Agency: Department of Health Care Finance (DHCF)/Department of Human Services (DHS)/Economic Security Administration (ESA) Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. The Medicaid State Plan: Citation 42 CFR Section 431.17AT-79-29. Section 4.7 (Maintenance of Records) states, ?The Medicaid agency maintains or supervises the maintenance of records necessary for the proper and efficient operation of the plan, including records regarding applications, determination of eligibility, the provision of medical assistance, and administrative costs and statistical, fiscal and other records necessary for reporting and accountability, and retains these records in accordance with Federal requirements. All requirements of 42 CFR 431.17 are met.? Economic Security Administration (ESA) Policy Manual, Section 1.3, ?All eligibility criteria and clarifying information are documented on the Record of Case Action, form 1052. The case record should speak for itself. An outside reviewer shall be able to follow the chronology of events in the case be reading the narrative. All application documents including verification and correspondence must be date-stamped. For working recipients, the record should include the dates pay is received and how often the recipient is paid. When the recipient?s statement is the best available source, the record should include the application/recipient and agency efforts to verify the information. All address changes should be documented.? Condition ? During testing over beneficiary eligibility for the Medicaid benefits, we noted that the District?s Economic Security Administration (ESA) was unable to provide sufficient documentation to support the beneficiary?s eligibility determination during the fiscal year 2022 audit. Specifically, out of a sample of 132 participant files tested, we noted the following exceptions: ? For fourteen (14) participant files where ESA did not process the application within the required timeframe. ? For one (1) participant file, ESA did not verify the applicant?s Social Security Number. ? For two (2) participant files, ESA did not verify the applicant?s citizenship. The Department of Health Care Finance, as the State Medicaid Agency, lacks a quality control oversight system to ensure that eligibility documentation and verification is maintained to support the eligibility decision. Questioned Costs ? Not determinable. Context ? This is a condition identified per review of ESA?s compliance with specified requirements using a statistically valid sample. Effect ? Lack of supporting documentation for program services and noncompliance with program requirements could result in disallowances of costs and participants could be receiving benefits that they are not entitled to receive under the program. Cause ? DHCF and ESA did not appear to adhere to internal control procedures to ensure that applications are properly processed in accordance with Federal Regulations. Recommendation - We recommend that ESA strictly implement internal control procedures to ensure that documentation is maintained to support the beneficiary determinations. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? DHCF and DHS concur with these findings. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-021 Prior Year Finding Number: N/A Compliance Requirement: Special Tests and Provisions ? Utilization Control and Program Integrity Program: U.S. Department of Health and Human Services Medicaid Cluster ALN 93.775, 93.777, 93.778 Award #: Various Award Year: 10/01/2021 ? 09/30/2022 Government Department/Agency: Department of Health Care Finance (DHCF) Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Condition ? During our testing of Utilization Control and Program Integrity for Quality Improvement Organization (QIO) invoices, for fourteen (14) out of forty (40) samples tested, we noted discrepancies between the price per review in the contract and the price per review in the actual vendor invoices, and such differences were not detected during the review of the invoice. This is an internal control deficiency. Questioned Costs ? Not determinable. Context ? This is a condition identified per review of QIO contracts and vendor invoices using a statistically valid sample. Effect ? The review of these QIO invoices contracted price failed to properly detect the price variances. Control Deficiency noted. Cause ? DHCF did not appear to adhere to internal control procedures to ensure that contract prices and vendor invoices agree. Recommendation - We recommend that DHCF implement internal control procedures to ensure that QIO invoices are properly reviewed and the amount in the contract agrees to the amount in the invoice. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? DHCF concurs with these findings. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-024 Prior Year Finding Number: N/A Compliance Requirement: Data Collection Form and Single Audit Reporting Package Programs: ALN: 10.551, 10.561 Supplemental Nutrition Assistance Program Cluster ALN: 10.553, 10.555, 10.559, 10.582 Child Nutrition Cluster ALN: 10.558 Child and Adult Care Food Program ALN: 14.218 Community Development Block Grants/Entitlement Grants Cluster ALN: 21.023 COVID-19 ? Emergency Rental Assistance Program ALN: 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Relief Funds ALN: 84.027, 84.173 Special Education Cluster ALN: 84.126 Rehabilitation Services - Vocational Rehabilitation Grants to States ALN: 84.425 COVID-19 ? Education Stabilization Fund ALN: 93.268 Immunization Cooperative Agreements ALN: 93.498 COVID-19 ? Provider Relief Fund ALN: 93.558 Temporary Assistance for Needy Families ALN: 93.568 Low Income Home Energy Assistance ALN: 93.569 Community Services Block Grant ALN: 93.658 Foster Care ? Title IV-E ALN: 93.775, 93.777, 93.778 Medicaid Cluster ALN: 93.914 HIV Emergency Relief Project Grants ALN: 97.036 Public Assistance - Presidentially Declared Disaster Criteria - The Uniform Guidance in 2 CFR Section 200.512, Report Submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor?s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Condition ? The District did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended September 30, 2022. Questioned Costs ? None. Context ? This is a condition identified per review of the District?s compliance with the specified requirements. Effect ? The District could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Cause ? The District did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe. Recommendation ? We recommend that the District closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? The District concurs with the auditor?s findings and recommendations. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-019 Prior Year Finding Number: N/A Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs/Cost Principles Program: U.S. Department of Health and Human Services Medicaid Cluster ALN 93.775, 93.777, 93.778 Award #: Various Award Year: 10/01/2021 ? 09/30/2022 Government Department/Agency: Department of Human Services (DHS) Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR Section 200.430 Compensation ? Personal Services: ?Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the establish written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities; (2) Follows an appointment made in accordance with a non-Federal entity?s laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, Standards for Documentation of Personnel Expenses, when applicable.? 2 CFR Section 200.430(i): ?Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity?s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; (vi) [Reserved] (vii) Support the distribution of the employee?s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards.? Condition ? During our review of 15 payroll transactions totaling $84,519, we noted that for 1 of the 15 payroll transactions, the hourly and annual employee pay amount was not supported by the Personnel Action Form or the People Soft payroll system. Department personnel could not explain the difference in pay between the amount noted on the Personnel Action form and the PeopleSoft Human Resources/Payroll System. In addition, management did not perform a reconciliation between the payroll amount in the PeopleSoft payroll system and the actual amount being paid to the employee. Questioned Costs ? Not determinable. Context ? This is a condition identified per review of DHS? compliance with specified requirements using a statistically valid sample. Payroll costs including fringe benefits, for the Medicaid Program in fiscal year 2022 were $48,126,394. Effect ? DHS was unable to provide support for the payroll expenditure charged to the Medicaid Program for fiscal year 2022. Cause ? DHS did not have policies and procedures in place to review and reconcile payroll expenditures posted in the People Soft system with the pay amount identified in the Personnel Action Form. In addition, the payroll expenses charged to the Medicaid program were not accurately stated for fiscal year 2022. Recommendation - We recommend that DHS implement policies and procedures to support payroll expenses charged to the Medicaid program. In addition, we recommend that DHS perform reconciliations of the employee?s pay noted on their Personnel Action Form to the payroll amount posted in the PeopleSoft payroll system. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? DHS agrees with the finding that for one payroll transaction, the hourly and annual employee pay amount was not supported by the Personnel Action Form of the PeopleSoft payroll system. DHS agrees with the finding that DHS did not perform a reconciliation between the payroll amount in PeopleSoft payroll system and the actual amount being paid to the employee. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-020 Prior Year Finding Number: 2021-020 Compliance Requirement: Eligibility Program: U.S. Department of Health and Human Services Medicaid Cluster ALN: 93.775, 93.777, 93.778 Award #: Various Award Year: 10/01/2021 ? 09/30/2022 Government Department/Agency: Department of Health Care Finance (DHCF)/Department of Human Services (DHS)/Economic Security Administration (ESA) Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. The Medicaid State Plan: Citation 42 CFR Section 431.17AT-79-29. Section 4.7 (Maintenance of Records) states, ?The Medicaid agency maintains or supervises the maintenance of records necessary for the proper and efficient operation of the plan, including records regarding applications, determination of eligibility, the provision of medical assistance, and administrative costs and statistical, fiscal and other records necessary for reporting and accountability, and retains these records in accordance with Federal requirements. All requirements of 42 CFR 431.17 are met.? Economic Security Administration (ESA) Policy Manual, Section 1.3, ?All eligibility criteria and clarifying information are documented on the Record of Case Action, form 1052. The case record should speak for itself. An outside reviewer shall be able to follow the chronology of events in the case be reading the narrative. All application documents including verification and correspondence must be date-stamped. For working recipients, the record should include the dates pay is received and how often the recipient is paid. When the recipient?s statement is the best available source, the record should include the application/recipient and agency efforts to verify the information. All address changes should be documented.? Condition ? During testing over beneficiary eligibility for the Medicaid benefits, we noted that the District?s Economic Security Administration (ESA) was unable to provide sufficient documentation to support the beneficiary?s eligibility determination during the fiscal year 2022 audit. Specifically, out of a sample of 132 participant files tested, we noted the following exceptions: ? For fourteen (14) participant files where ESA did not process the application within the required timeframe. ? For one (1) participant file, ESA did not verify the applicant?s Social Security Number. ? For two (2) participant files, ESA did not verify the applicant?s citizenship. The Department of Health Care Finance, as the State Medicaid Agency, lacks a quality control oversight system to ensure that eligibility documentation and verification is maintained to support the eligibility decision. Questioned Costs ? Not determinable. Context ? This is a condition identified per review of ESA?s compliance with specified requirements using a statistically valid sample. Effect ? Lack of supporting documentation for program services and noncompliance with program requirements could result in disallowances of costs and participants could be receiving benefits that they are not entitled to receive under the program. Cause ? DHCF and ESA did not appear to adhere to internal control procedures to ensure that applications are properly processed in accordance with Federal Regulations. Recommendation - We recommend that ESA strictly implement internal control procedures to ensure that documentation is maintained to support the beneficiary determinations. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? DHCF and DHS concur with these findings. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-021 Prior Year Finding Number: N/A Compliance Requirement: Special Tests and Provisions ? Utilization Control and Program Integrity Program: U.S. Department of Health and Human Services Medicaid Cluster ALN 93.775, 93.777, 93.778 Award #: Various Award Year: 10/01/2021 ? 09/30/2022 Government Department/Agency: Department of Health Care Finance (DHCF) Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Condition ? During our testing of Utilization Control and Program Integrity for Quality Improvement Organization (QIO) invoices, for fourteen (14) out of forty (40) samples tested, we noted discrepancies between the price per review in the contract and the price per review in the actual vendor invoices, and such differences were not detected during the review of the invoice. This is an internal control deficiency. Questioned Costs ? Not determinable. Context ? This is a condition identified per review of QIO contracts and vendor invoices using a statistically valid sample. Effect ? The review of these QIO invoices contracted price failed to properly detect the price variances. Control Deficiency noted. Cause ? DHCF did not appear to adhere to internal control procedures to ensure that contract prices and vendor invoices agree. Recommendation - We recommend that DHCF implement internal control procedures to ensure that QIO invoices are properly reviewed and the amount in the contract agrees to the amount in the invoice. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? DHCF concurs with these findings. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-024 Prior Year Finding Number: N/A Compliance Requirement: Data Collection Form and Single Audit Reporting Package Programs: ALN: 10.551, 10.561 Supplemental Nutrition Assistance Program Cluster ALN: 10.553, 10.555, 10.559, 10.582 Child Nutrition Cluster ALN: 10.558 Child and Adult Care Food Program ALN: 14.218 Community Development Block Grants/Entitlement Grants Cluster ALN: 21.023 COVID-19 ? Emergency Rental Assistance Program ALN: 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Relief Funds ALN: 84.027, 84.173 Special Education Cluster ALN: 84.126 Rehabilitation Services - Vocational Rehabilitation Grants to States ALN: 84.425 COVID-19 ? Education Stabilization Fund ALN: 93.268 Immunization Cooperative Agreements ALN: 93.498 COVID-19 ? Provider Relief Fund ALN: 93.558 Temporary Assistance for Needy Families ALN: 93.568 Low Income Home Energy Assistance ALN: 93.569 Community Services Block Grant ALN: 93.658 Foster Care ? Title IV-E ALN: 93.775, 93.777, 93.778 Medicaid Cluster ALN: 93.914 HIV Emergency Relief Project Grants ALN: 97.036 Public Assistance - Presidentially Declared Disaster Criteria - The Uniform Guidance in 2 CFR Section 200.512, Report Submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor?s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Condition ? The District did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended September 30, 2022. Questioned Costs ? None. Context ? This is a condition identified per review of the District?s compliance with the specified requirements. Effect ? The District could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Cause ? The District did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe. Recommendation ? We recommend that the District closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? The District concurs with the auditor?s findings and recommendations. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-019 Prior Year Finding Number: N/A Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs/Cost Principles Program: U.S. Department of Health and Human Services Medicaid Cluster ALN 93.775, 93.777, 93.778 Award #: Various Award Year: 10/01/2021 ? 09/30/2022 Government Department/Agency: Department of Human Services (DHS) Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR Section 200.430 Compensation ? Personal Services: ?Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the establish written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities; (2) Follows an appointment made in accordance with a non-Federal entity?s laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, Standards for Documentation of Personnel Expenses, when applicable.? 2 CFR Section 200.430(i): ?Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity?s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; (vi) [Reserved] (vii) Support the distribution of the employee?s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards.? Condition ? During our review of 15 payroll transactions totaling $84,519, we noted that for 1 of the 15 payroll transactions, the hourly and annual employee pay amount was not supported by the Personnel Action Form or the People Soft payroll system. Department personnel could not explain the difference in pay between the amount noted on the Personnel Action form and the PeopleSoft Human Resources/Payroll System. In addition, management did not perform a reconciliation between the payroll amount in the PeopleSoft payroll system and the actual amount being paid to the employee. Questioned Costs ? Not determinable. Context ? This is a condition identified per review of DHS? compliance with specified requirements using a statistically valid sample. Payroll costs including fringe benefits, for the Medicaid Program in fiscal year 2022 were $48,126,394. Effect ? DHS was unable to provide support for the payroll expenditure charged to the Medicaid Program for fiscal year 2022. Cause ? DHS did not have policies and procedures in place to review and reconcile payroll expenditures posted in the People Soft system with the pay amount identified in the Personnel Action Form. In addition, the payroll expenses charged to the Medicaid program were not accurately stated for fiscal year 2022. Recommendation - We recommend that DHS implement policies and procedures to support payroll expenses charged to the Medicaid program. In addition, we recommend that DHS perform reconciliations of the employee?s pay noted on their Personnel Action Form to the payroll amount posted in the PeopleSoft payroll system. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? DHS agrees with the finding that for one payroll transaction, the hourly and annual employee pay amount was not supported by the Personnel Action Form of the PeopleSoft payroll system. DHS agrees with the finding that DHS did not perform a reconciliation between the payroll amount in PeopleSoft payroll system and the actual amount being paid to the employee. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-020 Prior Year Finding Number: 2021-020 Compliance Requirement: Eligibility Program: U.S. Department of Health and Human Services Medicaid Cluster ALN: 93.775, 93.777, 93.778 Award #: Various Award Year: 10/01/2021 ? 09/30/2022 Government Department/Agency: Department of Health Care Finance (DHCF)/Department of Human Services (DHS)/Economic Security Administration (ESA) Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. The Medicaid State Plan: Citation 42 CFR Section 431.17AT-79-29. Section 4.7 (Maintenance of Records) states, ?The Medicaid agency maintains or supervises the maintenance of records necessary for the proper and efficient operation of the plan, including records regarding applications, determination of eligibility, the provision of medical assistance, and administrative costs and statistical, fiscal and other records necessary for reporting and accountability, and retains these records in accordance with Federal requirements. All requirements of 42 CFR 431.17 are met.? Economic Security Administration (ESA) Policy Manual, Section 1.3, ?All eligibility criteria and clarifying information are documented on the Record of Case Action, form 1052. The case record should speak for itself. An outside reviewer shall be able to follow the chronology of events in the case be reading the narrative. All application documents including verification and correspondence must be date-stamped. For working recipients, the record should include the dates pay is received and how often the recipient is paid. When the recipient?s statement is the best available source, the record should include the application/recipient and agency efforts to verify the information. All address changes should be documented.? Condition ? During testing over beneficiary eligibility for the Medicaid benefits, we noted that the District?s Economic Security Administration (ESA) was unable to provide sufficient documentation to support the beneficiary?s eligibility determination during the fiscal year 2022 audit. Specifically, out of a sample of 132 participant files tested, we noted the following exceptions: ? For fourteen (14) participant files where ESA did not process the application within the required timeframe. ? For one (1) participant file, ESA did not verify the applicant?s Social Security Number. ? For two (2) participant files, ESA did not verify the applicant?s citizenship. The Department of Health Care Finance, as the State Medicaid Agency, lacks a quality control oversight system to ensure that eligibility documentation and verification is maintained to support the eligibility decision. Questioned Costs ? Not determinable. Context ? This is a condition identified per review of ESA?s compliance with specified requirements using a statistically valid sample. Effect ? Lack of supporting documentation for program services and noncompliance with program requirements could result in disallowances of costs and participants could be receiving benefits that they are not entitled to receive under the program. Cause ? DHCF and ESA did not appear to adhere to internal control procedures to ensure that applications are properly processed in accordance with Federal Regulations. Recommendation - We recommend that ESA strictly implement internal control procedures to ensure that documentation is maintained to support the beneficiary determinations. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? DHCF and DHS concur with these findings. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-021 Prior Year Finding Number: N/A Compliance Requirement: Special Tests and Provisions ? Utilization Control and Program Integrity Program: U.S. Department of Health and Human Services Medicaid Cluster ALN 93.775, 93.777, 93.778 Award #: Various Award Year: 10/01/2021 ? 09/30/2022 Government Department/Agency: Department of Health Care Finance (DHCF) Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Condition ? During our testing of Utilization Control and Program Integrity for Quality Improvement Organization (QIO) invoices, for fourteen (14) out of forty (40) samples tested, we noted discrepancies between the price per review in the contract and the price per review in the actual vendor invoices, and such differences were not detected during the review of the invoice. This is an internal control deficiency. Questioned Costs ? Not determinable. Context ? This is a condition identified per review of QIO contracts and vendor invoices using a statistically valid sample. Effect ? The review of these QIO invoices contracted price failed to properly detect the price variances. Control Deficiency noted. Cause ? DHCF did not appear to adhere to internal control procedures to ensure that contract prices and vendor invoices agree. Recommendation - We recommend that DHCF implement internal control procedures to ensure that QIO invoices are properly reviewed and the amount in the contract agrees to the amount in the invoice. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? DHCF concurs with these findings. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-024 Prior Year Finding Number: N/A Compliance Requirement: Data Collection Form and Single Audit Reporting Package Programs: ALN: 10.551, 10.561 Supplemental Nutrition Assistance Program Cluster ALN: 10.553, 10.555, 10.559, 10.582 Child Nutrition Cluster ALN: 10.558 Child and Adult Care Food Program ALN: 14.218 Community Development Block Grants/Entitlement Grants Cluster ALN: 21.023 COVID-19 ? Emergency Rental Assistance Program ALN: 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Relief Funds ALN: 84.027, 84.173 Special Education Cluster ALN: 84.126 Rehabilitation Services - Vocational Rehabilitation Grants to States ALN: 84.425 COVID-19 ? Education Stabilization Fund ALN: 93.268 Immunization Cooperative Agreements ALN: 93.498 COVID-19 ? Provider Relief Fund ALN: 93.558 Temporary Assistance for Needy Families ALN: 93.568 Low Income Home Energy Assistance ALN: 93.569 Community Services Block Grant ALN: 93.658 Foster Care ? Title IV-E ALN: 93.775, 93.777, 93.778 Medicaid Cluster ALN: 93.914 HIV Emergency Relief Project Grants ALN: 97.036 Public Assistance - Presidentially Declared Disaster Criteria - The Uniform Guidance in 2 CFR Section 200.512, Report Submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor?s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Condition ? The District did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended September 30, 2022. Questioned Costs ? None. Context ? This is a condition identified per review of the District?s compliance with the specified requirements. Effect ? The District could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Cause ? The District did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe. Recommendation ? We recommend that the District closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? The District concurs with the auditor?s findings and recommendations. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-019 Prior Year Finding Number: N/A Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs/Cost Principles Program: U.S. Department of Health and Human Services Medicaid Cluster ALN 93.775, 93.777, 93.778 Award #: Various Award Year: 10/01/2021 ? 09/30/2022 Government Department/Agency: Department of Human Services (DHS) Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR Section 200.430 Compensation ? Personal Services: ?Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the establish written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities; (2) Follows an appointment made in accordance with a non-Federal entity?s laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, Standards for Documentation of Personnel Expenses, when applicable.? 2 CFR Section 200.430(i): ?Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity?s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; (vi) [Reserved] (vii) Support the distribution of the employee?s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards.? Condition ? During our review of 15 payroll transactions totaling $84,519, we noted that for 1 of the 15 payroll transactions, the hourly and annual employee pay amount was not supported by the Personnel Action Form or the People Soft payroll system. Department personnel could not explain the difference in pay between the amount noted on the Personnel Action form and the PeopleSoft Human Resources/Payroll System. In addition, management did not perform a reconciliation between the payroll amount in the PeopleSoft payroll system and the actual amount being paid to the employee. Questioned Costs ? Not determinable. Context ? This is a condition identified per review of DHS? compliance with specified requirements using a statistically valid sample. Payroll costs including fringe benefits, for the Medicaid Program in fiscal year 2022 were $48,126,394. Effect ? DHS was unable to provide support for the payroll expenditure charged to the Medicaid Program for fiscal year 2022. Cause ? DHS did not have policies and procedures in place to review and reconcile payroll expenditures posted in the People Soft system with the pay amount identified in the Personnel Action Form. In addition, the payroll expenses charged to the Medicaid program were not accurately stated for fiscal year 2022. Recommendation - We recommend that DHS implement policies and procedures to support payroll expenses charged to the Medicaid program. In addition, we recommend that DHS perform reconciliations of the employee?s pay noted on their Personnel Action Form to the payroll amount posted in the PeopleSoft payroll system. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? DHS agrees with the finding that for one payroll transaction, the hourly and annual employee pay amount was not supported by the Personnel Action Form of the PeopleSoft payroll system. DHS agrees with the finding that DHS did not perform a reconciliation between the payroll amount in PeopleSoft payroll system and the actual amount being paid to the employee. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-020 Prior Year Finding Number: 2021-020 Compliance Requirement: Eligibility Program: U.S. Department of Health and Human Services Medicaid Cluster ALN: 93.775, 93.777, 93.778 Award #: Various Award Year: 10/01/2021 ? 09/30/2022 Government Department/Agency: Department of Health Care Finance (DHCF)/Department of Human Services (DHS)/Economic Security Administration (ESA) Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. The Medicaid State Plan: Citation 42 CFR Section 431.17AT-79-29. Section 4.7 (Maintenance of Records) states, ?The Medicaid agency maintains or supervises the maintenance of records necessary for the proper and efficient operation of the plan, including records regarding applications, determination of eligibility, the provision of medical assistance, and administrative costs and statistical, fiscal and other records necessary for reporting and accountability, and retains these records in accordance with Federal requirements. All requirements of 42 CFR 431.17 are met.? Economic Security Administration (ESA) Policy Manual, Section 1.3, ?All eligibility criteria and clarifying information are documented on the Record of Case Action, form 1052. The case record should speak for itself. An outside reviewer shall be able to follow the chronology of events in the case be reading the narrative. All application documents including verification and correspondence must be date-stamped. For working recipients, the record should include the dates pay is received and how often the recipient is paid. When the recipient?s statement is the best available source, the record should include the application/recipient and agency efforts to verify the information. All address changes should be documented.? Condition ? During testing over beneficiary eligibility for the Medicaid benefits, we noted that the District?s Economic Security Administration (ESA) was unable to provide sufficient documentation to support the beneficiary?s eligibility determination during the fiscal year 2022 audit. Specifically, out of a sample of 132 participant files tested, we noted the following exceptions: ? For fourteen (14) participant files where ESA did not process the application within the required timeframe. ? For one (1) participant file, ESA did not verify the applicant?s Social Security Number. ? For two (2) participant files, ESA did not verify the applicant?s citizenship. The Department of Health Care Finance, as the State Medicaid Agency, lacks a quality control oversight system to ensure that eligibility documentation and verification is maintained to support the eligibility decision. Questioned Costs ? Not determinable. Context ? This is a condition identified per review of ESA?s compliance with specified requirements using a statistically valid sample. Effect ? Lack of supporting documentation for program services and noncompliance with program requirements could result in disallowances of costs and participants could be receiving benefits that they are not entitled to receive under the program. Cause ? DHCF and ESA did not appear to adhere to internal control procedures to ensure that applications are properly processed in accordance with Federal Regulations. Recommendation - We recommend that ESA strictly implement internal control procedures to ensure that documentation is maintained to support the beneficiary determinations. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? DHCF and DHS concur with these findings. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-021 Prior Year Finding Number: N/A Compliance Requirement: Special Tests and Provisions ? Utilization Control and Program Integrity Program: U.S. Department of Health and Human Services Medicaid Cluster ALN 93.775, 93.777, 93.778 Award #: Various Award Year: 10/01/2021 ? 09/30/2022 Government Department/Agency: Department of Health Care Finance (DHCF) Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Condition ? During our testing of Utilization Control and Program Integrity for Quality Improvement Organization (QIO) invoices, for fourteen (14) out of forty (40) samples tested, we noted discrepancies between the price per review in the contract and the price per review in the actual vendor invoices, and such differences were not detected during the review of the invoice. This is an internal control deficiency. Questioned Costs ? Not determinable. Context ? This is a condition identified per review of QIO contracts and vendor invoices using a statistically valid sample. Effect ? The review of these QIO invoices contracted price failed to properly detect the price variances. Control Deficiency noted. Cause ? DHCF did not appear to adhere to internal control procedures to ensure that contract prices and vendor invoices agree. Recommendation - We recommend that DHCF implement internal control procedures to ensure that QIO invoices are properly reviewed and the amount in the contract agrees to the amount in the invoice. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? DHCF concurs with these findings. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-024 Prior Year Finding Number: N/A Compliance Requirement: Data Collection Form and Single Audit Reporting Package Programs: ALN: 10.551, 10.561 Supplemental Nutrition Assistance Program Cluster ALN: 10.553, 10.555, 10.559, 10.582 Child Nutrition Cluster ALN: 10.558 Child and Adult Care Food Program ALN: 14.218 Community Development Block Grants/Entitlement Grants Cluster ALN: 21.023 COVID-19 ? Emergency Rental Assistance Program ALN: 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Relief Funds ALN: 84.027, 84.173 Special Education Cluster ALN: 84.126 Rehabilitation Services - Vocational Rehabilitation Grants to States ALN: 84.425 COVID-19 ? Education Stabilization Fund ALN: 93.268 Immunization Cooperative Agreements ALN: 93.498 COVID-19 ? Provider Relief Fund ALN: 93.558 Temporary Assistance for Needy Families ALN: 93.568 Low Income Home Energy Assistance ALN: 93.569 Community Services Block Grant ALN: 93.658 Foster Care ? Title IV-E ALN: 93.775, 93.777, 93.778 Medicaid Cluster ALN: 93.914 HIV Emergency Relief Project Grants ALN: 97.036 Public Assistance - Presidentially Declared Disaster Criteria - The Uniform Guidance in 2 CFR Section 200.512, Report Submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor?s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Condition ? The District did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended September 30, 2022. Questioned Costs ? None. Context ? This is a condition identified per review of the District?s compliance with the specified requirements. Effect ? The District could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Cause ? The District did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe. Recommendation ? We recommend that the District closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? The District concurs with the auditor?s findings and recommendations. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-019 Prior Year Finding Number: N/A Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs/Cost Principles Program: U.S. Department of Health and Human Services Medicaid Cluster ALN 93.775, 93.777, 93.778 Award #: Various Award Year: 10/01/2021 ? 09/30/2022 Government Department/Agency: Department of Human Services (DHS) Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR Section 200.430 Compensation ? Personal Services: ?Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the establish written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities; (2) Follows an appointment made in accordance with a non-Federal entity?s laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, Standards for Documentation of Personnel Expenses, when applicable.? 2 CFR Section 200.430(i): ?Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity?s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; (vi) [Reserved] (vii) Support the distribution of the employee?s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards.? Condition ? During our review of 15 payroll transactions totaling $84,519, we noted that for 1 of the 15 payroll transactions, the hourly and annual employee pay amount was not supported by the Personnel Action Form or the People Soft payroll system. Department personnel could not explain the difference in pay between the amount noted on the Personnel Action form and the PeopleSoft Human Resources/Payroll System. In addition, management did not perform a reconciliation between the payroll amount in the PeopleSoft payroll system and the actual amount being paid to the employee. Questioned Costs ? Not determinable. Context ? This is a condition identified per review of DHS? compliance with specified requirements using a statistically valid sample. Payroll costs including fringe benefits, for the Medicaid Program in fiscal year 2022 were $48,126,394. Effect ? DHS was unable to provide support for the payroll expenditure charged to the Medicaid Program for fiscal year 2022. Cause ? DHS did not have policies and procedures in place to review and reconcile payroll expenditures posted in the People Soft system with the pay amount identified in the Personnel Action Form. In addition, the payroll expenses charged to the Medicaid program were not accurately stated for fiscal year 2022. Recommendation - We recommend that DHS implement policies and procedures to support payroll expenses charged to the Medicaid program. In addition, we recommend that DHS perform reconciliations of the employee?s pay noted on their Personnel Action Form to the payroll amount posted in the PeopleSoft payroll system. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? DHS agrees with the finding that for one payroll transaction, the hourly and annual employee pay amount was not supported by the Personnel Action Form of the PeopleSoft payroll system. DHS agrees with the finding that DHS did not perform a reconciliation between the payroll amount in PeopleSoft payroll system and the actual amount being paid to the employee. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-020 Prior Year Finding Number: 2021-020 Compliance Requirement: Eligibility Program: U.S. Department of Health and Human Services Medicaid Cluster ALN: 93.775, 93.777, 93.778 Award #: Various Award Year: 10/01/2021 ? 09/30/2022 Government Department/Agency: Department of Health Care Finance (DHCF)/Department of Human Services (DHS)/Economic Security Administration (ESA) Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. The Medicaid State Plan: Citation 42 CFR Section 431.17AT-79-29. Section 4.7 (Maintenance of Records) states, ?The Medicaid agency maintains or supervises the maintenance of records necessary for the proper and efficient operation of the plan, including records regarding applications, determination of eligibility, the provision of medical assistance, and administrative costs and statistical, fiscal and other records necessary for reporting and accountability, and retains these records in accordance with Federal requirements. All requirements of 42 CFR 431.17 are met.? Economic Security Administration (ESA) Policy Manual, Section 1.3, ?All eligibility criteria and clarifying information are documented on the Record of Case Action, form 1052. The case record should speak for itself. An outside reviewer shall be able to follow the chronology of events in the case be reading the narrative. All application documents including verification and correspondence must be date-stamped. For working recipients, the record should include the dates pay is received and how often the recipient is paid. When the recipient?s statement is the best available source, the record should include the application/recipient and agency efforts to verify the information. All address changes should be documented.? Condition ? During testing over beneficiary eligibility for the Medicaid benefits, we noted that the District?s Economic Security Administration (ESA) was unable to provide sufficient documentation to support the beneficiary?s eligibility determination during the fiscal year 2022 audit. Specifically, out of a sample of 132 participant files tested, we noted the following exceptions: ? For fourteen (14) participant files where ESA did not process the application within the required timeframe. ? For one (1) participant file, ESA did not verify the applicant?s Social Security Number. ? For two (2) participant files, ESA did not verify the applicant?s citizenship. The Department of Health Care Finance, as the State Medicaid Agency, lacks a quality control oversight system to ensure that eligibility documentation and verification is maintained to support the eligibility decision. Questioned Costs ? Not determinable. Context ? This is a condition identified per review of ESA?s compliance with specified requirements using a statistically valid sample. Effect ? Lack of supporting documentation for program services and noncompliance with program requirements could result in disallowances of costs and participants could be receiving benefits that they are not entitled to receive under the program. Cause ? DHCF and ESA did not appear to adhere to internal control procedures to ensure that applications are properly processed in accordance with Federal Regulations. Recommendation - We recommend that ESA strictly implement internal control procedures to ensure that documentation is maintained to support the beneficiary determinations. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? DHCF and DHS concur with these findings. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-021 Prior Year Finding Number: N/A Compliance Requirement: Special Tests and Provisions ? Utilization Control and Program Integrity Program: U.S. Department of Health and Human Services Medicaid Cluster ALN 93.775, 93.777, 93.778 Award #: Various Award Year: 10/01/2021 ? 09/30/2022 Government Department/Agency: Department of Health Care Finance (DHCF) Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Condition ? During our testing of Utilization Control and Program Integrity for Quality Improvement Organization (QIO) invoices, for fourteen (14) out of forty (40) samples tested, we noted discrepancies between the price per review in the contract and the price per review in the actual vendor invoices, and such differences were not detected during the review of the invoice. This is an internal control deficiency. Questioned Costs ? Not determinable. Context ? This is a condition identified per review of QIO contracts and vendor invoices using a statistically valid sample. Effect ? The review of these QIO invoices contracted price failed to properly detect the price variances. Control Deficiency noted. Cause ? DHCF did not appear to adhere to internal control procedures to ensure that contract prices and vendor invoices agree. Recommendation - We recommend that DHCF implement internal control procedures to ensure that QIO invoices are properly reviewed and the amount in the contract agrees to the amount in the invoice. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? DHCF concurs with these findings. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-024 Prior Year Finding Number: N/A Compliance Requirement: Data Collection Form and Single Audit Reporting Package Programs: ALN: 10.551, 10.561 Supplemental Nutrition Assistance Program Cluster ALN: 10.553, 10.555, 10.559, 10.582 Child Nutrition Cluster ALN: 10.558 Child and Adult Care Food Program ALN: 14.218 Community Development Block Grants/Entitlement Grants Cluster ALN: 21.023 COVID-19 ? Emergency Rental Assistance Program ALN: 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Relief Funds ALN: 84.027, 84.173 Special Education Cluster ALN: 84.126 Rehabilitation Services - Vocational Rehabilitation Grants to States ALN: 84.425 COVID-19 ? Education Stabilization Fund ALN: 93.268 Immunization Cooperative Agreements ALN: 93.498 COVID-19 ? Provider Relief Fund ALN: 93.558 Temporary Assistance for Needy Families ALN: 93.568 Low Income Home Energy Assistance ALN: 93.569 Community Services Block Grant ALN: 93.658 Foster Care ? Title IV-E ALN: 93.775, 93.777, 93.778 Medicaid Cluster ALN: 93.914 HIV Emergency Relief Project Grants ALN: 97.036 Public Assistance - Presidentially Declared Disaster Criteria - The Uniform Guidance in 2 CFR Section 200.512, Report Submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor?s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Condition ? The District did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended September 30, 2022. Questioned Costs ? None. Context ? This is a condition identified per review of the District?s compliance with the specified requirements. Effect ? The District could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Cause ? The District did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe. Recommendation ? We recommend that the District closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? The District concurs with the auditor?s findings and recommendations. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-022 Prior Year Finding Number: 2021-021 Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs/Cost Principles Program: U.S. Department of Health and Human Services HIV Emergency Relief Project Grants ALN: 93.914 Award #: 2 H89HA00012-32-00, 2 H89HA00012-31-00 Award Year: 03/01/2022 ? 02/28/2025, 03/01/2021 ? 02/28/2022 Government Department/Agency: Department of Health (DC Health) Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR Section 200.430 Compensation ? Personal Services: ?Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the establish written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities; (2) Follows an appointment made in accordance with a non-Federal entity?s laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, Standards for Documentation of Personnel Expenses, when applicable.? 2 CFR Section 200.430(i): ?Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity?s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; (vi) [Reserved] (vii) Support the distribution of the employee?s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards.? Condition ? We noted that the District Department of Health (DC Health) continued to allocate payroll expenditures to the HIV Emergency Relief Project Grants (HIVER) program during fiscal year 2022 based on budgeted percentages. These percentages were entered into the PeopleSoft Human Resources/Payroll System (PeopleSoft) at the beginning of the fiscal year and were based on management?s estimate of the respective employee?s level of effort for each program. PeopleSoft calculated the payroll costs every payroll cycle for each employee and program based on the predetermined percentage, and reported it through the Labor Distribution Report (485 Report). However, management did not perform a periodic comparison of actual costs to the budgeted costs and make any necessary adjustment as required by 2 CFR Section 200.430. Specifically, 41 out of 60 sampled payroll items tested for the HIVER grant were recorded based on estimated hours and not actual hours. Questioned Costs ? Not determinable. Context ? This is a condition identified per review of DC Health?s compliance with specified requirements using a statistically valid sample. Payroll costs including fringe benefits, for the HIVER program in fiscal year 2022 were $3,470,982. Effect ? DC Health was unable to demonstrate that the payroll expenditures charged to the HIVER grant accurately reflected the time incurred on the program and were properly supported in accordance with 2 CFR Part 200.430 time and effort reporting requirements. Cause ? DC Health did not have policies and procedures in place to review and reconcile the estimated amounts of payroll expenditures charged to the HIVER program to the actual expenditures incurred. Per corrective action plans and status updates submitted by DC Health to BDO in fiscal year 2022, significant milestones have been achieved however due to several change management tasks, the corrective action plan is still progressing into fiscal year 2023 and is expected to fully implement by September 30, 2023. Recommendation ? We recommend that DC Health fully implement its current corrective action plan to deploy policies and procedures to periodically compare employees? estimated hours per the 485 Report to the actual hours incurred, and make any necessary adjustments as required by 2 CFR 200.430. Related Noncompliance ? Material noncompliance. Views of Responsible Officials and Planned Corrective Actions ? The District Department of Health (DC Health) concurs with the finding, causes and recommendations cited in the fiscal year 2022 single audit for the HIV Emergency Relief Project Grants (HIVER) program. The current corrective action plan (CAP), originating from the prior year's finding had been actively implemented in fiscal year 2022 and reached significant milestones. DC Health asserts that while a process was implemented to obtain a regular schedule of payroll and budget- to-actual data for personnel, and supervisors were provided a tool and process for delivering ?time and effort certifications?, there were still some errors and omissions. DC Health concurs with the auditor on the need to continue implementation of the current CAP, but DC Health will modify processes and tools to ensure that there is the required periodic comparison of actual costs to the budgeted costs of personnel per the requirements of 2 CFR 200.430. Contributing factors were delays in distributing and receiving the required certifications, provision of technical assistance and training, and managing manual errors. Additionally, there were missing certifications due to a large turnover of staff, including many supervisors assigned to complete time and effort certification forms. In fiscal year 2022, reporting templates and reporting repositories were being revised and further developed and continued in fiscal year 2023. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-024 Prior Year Finding Number: N/A Compliance Requirement: Data Collection Form and Single Audit Reporting Package Programs: ALN: 10.551, 10.561 Supplemental Nutrition Assistance Program Cluster ALN: 10.553, 10.555, 10.559, 10.582 Child Nutrition Cluster ALN: 10.558 Child and Adult Care Food Program ALN: 14.218 Community Development Block Grants/Entitlement Grants Cluster ALN: 21.023 COVID-19 ? Emergency Rental Assistance Program ALN: 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Relief Funds ALN: 84.027, 84.173 Special Education Cluster ALN: 84.126 Rehabilitation Services - Vocational Rehabilitation Grants to States ALN: 84.425 COVID-19 ? Education Stabilization Fund ALN: 93.268 Immunization Cooperative Agreements ALN: 93.498 COVID-19 ? Provider Relief Fund ALN: 93.558 Temporary Assistance for Needy Families ALN: 93.568 Low Income Home Energy Assistance ALN: 93.569 Community Services Block Grant ALN: 93.658 Foster Care ? Title IV-E ALN: 93.775, 93.777, 93.778 Medicaid Cluster ALN: 93.914 HIV Emergency Relief Project Grants ALN: 97.036 Public Assistance - Presidentially Declared Disaster Criteria - The Uniform Guidance in 2 CFR Section 200.512, Report Submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor?s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Condition ? The District did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended September 30, 2022. Questioned Costs ? None. Context ? This is a condition identified per review of the District?s compliance with the specified requirements. Effect ? The District could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Cause ? The District did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe. Recommendation ? We recommend that the District closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? The District concurs with the auditor?s findings and recommendations. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-001 Prior Year Finding Number: 2021-001 Compliance Requirement: Special Tests and Provisions ? ADP System for SNAP Program: U.S. Department of Agriculture Supplemental Nutrition Assistance Program Cluster (SNAP) ALN: 10.551, 10.561 Award #: Various Award Year: 10/01/2021 ? 09/30/2022 Government Department/Agency: Department of Human Services (DHS)/ Department of Health Care Finance (DHCF) DC Access System (DCAS) Program Management Administration Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR Section 272.10(a), ?All State agencies are required to sufficiently automate their SNAP operations and computerize their systems for obtaining, maintaining, utilizing, and transmitting information concerning SNAP.? Per 2 CFR Section 272.10(b), ?In order to meet the requirements of the Act and ensure the efficient and effective administration of the program, a SNAP system, at a minimum, shall be automated in each of the following program areas (1) Certification and (2) Issuance Reconciliation and Reporting. Under Certification ? States agencies must determine eligibility and calculate benefits or validate the eligibility worker?s calculations by processing and storing all casefile information necessary for the eligibility determination and benefit computation (including but not limited to all household members? names, addresses, dates of birth, social security numbers, individual household members? earned and unearned income by source, deductions, resources and household size). Also, State agencies must redetermine or revalidate eligibility and benefits based on notices of change in households? circumstances.? Condition ? The District is self-reporting findings it noted from its ongoing efforts to resolve issues with the ADP system for SNAP. The issues identified and the estimated impact follows: 1. The SNAP net and gross income tests are applied to households who are categorically eligible through receipt or authorization to receive non-cash benefits under the District?s Temporary Assistance for Needy Families (TANF) program operated to meet 7 CFR 273.2(j)(2)(i)(C). As a result, SNAP applications are being improperly denied for failing the net or gross income test. The cost of this underpayment is currently unknown. 2. The SNAP gross income test is applied to applicants that contain an elderly or disabled member. As a result, SNAP applications are being improperly denied for failing the gross income test. The cost of this underpayment is currently unknown. 3. SNAP benefits are issued for the initial month of the certification period if the prorated amount is less than $10. As a result, SNAP benefits are being improperly overissued to some households. The cost of this overpayment is $48,592. 4. The Federal minimum SNAP benefit is not issued to eligible one or two person households unless those households are categorically eligible. As a result, one or two person households that are not categorically eligible will not receive benefits they are entitled to. The cost of this underpayment is currently unknown. 5. Certain allowable medical expenses are not configured in DCAS to allow a medical expense deduction. As a result, certain households with elderly or disabled members are not receiving a medical expense deduction. The cost of this underpayment is currently unknown. 6. DCAS is excluding retirement benefits from ?Civil Service Retirement and Disability? as unearned income when determining eligibility and benefits levels. As a result, some households may be determined eligible even if these retirement benefits would make them ineligible and some households will receive overpayments for failing to include these retirement benefits in the SNAP benefit calculation. The cost of this overpayment is $126,574. 7. Certain SNAP applicants/household members verified as students but not meeting a student exemption are included as household members. As a result, ineligible students are included in SNAP households resulting in overpayments. The cost of this overpayment is $57,785. 8. ESA is not providing the mandatory homeless shelter deduction for SNAP households experiencing homelessness with allowable shelter costs that do not opt to claim an excess shelter deduction. The cost of this underpayment is currently unknown. 9. ESA is not terminating customers who refuse to cooperate with the District Quality Control (QC) reviewers. The District?s interviews with QC staff and examples of recent cases referred by QC to ESA for termination revealed that in two instances, a request to terminate a SNAP household was not acted on by ESA, and in one instance, a request to terminate a SNAP household was acted on but ESA issued a termination notice with an incorrect termination reason. The cost of this overpayment is currently unknown. 10. ESA is not acting on Electronic Disqualified Recipient System (eDRS) matches at initial application or when a new household member is added. The cost of this overpayment is currently unknown. 11. SNAP does not have a systemic way to identify SNAP customers subject to the Able-Bodied Adult Without Dependents (ABAWD) work requirements. The cost of this overpayment is currently $18,500 per month or $222,000 for fiscal year 2022. These amounts represent 0.09% of the total amounts paid by DHS in claims for beneficiary payments. DHS paid a total of $506,630,102 in beneficiary payments to all SNAP beneficiaries in fiscal year 2022. Questioned Costs ? Known amount is $454,951. Context ? This is a condition identified per review of DHS? compliance with specified requirements resulting from a system implementation. Effect ? Without an effectively designed and operated system in place, ineligible beneficiaries may receive benefits under the SNAP grant and DHS may make payments on behalf of those beneficiaries resulting in noncompliance with the eligibility requirements. Inaccurate beneficiary allotment payments could result in participants receiving benefits that they are not entitled to receive under the program. Cause ? DHS did not effectively design and operate the ADP system for SNAP which resulted to inaccurate benefit payments. Recommendation ? We recommend that DHS continue to evaluate and improve the new ADP system for SNAP to ensure that it addresses all the administration requirements of the SNAP program. Related Noncompliance ? Material noncompliance. Views of Responsible Officials and Planned Corrective Actions ? The DHS and DHCF DCAS team agree with the findings noted in this report. DHS self-reported these findings as part of the Agencies ongoing effort to maintain integrity with all eligibility determinations. The root cause for each of the eleven (11) issues with the ADP system for SNAP varied. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-002 Prior Year Finding Number: 2021-002 Compliance Requirement: Special Tests and Provisions ? EBT Card Security Program: U.S. Department of Agriculture Supplemental Nutrition Assistance Program Cluster (SNAP) ALN: 10.551, 10.561 Award #: Various Award Year: 10/01/2021 ? 09/30/2022 Government Department/Agency: Department of Human Services (DHS)/ Office of the Chief Financial Officer/Office of Finance and Treasury (OCFO/OFT) Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 7 CFR Section 274.8(b)(3), As an addition to or component of the Security Program required of Automated Data Processing (ADP) systems, the State agency shall ensure that the following electronic benefits transfer (EBT) security requirements are established: (i) Storage and control measures to control blank unissued EBT cards and PINs, and unused or spare POS devices; (ii) Measures to ensure communication access control. Communication controls shall include the transmission of transaction data and issuance information from POS terminals to work-stations and terminals at the data processing center; (iii) Message validation; (iv) Administrative and operational procedures; (v) A separate EBT security component shall be incorporated into the State agency Security Program for ADP systems. The periodic risk analyses required by the Security Program shall address the following items specific to an EBT system ? (B) Completeness and timeliness of the reconciliation system; and (vi) The State agency shall incorporate the contingency plan approved by FNS into the Security Program. Condition ? OCFO/OFT for DHS are required to maintain adequate security over, and documentation/records for EBT cards, to prevent their theft, embezzlement, loss damage, destruction, unauthorized transfer, negotiation, or use. OCFO/OFT have contracted with Fidelity National Information Service (FIS) for the issuance and security of the EBT cards; however, it is OCFO/OFT?s ultimate responsibility to ensure the contractor has controls in place to maintain adequate security over, and documentation/records of EBT cards. During our tests of the design and implementation of internal controls, we noted the following issues: ? For five (5) out of the 60 samples, although both EBT Balance Sheets reconciled with the EBT Card Issuance Logs included in the package, we noted the following deficiencies: o For one (1) of the samples, we noted that for at least one (1) customer the client signature was missing from the EBT Intake Form. o For three (3) of the samples, we noted that for at least one (1) customer on the UPO EBT Intake Form, the ID type for identification purposes was missing. o For one (1) of the samples, we noted that for at least one (1) customer the identification type was noted as referral on the EBT Intake Form, but no referral form was attached. Questioned Costs ? None. Context ? This is a condition identified per review of DHS? compliance with specified requirements using a statistically valid sample. Effect ? Without adequate internal controls to ensure compliance with EBT Card Security requirements, there is an increased risk that the inventory of EBT cards will not be properly maintained and accounted for. Cause ? OCFO/OFT for DHS does not have adequate policies and procedures in place to ensure adequate safeguarding, documentation over issuance and monitoring of EBT cards. Recommendation - We recommend that OCFO/OFT for DHS strengthen formal policies and procedures to maintain adequate security over, and documentation/records for EBT Cards. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? The OCFO/OFT for DHS concurs with this finding. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-024 Prior Year Finding Number: N/A Compliance Requirement: Data Collection Form and Single Audit Reporting Package Programs: ALN: 10.551, 10.561 Supplemental Nutrition Assistance Program Cluster ALN: 10.553, 10.555, 10.559, 10.582 Child Nutrition Cluster ALN: 10.558 Child and Adult Care Food Program ALN: 14.218 Community Development Block Grants/Entitlement Grants Cluster ALN: 21.023 COVID-19 ? Emergency Rental Assistance Program ALN: 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Relief Funds ALN: 84.027, 84.173 Special Education Cluster ALN: 84.126 Rehabilitation Services - Vocational Rehabilitation Grants to States ALN: 84.425 COVID-19 ? Education Stabilization Fund ALN: 93.268 Immunization Cooperative Agreements ALN: 93.498 COVID-19 ? Provider Relief Fund ALN: 93.558 Temporary Assistance for Needy Families ALN: 93.568 Low Income Home Energy Assistance ALN: 93.569 Community Services Block Grant ALN: 93.658 Foster Care ? Title IV-E ALN: 93.775, 93.777, 93.778 Medicaid Cluster ALN: 93.914 HIV Emergency Relief Project Grants ALN: 97.036 Public Assistance - Presidentially Declared Disaster Criteria - The Uniform Guidance in 2 CFR Section 200.512, Report Submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor?s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Condition ? The District did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended September 30, 2022. Questioned Costs ? None. Context ? This is a condition identified per review of the District?s compliance with the specified requirements. Effect ? The District could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Cause ? The District did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe. Recommendation ? We recommend that the District closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? The District concurs with the auditor?s findings and recommendations. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-003 Prior Year Finding Number: N/A Compliance Requirement: Reporting Program: U.S. Department of Agriculture Child Nutrition Cluster ALN: 10.553, 10.555, 10.559 and 10.582 Award #: 1DC300302 Award Year: 10/01/2021 ? 09/30/2022 Government Department/Agency: District of Columbia Public Schools (DCPS) Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. 7 CFR Section 210.8 Claims for Reimbursement states: (a) Internal controls. The school food authority shall establish internal controls which ensure the accuracy of meal counts prior to the submission of the monthly Claim for Reimbursement. At a minimum, these internal controls shall include: an on-site review of the meal counting and claiming system employed by each school within the jurisdiction of the school food authority; comparisons of daily free, reduced price and paid meal counts against data which will assist in the identification of meal counts in excess of the number of free, reduced price and paid meals served each day to children eligible for such meals; and a system for following up on those meal counts which suggest the likelihood of meal counting problems. (1) ?On-site reviews. Every school year, each school food authority with more than one school shall perform no less than one on-site review of the counting and claiming system and the readily observable general areas of review cited under Section 210.18(h), as prescribed by FNS for each school under its jurisdiction. The on-site review shall take place prior to February 1 of each school year. Further, if the review discloses problems with a school's meal counting or claiming procedures or general review areas, the school food authority shall: ensure that the school implements corrective action; and, within 45 days of the review, conducts a follow-up on-site review to determine that the corrective action resolved the problems. Each on-site review shall ensure that the school's claim is based on the counting system authorized by the State agency under Section 210.7(c) of this part and that the counting system, as implemented, yields the actual number of reimbursable free, reduced price and paid meals, respectively, served for each day of operation.? Condition ? DCPS conducted 158 on-site reviews in fiscal year 2022. We selected a sample of sixteen (16) on-site reviews and noted that DCPS is unable to provide evidence to support that a review took place on two (2) of the samples where DCPS assessed that the schools passed the on-site review. These on-site reviews are the main control of DCPS to ensure that the meal counts reported and eventually claimed for reimbursement to the Office of the State Superintendent of Education (OSSE) is accurate. Questioned Costs ? Not determinable. Context ? This is a condition identified per review of DCPS? compliance with specified requirements using a statistically valid sample. Effect ? DCPS did not comply with the reporting requirements of the Child Nutrition Cluster. Cause ? DCPS does not have a fully effective internal controls over record keeping of on-site review process. Recommendation ? We recommend DCPS to continue to enhance its controls over reporting to ensure compliance with the requirements of the Child Nutrition Cluster. This should include policies and procedures relating to record keeping of support for any on-site review conducted and enhance monitoring controls to ensure all supporting documentation over the on-site review are filed and available for inspection at any time. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? DCPS agrees with the conditions and recommendations of this finding. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-024 Prior Year Finding Number: N/A Compliance Requirement: Data Collection Form and Single Audit Reporting Package Programs: ALN: 10.551, 10.561 Supplemental Nutrition Assistance Program Cluster ALN: 10.553, 10.555, 10.559, 10.582 Child Nutrition Cluster ALN: 10.558 Child and Adult Care Food Program ALN: 14.218 Community Development Block Grants/Entitlement Grants Cluster ALN: 21.023 COVID-19 ? Emergency Rental Assistance Program ALN: 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Relief Funds ALN: 84.027, 84.173 Special Education Cluster ALN: 84.126 Rehabilitation Services - Vocational Rehabilitation Grants to States ALN: 84.425 COVID-19 ? Education Stabilization Fund ALN: 93.268 Immunization Cooperative Agreements ALN: 93.498 COVID-19 ? Provider Relief Fund ALN: 93.558 Temporary Assistance for Needy Families ALN: 93.568 Low Income Home Energy Assistance ALN: 93.569 Community Services Block Grant ALN: 93.658 Foster Care ? Title IV-E ALN: 93.775, 93.777, 93.778 Medicaid Cluster ALN: 93.914 HIV Emergency Relief Project Grants ALN: 97.036 Public Assistance - Presidentially Declared Disaster Criteria - The Uniform Guidance in 2 CFR Section 200.512, Report Submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor?s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Condition ? The District did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended September 30, 2022. Questioned Costs ? None. Context ? This is a condition identified per review of the District?s compliance with the specified requirements. Effect ? The District could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Cause ? The District did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe. Recommendation ? We recommend that the District closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? The District concurs with the auditor?s findings and recommendations. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-003 Prior Year Finding Number: N/A Compliance Requirement: Reporting Program: U.S. Department of Agriculture Child Nutrition Cluster ALN: 10.553, 10.555, 10.559 and 10.582 Award #: 1DC300302 Award Year: 10/01/2021 ? 09/30/2022 Government Department/Agency: District of Columbia Public Schools (DCPS) Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. 7 CFR Section 210.8 Claims for Reimbursement states: (a) Internal controls. The school food authority shall establish internal controls which ensure the accuracy of meal counts prior to the submission of the monthly Claim for Reimbursement. At a minimum, these internal controls shall include: an on-site review of the meal counting and claiming system employed by each school within the jurisdiction of the school food authority; comparisons of daily free, reduced price and paid meal counts against data which will assist in the identification of meal counts in excess of the number of free, reduced price and paid meals served each day to children eligible for such meals; and a system for following up on those meal counts which suggest the likelihood of meal counting problems. (1) ?On-site reviews. Every school year, each school food authority with more than one school shall perform no less than one on-site review of the counting and claiming system and the readily observable general areas of review cited under Section 210.18(h), as prescribed by FNS for each school under its jurisdiction. The on-site review shall take place prior to February 1 of each school year. Further, if the review discloses problems with a school's meal counting or claiming procedures or general review areas, the school food authority shall: ensure that the school implements corrective action; and, within 45 days of the review, conducts a follow-up on-site review to determine that the corrective action resolved the problems. Each on-site review shall ensure that the school's claim is based on the counting system authorized by the State agency under Section 210.7(c) of this part and that the counting system, as implemented, yields the actual number of reimbursable free, reduced price and paid meals, respectively, served for each day of operation.? Condition ? DCPS conducted 158 on-site reviews in fiscal year 2022. We selected a sample of sixteen (16) on-site reviews and noted that DCPS is unable to provide evidence to support that a review took place on two (2) of the samples where DCPS assessed that the schools passed the on-site review. These on-site reviews are the main control of DCPS to ensure that the meal counts reported and eventually claimed for reimbursement to the Office of the State Superintendent of Education (OSSE) is accurate. Questioned Costs ? Not determinable. Context ? This is a condition identified per review of DCPS? compliance with specified requirements using a statistically valid sample. Effect ? DCPS did not comply with the reporting requirements of the Child Nutrition Cluster. Cause ? DCPS does not have a fully effective internal controls over record keeping of on-site review process. Recommendation ? We recommend DCPS to continue to enhance its controls over reporting to ensure compliance with the requirements of the Child Nutrition Cluster. This should include policies and procedures relating to record keeping of support for any on-site review conducted and enhance monitoring controls to ensure all supporting documentation over the on-site review are filed and available for inspection at any time. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? DCPS agrees with the conditions and recommendations of this finding. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-024 Prior Year Finding Number: N/A Compliance Requirement: Data Collection Form and Single Audit Reporting Package Programs: ALN: 10.551, 10.561 Supplemental Nutrition Assistance Program Cluster ALN: 10.553, 10.555, 10.559, 10.582 Child Nutrition Cluster ALN: 10.558 Child and Adult Care Food Program ALN: 14.218 Community Development Block Grants/Entitlement Grants Cluster ALN: 21.023 COVID-19 ? Emergency Rental Assistance Program ALN: 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Relief Funds ALN: 84.027, 84.173 Special Education Cluster ALN: 84.126 Rehabilitation Services - Vocational Rehabilitation Grants to States ALN: 84.425 COVID-19 ? Education Stabilization Fund ALN: 93.268 Immunization Cooperative Agreements ALN: 93.498 COVID-19 ? Provider Relief Fund ALN: 93.558 Temporary Assistance for Needy Families ALN: 93.568 Low Income Home Energy Assistance ALN: 93.569 Community Services Block Grant ALN: 93.658 Foster Care ? Title IV-E ALN: 93.775, 93.777, 93.778 Medicaid Cluster ALN: 93.914 HIV Emergency Relief Project Grants ALN: 97.036 Public Assistance - Presidentially Declared Disaster Criteria - The Uniform Guidance in 2 CFR Section 200.512, Report Submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor?s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Condition ? The District did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended September 30, 2022. Questioned Costs ? None. Context ? This is a condition identified per review of the District?s compliance with the specified requirements. Effect ? The District could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Cause ? The District did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe. Recommendation ? We recommend that the District closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? The District concurs with the auditor?s findings and recommendations. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-003 Prior Year Finding Number: N/A Compliance Requirement: Reporting Program: U.S. Department of Agriculture Child Nutrition Cluster ALN: 10.553, 10.555, 10.559 and 10.582 Award #: 1DC300302 Award Year: 10/01/2021 ? 09/30/2022 Government Department/Agency: District of Columbia Public Schools (DCPS) Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. 7 CFR Section 210.8 Claims for Reimbursement states: (a) Internal controls. The school food authority shall establish internal controls which ensure the accuracy of meal counts prior to the submission of the monthly Claim for Reimbursement. At a minimum, these internal controls shall include: an on-site review of the meal counting and claiming system employed by each school within the jurisdiction of the school food authority; comparisons of daily free, reduced price and paid meal counts against data which will assist in the identification of meal counts in excess of the number of free, reduced price and paid meals served each day to children eligible for such meals; and a system for following up on those meal counts which suggest the likelihood of meal counting problems. (1) ?On-site reviews. Every school year, each school food authority with more than one school shall perform no less than one on-site review of the counting and claiming system and the readily observable general areas of review cited under Section 210.18(h), as prescribed by FNS for each school under its jurisdiction. The on-site review shall take place prior to February 1 of each school year. Further, if the review discloses problems with a school's meal counting or claiming procedures or general review areas, the school food authority shall: ensure that the school implements corrective action; and, within 45 days of the review, conducts a follow-up on-site review to determine that the corrective action resolved the problems. Each on-site review shall ensure that the school's claim is based on the counting system authorized by the State agency under Section 210.7(c) of this part and that the counting system, as implemented, yields the actual number of reimbursable free, reduced price and paid meals, respectively, served for each day of operation.? Condition ? DCPS conducted 158 on-site reviews in fiscal year 2022. We selected a sample of sixteen (16) on-site reviews and noted that DCPS is unable to provide evidence to support that a review took place on two (2) of the samples where DCPS assessed that the schools passed the on-site review. These on-site reviews are the main control of DCPS to ensure that the meal counts reported and eventually claimed for reimbursement to the Office of the State Superintendent of Education (OSSE) is accurate. Questioned Costs ? Not determinable. Context ? This is a condition identified per review of DCPS? compliance with specified requirements using a statistically valid sample. Effect ? DCPS did not comply with the reporting requirements of the Child Nutrition Cluster. Cause ? DCPS does not have a fully effective internal controls over record keeping of on-site review process. Recommendation ? We recommend DCPS to continue to enhance its controls over reporting to ensure compliance with the requirements of the Child Nutrition Cluster. This should include policies and procedures relating to record keeping of support for any on-site review conducted and enhance monitoring controls to ensure all supporting documentation over the on-site review are filed and available for inspection at any time. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? DCPS agrees with the conditions and recommendations of this finding. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-024 Prior Year Finding Number: N/A Compliance Requirement: Data Collection Form and Single Audit Reporting Package Programs: ALN: 10.551, 10.561 Supplemental Nutrition Assistance Program Cluster ALN: 10.553, 10.555, 10.559, 10.582 Child Nutrition Cluster ALN: 10.558 Child and Adult Care Food Program ALN: 14.218 Community Development Block Grants/Entitlement Grants Cluster ALN: 21.023 COVID-19 ? Emergency Rental Assistance Program ALN: 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Relief Funds ALN: 84.027, 84.173 Special Education Cluster ALN: 84.126 Rehabilitation Services - Vocational Rehabilitation Grants to States ALN: 84.425 COVID-19 ? Education Stabilization Fund ALN: 93.268 Immunization Cooperative Agreements ALN: 93.498 COVID-19 ? Provider Relief Fund ALN: 93.558 Temporary Assistance for Needy Families ALN: 93.568 Low Income Home Energy Assistance ALN: 93.569 Community Services Block Grant ALN: 93.658 Foster Care ? Title IV-E ALN: 93.775, 93.777, 93.778 Medicaid Cluster ALN: 93.914 HIV Emergency Relief Project Grants ALN: 97.036 Public Assistance - Presidentially Declared Disaster Criteria - The Uniform Guidance in 2 CFR Section 200.512, Report Submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor?s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Condition ? The District did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended September 30, 2022. Questioned Costs ? None. Context ? This is a condition identified per review of the District?s compliance with the specified requirements. Effect ? The District could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Cause ? The District did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe. Recommendation ? We recommend that the District closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? The District concurs with the auditor?s findings and recommendations. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-003 Prior Year Finding Number: N/A Compliance Requirement: Reporting Program: U.S. Department of Agriculture Child Nutrition Cluster ALN: 10.553, 10.555, 10.559 and 10.582 Award #: 1DC300302 Award Year: 10/01/2021 ? 09/30/2022 Government Department/Agency: District of Columbia Public Schools (DCPS) Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. 7 CFR Section 210.8 Claims for Reimbursement states: (a) Internal controls. The school food authority shall establish internal controls which ensure the accuracy of meal counts prior to the submission of the monthly Claim for Reimbursement. At a minimum, these internal controls shall include: an on-site review of the meal counting and claiming system employed by each school within the jurisdiction of the school food authority; comparisons of daily free, reduced price and paid meal counts against data which will assist in the identification of meal counts in excess of the number of free, reduced price and paid meals served each day to children eligible for such meals; and a system for following up on those meal counts which suggest the likelihood of meal counting problems. (1) ?On-site reviews. Every school year, each school food authority with more than one school shall perform no less than one on-site review of the counting and claiming system and the readily observable general areas of review cited under Section 210.18(h), as prescribed by FNS for each school under its jurisdiction. The on-site review shall take place prior to February 1 of each school year. Further, if the review discloses problems with a school's meal counting or claiming procedures or general review areas, the school food authority shall: ensure that the school implements corrective action; and, within 45 days of the review, conducts a follow-up on-site review to determine that the corrective action resolved the problems. Each on-site review shall ensure that the school's claim is based on the counting system authorized by the State agency under Section 210.7(c) of this part and that the counting system, as implemented, yields the actual number of reimbursable free, reduced price and paid meals, respectively, served for each day of operation.? Condition ? DCPS conducted 158 on-site reviews in fiscal year 2022. We selected a sample of sixteen (16) on-site reviews and noted that DCPS is unable to provide evidence to support that a review took place on two (2) of the samples where DCPS assessed that the schools passed the on-site review. These on-site reviews are the main control of DCPS to ensure that the meal counts reported and eventually claimed for reimbursement to the Office of the State Superintendent of Education (OSSE) is accurate. Questioned Costs ? Not determinable. Context ? This is a condition identified per review of DCPS? compliance with specified requirements using a statistically valid sample. Effect ? DCPS did not comply with the reporting requirements of the Child Nutrition Cluster. Cause ? DCPS does not have a fully effective internal controls over record keeping of on-site review process. Recommendation ? We recommend DCPS to continue to enhance its controls over reporting to ensure compliance with the requirements of the Child Nutrition Cluster. This should include policies and procedures relating to record keeping of support for any on-site review conducted and enhance monitoring controls to ensure all supporting documentation over the on-site review are filed and available for inspection at any time. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? DCPS agrees with the conditions and recommendations of this finding. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-024 Prior Year Finding Number: N/A Compliance Requirement: Data Collection Form and Single Audit Reporting Package Programs: ALN: 10.551, 10.561 Supplemental Nutrition Assistance Program Cluster ALN: 10.553, 10.555, 10.559, 10.582 Child Nutrition Cluster ALN: 10.558 Child and Adult Care Food Program ALN: 14.218 Community Development Block Grants/Entitlement Grants Cluster ALN: 21.023 COVID-19 ? Emergency Rental Assistance Program ALN: 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Relief Funds ALN: 84.027, 84.173 Special Education Cluster ALN: 84.126 Rehabilitation Services - Vocational Rehabilitation Grants to States ALN: 84.425 COVID-19 ? Education Stabilization Fund ALN: 93.268 Immunization Cooperative Agreements ALN: 93.498 COVID-19 ? Provider Relief Fund ALN: 93.558 Temporary Assistance for Needy Families ALN: 93.568 Low Income Home Energy Assistance ALN: 93.569 Community Services Block Grant ALN: 93.658 Foster Care ? Title IV-E ALN: 93.775, 93.777, 93.778 Medicaid Cluster ALN: 93.914 HIV Emergency Relief Project Grants ALN: 97.036 Public Assistance - Presidentially Declared Disaster Criteria - The Uniform Guidance in 2 CFR Section 200.512, Report Submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor?s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Condition ? The District did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended September 30, 2022. Questioned Costs ? None. Context ? This is a condition identified per review of the District?s compliance with the specified requirements. Effect ? The District could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Cause ? The District did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe. Recommendation ? We recommend that the District closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? The District concurs with the auditor?s findings and recommendations. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-024 Prior Year Finding Number: N/A Compliance Requirement: Data Collection Form and Single Audit Reporting Package Programs: ALN: 10.551, 10.561 Supplemental Nutrition Assistance Program Cluster ALN: 10.553, 10.555, 10.559, 10.582 Child Nutrition Cluster ALN: 10.558 Child and Adult Care Food Program ALN: 14.218 Community Development Block Grants/Entitlement Grants Cluster ALN: 21.023 COVID-19 ? Emergency Rental Assistance Program ALN: 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Relief Funds ALN: 84.027, 84.173 Special Education Cluster ALN: 84.126 Rehabilitation Services - Vocational Rehabilitation Grants to States ALN: 84.425 COVID-19 ? Education Stabilization Fund ALN: 93.268 Immunization Cooperative Agreements ALN: 93.498 COVID-19 ? Provider Relief Fund ALN: 93.558 Temporary Assistance for Needy Families ALN: 93.568 Low Income Home Energy Assistance ALN: 93.569 Community Services Block Grant ALN: 93.658 Foster Care ? Title IV-E ALN: 93.775, 93.777, 93.778 Medicaid Cluster ALN: 93.914 HIV Emergency Relief Project Grants ALN: 97.036 Public Assistance - Presidentially Declared Disaster Criteria - The Uniform Guidance in 2 CFR Section 200.512, Report Submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor?s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Condition ? The District did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended September 30, 2022. Questioned Costs ? None. Context ? This is a condition identified per review of the District?s compliance with the specified requirements. Effect ? The District could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Cause ? The District did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe. Recommendation ? We recommend that the District closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? The District concurs with the auditor?s findings and recommendations. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-003 Prior Year Finding Number: N/A Compliance Requirement: Reporting Program: U.S. Department of Agriculture Child Nutrition Cluster ALN: 10.553, 10.555, 10.559 and 10.582 Award #: 1DC300302 Award Year: 10/01/2021 ? 09/30/2022 Government Department/Agency: District of Columbia Public Schools (DCPS) Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. 7 CFR Section 210.8 Claims for Reimbursement states: (a) Internal controls. The school food authority shall establish internal controls which ensure the accuracy of meal counts prior to the submission of the monthly Claim for Reimbursement. At a minimum, these internal controls shall include: an on-site review of the meal counting and claiming system employed by each school within the jurisdiction of the school food authority; comparisons of daily free, reduced price and paid meal counts against data which will assist in the identification of meal counts in excess of the number of free, reduced price and paid meals served each day to children eligible for such meals; and a system for following up on those meal counts which suggest the likelihood of meal counting problems. (1) ?On-site reviews. Every school year, each school food authority with more than one school shall perform no less than one on-site review of the counting and claiming system and the readily observable general areas of review cited under Section 210.18(h), as prescribed by FNS for each school under its jurisdiction. The on-site review shall take place prior to February 1 of each school year. Further, if the review discloses problems with a school's meal counting or claiming procedures or general review areas, the school food authority shall: ensure that the school implements corrective action; and, within 45 days of the review, conducts a follow-up on-site review to determine that the corrective action resolved the problems. Each on-site review shall ensure that the school's claim is based on the counting system authorized by the State agency under Section 210.7(c) of this part and that the counting system, as implemented, yields the actual number of reimbursable free, reduced price and paid meals, respectively, served for each day of operation.? Condition ? DCPS conducted 158 on-site reviews in fiscal year 2022. We selected a sample of sixteen (16) on-site reviews and noted that DCPS is unable to provide evidence to support that a review took place on two (2) of the samples where DCPS assessed that the schools passed the on-site review. These on-site reviews are the main control of DCPS to ensure that the meal counts reported and eventually claimed for reimbursement to the Office of the State Superintendent of Education (OSSE) is accurate. Questioned Costs ? Not determinable. Context ? This is a condition identified per review of DCPS? compliance with specified requirements using a statistically valid sample. Effect ? DCPS did not comply with the reporting requirements of the Child Nutrition Cluster. Cause ? DCPS does not have a fully effective internal controls over record keeping of on-site review process. Recommendation ? We recommend DCPS to continue to enhance its controls over reporting to ensure compliance with the requirements of the Child Nutrition Cluster. This should include policies and procedures relating to record keeping of support for any on-site review conducted and enhance monitoring controls to ensure all supporting documentation over the on-site review are filed and available for inspection at any time. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? DCPS agrees with the conditions and recommendations of this finding. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-024 Prior Year Finding Number: N/A Compliance Requirement: Data Collection Form and Single Audit Reporting Package Programs: ALN: 10.551, 10.561 Supplemental Nutrition Assistance Program Cluster ALN: 10.553, 10.555, 10.559, 10.582 Child Nutrition Cluster ALN: 10.558 Child and Adult Care Food Program ALN: 14.218 Community Development Block Grants/Entitlement Grants Cluster ALN: 21.023 COVID-19 ? Emergency Rental Assistance Program ALN: 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Relief Funds ALN: 84.027, 84.173 Special Education Cluster ALN: 84.126 Rehabilitation Services - Vocational Rehabilitation Grants to States ALN: 84.425 COVID-19 ? Education Stabilization Fund ALN: 93.268 Immunization Cooperative Agreements ALN: 93.498 COVID-19 ? Provider Relief Fund ALN: 93.558 Temporary Assistance for Needy Families ALN: 93.568 Low Income Home Energy Assistance ALN: 93.569 Community Services Block Grant ALN: 93.658 Foster Care ? Title IV-E ALN: 93.775, 93.777, 93.778 Medicaid Cluster ALN: 93.914 HIV Emergency Relief Project Grants ALN: 97.036 Public Assistance - Presidentially Declared Disaster Criteria - The Uniform Guidance in 2 CFR Section 200.512, Report Submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor?s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Condition ? The District did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended September 30, 2022. Questioned Costs ? None. Context ? This is a condition identified per review of the District?s compliance with the specified requirements. Effect ? The District could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Cause ? The District did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe. Recommendation ? We recommend that the District closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? The District concurs with the auditor?s findings and recommendations. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-023 Prior Year Finding Number: 2021-023 Compliance Requirement: Reporting Program: U.S. Department of Homeland Security Federal Emergency Management Agency (FEMA) Public Assistance - Presidentially Declared Disaster ALN: 97.036 Award #: FEMA-4502-DR-DC and FEMA-3553-EM-DC Award Year: 10/01/2021 ? 09/30/2022 Government Department/Agency: Homeland Security and Emergency Management Agency (HSEMA) Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. In accordance with 2 CFR Part 170, Appendix A, under the Federal Funding Accountability and Transparency Act (FFATA), the department is required to collect and report information on each subaward or amendment of $30,000 or more in federal funds in the FFATA Subaward Reporting System. In accordance with the requirements of 2 CFR Section 1402.300, the non-Federal entity is responsible for complying with all requirements of the Federal award. For all Federal awards, this includes the provisions of FFATA, which includes requirements on executive compensation, and also requirements implementing the Act for the non-Federal entity at 2 CFR part 25 Financial Assistance Use of Universal Identifier and System for Award Management and 2 CFR part 170 Reporting Subaward and Executive Compensation Information. Condition ? Our examination of the program?s reporting requirements identified that Homeland Security and Emergency Management Agency failed to collect and report information on subawards or amendments of $30,000 or more in federal funds in the FFATA Subaward Reporting System to fulfil the FFATA requirements for the entire year under audit. Questioned Costs ? None. Context ? This is a condition identified per review of HSEMA?s compliance with reporting requirements. No sampling was performed as no FFATA reporting was completed by HSEMA during the year under audit. Effect ? HSEMA is not in compliance with reporting requirements as it failed to provide evidence of identifying and reporting FFATA reporting requirements. Cause ? HSEMA did not have proper internal controls and policies and procedures in place to fulfill the FFATA reporting requirement. Recommendation ? We recommend that HSEMA should implement policies, procedures and controls that will ensure compliance with all the required laws, guidelines and requirement under the award. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? HSEMA concurs with the substance of the finding. The FFATA report for this grant is currently incomplete. HSEMA has procedures in place to file FFATA reports and does so for the other grants it manages. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-024 Prior Year Finding Number: N/A Compliance Requirement: Data Collection Form and Single Audit Reporting Package Programs: ALN: 10.551, 10.561 Supplemental Nutrition Assistance Program Cluster ALN: 10.553, 10.555, 10.559, 10.582 Child Nutrition Cluster ALN: 10.558 Child and Adult Care Food Program ALN: 14.218 Community Development Block Grants/Entitlement Grants Cluster ALN: 21.023 COVID-19 ? Emergency Rental Assistance Program ALN: 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Relief Funds ALN: 84.027, 84.173 Special Education Cluster ALN: 84.126 Rehabilitation Services - Vocational Rehabilitation Grants to States ALN: 84.425 COVID-19 ? Education Stabilization Fund ALN: 93.268 Immunization Cooperative Agreements ALN: 93.498 COVID-19 ? Provider Relief Fund ALN: 93.558 Temporary Assistance for Needy Families ALN: 93.568 Low Income Home Energy Assistance ALN: 93.569 Community Services Block Grant ALN: 93.658 Foster Care ? Title IV-E ALN: 93.775, 93.777, 93.778 Medicaid Cluster ALN: 93.914 HIV Emergency Relief Project Grants ALN: 97.036 Public Assistance - Presidentially Declared Disaster Criteria - The Uniform Guidance in 2 CFR Section 200.512, Report Submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor?s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Condition ? The District did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended September 30, 2022. Questioned Costs ? None. Context ? This is a condition identified per review of the District?s compliance with the specified requirements. Effect ? The District could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Cause ? The District did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe. Recommendation ? We recommend that the District closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? The District concurs with the auditor?s findings and recommendations. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-023 Prior Year Finding Number: 2021-023 Compliance Requirement: Reporting Program: U.S. Department of Homeland Security Federal Emergency Management Agency (FEMA) Public Assistance - Presidentially Declared Disaster ALN: 97.036 Award #: FEMA-4502-DR-DC and FEMA-3553-EM-DC Award Year: 10/01/2021 ? 09/30/2022 Government Department/Agency: Homeland Security and Emergency Management Agency (HSEMA) Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. In accordance with 2 CFR Part 170, Appendix A, under the Federal Funding Accountability and Transparency Act (FFATA), the department is required to collect and report information on each subaward or amendment of $30,000 or more in federal funds in the FFATA Subaward Reporting System. In accordance with the requirements of 2 CFR Section 1402.300, the non-Federal entity is responsible for complying with all requirements of the Federal award. For all Federal awards, this includes the provisions of FFATA, which includes requirements on executive compensation, and also requirements implementing the Act for the non-Federal entity at 2 CFR part 25 Financial Assistance Use of Universal Identifier and System for Award Management and 2 CFR part 170 Reporting Subaward and Executive Compensation Information. Condition ? Our examination of the program?s reporting requirements identified that Homeland Security and Emergency Management Agency failed to collect and report information on subawards or amendments of $30,000 or more in federal funds in the FFATA Subaward Reporting System to fulfil the FFATA requirements for the entire year under audit. Questioned Costs ? None. Context ? This is a condition identified per review of HSEMA?s compliance with reporting requirements. No sampling was performed as no FFATA reporting was completed by HSEMA during the year under audit. Effect ? HSEMA is not in compliance with reporting requirements as it failed to provide evidence of identifying and reporting FFATA reporting requirements. Cause ? HSEMA did not have proper internal controls and policies and procedures in place to fulfill the FFATA reporting requirement. Recommendation ? We recommend that HSEMA should implement policies, procedures and controls that will ensure compliance with all the required laws, guidelines and requirement under the award. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? HSEMA concurs with the substance of the finding. The FFATA report for this grant is currently incomplete. HSEMA has procedures in place to file FFATA reports and does so for the other grants it manages. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-024 Prior Year Finding Number: N/A Compliance Requirement: Data Collection Form and Single Audit Reporting Package Programs: ALN: 10.551, 10.561 Supplemental Nutrition Assistance Program Cluster ALN: 10.553, 10.555, 10.559, 10.582 Child Nutrition Cluster ALN: 10.558 Child and Adult Care Food Program ALN: 14.218 Community Development Block Grants/Entitlement Grants Cluster ALN: 21.023 COVID-19 ? Emergency Rental Assistance Program ALN: 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Relief Funds ALN: 84.027, 84.173 Special Education Cluster ALN: 84.126 Rehabilitation Services - Vocational Rehabilitation Grants to States ALN: 84.425 COVID-19 ? Education Stabilization Fund ALN: 93.268 Immunization Cooperative Agreements ALN: 93.498 COVID-19 ? Provider Relief Fund ALN: 93.558 Temporary Assistance for Needy Families ALN: 93.568 Low Income Home Energy Assistance ALN: 93.569 Community Services Block Grant ALN: 93.658 Foster Care ? Title IV-E ALN: 93.775, 93.777, 93.778 Medicaid Cluster ALN: 93.914 HIV Emergency Relief Project Grants ALN: 97.036 Public Assistance - Presidentially Declared Disaster Criteria - The Uniform Guidance in 2 CFR Section 200.512, Report Submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor?s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Condition ? The District did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended September 30, 2022. Questioned Costs ? None. Context ? This is a condition identified per review of the District?s compliance with the specified requirements. Effect ? The District could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Cause ? The District did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe. Recommendation ? We recommend that the District closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? The District concurs with the auditor?s findings and recommendations. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-003 Prior Year Finding Number: N/A Compliance Requirement: Reporting Program: U.S. Department of Agriculture Child Nutrition Cluster ALN: 10.553, 10.555, 10.559 and 10.582 Award #: 1DC300302 Award Year: 10/01/2021 ? 09/30/2022 Government Department/Agency: District of Columbia Public Schools (DCPS) Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. 7 CFR Section 210.8 Claims for Reimbursement states: (a) Internal controls. The school food authority shall establish internal controls which ensure the accuracy of meal counts prior to the submission of the monthly Claim for Reimbursement. At a minimum, these internal controls shall include: an on-site review of the meal counting and claiming system employed by each school within the jurisdiction of the school food authority; comparisons of daily free, reduced price and paid meal counts against data which will assist in the identification of meal counts in excess of the number of free, reduced price and paid meals served each day to children eligible for such meals; and a system for following up on those meal counts which suggest the likelihood of meal counting problems. (1) ?On-site reviews. Every school year, each school food authority with more than one school shall perform no less than one on-site review of the counting and claiming system and the readily observable general areas of review cited under Section 210.18(h), as prescribed by FNS for each school under its jurisdiction. The on-site review shall take place prior to February 1 of each school year. Further, if the review discloses problems with a school's meal counting or claiming procedures or general review areas, the school food authority shall: ensure that the school implements corrective action; and, within 45 days of the review, conducts a follow-up on-site review to determine that the corrective action resolved the problems. Each on-site review shall ensure that the school's claim is based on the counting system authorized by the State agency under Section 210.7(c) of this part and that the counting system, as implemented, yields the actual number of reimbursable free, reduced price and paid meals, respectively, served for each day of operation.? Condition ? DCPS conducted 158 on-site reviews in fiscal year 2022. We selected a sample of sixteen (16) on-site reviews and noted that DCPS is unable to provide evidence to support that a review took place on two (2) of the samples where DCPS assessed that the schools passed the on-site review. These on-site reviews are the main control of DCPS to ensure that the meal counts reported and eventually claimed for reimbursement to the Office of the State Superintendent of Education (OSSE) is accurate. Questioned Costs ? Not determinable. Context ? This is a condition identified per review of DCPS? compliance with specified requirements using a statistically valid sample. Effect ? DCPS did not comply with the reporting requirements of the Child Nutrition Cluster. Cause ? DCPS does not have a fully effective internal controls over record keeping of on-site review process. Recommendation ? We recommend DCPS to continue to enhance its controls over reporting to ensure compliance with the requirements of the Child Nutrition Cluster. This should include policies and procedures relating to record keeping of support for any on-site review conducted and enhance monitoring controls to ensure all supporting documentation over the on-site review are filed and available for inspection at any time. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? DCPS agrees with the conditions and recommendations of this finding. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-024 Prior Year Finding Number: N/A Compliance Requirement: Data Collection Form and Single Audit Reporting Package Programs: ALN: 10.551, 10.561 Supplemental Nutrition Assistance Program Cluster ALN: 10.553, 10.555, 10.559, 10.582 Child Nutrition Cluster ALN: 10.558 Child and Adult Care Food Program ALN: 14.218 Community Development Block Grants/Entitlement Grants Cluster ALN: 21.023 COVID-19 ? Emergency Rental Assistance Program ALN: 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Relief Funds ALN: 84.027, 84.173 Special Education Cluster ALN: 84.126 Rehabilitation Services - Vocational Rehabilitation Grants to States ALN: 84.425 COVID-19 ? Education Stabilization Fund ALN: 93.268 Immunization Cooperative Agreements ALN: 93.498 COVID-19 ? Provider Relief Fund ALN: 93.558 Temporary Assistance for Needy Families ALN: 93.568 Low Income Home Energy Assistance ALN: 93.569 Community Services Block Grant ALN: 93.658 Foster Care ? Title IV-E ALN: 93.775, 93.777, 93.778 Medicaid Cluster ALN: 93.914 HIV Emergency Relief Project Grants ALN: 97.036 Public Assistance - Presidentially Declared Disaster Criteria - The Uniform Guidance in 2 CFR Section 200.512, Report Submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor?s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Condition ? The District did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended September 30, 2022. Questioned Costs ? None. Context ? This is a condition identified per review of the District?s compliance with the specified requirements. Effect ? The District could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Cause ? The District did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe. Recommendation ? We recommend that the District closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? The District concurs with the auditor?s findings and recommendations. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-001 Prior Year Finding Number: 2021-001 Compliance Requirement: Special Tests and Provisions ? ADP System for SNAP Program: U.S. Department of Agriculture Supplemental Nutrition Assistance Program Cluster (SNAP) ALN: 10.551, 10.561 Award #: Various Award Year: 10/01/2021 ? 09/30/2022 Government Department/Agency: Department of Human Services (DHS)/ Department of Health Care Finance (DHCF) DC Access System (DCAS) Program Management Administration Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR Section 272.10(a), ?All State agencies are required to sufficiently automate their SNAP operations and computerize their systems for obtaining, maintaining, utilizing, and transmitting information concerning SNAP.? Per 2 CFR Section 272.10(b), ?In order to meet the requirements of the Act and ensure the efficient and effective administration of the program, a SNAP system, at a minimum, shall be automated in each of the following program areas (1) Certification and (2) Issuance Reconciliation and Reporting. Under Certification ? States agencies must determine eligibility and calculate benefits or validate the eligibility worker?s calculations by processing and storing all casefile information necessary for the eligibility determination and benefit computation (including but not limited to all household members? names, addresses, dates of birth, social security numbers, individual household members? earned and unearned income by source, deductions, resources and household size). Also, State agencies must redetermine or revalidate eligibility and benefits based on notices of change in households? circumstances.? Condition ? The District is self-reporting findings it noted from its ongoing efforts to resolve issues with the ADP system for SNAP. The issues identified and the estimated impact follows: 1. The SNAP net and gross income tests are applied to households who are categorically eligible through receipt or authorization to receive non-cash benefits under the District?s Temporary Assistance for Needy Families (TANF) program operated to meet 7 CFR 273.2(j)(2)(i)(C). As a result, SNAP applications are being improperly denied for failing the net or gross income test. The cost of this underpayment is currently unknown. 2. The SNAP gross income test is applied to applicants that contain an elderly or disabled member. As a result, SNAP applications are being improperly denied for failing the gross income test. The cost of this underpayment is currently unknown. 3. SNAP benefits are issued for the initial month of the certification period if the prorated amount is less than $10. As a result, SNAP benefits are being improperly overissued to some households. The cost of this overpayment is $48,592. 4. The Federal minimum SNAP benefit is not issued to eligible one or two person households unless those households are categorically eligible. As a result, one or two person households that are not categorically eligible will not receive benefits they are entitled to. The cost of this underpayment is currently unknown. 5. Certain allowable medical expenses are not configured in DCAS to allow a medical expense deduction. As a result, certain households with elderly or disabled members are not receiving a medical expense deduction. The cost of this underpayment is currently unknown. 6. DCAS is excluding retirement benefits from ?Civil Service Retirement and Disability? as unearned income when determining eligibility and benefits levels. As a result, some households may be determined eligible even if these retirement benefits would make them ineligible and some households will receive overpayments for failing to include these retirement benefits in the SNAP benefit calculation. The cost of this overpayment is $126,574. 7. Certain SNAP applicants/household members verified as students but not meeting a student exemption are included as household members. As a result, ineligible students are included in SNAP households resulting in overpayments. The cost of this overpayment is $57,785. 8. ESA is not providing the mandatory homeless shelter deduction for SNAP households experiencing homelessness with allowable shelter costs that do not opt to claim an excess shelter deduction. The cost of this underpayment is currently unknown. 9. ESA is not terminating customers who refuse to cooperate with the District Quality Control (QC) reviewers. The District?s interviews with QC staff and examples of recent cases referred by QC to ESA for termination revealed that in two instances, a request to terminate a SNAP household was not acted on by ESA, and in one instance, a request to terminate a SNAP household was acted on but ESA issued a termination notice with an incorrect termination reason. The cost of this overpayment is currently unknown. 10. ESA is not acting on Electronic Disqualified Recipient System (eDRS) matches at initial application or when a new household member is added. The cost of this overpayment is currently unknown. 11. SNAP does not have a systemic way to identify SNAP customers subject to the Able-Bodied Adult Without Dependents (ABAWD) work requirements. The cost of this overpayment is currently $18,500 per month or $222,000 for fiscal year 2022. These amounts represent 0.09% of the total amounts paid by DHS in claims for beneficiary payments. DHS paid a total of $506,630,102 in beneficiary payments to all SNAP beneficiaries in fiscal year 2022. Questioned Costs ? Known amount is $454,951. Context ? This is a condition identified per review of DHS? compliance with specified requirements resulting from a system implementation. Effect ? Without an effectively designed and operated system in place, ineligible beneficiaries may receive benefits under the SNAP grant and DHS may make payments on behalf of those beneficiaries resulting in noncompliance with the eligibility requirements. Inaccurate beneficiary allotment payments could result in participants receiving benefits that they are not entitled to receive under the program. Cause ? DHS did not effectively design and operate the ADP system for SNAP which resulted to inaccurate benefit payments. Recommendation ? We recommend that DHS continue to evaluate and improve the new ADP system for SNAP to ensure that it addresses all the administration requirements of the SNAP program. Related Noncompliance ? Material noncompliance. Views of Responsible Officials and Planned Corrective Actions ? The DHS and DHCF DCAS team agree with the findings noted in this report. DHS self-reported these findings as part of the Agencies ongoing effort to maintain integrity with all eligibility determinations. The root cause for each of the eleven (11) issues with the ADP system for SNAP varied. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-002 Prior Year Finding Number: 2021-002 Compliance Requirement: Special Tests and Provisions ? EBT Card Security Program: U.S. Department of Agriculture Supplemental Nutrition Assistance Program Cluster (SNAP) ALN: 10.551, 10.561 Award #: Various Award Year: 10/01/2021 ? 09/30/2022 Government Department/Agency: Department of Human Services (DHS)/ Office of the Chief Financial Officer/Office of Finance and Treasury (OCFO/OFT) Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 7 CFR Section 274.8(b)(3), As an addition to or component of the Security Program required of Automated Data Processing (ADP) systems, the State agency shall ensure that the following electronic benefits transfer (EBT) security requirements are established: (i) Storage and control measures to control blank unissued EBT cards and PINs, and unused or spare POS devices; (ii) Measures to ensure communication access control. Communication controls shall include the transmission of transaction data and issuance information from POS terminals to work-stations and terminals at the data processing center; (iii) Message validation; (iv) Administrative and operational procedures; (v) A separate EBT security component shall be incorporated into the State agency Security Program for ADP systems. The periodic risk analyses required by the Security Program shall address the following items specific to an EBT system ? (B) Completeness and timeliness of the reconciliation system; and (vi) The State agency shall incorporate the contingency plan approved by FNS into the Security Program. Condition ? OCFO/OFT for DHS are required to maintain adequate security over, and documentation/records for EBT cards, to prevent their theft, embezzlement, loss damage, destruction, unauthorized transfer, negotiation, or use. OCFO/OFT have contracted with Fidelity National Information Service (FIS) for the issuance and security of the EBT cards; however, it is OCFO/OFT?s ultimate responsibility to ensure the contractor has controls in place to maintain adequate security over, and documentation/records of EBT cards. During our tests of the design and implementation of internal controls, we noted the following issues: ? For five (5) out of the 60 samples, although both EBT Balance Sheets reconciled with the EBT Card Issuance Logs included in the package, we noted the following deficiencies: o For one (1) of the samples, we noted that for at least one (1) customer the client signature was missing from the EBT Intake Form. o For three (3) of the samples, we noted that for at least one (1) customer on the UPO EBT Intake Form, the ID type for identification purposes was missing. o For one (1) of the samples, we noted that for at least one (1) customer the identification type was noted as referral on the EBT Intake Form, but no referral form was attached. Questioned Costs ? None. Context ? This is a condition identified per review of DHS? compliance with specified requirements using a statistically valid sample. Effect ? Without adequate internal controls to ensure compliance with EBT Card Security requirements, there is an increased risk that the inventory of EBT cards will not be properly maintained and accounted for. Cause ? OCFO/OFT for DHS does not have adequate policies and procedures in place to ensure adequate safeguarding, documentation over issuance and monitoring of EBT cards. Recommendation - We recommend that OCFO/OFT for DHS strengthen formal policies and procedures to maintain adequate security over, and documentation/records for EBT Cards. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? The OCFO/OFT for DHS concurs with this finding. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-024 Prior Year Finding Number: N/A Compliance Requirement: Data Collection Form and Single Audit Reporting Package Programs: ALN: 10.551, 10.561 Supplemental Nutrition Assistance Program Cluster ALN: 10.553, 10.555, 10.559, 10.582 Child Nutrition Cluster ALN: 10.558 Child and Adult Care Food Program ALN: 14.218 Community Development Block Grants/Entitlement Grants Cluster ALN: 21.023 COVID-19 ? Emergency Rental Assistance Program ALN: 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Relief Funds ALN: 84.027, 84.173 Special Education Cluster ALN: 84.126 Rehabilitation Services - Vocational Rehabilitation Grants to States ALN: 84.425 COVID-19 ? Education Stabilization Fund ALN: 93.268 Immunization Cooperative Agreements ALN: 93.498 COVID-19 ? Provider Relief Fund ALN: 93.558 Temporary Assistance for Needy Families ALN: 93.568 Low Income Home Energy Assistance ALN: 93.569 Community Services Block Grant ALN: 93.658 Foster Care ? Title IV-E ALN: 93.775, 93.777, 93.778 Medicaid Cluster ALN: 93.914 HIV Emergency Relief Project Grants ALN: 97.036 Public Assistance - Presidentially Declared Disaster Criteria - The Uniform Guidance in 2 CFR Section 200.512, Report Submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor?s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Condition ? The District did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended September 30, 2022. Questioned Costs ? None. Context ? This is a condition identified per review of the District?s compliance with the specified requirements. Effect ? The District could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Cause ? The District did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe. Recommendation ? We recommend that the District closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? The District concurs with the auditor?s findings and recommendations. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-001 Prior Year Finding Number: 2021-001 Compliance Requirement: Special Tests and Provisions ? ADP System for SNAP Program: U.S. Department of Agriculture Supplemental Nutrition Assistance Program Cluster (SNAP) ALN: 10.551, 10.561 Award #: Various Award Year: 10/01/2021 ? 09/30/2022 Government Department/Agency: Department of Human Services (DHS)/ Department of Health Care Finance (DHCF) DC Access System (DCAS) Program Management Administration Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR Section 272.10(a), ?All State agencies are required to sufficiently automate their SNAP operations and computerize their systems for obtaining, maintaining, utilizing, and transmitting information concerning SNAP.? Per 2 CFR Section 272.10(b), ?In order to meet the requirements of the Act and ensure the efficient and effective administration of the program, a SNAP system, at a minimum, shall be automated in each of the following program areas (1) Certification and (2) Issuance Reconciliation and Reporting. Under Certification ? States agencies must determine eligibility and calculate benefits or validate the eligibility worker?s calculations by processing and storing all casefile information necessary for the eligibility determination and benefit computation (including but not limited to all household members? names, addresses, dates of birth, social security numbers, individual household members? earned and unearned income by source, deductions, resources and household size). Also, State agencies must redetermine or revalidate eligibility and benefits based on notices of change in households? circumstances.? Condition ? The District is self-reporting findings it noted from its ongoing efforts to resolve issues with the ADP system for SNAP. The issues identified and the estimated impact follows: 1. The SNAP net and gross income tests are applied to households who are categorically eligible through receipt or authorization to receive non-cash benefits under the District?s Temporary Assistance for Needy Families (TANF) program operated to meet 7 CFR 273.2(j)(2)(i)(C). As a result, SNAP applications are being improperly denied for failing the net or gross income test. The cost of this underpayment is currently unknown. 2. The SNAP gross income test is applied to applicants that contain an elderly or disabled member. As a result, SNAP applications are being improperly denied for failing the gross income test. The cost of this underpayment is currently unknown. 3. SNAP benefits are issued for the initial month of the certification period if the prorated amount is less than $10. As a result, SNAP benefits are being improperly overissued to some households. The cost of this overpayment is $48,592. 4. The Federal minimum SNAP benefit is not issued to eligible one or two person households unless those households are categorically eligible. As a result, one or two person households that are not categorically eligible will not receive benefits they are entitled to. The cost of this underpayment is currently unknown. 5. Certain allowable medical expenses are not configured in DCAS to allow a medical expense deduction. As a result, certain households with elderly or disabled members are not receiving a medical expense deduction. The cost of this underpayment is currently unknown. 6. DCAS is excluding retirement benefits from ?Civil Service Retirement and Disability? as unearned income when determining eligibility and benefits levels. As a result, some households may be determined eligible even if these retirement benefits would make them ineligible and some households will receive overpayments for failing to include these retirement benefits in the SNAP benefit calculation. The cost of this overpayment is $126,574. 7. Certain SNAP applicants/household members verified as students but not meeting a student exemption are included as household members. As a result, ineligible students are included in SNAP households resulting in overpayments. The cost of this overpayment is $57,785. 8. ESA is not providing the mandatory homeless shelter deduction for SNAP households experiencing homelessness with allowable shelter costs that do not opt to claim an excess shelter deduction. The cost of this underpayment is currently unknown. 9. ESA is not terminating customers who refuse to cooperate with the District Quality Control (QC) reviewers. The District?s interviews with QC staff and examples of recent cases referred by QC to ESA for termination revealed that in two instances, a request to terminate a SNAP household was not acted on by ESA, and in one instance, a request to terminate a SNAP household was acted on but ESA issued a termination notice with an incorrect termination reason. The cost of this overpayment is currently unknown. 10. ESA is not acting on Electronic Disqualified Recipient System (eDRS) matches at initial application or when a new household member is added. The cost of this overpayment is currently unknown. 11. SNAP does not have a systemic way to identify SNAP customers subject to the Able-Bodied Adult Without Dependents (ABAWD) work requirements. The cost of this overpayment is currently $18,500 per month or $222,000 for fiscal year 2022. These amounts represent 0.09% of the total amounts paid by DHS in claims for beneficiary payments. DHS paid a total of $506,630,102 in beneficiary payments to all SNAP beneficiaries in fiscal year 2022. Questioned Costs ? Known amount is $454,951. Context ? This is a condition identified per review of DHS? compliance with specified requirements resulting from a system implementation. Effect ? Without an effectively designed and operated system in place, ineligible beneficiaries may receive benefits under the SNAP grant and DHS may make payments on behalf of those beneficiaries resulting in noncompliance with the eligibility requirements. Inaccurate beneficiary allotment payments could result in participants receiving benefits that they are not entitled to receive under the program. Cause ? DHS did not effectively design and operate the ADP system for SNAP which resulted to inaccurate benefit payments. Recommendation ? We recommend that DHS continue to evaluate and improve the new ADP system for SNAP to ensure that it addresses all the administration requirements of the SNAP program. Related Noncompliance ? Material noncompliance. Views of Responsible Officials and Planned Corrective Actions ? The DHS and DHCF DCAS team agree with the findings noted in this report. DHS self-reported these findings as part of the Agencies ongoing effort to maintain integrity with all eligibility determinations. The root cause for each of the eleven (11) issues with the ADP system for SNAP varied. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-002 Prior Year Finding Number: 2021-002 Compliance Requirement: Special Tests and Provisions ? EBT Card Security Program: U.S. Department of Agriculture Supplemental Nutrition Assistance Program Cluster (SNAP) ALN: 10.551, 10.561 Award #: Various Award Year: 10/01/2021 ? 09/30/2022 Government Department/Agency: Department of Human Services (DHS)/ Office of the Chief Financial Officer/Office of Finance and Treasury (OCFO/OFT) Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 7 CFR Section 274.8(b)(3), As an addition to or component of the Security Program required of Automated Data Processing (ADP) systems, the State agency shall ensure that the following electronic benefits transfer (EBT) security requirements are established: (i) Storage and control measures to control blank unissued EBT cards and PINs, and unused or spare POS devices; (ii) Measures to ensure communication access control. Communication controls shall include the transmission of transaction data and issuance information from POS terminals to work-stations and terminals at the data processing center; (iii) Message validation; (iv) Administrative and operational procedures; (v) A separate EBT security component shall be incorporated into the State agency Security Program for ADP systems. The periodic risk analyses required by the Security Program shall address the following items specific to an EBT system ? (B) Completeness and timeliness of the reconciliation system; and (vi) The State agency shall incorporate the contingency plan approved by FNS into the Security Program. Condition ? OCFO/OFT for DHS are required to maintain adequate security over, and documentation/records for EBT cards, to prevent their theft, embezzlement, loss damage, destruction, unauthorized transfer, negotiation, or use. OCFO/OFT have contracted with Fidelity National Information Service (FIS) for the issuance and security of the EBT cards; however, it is OCFO/OFT?s ultimate responsibility to ensure the contractor has controls in place to maintain adequate security over, and documentation/records of EBT cards. During our tests of the design and implementation of internal controls, we noted the following issues: ? For five (5) out of the 60 samples, although both EBT Balance Sheets reconciled with the EBT Card Issuance Logs included in the package, we noted the following deficiencies: o For one (1) of the samples, we noted that for at least one (1) customer the client signature was missing from the EBT Intake Form. o For three (3) of the samples, we noted that for at least one (1) customer on the UPO EBT Intake Form, the ID type for identification purposes was missing. o For one (1) of the samples, we noted that for at least one (1) customer the identification type was noted as referral on the EBT Intake Form, but no referral form was attached. Questioned Costs ? None. Context ? This is a condition identified per review of DHS? compliance with specified requirements using a statistically valid sample. Effect ? Without adequate internal controls to ensure compliance with EBT Card Security requirements, there is an increased risk that the inventory of EBT cards will not be properly maintained and accounted for. Cause ? OCFO/OFT for DHS does not have adequate policies and procedures in place to ensure adequate safeguarding, documentation over issuance and monitoring of EBT cards. Recommendation - We recommend that OCFO/OFT for DHS strengthen formal policies and procedures to maintain adequate security over, and documentation/records for EBT Cards. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? The OCFO/OFT for DHS concurs with this finding. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-024 Prior Year Finding Number: N/A Compliance Requirement: Data Collection Form and Single Audit Reporting Package Programs: ALN: 10.551, 10.561 Supplemental Nutrition Assistance Program Cluster ALN: 10.553, 10.555, 10.559, 10.582 Child Nutrition Cluster ALN: 10.558 Child and Adult Care Food Program ALN: 14.218 Community Development Block Grants/Entitlement Grants Cluster ALN: 21.023 COVID-19 ? Emergency Rental Assistance Program ALN: 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Relief Funds ALN: 84.027, 84.173 Special Education Cluster ALN: 84.126 Rehabilitation Services - Vocational Rehabilitation Grants to States ALN: 84.425 COVID-19 ? Education Stabilization Fund ALN: 93.268 Immunization Cooperative Agreements ALN: 93.498 COVID-19 ? Provider Relief Fund ALN: 93.558 Temporary Assistance for Needy Families ALN: 93.568 Low Income Home Energy Assistance ALN: 93.569 Community Services Block Grant ALN: 93.658 Foster Care ? Title IV-E ALN: 93.775, 93.777, 93.778 Medicaid Cluster ALN: 93.914 HIV Emergency Relief Project Grants ALN: 97.036 Public Assistance - Presidentially Declared Disaster Criteria - The Uniform Guidance in 2 CFR Section 200.512, Report Submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor?s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Condition ? The District did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended September 30, 2022. Questioned Costs ? None. Context ? This is a condition identified per review of the District?s compliance with the specified requirements. Effect ? The District could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Cause ? The District did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe. Recommendation ? We recommend that the District closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? The District concurs with the auditor?s findings and recommendations. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-003 Prior Year Finding Number: N/A Compliance Requirement: Reporting Program: U.S. Department of Agriculture Child Nutrition Cluster ALN: 10.553, 10.555, 10.559 and 10.582 Award #: 1DC300302 Award Year: 10/01/2021 ? 09/30/2022 Government Department/Agency: District of Columbia Public Schools (DCPS) Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. 7 CFR Section 210.8 Claims for Reimbursement states: (a) Internal controls. The school food authority shall establish internal controls which ensure the accuracy of meal counts prior to the submission of the monthly Claim for Reimbursement. At a minimum, these internal controls shall include: an on-site review of the meal counting and claiming system employed by each school within the jurisdiction of the school food authority; comparisons of daily free, reduced price and paid meal counts against data which will assist in the identification of meal counts in excess of the number of free, reduced price and paid meals served each day to children eligible for such meals; and a system for following up on those meal counts which suggest the likelihood of meal counting problems. (1) ?On-site reviews. Every school year, each school food authority with more than one school shall perform no less than one on-site review of the counting and claiming system and the readily observable general areas of review cited under Section 210.18(h), as prescribed by FNS for each school under its jurisdiction. The on-site review shall take place prior to February 1 of each school year. Further, if the review discloses problems with a school's meal counting or claiming procedures or general review areas, the school food authority shall: ensure that the school implements corrective action; and, within 45 days of the review, conducts a follow-up on-site review to determine that the corrective action resolved the problems. Each on-site review shall ensure that the school's claim is based on the counting system authorized by the State agency under Section 210.7(c) of this part and that the counting system, as implemented, yields the actual number of reimbursable free, reduced price and paid meals, respectively, served for each day of operation.? Condition ? DCPS conducted 158 on-site reviews in fiscal year 2022. We selected a sample of sixteen (16) on-site reviews and noted that DCPS is unable to provide evidence to support that a review took place on two (2) of the samples where DCPS assessed that the schools passed the on-site review. These on-site reviews are the main control of DCPS to ensure that the meal counts reported and eventually claimed for reimbursement to the Office of the State Superintendent of Education (OSSE) is accurate. Questioned Costs ? Not determinable. Context ? This is a condition identified per review of DCPS? compliance with specified requirements using a statistically valid sample. Effect ? DCPS did not comply with the reporting requirements of the Child Nutrition Cluster. Cause ? DCPS does not have a fully effective internal controls over record keeping of on-site review process. Recommendation ? We recommend DCPS to continue to enhance its controls over reporting to ensure compliance with the requirements of the Child Nutrition Cluster. This should include policies and procedures relating to record keeping of support for any on-site review conducted and enhance monitoring controls to ensure all supporting documentation over the on-site review are filed and available for inspection at any time. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? DCPS agrees with the conditions and recommendations of this finding. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-024 Prior Year Finding Number: N/A Compliance Requirement: Data Collection Form and Single Audit Reporting Package Programs: ALN: 10.551, 10.561 Supplemental Nutrition Assistance Program Cluster ALN: 10.553, 10.555, 10.559, 10.582 Child Nutrition Cluster ALN: 10.558 Child and Adult Care Food Program ALN: 14.218 Community Development Block Grants/Entitlement Grants Cluster ALN: 21.023 COVID-19 ? Emergency Rental Assistance Program ALN: 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Relief Funds ALN: 84.027, 84.173 Special Education Cluster ALN: 84.126 Rehabilitation Services - Vocational Rehabilitation Grants to States ALN: 84.425 COVID-19 ? Education Stabilization Fund ALN: 93.268 Immunization Cooperative Agreements ALN: 93.498 COVID-19 ? Provider Relief Fund ALN: 93.558 Temporary Assistance for Needy Families ALN: 93.568 Low Income Home Energy Assistance ALN: 93.569 Community Services Block Grant ALN: 93.658 Foster Care ? Title IV-E ALN: 93.775, 93.777, 93.778 Medicaid Cluster ALN: 93.914 HIV Emergency Relief Project Grants ALN: 97.036 Public Assistance - Presidentially Declared Disaster Criteria - The Uniform Guidance in 2 CFR Section 200.512, Report Submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor?s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Condition ? The District did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended September 30, 2022. Questioned Costs ? None. Context ? This is a condition identified per review of the District?s compliance with the specified requirements. Effect ? The District could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Cause ? The District did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe. Recommendation ? We recommend that the District closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? The District concurs with the auditor?s findings and recommendations. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-024 Prior Year Finding Number: N/A Compliance Requirement: Data Collection Form and Single Audit Reporting Package Programs: ALN: 10.551, 10.561 Supplemental Nutrition Assistance Program Cluster ALN: 10.553, 10.555, 10.559, 10.582 Child Nutrition Cluster ALN: 10.558 Child and Adult Care Food Program ALN: 14.218 Community Development Block Grants/Entitlement Grants Cluster ALN: 21.023 COVID-19 ? Emergency Rental Assistance Program ALN: 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Relief Funds ALN: 84.027, 84.173 Special Education Cluster ALN: 84.126 Rehabilitation Services - Vocational Rehabilitation Grants to States ALN: 84.425 COVID-19 ? Education Stabilization Fund ALN: 93.268 Immunization Cooperative Agreements ALN: 93.498 COVID-19 ? Provider Relief Fund ALN: 93.558 Temporary Assistance for Needy Families ALN: 93.568 Low Income Home Energy Assistance ALN: 93.569 Community Services Block Grant ALN: 93.658 Foster Care ? Title IV-E ALN: 93.775, 93.777, 93.778 Medicaid Cluster ALN: 93.914 HIV Emergency Relief Project Grants ALN: 97.036 Public Assistance - Presidentially Declared Disaster Criteria - The Uniform Guidance in 2 CFR Section 200.512, Report Submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor?s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Condition ? The District did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended September 30, 2022. Questioned Costs ? None. Context ? This is a condition identified per review of the District?s compliance with the specified requirements. Effect ? The District could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Cause ? The District did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe. Recommendation ? We recommend that the District closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? The District concurs with the auditor?s findings and recommendations. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-024 Prior Year Finding Number: N/A Compliance Requirement: Data Collection Form and Single Audit Reporting Package Programs: ALN: 10.551, 10.561 Supplemental Nutrition Assistance Program Cluster ALN: 10.553, 10.555, 10.559, 10.582 Child Nutrition Cluster ALN: 10.558 Child and Adult Care Food Program ALN: 14.218 Community Development Block Grants/Entitlement Grants Cluster ALN: 21.023 COVID-19 ? Emergency Rental Assistance Program ALN: 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Relief Funds ALN: 84.027, 84.173 Special Education Cluster ALN: 84.126 Rehabilitation Services - Vocational Rehabilitation Grants to States ALN: 84.425 COVID-19 ? Education Stabilization Fund ALN: 93.268 Immunization Cooperative Agreements ALN: 93.498 COVID-19 ? Provider Relief Fund ALN: 93.558 Temporary Assistance for Needy Families ALN: 93.568 Low Income Home Energy Assistance ALN: 93.569 Community Services Block Grant ALN: 93.658 Foster Care ? Title IV-E ALN: 93.775, 93.777, 93.778 Medicaid Cluster ALN: 93.914 HIV Emergency Relief Project Grants ALN: 97.036 Public Assistance - Presidentially Declared Disaster Criteria - The Uniform Guidance in 2 CFR Section 200.512, Report Submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor?s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Condition ? The District did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended September 30, 2022. Questioned Costs ? None. Context ? This is a condition identified per review of the District?s compliance with the specified requirements. Effect ? The District could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Cause ? The District did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe. Recommendation ? We recommend that the District closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? The District concurs with the auditor?s findings and recommendations. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-024 Prior Year Finding Number: N/A Compliance Requirement: Data Collection Form and Single Audit Reporting Package Programs: ALN: 10.551, 10.561 Supplemental Nutrition Assistance Program Cluster ALN: 10.553, 10.555, 10.559, 10.582 Child Nutrition Cluster ALN: 10.558 Child and Adult Care Food Program ALN: 14.218 Community Development Block Grants/Entitlement Grants Cluster ALN: 21.023 COVID-19 ? Emergency Rental Assistance Program ALN: 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Relief Funds ALN: 84.027, 84.173 Special Education Cluster ALN: 84.126 Rehabilitation Services - Vocational Rehabilitation Grants to States ALN: 84.425 COVID-19 ? Education Stabilization Fund ALN: 93.268 Immunization Cooperative Agreements ALN: 93.498 COVID-19 ? Provider Relief Fund ALN: 93.558 Temporary Assistance for Needy Families ALN: 93.568 Low Income Home Energy Assistance ALN: 93.569 Community Services Block Grant ALN: 93.658 Foster Care ? Title IV-E ALN: 93.775, 93.777, 93.778 Medicaid Cluster ALN: 93.914 HIV Emergency Relief Project Grants ALN: 97.036 Public Assistance - Presidentially Declared Disaster Criteria - The Uniform Guidance in 2 CFR Section 200.512, Report Submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor?s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Condition ? The District did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended September 30, 2022. Questioned Costs ? None. Context ? This is a condition identified per review of the District?s compliance with the specified requirements. Effect ? The District could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Cause ? The District did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe. Recommendation ? We recommend that the District closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? The District concurs with the auditor?s findings and recommendations. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-004 Prior Year Finding Number: 2021-004 Compliance Requirement: Eligibility Program: U.S. Department of the Treasury COVID-19 ? Emergency Rental Assistance (ERA) Program ALN: 21.023 Award #: N/A Award Year: 12/27/2020 ? 09/30/2025 Government Department/Agency: Department of Human Services Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. The Treasury Department ERA FAQ 8-25-21, question 1, states that grantees must require all applications for assistance to include an attestation from the applicant that all information included is correct and complete. The Treasury Department ERA FAQ 8-25-21, question 4, states that the statutes establishing ERA1 and ERA2 limit eligibility to households based on certain income criteria. For purposes of ERA1, the area median income for a household is the same as the income limits for families published by the Department of Housing and Urban Development (HUD) in accordance with 42 U.S.C. 1437a(b)(2), available under the heading for ?Access Individual Income Limits Areas? at https://www.huduser.gov/portal/datasets/il.html. If a grantee in ERA1 uses a household?s monthly income to determine eligibility, the grantee should review the monthly income information provided at the time of application and extrapolate over a 12-month period to determine whether household income exceeds 80 percent of area median income. For example, if the applicant provides income information for two months, the grantee should multiply it by six to determine the annual amount. If a household qualifies based on monthly income, the grantee must redetermine the household income eligibility every three months for the duration of assistance. Grantees in ERA1 and ERA2 must have a reasonable basis under the circumstances for determining income. A grantee may support its determination with both a written attestation from the applicant as to household income and also documentation available to the applicant, such as paystubs, W-2s or other wage statements, tax filings, bank statements demonstrating regular income, or an attestation from an employer. In appropriate cases, grantees may rely on an attestation from a caseworker or other professional with knowledge of a household?s circumstances to certify that an applicant?s household income qualifies for assistance. Under categorical eligibility, if an applicant?s household income has been verified to be at or below 80 percent of the area median income (for ERA1) or if an applicant?s household has been verified as a low-income family as defined in section 3(b) of the United States Housing Act of 1937 (42 U.S.C. 1437a(b)) (for ERA2) in connection with another local, state, or federal government assistance program, grantees are permitted to rely on a determination letter from the government agency that verified the applicant?s household income or status as a low-income family, provided that the determination for such program was made on or after January 1, 2020. The Treasury Department ERA FAQ 8-25-21, question 5, states grantees must obtain, if available, a current lease, signed by the applicant and the landlord or sublessor, that identifies the unit where the applicant resides and establishes the rental payment amount. If a household does not have a signed lease, documentation of residence may include evidence of paying utilities for the residential unit, an attestation by a landlord who can be identified as the verified owner or management agent of the unit, or other reasonable documentation as determined by the grantee. In the absence of a signed lease, evidence of the amount of a rental payment may include bank statements, check stubs, or other documentation that reasonably establishes a pattern of paying rent, a written attestation by a landlord who can be verified as the legitimate owner or management agent of the unit, or other reasonable documentation as defined by the grantee in its policies and procedures. Condition ? During testing over rental and utility beneficiary eligibility for the Emergency Rental Assistance Program, we noted that the District Department of Human Services, Family Services Agency (FSA) (?the Agency?) was unable to provide sufficient documentation to support the beneficiaries? determination for rent paid and utility payments during the fiscal year 2022 audit. Specifically, out of a sample of 60 transactions tested, we noted the following exceptions: ? For one (1) participant, in the participant?s second application, the Agency paid $4,011 in rental assistance for the months from October to December 2021. Per further review of the applicant?s history, in the initial application, the Agency paid rent for eight months (April to November 2021) with rent ranging from $610 to $1,360. The approval of the second application resulted in improper double payment for the months of October and November 2021 totaling $2,674, representing known questioned costs. ? For one (1) participant, the amount the Agency paid for rental assistance did not agree to the documentation provided. The rental agreement of $1,635 did not match the payment of $1,798 per month for three months. The total payment not supported totaled $489, representing known questioned costs. ? For one (1) participant, in the initial application, the Agency paid rent for October 2021 totaling $1,600, which was not supported by the agreement which was $1,327. Per further review of the participant?s history, we noted under a second application, the Agency paid $3,297 in rent for the months of November and December 2021, however, per the rent agreement the rent amount supported was $2,654. For the months of October through December 2021, the amount paid for rental assistance totaled $4,897, however the rent amount supported totaled $3,981. The total amount not supported totaled $916, representing known questioned costs. ? For one (1) participant, the amount the Agency paid for utility did not agree to the documentation provided. The utility payment of $1,622 did not agree to the supported amount of $1,509. The total amount not supported totaled $113, representing known questioned costs. ? For six (6) participants, the Agency did not follow their documented policies and procedures such that the rental calculation worksheets were not provided, or these were not signed by the participants or by the housing support provider. During our tests of completeness for the eligibility population we noted payments that were labeled as duplicate payments and payments sent to the wrong recipients, that have not been refunded. Given that the Agency noted that these payments were sent in error, they should not have been included in the schedule of expenditures of federal awards. The total payments sent in error during 2022 totaled $315,572, representing known questioned costs. The DC Department of Human Services, Family Services Agency, lacks a quality control oversight system to ensure that eligibility documentation is maintained to support eligibility decisions. Questioned Costs ? $319,764. Context ? This is a condition identified per review of the Agency?s compliance with specified requirements using a statistically valid sample. Effect ? Lack of supporting documentation for program services and noncompliance with program requirements could result in disallowances of costs and participants could be receiving benefits that they are not entitled to receive under the program. Cause ? The Agency did not appear to adhere to internal control procedures to ensure that applications are properly completed and retained. Recommendation ? We recommend that the Agency strictly implement internal control procedures to ensure that documentation is maintained to support the beneficiary determinations. Related Noncompliance ? Material noncompliance. Views of Responsible Officials and Planned Corrective Actions ? The Department of Human Services (DHS) agrees with the findings that for four (4) STAY DC participants, the amount paid was not fully supported by lease or utility arrears documentation, resulting in improper payments totaling $4,192. DHS will reach out to the payees to formally request the return of improper payments to the District of Columbia. This will be tracked to ensure the return is recorded against ERA within the District?s financial system. DHS agrees with the finding that six (6) participants were missing rental subsidy calculation worksheets or were missing signatures on their rental calculation worksheet. These participants were enrolled in the Family Rehousing and Stabilization Program (FRSP), also known as Rapid Re-housing (RRH). FRSP is a key program within the District?s continuum of care to support families who are experiencing homelessness or are at imminent risk of experiencing homelessness. The rental calculation worksheet is used to determine the amount an FRSP household contributes towards monthly rent based on household income and makeup. The remaining monthly rent is covered by a subsidy, paid out of ERA funds. Gaps in rental subsidy calculation worksheet documentations were due to rapidly expanding caseloads during the pandemic and new safety protocols that required certain changes to case management protocols. To address any documentation gaps, DHS introduced new Standard Operating Procedures (SOPs) for FRSP in fiscal year 2023. The new SOP implements stricter internal control procedures, conducting regular audits, and streamlining the eligibility determination process. DHS agrees with the finding that $315,572 in STAY DC payments were sent in error during 2022. In Jan. 2023, DHS conducted an in-depth review of the STAY DC program comparing every rental assistance payment made via the District?s financial management system to applications approved for payment by the STAY DC program. This process reviewed $120.1M in fiscal year 2022 STAY DC rental assistance payments and identified $315.6K of payments made in error that were not later refunded to the District. The District will reclass all identified errored payments off of the ERA fund to Local funds by the closeout of fiscal year 2023, Sept. 30, 2023. DHS also completed a reconciliation of data reported to U.S. Treasury for ERA1 closeout reporting and ERA2 2023 Q2 reporting to ensure that no errored payments were included in reported data. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-005 Prior Year Finding Number: 2021-005 Compliance Requirement: Reporting Program: U.S. Department of the Treasury COVID-19 ? Emergency Rental Assistance (ERA) Program ALN: 21.023 Award #: N/A Award Year: 12/27/2020 ? 09/30/2025 Government Department/Agency: Department of Human Services Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR Section 200.328 Financial Reporting: ?Unless otherwise approved by OMB, the Federal awarding agency must solicit only the OMB-approved governmentwide data elements for collection of financial information (at time of publication the Federal Financial Report or such future, OMB-approved, governmentwide data elements available from the OMB-designated standards lead. This information must be collected with the frequency required by the terms and conditions of the Federal award, but no less frequently than annually nor more frequently than quarterly except in unusual circumstances, for example where more frequent reporting is necessary for the effective monitoring of the Federal award or could significantly affect program outcomes, and preferably in coordination with performance reporting. The Federal awarding agency must use OMB-approved common information collections, as applicable, when providing financial and performance reporting information.? The 2022 Compliance Supplement outlines the Special Reports required under the Emergency Rental Assistances program, and the key data elements, and the submission requirements. The Reporting Guidance is located on the Treasury?s website for the ERA program. Monthly Special Reports were required to be submitted on a monthly basis, beginning in April 2021 for ERA1 and June 2021 for ERA2, generally by the 15th of the following month unless otherwise specified within the Reporting Guidance. As outlined in the 2022 Compliance Supplement, the key data elements for the monthly reports included (1) the total number of participant households that received ERA assistance of any kind and (2) the total amount of ERA funds expended by the ERA grantee to or for participating households on behalf of eligible households. The program also requires ERA recipients to certify the reports submitted. As outlined in the 2022 Compliance Supplement, the key data elements for the quarterly reports included (1) the cumulative amount obligated by the grantee; and (2) the cumulative amount expended by the grantee. The program also requires ERA recipients to certify the reports submitted. Condition ? We noted the following for one of nine quarterly and monthly reports tested: ? For one quarterly report (the ERA1 Quarter 1 2022 Report), the key data elements (1) the cumulative amount obligated by the grantee; and (2) the cumulative amount expended by the grantee were not included in the quarterly report. Questioned Costs ? None. Context ? This is a condition identified per review of the Department of Human Services? compliance with specified requirements using a statistically valid sample. Effect ? Without proper internal controls and policies and procedures in place, the required financial and special reports are either not submitted or not submitted with accurate information. Cause ? Per discussion with management, it was noted that at the time the report was submitted they didn?t have access to key data elements to be input into the quarterly report. However, BDO could not verify that this was the case as there was no documentation around the same. Management did not establish controls to make sure that all the required information as noted in the compliance supplement was submitted to the Treasury Department. Recommendation ? We recommend that the Department of Human Services fully implement its current corrective action plan to deploy policies and procedures and controls to ensure reports are submitted with accurate information. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? The Department of Human Services (DHS) concurs with the finding that we could not substantiate that cumulative expenditure and obligation data were included in the ERA1 Quarter 1 2022 Report, which was submitted on April 15, 2022 in the U.S. Department of the Treasury?s COVID-19 Relief Hub reporting portal. DHS believes that updates in the reporting format and fields caused this issue. U.S. Treasury Reporting staff has confirmed that when new fields are added or changed to reports within the reporting portal, these changes override prior submitted reports. In response to a similar finding for the fiscal year 2021 ERA single audit where original submission data was overridden by formatting updates, DHS began saving screen shots of reported data within Treasury?s reporting portal. This practice began in June 2022 and will continue for the duration of the ERA program, through ERA2 closeout reporting. This will ensure that even if Treasury reporting portal functionality changes in the future, there is clear supporting documentation of the information submitted. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-024 Prior Year Finding Number: N/A Compliance Requirement: Data Collection Form and Single Audit Reporting Package Programs: ALN: 10.551, 10.561 Supplemental Nutrition Assistance Program Cluster ALN: 10.553, 10.555, 10.559, 10.582 Child Nutrition Cluster ALN: 10.558 Child and Adult Care Food Program ALN: 14.218 Community Development Block Grants/Entitlement Grants Cluster ALN: 21.023 COVID-19 ? Emergency Rental Assistance Program ALN: 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Relief Funds ALN: 84.027, 84.173 Special Education Cluster ALN: 84.126 Rehabilitation Services - Vocational Rehabilitation Grants to States ALN: 84.425 COVID-19 ? Education Stabilization Fund ALN: 93.268 Immunization Cooperative Agreements ALN: 93.498 COVID-19 ? Provider Relief Fund ALN: 93.558 Temporary Assistance for Needy Families ALN: 93.568 Low Income Home Energy Assistance ALN: 93.569 Community Services Block Grant ALN: 93.658 Foster Care ? Title IV-E ALN: 93.775, 93.777, 93.778 Medicaid Cluster ALN: 93.914 HIV Emergency Relief Project Grants ALN: 97.036 Public Assistance - Presidentially Declared Disaster Criteria - The Uniform Guidance in 2 CFR Section 200.512, Report Submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor?s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Condition ? The District did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended September 30, 2022. Questioned Costs ? None. Context ? This is a condition identified per review of the District?s compliance with the specified requirements. Effect ? The District could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Cause ? The District did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe. Recommendation ? We recommend that the District closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? The District concurs with the auditor?s findings and recommendations. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-006 Prior Year Finding Number: N/A Compliance Requirement: Reporting Program: U.S. Department of the Treasury COVID-19 ? Coronavirus State and Local Fiscal Recovery Funds ALN: 21.027 Award #: N/A Award Year: 10/01/2021 ? 09/20/2022 Government Department/Agency: Office of the Chief Financial Officer (OCFO) Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. The Uniform Guidance in 2 CFR Section 2 CFR Section 200.302(a), Financial Management, states that each state must expend and account for the federal award in accordance with state laws and procedures for expending and accounting for the state?s own funds. In addition, the state?s and the other non-federal entity?s financial management systems, including records documenting compliance with federal statutes, regulations, and the terms and conditions of the federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the federal statutes, regulations, and the terms and conditions of the federal award. Condition ? Certain grant expenditures related to the PAY-AS-You-Go (PAYGO Capital) program, amounting to approximately $36.4 million, had erroneously been reflected as expenditures under assistance listing number 21.027, COVID-19 - Coronavirus State and Local Fiscal Recovery Funds. Subsequently, OCFO adjusted the SEFA to reflect the actual amount of expenditures incurred for the program. Questioned Costs ? None. Context ? This is a condition identified per review of the OCFO?s compliance with the specified requirements. Effect ? OCFO is not in compliance with the stated provisions. Failure to properly review and support expenditures can result in noncompliance with laws and regulations along with loss of funding. Cause ? OCFO did not appear to have adequate policies and procedures in place to ensure accuracy of the SEFA. Recommendation ? We recommend that OCFO adhere to instituted policies and procedures to ensure the accuracy of the SEFA. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? OCFO concurs with the finding. In the compilation and reconciliation of the SEFA, the PAYGO ARPA Local Revenue Replacement expenditures component was inadvertently included in the draft District fiscal year 2022 SEFA presented to the external auditors. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-024 Prior Year Finding Number: N/A Compliance Requirement: Data Collection Form and Single Audit Reporting Package Programs: ALN: 10.551, 10.561 Supplemental Nutrition Assistance Program Cluster ALN: 10.553, 10.555, 10.559, 10.582 Child Nutrition Cluster ALN: 10.558 Child and Adult Care Food Program ALN: 14.218 Community Development Block Grants/Entitlement Grants Cluster ALN: 21.023 COVID-19 ? Emergency Rental Assistance Program ALN: 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Relief Funds ALN: 84.027, 84.173 Special Education Cluster ALN: 84.126 Rehabilitation Services - Vocational Rehabilitation Grants to States ALN: 84.425 COVID-19 ? Education Stabilization Fund ALN: 93.268 Immunization Cooperative Agreements ALN: 93.498 COVID-19 ? Provider Relief Fund ALN: 93.558 Temporary Assistance for Needy Families ALN: 93.568 Low Income Home Energy Assistance ALN: 93.569 Community Services Block Grant ALN: 93.658 Foster Care ? Title IV-E ALN: 93.775, 93.777, 93.778 Medicaid Cluster ALN: 93.914 HIV Emergency Relief Project Grants ALN: 97.036 Public Assistance - Presidentially Declared Disaster Criteria - The Uniform Guidance in 2 CFR Section 200.512, Report Submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor?s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Condition ? The District did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended September 30, 2022. Questioned Costs ? None. Context ? This is a condition identified per review of the District?s compliance with the specified requirements. Effect ? The District could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Cause ? The District did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe. Recommendation ? We recommend that the District closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? The District concurs with the auditor?s findings and recommendations. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-024 Prior Year Finding Number: N/A Compliance Requirement: Data Collection Form and Single Audit Reporting Package Programs: ALN: 10.551, 10.561 Supplemental Nutrition Assistance Program Cluster ALN: 10.553, 10.555, 10.559, 10.582 Child Nutrition Cluster ALN: 10.558 Child and Adult Care Food Program ALN: 14.218 Community Development Block Grants/Entitlement Grants Cluster ALN: 21.023 COVID-19 ? Emergency Rental Assistance Program ALN: 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Relief Funds ALN: 84.027, 84.173 Special Education Cluster ALN: 84.126 Rehabilitation Services - Vocational Rehabilitation Grants to States ALN: 84.425 COVID-19 ? Education Stabilization Fund ALN: 93.268 Immunization Cooperative Agreements ALN: 93.498 COVID-19 ? Provider Relief Fund ALN: 93.558 Temporary Assistance for Needy Families ALN: 93.568 Low Income Home Energy Assistance ALN: 93.569 Community Services Block Grant ALN: 93.658 Foster Care ? Title IV-E ALN: 93.775, 93.777, 93.778 Medicaid Cluster ALN: 93.914 HIV Emergency Relief Project Grants ALN: 97.036 Public Assistance - Presidentially Declared Disaster Criteria - The Uniform Guidance in 2 CFR Section 200.512, Report Submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor?s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Condition ? The District did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended September 30, 2022. Questioned Costs ? None. Context ? This is a condition identified per review of the District?s compliance with the specified requirements. Effect ? The District could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Cause ? The District did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe. Recommendation ? We recommend that the District closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? The District concurs with the auditor?s findings and recommendations. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-024 Prior Year Finding Number: N/A Compliance Requirement: Data Collection Form and Single Audit Reporting Package Programs: ALN: 10.551, 10.561 Supplemental Nutrition Assistance Program Cluster ALN: 10.553, 10.555, 10.559, 10.582 Child Nutrition Cluster ALN: 10.558 Child and Adult Care Food Program ALN: 14.218 Community Development Block Grants/Entitlement Grants Cluster ALN: 21.023 COVID-19 ? Emergency Rental Assistance Program ALN: 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Relief Funds ALN: 84.027, 84.173 Special Education Cluster ALN: 84.126 Rehabilitation Services - Vocational Rehabilitation Grants to States ALN: 84.425 COVID-19 ? Education Stabilization Fund ALN: 93.268 Immunization Cooperative Agreements ALN: 93.498 COVID-19 ? Provider Relief Fund ALN: 93.558 Temporary Assistance for Needy Families ALN: 93.568 Low Income Home Energy Assistance ALN: 93.569 Community Services Block Grant ALN: 93.658 Foster Care ? Title IV-E ALN: 93.775, 93.777, 93.778 Medicaid Cluster ALN: 93.914 HIV Emergency Relief Project Grants ALN: 97.036 Public Assistance - Presidentially Declared Disaster Criteria - The Uniform Guidance in 2 CFR Section 200.512, Report Submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor?s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Condition ? The District did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended September 30, 2022. Questioned Costs ? None. Context ? This is a condition identified per review of the District?s compliance with the specified requirements. Effect ? The District could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Cause ? The District did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe. Recommendation ? We recommend that the District closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? The District concurs with the auditor?s findings and recommendations. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-024 Prior Year Finding Number: N/A Compliance Requirement: Data Collection Form and Single Audit Reporting Package Programs: ALN: 10.551, 10.561 Supplemental Nutrition Assistance Program Cluster ALN: 10.553, 10.555, 10.559, 10.582 Child Nutrition Cluster ALN: 10.558 Child and Adult Care Food Program ALN: 14.218 Community Development Block Grants/Entitlement Grants Cluster ALN: 21.023 COVID-19 ? Emergency Rental Assistance Program ALN: 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Relief Funds ALN: 84.027, 84.173 Special Education Cluster ALN: 84.126 Rehabilitation Services - Vocational Rehabilitation Grants to States ALN: 84.425 COVID-19 ? Education Stabilization Fund ALN: 93.268 Immunization Cooperative Agreements ALN: 93.498 COVID-19 ? Provider Relief Fund ALN: 93.558 Temporary Assistance for Needy Families ALN: 93.568 Low Income Home Energy Assistance ALN: 93.569 Community Services Block Grant ALN: 93.658 Foster Care ? Title IV-E ALN: 93.775, 93.777, 93.778 Medicaid Cluster ALN: 93.914 HIV Emergency Relief Project Grants ALN: 97.036 Public Assistance - Presidentially Declared Disaster Criteria - The Uniform Guidance in 2 CFR Section 200.512, Report Submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor?s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Condition ? The District did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended September 30, 2022. Questioned Costs ? None. Context ? This is a condition identified per review of the District?s compliance with the specified requirements. Effect ? The District could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Cause ? The District did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe. Recommendation ? We recommend that the District closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? The District concurs with the auditor?s findings and recommendations. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-024 Prior Year Finding Number: N/A Compliance Requirement: Data Collection Form and Single Audit Reporting Package Programs: ALN: 10.551, 10.561 Supplemental Nutrition Assistance Program Cluster ALN: 10.553, 10.555, 10.559, 10.582 Child Nutrition Cluster ALN: 10.558 Child and Adult Care Food Program ALN: 14.218 Community Development Block Grants/Entitlement Grants Cluster ALN: 21.023 COVID-19 ? Emergency Rental Assistance Program ALN: 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Relief Funds ALN: 84.027, 84.173 Special Education Cluster ALN: 84.126 Rehabilitation Services - Vocational Rehabilitation Grants to States ALN: 84.425 COVID-19 ? Education Stabilization Fund ALN: 93.268 Immunization Cooperative Agreements ALN: 93.498 COVID-19 ? Provider Relief Fund ALN: 93.558 Temporary Assistance for Needy Families ALN: 93.568 Low Income Home Energy Assistance ALN: 93.569 Community Services Block Grant ALN: 93.658 Foster Care ? Title IV-E ALN: 93.775, 93.777, 93.778 Medicaid Cluster ALN: 93.914 HIV Emergency Relief Project Grants ALN: 97.036 Public Assistance - Presidentially Declared Disaster Criteria - The Uniform Guidance in 2 CFR Section 200.512, Report Submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor?s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Condition ? The District did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended September 30, 2022. Questioned Costs ? None. Context ? This is a condition identified per review of the District?s compliance with the specified requirements. Effect ? The District could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Cause ? The District did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe. Recommendation ? We recommend that the District closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? The District concurs with the auditor?s findings and recommendations. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-024 Prior Year Finding Number: N/A Compliance Requirement: Data Collection Form and Single Audit Reporting Package Programs: ALN: 10.551, 10.561 Supplemental Nutrition Assistance Program Cluster ALN: 10.553, 10.555, 10.559, 10.582 Child Nutrition Cluster ALN: 10.558 Child and Adult Care Food Program ALN: 14.218 Community Development Block Grants/Entitlement Grants Cluster ALN: 21.023 COVID-19 ? Emergency Rental Assistance Program ALN: 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Relief Funds ALN: 84.027, 84.173 Special Education Cluster ALN: 84.126 Rehabilitation Services - Vocational Rehabilitation Grants to States ALN: 84.425 COVID-19 ? Education Stabilization Fund ALN: 93.268 Immunization Cooperative Agreements ALN: 93.498 COVID-19 ? Provider Relief Fund ALN: 93.558 Temporary Assistance for Needy Families ALN: 93.568 Low Income Home Energy Assistance ALN: 93.569 Community Services Block Grant ALN: 93.658 Foster Care ? Title IV-E ALN: 93.775, 93.777, 93.778 Medicaid Cluster ALN: 93.914 HIV Emergency Relief Project Grants ALN: 97.036 Public Assistance - Presidentially Declared Disaster Criteria - The Uniform Guidance in 2 CFR Section 200.512, Report Submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor?s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Condition ? The District did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended September 30, 2022. Questioned Costs ? None. Context ? This is a condition identified per review of the District?s compliance with the specified requirements. Effect ? The District could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Cause ? The District did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe. Recommendation ? We recommend that the District closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? The District concurs with the auditor?s findings and recommendations. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-007 Prior Year Finding Number: 2021-008 Compliance Requirement: Equipment and Real Property Management Program: U.S. Department of Education COVID-19 ? Education Stabilization Fund Elementary and Secondary School Emergency Relief (ESSER) Fund ALN: 84.425D Award #: S425D210034 Award Year: 01/05/2021 ? 09/30/2022 COVID-19 ? Education Stabilization Fund American Rescue Plan - Elementary and Secondary Schools Emergency Relief Fund (ARP-ESSER) ALN: 84.425U Award #: S425U210034-21A Award Year: 03/24/2021 ? 09/30/2023 Government Department/Agency: District of Columbia Public Schools Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Additionally, per the Uniform Guidance in 2 CFR Section 200.313, Equipment, property records must be maintained that include a description of the property, a 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, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property. Further, a physical inventory of the property must be taken and the results reconciled with the property records at least once every two years (2 CFR section 200.313(d)(2)). Condition ? We noted that DCPS has a policy to track and maintain a list of equipment purchased using federal funds with a single unit cost of $200 or more; and to conduct periodic equipment inventory count twice a year. Of the 56 out of 60 samples tested for equipment real property management requirements, we noted that: (1) Equipment purchased using federal funds with a single unit cost of $200 or more is tracked in the TIPWeb-IT system; however, there is no linkage between assets tracked in TIPWeb-IT and the funding source or Purchase Order. As a result, we were not able to verify that the equipment purchased using federal funds was being tracked in the TIPWeb-IT system. (2) There is no separate listing of equipment purchased using federal funds being maintained. (3) No physical inventory count was performed for equipment purchased using federal funds in 2022. Questioned Costs ? Not determinable. Context ? This is a condition identified per review of District of Columbia Public School (DCPS)?s compliance with the specified requirements using a statistically valid sample. Effect ? There is a risk that inadequate recordkeeping of equipment could lead to misappropriation of assets and noncompliance with Federal regulations resulting in a return of Federal awards received. Cause ? Due to a lack of linkage between procurement systems and asset management systems and COVID related concerns, DCPS was unable to adequately support compliance with its policies and procedures regarding monitoring of equipment acquired with Federal funds. Recommendation ? We recommend that DCPS implement policies, procedures and controls that will ensure that equipment purchased using federal funds are tracked and maintained, in order to adhere to Federal regulations related to equipment and its related maintenance. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? The District of Columbia Public School (DCPS) agrees with the conditions and recommendations of this finding. While DCPS has implemented and follows stringent asset procurement and management policies, we have adopted separate systems to track the purchasing, receiving, and the lifecycle of assets. The Procurement and ERP systems, PASS/SOAR are used to track purchases of assets, while the Warehouse receiving system captures a record of assets received by DCPS. The DCPS?s Asset Management System, TIPWeb tracks a device throughout its lifecycle (deployment/assignment, condition, location, disposal, etc.). This split system functionality contributes to the conditions noted in the audit findings. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-024 Prior Year Finding Number: N/A Compliance Requirement: Data Collection Form and Single Audit Reporting Package Programs: ALN: 10.551, 10.561 Supplemental Nutrition Assistance Program Cluster ALN: 10.553, 10.555, 10.559, 10.582 Child Nutrition Cluster ALN: 10.558 Child and Adult Care Food Program ALN: 14.218 Community Development Block Grants/Entitlement Grants Cluster ALN: 21.023 COVID-19 ? Emergency Rental Assistance Program ALN: 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Relief Funds ALN: 84.027, 84.173 Special Education Cluster ALN: 84.126 Rehabilitation Services - Vocational Rehabilitation Grants to States ALN: 84.425 COVID-19 ? Education Stabilization Fund ALN: 93.268 Immunization Cooperative Agreements ALN: 93.498 COVID-19 ? Provider Relief Fund ALN: 93.558 Temporary Assistance for Needy Families ALN: 93.568 Low Income Home Energy Assistance ALN: 93.569 Community Services Block Grant ALN: 93.658 Foster Care ? Title IV-E ALN: 93.775, 93.777, 93.778 Medicaid Cluster ALN: 93.914 HIV Emergency Relief Project Grants ALN: 97.036 Public Assistance - Presidentially Declared Disaster Criteria - The Uniform Guidance in 2 CFR Section 200.512, Report Submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor?s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Condition ? The District did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended September 30, 2022. Questioned Costs ? None. Context ? This is a condition identified per review of the District?s compliance with the specified requirements. Effect ? The District could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Cause ? The District did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe. Recommendation ? We recommend that the District closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? The District concurs with the auditor?s findings and recommendations. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-008 Prior Year Finding Number: 2021-010 Compliance Requirement: Reporting Program: U.S. Department of Education COVID-19 ? Education Stabilization Fund Higher Education Emergency Relief Fund (HEERF) Student Aid Portion ALN #: 84.425E Award #: P425E201913 - 20B Award Year: 04/24/2020 ? 06/30/2023 COVID-19 ? Education Stabilization Fund HEERF Institutional Aid Portion ALN: 84.425F Award #: P425F202580 - 20B Award Year: 05/07/2020 ? 06/30/2023 COVID-19 ? Education Stabilization Fund HEERF Historically Black Colleges and Universities (HBCUs) ALN: 84.425J Award #: P425J200098 - 20C Award Year: 05/01/2020 ? 06/30/2023 Government Department/Agency: University of the District of Columbia Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. There are three components to reporting for HEERF: 1) public reporting on the (a)(1) Student Aid Portion; 2) public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Reporting Form), as applicable; and 3) the annual report. The CARES Act 18004(e) and the Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA) 314(e) requires an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such time in such a manner as the secretary may require. While ARP does not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, Education Department exercises this reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329. Condition ? During our testing of the quarterly public reporting requirements for HEERF Student Aid Portion and HEERF Institutional Portion, we noted the following: ? For three (3) out of six (6) reports, University of the District of Columbia (UDC) was not able to provide evidence of the timely posting of the quarterly public reports to the UDC website because the webmaster?s web posting audit log, which expires after 60 days, had not been retained by UDC. ? For three (3) out of six (6) reports, UDC was not able to provide evidence that the quarterly public reports were reviewed prior to posting to the UDC website because the evidence had not been retained by UDC. UDC implemented its corrective action plan on June 30, 2022, and the exceptions identified above relate to reporting transactions made prior to the above-mentioned implementation date. We also examined one report made post the above-mentioned implementation date and we noted that UDC had kept all evidence of review of the report and the evidence of the report being published in the UDC website. Questioned Costs ? None. Context ? This is a condition identified per review of UDC?s compliance with specified reporting requirements related to the program using a statistically valid sample. Effect ? Without adequate controls in place to ensure that reports are posted timely and proof that the reports were reviewed leads to noncompliance of the reporting requirements under the program. Cause ? UDC does not have adequate controls in place to ensure that documents are maintained related to the review and the timely posting of reports to the UDC website. Recommendation ? We recommend for UDC to continue to maintain documentation of the timely submission of reports and proof of review of reports as required to ensure compliance with reporting requirements. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? UDC OCFO agrees with the conditions and recommendations of this finding. As noted in the condition above, UDC implemented corrective action to remediate the conditions and recommendations reported in the prior year when findings were issued. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-024 Prior Year Finding Number: N/A Compliance Requirement: Data Collection Form and Single Audit Reporting Package Programs: ALN: 10.551, 10.561 Supplemental Nutrition Assistance Program Cluster ALN: 10.553, 10.555, 10.559, 10.582 Child Nutrition Cluster ALN: 10.558 Child and Adult Care Food Program ALN: 14.218 Community Development Block Grants/Entitlement Grants Cluster ALN: 21.023 COVID-19 ? Emergency Rental Assistance Program ALN: 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Relief Funds ALN: 84.027, 84.173 Special Education Cluster ALN: 84.126 Rehabilitation Services - Vocational Rehabilitation Grants to States ALN: 84.425 COVID-19 ? Education Stabilization Fund ALN: 93.268 Immunization Cooperative Agreements ALN: 93.498 COVID-19 ? Provider Relief Fund ALN: 93.558 Temporary Assistance for Needy Families ALN: 93.568 Low Income Home Energy Assistance ALN: 93.569 Community Services Block Grant ALN: 93.658 Foster Care ? Title IV-E ALN: 93.775, 93.777, 93.778 Medicaid Cluster ALN: 93.914 HIV Emergency Relief Project Grants ALN: 97.036 Public Assistance - Presidentially Declared Disaster Criteria - The Uniform Guidance in 2 CFR Section 200.512, Report Submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor?s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Condition ? The District did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended September 30, 2022. Questioned Costs ? None. Context ? This is a condition identified per review of the District?s compliance with the specified requirements. Effect ? The District could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Cause ? The District did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe. Recommendation ? We recommend that the District closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? The District concurs with the auditor?s findings and recommendations. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-008 Prior Year Finding Number: 2021-010 Compliance Requirement: Reporting Program: U.S. Department of Education COVID-19 ? Education Stabilization Fund Higher Education Emergency Relief Fund (HEERF) Student Aid Portion ALN #: 84.425E Award #: P425E201913 - 20B Award Year: 04/24/2020 ? 06/30/2023 COVID-19 ? Education Stabilization Fund HEERF Institutional Aid Portion ALN: 84.425F Award #: P425F202580 - 20B Award Year: 05/07/2020 ? 06/30/2023 COVID-19 ? Education Stabilization Fund HEERF Historically Black Colleges and Universities (HBCUs) ALN: 84.425J Award #: P425J200098 - 20C Award Year: 05/01/2020 ? 06/30/2023 Government Department/Agency: University of the District of Columbia Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. There are three components to reporting for HEERF: 1) public reporting on the (a)(1) Student Aid Portion; 2) public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Reporting Form), as applicable; and 3) the annual report. The CARES Act 18004(e) and the Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA) 314(e) requires an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such time in such a manner as the secretary may require. While ARP does not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, Education Department exercises this reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329. Condition ? During our testing of the quarterly public reporting requirements for HEERF Student Aid Portion and HEERF Institutional Portion, we noted the following: ? For three (3) out of six (6) reports, University of the District of Columbia (UDC) was not able to provide evidence of the timely posting of the quarterly public reports to the UDC website because the webmaster?s web posting audit log, which expires after 60 days, had not been retained by UDC. ? For three (3) out of six (6) reports, UDC was not able to provide evidence that the quarterly public reports were reviewed prior to posting to the UDC website because the evidence had not been retained by UDC. UDC implemented its corrective action plan on June 30, 2022, and the exceptions identified above relate to reporting transactions made prior to the above-mentioned implementation date. We also examined one report made post the above-mentioned implementation date and we noted that UDC had kept all evidence of review of the report and the evidence of the report being published in the UDC website. Questioned Costs ? None. Context ? This is a condition identified per review of UDC?s compliance with specified reporting requirements related to the program using a statistically valid sample. Effect ? Without adequate controls in place to ensure that reports are posted timely and proof that the reports were reviewed leads to noncompliance of the reporting requirements under the program. Cause ? UDC does not have adequate controls in place to ensure that documents are maintained related to the review and the timely posting of reports to the UDC website. Recommendation ? We recommend for UDC to continue to maintain documentation of the timely submission of reports and proof of review of reports as required to ensure compliance with reporting requirements. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? UDC OCFO agrees with the conditions and recommendations of this finding. As noted in the condition above, UDC implemented corrective action to remediate the conditions and recommendations reported in the prior year when findings were issued. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-024 Prior Year Finding Number: N/A Compliance Requirement: Data Collection Form and Single Audit Reporting Package Programs: ALN: 10.551, 10.561 Supplemental Nutrition Assistance Program Cluster ALN: 10.553, 10.555, 10.559, 10.582 Child Nutrition Cluster ALN: 10.558 Child and Adult Care Food Program ALN: 14.218 Community Development Block Grants/Entitlement Grants Cluster ALN: 21.023 COVID-19 ? Emergency Rental Assistance Program ALN: 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Relief Funds ALN: 84.027, 84.173 Special Education Cluster ALN: 84.126 Rehabilitation Services - Vocational Rehabilitation Grants to States ALN: 84.425 COVID-19 ? Education Stabilization Fund ALN: 93.268 Immunization Cooperative Agreements ALN: 93.498 COVID-19 ? Provider Relief Fund ALN: 93.558 Temporary Assistance for Needy Families ALN: 93.568 Low Income Home Energy Assistance ALN: 93.569 Community Services Block Grant ALN: 93.658 Foster Care ? Title IV-E ALN: 93.775, 93.777, 93.778 Medicaid Cluster ALN: 93.914 HIV Emergency Relief Project Grants ALN: 97.036 Public Assistance - Presidentially Declared Disaster Criteria - The Uniform Guidance in 2 CFR Section 200.512, Report Submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor?s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Condition ? The District did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended September 30, 2022. Questioned Costs ? None. Context ? This is a condition identified per review of the District?s compliance with the specified requirements. Effect ? The District could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Cause ? The District did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe. Recommendation ? We recommend that the District closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? The District concurs with the auditor?s findings and recommendations. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-008 Prior Year Finding Number: 2021-010 Compliance Requirement: Reporting Program: U.S. Department of Education COVID-19 ? Education Stabilization Fund Higher Education Emergency Relief Fund (HEERF) Student Aid Portion ALN #: 84.425E Award #: P425E201913 - 20B Award Year: 04/24/2020 ? 06/30/2023 COVID-19 ? Education Stabilization Fund HEERF Institutional Aid Portion ALN: 84.425F Award #: P425F202580 - 20B Award Year: 05/07/2020 ? 06/30/2023 COVID-19 ? Education Stabilization Fund HEERF Historically Black Colleges and Universities (HBCUs) ALN: 84.425J Award #: P425J200098 - 20C Award Year: 05/01/2020 ? 06/30/2023 Government Department/Agency: University of the District of Columbia Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. There are three components to reporting for HEERF: 1) public reporting on the (a)(1) Student Aid Portion; 2) public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Reporting Form), as applicable; and 3) the annual report. The CARES Act 18004(e) and the Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA) 314(e) requires an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such time in such a manner as the secretary may require. While ARP does not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, Education Department exercises this reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329. Condition ? During our testing of the quarterly public reporting requirements for HEERF Student Aid Portion and HEERF Institutional Portion, we noted the following: ? For three (3) out of six (6) reports, University of the District of Columbia (UDC) was not able to provide evidence of the timely posting of the quarterly public reports to the UDC website because the webmaster?s web posting audit log, which expires after 60 days, had not been retained by UDC. ? For three (3) out of six (6) reports, UDC was not able to provide evidence that the quarterly public reports were reviewed prior to posting to the UDC website because the evidence had not been retained by UDC. UDC implemented its corrective action plan on June 30, 2022, and the exceptions identified above relate to reporting transactions made prior to the above-mentioned implementation date. We also examined one report made post the above-mentioned implementation date and we noted that UDC had kept all evidence of review of the report and the evidence of the report being published in the UDC website. Questioned Costs ? None. Context ? This is a condition identified per review of UDC?s compliance with specified reporting requirements related to the program using a statistically valid sample. Effect ? Without adequate controls in place to ensure that reports are posted timely and proof that the reports were reviewed leads to noncompliance of the reporting requirements under the program. Cause ? UDC does not have adequate controls in place to ensure that documents are maintained related to the review and the timely posting of reports to the UDC website. Recommendation ? We recommend for UDC to continue to maintain documentation of the timely submission of reports and proof of review of reports as required to ensure compliance with reporting requirements. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? UDC OCFO agrees with the conditions and recommendations of this finding. As noted in the condition above, UDC implemented corrective action to remediate the conditions and recommendations reported in the prior year when findings were issued. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-024 Prior Year Finding Number: N/A Compliance Requirement: Data Collection Form and Single Audit Reporting Package Programs: ALN: 10.551, 10.561 Supplemental Nutrition Assistance Program Cluster ALN: 10.553, 10.555, 10.559, 10.582 Child Nutrition Cluster ALN: 10.558 Child and Adult Care Food Program ALN: 14.218 Community Development Block Grants/Entitlement Grants Cluster ALN: 21.023 COVID-19 ? Emergency Rental Assistance Program ALN: 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Relief Funds ALN: 84.027, 84.173 Special Education Cluster ALN: 84.126 Rehabilitation Services - Vocational Rehabilitation Grants to States ALN: 84.425 COVID-19 ? Education Stabilization Fund ALN: 93.268 Immunization Cooperative Agreements ALN: 93.498 COVID-19 ? Provider Relief Fund ALN: 93.558 Temporary Assistance for Needy Families ALN: 93.568 Low Income Home Energy Assistance ALN: 93.569 Community Services Block Grant ALN: 93.658 Foster Care ? Title IV-E ALN: 93.775, 93.777, 93.778 Medicaid Cluster ALN: 93.914 HIV Emergency Relief Project Grants ALN: 97.036 Public Assistance - Presidentially Declared Disaster Criteria - The Uniform Guidance in 2 CFR Section 200.512, Report Submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor?s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Condition ? The District did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended September 30, 2022. Questioned Costs ? None. Context ? This is a condition identified per review of the District?s compliance with the specified requirements. Effect ? The District could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Cause ? The District did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe. Recommendation ? We recommend that the District closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? The District concurs with the auditor?s findings and recommendations. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-024 Prior Year Finding Number: N/A Compliance Requirement: Data Collection Form and Single Audit Reporting Package Programs: ALN: 10.551, 10.561 Supplemental Nutrition Assistance Program Cluster ALN: 10.553, 10.555, 10.559, 10.582 Child Nutrition Cluster ALN: 10.558 Child and Adult Care Food Program ALN: 14.218 Community Development Block Grants/Entitlement Grants Cluster ALN: 21.023 COVID-19 ? Emergency Rental Assistance Program ALN: 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Relief Funds ALN: 84.027, 84.173 Special Education Cluster ALN: 84.126 Rehabilitation Services - Vocational Rehabilitation Grants to States ALN: 84.425 COVID-19 ? Education Stabilization Fund ALN: 93.268 Immunization Cooperative Agreements ALN: 93.498 COVID-19 ? Provider Relief Fund ALN: 93.558 Temporary Assistance for Needy Families ALN: 93.568 Low Income Home Energy Assistance ALN: 93.569 Community Services Block Grant ALN: 93.658 Foster Care ? Title IV-E ALN: 93.775, 93.777, 93.778 Medicaid Cluster ALN: 93.914 HIV Emergency Relief Project Grants ALN: 97.036 Public Assistance - Presidentially Declared Disaster Criteria - The Uniform Guidance in 2 CFR Section 200.512, Report Submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor?s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Condition ? The District did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended September 30, 2022. Questioned Costs ? None. Context ? This is a condition identified per review of the District?s compliance with the specified requirements. Effect ? The District could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Cause ? The District did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe. Recommendation ? We recommend that the District closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? The District concurs with the auditor?s findings and recommendations. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-007 Prior Year Finding Number: 2021-008 Compliance Requirement: Equipment and Real Property Management Program: U.S. Department of Education COVID-19 ? Education Stabilization Fund Elementary and Secondary School Emergency Relief (ESSER) Fund ALN: 84.425D Award #: S425D210034 Award Year: 01/05/2021 ? 09/30/2022 COVID-19 ? Education Stabilization Fund American Rescue Plan - Elementary and Secondary Schools Emergency Relief Fund (ARP-ESSER) ALN: 84.425U Award #: S425U210034-21A Award Year: 03/24/2021 ? 09/30/2023 Government Department/Agency: District of Columbia Public Schools Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Additionally, per the Uniform Guidance in 2 CFR Section 200.313, Equipment, property records must be maintained that include a description of the property, a 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, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property. Further, a physical inventory of the property must be taken and the results reconciled with the property records at least once every two years (2 CFR section 200.313(d)(2)). Condition ? We noted that DCPS has a policy to track and maintain a list of equipment purchased using federal funds with a single unit cost of $200 or more; and to conduct periodic equipment inventory count twice a year. Of the 56 out of 60 samples tested for equipment real property management requirements, we noted that: (1) Equipment purchased using federal funds with a single unit cost of $200 or more is tracked in the TIPWeb-IT system; however, there is no linkage between assets tracked in TIPWeb-IT and the funding source or Purchase Order. As a result, we were not able to verify that the equipment purchased using federal funds was being tracked in the TIPWeb-IT system. (2) There is no separate listing of equipment purchased using federal funds being maintained. (3) No physical inventory count was performed for equipment purchased using federal funds in 2022. Questioned Costs ? Not determinable. Context ? This is a condition identified per review of District of Columbia Public School (DCPS)?s compliance with the specified requirements using a statistically valid sample. Effect ? There is a risk that inadequate recordkeeping of equipment could lead to misappropriation of assets and noncompliance with Federal regulations resulting in a return of Federal awards received. Cause ? Due to a lack of linkage between procurement systems and asset management systems and COVID related concerns, DCPS was unable to adequately support compliance with its policies and procedures regarding monitoring of equipment acquired with Federal funds. Recommendation ? We recommend that DCPS implement policies, procedures and controls that will ensure that equipment purchased using federal funds are tracked and maintained, in order to adhere to Federal regulations related to equipment and its related maintenance. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? The District of Columbia Public School (DCPS) agrees with the conditions and recommendations of this finding. While DCPS has implemented and follows stringent asset procurement and management policies, we have adopted separate systems to track the purchasing, receiving, and the lifecycle of assets. The Procurement and ERP systems, PASS/SOAR are used to track purchases of assets, while the Warehouse receiving system captures a record of assets received by DCPS. The DCPS?s Asset Management System, TIPWeb tracks a device throughout its lifecycle (deployment/assignment, condition, location, disposal, etc.). This split system functionality contributes to the conditions noted in the audit findings. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-024 Prior Year Finding Number: N/A Compliance Requirement: Data Collection Form and Single Audit Reporting Package Programs: ALN: 10.551, 10.561 Supplemental Nutrition Assistance Program Cluster ALN: 10.553, 10.555, 10.559, 10.582 Child Nutrition Cluster ALN: 10.558 Child and Adult Care Food Program ALN: 14.218 Community Development Block Grants/Entitlement Grants Cluster ALN: 21.023 COVID-19 ? Emergency Rental Assistance Program ALN: 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Relief Funds ALN: 84.027, 84.173 Special Education Cluster ALN: 84.126 Rehabilitation Services - Vocational Rehabilitation Grants to States ALN: 84.425 COVID-19 ? Education Stabilization Fund ALN: 93.268 Immunization Cooperative Agreements ALN: 93.498 COVID-19 ? Provider Relief Fund ALN: 93.558 Temporary Assistance for Needy Families ALN: 93.568 Low Income Home Energy Assistance ALN: 93.569 Community Services Block Grant ALN: 93.658 Foster Care ? Title IV-E ALN: 93.775, 93.777, 93.778 Medicaid Cluster ALN: 93.914 HIV Emergency Relief Project Grants ALN: 97.036 Public Assistance - Presidentially Declared Disaster Criteria - The Uniform Guidance in 2 CFR Section 200.512, Report Submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor?s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Condition ? The District did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended September 30, 2022. Questioned Costs ? None. Context ? This is a condition identified per review of the District?s compliance with the specified requirements. Effect ? The District could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Cause ? The District did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe. Recommendation ? We recommend that the District closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? The District concurs with the auditor?s findings and recommendations. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-024 Prior Year Finding Number: N/A Compliance Requirement: Data Collection Form and Single Audit Reporting Package Programs: ALN: 10.551, 10.561 Supplemental Nutrition Assistance Program Cluster ALN: 10.553, 10.555, 10.559, 10.582 Child Nutrition Cluster ALN: 10.558 Child and Adult Care Food Program ALN: 14.218 Community Development Block Grants/Entitlement Grants Cluster ALN: 21.023 COVID-19 ? Emergency Rental Assistance Program ALN: 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Relief Funds ALN: 84.027, 84.173 Special Education Cluster ALN: 84.126 Rehabilitation Services - Vocational Rehabilitation Grants to States ALN: 84.425 COVID-19 ? Education Stabilization Fund ALN: 93.268 Immunization Cooperative Agreements ALN: 93.498 COVID-19 ? Provider Relief Fund ALN: 93.558 Temporary Assistance for Needy Families ALN: 93.568 Low Income Home Energy Assistance ALN: 93.569 Community Services Block Grant ALN: 93.658 Foster Care ? Title IV-E ALN: 93.775, 93.777, 93.778 Medicaid Cluster ALN: 93.914 HIV Emergency Relief Project Grants ALN: 97.036 Public Assistance - Presidentially Declared Disaster Criteria - The Uniform Guidance in 2 CFR Section 200.512, Report Submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor?s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Condition ? The District did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended September 30, 2022. Questioned Costs ? None. Context ? This is a condition identified per review of the District?s compliance with the specified requirements. Effect ? The District could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Cause ? The District did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe. Recommendation ? We recommend that the District closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? The District concurs with the auditor?s findings and recommendations. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-024 Prior Year Finding Number: N/A Compliance Requirement: Data Collection Form and Single Audit Reporting Package Programs: ALN: 10.551, 10.561 Supplemental Nutrition Assistance Program Cluster ALN: 10.553, 10.555, 10.559, 10.582 Child Nutrition Cluster ALN: 10.558 Child and Adult Care Food Program ALN: 14.218 Community Development Block Grants/Entitlement Grants Cluster ALN: 21.023 COVID-19 ? Emergency Rental Assistance Program ALN: 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Relief Funds ALN: 84.027, 84.173 Special Education Cluster ALN: 84.126 Rehabilitation Services - Vocational Rehabilitation Grants to States ALN: 84.425 COVID-19 ? Education Stabilization Fund ALN: 93.268 Immunization Cooperative Agreements ALN: 93.498 COVID-19 ? Provider Relief Fund ALN: 93.558 Temporary Assistance for Needy Families ALN: 93.568 Low Income Home Energy Assistance ALN: 93.569 Community Services Block Grant ALN: 93.658 Foster Care ? Title IV-E ALN: 93.775, 93.777, 93.778 Medicaid Cluster ALN: 93.914 HIV Emergency Relief Project Grants ALN: 97.036 Public Assistance - Presidentially Declared Disaster Criteria - The Uniform Guidance in 2 CFR Section 200.512, Report Submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor?s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Condition ? The District did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended September 30, 2022. Questioned Costs ? None. Context ? This is a condition identified per review of the District?s compliance with the specified requirements. Effect ? The District could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Cause ? The District did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe. Recommendation ? We recommend that the District closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? The District concurs with the auditor?s findings and recommendations. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-009 Prior Year Finding Number: 2021-011 Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs/Cost Principles Program: U.S. Department of Health and Human Services Immunization Cooperative Agreements ALN: 93.268 Award #: 1 NH23IP922596-02-02 to NH23IP922596-02-11 Award Year: 08/01/2019 ? 06/30/2024 Government Department/Agency: Department of Health (DC Health) Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR Section 200.430 Compensation ? Personal Services: ?Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the establish written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities; (2) Follows an appointment made in accordance with a non-Federal entity?s laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, Standards for Documentation of Personnel Expenses, when applicable.? 2 CFR Section 200.430(i): ?Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity?s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; (vi) [Reserved] (vii) Support the distribution of the employee?s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards.? Condition ? We noted that the District Department of Health (DC Health) continued to allocate payroll expenditures to the Immunization Cooperative Agreements (ICA) program during fiscal year 2022 based on budgeted percentages. These percentages were entered into the PeopleSoft Human Resources/Payroll System (PeopleSoft) at the beginning of the fiscal year and were based on management?s estimate of the respective employee?s level of effort for each program. PeopleSoft calculated the payroll costs every payroll cycle for each employee and program based on the predetermined percentage, and reported it through the Labor Distribution Report (485 Report). However, management did not perform a periodic comparison of actual costs to the budgeted costs and make any necessary adjustment as required by 2 CFR Section 200.430. Specifically, 11 out of 60 sampled payroll items tested for the ICA grant were recorded based on estimated hours and not actual hours. Questioned Costs ? Not determinable. Context ? This is a condition identified per review of DC Health?s compliance with specified requirements using a statistically valid sample. Payroll costs including fringe benefits, for the ICA program in fiscal year 2022 were $2,646,210. Effect ? DC Health was unable to demonstrate that the payroll expenditures charged to the ICA grant accurately reflected the time incurred on the program and were properly supported in accordance with 2 CFR Part 200.430 time and effort reporting requirements. Cause ? DC Health did not have policies and procedures in place to review and reconcile the estimated amounts of payroll expenditures charged to the ICA program to the actual expenditures incurred. Per corrective action plans and status updates submitted by DC Health to BDO in fiscal year 2022, significant milestones have been achieved however due to several change management tasks, the corrective action plan is still progressing into fiscal year 2023 and is expected to fully implement by September 30, 2023. Recommendation ? We recommend that DC Health fully implement its current corrective action plan to deploy policies and procedures to periodically compare employees? estimated hours per the 485 Report to the actual hours incurred, and make any necessary adjustments as required by 2 CFR 200.430. Related Noncompliance ? Material noncompliance. Views of Responsible Officials and Planned Corrective Actions ? The District Department of Health (DC Health) concurs with the finding, causes and recommendations cited in the fiscal year 2022 single audit for the Immunization Cooperative Agreements (ICA) program. The current corrective action plan (CAP), originating from the prior year's finding had been actively implemented in fiscal year 2022 and reached significant milestones. DC Health asserts that while a process was implemented to obtain a regular schedule of payroll and budget- to-actual data for personnel, and supervisors were provided a tool and process for delivering ?time and effort certifications?, there were still some errors and omissions. DC Health concurs with the auditor on the need to continue implementation of the current CAP, but DC Health will modify processes and tools to ensure that there is the required periodic comparison of actual costs to the budgeted costs of personnel per the requirements of 2 CFR 200.430. Contributing factors were delays in distributing and receiving the required certifications, provision of technical assistance and training, and managing manual errors. Additionally, there were missing certifications due to a large turnover of staff, including many supervisors assigned to complete time and effort certification forms. In fiscal year 2022, reporting templates and reporting repositories were being revised and further developed and continued in fiscal year 2023. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-024 Prior Year Finding Number: N/A Compliance Requirement: Data Collection Form and Single Audit Reporting Package Programs: ALN: 10.551, 10.561 Supplemental Nutrition Assistance Program Cluster ALN: 10.553, 10.555, 10.559, 10.582 Child Nutrition Cluster ALN: 10.558 Child and Adult Care Food Program ALN: 14.218 Community Development Block Grants/Entitlement Grants Cluster ALN: 21.023 COVID-19 ? Emergency Rental Assistance Program ALN: 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Relief Funds ALN: 84.027, 84.173 Special Education Cluster ALN: 84.126 Rehabilitation Services - Vocational Rehabilitation Grants to States ALN: 84.425 COVID-19 ? Education Stabilization Fund ALN: 93.268 Immunization Cooperative Agreements ALN: 93.498 COVID-19 ? Provider Relief Fund ALN: 93.558 Temporary Assistance for Needy Families ALN: 93.568 Low Income Home Energy Assistance ALN: 93.569 Community Services Block Grant ALN: 93.658 Foster Care ? Title IV-E ALN: 93.775, 93.777, 93.778 Medicaid Cluster ALN: 93.914 HIV Emergency Relief Project Grants ALN: 97.036 Public Assistance - Presidentially Declared Disaster Criteria - The Uniform Guidance in 2 CFR Section 200.512, Report Submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor?s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Condition ? The District did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended September 30, 2022. Questioned Costs ? None. Context ? This is a condition identified per review of the District?s compliance with the specified requirements. Effect ? The District could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Cause ? The District did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe. Recommendation ? We recommend that the District closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? The District concurs with the auditor?s findings and recommendations. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-009 Prior Year Finding Number: 2021-011 Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs/Cost Principles Program: U.S. Department of Health and Human Services Immunization Cooperative Agreements ALN: 93.268 Award #: 1 NH23IP922596-02-02 to NH23IP922596-02-11 Award Year: 08/01/2019 ? 06/30/2024 Government Department/Agency: Department of Health (DC Health) Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR Section 200.430 Compensation ? Personal Services: ?Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the establish written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities; (2) Follows an appointment made in accordance with a non-Federal entity?s laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, Standards for Documentation of Personnel Expenses, when applicable.? 2 CFR Section 200.430(i): ?Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity?s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; (vi) [Reserved] (vii) Support the distribution of the employee?s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards.? Condition ? We noted that the District Department of Health (DC Health) continued to allocate payroll expenditures to the Immunization Cooperative Agreements (ICA) program during fiscal year 2022 based on budgeted percentages. These percentages were entered into the PeopleSoft Human Resources/Payroll System (PeopleSoft) at the beginning of the fiscal year and were based on management?s estimate of the respective employee?s level of effort for each program. PeopleSoft calculated the payroll costs every payroll cycle for each employee and program based on the predetermined percentage, and reported it through the Labor Distribution Report (485 Report). However, management did not perform a periodic comparison of actual costs to the budgeted costs and make any necessary adjustment as required by 2 CFR Section 200.430. Specifically, 11 out of 60 sampled payroll items tested for the ICA grant were recorded based on estimated hours and not actual hours. Questioned Costs ? Not determinable. Context ? This is a condition identified per review of DC Health?s compliance with specified requirements using a statistically valid sample. Payroll costs including fringe benefits, for the ICA program in fiscal year 2022 were $2,646,210. Effect ? DC Health was unable to demonstrate that the payroll expenditures charged to the ICA grant accurately reflected the time incurred on the program and were properly supported in accordance with 2 CFR Part 200.430 time and effort reporting requirements. Cause ? DC Health did not have policies and procedures in place to review and reconcile the estimated amounts of payroll expenditures charged to the ICA program to the actual expenditures incurred. Per corrective action plans and status updates submitted by DC Health to BDO in fiscal year 2022, significant milestones have been achieved however due to several change management tasks, the corrective action plan is still progressing into fiscal year 2023 and is expected to fully implement by September 30, 2023. Recommendation ? We recommend that DC Health fully implement its current corrective action plan to deploy policies and procedures to periodically compare employees? estimated hours per the 485 Report to the actual hours incurred, and make any necessary adjustments as required by 2 CFR 200.430. Related Noncompliance ? Material noncompliance. Views of Responsible Officials and Planned Corrective Actions ? The District Department of Health (DC Health) concurs with the finding, causes and recommendations cited in the fiscal year 2022 single audit for the Immunization Cooperative Agreements (ICA) program. The current corrective action plan (CAP), originating from the prior year's finding had been actively implemented in fiscal year 2022 and reached significant milestones. DC Health asserts that while a process was implemented to obtain a regular schedule of payroll and budget- to-actual data for personnel, and supervisors were provided a tool and process for delivering ?time and effort certifications?, there were still some errors and omissions. DC Health concurs with the auditor on the need to continue implementation of the current CAP, but DC Health will modify processes and tools to ensure that there is the required periodic comparison of actual costs to the budgeted costs of personnel per the requirements of 2 CFR 200.430. Contributing factors were delays in distributing and receiving the required certifications, provision of technical assistance and training, and managing manual errors. Additionally, there were missing certifications due to a large turnover of staff, including many supervisors assigned to complete time and effort certification forms. In fiscal year 2022, reporting templates and reporting repositories were being revised and further developed and continued in fiscal year 2023. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-024 Prior Year Finding Number: N/A Compliance Requirement: Data Collection Form and Single Audit Reporting Package Programs: ALN: 10.551, 10.561 Supplemental Nutrition Assistance Program Cluster ALN: 10.553, 10.555, 10.559, 10.582 Child Nutrition Cluster ALN: 10.558 Child and Adult Care Food Program ALN: 14.218 Community Development Block Grants/Entitlement Grants Cluster ALN: 21.023 COVID-19 ? Emergency Rental Assistance Program ALN: 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Relief Funds ALN: 84.027, 84.173 Special Education Cluster ALN: 84.126 Rehabilitation Services - Vocational Rehabilitation Grants to States ALN: 84.425 COVID-19 ? Education Stabilization Fund ALN: 93.268 Immunization Cooperative Agreements ALN: 93.498 COVID-19 ? Provider Relief Fund ALN: 93.558 Temporary Assistance for Needy Families ALN: 93.568 Low Income Home Energy Assistance ALN: 93.569 Community Services Block Grant ALN: 93.658 Foster Care ? Title IV-E ALN: 93.775, 93.777, 93.778 Medicaid Cluster ALN: 93.914 HIV Emergency Relief Project Grants ALN: 97.036 Public Assistance - Presidentially Declared Disaster Criteria - The Uniform Guidance in 2 CFR Section 200.512, Report Submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor?s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Condition ? The District did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended September 30, 2022. Questioned Costs ? None. Context ? This is a condition identified per review of the District?s compliance with the specified requirements. Effect ? The District could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Cause ? The District did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe. Recommendation ? We recommend that the District closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? The District concurs with the auditor?s findings and recommendations. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-024 Prior Year Finding Number: N/A Compliance Requirement: Data Collection Form and Single Audit Reporting Package Programs: ALN: 10.551, 10.561 Supplemental Nutrition Assistance Program Cluster ALN: 10.553, 10.555, 10.559, 10.582 Child Nutrition Cluster ALN: 10.558 Child and Adult Care Food Program ALN: 14.218 Community Development Block Grants/Entitlement Grants Cluster ALN: 21.023 COVID-19 ? Emergency Rental Assistance Program ALN: 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Relief Funds ALN: 84.027, 84.173 Special Education Cluster ALN: 84.126 Rehabilitation Services - Vocational Rehabilitation Grants to States ALN: 84.425 COVID-19 ? Education Stabilization Fund ALN: 93.268 Immunization Cooperative Agreements ALN: 93.498 COVID-19 ? Provider Relief Fund ALN: 93.558 Temporary Assistance for Needy Families ALN: 93.568 Low Income Home Energy Assistance ALN: 93.569 Community Services Block Grant ALN: 93.658 Foster Care ? Title IV-E ALN: 93.775, 93.777, 93.778 Medicaid Cluster ALN: 93.914 HIV Emergency Relief Project Grants ALN: 97.036 Public Assistance - Presidentially Declared Disaster Criteria - The Uniform Guidance in 2 CFR Section 200.512, Report Submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor?s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Condition ? The District did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended September 30, 2022. Questioned Costs ? None. Context ? This is a condition identified per review of the District?s compliance with the specified requirements. Effect ? The District could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Cause ? The District did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe. Recommendation ? We recommend that the District closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? The District concurs with the auditor?s findings and recommendations. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-010 Prior Year Finding Number: N/A Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs/Cost Principles Program: U.S. Department of Health and Human Services Temporary Assistance for Needy Families (TANF) ALN: 93.558 Award #: Various Award Year: 10/01/2021 ? 09/30/2022 Government Department/Agency: Department of Human Services (DHS)/Economic Security Administration (ESA) Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR Section 200.430 Compensation ? Personal Services: ?Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the establish written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities; (2) Follows an appointment made in accordance with a non-Federal entity?s laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, Standards for Documentation of Personnel Expenses, when applicable.? 2 CFR Section 200.430(i): ?Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity?s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; (vi) [Reserved] (vii) Support the distribution of the employee?s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards.? Per District Personnel Issuance No. 2019-07 (Approval Required - page 10) ? ?Overtime work must be officially ordered and approved in advance. Agency heads and their designees are authorized to order and approve overtime work provided the agency has sufficient funding available. Overtime should be approved using DCSF No. 11B-12, Request for Authorization of Overtime Work. However, when responding to an immediate operational need, pre-approval may be memorialized in any written form, such as e-mail, and followed-up with the official overtime approval. Completed overtime forms and any supporting documentation should be submitted to the employee?s timekeeper for processing.? Condition ? We noted that for three (3) out of a sample of 25 employees tested, although the employee's timesheet was approved by the supervisor, DHS/ESA was unable to provide documentation that the overtime hours worked by the employee during the selected payperiods were preapproved. Questioned Costs ? Not determinable. Context ? This is a condition identified per review of DHS/ESA?s compliance with specified requirements using a statistically valid sample. Payroll costs including fringe benefits, for the TANF program in fiscal year 2022 were $15,092,248. Effect ? DHS/ESA was unable to demonstrate that overtime charged to the federal program was approved in advanced in accordance with the internal policies and procedures of the agency. Cause ? DHS/ESA did not follow its own internal controls and policies and procedures to ensure that authorization forms evidencing the preapproval of overtime are obtained and maintained. Recommendation ? We recommend that DHS/ESA follow its own policies, procedures and controls to ensure that pre-authorization of overtime are obtained and maintained. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? DHS concurs with the finding. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-011 Prior Year Finding Number: 2021-014 Compliance Requirement: Eligibility Program: U.S. Department of Health and Human Services Temporary Assistance for Needy Families (TANF) ALN: 93.558 Award #: Various Award Year: 10/01/2021 ? 09/30/2022 Government Department/Agency: Department of Human Services (DHS)/Economic Security Administration (ESA) Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. For TANF, per 45 CFR Section 205.60 (a), ?The State agency will maintain or supervise the maintenance of records necessary for the proper and efficient operation of the plan, including records regarding applications, determination of eligibility, the provision of financial assistance, and the use of any information obtained under Section 205.55, with respect to individual applications denied, recipients whose benefits have been terminated, recipients whose benefits have been modified, and the dollar value of these denials, terminations and modifications. Under this requirement, the agency will keep individual records which contain pertinent facts about each applicant and recipient. The records will include information concerning the date of application and the date and basis of its disposition; facts essential to the determination of initial and continuing eligibility (including the individual's social security number, need for, and provision of financial assistance); and the basis for discontinuing assistance.? For the Pandemic Emergency Assistance Fund (PEAF), per TANF-ACF-IM-2022-01 (Guidance for Use of the Pandemic Emergency Assistance Fund Appropriated in the American Rescue Plan (ARP) Act of 2021 (Pub. L. 117-2); Accompaniment to ACF-IOAS-DCL-22-01) ?For the purposes of the Pandemic Emergency Assistance Fund, Non-Recurrent, Short Term (NRST) benefits mean cash payments or other benefits that meet the regulatory definition (45 CFR 260.31(b)(1)), but are limited to those that fall into the specific expenditure reporting category mentioned in the legislation (line 15 of the ACF-196R (PDF), the state financial reporting form for the TANF program). In other words, for this fund, NRST benefits, like all NRSTs under TANF, must: ? be designed to deal with a specific crisis situation or episode of need; ? not be intended to meet on-going needs; and ? not extend beyond four months. And (as explained in the instructions for reporting on line 15 of the ACF-196R) NRSTs paid for with PEAF funds: ? must only include expenditures such as emergency assistance and diversion payments, emergency housing and short-term homelessness assistance, emergency food aid, short-term utilities payments, burial assistance, clothing allowances, and back-to-school payments; and ? may not include tax credits, childcare, transportation, or short-term education and training. In addition, ?The recipients of PEAF-funded NRSTs must be needy families with children but they do not necessarily have to be eligible for TANF cash assistance. A grantee has the flexibility to determine what needy means for each NRST and may wish to set a higher standard than it does for TANF cash assistance, such as aligning with SNAP or Medicaid income eligibility criteria.? Condition ? During our testing over beneficiary eligibility compliance requirements of the Temporary Assistance for Needy Families (TANF) program, we selected a sample of 60 beneficiaries in fiscal year 2022 to test DHS? compliance with TANF eligibility requirements. We noted the following: ? For one (1) out of 60, we noted that the application/recertification submitted on April 19, 2022, as identified in DCAS, could not be located in DIMS. We were therefore unable to test the following: o There was a completed and signed application that agreed to the information in DCAS: household composition, income, proof of residency, and Social Security Numbers for all individuals included on the application. o The family included a minor child who lives with a parent or other adult caretaker relative, or pregnant woman. o The family met state?s income requirements to be considered eligible as financially ?needy?. Only the financially ?needy? are eligible for services, benefits, or ?assistance?. Financially ?needy? for TANF and MOE purposes means financial deprivation, i.e., lacking adequate income and resources. For example, a needy family or a needy parent is one who is financially eligible according to the State's quantified financial eligibility criteria. o Assistance was not provided to an individual who was under age 18, was unmarried, had a minor child at least 12 weeks old, and had not successfully completed high school or its equivalent unless the individual either participates in education activities directed toward attainment of a high school diploma or its equivalent, or participates in an alternative education or training program approved by the District. o Assistance was not provided to an unmarried individual under 18 caring for a child, if the minor parent and child are not residing with a parent, legal guardian, or other adult relative, unless one of the statutory exceptions applies (42 USC 608(a)(5)). o Assistance was not provided for a minor child who had been or was expected to be absent from the home for a period of 45 consecutive days or, at the option of the State, such period of not less than 30 and not more than 180 consecutive days unless the State grants a good cause exception, as provided in its State Plan. o Assistance was not provided for an individual who was a parent (or other caretaker relative) of a minor child who fails to notify the State agency of the absence of the minor child from the home, as in paragraph e. immediately above, within five days of the date that it becomes clear to that individual that the child will be absent for the specified period of time (42 USC 608(a)(10)(C)). o That cash assistance was not provided to an individual during the 10-year period that began on the date the individual was convicted in Federal or State court of having made a fraudulent statement or representation with respect to place of residence in order to simultaneously receive assistance from two or more States under TANF, Title XIX, or the Food Stamp Act of 1977, or benefits in two or more States under the Supplemental Security Income program under Title XVI of the Social Security Act. o Assistance was not provided to any individual who was fleeing to avoid prosecution, or custody or confinement after conviction, for a felony or attempt to commit a felony, or who is violating a condition of probation or parole imposed under Federal or State law. o An individual convicted under Federal or State law of any offense which is classified as a felony and which involves the possession, use, or distribution of a controlled substance (as defined the Controlled Substances Act (21 USC 802(6)) is ineligible for assistance if the conviction was based on conduct occurring after August 22, 1996. A State shall require each individual applying for TANF assistance to state in writing whether the individual or any member of their household has been convicted of such a felony involving a controlled substance. However, a State may by law enacted after August 22, 1996, exempt any or all individuals from this prohibition or limit the time period that this prohibition applies to any or all individuals 21 USC 862a). o Qualified aliens, as defined at 8 USC 1641b (unless exempt) entering the United States on or after August 22, 1996, who were not eligible for Federal public benefits, as defined in 8 USC 1611(c), for a period of five years beginning on the date of the alien?s entry into the United States, unless they met an exception at 8 USC 1612(b)(2) or 1613 did not receive benefits. o Verified that for any TANF recipient that received subsidized child care, the District ensured that a completed application was submitted by the applicant prior to receiving the child care subsidy. ? For ten (10) out of 60, DHS was unable to provide support that would allow us to test that cash assistance was not provided to an individual during the 10-year period that began on the date the individual was convicted in Federal or State court of having made a fraudulent statement or representation with respect to place of residence in order to simultaneously receive assistance from two or more States under TANF, Title XIX, or the Food Stamp Act of 1977, or benefits in two or more States under the Supplemental Security Income program under Title XVI of the Social Security Act. In addition, for two (2) of these samples, DHS was unable to provide support that would allow us to test that assistance was not provided to any individual who was fleeing to avoid prosecution, or custody or confinement after conviction, for a felony or attempt to commit a felony, or who is violating a condition of probation or parole imposed under Federal or State law. ? For one (1) out of 60, we noted that the application consisted of a household comprised of 1 adult and 2 children but the amount paid was only $452 (not $665). Further review shows that it is an only child case (as one child did not meet school attendance requirement); however, the household was paid $452 instead of $418. DHS/ESA was unable to determine why the amount reported did not agree with the maximum amount for one individual. The questioned costs for the above issues amounted to $44,067, which represent 14.7% of the total eligibility amounts tested related to the 60 sampled items of $299,727. In addition, during our testing over beneficiary eligibility compliance requirements of the PEAF program for TANF, we selected a sample of 60 beneficiaries in fiscal year 2022 to test DHS? compliance with PEAF eligibility requirements (50 of the TANF Eligibility sample customers that received PEAF and 10 additional sample customers that received PEAF). We noted the following for the 50 samples already tested for TANF: ? For one (1) out of 50, we noted that DHS/ESA was unable to locate the correct TANF application. We were therefore unable to test the following: o A completed and signed application existed and agreed the information in DCAS for: household composition, income, proof of residency, and Social Security Numbers for all individuals included on the application, and o Whether the family met state's income requirements to be considered eligible as financially "needy". Only the financially ?needy? are eligible for services, benefits, or ?assistance?. Financially ?needy? for TANF and MOE purposes means financial deprivation, i.e., lacking adequate income and resources. For example, a needy family or a needy parent is one who is financially eligible according to the State?s quantified financial eligibility criteria. We noted the following for the additional 10 samples tested for PEAF: ? For one (1) out of 10, we noted that per review of DCAS the client tested was identified as ineligible for TANF for 11/1/2020 to 11/1/2022 as household had no eligible members; however, we noted that the PEAF payment of $1,038 was made to the customer during fiscal year 2022. DHS ESA was unable to support how eligibility was determined. The questioned costs for the above issues for PEAF amounted to $2,076, which represent 3.33% of the total eligibility amounts tested related to the 60 sampled items of $62,288. Questioned Costs ? Known amount is $46,143. Context ? This is a condition identified per review of DHS? compliance with specified requirements using a statistically valid sample. Effect ? Without properly maintaining documentation to support eligibility determinations, ineligible beneficiaries may receive benefits under the TANF grant and DHS may make payments on behalf of those beneficiaries resulting in noncompliance with the eligibility requirements. Cause ? DHS did not consistently adhere to its established policies and procedures requiring it to maintain documentation supporting participant eligibility. Recommendation - We recommend that DHS strengthen its existing policies and procedures over the review and maintenance of appropriate documentation to ensure compliance with eligibility requirements. Related Noncompliance ? Material noncompliance. Views of Responsible Officials and Planned Corrective Actions ? DHS/ESA concur with the findings. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-012 Prior Year Finding Number: 2021-017 Compliance Requirement: Reporting; Special Tests and Provisions ? Penalty for Failure to Comply With Work Verification Plan Program: U.S. Department of Health and Human Services Temporary Assistance for Needy Families (TANF) ALN: 93.558 Award #: Various Award Year: 10/01/2021 ? 09/30/2022 Government Department/Agency: Department of Human Services (DHS)/ Economic Security Administration (ESA) Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 45 CFR Section 261.60 (a), ?A State must report the actual hours that an individual participates in an activity, subject to the qualifications in paragraphs (b) and (c) of this section and Section 261.61(c). It is not sufficient to report the hours an individual is scheduled to participate in an activity. (b) For the purposes of calculating the work participation rates for a month, actual hours may include the hours for which an individual was paid, including paid holidays and sick leave. For participation in unpaid work activities, it may include excused absences for hours missed due to a maximum of 10 holidays in the preceding 12-month period and up to 80 hours of additional excused absences in the preceding 12-month period, no more than 16 of which may occur in a month, for each work-eligible individual. Each State must designate the days that it wishes to count as holidays for those in unpaid activities in its Work Verification Plan. It may designate no more than 10 such days. In order to count an excused absence as actual hours of participation, the individual must have been scheduled to participate in a countable work activity for the period of the absence that the State reports as participation. A State must describe its excused absence policies and definitions as part of its Work Verification Plan, specified at Section 261.62. (c) For unsubsidized employment, subsidized employment, and OJT, a State may report projected actual hours of employment participation for up to six months based on current, documented actual hours of work. Any time a State receives information that the client's actual hours of work have changed, or no later than the end of any six-month period, the State must re-verify the client's current actual average hours of work, and may report these projected actual hours of participation for another six-month period. (d) A State may not count more hours toward the participation rate for a self-employed individual than the number derived by dividing the individual's self-employment income (gross income less business expenses) by the Federal minimum wage. A State may propose an alternative method of determining self-employment hours as part of its Work Verification Plan. (e) A State may count supervised homework time and up to one hour of unsupervised homework time for each hour of class time. Total homework time counted for participation cannot exceed the hours required or advised by a particular educational program.? Per 45 CFR Section 261.61 (a), ?A State must support each individual?s hours of participation with documentation in the case file. In accordance with Section 261.62, a State must describe in its Work Verification Plan the documentation it uses to verify hours of participation in each activity.? According to the DC State Verification Plan, the D.C. Department of Human Services (DHS), Department of Human Services Monitoring Unit reviews and audits all documentation submitted by vendors reflecting the activities of recipients in TANF Employment program. This documentation includes time sheets, activity logs, school records, pay stubs, and verification of employment, work experience and on-the-job training. The Monitoring Unit completes this audit process to determine if sufficient documentation exists to substantiate reported time and attendance data, to warrant a payment to TANF Employment program vendors, and submission of countable hours for federal reporting purposes. The District projects hours of participation in unsubsidized, self-employment for six months or until the recipient's next scheduled recertification, whichever is sooner. Per 45 CFR Section 265.7 (a)-(c), ?Each State?s quarterly reports (the TANF Data Report, the TANF Financial Report (or Territorial Financial Report), and the SSP-MOE Data Report) must be complete and accurate and filed by the due date.? For disaggregated data report, `a complete and accurate report? means that: (1) The reported data accurately reflect information available to the State in case records, financial records, and automated data systems, and include correction of the quarterly data by the end of the fiscal year reporting period; (2) The data are free from computational errors and are internally consistent (e.g., items that should add to totals do so); (3) The State reports data for all required elements (i.e., no data are missing); (4)(i) The State provides data on all families; or (ii) if the State opts to use sampling, the State reports data on all families selected in a sample that meets the specification and procedures in the TANF Sampling Manual (except for families listed in error); and (5) Where estimates are necessary (e.g., some types of assistance may require cost estimates), the State uses reasonable methods to develop these estimates. For an aggregated data report, ?a complete and accurate report? means that: (1) The reported data accurately reflect information available to the State in case records, financial records, and automated data systems; (2) The data are free from computational errors and are internally consistent (e.g., items that should add to totals do so); (3) The State reports data on all applicable elements; and (4) Monthly totals are unduplicated counts for all families (e.g., the number of families and the number of out-of-wedlock births are unduplicated counts).? 45 CFR Section 265.7 (f) states that ?States must maintain records to adequately support any report, in accordance with Section 75.361 through 75.370 of this title.? Condition ? During our test work over a sample of 60 participants for Special Tests and Provisions - Penalty for Failure to Comply with Work Verification Plan and Reporting, we noted: ? For eight (8) instances, we noted that although the hours reported met or exceeded the required work participation hours, and the customer met the requirement, DHS/ESA was unable to provide documentation to support the hours reported. Therefore, we were unable to confirm that approved hours were properly supported. ? For two (2) instances, we noted that although the hours reported met or exceeded the required work participation hours, the customer did not meet the requirement, and the hours reported did not agree with the recalculated hours. ? For eleven (11) instances, we noted that although the hours reported met or exceeded the required work participation hours, the hours reported did not agree with the projected hours for unsubsidized employment for the customer. ? For one (1) instance, we noted that although the participant had no recorded participation hours in CATCH and a medical letter of patient admission dated two months prior to the month selected stating the customer?s inability to work, DHS/ESA was unable to provide documentation to support the hours reported on the ACF-199 report. ? For one (1) instance, we noted that the participant had no recorded participation hours in CATCH and had a child under one making her exempt from the work requirement. We noted we noted that although the hours reported met or exceeded the required work participation hours. The information tested in our sample represents the underlying data used in Reporting for the 1st and 3rd quarters of fiscal year 2022. Consequently, DHS incorrectly reported data in the ACF-199 report for the 1st and 3rd quarters of fiscal year 2022. Questioned Costs ? Not determinable. Context ? This is a condition identified per review of DHS? compliance with specified requirements using a statistically valid sample. Effect ? Data within the ACF-199 report may not be complete and accurate. Specifically, if the work participation data is not substantiated, or inconsistencies are noted, it may result in inaccurate data being reported and may lead to an incorrect ACF-199 report and could result in an incorrect allocation of Federal Funds to the state. Cause ? Controls are not operating effectively over the documentation of work participation data to ensure that adequate evidence of the work participation is maintained. Recommendation - We recommend that DHS enforce existing policies and procedures and implement additional controls to ensure that adequate documentation is maintained to substantiate the work participation data reported in the ACF-199 report in accordance with the District of Columbia Work Verification Plan. We also recommend that DHS implement policies, procedures and controls that will enable an accurate reconciliation between the data sources used in the preparation of the ACF-199 report to ensure proper reporting of data elements. Related Noncompliance ? Material noncompliance. Views of Responsible Officials and Planned Corrective Actions ? DHS agrees with the findings and will work with the DCAS and the Division of Innovation and Change Management (DICM) teams to mitigate the causes of the findings. These findings are mostly residual issues with the tables in DHS/ESA DCAS system. ? For the eight (8) cases, where DHS/ESA was unable to provide documentation to support the hours reported, customer participation hours were not updated/closed when employment ended so there were no supporting documents in DIMS. Customer did not have participation hours in CATCH however shown in DCAS. ? For the two (2) instances, where the hours reported did not agree with the recalculated hours, this is intentional, as it ?preserves? caped federal hours. DHS is updating the work verification plan to document this. ? For the eleven (11) cases where the hours reported did not agree with the projected hours for unsubsidized employment for the customer. These were DCAS hours that were not updated timely in the employment record. Customer participation hours were not updated/closed when employment ended so there were no supporting documents in DIMS. ? For the one (1) instance, where DHS/ESA was unable to provide documentation to support the hours reported on the ACF-199 report. This was also a DCAS issue because the income evidence was not end dated once the employment evidence was end dated. ? For the one (1) instance where a customer had a child under one making her exempt from the work requirement. However, the hours reported met or exceeded the required work participation hours. Customer had participation hours in ACF when employed. Customer was exempt due to pregnancy for the report month/year however the employment hours were not end dated in the ACF. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-013 Prior Year Finding Number: 2021-016 Compliance Requirement: Special Tests and Provisions ? Income Eligibility and Verification System Program: U.S. Department of Health and Human Services Temporary Assistance for Needy Families (TANF) ALN: 93.558 Award #: Various Award Year: 10/01/2021 ? 09/30/2022 Government Department/Agency: Department of Human Services (DHS)/ Economic Security Administration (ESA) Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 45 CFR Section 205.56(a)(1)(i), ?The State agency shall review and compare the information obtained from each data exchange against information contained in the case record to determine whether it affects the applicant?s or the recipient?s eligibility or the amount of assistance.? Per 45 CFR Section 205.60 (a), ?The State agency will maintain or supervise the maintenance of records necessary for the proper and efficient operation of the plan, including records regarding applications, determination of eligibility, the provision of financial assistance, and the use of any information obtained under Section 205.55, with respect to individual applications denied, recipients whose benefits have been terminated, recipients whose benefits have been modified, and the dollar value of these denials, terminations and modifications. Under this requirement, the agency will keep individual records which contain pertinent facts about each applicant and recipient. The records will include information concerning the date of application and the date and basis of its disposition; facts essential to the determination of initial and continuing eligibility (including the individual's social security number, need for, and provision of financial assistance); and the basis for discontinuing assistance.? For the Pandemic Emergency Assistance Fund (PEAF), per TANF-ACF-IM-2022-01 (Guidance for Use of the Pandemic Emergency Assistance Fund Appropriated in the American Rescue Plan (ARP) Act of 2021 (Pub. L. 117-2); Accompaniment to ACF-IOAS-DCL-22-01) ?We remind grantees that the Income Eligibility Verification System (IEVS) does apply to the PEAF, as it is funded under Title IV-A; however, tribes are not subject to the IEVS requirements.? Condition ? During our test work of 60 cases selected to test the Special Tests and Provisions ? Income Eligibility and Verification Systems (IEVS) for TANF, we noted that DHS was unable to provide sufficient documentation to support all eligibility determinations tested during the fiscal year 2022 audit. Specifically, out of the 60 beneficiary disbursements tested, we noted the following exceptions: ? For three (3) out of 60, DHS was unable to provide evidence of use of IEVS to determine eligibility. ? For one (1) out of 60, DHS did not provide evidence that Social Security monthly disability payment of $758, was considered when determining eligibility and the related eligibility payments. Furthermore, DCAS sent request to the Social Security Administration and received a termination payment status code, however no reduction in benefit amount was made. In addition, during our test work of 60 cases selected to test the Special Tests and Provisions ? Income Eligibility and Verification Systems (IEVS) for PEAF, we noted that DHS was unable to provide sufficient documentation to support all eligibility determinations tested during the fiscal year 2022 audit. Specifically, out of the 60 beneficiary disbursements tested, we noted the following exception: ? For three (3) out of 60, DHS did not provide evidence of use of IEVS to determine eligibility. Questioned Costs ? Not determinable. Context ? This is a condition identified per review of DHS? compliance with specified requirements using a statistically valid sample. Effect ? The District is not in full compliance with its policies and with Federal program compliance requirements surrounding records maintenance. Further, ineligible TANF beneficiaries may receive benefits under the TANF grant and the District may make payments on behalf of those beneficiaries. Cause ? Controls are not adequate to ensure that the District adheres to its established policies and procedures requiring it to maintain documentation supporting participant eligibility. Recommendation - We recommend that DHS enforce existing policies and procedures and implement additional policies and procedures for maintaining and monitoring case record documentation to ensure that Income Eligibility and Verification System requirements are complied with. Related Noncompliance ? Material noncompliance. Views of Responsible Officials and Planned Corrective Actions ? DHS agrees with the finding in this report. DHS in collaboration with DHCF DCAS project teams is taking efforts to address the issues identified. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-024 Prior Year Finding Number: N/A Compliance Requirement: Data Collection Form and Single Audit Reporting Package Programs: ALN: 10.551, 10.561 Supplemental Nutrition Assistance Program Cluster ALN: 10.553, 10.555, 10.559, 10.582 Child Nutrition Cluster ALN: 10.558 Child and Adult Care Food Program ALN: 14.218 Community Development Block Grants/Entitlement Grants Cluster ALN: 21.023 COVID-19 ? Emergency Rental Assistance Program ALN: 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Relief Funds ALN: 84.027, 84.173 Special Education Cluster ALN: 84.126 Rehabilitation Services - Vocational Rehabilitation Grants to States ALN: 84.425 COVID-19 ? Education Stabilization Fund ALN: 93.268 Immunization Cooperative Agreements ALN: 93.498 COVID-19 ? Provider Relief Fund ALN: 93.558 Temporary Assistance for Needy Families ALN: 93.568 Low Income Home Energy Assistance ALN: 93.569 Community Services Block Grant ALN: 93.658 Foster Care ? Title IV-E ALN: 93.775, 93.777, 93.778 Medicaid Cluster ALN: 93.914 HIV Emergency Relief Project Grants ALN: 97.036 Public Assistance - Presidentially Declared Disaster Criteria - The Uniform Guidance in 2 CFR Section 200.512, Report Submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor?s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Condition ? The District did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended September 30, 2022. Questioned Costs ? None. Context ? This is a condition identified per review of the District?s compliance with the specified requirements. Effect ? The District could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Cause ? The District did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe. Recommendation ? We recommend that the District closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? The District concurs with the auditor?s findings and recommendations. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-014 Prior Year Finding Number: N/A Compliance Requirement: Eligibility Program: U.S. Department of Health and Human Services Low Income Home Energy Assistance ALN: 93.568 Award #: Various Award Year: 10/01/2021 ? 09/30/2022 Government Department/Agency: Department of Energy and Environment (DOEE) Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. The OMB Compliance Supplement states that ?Grantees may provide assistance to (a) households in which one or more individuals are receiving Temporary Assistance for Needy Families (TANF), Supplemental Security Income (SSI), Supplemental Nutrition Assistance Program (SNAP) benefits, or certain needs-tested veterans? benefits; or (b) households with incomes which do not exceed the greater of 150 percent of the state?s established poverty level, or 60 percent of the state median income. Grantees may establish lower income eligibility criteria, but no household may be excluded solely on the basis of income if the household income is less than 110 percent of the state?s poverty level (42 USC 8624(b)(2)). Grantees must give priority to those households with the highest home energy costs or needs in relation to income and household size (42 USC 8624(b)(5)).? Per 42 U.S. Code Section 8624(b)(2): ?The chief executive officer of each State shall certify that the State agrees to make payments under this subchapter only with respect to: (A) Households in which 1 or more individuals are receiving: (i) Assistance under the State program foundered under part A of the title IV of the Social Security Act; (ii) supplemental security income payments under title XVI of the Social Security Act; (iii) supplemental nutrition assistance program benefits under the Food and Nutrition Act of 2008; or (iv) payments under section 1315, 1521, 1541, or 1542 of title 38, or under section 306 of the Veterans? and Survivors? Pension Improvement Act of 1978; or (B) Households with incomes which do not exceed the greater of: (i) An amount equal to 150 percent of the poverty level for such State; or (ii) An amount equal to 60 percent of the State median income.? Condition ? During our review of 60 eligibility samples, we noted the following exceptions: ? For two (2) samples, the benefit paid to the participant was more than the actual benefit amount allowed per the benefit table. This was due to an error in the program database system, which resulted in the incorrect income being reported by the system. ? DOEE is not performing review of all individual?s application. DOEE?s policy is to perform secondary reviews of a minimum of 25% of all applications each fiscal year, as well as supervisors will conduct detailed reviews of 5 applications per processor per month, however, there is no documentation how these policies and procedures were actually implemented. Questioned Costs ? Not determinable. Context ? This is a condition identified per review of DOEE?s compliance with specified requirements using a statistically valid sample. Effect ? Without proper review, inaccurate benefit amount is paid to the beneficiary which resulted in higher payment made. Cause ? It appears that DOEE?s internal controls were not operating effectively over the eligibility household income calculation process which resulted in accurate amount being paid. Recommendation ? We recommend that DOEE strengthen their existing policies and procedures to ensure the review of the initial application household information including household incomes, household sizes, etc. are correctly recorded into the system based on supporting documentation. Further, proper supporting documentation should be put in place to document the department?s control over review of applicant?s benefit application. Related Noncompliance ? Material noncompliance. Views of Responsible Officials and Planned Corrective Actions ? DOEE agrees with the conditions and recommendations of this finding. DOEE is committed to operating an efficient and effective LIHEAP program in the District. DOEE notes that out of 60 samples reviewed, the eligibility criteria stated above was met as none of the households reviewed had incomes that exceeded 60 percent of the State median income per 42 U.S Code Section 8624(b)(2). Vendor agreements are in place that require the refund of a benefit amount if the benefit cannot be applied to the account (due to moving, death, conversion to other heating or cooling source, or a payment made in error). DOEE has requested a refund from utilities of the two (2) samples in question. The two (2) samples in question were a result of a database error generated after a benefit payment batching and not the result of inaccurate income input by the processor. It is standard practice for DOEE to perform 1st level reviews of individual applications before, during and after certification. Twenty-five percent of secondary reviews are conducted by staff who did not process the application and are performed after the first review and captured by signature on one form within the database. Supervisory level reviews of 5 applications per processor per month is documented in our Operations Manual. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-015 Prior Year Finding Number: N/A Compliance Requirement: Matching, Level of Effort, Earmarking Program: U.S. Department of Health and Human Services Low Income Home Energy Assistance ALN: 93.568 Award #: Various Award Year: 10/01/2021 ? 09/30/2022 Government Department/Agency: Department of Energy and Environment (DOEE) Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per Compliance Supplement on earmarking requirement, a. Planning and Administrative Costs, (1) No more than 10 percent of a state?s LIHEAP funds for a federal fiscal year may be used for planning and administrative costs, including both direct and indirect costs. This limitation applies, in the aggregate, to planning and administrative costs at both the state and subrecipient levels. This cap may not be exceeded by supplementing with other federal funds (42 USC 8624(b)(9)(A); 45 CFR section 96.88(a)). Energy Need Reduction Services ? No more than 5 percent of the LIHEAP funds may be used to provide services that encourage and enable households to reduce their home energy needs and, thereby, the need for energy assistance. Such services may include needs assessments, counseling, and assistance with energy vendors (42 USC 8624(b)(16)). Condition ? During our review of two (2) samples, although DOEE met the earmarking requirement, there was no evidence of review was performed. Questioned Costs ? Not determinable. Context ? This is a condition identified per review of DOEE?s compliance with specified requirements for earmarking calculations. Effect ? Without proper internal controls and policies and procedures in place to monitor and review, DOEE was not in compliance with the earmarking requirements. Cause ? DOEE does not have adequate controls in place to ensure that earmarking requirements are being properly reviewed and the required documentation is being maintained to evidence compliance with the requirements. Recommendation ? We recommend that DOEE strengthen their existing policies and procedures to ensure the review of the earmarking calculations are performed. Further, proper supporting documentation should be put in place to document the department?s control over review of such calculations. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? DOEE agrees with the conditions and recommendations of this finding. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-024 Prior Year Finding Number: N/A Compliance Requirement: Data Collection Form and Single Audit Reporting Package Programs: ALN: 10.551, 10.561 Supplemental Nutrition Assistance Program Cluster ALN: 10.553, 10.555, 10.559, 10.582 Child Nutrition Cluster ALN: 10.558 Child and Adult Care Food Program ALN: 14.218 Community Development Block Grants/Entitlement Grants Cluster ALN: 21.023 COVID-19 ? Emergency Rental Assistance Program ALN: 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Relief Funds ALN: 84.027, 84.173 Special Education Cluster ALN: 84.126 Rehabilitation Services - Vocational Rehabilitation Grants to States ALN: 84.425 COVID-19 ? Education Stabilization Fund ALN: 93.268 Immunization Cooperative Agreements ALN: 93.498 COVID-19 ? Provider Relief Fund ALN: 93.558 Temporary Assistance for Needy Families ALN: 93.568 Low Income Home Energy Assistance ALN: 93.569 Community Services Block Grant ALN: 93.658 Foster Care ? Title IV-E ALN: 93.775, 93.777, 93.778 Medicaid Cluster ALN: 93.914 HIV Emergency Relief Project Grants ALN: 97.036 Public Assistance - Presidentially Declared Disaster Criteria - The Uniform Guidance in 2 CFR Section 200.512, Report Submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor?s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Condition ? The District did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended September 30, 2022. Questioned Costs ? None. Context ? This is a condition identified per review of the District?s compliance with the specified requirements. Effect ? The District could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Cause ? The District did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe. Recommendation ? We recommend that the District closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? The District concurs with the auditor?s findings and recommendations. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-014 Prior Year Finding Number: N/A Compliance Requirement: Eligibility Program: U.S. Department of Health and Human Services Low Income Home Energy Assistance ALN: 93.568 Award #: Various Award Year: 10/01/2021 ? 09/30/2022 Government Department/Agency: Department of Energy and Environment (DOEE) Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. The OMB Compliance Supplement states that ?Grantees may provide assistance to (a) households in which one or more individuals are receiving Temporary Assistance for Needy Families (TANF), Supplemental Security Income (SSI), Supplemental Nutrition Assistance Program (SNAP) benefits, or certain needs-tested veterans? benefits; or (b) households with incomes which do not exceed the greater of 150 percent of the state?s established poverty level, or 60 percent of the state median income. Grantees may establish lower income eligibility criteria, but no household may be excluded solely on the basis of income if the household income is less than 110 percent of the state?s poverty level (42 USC 8624(b)(2)). Grantees must give priority to those households with the highest home energy costs or needs in relation to income and household size (42 USC 8624(b)(5)).? Per 42 U.S. Code Section 8624(b)(2): ?The chief executive officer of each State shall certify that the State agrees to make payments under this subchapter only with respect to: (A) Households in which 1 or more individuals are receiving: (i) Assistance under the State program foundered under part A of the title IV of the Social Security Act; (ii) supplemental security income payments under title XVI of the Social Security Act; (iii) supplemental nutrition assistance program benefits under the Food and Nutrition Act of 2008; or (iv) payments under section 1315, 1521, 1541, or 1542 of title 38, or under section 306 of the Veterans? and Survivors? Pension Improvement Act of 1978; or (B) Households with incomes which do not exceed the greater of: (i) An amount equal to 150 percent of the poverty level for such State; or (ii) An amount equal to 60 percent of the State median income.? Condition ? During our review of 60 eligibility samples, we noted the following exceptions: ? For two (2) samples, the benefit paid to the participant was more than the actual benefit amount allowed per the benefit table. This was due to an error in the program database system, which resulted in the incorrect income being reported by the system. ? DOEE is not performing review of all individual?s application. DOEE?s policy is to perform secondary reviews of a minimum of 25% of all applications each fiscal year, as well as supervisors will conduct detailed reviews of 5 applications per processor per month, however, there is no documentation how these policies and procedures were actually implemented. Questioned Costs ? Not determinable. Context ? This is a condition identified per review of DOEE?s compliance with specified requirements using a statistically valid sample. Effect ? Without proper review, inaccurate benefit amount is paid to the beneficiary which resulted in higher payment made. Cause ? It appears that DOEE?s internal controls were not operating effectively over the eligibility household income calculation process which resulted in accurate amount being paid. Recommendation ? We recommend that DOEE strengthen their existing policies and procedures to ensure the review of the initial application household information including household incomes, household sizes, etc. are correctly recorded into the system based on supporting documentation. Further, proper supporting documentation should be put in place to document the department?s control over review of applicant?s benefit application. Related Noncompliance ? Material noncompliance. Views of Responsible Officials and Planned Corrective Actions ? DOEE agrees with the conditions and recommendations of this finding. DOEE is committed to operating an efficient and effective LIHEAP program in the District. DOEE notes that out of 60 samples reviewed, the eligibility criteria stated above was met as none of the households reviewed had incomes that exceeded 60 percent of the State median income per 42 U.S Code Section 8624(b)(2). Vendor agreements are in place that require the refund of a benefit amount if the benefit cannot be applied to the account (due to moving, death, conversion to other heating or cooling source, or a payment made in error). DOEE has requested a refund from utilities of the two (2) samples in question. The two (2) samples in question were a result of a database error generated after a benefit payment batching and not the result of inaccurate income input by the processor. It is standard practice for DOEE to perform 1st level reviews of individual applications before, during and after certification. Twenty-five percent of secondary reviews are conducted by staff who did not process the application and are performed after the first review and captured by signature on one form within the database. Supervisory level reviews of 5 applications per processor per month is documented in our Operations Manual. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-015 Prior Year Finding Number: N/A Compliance Requirement: Matching, Level of Effort, Earmarking Program: U.S. Department of Health and Human Services Low Income Home Energy Assistance ALN: 93.568 Award #: Various Award Year: 10/01/2021 ? 09/30/2022 Government Department/Agency: Department of Energy and Environment (DOEE) Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per Compliance Supplement on earmarking requirement, a. Planning and Administrative Costs, (1) No more than 10 percent of a state?s LIHEAP funds for a federal fiscal year may be used for planning and administrative costs, including both direct and indirect costs. This limitation applies, in the aggregate, to planning and administrative costs at both the state and subrecipient levels. This cap may not be exceeded by supplementing with other federal funds (42 USC 8624(b)(9)(A); 45 CFR section 96.88(a)). Energy Need Reduction Services ? No more than 5 percent of the LIHEAP funds may be used to provide services that encourage and enable households to reduce their home energy needs and, thereby, the need for energy assistance. Such services may include needs assessments, counseling, and assistance with energy vendors (42 USC 8624(b)(16)). Condition ? During our review of two (2) samples, although DOEE met the earmarking requirement, there was no evidence of review was performed. Questioned Costs ? Not determinable. Context ? This is a condition identified per review of DOEE?s compliance with specified requirements for earmarking calculations. Effect ? Without proper internal controls and policies and procedures in place to monitor and review, DOEE was not in compliance with the earmarking requirements. Cause ? DOEE does not have adequate controls in place to ensure that earmarking requirements are being properly reviewed and the required documentation is being maintained to evidence compliance with the requirements. Recommendation ? We recommend that DOEE strengthen their existing policies and procedures to ensure the review of the earmarking calculations are performed. Further, proper supporting documentation should be put in place to document the department?s control over review of such calculations. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? DOEE agrees with the conditions and recommendations of this finding. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-024 Prior Year Finding Number: N/A Compliance Requirement: Data Collection Form and Single Audit Reporting Package Programs: ALN: 10.551, 10.561 Supplemental Nutrition Assistance Program Cluster ALN: 10.553, 10.555, 10.559, 10.582 Child Nutrition Cluster ALN: 10.558 Child and Adult Care Food Program ALN: 14.218 Community Development Block Grants/Entitlement Grants Cluster ALN: 21.023 COVID-19 ? Emergency Rental Assistance Program ALN: 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Relief Funds ALN: 84.027, 84.173 Special Education Cluster ALN: 84.126 Rehabilitation Services - Vocational Rehabilitation Grants to States ALN: 84.425 COVID-19 ? Education Stabilization Fund ALN: 93.268 Immunization Cooperative Agreements ALN: 93.498 COVID-19 ? Provider Relief Fund ALN: 93.558 Temporary Assistance for Needy Families ALN: 93.568 Low Income Home Energy Assistance ALN: 93.569 Community Services Block Grant ALN: 93.658 Foster Care ? Title IV-E ALN: 93.775, 93.777, 93.778 Medicaid Cluster ALN: 93.914 HIV Emergency Relief Project Grants ALN: 97.036 Public Assistance - Presidentially Declared Disaster Criteria - The Uniform Guidance in 2 CFR Section 200.512, Report Submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor?s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Condition ? The District did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended September 30, 2022. Questioned Costs ? None. Context ? This is a condition identified per review of the District?s compliance with the specified requirements. Effect ? The District could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Cause ? The District did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe. Recommendation ? We recommend that the District closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? The District concurs with the auditor?s findings and recommendations. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-024 Prior Year Finding Number: N/A Compliance Requirement: Data Collection Form and Single Audit Reporting Package Programs: ALN: 10.551, 10.561 Supplemental Nutrition Assistance Program Cluster ALN: 10.553, 10.555, 10.559, 10.582 Child Nutrition Cluster ALN: 10.558 Child and Adult Care Food Program ALN: 14.218 Community Development Block Grants/Entitlement Grants Cluster ALN: 21.023 COVID-19 ? Emergency Rental Assistance Program ALN: 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Relief Funds ALN: 84.027, 84.173 Special Education Cluster ALN: 84.126 Rehabilitation Services - Vocational Rehabilitation Grants to States ALN: 84.425 COVID-19 ? Education Stabilization Fund ALN: 93.268 Immunization Cooperative Agreements ALN: 93.498 COVID-19 ? Provider Relief Fund ALN: 93.558 Temporary Assistance for Needy Families ALN: 93.568 Low Income Home Energy Assistance ALN: 93.569 Community Services Block Grant ALN: 93.658 Foster Care ? Title IV-E ALN: 93.775, 93.777, 93.778 Medicaid Cluster ALN: 93.914 HIV Emergency Relief Project Grants ALN: 97.036 Public Assistance - Presidentially Declared Disaster Criteria - The Uniform Guidance in 2 CFR Section 200.512, Report Submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor?s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Condition ? The District did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended September 30, 2022. Questioned Costs ? None. Context ? This is a condition identified per review of the District?s compliance with the specified requirements. Effect ? The District could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Cause ? The District did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe. Recommendation ? We recommend that the District closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? The District concurs with the auditor?s findings and recommendations. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-016 Prior Year Finding Number: N/A Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs/Cost Principles Program: U.S. Department of Health and Human Services Foster Care ? Title IV-E ALN: 93.658 Award #: Various Award Year: 10/01/2021 ? 09/30/2022 Government Department/Agency: Child and Family Services Agency (CFSA) Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Based on CFSA?s Human Resources Administration Issuance: HR-06-1 dated May 12, 2006, staff must seek and receive advance written approval prior to working overtime. It also indicate that in emergency situations requiring an immediate response, the employee shall make every reasonable attempt to obtain advance approval by an appropriate manager or supervisor. Condition ? During our review of the payroll process regarding the review and approval of time and attendance, we noted that the Agency was unable to provide documentation supporting the preapproval of overtime for three (3) employees. Questioned Costs ? Not determinable. Context ? This is a condition identified per review of CFSA?s compliance with specified requirements using a statistically valid sample. Effect ? Without proper internal controls and policies and procedures in place to ensure maintenance of records increase the risk of disagreements between employer and employee regarding the employee?s correct payment. Cause ? CFSA did not have proper internal controls and policies and procedures in place to ensure that authorization forms evidencing the preapproval of overtime are maintained. Recommendation - We recommend that CFSA strengthen its policies, procedures and controls to ensure that pre-authorization of overtime is maintained. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? CFSA concurs with the finding as stated. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-017 Prior Year Finding Number: 2021-018 Compliance Requirement: Eligibility Program: U.S. Department of Health and Human Services Foster Care ? Title IV-E ALN: 93.658 Award #: Various Award Year: 10/01/2021 ? 09/30/2022 Government Department/Agency: Child and Family Services Agency (CFSA) Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. 45 CFR Section 92.20(b)(2), ?Accounting records, "Grantees and sub grantees must maintain records which adequately identify the source and application of funds provided for financially assisted activities. These records must contain information pertaining to grant or subgrant awards and authorizations, obligations, unobligated balances, assets, liabilities, outlays or expenditures, and income.? 45 CFR Section 1356.30(a) states, ?The Title IV-E agency must provide documentation that criminal records checks have been conducted with respect to prospective foster and adoptive parents.? 42 U.S. Code Section 671(a)(20)(A), ?In order for a State to be eligible for payments under this part, it shall have a plan approved by the Secretary which provides procedures for criminal records checks of national crime information databases for any prospective foster or adoptive parent before the foster or adoptive parent may be finally approved for placement of a child regardless of whether foster care maintenance payments or adoption assistance payments are to be made on behalf of the child under the State plan.? Furthermore, per 45 CFR Section 1356.21(a), ?Statutory and regulatory requirements of the Federal foster care program, To implement the foster care maintenance payments program provisions of the title IV-E plan and to be eligible to receive Federal financial participation (FFP) for foster care maintenance payments under this part, a Title IV-E agency must meet the requirements of this section, 45 CFR 1356.22, 45 CFR 1356.30, and Parts 472, 475(1), 475(4), 475(5), 475(6).? Condition ? During our audit we noted that in fiscal year 2022, the Foster Care program had total disbursements of $2,851,787 for 3,754 maintenance payments. We selected a sample of 60 participants representing disbursed federal funds totaling $47,395, we noted the following deficiencies: ? For one (1) of 60 samples, the redetermination form provided indicated that claim billed and included in the population and samples selected included amounts with eligibility status of ?Eligible Not Reimbursable?. ? For two (2) of 60 samples, CFSA was unable to provide documentation supporting that a child over the age of 18 was enrolled as a full-time student expected to complete secondary schooling or equivalent vocational or technical training. ? For seven (7) of 60 samples, CFSA did not always provide complete evidence of background checks such as criminal record checks and fingerprint-based checks from the national crime information databases. These deficiencies represent 15% of the total disbursements tested. Questioned Costs ? Known amount is $7,249. Context ? This is a condition identified per review of CFSA?s compliance with specified requirements using a statistically valid sample. Effect ? CFSA was not in compliance with the eligibility requirements of the Foster Care program. Cause ? CFSA does not have adequate controls in place to ensure that eligibility files are being properly reviewed and the required documentation is being maintained to evidence compliance with eligibility requirements. Recommendation - We recommend CFSA reevaluate and strengthen its existing policies and procedures over the review and maintenance of appropriate documentation to ensure compliance with eligibility requirements in accordance with the program. Related Noncompliance ? Material noncompliance. Views of Responsible Officials and Planned Corrective Actions ? CFSA concurs with the findings as stated. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-018 Prior Year Finding Number: N/A Compliance Requirement: Reporting Program: U.S. Department of Health and Human Services Foster Care ? Title IV-E ALN: 93.658 Award #: Various Award Year: 10/01/2021 ? 09/30/2022 Government Department/Agency: Child and Family Services Agency (CFSA) Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Condition ? During our review and reconciliation of program expenditures charged to the grant, we noted that certain expenditures were inaccurately reported in fiscal year 2022. Per review of the general ledger, it was discovered that $32,325 incurred from February 2018 through September 2020 were incorrectly reported in the SEFA. Questioned Costs ? Not determinable. Context ? This is a condition identified per review of CFSA?s compliance with specified requirements. Effect ? Without proper internal controls and policies and procedures in place to ensure that costs were properly reported in the SF-425, the Foster Care program expenditures were overstated. Lack of proper internal controls over the review of the financial report may lead to incorrect reporting of financial data. Cause ? CFSA overstated expenditures reported as a result of the inclusion of transactions that were incurred outside of the grant award reporting period. Thus, management did not have proper internal controls and policies and procedures in place to ensure that the SF-425 was properly reviewed prior to approval. Recommendation - We recommend that CFSA strengthen its policies, procedures and controls to ensure the amounts reported in the SF-425 annual report are properly review prior to approval and submission to the federal agency. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? CFSA concurs with the finding as stated. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-024 Prior Year Finding Number: N/A Compliance Requirement: Data Collection Form and Single Audit Reporting Package Programs: ALN: 10.551, 10.561 Supplemental Nutrition Assistance Program Cluster ALN: 10.553, 10.555, 10.559, 10.582 Child Nutrition Cluster ALN: 10.558 Child and Adult Care Food Program ALN: 14.218 Community Development Block Grants/Entitlement Grants Cluster ALN: 21.023 COVID-19 ? Emergency Rental Assistance Program ALN: 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Relief Funds ALN: 84.027, 84.173 Special Education Cluster ALN: 84.126 Rehabilitation Services - Vocational Rehabilitation Grants to States ALN: 84.425 COVID-19 ? Education Stabilization Fund ALN: 93.268 Immunization Cooperative Agreements ALN: 93.498 COVID-19 ? Provider Relief Fund ALN: 93.558 Temporary Assistance for Needy Families ALN: 93.568 Low Income Home Energy Assistance ALN: 93.569 Community Services Block Grant ALN: 93.658 Foster Care ? Title IV-E ALN: 93.775, 93.777, 93.778 Medicaid Cluster ALN: 93.914 HIV Emergency Relief Project Grants ALN: 97.036 Public Assistance - Presidentially Declared Disaster Criteria - The Uniform Guidance in 2 CFR Section 200.512, Report Submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor?s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Condition ? The District did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended September 30, 2022. Questioned Costs ? None. Context ? This is a condition identified per review of the District?s compliance with the specified requirements. Effect ? The District could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Cause ? The District did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe. Recommendation ? We recommend that the District closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? The District concurs with the auditor?s findings and recommendations. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-019 Prior Year Finding Number: N/A Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs/Cost Principles Program: U.S. Department of Health and Human Services Medicaid Cluster ALN 93.775, 93.777, 93.778 Award #: Various Award Year: 10/01/2021 ? 09/30/2022 Government Department/Agency: Department of Human Services (DHS) Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR Section 200.430 Compensation ? Personal Services: ?Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the establish written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities; (2) Follows an appointment made in accordance with a non-Federal entity?s laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, Standards for Documentation of Personnel Expenses, when applicable.? 2 CFR Section 200.430(i): ?Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity?s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; (vi) [Reserved] (vii) Support the distribution of the employee?s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards.? Condition ? During our review of 15 payroll transactions totaling $84,519, we noted that for 1 of the 15 payroll transactions, the hourly and annual employee pay amount was not supported by the Personnel Action Form or the People Soft payroll system. Department personnel could not explain the difference in pay between the amount noted on the Personnel Action form and the PeopleSoft Human Resources/Payroll System. In addition, management did not perform a reconciliation between the payroll amount in the PeopleSoft payroll system and the actual amount being paid to the employee. Questioned Costs ? Not determinable. Context ? This is a condition identified per review of DHS? compliance with specified requirements using a statistically valid sample. Payroll costs including fringe benefits, for the Medicaid Program in fiscal year 2022 were $48,126,394. Effect ? DHS was unable to provide support for the payroll expenditure charged to the Medicaid Program for fiscal year 2022. Cause ? DHS did not have policies and procedures in place to review and reconcile payroll expenditures posted in the People Soft system with the pay amount identified in the Personnel Action Form. In addition, the payroll expenses charged to the Medicaid program were not accurately stated for fiscal year 2022. Recommendation - We recommend that DHS implement policies and procedures to support payroll expenses charged to the Medicaid program. In addition, we recommend that DHS perform reconciliations of the employee?s pay noted on their Personnel Action Form to the payroll amount posted in the PeopleSoft payroll system. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? DHS agrees with the finding that for one payroll transaction, the hourly and annual employee pay amount was not supported by the Personnel Action Form of the PeopleSoft payroll system. DHS agrees with the finding that DHS did not perform a reconciliation between the payroll amount in PeopleSoft payroll system and the actual amount being paid to the employee. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-020 Prior Year Finding Number: 2021-020 Compliance Requirement: Eligibility Program: U.S. Department of Health and Human Services Medicaid Cluster ALN: 93.775, 93.777, 93.778 Award #: Various Award Year: 10/01/2021 ? 09/30/2022 Government Department/Agency: Department of Health Care Finance (DHCF)/Department of Human Services (DHS)/Economic Security Administration (ESA) Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. The Medicaid State Plan: Citation 42 CFR Section 431.17AT-79-29. Section 4.7 (Maintenance of Records) states, ?The Medicaid agency maintains or supervises the maintenance of records necessary for the proper and efficient operation of the plan, including records regarding applications, determination of eligibility, the provision of medical assistance, and administrative costs and statistical, fiscal and other records necessary for reporting and accountability, and retains these records in accordance with Federal requirements. All requirements of 42 CFR 431.17 are met.? Economic Security Administration (ESA) Policy Manual, Section 1.3, ?All eligibility criteria and clarifying information are documented on the Record of Case Action, form 1052. The case record should speak for itself. An outside reviewer shall be able to follow the chronology of events in the case be reading the narrative. All application documents including verification and correspondence must be date-stamped. For working recipients, the record should include the dates pay is received and how often the recipient is paid. When the recipient?s statement is the best available source, the record should include the application/recipient and agency efforts to verify the information. All address changes should be documented.? Condition ? During testing over beneficiary eligibility for the Medicaid benefits, we noted that the District?s Economic Security Administration (ESA) was unable to provide sufficient documentation to support the beneficiary?s eligibility determination during the fiscal year 2022 audit. Specifically, out of a sample of 132 participant files tested, we noted the following exceptions: ? For fourteen (14) participant files where ESA did not process the application within the required timeframe. ? For one (1) participant file, ESA did not verify the applicant?s Social Security Number. ? For two (2) participant files, ESA did not verify the applicant?s citizenship. The Department of Health Care Finance, as the State Medicaid Agency, lacks a quality control oversight system to ensure that eligibility documentation and verification is maintained to support the eligibility decision. Questioned Costs ? Not determinable. Context ? This is a condition identified per review of ESA?s compliance with specified requirements using a statistically valid sample. Effect ? Lack of supporting documentation for program services and noncompliance with program requirements could result in disallowances of costs and participants could be receiving benefits that they are not entitled to receive under the program. Cause ? DHCF and ESA did not appear to adhere to internal control procedures to ensure that applications are properly processed in accordance with Federal Regulations. Recommendation - We recommend that ESA strictly implement internal control procedures to ensure that documentation is maintained to support the beneficiary determinations. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? DHCF and DHS concur with these findings. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-021 Prior Year Finding Number: N/A Compliance Requirement: Special Tests and Provisions ? Utilization Control and Program Integrity Program: U.S. Department of Health and Human Services Medicaid Cluster ALN 93.775, 93.777, 93.778 Award #: Various Award Year: 10/01/2021 ? 09/30/2022 Government Department/Agency: Department of Health Care Finance (DHCF) Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Condition ? During our testing of Utilization Control and Program Integrity for Quality Improvement Organization (QIO) invoices, for fourteen (14) out of forty (40) samples tested, we noted discrepancies between the price per review in the contract and the price per review in the actual vendor invoices, and such differences were not detected during the review of the invoice. This is an internal control deficiency. Questioned Costs ? Not determinable. Context ? This is a condition identified per review of QIO contracts and vendor invoices using a statistically valid sample. Effect ? The review of these QIO invoices contracted price failed to properly detect the price variances. Control Deficiency noted. Cause ? DHCF did not appear to adhere to internal control procedures to ensure that contract prices and vendor invoices agree. Recommendation - We recommend that DHCF implement internal control procedures to ensure that QIO invoices are properly reviewed and the amount in the contract agrees to the amount in the invoice. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? DHCF concurs with these findings. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-024 Prior Year Finding Number: N/A Compliance Requirement: Data Collection Form and Single Audit Reporting Package Programs: ALN: 10.551, 10.561 Supplemental Nutrition Assistance Program Cluster ALN: 10.553, 10.555, 10.559, 10.582 Child Nutrition Cluster ALN: 10.558 Child and Adult Care Food Program ALN: 14.218 Community Development Block Grants/Entitlement Grants Cluster ALN: 21.023 COVID-19 ? Emergency Rental Assistance Program ALN: 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Relief Funds ALN: 84.027, 84.173 Special Education Cluster ALN: 84.126 Rehabilitation Services - Vocational Rehabilitation Grants to States ALN: 84.425 COVID-19 ? Education Stabilization Fund ALN: 93.268 Immunization Cooperative Agreements ALN: 93.498 COVID-19 ? Provider Relief Fund ALN: 93.558 Temporary Assistance for Needy Families ALN: 93.568 Low Income Home Energy Assistance ALN: 93.569 Community Services Block Grant ALN: 93.658 Foster Care ? Title IV-E ALN: 93.775, 93.777, 93.778 Medicaid Cluster ALN: 93.914 HIV Emergency Relief Project Grants ALN: 97.036 Public Assistance - Presidentially Declared Disaster Criteria - The Uniform Guidance in 2 CFR Section 200.512, Report Submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor?s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Condition ? The District did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended September 30, 2022. Questioned Costs ? None. Context ? This is a condition identified per review of the District?s compliance with the specified requirements. Effect ? The District could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Cause ? The District did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe. Recommendation ? We recommend that the District closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? The District concurs with the auditor?s findings and recommendations. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-019 Prior Year Finding Number: N/A Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs/Cost Principles Program: U.S. Department of Health and Human Services Medicaid Cluster ALN 93.775, 93.777, 93.778 Award #: Various Award Year: 10/01/2021 ? 09/30/2022 Government Department/Agency: Department of Human Services (DHS) Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR Section 200.430 Compensation ? Personal Services: ?Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the establish written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities; (2) Follows an appointment made in accordance with a non-Federal entity?s laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, Standards for Documentation of Personnel Expenses, when applicable.? 2 CFR Section 200.430(i): ?Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity?s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; (vi) [Reserved] (vii) Support the distribution of the employee?s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards.? Condition ? During our review of 15 payroll transactions totaling $84,519, we noted that for 1 of the 15 payroll transactions, the hourly and annual employee pay amount was not supported by the Personnel Action Form or the People Soft payroll system. Department personnel could not explain the difference in pay between the amount noted on the Personnel Action form and the PeopleSoft Human Resources/Payroll System. In addition, management did not perform a reconciliation between the payroll amount in the PeopleSoft payroll system and the actual amount being paid to the employee. Questioned Costs ? Not determinable. Context ? This is a condition identified per review of DHS? compliance with specified requirements using a statistically valid sample. Payroll costs including fringe benefits, for the Medicaid Program in fiscal year 2022 were $48,126,394. Effect ? DHS was unable to provide support for the payroll expenditure charged to the Medicaid Program for fiscal year 2022. Cause ? DHS did not have policies and procedures in place to review and reconcile payroll expenditures posted in the People Soft system with the pay amount identified in the Personnel Action Form. In addition, the payroll expenses charged to the Medicaid program were not accurately stated for fiscal year 2022. Recommendation - We recommend that DHS implement policies and procedures to support payroll expenses charged to the Medicaid program. In addition, we recommend that DHS perform reconciliations of the employee?s pay noted on their Personnel Action Form to the payroll amount posted in the PeopleSoft payroll system. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? DHS agrees with the finding that for one payroll transaction, the hourly and annual employee pay amount was not supported by the Personnel Action Form of the PeopleSoft payroll system. DHS agrees with the finding that DHS did not perform a reconciliation between the payroll amount in PeopleSoft payroll system and the actual amount being paid to the employee. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-020 Prior Year Finding Number: 2021-020 Compliance Requirement: Eligibility Program: U.S. Department of Health and Human Services Medicaid Cluster ALN: 93.775, 93.777, 93.778 Award #: Various Award Year: 10/01/2021 ? 09/30/2022 Government Department/Agency: Department of Health Care Finance (DHCF)/Department of Human Services (DHS)/Economic Security Administration (ESA) Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. The Medicaid State Plan: Citation 42 CFR Section 431.17AT-79-29. Section 4.7 (Maintenance of Records) states, ?The Medicaid agency maintains or supervises the maintenance of records necessary for the proper and efficient operation of the plan, including records regarding applications, determination of eligibility, the provision of medical assistance, and administrative costs and statistical, fiscal and other records necessary for reporting and accountability, and retains these records in accordance with Federal requirements. All requirements of 42 CFR 431.17 are met.? Economic Security Administration (ESA) Policy Manual, Section 1.3, ?All eligibility criteria and clarifying information are documented on the Record of Case Action, form 1052. The case record should speak for itself. An outside reviewer shall be able to follow the chronology of events in the case be reading the narrative. All application documents including verification and correspondence must be date-stamped. For working recipients, the record should include the dates pay is received and how often the recipient is paid. When the recipient?s statement is the best available source, the record should include the application/recipient and agency efforts to verify the information. All address changes should be documented.? Condition ? During testing over beneficiary eligibility for the Medicaid benefits, we noted that the District?s Economic Security Administration (ESA) was unable to provide sufficient documentation to support the beneficiary?s eligibility determination during the fiscal year 2022 audit. Specifically, out of a sample of 132 participant files tested, we noted the following exceptions: ? For fourteen (14) participant files where ESA did not process the application within the required timeframe. ? For one (1) participant file, ESA did not verify the applicant?s Social Security Number. ? For two (2) participant files, ESA did not verify the applicant?s citizenship. The Department of Health Care Finance, as the State Medicaid Agency, lacks a quality control oversight system to ensure that eligibility documentation and verification is maintained to support the eligibility decision. Questioned Costs ? Not determinable. Context ? This is a condition identified per review of ESA?s compliance with specified requirements using a statistically valid sample. Effect ? Lack of supporting documentation for program services and noncompliance with program requirements could result in disallowances of costs and participants could be receiving benefits that they are not entitled to receive under the program. Cause ? DHCF and ESA did not appear to adhere to internal control procedures to ensure that applications are properly processed in accordance with Federal Regulations. Recommendation - We recommend that ESA strictly implement internal control procedures to ensure that documentation is maintained to support the beneficiary determinations. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? DHCF and DHS concur with these findings. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-021 Prior Year Finding Number: N/A Compliance Requirement: Special Tests and Provisions ? Utilization Control and Program Integrity Program: U.S. Department of Health and Human Services Medicaid Cluster ALN 93.775, 93.777, 93.778 Award #: Various Award Year: 10/01/2021 ? 09/30/2022 Government Department/Agency: Department of Health Care Finance (DHCF) Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Condition ? During our testing of Utilization Control and Program Integrity for Quality Improvement Organization (QIO) invoices, for fourteen (14) out of forty (40) samples tested, we noted discrepancies between the price per review in the contract and the price per review in the actual vendor invoices, and such differences were not detected during the review of the invoice. This is an internal control deficiency. Questioned Costs ? Not determinable. Context ? This is a condition identified per review of QIO contracts and vendor invoices using a statistically valid sample. Effect ? The review of these QIO invoices contracted price failed to properly detect the price variances. Control Deficiency noted. Cause ? DHCF did not appear to adhere to internal control procedures to ensure that contract prices and vendor invoices agree. Recommendation - We recommend that DHCF implement internal control procedures to ensure that QIO invoices are properly reviewed and the amount in the contract agrees to the amount in the invoice. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? DHCF concurs with these findings. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-024 Prior Year Finding Number: N/A Compliance Requirement: Data Collection Form and Single Audit Reporting Package Programs: ALN: 10.551, 10.561 Supplemental Nutrition Assistance Program Cluster ALN: 10.553, 10.555, 10.559, 10.582 Child Nutrition Cluster ALN: 10.558 Child and Adult Care Food Program ALN: 14.218 Community Development Block Grants/Entitlement Grants Cluster ALN: 21.023 COVID-19 ? Emergency Rental Assistance Program ALN: 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Relief Funds ALN: 84.027, 84.173 Special Education Cluster ALN: 84.126 Rehabilitation Services - Vocational Rehabilitation Grants to States ALN: 84.425 COVID-19 ? Education Stabilization Fund ALN: 93.268 Immunization Cooperative Agreements ALN: 93.498 COVID-19 ? Provider Relief Fund ALN: 93.558 Temporary Assistance for Needy Families ALN: 93.568 Low Income Home Energy Assistance ALN: 93.569 Community Services Block Grant ALN: 93.658 Foster Care ? Title IV-E ALN: 93.775, 93.777, 93.778 Medicaid Cluster ALN: 93.914 HIV Emergency Relief Project Grants ALN: 97.036 Public Assistance - Presidentially Declared Disaster Criteria - The Uniform Guidance in 2 CFR Section 200.512, Report Submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor?s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Condition ? The District did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended September 30, 2022. Questioned Costs ? None. Context ? This is a condition identified per review of the District?s compliance with the specified requirements. Effect ? The District could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Cause ? The District did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe. Recommendation ? We recommend that the District closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? The District concurs with the auditor?s findings and recommendations. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-019 Prior Year Finding Number: N/A Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs/Cost Principles Program: U.S. Department of Health and Human Services Medicaid Cluster ALN 93.775, 93.777, 93.778 Award #: Various Award Year: 10/01/2021 ? 09/30/2022 Government Department/Agency: Department of Human Services (DHS) Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR Section 200.430 Compensation ? Personal Services: ?Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the establish written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities; (2) Follows an appointment made in accordance with a non-Federal entity?s laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, Standards for Documentation of Personnel Expenses, when applicable.? 2 CFR Section 200.430(i): ?Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity?s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; (vi) [Reserved] (vii) Support the distribution of the employee?s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards.? Condition ? During our review of 15 payroll transactions totaling $84,519, we noted that for 1 of the 15 payroll transactions, the hourly and annual employee pay amount was not supported by the Personnel Action Form or the People Soft payroll system. Department personnel could not explain the difference in pay between the amount noted on the Personnel Action form and the PeopleSoft Human Resources/Payroll System. In addition, management did not perform a reconciliation between the payroll amount in the PeopleSoft payroll system and the actual amount being paid to the employee. Questioned Costs ? Not determinable. Context ? This is a condition identified per review of DHS? compliance with specified requirements using a statistically valid sample. Payroll costs including fringe benefits, for the Medicaid Program in fiscal year 2022 were $48,126,394. Effect ? DHS was unable to provide support for the payroll expenditure charged to the Medicaid Program for fiscal year 2022. Cause ? DHS did not have policies and procedures in place to review and reconcile payroll expenditures posted in the People Soft system with the pay amount identified in the Personnel Action Form. In addition, the payroll expenses charged to the Medicaid program were not accurately stated for fiscal year 2022. Recommendation - We recommend that DHS implement policies and procedures to support payroll expenses charged to the Medicaid program. In addition, we recommend that DHS perform reconciliations of the employee?s pay noted on their Personnel Action Form to the payroll amount posted in the PeopleSoft payroll system. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? DHS agrees with the finding that for one payroll transaction, the hourly and annual employee pay amount was not supported by the Personnel Action Form of the PeopleSoft payroll system. DHS agrees with the finding that DHS did not perform a reconciliation between the payroll amount in PeopleSoft payroll system and the actual amount being paid to the employee. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-020 Prior Year Finding Number: 2021-020 Compliance Requirement: Eligibility Program: U.S. Department of Health and Human Services Medicaid Cluster ALN: 93.775, 93.777, 93.778 Award #: Various Award Year: 10/01/2021 ? 09/30/2022 Government Department/Agency: Department of Health Care Finance (DHCF)/Department of Human Services (DHS)/Economic Security Administration (ESA) Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. The Medicaid State Plan: Citation 42 CFR Section 431.17AT-79-29. Section 4.7 (Maintenance of Records) states, ?The Medicaid agency maintains or supervises the maintenance of records necessary for the proper and efficient operation of the plan, including records regarding applications, determination of eligibility, the provision of medical assistance, and administrative costs and statistical, fiscal and other records necessary for reporting and accountability, and retains these records in accordance with Federal requirements. All requirements of 42 CFR 431.17 are met.? Economic Security Administration (ESA) Policy Manual, Section 1.3, ?All eligibility criteria and clarifying information are documented on the Record of Case Action, form 1052. The case record should speak for itself. An outside reviewer shall be able to follow the chronology of events in the case be reading the narrative. All application documents including verification and correspondence must be date-stamped. For working recipients, the record should include the dates pay is received and how often the recipient is paid. When the recipient?s statement is the best available source, the record should include the application/recipient and agency efforts to verify the information. All address changes should be documented.? Condition ? During testing over beneficiary eligibility for the Medicaid benefits, we noted that the District?s Economic Security Administration (ESA) was unable to provide sufficient documentation to support the beneficiary?s eligibility determination during the fiscal year 2022 audit. Specifically, out of a sample of 132 participant files tested, we noted the following exceptions: ? For fourteen (14) participant files where ESA did not process the application within the required timeframe. ? For one (1) participant file, ESA did not verify the applicant?s Social Security Number. ? For two (2) participant files, ESA did not verify the applicant?s citizenship. The Department of Health Care Finance, as the State Medicaid Agency, lacks a quality control oversight system to ensure that eligibility documentation and verification is maintained to support the eligibility decision. Questioned Costs ? Not determinable. Context ? This is a condition identified per review of ESA?s compliance with specified requirements using a statistically valid sample. Effect ? Lack of supporting documentation for program services and noncompliance with program requirements could result in disallowances of costs and participants could be receiving benefits that they are not entitled to receive under the program. Cause ? DHCF and ESA did not appear to adhere to internal control procedures to ensure that applications are properly processed in accordance with Federal Regulations. Recommendation - We recommend that ESA strictly implement internal control procedures to ensure that documentation is maintained to support the beneficiary determinations. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? DHCF and DHS concur with these findings. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-021 Prior Year Finding Number: N/A Compliance Requirement: Special Tests and Provisions ? Utilization Control and Program Integrity Program: U.S. Department of Health and Human Services Medicaid Cluster ALN 93.775, 93.777, 93.778 Award #: Various Award Year: 10/01/2021 ? 09/30/2022 Government Department/Agency: Department of Health Care Finance (DHCF) Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Condition ? During our testing of Utilization Control and Program Integrity for Quality Improvement Organization (QIO) invoices, for fourteen (14) out of forty (40) samples tested, we noted discrepancies between the price per review in the contract and the price per review in the actual vendor invoices, and such differences were not detected during the review of the invoice. This is an internal control deficiency. Questioned Costs ? Not determinable. Context ? This is a condition identified per review of QIO contracts and vendor invoices using a statistically valid sample. Effect ? The review of these QIO invoices contracted price failed to properly detect the price variances. Control Deficiency noted. Cause ? DHCF did not appear to adhere to internal control procedures to ensure that contract prices and vendor invoices agree. Recommendation - We recommend that DHCF implement internal control procedures to ensure that QIO invoices are properly reviewed and the amount in the contract agrees to the amount in the invoice. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? DHCF concurs with these findings. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-024 Prior Year Finding Number: N/A Compliance Requirement: Data Collection Form and Single Audit Reporting Package Programs: ALN: 10.551, 10.561 Supplemental Nutrition Assistance Program Cluster ALN: 10.553, 10.555, 10.559, 10.582 Child Nutrition Cluster ALN: 10.558 Child and Adult Care Food Program ALN: 14.218 Community Development Block Grants/Entitlement Grants Cluster ALN: 21.023 COVID-19 ? Emergency Rental Assistance Program ALN: 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Relief Funds ALN: 84.027, 84.173 Special Education Cluster ALN: 84.126 Rehabilitation Services - Vocational Rehabilitation Grants to States ALN: 84.425 COVID-19 ? Education Stabilization Fund ALN: 93.268 Immunization Cooperative Agreements ALN: 93.498 COVID-19 ? Provider Relief Fund ALN: 93.558 Temporary Assistance for Needy Families ALN: 93.568 Low Income Home Energy Assistance ALN: 93.569 Community Services Block Grant ALN: 93.658 Foster Care ? Title IV-E ALN: 93.775, 93.777, 93.778 Medicaid Cluster ALN: 93.914 HIV Emergency Relief Project Grants ALN: 97.036 Public Assistance - Presidentially Declared Disaster Criteria - The Uniform Guidance in 2 CFR Section 200.512, Report Submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor?s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Condition ? The District did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended September 30, 2022. Questioned Costs ? None. Context ? This is a condition identified per review of the District?s compliance with the specified requirements. Effect ? The District could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Cause ? The District did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe. Recommendation ? We recommend that the District closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? The District concurs with the auditor?s findings and recommendations. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-019 Prior Year Finding Number: N/A Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs/Cost Principles Program: U.S. Department of Health and Human Services Medicaid Cluster ALN 93.775, 93.777, 93.778 Award #: Various Award Year: 10/01/2021 ? 09/30/2022 Government Department/Agency: Department of Human Services (DHS) Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR Section 200.430 Compensation ? Personal Services: ?Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the establish written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities; (2) Follows an appointment made in accordance with a non-Federal entity?s laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, Standards for Documentation of Personnel Expenses, when applicable.? 2 CFR Section 200.430(i): ?Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity?s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; (vi) [Reserved] (vii) Support the distribution of the employee?s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards.? Condition ? During our review of 15 payroll transactions totaling $84,519, we noted that for 1 of the 15 payroll transactions, the hourly and annual employee pay amount was not supported by the Personnel Action Form or the People Soft payroll system. Department personnel could not explain the difference in pay between the amount noted on the Personnel Action form and the PeopleSoft Human Resources/Payroll System. In addition, management did not perform a reconciliation between the payroll amount in the PeopleSoft payroll system and the actual amount being paid to the employee. Questioned Costs ? Not determinable. Context ? This is a condition identified per review of DHS? compliance with specified requirements using a statistically valid sample. Payroll costs including fringe benefits, for the Medicaid Program in fiscal year 2022 were $48,126,394. Effect ? DHS was unable to provide support for the payroll expenditure charged to the Medicaid Program for fiscal year 2022. Cause ? DHS did not have policies and procedures in place to review and reconcile payroll expenditures posted in the People Soft system with the pay amount identified in the Personnel Action Form. In addition, the payroll expenses charged to the Medicaid program were not accurately stated for fiscal year 2022. Recommendation - We recommend that DHS implement policies and procedures to support payroll expenses charged to the Medicaid program. In addition, we recommend that DHS perform reconciliations of the employee?s pay noted on their Personnel Action Form to the payroll amount posted in the PeopleSoft payroll system. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? DHS agrees with the finding that for one payroll transaction, the hourly and annual employee pay amount was not supported by the Personnel Action Form of the PeopleSoft payroll system. DHS agrees with the finding that DHS did not perform a reconciliation between the payroll amount in PeopleSoft payroll system and the actual amount being paid to the employee. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-020 Prior Year Finding Number: 2021-020 Compliance Requirement: Eligibility Program: U.S. Department of Health and Human Services Medicaid Cluster ALN: 93.775, 93.777, 93.778 Award #: Various Award Year: 10/01/2021 ? 09/30/2022 Government Department/Agency: Department of Health Care Finance (DHCF)/Department of Human Services (DHS)/Economic Security Administration (ESA) Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. The Medicaid State Plan: Citation 42 CFR Section 431.17AT-79-29. Section 4.7 (Maintenance of Records) states, ?The Medicaid agency maintains or supervises the maintenance of records necessary for the proper and efficient operation of the plan, including records regarding applications, determination of eligibility, the provision of medical assistance, and administrative costs and statistical, fiscal and other records necessary for reporting and accountability, and retains these records in accordance with Federal requirements. All requirements of 42 CFR 431.17 are met.? Economic Security Administration (ESA) Policy Manual, Section 1.3, ?All eligibility criteria and clarifying information are documented on the Record of Case Action, form 1052. The case record should speak for itself. An outside reviewer shall be able to follow the chronology of events in the case be reading the narrative. All application documents including verification and correspondence must be date-stamped. For working recipients, the record should include the dates pay is received and how often the recipient is paid. When the recipient?s statement is the best available source, the record should include the application/recipient and agency efforts to verify the information. All address changes should be documented.? Condition ? During testing over beneficiary eligibility for the Medicaid benefits, we noted that the District?s Economic Security Administration (ESA) was unable to provide sufficient documentation to support the beneficiary?s eligibility determination during the fiscal year 2022 audit. Specifically, out of a sample of 132 participant files tested, we noted the following exceptions: ? For fourteen (14) participant files where ESA did not process the application within the required timeframe. ? For one (1) participant file, ESA did not verify the applicant?s Social Security Number. ? For two (2) participant files, ESA did not verify the applicant?s citizenship. The Department of Health Care Finance, as the State Medicaid Agency, lacks a quality control oversight system to ensure that eligibility documentation and verification is maintained to support the eligibility decision. Questioned Costs ? Not determinable. Context ? This is a condition identified per review of ESA?s compliance with specified requirements using a statistically valid sample. Effect ? Lack of supporting documentation for program services and noncompliance with program requirements could result in disallowances of costs and participants could be receiving benefits that they are not entitled to receive under the program. Cause ? DHCF and ESA did not appear to adhere to internal control procedures to ensure that applications are properly processed in accordance with Federal Regulations. Recommendation - We recommend that ESA strictly implement internal control procedures to ensure that documentation is maintained to support the beneficiary determinations. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? DHCF and DHS concur with these findings. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-021 Prior Year Finding Number: N/A Compliance Requirement: Special Tests and Provisions ? Utilization Control and Program Integrity Program: U.S. Department of Health and Human Services Medicaid Cluster ALN 93.775, 93.777, 93.778 Award #: Various Award Year: 10/01/2021 ? 09/30/2022 Government Department/Agency: Department of Health Care Finance (DHCF) Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Condition ? During our testing of Utilization Control and Program Integrity for Quality Improvement Organization (QIO) invoices, for fourteen (14) out of forty (40) samples tested, we noted discrepancies between the price per review in the contract and the price per review in the actual vendor invoices, and such differences were not detected during the review of the invoice. This is an internal control deficiency. Questioned Costs ? Not determinable. Context ? This is a condition identified per review of QIO contracts and vendor invoices using a statistically valid sample. Effect ? The review of these QIO invoices contracted price failed to properly detect the price variances. Control Deficiency noted. Cause ? DHCF did not appear to adhere to internal control procedures to ensure that contract prices and vendor invoices agree. Recommendation - We recommend that DHCF implement internal control procedures to ensure that QIO invoices are properly reviewed and the amount in the contract agrees to the amount in the invoice. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? DHCF concurs with these findings. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-024 Prior Year Finding Number: N/A Compliance Requirement: Data Collection Form and Single Audit Reporting Package Programs: ALN: 10.551, 10.561 Supplemental Nutrition Assistance Program Cluster ALN: 10.553, 10.555, 10.559, 10.582 Child Nutrition Cluster ALN: 10.558 Child and Adult Care Food Program ALN: 14.218 Community Development Block Grants/Entitlement Grants Cluster ALN: 21.023 COVID-19 ? Emergency Rental Assistance Program ALN: 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Relief Funds ALN: 84.027, 84.173 Special Education Cluster ALN: 84.126 Rehabilitation Services - Vocational Rehabilitation Grants to States ALN: 84.425 COVID-19 ? Education Stabilization Fund ALN: 93.268 Immunization Cooperative Agreements ALN: 93.498 COVID-19 ? Provider Relief Fund ALN: 93.558 Temporary Assistance for Needy Families ALN: 93.568 Low Income Home Energy Assistance ALN: 93.569 Community Services Block Grant ALN: 93.658 Foster Care ? Title IV-E ALN: 93.775, 93.777, 93.778 Medicaid Cluster ALN: 93.914 HIV Emergency Relief Project Grants ALN: 97.036 Public Assistance - Presidentially Declared Disaster Criteria - The Uniform Guidance in 2 CFR Section 200.512, Report Submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor?s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Condition ? The District did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended September 30, 2022. Questioned Costs ? None. Context ? This is a condition identified per review of the District?s compliance with the specified requirements. Effect ? The District could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Cause ? The District did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe. Recommendation ? We recommend that the District closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? The District concurs with the auditor?s findings and recommendations. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-019 Prior Year Finding Number: N/A Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs/Cost Principles Program: U.S. Department of Health and Human Services Medicaid Cluster ALN 93.775, 93.777, 93.778 Award #: Various Award Year: 10/01/2021 ? 09/30/2022 Government Department/Agency: Department of Human Services (DHS) Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR Section 200.430 Compensation ? Personal Services: ?Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the establish written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities; (2) Follows an appointment made in accordance with a non-Federal entity?s laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, Standards for Documentation of Personnel Expenses, when applicable.? 2 CFR Section 200.430(i): ?Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity?s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; (vi) [Reserved] (vii) Support the distribution of the employee?s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards.? Condition ? During our review of 15 payroll transactions totaling $84,519, we noted that for 1 of the 15 payroll transactions, the hourly and annual employee pay amount was not supported by the Personnel Action Form or the People Soft payroll system. Department personnel could not explain the difference in pay between the amount noted on the Personnel Action form and the PeopleSoft Human Resources/Payroll System. In addition, management did not perform a reconciliation between the payroll amount in the PeopleSoft payroll system and the actual amount being paid to the employee. Questioned Costs ? Not determinable. Context ? This is a condition identified per review of DHS? compliance with specified requirements using a statistically valid sample. Payroll costs including fringe benefits, for the Medicaid Program in fiscal year 2022 were $48,126,394. Effect ? DHS was unable to provide support for the payroll expenditure charged to the Medicaid Program for fiscal year 2022. Cause ? DHS did not have policies and procedures in place to review and reconcile payroll expenditures posted in the People Soft system with the pay amount identified in the Personnel Action Form. In addition, the payroll expenses charged to the Medicaid program were not accurately stated for fiscal year 2022. Recommendation - We recommend that DHS implement policies and procedures to support payroll expenses charged to the Medicaid program. In addition, we recommend that DHS perform reconciliations of the employee?s pay noted on their Personnel Action Form to the payroll amount posted in the PeopleSoft payroll system. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? DHS agrees with the finding that for one payroll transaction, the hourly and annual employee pay amount was not supported by the Personnel Action Form of the PeopleSoft payroll system. DHS agrees with the finding that DHS did not perform a reconciliation between the payroll amount in PeopleSoft payroll system and the actual amount being paid to the employee. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-020 Prior Year Finding Number: 2021-020 Compliance Requirement: Eligibility Program: U.S. Department of Health and Human Services Medicaid Cluster ALN: 93.775, 93.777, 93.778 Award #: Various Award Year: 10/01/2021 ? 09/30/2022 Government Department/Agency: Department of Health Care Finance (DHCF)/Department of Human Services (DHS)/Economic Security Administration (ESA) Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. The Medicaid State Plan: Citation 42 CFR Section 431.17AT-79-29. Section 4.7 (Maintenance of Records) states, ?The Medicaid agency maintains or supervises the maintenance of records necessary for the proper and efficient operation of the plan, including records regarding applications, determination of eligibility, the provision of medical assistance, and administrative costs and statistical, fiscal and other records necessary for reporting and accountability, and retains these records in accordance with Federal requirements. All requirements of 42 CFR 431.17 are met.? Economic Security Administration (ESA) Policy Manual, Section 1.3, ?All eligibility criteria and clarifying information are documented on the Record of Case Action, form 1052. The case record should speak for itself. An outside reviewer shall be able to follow the chronology of events in the case be reading the narrative. All application documents including verification and correspondence must be date-stamped. For working recipients, the record should include the dates pay is received and how often the recipient is paid. When the recipient?s statement is the best available source, the record should include the application/recipient and agency efforts to verify the information. All address changes should be documented.? Condition ? During testing over beneficiary eligibility for the Medicaid benefits, we noted that the District?s Economic Security Administration (ESA) was unable to provide sufficient documentation to support the beneficiary?s eligibility determination during the fiscal year 2022 audit. Specifically, out of a sample of 132 participant files tested, we noted the following exceptions: ? For fourteen (14) participant files where ESA did not process the application within the required timeframe. ? For one (1) participant file, ESA did not verify the applicant?s Social Security Number. ? For two (2) participant files, ESA did not verify the applicant?s citizenship. The Department of Health Care Finance, as the State Medicaid Agency, lacks a quality control oversight system to ensure that eligibility documentation and verification is maintained to support the eligibility decision. Questioned Costs ? Not determinable. Context ? This is a condition identified per review of ESA?s compliance with specified requirements using a statistically valid sample. Effect ? Lack of supporting documentation for program services and noncompliance with program requirements could result in disallowances of costs and participants could be receiving benefits that they are not entitled to receive under the program. Cause ? DHCF and ESA did not appear to adhere to internal control procedures to ensure that applications are properly processed in accordance with Federal Regulations. Recommendation - We recommend that ESA strictly implement internal control procedures to ensure that documentation is maintained to support the beneficiary determinations. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? DHCF and DHS concur with these findings. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-021 Prior Year Finding Number: N/A Compliance Requirement: Special Tests and Provisions ? Utilization Control and Program Integrity Program: U.S. Department of Health and Human Services Medicaid Cluster ALN 93.775, 93.777, 93.778 Award #: Various Award Year: 10/01/2021 ? 09/30/2022 Government Department/Agency: Department of Health Care Finance (DHCF) Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Condition ? During our testing of Utilization Control and Program Integrity for Quality Improvement Organization (QIO) invoices, for fourteen (14) out of forty (40) samples tested, we noted discrepancies between the price per review in the contract and the price per review in the actual vendor invoices, and such differences were not detected during the review of the invoice. This is an internal control deficiency. Questioned Costs ? Not determinable. Context ? This is a condition identified per review of QIO contracts and vendor invoices using a statistically valid sample. Effect ? The review of these QIO invoices contracted price failed to properly detect the price variances. Control Deficiency noted. Cause ? DHCF did not appear to adhere to internal control procedures to ensure that contract prices and vendor invoices agree. Recommendation - We recommend that DHCF implement internal control procedures to ensure that QIO invoices are properly reviewed and the amount in the contract agrees to the amount in the invoice. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? DHCF concurs with these findings. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-024 Prior Year Finding Number: N/A Compliance Requirement: Data Collection Form and Single Audit Reporting Package Programs: ALN: 10.551, 10.561 Supplemental Nutrition Assistance Program Cluster ALN: 10.553, 10.555, 10.559, 10.582 Child Nutrition Cluster ALN: 10.558 Child and Adult Care Food Program ALN: 14.218 Community Development Block Grants/Entitlement Grants Cluster ALN: 21.023 COVID-19 ? Emergency Rental Assistance Program ALN: 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Relief Funds ALN: 84.027, 84.173 Special Education Cluster ALN: 84.126 Rehabilitation Services - Vocational Rehabilitation Grants to States ALN: 84.425 COVID-19 ? Education Stabilization Fund ALN: 93.268 Immunization Cooperative Agreements ALN: 93.498 COVID-19 ? Provider Relief Fund ALN: 93.558 Temporary Assistance for Needy Families ALN: 93.568 Low Income Home Energy Assistance ALN: 93.569 Community Services Block Grant ALN: 93.658 Foster Care ? Title IV-E ALN: 93.775, 93.777, 93.778 Medicaid Cluster ALN: 93.914 HIV Emergency Relief Project Grants ALN: 97.036 Public Assistance - Presidentially Declared Disaster Criteria - The Uniform Guidance in 2 CFR Section 200.512, Report Submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor?s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Condition ? The District did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended September 30, 2022. Questioned Costs ? None. Context ? This is a condition identified per review of the District?s compliance with the specified requirements. Effect ? The District could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Cause ? The District did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe. Recommendation ? We recommend that the District closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? The District concurs with the auditor?s findings and recommendations. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-022 Prior Year Finding Number: 2021-021 Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs/Cost Principles Program: U.S. Department of Health and Human Services HIV Emergency Relief Project Grants ALN: 93.914 Award #: 2 H89HA00012-32-00, 2 H89HA00012-31-00 Award Year: 03/01/2022 ? 02/28/2025, 03/01/2021 ? 02/28/2022 Government Department/Agency: Department of Health (DC Health) Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR Section 200.430 Compensation ? Personal Services: ?Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the establish written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities; (2) Follows an appointment made in accordance with a non-Federal entity?s laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, Standards for Documentation of Personnel Expenses, when applicable.? 2 CFR Section 200.430(i): ?Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity?s written policy; (v) Comply with the established accounting policies and practices of the non-Federal entity; (vi) [Reserved] (vii) Support the distribution of the employee?s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards.? Condition ? We noted that the District Department of Health (DC Health) continued to allocate payroll expenditures to the HIV Emergency Relief Project Grants (HIVER) program during fiscal year 2022 based on budgeted percentages. These percentages were entered into the PeopleSoft Human Resources/Payroll System (PeopleSoft) at the beginning of the fiscal year and were based on management?s estimate of the respective employee?s level of effort for each program. PeopleSoft calculated the payroll costs every payroll cycle for each employee and program based on the predetermined percentage, and reported it through the Labor Distribution Report (485 Report). However, management did not perform a periodic comparison of actual costs to the budgeted costs and make any necessary adjustment as required by 2 CFR Section 200.430. Specifically, 41 out of 60 sampled payroll items tested for the HIVER grant were recorded based on estimated hours and not actual hours. Questioned Costs ? Not determinable. Context ? This is a condition identified per review of DC Health?s compliance with specified requirements using a statistically valid sample. Payroll costs including fringe benefits, for the HIVER program in fiscal year 2022 were $3,470,982. Effect ? DC Health was unable to demonstrate that the payroll expenditures charged to the HIVER grant accurately reflected the time incurred on the program and were properly supported in accordance with 2 CFR Part 200.430 time and effort reporting requirements. Cause ? DC Health did not have policies and procedures in place to review and reconcile the estimated amounts of payroll expenditures charged to the HIVER program to the actual expenditures incurred. Per corrective action plans and status updates submitted by DC Health to BDO in fiscal year 2022, significant milestones have been achieved however due to several change management tasks, the corrective action plan is still progressing into fiscal year 2023 and is expected to fully implement by September 30, 2023. Recommendation ? We recommend that DC Health fully implement its current corrective action plan to deploy policies and procedures to periodically compare employees? estimated hours per the 485 Report to the actual hours incurred, and make any necessary adjustments as required by 2 CFR 200.430. Related Noncompliance ? Material noncompliance. Views of Responsible Officials and Planned Corrective Actions ? The District Department of Health (DC Health) concurs with the finding, causes and recommendations cited in the fiscal year 2022 single audit for the HIV Emergency Relief Project Grants (HIVER) program. The current corrective action plan (CAP), originating from the prior year's finding had been actively implemented in fiscal year 2022 and reached significant milestones. DC Health asserts that while a process was implemented to obtain a regular schedule of payroll and budget- to-actual data for personnel, and supervisors were provided a tool and process for delivering ?time and effort certifications?, there were still some errors and omissions. DC Health concurs with the auditor on the need to continue implementation of the current CAP, but DC Health will modify processes and tools to ensure that there is the required periodic comparison of actual costs to the budgeted costs of personnel per the requirements of 2 CFR 200.430. Contributing factors were delays in distributing and receiving the required certifications, provision of technical assistance and training, and managing manual errors. Additionally, there were missing certifications due to a large turnover of staff, including many supervisors assigned to complete time and effort certification forms. In fiscal year 2022, reporting templates and reporting repositories were being revised and further developed and continued in fiscal year 2023. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-024 Prior Year Finding Number: N/A Compliance Requirement: Data Collection Form and Single Audit Reporting Package Programs: ALN: 10.551, 10.561 Supplemental Nutrition Assistance Program Cluster ALN: 10.553, 10.555, 10.559, 10.582 Child Nutrition Cluster ALN: 10.558 Child and Adult Care Food Program ALN: 14.218 Community Development Block Grants/Entitlement Grants Cluster ALN: 21.023 COVID-19 ? Emergency Rental Assistance Program ALN: 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Relief Funds ALN: 84.027, 84.173 Special Education Cluster ALN: 84.126 Rehabilitation Services - Vocational Rehabilitation Grants to States ALN: 84.425 COVID-19 ? Education Stabilization Fund ALN: 93.268 Immunization Cooperative Agreements ALN: 93.498 COVID-19 ? Provider Relief Fund ALN: 93.558 Temporary Assistance for Needy Families ALN: 93.568 Low Income Home Energy Assistance ALN: 93.569 Community Services Block Grant ALN: 93.658 Foster Care ? Title IV-E ALN: 93.775, 93.777, 93.778 Medicaid Cluster ALN: 93.914 HIV Emergency Relief Project Grants ALN: 97.036 Public Assistance - Presidentially Declared Disaster Criteria - The Uniform Guidance in 2 CFR Section 200.512, Report Submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor?s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Condition ? The District did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended September 30, 2022. Questioned Costs ? None. Context ? This is a condition identified per review of the District?s compliance with the specified requirements. Effect ? The District could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Cause ? The District did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe. Recommendation ? We recommend that the District closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? The District concurs with the auditor?s findings and recommendations. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-001 Prior Year Finding Number: 2021-001 Compliance Requirement: Special Tests and Provisions ? ADP System for SNAP Program: U.S. Department of Agriculture Supplemental Nutrition Assistance Program Cluster (SNAP) ALN: 10.551, 10.561 Award #: Various Award Year: 10/01/2021 ? 09/30/2022 Government Department/Agency: Department of Human Services (DHS)/ Department of Health Care Finance (DHCF) DC Access System (DCAS) Program Management Administration Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 2 CFR Section 272.10(a), ?All State agencies are required to sufficiently automate their SNAP operations and computerize their systems for obtaining, maintaining, utilizing, and transmitting information concerning SNAP.? Per 2 CFR Section 272.10(b), ?In order to meet the requirements of the Act and ensure the efficient and effective administration of the program, a SNAP system, at a minimum, shall be automated in each of the following program areas (1) Certification and (2) Issuance Reconciliation and Reporting. Under Certification ? States agencies must determine eligibility and calculate benefits or validate the eligibility worker?s calculations by processing and storing all casefile information necessary for the eligibility determination and benefit computation (including but not limited to all household members? names, addresses, dates of birth, social security numbers, individual household members? earned and unearned income by source, deductions, resources and household size). Also, State agencies must redetermine or revalidate eligibility and benefits based on notices of change in households? circumstances.? Condition ? The District is self-reporting findings it noted from its ongoing efforts to resolve issues with the ADP system for SNAP. The issues identified and the estimated impact follows: 1. The SNAP net and gross income tests are applied to households who are categorically eligible through receipt or authorization to receive non-cash benefits under the District?s Temporary Assistance for Needy Families (TANF) program operated to meet 7 CFR 273.2(j)(2)(i)(C). As a result, SNAP applications are being improperly denied for failing the net or gross income test. The cost of this underpayment is currently unknown. 2. The SNAP gross income test is applied to applicants that contain an elderly or disabled member. As a result, SNAP applications are being improperly denied for failing the gross income test. The cost of this underpayment is currently unknown. 3. SNAP benefits are issued for the initial month of the certification period if the prorated amount is less than $10. As a result, SNAP benefits are being improperly overissued to some households. The cost of this overpayment is $48,592. 4. The Federal minimum SNAP benefit is not issued to eligible one or two person households unless those households are categorically eligible. As a result, one or two person households that are not categorically eligible will not receive benefits they are entitled to. The cost of this underpayment is currently unknown. 5. Certain allowable medical expenses are not configured in DCAS to allow a medical expense deduction. As a result, certain households with elderly or disabled members are not receiving a medical expense deduction. The cost of this underpayment is currently unknown. 6. DCAS is excluding retirement benefits from ?Civil Service Retirement and Disability? as unearned income when determining eligibility and benefits levels. As a result, some households may be determined eligible even if these retirement benefits would make them ineligible and some households will receive overpayments for failing to include these retirement benefits in the SNAP benefit calculation. The cost of this overpayment is $126,574. 7. Certain SNAP applicants/household members verified as students but not meeting a student exemption are included as household members. As a result, ineligible students are included in SNAP households resulting in overpayments. The cost of this overpayment is $57,785. 8. ESA is not providing the mandatory homeless shelter deduction for SNAP households experiencing homelessness with allowable shelter costs that do not opt to claim an excess shelter deduction. The cost of this underpayment is currently unknown. 9. ESA is not terminating customers who refuse to cooperate with the District Quality Control (QC) reviewers. The District?s interviews with QC staff and examples of recent cases referred by QC to ESA for termination revealed that in two instances, a request to terminate a SNAP household was not acted on by ESA, and in one instance, a request to terminate a SNAP household was acted on but ESA issued a termination notice with an incorrect termination reason. The cost of this overpayment is currently unknown. 10. ESA is not acting on Electronic Disqualified Recipient System (eDRS) matches at initial application or when a new household member is added. The cost of this overpayment is currently unknown. 11. SNAP does not have a systemic way to identify SNAP customers subject to the Able-Bodied Adult Without Dependents (ABAWD) work requirements. The cost of this overpayment is currently $18,500 per month or $222,000 for fiscal year 2022. These amounts represent 0.09% of the total amounts paid by DHS in claims for beneficiary payments. DHS paid a total of $506,630,102 in beneficiary payments to all SNAP beneficiaries in fiscal year 2022. Questioned Costs ? Known amount is $454,951. Context ? This is a condition identified per review of DHS? compliance with specified requirements resulting from a system implementation. Effect ? Without an effectively designed and operated system in place, ineligible beneficiaries may receive benefits under the SNAP grant and DHS may make payments on behalf of those beneficiaries resulting in noncompliance with the eligibility requirements. Inaccurate beneficiary allotment payments could result in participants receiving benefits that they are not entitled to receive under the program. Cause ? DHS did not effectively design and operate the ADP system for SNAP which resulted to inaccurate benefit payments. Recommendation ? We recommend that DHS continue to evaluate and improve the new ADP system for SNAP to ensure that it addresses all the administration requirements of the SNAP program. Related Noncompliance ? Material noncompliance. Views of Responsible Officials and Planned Corrective Actions ? The DHS and DHCF DCAS team agree with the findings noted in this report. DHS self-reported these findings as part of the Agencies ongoing effort to maintain integrity with all eligibility determinations. The root cause for each of the eleven (11) issues with the ADP system for SNAP varied. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-002 Prior Year Finding Number: 2021-002 Compliance Requirement: Special Tests and Provisions ? EBT Card Security Program: U.S. Department of Agriculture Supplemental Nutrition Assistance Program Cluster (SNAP) ALN: 10.551, 10.561 Award #: Various Award Year: 10/01/2021 ? 09/30/2022 Government Department/Agency: Department of Human Services (DHS)/ Office of the Chief Financial Officer/Office of Finance and Treasury (OCFO/OFT) Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Per 7 CFR Section 274.8(b)(3), As an addition to or component of the Security Program required of Automated Data Processing (ADP) systems, the State agency shall ensure that the following electronic benefits transfer (EBT) security requirements are established: (i) Storage and control measures to control blank unissued EBT cards and PINs, and unused or spare POS devices; (ii) Measures to ensure communication access control. Communication controls shall include the transmission of transaction data and issuance information from POS terminals to work-stations and terminals at the data processing center; (iii) Message validation; (iv) Administrative and operational procedures; (v) A separate EBT security component shall be incorporated into the State agency Security Program for ADP systems. The periodic risk analyses required by the Security Program shall address the following items specific to an EBT system ? (B) Completeness and timeliness of the reconciliation system; and (vi) The State agency shall incorporate the contingency plan approved by FNS into the Security Program. Condition ? OCFO/OFT for DHS are required to maintain adequate security over, and documentation/records for EBT cards, to prevent their theft, embezzlement, loss damage, destruction, unauthorized transfer, negotiation, or use. OCFO/OFT have contracted with Fidelity National Information Service (FIS) for the issuance and security of the EBT cards; however, it is OCFO/OFT?s ultimate responsibility to ensure the contractor has controls in place to maintain adequate security over, and documentation/records of EBT cards. During our tests of the design and implementation of internal controls, we noted the following issues: ? For five (5) out of the 60 samples, although both EBT Balance Sheets reconciled with the EBT Card Issuance Logs included in the package, we noted the following deficiencies: o For one (1) of the samples, we noted that for at least one (1) customer the client signature was missing from the EBT Intake Form. o For three (3) of the samples, we noted that for at least one (1) customer on the UPO EBT Intake Form, the ID type for identification purposes was missing. o For one (1) of the samples, we noted that for at least one (1) customer the identification type was noted as referral on the EBT Intake Form, but no referral form was attached. Questioned Costs ? None. Context ? This is a condition identified per review of DHS? compliance with specified requirements using a statistically valid sample. Effect ? Without adequate internal controls to ensure compliance with EBT Card Security requirements, there is an increased risk that the inventory of EBT cards will not be properly maintained and accounted for. Cause ? OCFO/OFT for DHS does not have adequate policies and procedures in place to ensure adequate safeguarding, documentation over issuance and monitoring of EBT cards. Recommendation - We recommend that OCFO/OFT for DHS strengthen formal policies and procedures to maintain adequate security over, and documentation/records for EBT Cards. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? The OCFO/OFT for DHS concurs with this finding. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-024 Prior Year Finding Number: N/A Compliance Requirement: Data Collection Form and Single Audit Reporting Package Programs: ALN: 10.551, 10.561 Supplemental Nutrition Assistance Program Cluster ALN: 10.553, 10.555, 10.559, 10.582 Child Nutrition Cluster ALN: 10.558 Child and Adult Care Food Program ALN: 14.218 Community Development Block Grants/Entitlement Grants Cluster ALN: 21.023 COVID-19 ? Emergency Rental Assistance Program ALN: 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Relief Funds ALN: 84.027, 84.173 Special Education Cluster ALN: 84.126 Rehabilitation Services - Vocational Rehabilitation Grants to States ALN: 84.425 COVID-19 ? Education Stabilization Fund ALN: 93.268 Immunization Cooperative Agreements ALN: 93.498 COVID-19 ? Provider Relief Fund ALN: 93.558 Temporary Assistance for Needy Families ALN: 93.568 Low Income Home Energy Assistance ALN: 93.569 Community Services Block Grant ALN: 93.658 Foster Care ? Title IV-E ALN: 93.775, 93.777, 93.778 Medicaid Cluster ALN: 93.914 HIV Emergency Relief Project Grants ALN: 97.036 Public Assistance - Presidentially Declared Disaster Criteria - The Uniform Guidance in 2 CFR Section 200.512, Report Submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor?s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Condition ? The District did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended September 30, 2022. Questioned Costs ? None. Context ? This is a condition identified per review of the District?s compliance with the specified requirements. Effect ? The District could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Cause ? The District did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe. Recommendation ? We recommend that the District closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? The District concurs with the auditor?s findings and recommendations. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-003 Prior Year Finding Number: N/A Compliance Requirement: Reporting Program: U.S. Department of Agriculture Child Nutrition Cluster ALN: 10.553, 10.555, 10.559 and 10.582 Award #: 1DC300302 Award Year: 10/01/2021 ? 09/30/2022 Government Department/Agency: District of Columbia Public Schools (DCPS) Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. 7 CFR Section 210.8 Claims for Reimbursement states: (a) Internal controls. The school food authority shall establish internal controls which ensure the accuracy of meal counts prior to the submission of the monthly Claim for Reimbursement. At a minimum, these internal controls shall include: an on-site review of the meal counting and claiming system employed by each school within the jurisdiction of the school food authority; comparisons of daily free, reduced price and paid meal counts against data which will assist in the identification of meal counts in excess of the number of free, reduced price and paid meals served each day to children eligible for such meals; and a system for following up on those meal counts which suggest the likelihood of meal counting problems. (1) ?On-site reviews. Every school year, each school food authority with more than one school shall perform no less than one on-site review of the counting and claiming system and the readily observable general areas of review cited under Section 210.18(h), as prescribed by FNS for each school under its jurisdiction. The on-site review shall take place prior to February 1 of each school year. Further, if the review discloses problems with a school's meal counting or claiming procedures or general review areas, the school food authority shall: ensure that the school implements corrective action; and, within 45 days of the review, conducts a follow-up on-site review to determine that the corrective action resolved the problems. Each on-site review shall ensure that the school's claim is based on the counting system authorized by the State agency under Section 210.7(c) of this part and that the counting system, as implemented, yields the actual number of reimbursable free, reduced price and paid meals, respectively, served for each day of operation.? Condition ? DCPS conducted 158 on-site reviews in fiscal year 2022. We selected a sample of sixteen (16) on-site reviews and noted that DCPS is unable to provide evidence to support that a review took place on two (2) of the samples where DCPS assessed that the schools passed the on-site review. These on-site reviews are the main control of DCPS to ensure that the meal counts reported and eventually claimed for reimbursement to the Office of the State Superintendent of Education (OSSE) is accurate. Questioned Costs ? Not determinable. Context ? This is a condition identified per review of DCPS? compliance with specified requirements using a statistically valid sample. Effect ? DCPS did not comply with the reporting requirements of the Child Nutrition Cluster. Cause ? DCPS does not have a fully effective internal controls over record keeping of on-site review process. Recommendation ? We recommend DCPS to continue to enhance its controls over reporting to ensure compliance with the requirements of the Child Nutrition Cluster. This should include policies and procedures relating to record keeping of support for any on-site review conducted and enhance monitoring controls to ensure all supporting documentation over the on-site review are filed and available for inspection at any time. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? DCPS agrees with the conditions and recommendations of this finding. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-024 Prior Year Finding Number: N/A Compliance Requirement: Data Collection Form and Single Audit Reporting Package Programs: ALN: 10.551, 10.561 Supplemental Nutrition Assistance Program Cluster ALN: 10.553, 10.555, 10.559, 10.582 Child Nutrition Cluster ALN: 10.558 Child and Adult Care Food Program ALN: 14.218 Community Development Block Grants/Entitlement Grants Cluster ALN: 21.023 COVID-19 ? Emergency Rental Assistance Program ALN: 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Relief Funds ALN: 84.027, 84.173 Special Education Cluster ALN: 84.126 Rehabilitation Services - Vocational Rehabilitation Grants to States ALN: 84.425 COVID-19 ? Education Stabilization Fund ALN: 93.268 Immunization Cooperative Agreements ALN: 93.498 COVID-19 ? Provider Relief Fund ALN: 93.558 Temporary Assistance for Needy Families ALN: 93.568 Low Income Home Energy Assistance ALN: 93.569 Community Services Block Grant ALN: 93.658 Foster Care ? Title IV-E ALN: 93.775, 93.777, 93.778 Medicaid Cluster ALN: 93.914 HIV Emergency Relief Project Grants ALN: 97.036 Public Assistance - Presidentially Declared Disaster Criteria - The Uniform Guidance in 2 CFR Section 200.512, Report Submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor?s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Condition ? The District did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended September 30, 2022. Questioned Costs ? None. Context ? This is a condition identified per review of the District?s compliance with the specified requirements. Effect ? The District could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Cause ? The District did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe. Recommendation ? We recommend that the District closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? The District concurs with the auditor?s findings and recommendations. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-003 Prior Year Finding Number: N/A Compliance Requirement: Reporting Program: U.S. Department of Agriculture Child Nutrition Cluster ALN: 10.553, 10.555, 10.559 and 10.582 Award #: 1DC300302 Award Year: 10/01/2021 ? 09/30/2022 Government Department/Agency: District of Columbia Public Schools (DCPS) Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. 7 CFR Section 210.8 Claims for Reimbursement states: (a) Internal controls. The school food authority shall establish internal controls which ensure the accuracy of meal counts prior to the submission of the monthly Claim for Reimbursement. At a minimum, these internal controls shall include: an on-site review of the meal counting and claiming system employed by each school within the jurisdiction of the school food authority; comparisons of daily free, reduced price and paid meal counts against data which will assist in the identification of meal counts in excess of the number of free, reduced price and paid meals served each day to children eligible for such meals; and a system for following up on those meal counts which suggest the likelihood of meal counting problems. (1) ?On-site reviews. Every school year, each school food authority with more than one school shall perform no less than one on-site review of the counting and claiming system and the readily observable general areas of review cited under Section 210.18(h), as prescribed by FNS for each school under its jurisdiction. The on-site review shall take place prior to February 1 of each school year. Further, if the review discloses problems with a school's meal counting or claiming procedures or general review areas, the school food authority shall: ensure that the school implements corrective action; and, within 45 days of the review, conducts a follow-up on-site review to determine that the corrective action resolved the problems. Each on-site review shall ensure that the school's claim is based on the counting system authorized by the State agency under Section 210.7(c) of this part and that the counting system, as implemented, yields the actual number of reimbursable free, reduced price and paid meals, respectively, served for each day of operation.? Condition ? DCPS conducted 158 on-site reviews in fiscal year 2022. We selected a sample of sixteen (16) on-site reviews and noted that DCPS is unable to provide evidence to support that a review took place on two (2) of the samples where DCPS assessed that the schools passed the on-site review. These on-site reviews are the main control of DCPS to ensure that the meal counts reported and eventually claimed for reimbursement to the Office of the State Superintendent of Education (OSSE) is accurate. Questioned Costs ? Not determinable. Context ? This is a condition identified per review of DCPS? compliance with specified requirements using a statistically valid sample. Effect ? DCPS did not comply with the reporting requirements of the Child Nutrition Cluster. Cause ? DCPS does not have a fully effective internal controls over record keeping of on-site review process. Recommendation ? We recommend DCPS to continue to enhance its controls over reporting to ensure compliance with the requirements of the Child Nutrition Cluster. This should include policies and procedures relating to record keeping of support for any on-site review conducted and enhance monitoring controls to ensure all supporting documentation over the on-site review are filed and available for inspection at any time. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? DCPS agrees with the conditions and recommendations of this finding. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-024 Prior Year Finding Number: N/A Compliance Requirement: Data Collection Form and Single Audit Reporting Package Programs: ALN: 10.551, 10.561 Supplemental Nutrition Assistance Program Cluster ALN: 10.553, 10.555, 10.559, 10.582 Child Nutrition Cluster ALN: 10.558 Child and Adult Care Food Program ALN: 14.218 Community Development Block Grants/Entitlement Grants Cluster ALN: 21.023 COVID-19 ? Emergency Rental Assistance Program ALN: 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Relief Funds ALN: 84.027, 84.173 Special Education Cluster ALN: 84.126 Rehabilitation Services - Vocational Rehabilitation Grants to States ALN: 84.425 COVID-19 ? Education Stabilization Fund ALN: 93.268 Immunization Cooperative Agreements ALN: 93.498 COVID-19 ? Provider Relief Fund ALN: 93.558 Temporary Assistance for Needy Families ALN: 93.568 Low Income Home Energy Assistance ALN: 93.569 Community Services Block Grant ALN: 93.658 Foster Care ? Title IV-E ALN: 93.775, 93.777, 93.778 Medicaid Cluster ALN: 93.914 HIV Emergency Relief Project Grants ALN: 97.036 Public Assistance - Presidentially Declared Disaster Criteria - The Uniform Guidance in 2 CFR Section 200.512, Report Submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor?s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Condition ? The District did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended September 30, 2022. Questioned Costs ? None. Context ? This is a condition identified per review of the District?s compliance with the specified requirements. Effect ? The District could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Cause ? The District did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe. Recommendation ? We recommend that the District closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? The District concurs with the auditor?s findings and recommendations. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-003 Prior Year Finding Number: N/A Compliance Requirement: Reporting Program: U.S. Department of Agriculture Child Nutrition Cluster ALN: 10.553, 10.555, 10.559 and 10.582 Award #: 1DC300302 Award Year: 10/01/2021 ? 09/30/2022 Government Department/Agency: District of Columbia Public Schools (DCPS) Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. 7 CFR Section 210.8 Claims for Reimbursement states: (a) Internal controls. The school food authority shall establish internal controls which ensure the accuracy of meal counts prior to the submission of the monthly Claim for Reimbursement. At a minimum, these internal controls shall include: an on-site review of the meal counting and claiming system employed by each school within the jurisdiction of the school food authority; comparisons of daily free, reduced price and paid meal counts against data which will assist in the identification of meal counts in excess of the number of free, reduced price and paid meals served each day to children eligible for such meals; and a system for following up on those meal counts which suggest the likelihood of meal counting problems. (1) ?On-site reviews. Every school year, each school food authority with more than one school shall perform no less than one on-site review of the counting and claiming system and the readily observable general areas of review cited under Section 210.18(h), as prescribed by FNS for each school under its jurisdiction. The on-site review shall take place prior to February 1 of each school year. Further, if the review discloses problems with a school's meal counting or claiming procedures or general review areas, the school food authority shall: ensure that the school implements corrective action; and, within 45 days of the review, conducts a follow-up on-site review to determine that the corrective action resolved the problems. Each on-site review shall ensure that the school's claim is based on the counting system authorized by the State agency under Section 210.7(c) of this part and that the counting system, as implemented, yields the actual number of reimbursable free, reduced price and paid meals, respectively, served for each day of operation.? Condition ? DCPS conducted 158 on-site reviews in fiscal year 2022. We selected a sample of sixteen (16) on-site reviews and noted that DCPS is unable to provide evidence to support that a review took place on two (2) of the samples where DCPS assessed that the schools passed the on-site review. These on-site reviews are the main control of DCPS to ensure that the meal counts reported and eventually claimed for reimbursement to the Office of the State Superintendent of Education (OSSE) is accurate. Questioned Costs ? Not determinable. Context ? This is a condition identified per review of DCPS? compliance with specified requirements using a statistically valid sample. Effect ? DCPS did not comply with the reporting requirements of the Child Nutrition Cluster. Cause ? DCPS does not have a fully effective internal controls over record keeping of on-site review process. Recommendation ? We recommend DCPS to continue to enhance its controls over reporting to ensure compliance with the requirements of the Child Nutrition Cluster. This should include policies and procedures relating to record keeping of support for any on-site review conducted and enhance monitoring controls to ensure all supporting documentation over the on-site review are filed and available for inspection at any time. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? DCPS agrees with the conditions and recommendations of this finding. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-024 Prior Year Finding Number: N/A Compliance Requirement: Data Collection Form and Single Audit Reporting Package Programs: ALN: 10.551, 10.561 Supplemental Nutrition Assistance Program Cluster ALN: 10.553, 10.555, 10.559, 10.582 Child Nutrition Cluster ALN: 10.558 Child and Adult Care Food Program ALN: 14.218 Community Development Block Grants/Entitlement Grants Cluster ALN: 21.023 COVID-19 ? Emergency Rental Assistance Program ALN: 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Relief Funds ALN: 84.027, 84.173 Special Education Cluster ALN: 84.126 Rehabilitation Services - Vocational Rehabilitation Grants to States ALN: 84.425 COVID-19 ? Education Stabilization Fund ALN: 93.268 Immunization Cooperative Agreements ALN: 93.498 COVID-19 ? Provider Relief Fund ALN: 93.558 Temporary Assistance for Needy Families ALN: 93.568 Low Income Home Energy Assistance ALN: 93.569 Community Services Block Grant ALN: 93.658 Foster Care ? Title IV-E ALN: 93.775, 93.777, 93.778 Medicaid Cluster ALN: 93.914 HIV Emergency Relief Project Grants ALN: 97.036 Public Assistance - Presidentially Declared Disaster Criteria - The Uniform Guidance in 2 CFR Section 200.512, Report Submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor?s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Condition ? The District did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended September 30, 2022. Questioned Costs ? None. Context ? This is a condition identified per review of the District?s compliance with the specified requirements. Effect ? The District could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Cause ? The District did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe. Recommendation ? We recommend that the District closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? The District concurs with the auditor?s findings and recommendations. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-003 Prior Year Finding Number: N/A Compliance Requirement: Reporting Program: U.S. Department of Agriculture Child Nutrition Cluster ALN: 10.553, 10.555, 10.559 and 10.582 Award #: 1DC300302 Award Year: 10/01/2021 ? 09/30/2022 Government Department/Agency: District of Columbia Public Schools (DCPS) Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. 7 CFR Section 210.8 Claims for Reimbursement states: (a) Internal controls. The school food authority shall establish internal controls which ensure the accuracy of meal counts prior to the submission of the monthly Claim for Reimbursement. At a minimum, these internal controls shall include: an on-site review of the meal counting and claiming system employed by each school within the jurisdiction of the school food authority; comparisons of daily free, reduced price and paid meal counts against data which will assist in the identification of meal counts in excess of the number of free, reduced price and paid meals served each day to children eligible for such meals; and a system for following up on those meal counts which suggest the likelihood of meal counting problems. (1) ?On-site reviews. Every school year, each school food authority with more than one school shall perform no less than one on-site review of the counting and claiming system and the readily observable general areas of review cited under Section 210.18(h), as prescribed by FNS for each school under its jurisdiction. The on-site review shall take place prior to February 1 of each school year. Further, if the review discloses problems with a school's meal counting or claiming procedures or general review areas, the school food authority shall: ensure that the school implements corrective action; and, within 45 days of the review, conducts a follow-up on-site review to determine that the corrective action resolved the problems. Each on-site review shall ensure that the school's claim is based on the counting system authorized by the State agency under Section 210.7(c) of this part and that the counting system, as implemented, yields the actual number of reimbursable free, reduced price and paid meals, respectively, served for each day of operation.? Condition ? DCPS conducted 158 on-site reviews in fiscal year 2022. We selected a sample of sixteen (16) on-site reviews and noted that DCPS is unable to provide evidence to support that a review took place on two (2) of the samples where DCPS assessed that the schools passed the on-site review. These on-site reviews are the main control of DCPS to ensure that the meal counts reported and eventually claimed for reimbursement to the Office of the State Superintendent of Education (OSSE) is accurate. Questioned Costs ? Not determinable. Context ? This is a condition identified per review of DCPS? compliance with specified requirements using a statistically valid sample. Effect ? DCPS did not comply with the reporting requirements of the Child Nutrition Cluster. Cause ? DCPS does not have a fully effective internal controls over record keeping of on-site review process. Recommendation ? We recommend DCPS to continue to enhance its controls over reporting to ensure compliance with the requirements of the Child Nutrition Cluster. This should include policies and procedures relating to record keeping of support for any on-site review conducted and enhance monitoring controls to ensure all supporting documentation over the on-site review are filed and available for inspection at any time. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? DCPS agrees with the conditions and recommendations of this finding. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-024 Prior Year Finding Number: N/A Compliance Requirement: Data Collection Form and Single Audit Reporting Package Programs: ALN: 10.551, 10.561 Supplemental Nutrition Assistance Program Cluster ALN: 10.553, 10.555, 10.559, 10.582 Child Nutrition Cluster ALN: 10.558 Child and Adult Care Food Program ALN: 14.218 Community Development Block Grants/Entitlement Grants Cluster ALN: 21.023 COVID-19 ? Emergency Rental Assistance Program ALN: 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Relief Funds ALN: 84.027, 84.173 Special Education Cluster ALN: 84.126 Rehabilitation Services - Vocational Rehabilitation Grants to States ALN: 84.425 COVID-19 ? Education Stabilization Fund ALN: 93.268 Immunization Cooperative Agreements ALN: 93.498 COVID-19 ? Provider Relief Fund ALN: 93.558 Temporary Assistance for Needy Families ALN: 93.568 Low Income Home Energy Assistance ALN: 93.569 Community Services Block Grant ALN: 93.658 Foster Care ? Title IV-E ALN: 93.775, 93.777, 93.778 Medicaid Cluster ALN: 93.914 HIV Emergency Relief Project Grants ALN: 97.036 Public Assistance - Presidentially Declared Disaster Criteria - The Uniform Guidance in 2 CFR Section 200.512, Report Submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor?s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Condition ? The District did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended September 30, 2022. Questioned Costs ? None. Context ? This is a condition identified per review of the District?s compliance with the specified requirements. Effect ? The District could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Cause ? The District did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe. Recommendation ? We recommend that the District closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? The District concurs with the auditor?s findings and recommendations. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-024 Prior Year Finding Number: N/A Compliance Requirement: Data Collection Form and Single Audit Reporting Package Programs: ALN: 10.551, 10.561 Supplemental Nutrition Assistance Program Cluster ALN: 10.553, 10.555, 10.559, 10.582 Child Nutrition Cluster ALN: 10.558 Child and Adult Care Food Program ALN: 14.218 Community Development Block Grants/Entitlement Grants Cluster ALN: 21.023 COVID-19 ? Emergency Rental Assistance Program ALN: 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Relief Funds ALN: 84.027, 84.173 Special Education Cluster ALN: 84.126 Rehabilitation Services - Vocational Rehabilitation Grants to States ALN: 84.425 COVID-19 ? Education Stabilization Fund ALN: 93.268 Immunization Cooperative Agreements ALN: 93.498 COVID-19 ? Provider Relief Fund ALN: 93.558 Temporary Assistance for Needy Families ALN: 93.568 Low Income Home Energy Assistance ALN: 93.569 Community Services Block Grant ALN: 93.658 Foster Care ? Title IV-E ALN: 93.775, 93.777, 93.778 Medicaid Cluster ALN: 93.914 HIV Emergency Relief Project Grants ALN: 97.036 Public Assistance - Presidentially Declared Disaster Criteria - The Uniform Guidance in 2 CFR Section 200.512, Report Submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor?s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Condition ? The District did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended September 30, 2022. Questioned Costs ? None. Context ? This is a condition identified per review of the District?s compliance with the specified requirements. Effect ? The District could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Cause ? The District did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe. Recommendation ? We recommend that the District closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? The District concurs with the auditor?s findings and recommendations. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-003 Prior Year Finding Number: N/A Compliance Requirement: Reporting Program: U.S. Department of Agriculture Child Nutrition Cluster ALN: 10.553, 10.555, 10.559 and 10.582 Award #: 1DC300302 Award Year: 10/01/2021 ? 09/30/2022 Government Department/Agency: District of Columbia Public Schools (DCPS) Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. 7 CFR Section 210.8 Claims for Reimbursement states: (a) Internal controls. The school food authority shall establish internal controls which ensure the accuracy of meal counts prior to the submission of the monthly Claim for Reimbursement. At a minimum, these internal controls shall include: an on-site review of the meal counting and claiming system employed by each school within the jurisdiction of the school food authority; comparisons of daily free, reduced price and paid meal counts against data which will assist in the identification of meal counts in excess of the number of free, reduced price and paid meals served each day to children eligible for such meals; and a system for following up on those meal counts which suggest the likelihood of meal counting problems. (1) ?On-site reviews. Every school year, each school food authority with more than one school shall perform no less than one on-site review of the counting and claiming system and the readily observable general areas of review cited under Section 210.18(h), as prescribed by FNS for each school under its jurisdiction. The on-site review shall take place prior to February 1 of each school year. Further, if the review discloses problems with a school's meal counting or claiming procedures or general review areas, the school food authority shall: ensure that the school implements corrective action; and, within 45 days of the review, conducts a follow-up on-site review to determine that the corrective action resolved the problems. Each on-site review shall ensure that the school's claim is based on the counting system authorized by the State agency under Section 210.7(c) of this part and that the counting system, as implemented, yields the actual number of reimbursable free, reduced price and paid meals, respectively, served for each day of operation.? Condition ? DCPS conducted 158 on-site reviews in fiscal year 2022. We selected a sample of sixteen (16) on-site reviews and noted that DCPS is unable to provide evidence to support that a review took place on two (2) of the samples where DCPS assessed that the schools passed the on-site review. These on-site reviews are the main control of DCPS to ensure that the meal counts reported and eventually claimed for reimbursement to the Office of the State Superintendent of Education (OSSE) is accurate. Questioned Costs ? Not determinable. Context ? This is a condition identified per review of DCPS? compliance with specified requirements using a statistically valid sample. Effect ? DCPS did not comply with the reporting requirements of the Child Nutrition Cluster. Cause ? DCPS does not have a fully effective internal controls over record keeping of on-site review process. Recommendation ? We recommend DCPS to continue to enhance its controls over reporting to ensure compliance with the requirements of the Child Nutrition Cluster. This should include policies and procedures relating to record keeping of support for any on-site review conducted and enhance monitoring controls to ensure all supporting documentation over the on-site review are filed and available for inspection at any time. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? DCPS agrees with the conditions and recommendations of this finding. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-024 Prior Year Finding Number: N/A Compliance Requirement: Data Collection Form and Single Audit Reporting Package Programs: ALN: 10.551, 10.561 Supplemental Nutrition Assistance Program Cluster ALN: 10.553, 10.555, 10.559, 10.582 Child Nutrition Cluster ALN: 10.558 Child and Adult Care Food Program ALN: 14.218 Community Development Block Grants/Entitlement Grants Cluster ALN: 21.023 COVID-19 ? Emergency Rental Assistance Program ALN: 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Relief Funds ALN: 84.027, 84.173 Special Education Cluster ALN: 84.126 Rehabilitation Services - Vocational Rehabilitation Grants to States ALN: 84.425 COVID-19 ? Education Stabilization Fund ALN: 93.268 Immunization Cooperative Agreements ALN: 93.498 COVID-19 ? Provider Relief Fund ALN: 93.558 Temporary Assistance for Needy Families ALN: 93.568 Low Income Home Energy Assistance ALN: 93.569 Community Services Block Grant ALN: 93.658 Foster Care ? Title IV-E ALN: 93.775, 93.777, 93.778 Medicaid Cluster ALN: 93.914 HIV Emergency Relief Project Grants ALN: 97.036 Public Assistance - Presidentially Declared Disaster Criteria - The Uniform Guidance in 2 CFR Section 200.512, Report Submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor?s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Condition ? The District did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended September 30, 2022. Questioned Costs ? None. Context ? This is a condition identified per review of the District?s compliance with the specified requirements. Effect ? The District could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Cause ? The District did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe. Recommendation ? We recommend that the District closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? The District concurs with the auditor?s findings and recommendations. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-023 Prior Year Finding Number: 2021-023 Compliance Requirement: Reporting Program: U.S. Department of Homeland Security Federal Emergency Management Agency (FEMA) Public Assistance - Presidentially Declared Disaster ALN: 97.036 Award #: FEMA-4502-DR-DC and FEMA-3553-EM-DC Award Year: 10/01/2021 ? 09/30/2022 Government Department/Agency: Homeland Security and Emergency Management Agency (HSEMA) Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. In accordance with 2 CFR Part 170, Appendix A, under the Federal Funding Accountability and Transparency Act (FFATA), the department is required to collect and report information on each subaward or amendment of $30,000 or more in federal funds in the FFATA Subaward Reporting System. In accordance with the requirements of 2 CFR Section 1402.300, the non-Federal entity is responsible for complying with all requirements of the Federal award. For all Federal awards, this includes the provisions of FFATA, which includes requirements on executive compensation, and also requirements implementing the Act for the non-Federal entity at 2 CFR part 25 Financial Assistance Use of Universal Identifier and System for Award Management and 2 CFR part 170 Reporting Subaward and Executive Compensation Information. Condition ? Our examination of the program?s reporting requirements identified that Homeland Security and Emergency Management Agency failed to collect and report information on subawards or amendments of $30,000 or more in federal funds in the FFATA Subaward Reporting System to fulfil the FFATA requirements for the entire year under audit. Questioned Costs ? None. Context ? This is a condition identified per review of HSEMA?s compliance with reporting requirements. No sampling was performed as no FFATA reporting was completed by HSEMA during the year under audit. Effect ? HSEMA is not in compliance with reporting requirements as it failed to provide evidence of identifying and reporting FFATA reporting requirements. Cause ? HSEMA did not have proper internal controls and policies and procedures in place to fulfill the FFATA reporting requirement. Recommendation ? We recommend that HSEMA should implement policies, procedures and controls that will ensure compliance with all the required laws, guidelines and requirement under the award. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? HSEMA concurs with the substance of the finding. The FFATA report for this grant is currently incomplete. HSEMA has procedures in place to file FFATA reports and does so for the other grants it manages. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-024 Prior Year Finding Number: N/A Compliance Requirement: Data Collection Form and Single Audit Reporting Package Programs: ALN: 10.551, 10.561 Supplemental Nutrition Assistance Program Cluster ALN: 10.553, 10.555, 10.559, 10.582 Child Nutrition Cluster ALN: 10.558 Child and Adult Care Food Program ALN: 14.218 Community Development Block Grants/Entitlement Grants Cluster ALN: 21.023 COVID-19 ? Emergency Rental Assistance Program ALN: 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Relief Funds ALN: 84.027, 84.173 Special Education Cluster ALN: 84.126 Rehabilitation Services - Vocational Rehabilitation Grants to States ALN: 84.425 COVID-19 ? Education Stabilization Fund ALN: 93.268 Immunization Cooperative Agreements ALN: 93.498 COVID-19 ? Provider Relief Fund ALN: 93.558 Temporary Assistance for Needy Families ALN: 93.568 Low Income Home Energy Assistance ALN: 93.569 Community Services Block Grant ALN: 93.658 Foster Care ? Title IV-E ALN: 93.775, 93.777, 93.778 Medicaid Cluster ALN: 93.914 HIV Emergency Relief Project Grants ALN: 97.036 Public Assistance - Presidentially Declared Disaster Criteria - The Uniform Guidance in 2 CFR Section 200.512, Report Submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor?s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Condition ? The District did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended September 30, 2022. Questioned Costs ? None. Context ? This is a condition identified per review of the District?s compliance with the specified requirements. Effect ? The District could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Cause ? The District did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe. Recommendation ? We recommend that the District closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? The District concurs with the auditor?s findings and recommendations. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-023 Prior Year Finding Number: 2021-023 Compliance Requirement: Reporting Program: U.S. Department of Homeland Security Federal Emergency Management Agency (FEMA) Public Assistance - Presidentially Declared Disaster ALN: 97.036 Award #: FEMA-4502-DR-DC and FEMA-3553-EM-DC Award Year: 10/01/2021 ? 09/30/2022 Government Department/Agency: Homeland Security and Emergency Management Agency (HSEMA) Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. In accordance with 2 CFR Part 170, Appendix A, under the Federal Funding Accountability and Transparency Act (FFATA), the department is required to collect and report information on each subaward or amendment of $30,000 or more in federal funds in the FFATA Subaward Reporting System. In accordance with the requirements of 2 CFR Section 1402.300, the non-Federal entity is responsible for complying with all requirements of the Federal award. For all Federal awards, this includes the provisions of FFATA, which includes requirements on executive compensation, and also requirements implementing the Act for the non-Federal entity at 2 CFR part 25 Financial Assistance Use of Universal Identifier and System for Award Management and 2 CFR part 170 Reporting Subaward and Executive Compensation Information. Condition ? Our examination of the program?s reporting requirements identified that Homeland Security and Emergency Management Agency failed to collect and report information on subawards or amendments of $30,000 or more in federal funds in the FFATA Subaward Reporting System to fulfil the FFATA requirements for the entire year under audit. Questioned Costs ? None. Context ? This is a condition identified per review of HSEMA?s compliance with reporting requirements. No sampling was performed as no FFATA reporting was completed by HSEMA during the year under audit. Effect ? HSEMA is not in compliance with reporting requirements as it failed to provide evidence of identifying and reporting FFATA reporting requirements. Cause ? HSEMA did not have proper internal controls and policies and procedures in place to fulfill the FFATA reporting requirement. Recommendation ? We recommend that HSEMA should implement policies, procedures and controls that will ensure compliance with all the required laws, guidelines and requirement under the award. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? HSEMA concurs with the substance of the finding. The FFATA report for this grant is currently incomplete. HSEMA has procedures in place to file FFATA reports and does so for the other grants it manages. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.
Finding Number: 2022-024 Prior Year Finding Number: N/A Compliance Requirement: Data Collection Form and Single Audit Reporting Package Programs: ALN: 10.551, 10.561 Supplemental Nutrition Assistance Program Cluster ALN: 10.553, 10.555, 10.559, 10.582 Child Nutrition Cluster ALN: 10.558 Child and Adult Care Food Program ALN: 14.218 Community Development Block Grants/Entitlement Grants Cluster ALN: 21.023 COVID-19 ? Emergency Rental Assistance Program ALN: 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Relief Funds ALN: 84.027, 84.173 Special Education Cluster ALN: 84.126 Rehabilitation Services - Vocational Rehabilitation Grants to States ALN: 84.425 COVID-19 ? Education Stabilization Fund ALN: 93.268 Immunization Cooperative Agreements ALN: 93.498 COVID-19 ? Provider Relief Fund ALN: 93.558 Temporary Assistance for Needy Families ALN: 93.568 Low Income Home Energy Assistance ALN: 93.569 Community Services Block Grant ALN: 93.658 Foster Care ? Title IV-E ALN: 93.775, 93.777, 93.778 Medicaid Cluster ALN: 93.914 HIV Emergency Relief Project Grants ALN: 97.036 Public Assistance - Presidentially Declared Disaster Criteria - The Uniform Guidance in 2 CFR Section 200.512, Report Submission, states that the audit must be completed and the data collection form and reporting package must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after receipt of the auditor?s report or nine (9) months after the end of the audit period, unless a longer period is agreed to in advance by the cognizant or oversight agency for audit. Condition ? The District did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended September 30, 2022. Questioned Costs ? None. Context ? This is a condition identified per review of the District?s compliance with the specified requirements. Effect ? The District could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Cause ? The District did not comply with the controls in place to ensure that the reporting package was submitted to the FAC within the required timeframe. Recommendation ? We recommend that the District closely monitor and comply to the established controls to ensure the reporting package is submitted to the FAC annually within the required timeframe. Related Noncompliance ? Noncompliance. Views of Responsible Officials and Planned Corrective Actions ? The District concurs with the auditor?s findings and recommendations. The District?s corrective action is described in the Management?s Corrective Action Plan included as Appendix B of the attached Management?s Section.