Audit 47077

FY End
2022-06-30
Total Expended
$3.68M
Findings
6
Programs
32
Organization: Warren County, North Carolina (NC)
Year: 2022 Accepted: 2023-03-29

Organization Exclusion Status:

Checking exclusion status...

Findings

ID Ref Severity Repeat Requirement
50528 2022-004 Material Weakness Yes E
50529 2022-005 Material Weakness Yes L
50530 2022-006 Material Weakness - E
626970 2022-004 Material Weakness Yes E
626971 2022-005 Material Weakness Yes L
626972 2022-006 Material Weakness - E

Programs

ALN Program Spent Major Findings
93.778 Medical Assistance Program $920,771 Yes 2
93.563 Child Support Enforcement $407,744 - 0
10.561 State Administrative Matching Grants for the Supplemental Nutrition Assistance Program $385,425 - 0
93.558 Temporary Assistance for Needy Families $249,880 - 0
93.568 Low-Income Home Energy Assistance $202,200 Yes 0
93.667 Social Services Block Grant $192,360 - 0
10.557 Special Supplemental Nutrition Program for Women, Infants, and Children $107,182 - 0
93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $106,737 - 0
93.994 Maternal and Child Health Services Block Grant to the States $64,049 - 0
93.044 Special Programs for the Aging_title Iii, Part B_grants for Supportive Services and Senior Centers $63,660 - 0
93.596 Child Care Mandatory and Matching Funds of the Child Care and Development Fund $61,218 - 0
93.268 Immunization Cooperative Agreements $58,167 - 0
93.391 Activities to Support State, Tribal, Local and Territorial (stlt) Health Department Response to Public Health Or Healthcare Crises $39,821 - 0
93.045 Special Programs for the Aging_title Iii, Part C_nutrition Services $37,024 - 0
93.217 Family Planning_services $26,555 - 0
93.991 Preventive Health and Health Services Block Grant $25,308 - 0
21.027 Coronavirus State and Local Fiscal Recovery Funds $23,671 - 0
93.069 Public Health Emergency Preparedness $22,030 - 0
93.053 Nutrition Services Incentive Program $19,635 - 0
93.659 Adoption Assistance $14,821 - 0
97.042 Emergency Management Performance Grants $14,212 - 0
93.767 Children's Health Insurance Program $13,785 - 0
93.645 Stephanie Tubbs Jones Child Welfare Services Program $10,361 - 0
93.658 Foster Care_title IV-E $7,096 - 0
93.898 Cancer Prevention and Control Programs for State, Territorial and Tribal Organizations $5,550 - 0
93.324 State Health Insurance Assistance Program $2,534 - 0
93.052 National Family Caregiver Support, Title Iii, Part E $2,205 - 0
93.674 John H. Chafee Foster Care Program for Successful Transition to Adulthood $1,223 - 0
10.556 Special Milk Program for Children $173 - 0
93.977 Preventive Health Services_sexually Transmitted Diseases Control Grants $58 - 0
93.116 Project Grants and Cooperative Agreements for Tuberculosis Control Programs $50 - 0
93.566 Refugee and Entrant Assistance_state Administered Programs $-1,305 - 0

Contacts

Name Title Type
WLTATC4JLJ54 Lee Faines Auditee
2522571778 Jennifer Reese Auditor
No contacts on file

Notes to SEFA

Accounting Policies: Expenditures reported in the SEFA are reported on the modified accrual basis of accounting. Such expenditures are recognized following the cost principles contained in Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursements. De Minimis Rate Used: N Rate Explanation: The auditee did not use the 10-percent de minimis cost rate as allowed under the Uniform Guidance.

Finding Details

US Department of Health and Human Services Passed-through the NC Dept. of Health and Human Services Program Name: Medical Assistance Program (Medicaid; Title XIX) CFDA #: 93.778 Finding: 2022-4 MATERIAL WEAKNESS Required verifications and documentation for Eligibility Criteria: Per the North Carolina Medicaid Assistance Program Compliance Supplement, the DSS manuals (Aged, Blind and Disabled manual and the Family and Children Medicaid manual), and Administrative Letters from the Division of Health Benefits case files for individuals or families receiving assistance are required to retain documentation to evidence appropriate eligibility determination, including verifications of and support for: ? Age ? Citizenship/Identity ? State residency ? Household composition and relationship ? Living arrangement ? Social Security Number ? Pregnancy (if applicable) ? Disability, Blindness (if applicable) ? Medicare ? Cooperation with Child Support ? Liquid Assets ? Vehicles and Other Personal Property ? Real Property ? Deductibles ? Income (Self-employment, Other earned income, Unearned income) ? Accurate computation of countable income and resources. ? Reviews/Applications must be completed timely. The DSS manuals and Administrative Letters also provide income maintenance amounts and resource limits for the respective Medicaid program and budget unit size. The computed countable income and resources must be under these limits for the person / family to be eligible for the Medicaid program. Condition: We noted 45 instances of case records not containing the proper verifications or proper computations as required by policy. The files for four claims did not contain appropriate verification of real property ownership with the Register of Deeds Office and the Tax Office. Files for 7 claims did not properly verify or document vehicles per policy. Vehicles were not rebutted timely, not keyed into evidence timely or not keyed into evidence at all. Thirteen of the claims had files that did not properly verify or document bank accounts. Ownership of account was not entered correctly. Accounts were not verified correctly or entered into evidence correctly or timely. Two claims included burial plans that were not accurately reflected in the case file. There 12 claims where the corresponding files show that policy was not followed and verified correctly including evidence entered after the eligibility check, exparte reviews not being completed timely, citizenship, reduction of reserve, level of care and FL-2 not being updated or in the file, required visit of facility due to level of care not being performed, SA payments being calculated incorrectly, and SSI applications and follow up to determine status not performed. There were files related to seven claims that income was not counted correctly or not updated in evidence. Questioned Costs: There were $15.32 in known errors. The known error rate projects or extrapolates to the entire population of claims paid for the year to an estimated $28,184 in questioned costs for claims paid during the fiscal year. Context: Out of $45,601,990 Medicaid claims paid during the year, we tested the Medicaid certification of eligibility (initial application or recertification of eligibility) that related to the period that included the date of service for the claim being tested for 101 claims that totaled $24,788. The conditions noted above were noted in 22 of the 101 claims tested. Effect: Case files not containing all required documentation result in a risk that the County could provide services to individuals not eligible to receive such services or that such individuals could be denied access to eligible benefits. Upon notification of the missing documentation or the errors in calculations in the case files, the County was able to obtain documentation and provide corrected calculations to substantiate that the recipients tested were eligible to receive benefits in all but 2 claims. Those claims totaled $15.32. Identification of a repeat finding: This is a repeat finding from previous audits, 2021-5, 2020-1, 2019-1, 2017-1, 2017-2, 2016-1, 2016-2, 2016-3, 2016-4, 2016-5, and 2016-6. Cause: The County did not obtain or retain required documentation in case files at the time that eligibility was determined. The review performed by the caseworker was ineffective in determining that all required items were retained, that all calculations were accurate, and that all necessary information was entered into NCFast. Recommendation: We recommend that the County train and monitor employees on the eligibility determination process, specifically those areas noted to have errors above. Files should be reviewed internally to ensure proper documentation is in place for eligibility. Work aids for areas such as resources may be helpful for Caseworkers as they document the eligibility process. NCFast should be reviewed to determine that information gathered during the review is properly input into the system and that system driven calculations are utilizing the available information. Views of responsible officials and planned corrective actions: The County will continue to train employees on a monthly basis and as needed when new and updated policies are received. Supervisors and lead workers will continue to conduct second party reviews and utilizing any findings to aid in training staff on any necessary policy information. The County added a Quality Control position effective January 1, 2021, to assist with conducting second party reviews and training. During Fiscal Year 2021 an experienced supervisor was hired for adult Medicaid with extensive knowledge of long-term care and SA policy. This has led to internal process changes for the department. The department will continue to implement changes as necessary to achieve the overall improvement of eligibility determinations.
US Department of Health and Human Services Passed-through the NC Dept. of Health and Human Services Program Name: Medical Assistance Program (Medicaid; Title XIX) CFDA #: 93.778 Finding: 2022-5 MATERIAL WEAKNESS DSS Crosscutting Requirements for Reporting Criteria: Employee timesheets for in-home aides? payroll should be completed timely and completely so all time is properly approved for payroll and included in the monthly 1571 report submitted to the State. All time included on the report should be supported by documentation within the casefiles or other documentation maintained by the County. Also, Day Sheets are completed for all client-facing employees to document the time spent spent working on cases and what the work that was done. All work should be accurately recorded and recorded to the correct client. Condition: We noted that the report submitted to the reporting officer did not match the manual time sheets filled out by the in-home aides for the time worked by salaried and hourly in-home aides. Time was not documented properly for administrative time on their manual time sheets. All discrepancies were around the documentation of administrative or paid time off and what was documented on the in-home aides? time sheets differed from what was on the Day Sheet. Questioned Costs: None. Finding relates to reporting criteria. As the time reported on the 1571 did agree, there are no questioned costs. Context: We reviewed in-home payroll. Out of the 3 in-home aides we reviewed, all had issues with their time sheets. For caseworkers, we selected 4 cases each for 10 employees. All caseworkers were able to provide justification for time listed. Effect: Time included on the employee?s signed time sheet but not included on the Daysheet and thus the 1571 report creates an issue in the County being able to properly track things such as benefits since many times the time that was underreported were in the areas of vacation and sick leave. Reporting of time worked on the 1571 by Caseworkers for work performed on cases that cannot be supported may lead to reimbursements for work that was not actually performed or that cannot be reperformed since the documentation is missing. Identification of a repeat finding: This is a repeat finding from previous audits, 2021-6, 2020-2, and 2019-2. Cause: Ineffective review of the timesheets. Timesheets for all full-time employees should account for a full work week and be approved by a supervisor. Recommendation: We recommend that employees ensure that there is support maintained in files to support the work performed and claimed on their time sheets. The County should continue to implement the review process started during this fiscal year of the timesheets for in-home aides where a sample is taken monthly to review support for the time claimed on the timesheets to verify that in-home aides are reporting time accurately and completely and that required support is being maintained. Administration should also review the program to determine that most effective and efficient resource allocation is being utilized to service the clients in the program. The review process started with the in-home aides should be considered for expansion to other areas for review of Daysheets to ensure accurate reporting of time on the Daysheets monthly. Overall, for this fiscal year, there was some improvement seen in the area of in-home aide time sheet tracking but with the administrative time there were still issues between the manual time sheet and the Daysheet of information being transferred and reconciled between the two. The worker seems to be more conscientious about recording all of their time and not just their field time but now the reconciliation between the two reports needs to be improved and tightened up. Views of responsible officials and planned corrective actions: Employees will be provided a refresher training on documentation of time sheets. Supervisors will be provided training on the review and reconciliation of data between the timesheet and the daysheet.
US Department of Health and Human Services Passed-through the NC Dept. of Health and Human Services Program Name: Low Income Home energy Assistance CFDA #: 93.568 Finding: 2022-6 MATERIAL WEAKNESS/SIGNIFICANT NONCOMPLIANCE Required verifications and documentation for Eligibility Criteria: Per the North Carolina Low-Income Home Energy Assistance Compliance Supplement, the DSS manuals (Energy Programs Manual and others referenced therein), and Administrative Letters from the Division of Health Benefits case files for individuals or families receiving assistance are required to retain documentation to evidence appropriate eligibility determination, including verifications of and support for: ? Household composition ? Citizenship ? Vulnerability ? Income and Deductions ? Energy-related crisis (CIP only) The DSS manuals and Administrative Letters also provide income maintenance amounts for the respective energy program and budget unit size. The computed countable income must be under these limits for the person / family to be eligible for the Medicaid program. Condition: We noted 37 instances of case records not containing the proper verifications or proper computations as required by policy. The files for 5 applications did not calculate income using the gross pay. 13 files for applications did not calculate income using an income averaging method as described in the manual and instead used actual income for the base period. Files for 4 applications did not record or use the correct social security payment in income. 1 additional application did not properly record or use the correct earned income in the income calculation. 10 applications for CIP did not document a life-threatening emergency AND the danger of a household member if the crisis was not alleviated or an illness/medical condition that poses an immediate risk to health or life of any household member. 1 application included a medical condition that posed an immediate risk to health or life, but the person was not included in the household. There were 3 applications that were not approved for the full amount of the crisis because the County was applying an annual maximum benefit for CIP of $600. For the Federal Fiscal Year 2022, the annual maximum for CIP was $1,000. Questioned Costs: There were $3,168 in known errors. The known error rate projects or extrapolates to the entire population of claims paid for the year to an estimated $59,333 in questioned costs for claims paid during the fiscal year. Context: Out of $338,557 claims paid during the year, we tested the eligibility of the application for 40 claims that totaled $18,076. The conditions noted above were noted in 26 of the 40 applications tested. Effect: Case files not containing all required documentation result in a risk that the County could provide benefits to individuals not eligible to receive such benefits or that such individuals could be denied access to eligible benefits. Upon notification of the missing documentation or the errors in calculations in the case files, the County was able to obtain documentation and provide corrected calculations to substantiate that the recipients tested were eligible to receive benefits in all but 11 claims. Those claims totaled $3,168. Identification of a repeat finding: This is a new finding. Cause: The County did not obtain or retain required documentation in case files at the time that eligibility was determined. The review performed by the caseworker was ineffective in determining that all required items were retained, that all calculations were accurate, and that all necessary information was entered into NCFast. Recommendation: We recommend that the County train and monitor employees on the eligibility determination process, specifically those areas noted to have errors above. Files should be reviewed internally to ensure proper documentation is in place for eligibility. Work aids for areas such as income may be helpful for Caseworkers as they document the eligibility process. NCFast should be reviewed to determine that information gathered during the review is properly input into the system and that system driven calculations are utilizing the available information. Views of responsible officials and planned corrective actions: The County agrees with the finding. The Crisis Department will do a monthly review of Crisis and LIEAP policies to stay on top of any changes that may occur between fiscal years and to ensure we are implementing correct procedures. We will also perform self-audits monthly. We will randomly pull two applications from each caseworker to ensure that we are improving on areas we?ve made errors in the past and that we are correctly documenting/processing applications. Based on any findings/questions we have during these self-audits, we will contact our state representative for clarifications.
US Department of Health and Human Services Passed-through the NC Dept. of Health and Human Services Program Name: Medical Assistance Program (Medicaid; Title XIX) CFDA #: 93.778 Finding: 2022-4 MATERIAL WEAKNESS Required verifications and documentation for Eligibility Criteria: Per the North Carolina Medicaid Assistance Program Compliance Supplement, the DSS manuals (Aged, Blind and Disabled manual and the Family and Children Medicaid manual), and Administrative Letters from the Division of Health Benefits case files for individuals or families receiving assistance are required to retain documentation to evidence appropriate eligibility determination, including verifications of and support for: ? Age ? Citizenship/Identity ? State residency ? Household composition and relationship ? Living arrangement ? Social Security Number ? Pregnancy (if applicable) ? Disability, Blindness (if applicable) ? Medicare ? Cooperation with Child Support ? Liquid Assets ? Vehicles and Other Personal Property ? Real Property ? Deductibles ? Income (Self-employment, Other earned income, Unearned income) ? Accurate computation of countable income and resources. ? Reviews/Applications must be completed timely. The DSS manuals and Administrative Letters also provide income maintenance amounts and resource limits for the respective Medicaid program and budget unit size. The computed countable income and resources must be under these limits for the person / family to be eligible for the Medicaid program. Condition: We noted 45 instances of case records not containing the proper verifications or proper computations as required by policy. The files for four claims did not contain appropriate verification of real property ownership with the Register of Deeds Office and the Tax Office. Files for 7 claims did not properly verify or document vehicles per policy. Vehicles were not rebutted timely, not keyed into evidence timely or not keyed into evidence at all. Thirteen of the claims had files that did not properly verify or document bank accounts. Ownership of account was not entered correctly. Accounts were not verified correctly or entered into evidence correctly or timely. Two claims included burial plans that were not accurately reflected in the case file. There 12 claims where the corresponding files show that policy was not followed and verified correctly including evidence entered after the eligibility check, exparte reviews not being completed timely, citizenship, reduction of reserve, level of care and FL-2 not being updated or in the file, required visit of facility due to level of care not being performed, SA payments being calculated incorrectly, and SSI applications and follow up to determine status not performed. There were files related to seven claims that income was not counted correctly or not updated in evidence. Questioned Costs: There were $15.32 in known errors. The known error rate projects or extrapolates to the entire population of claims paid for the year to an estimated $28,184 in questioned costs for claims paid during the fiscal year. Context: Out of $45,601,990 Medicaid claims paid during the year, we tested the Medicaid certification of eligibility (initial application or recertification of eligibility) that related to the period that included the date of service for the claim being tested for 101 claims that totaled $24,788. The conditions noted above were noted in 22 of the 101 claims tested. Effect: Case files not containing all required documentation result in a risk that the County could provide services to individuals not eligible to receive such services or that such individuals could be denied access to eligible benefits. Upon notification of the missing documentation or the errors in calculations in the case files, the County was able to obtain documentation and provide corrected calculations to substantiate that the recipients tested were eligible to receive benefits in all but 2 claims. Those claims totaled $15.32. Identification of a repeat finding: This is a repeat finding from previous audits, 2021-5, 2020-1, 2019-1, 2017-1, 2017-2, 2016-1, 2016-2, 2016-3, 2016-4, 2016-5, and 2016-6. Cause: The County did not obtain or retain required documentation in case files at the time that eligibility was determined. The review performed by the caseworker was ineffective in determining that all required items were retained, that all calculations were accurate, and that all necessary information was entered into NCFast. Recommendation: We recommend that the County train and monitor employees on the eligibility determination process, specifically those areas noted to have errors above. Files should be reviewed internally to ensure proper documentation is in place for eligibility. Work aids for areas such as resources may be helpful for Caseworkers as they document the eligibility process. NCFast should be reviewed to determine that information gathered during the review is properly input into the system and that system driven calculations are utilizing the available information. Views of responsible officials and planned corrective actions: The County will continue to train employees on a monthly basis and as needed when new and updated policies are received. Supervisors and lead workers will continue to conduct second party reviews and utilizing any findings to aid in training staff on any necessary policy information. The County added a Quality Control position effective January 1, 2021, to assist with conducting second party reviews and training. During Fiscal Year 2021 an experienced supervisor was hired for adult Medicaid with extensive knowledge of long-term care and SA policy. This has led to internal process changes for the department. The department will continue to implement changes as necessary to achieve the overall improvement of eligibility determinations.
US Department of Health and Human Services Passed-through the NC Dept. of Health and Human Services Program Name: Medical Assistance Program (Medicaid; Title XIX) CFDA #: 93.778 Finding: 2022-5 MATERIAL WEAKNESS DSS Crosscutting Requirements for Reporting Criteria: Employee timesheets for in-home aides? payroll should be completed timely and completely so all time is properly approved for payroll and included in the monthly 1571 report submitted to the State. All time included on the report should be supported by documentation within the casefiles or other documentation maintained by the County. Also, Day Sheets are completed for all client-facing employees to document the time spent spent working on cases and what the work that was done. All work should be accurately recorded and recorded to the correct client. Condition: We noted that the report submitted to the reporting officer did not match the manual time sheets filled out by the in-home aides for the time worked by salaried and hourly in-home aides. Time was not documented properly for administrative time on their manual time sheets. All discrepancies were around the documentation of administrative or paid time off and what was documented on the in-home aides? time sheets differed from what was on the Day Sheet. Questioned Costs: None. Finding relates to reporting criteria. As the time reported on the 1571 did agree, there are no questioned costs. Context: We reviewed in-home payroll. Out of the 3 in-home aides we reviewed, all had issues with their time sheets. For caseworkers, we selected 4 cases each for 10 employees. All caseworkers were able to provide justification for time listed. Effect: Time included on the employee?s signed time sheet but not included on the Daysheet and thus the 1571 report creates an issue in the County being able to properly track things such as benefits since many times the time that was underreported were in the areas of vacation and sick leave. Reporting of time worked on the 1571 by Caseworkers for work performed on cases that cannot be supported may lead to reimbursements for work that was not actually performed or that cannot be reperformed since the documentation is missing. Identification of a repeat finding: This is a repeat finding from previous audits, 2021-6, 2020-2, and 2019-2. Cause: Ineffective review of the timesheets. Timesheets for all full-time employees should account for a full work week and be approved by a supervisor. Recommendation: We recommend that employees ensure that there is support maintained in files to support the work performed and claimed on their time sheets. The County should continue to implement the review process started during this fiscal year of the timesheets for in-home aides where a sample is taken monthly to review support for the time claimed on the timesheets to verify that in-home aides are reporting time accurately and completely and that required support is being maintained. Administration should also review the program to determine that most effective and efficient resource allocation is being utilized to service the clients in the program. The review process started with the in-home aides should be considered for expansion to other areas for review of Daysheets to ensure accurate reporting of time on the Daysheets monthly. Overall, for this fiscal year, there was some improvement seen in the area of in-home aide time sheet tracking but with the administrative time there were still issues between the manual time sheet and the Daysheet of information being transferred and reconciled between the two. The worker seems to be more conscientious about recording all of their time and not just their field time but now the reconciliation between the two reports needs to be improved and tightened up. Views of responsible officials and planned corrective actions: Employees will be provided a refresher training on documentation of time sheets. Supervisors will be provided training on the review and reconciliation of data between the timesheet and the daysheet.
US Department of Health and Human Services Passed-through the NC Dept. of Health and Human Services Program Name: Low Income Home energy Assistance CFDA #: 93.568 Finding: 2022-6 MATERIAL WEAKNESS/SIGNIFICANT NONCOMPLIANCE Required verifications and documentation for Eligibility Criteria: Per the North Carolina Low-Income Home Energy Assistance Compliance Supplement, the DSS manuals (Energy Programs Manual and others referenced therein), and Administrative Letters from the Division of Health Benefits case files for individuals or families receiving assistance are required to retain documentation to evidence appropriate eligibility determination, including verifications of and support for: ? Household composition ? Citizenship ? Vulnerability ? Income and Deductions ? Energy-related crisis (CIP only) The DSS manuals and Administrative Letters also provide income maintenance amounts for the respective energy program and budget unit size. The computed countable income must be under these limits for the person / family to be eligible for the Medicaid program. Condition: We noted 37 instances of case records not containing the proper verifications or proper computations as required by policy. The files for 5 applications did not calculate income using the gross pay. 13 files for applications did not calculate income using an income averaging method as described in the manual and instead used actual income for the base period. Files for 4 applications did not record or use the correct social security payment in income. 1 additional application did not properly record or use the correct earned income in the income calculation. 10 applications for CIP did not document a life-threatening emergency AND the danger of a household member if the crisis was not alleviated or an illness/medical condition that poses an immediate risk to health or life of any household member. 1 application included a medical condition that posed an immediate risk to health or life, but the person was not included in the household. There were 3 applications that were not approved for the full amount of the crisis because the County was applying an annual maximum benefit for CIP of $600. For the Federal Fiscal Year 2022, the annual maximum for CIP was $1,000. Questioned Costs: There were $3,168 in known errors. The known error rate projects or extrapolates to the entire population of claims paid for the year to an estimated $59,333 in questioned costs for claims paid during the fiscal year. Context: Out of $338,557 claims paid during the year, we tested the eligibility of the application for 40 claims that totaled $18,076. The conditions noted above were noted in 26 of the 40 applications tested. Effect: Case files not containing all required documentation result in a risk that the County could provide benefits to individuals not eligible to receive such benefits or that such individuals could be denied access to eligible benefits. Upon notification of the missing documentation or the errors in calculations in the case files, the County was able to obtain documentation and provide corrected calculations to substantiate that the recipients tested were eligible to receive benefits in all but 11 claims. Those claims totaled $3,168. Identification of a repeat finding: This is a new finding. Cause: The County did not obtain or retain required documentation in case files at the time that eligibility was determined. The review performed by the caseworker was ineffective in determining that all required items were retained, that all calculations were accurate, and that all necessary information was entered into NCFast. Recommendation: We recommend that the County train and monitor employees on the eligibility determination process, specifically those areas noted to have errors above. Files should be reviewed internally to ensure proper documentation is in place for eligibility. Work aids for areas such as income may be helpful for Caseworkers as they document the eligibility process. NCFast should be reviewed to determine that information gathered during the review is properly input into the system and that system driven calculations are utilizing the available information. Views of responsible officials and planned corrective actions: The County agrees with the finding. The Crisis Department will do a monthly review of Crisis and LIEAP policies to stay on top of any changes that may occur between fiscal years and to ensure we are implementing correct procedures. We will also perform self-audits monthly. We will randomly pull two applications from each caseworker to ensure that we are improving on areas we?ve made errors in the past and that we are correctly documenting/processing applications. Based on any findings/questions we have during these self-audits, we will contact our state representative for clarifications.