2023-007 Assistance Listing No. 96.001 , 96.006 and Social Security Disability lnsurance Cluster
Type of Compliance Requirement: Period of Performance
lnternal controls over period of performance were not consistentlv performed
Response:
Of the five instances noted in the auditor's "Period of Perfor...
2023-007 Assistance Listing No. 96.001 , 96.006 and Social Security Disability lnsurance Cluster
Type of Compliance Requirement: Period of Performance
lnternal controls over period of performance were not consistentlv performed
Response:
Of the five instances noted in the auditor's "Period of Performance" test work, we concur
with four. With one of the sample items, however, we argue that since the service was
invoiced on a State Fiscal Year, it was impractical to further split the invoice into the various
appropriate Federal periods of performance, especially given the way those specific
invoices are allocated between other shared program areas within our agency, etc.
Corrective Action Plan:
Our agency takes these findings seraously and will continue to evaluate ways of improving
controls. At a minimum, it is our intent to increase and provide additional training to the
staff overseeing and approving these types of transactions so that they can accurately
apply transactions to the appropriate periods. This was something we had already begun
(i.e. provrding additional guidance and training to stafD during the current fiscal year. So,
we hope our agency is already on a corrective path. But, we will continue to push for more
training in the immediate future and strive for improvement in all other aspects.
We also think it is important to note that, of the findings identifled by the auditors related to
"Period of Performance," those items were discovered out of a total sample size oI 120
items (i.e. 60 sample items related to thejr "Period of Performance" test work and 60 sample items related to "General Disbursements" test work). So, a slightly larger sample
size than that of the 60 referenced in the auditor's schedule of flndings. Additionally, the
auditor's sample appeared to selectively target the specific periods and transactions that
would have been most susceptible to these types of potential errors. And, although we are
not objecting to the way in which the sample was selected, we would.just point out that this
approach of sample selection may not be truly reflective of a purely random sample
covering all transactions across the entire fiscal year. Therefore, although we ultimately
concur with the findings here, we do not necessarily believe these results paint the fairest
picture on the overall effectiveness of our agency's controls across the more than '100,000
transactions that would have been processed during the period of audit for this program.
Again, we take these findings seriously. But, based on the audit test work and results, we
feel the controls we have in place are ultimately working adequately enough to mitigate the
potential for material misstatements. Regardless, we will continue to monitor and evaluate
our controls to help further reduce the risk of these types of issues moving forward.
Planned completion date for corrective action plan: lmmediately. But, additional training for
managers to be provided by September 30, 2024.