Corrective Action Plans

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ACOE updated the purchasing procurement policy and offered agency-wide training.
ACOE updated the purchasing procurement policy and offered agency-wide training.
View Audit 293447 Questioned Costs: $1
ACOE updated the new Time and Effort policy and offered agency-wide training.
ACOE updated the new Time and Effort policy and offered agency-wide training.
View Audit 293447 Questioned Costs: $1
Finding #2023-001 – Material Weakness and Material Noncompliance. Major programs: U. S. Department of Health and Human Services:, Assistance Listing #93.243, Substance Abuse and Mental Health Services Projects of Regional and National Significance, Contract #5H79TI080624-03, Contract year: 09/30/2...
Finding #2023-001 – Material Weakness and Material Noncompliance. Major programs: U. S. Department of Health and Human Services:, Assistance Listing #93.243, Substance Abuse and Mental Health Services Projects of Regional and National Significance, Contract #5H79TI080624-03, Contract year: 09/30/21 – 09/29/22, Contract #5H79TI080624-04, Contract year: 09/30/22 – 09/29/23, Assistance Listing #93.959, Block Grants for Prevention and Treatment of Substance Abuse, Passed through the Texas Health and Human Services Commission, Contract #HHS000130500019, Contract years: 09/01/21 – 08/31/22 and 09/01/22 – 08/31/23, Passed through the City of Houston Health Department, Contract #H79SP080300, Contract years: 11/01/21 – 10/31/22, 11/01/22 – 10/31/23 and 06/08/21 – 06/30/23. Other federal programs: U. S. Department of Treasury, Assistance Listing #21.027, COVID-19 Coronavirus State and Local Fiscal Recovery Funds, Passed through Harris County, Texas, Contract #220163, Contract year: 12/01/22 – 12/31/24, Assistance Listing #93.788, Opioid STR, Passed through the Texas Health and Human Services Commission, Contract #HHS000357900001, Contract years: 09/01/21 – 08/31/22 and 09/01/22 – 08/31/23, Passed through the University of Texas Health Science Center, San Antonio, Contract #HHS000561800001, Contract year: 09/01/21 – 08/31/22. Condition and context: Houston Recovery Center has personnel funded by more than one grant award. The responsibilities for each position are examined and an assessment of time needed to perform each assigned task is made. The time allotment is then converted to a percentage of salary, documented on the personnel action form for each employee, and used to create the personnel section of each grant budget. Each grant is charged based on the percentages documented on the personnel action forms. In fiscal 2022, quarterly time studies were utilized to support that the budgeted estimates per the personnel action forms were reasonable and, if needed, adjustments were made in the general ledger. On July 1, 2022, Houston Recovery Center changed third-party payroll processors and the new processor did not provide the capability to charge time to more than one cost center. Therefore, while allocations are still made in the general ledger based on the percentages documented on the employee’s personnel action form, actual time worked by grant/cost center was not tracked. Additionally, a time study was not performed in the year ended June 30, 2023 to evaluate the reasonableness of time charged to the grants. Recommendation: Houston Recovery Center should establish policies and procedures to ensure that grants are charged based on actual time and effort expended. Planned corrective action: Management believes that the grants were reasonably charged in all material respects although the payroll provider was unable to allow us to use actual time and effort. Comparison of fiscal year 2022 actual time and effort with the fiscal year 2022 time studies revealed very small differences. However, Houston Recovery Center is in the process of changing to a payroll software provider where actual time can be tracked to each grant as supported by a timesheet. In addition, Houston Recovery Center is using Time Distribution Sheets (TDSs) where the employee is required to record their hours worked by grants. Training on the TDSs will be completed by November 1, 2023 for all employees on multiple awards as appropriate. TDSs will be turned in weekly and utilized until the payroll conversion is completed and is working as needed. Responsible officer: Leonard Kincaid, Executive Director. Estimated completion date: November 1, 2023.
Internal Control over Compliance- Cash Management Recommendation: Internal controls are designed to ensure an adequate review and approval process is in place before submission of any drawdown requests. Explanation of disagreement with audit finding: There is no disagreement with the audit finding...
Internal Control over Compliance- Cash Management Recommendation: Internal controls are designed to ensure an adequate review and approval process is in place before submission of any drawdown requests. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Response by management to the finding: Management has implemented appropriate controls to ensure drawdowns are reviewed and approved by staff familiar with the purpose and operations of the contracts before requests are processed in the payment management system. Name of the contact person responsible for corrective action: David Rivera-Garcia, Executive Vice President/CFO Planned completion date for corrective action plan: June 2024
Finding 372076 (2023-001)
Significant Deficiency 2023
Condition: The Town has not documented in writing its policies regarding federal awards. Corrective Action Planned: A financial policy for managing receipt of federal awards is in the process of being created by the Financial Policies Committee Anticipated Completion Date: December 31, 2024 ...
Condition: The Town has not documented in writing its policies regarding federal awards. Corrective Action Planned: A financial policy for managing receipt of federal awards is in the process of being created by the Financial Policies Committee Anticipated Completion Date: December 31, 2024 Contact: April Steward, Town Administrator
Management concurs with the finding and is implementing the following corrective actions: • The University’s Cost Transfer for Sponsored Projects policy has been updated (completed February 2024) to include more specific language regarding the timing requirements for awards from the National Insti...
Management concurs with the finding and is implementing the following corrective actions: • The University’s Cost Transfer for Sponsored Projects policy has been updated (completed February 2024) to include more specific language regarding the timing requirements for awards from the National Institutes of Health, the Department of Health and Human Services, and Other Sponsoring agencies (see below). • Management will regularly send targeted communication to the Principal Investigators and the appropriate research administrators in their academic units that hold awards from the Department of Health and Human Services agencies (non-NIH) as a reminder that DHHS requires permissible cost transfers to be made promptly after the error occurs but no later than 90 days following occurrence unless a longer period is approved in advance by the Grants Management Office. • Management will provide ongoing communication to the research community about the importance of adhering to cost transfer deadlines through its various communication channels, including, but not limited to, Research Administrator meetings and the Research News emails. Update to Cost Transfer for Sponsored Projects policy: Faculty and staff are responsible for ensuring that Cost Transfers are processed in a timely manner. Cost Transfers should be prepared and submitted within 90 days from the date of discovery (per National Institutes of Health Grants Policy Statement section 7.5). In cases when the sponsor’s (federal or non-federal) terms and conditions relating to the timing of Cost Transfers are stricter than this policy, the sponsor’s terms and conditions are applicable and supersede this policy. Note: The Department of Health and Human Services agencies (e.g., funding from HRSA, CDC, AHRQ…) grants policy requires cost transfers to be made promptly after the error occurs but no later than 90 days following occurrence unless a longer period is approved in advance by the GMO. Completion Date: June 30, 2024 University Contact and Responsible Party: Joseph M. Gindhart, (314) 935-7089
CORONAVIRUS STATE AND LOCAL RECOVERY FUNDS, ASSISTANCE LISTING 21.027 : INELIGIBLE COSTS / UNIFORM GUIDANCE 2 CFR PART 200 UNIFORM ADMINISTRATIVE REQUIREMENTS, COST PRINCIPLES, AND AUDIT REQUIREMENTS FOR FEDERAL AWARDS, SUBPART E: COST PRINCIPLES SECTION 200.403(F) STATE "EXCEPT WHERE OTHERWISE AUTH...
CORONAVIRUS STATE AND LOCAL RECOVERY FUNDS, ASSISTANCE LISTING 21.027 : INELIGIBLE COSTS / UNIFORM GUIDANCE 2 CFR PART 200 UNIFORM ADMINISTRATIVE REQUIREMENTS, COST PRINCIPLES, AND AUDIT REQUIREMENTS FOR FEDERAL AWARDS, SUBPART E: COST PRINCIPLES SECTION 200.403(F) STATE "EXCEPT WHERE OTHERWISE AUTHORIZED BY STATUTE, COSTS MUST MEET THE FOLLOWING CRITERIA IN ORDER TO BE ALLOWABLE UNDER FEDERAL AWARDS: (F) NOT BE INCLUDED AS A COST OR USED TO MEET COST SHARING OR MATCHING REQUIREMENTS OF ANY OTHER FEDERALLY-FINANCED PROGRAM IN EITHER THE CURRENT OR PRIOR PERIOD. / THE CITY OF EAST PRAIRIE RECEIVED ARPA FUNDS THROUGH MISSISSIPPI COUNTY, MISSOURI FOR THE REMOVAL OF ASBESTOS AND DEMOLITION OF A HAZARDOUS SCHOOL STRUCTURE IN ORDER TO FACILITATE THE CONSTRUCTION OF A PUBLIC HEALTH FACILITY IN AUGUST AND SEPTEMBER, 2022. IN DECEMBER OF THE SAME YEAR, THE CITY RECEIVED WAS AWARDED AND ARPA GRANT AND FUNDS THROUGH THE MISSOURI DEPARTMENT OF ELEMENTARY AND SECONDARY EDUCATION FOR THE SAME PROJECT. THIS WAS A DUPLICATION OF ARPA FUNDS DUE TO THE CITY NOT BEING FULLY AWARE OF THE COST STANDARDS OF UNIFORM GUIDANCE AND A MISCOMMUNICATION REGARDING ELIGIBILITY OF COSTS. / THE CITY OF EAST PRAIRIE HAS CONTACTED MISSISSIPPI COUNTY AND WILL BE RECEIVING AUTHORIZATION FROM THE MISSISSIPPI COUNTY COMMISSION TO RE-ALLOCATE THOSE FUNDS FOR THE SAME PUBLIC HEALTH FACILITY PROJECT. WE ARE ALSO DEVELOPING A WRITTEN POLICY AND PROCEDURE MANUAL CONFORMING TO UNIFORM GUIDANCE.
View Audit 293337 Questioned Costs: $1
COMMUNITY DEVELOPMENT BLOCK GRANT/ ASSISTANCE LISTING 14.228; HIGHWAY PLANNING AND CONSTRUCTION CLUSTER, ASSISTANCE LISTING 20.205 / WRITTEN POLICIES AND PROCEDURES/ UNIFORM GUIDANCE 2 CFR PART 200 UNIFORM ADMINISTRATIVE REQUIREMENTS, COST PRINCIPLES, AND AUDIT REQUIREMENTS FOR FEDERAL AWARDS, SUBPA...
COMMUNITY DEVELOPMENT BLOCK GRANT/ ASSISTANCE LISTING 14.228; HIGHWAY PLANNING AND CONSTRUCTION CLUSTER, ASSISTANCE LISTING 20.205 / WRITTEN POLICIES AND PROCEDURES/ UNIFORM GUIDANCE 2 CFR PART 200 UNIFORM ADMINISTRATIVE REQUIREMENTS, COST PRINCIPLES, AND AUDIT REQUIREMENTS FOR FEDERAL AWARDS, SUBPART D-POST FEDERAL AWARD REQUIREMENTS SECTION 200.300 THROUGH 200.346 REQUIRES THAT THE GRANTEE ESTABLISH WITTEN POLICIES AND PROCEDURES FOR ADMINISTRATION OF THE APPLICABLE FEDERAL COMPLIANCE REQUIREMENTS. THE CITY OPERATES UNDER APPROVED WRITTEN POLICIES FOR PROCUREMENT AND CONFLICTS OF INTEREST, BUT THE APPROVED WRITTEN POLICIES DO NOT CONTAIN ALL THE REQUIRED ELEMENTS OF THE UNIFORM GUIDANCE, AND WAS NOT AWARE THAT UNIFORM GUIDANCE REQUIRED WRITTEN POLICIES AND PROCEDURES FOR EACH APPLICABLE COMPLIANCE REQUIREMENT. / THE CITY IS IN AGREEMENT AND IS DEVELOPING A WRITTEN POLICY AND PROCEDURE MANUAL THAT WILL ADDRESS THE ADMINISTRATION OF EACH APPLICABLE FEDERAL COMPLIANCE REQUIREMENT TO CONFORM TO THE UNIFORM GUIDANCE.
Enrollment Reporting Name of contact person responsible for Corrective Action Plan: Whitney Costner, Registrar Corrective Action Plan: We concur with the finding. The University is currently implementing additional controls and procedures to ensure that all student roster files are reviewed, updated...
Enrollment Reporting Name of contact person responsible for Corrective Action Plan: Whitney Costner, Registrar Corrective Action Plan: We concur with the finding. The University is currently implementing additional controls and procedures to ensure that all student roster files are reviewed, updated, and submitted in accordance with applicable compliance requirements. Anticipated Completion Date: January 2024
Finding Number: 2023-006 Condition: Of the 9 students selected for enrollment reporting testing, the Seminary did not properly update student enrollment Information for 1 student in a timely manner. Planned Corrective Action: For students who finish their degree in December, they are reported as "wi...
Finding Number: 2023-006 Condition: Of the 9 students selected for enrollment reporting testing, the Seminary did not properly update student enrollment Information for 1 student in a timely manner. Planned Corrective Action: For students who finish their degree in December, they are reported as "withdrawn" as there is no option to confer in December (institutional policy). The student status is updated to "graduated" and reported to Clearinghouse in May when students are conferred. Contact person responsible for corrective action: Vince McGlothin-Eller, Registrar Anticipated Completion Date: 05/31/2024
Finding Number: 2023-003 Condition: The Seminary did not have controls in place to identify and document the students who have withdrawn and the applicability of performing a return of Title IV funds. Planned Corrective Action: Financial Aid Director has established a procedure to ensure that R2T4 c...
Finding Number: 2023-003 Condition: The Seminary did not have controls in place to identify and document the students who have withdrawn and the applicability of performing a return of Title IV funds. Planned Corrective Action: Financial Aid Director has established a procedure to ensure that R2T4 calculations are completed and any funds due to be returned are sent back to the Department of Education within 45 days of the date of the student's withdrawal. The Financial Aid Director created a listing to track all student withdrawals (including details of withdrawal). The Registrar sends an email to the Financial Aid Director notifying when a student has withdrawn from the institution, which gets entered onto the list. The Financial Aid Director set up the Department of Education's R2T4 calculator for the 2023-2024 academic year. R2T4 calculations are completed for any student withdrawn and if necessary, funds are returned to the Department of Education. Contact person responsible for corrective action: Ashley Schreiner, Director of Financial Aid Anticipated Completion Date: 09/05/2023 (beginning of Fall 2023 term)
View Audit 293235 Questioned Costs: $1
March 1, 2024 FEDERAL AWARD FINDINGS AND QUESTIONED COSTS 2023-001 – Eligibility - Tenant File Documentation Finding Type. Immaterial noncompliance, Significant deficiency in internal controls over compliance (Eligibility) Federal programs U.S. Department of Housing and Urban Development  Supp...
March 1, 2024 FEDERAL AWARD FINDINGS AND QUESTIONED COSTS 2023-001 – Eligibility - Tenant File Documentation Finding Type. Immaterial noncompliance, Significant deficiency in internal controls over compliance (Eligibility) Federal programs U.S. Department of Housing and Urban Development  Supportive Housing for the Elderly (ALN# 14.157)  Section 8 Housing Assistance Payments Program (ALN# 14.195) Condition. Out of a sample of 8 tenant files, we noted three instances where an EIV was not run for a tenant within 90 days of move in. Additionally, out of a sample of 8 tenant files, we noted one instance where a refund check was not disbursed to the tenant within 60 days of move out. Effect. As a result of this condition, employees did not follow HUD guideline procedures. While there were no differences in the amount of subsidies allowed upon review of the subsequent EIV compared to subsidies received, the lack of effective internal controls could lead to future significant noncompliance. Additionally, a former tenant was not disbursed a refund in a timely manner under the HUD guidelines. Plan. Management agrees with finding 2023-001. All files are to be inspected in the current fiscal year to ensure compliance with HUD regulations. File maintenance will be competed following each move in, move out, and annual recertification. In addition to one-on-one training, the housing administrator has signed up for additional training including a WebEx on annual recertification and a basic EIV course. Additional training sessions are forthcoming. Contact Person Responsible for This Corrective Action: Laura Maisevich, Senior Housing Manager Anticipated completion date: December 31, 2024
March 1, 2024 FEDERAL AWARD FINDINGS AND QUESTIONED COSTS 2023-001 – Eligibility - Tenant File Documentation Finding Type. Immaterial noncompliance, Significant deficiency in internal controls over compliance (Eligibility) Federal programs U.S. Department of Housing and Urban Development  Supp...
March 1, 2024 FEDERAL AWARD FINDINGS AND QUESTIONED COSTS 2023-001 – Eligibility - Tenant File Documentation Finding Type. Immaterial noncompliance, Significant deficiency in internal controls over compliance (Eligibility) Federal programs U.S. Department of Housing and Urban Development  Supportive Housing for the Elderly (ALN# 14.157) Condition. Out of a sample of 6 tenant files, it was noted: 1. Two out of six instances where an EIV was not run for a tenant file within 90 days of move in; 2. One out of six instances where the incorrect tenant income was used to calculate the tenant assistance payment; 3. One out of six instances where a tenant moved out and the requested overages were not adjusted for the correct time period; In addition, procedures were not in place to document the applicants, admissions, and removals to and from the tenant waitlist. Effect. As a result of this condition, certain tenant files did not contain all required supporting documentation. In addition, employees did not follow HUD guideline procedures, and/or did not properly calculate the tenant subsidy in HUD Form 50059. While there were no significant differences in the amount of subsidies allowed compared to subsidies received, the lack of effective internal controls could lead to future significant noncompliance. Plan. Management agrees with finding 2023-001. All files are to be inspected in the current fiscal year to ensure compliance with HUD regulations. File maintenance will be competed following each move in and annual recertification. In addition to one-on-one training, the housing administrator has signed up for additional training including a WebEx on annual recertification and a basic EIV course. Additional training sessions are forthcoming. A tenant waitlist will be created and maintained. Contact Person Responsible for This Corrective Action: Laura Maisevich, Senior Housing Manager Anticipated completion date: December 31, 2024
March 1, 2024 FEDERAL AWARD FINDINGS AND QUESTIONED COSTS 2023-001 – Timely Payment of Mortgage Balance Finding Type. Immaterial noncompliance, Significant deficiency in internal controls over compliance (Special Tests and Provisions) Federal programs U.S. Department of Housing and Urban Deve...
March 1, 2024 FEDERAL AWARD FINDINGS AND QUESTIONED COSTS 2023-001 – Timely Payment of Mortgage Balance Finding Type. Immaterial noncompliance, Significant deficiency in internal controls over compliance (Special Tests and Provisions) Federal programs U.S. Department of Housing and Urban Development Supportive Housing for the Elderly (ALN# 14.157) Condition. Out of 12 monthly payments on the Project's HUD insured mortgage payable, that are due each fiscal year, 1 payment was late, resulting in a late fee. Effect. As a result of this condition, the mortgage was not paid on time. While there was ultimately payment of the delinquent monthly balance, the lack of effective internal controls could lead to future significant noncompliance. Plan. Management agrees with finding 2023-001 and has developed the following plan. Mortgage invoices are now sent to two accounts payable employees, as well as a monitored inbox, to ensure timely processing. Contact Person Responsible for This Corrective Action: David DeFrain Anticipated completion date: July 17, 2023
March 1, 2024 FEDERAL AWARD FINDINGS AND QUESTIONED COSTS 2023-001 – Timely Payment of Mortgage Balance Finding Type. Immaterial noncompliance, Significant deficiency in internal controls over compliance (Special Tests and Provisions) Federal programs U.S. Department of Housing and Urban Deve...
March 1, 2024 FEDERAL AWARD FINDINGS AND QUESTIONED COSTS 2023-001 – Timely Payment of Mortgage Balance Finding Type. Immaterial noncompliance, Significant deficiency in internal controls over compliance (Special Tests and Provisions) Federal programs U.S. Department of Housing and Urban Development Supportive Housing for the Elderly (ALN# 14.157) Condition. Out of 12 monthly payments on the Project's HUD insured mortgage payable, that are due each fiscal year, 1 payment was late, resulting in a late fee. Effect. As a result of this condition, the mortgage was not paid on time. While there was ultimately payment of the delinquent monthly balance, the lack of effective internal controls could lead to future significant noncompliance. Plan. Management agrees with finding 2023-001 and has developed the following plan. Mortgage invoices are now sent to two accounts payable employees, as well as a monitored inbox, to ensure timely processing. Contact Person Responsible for This Corrective Action: David DeFrain Anticipated completion date: July 17, 2023
Finding 2023-004 Internal control deficiency and noncompliance over Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and Reporting related to expenses attributable to coronavirus reported in the provider relief fund reports. The entity has excess lost revenues to cover all payment...
Finding 2023-004 Internal control deficiency and noncompliance over Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and Reporting related to expenses attributable to coronavirus reported in the provider relief fund reports. The entity has excess lost revenues to cover all payments received (excluding the expenses submitted). Therefore, no refund is required for any payments received. Since the program has ended, the management has implemented the following procedures for future grants: 1) An education session occurred on February 15, 2024, with the relevant parties across Huntington Health entities to formally implement a review process whereby the Controller will review the support files prior to filings being made related to grant applications/programs across any of Huntington’s entities. Documentation of this review will be retained in the central file repository. These steps and controls will be updated and documented in the departmental policy. 2) A central folder on the Huntington Hospital’s main accounting drive has been created. This folder will be populated with all support for filed figures related to grant applications/programs across the hospital’s various entities. The support will be validated as having been placed into this folder as part of the reporting out process by the accounting manager and Controller handling the reporting. Files will be retained in this central drive for a minimum of 7 years. These steps and controls will be updated and documented in the departmental policy. Contact Person: Byron Davis, Controller and Steven Mohr, Senior Vice President and Chief Financial Officer, Huntington Hospital Anticipated Completion Date: Completed
View Audit 293159 Questioned Costs: $1
Finding 2023-001 Internal control deficiency and noncompliance over Activities Allowed or Unallowed and Allowable Costs/Cost Principles related to salary cap limitation. In response to this finding management will implement the following: We are revising our internal controls to more frequently p...
Finding 2023-001 Internal control deficiency and noncompliance over Activities Allowed or Unallowed and Allowable Costs/Cost Principles related to salary cap limitation. In response to this finding management will implement the following: We are revising our internal controls to more frequently perform our salary cap reconciliation ensuring the appropriate sponsor invoicing for employees who are over the salary cap limitation. For the salary cap variances that were identified through the previous reconciliation process, they will be adjusted and posted by the close of our March 2024 accounting period. Lastly, we will offset our cash for the March 2024 letter of credit draw down process in the Payment Management System, and incorporate adjustments in our March 2024 invoices for federal pass-thru awards. In addition, the salary cap adjustment program in our new ERP system was designed to remove the defect experienced in our legacy system. Contact Person: Nicole Anderson Leonard, Vice President, Research and Vice Dean Anticipated Completion Date: March 31, 2024
Corrective Action Plan: Reimbursement of Department of Agriculture cash has been completed for year-end 2022-2023. District Administration will assess staffing needs to determine separation of duties and to determine additional staffing needs to meet the requirements of duty separation. Currently,...
Corrective Action Plan: Reimbursement of Department of Agriculture cash has been completed for year-end 2022-2023. District Administration will assess staffing needs to determine separation of duties and to determine additional staffing needs to meet the requirements of duty separation. Currently, the Finance Department consists of one Payroll/Benefits position, one Accounts Payable/Receivable Position, one Grants Specialist Position, and one Finance Director. In prior years, the Finance Department had two additional positions that have since been eliminated, causing position duties to be absorbed amongst the remaining staff. Journal postings to reimburse shown below. Anticipated Completion Date: March 29, 2024
Prior to the completion of the audit, the Organization has entered a contract with a CPA firm, CLA, to outsource its accounting functions. This will allow the Organization to have qualified accounting professionals perform and oversee accounting activity. The finding was shared with CLA and CLA has ...
Prior to the completion of the audit, the Organization has entered a contract with a CPA firm, CLA, to outsource its accounting functions. This will allow the Organization to have qualified accounting professionals perform and oversee accounting activity. The finding was shared with CLA and CLA has committed to working with the audit firm to meet deadlines so that all entries are recorded prior to fieldwork and if there are any open items that may result in an entry, those items are clearly communicated to the audit firm prior to fieldwork.
We categorically reject the assessment that our county “did not establish and maintain effective internal controls over compliance with coronavirus State and Local Recovery Fund requirement”. The transactions cited happened before state auditors finally clarified how they believed interfund transfer...
We categorically reject the assessment that our county “did not establish and maintain effective internal controls over compliance with coronavirus State and Local Recovery Fund requirement”. The transactions cited happened before state auditors finally clarified how they believed interfund transfers of those funds should have been handled. Before that moment, there had been little to no clear, written guidance from the state on the proper procedure for utilizing these funds for other needs within our budgets (in our case, fixing roads). Our staff spent weeks combing through and attempting to understand federal documents issued with spending rules that changed often and continue to change today. We have traced and will track every penny of those monies were spend and account for them in any way we are required. I believe it is not fair to our county to suggest otherwise in this finding, but we will certainly follow your instructions on interfund transfers, now that we finally know what those are.
ALLOWABLE COSTS AND COST PRINCIPLES Department of Health and Human Resources (DHHR) Assistance Listing Number 97.036, COVID-19 97.036 The DHHR analyzed this finding and hereby offers more details into the condition and cause of the finding. Although the DHHR concurs with the condition statement in...
ALLOWABLE COSTS AND COST PRINCIPLES Department of Health and Human Resources (DHHR) Assistance Listing Number 97.036, COVID-19 97.036 The DHHR analyzed this finding and hereby offers more details into the condition and cause of the finding. Although the DHHR concurs with the condition statement in the finding, in that certain invoices were paid to one vendor without verifying their accuracy, the DHHR does not concur with the cause statement, which proclaims a lack of proper controls within the DHHR. While no set of internal controls can prevent unseemly or otherwise improper payment activities with absolute assurance, the DHHR does indeed have proper internal controls in place to provide reasonable assurance that invoices are verified for accuracy prior to payment. The DHHR is a large state agency with many spending units, divisions, and levels of oversight and approval. Accordingly, when paying invoices, the process includes a separation of duties. Authorization to approve cash payments begins with the DHHR spending unit, which was a programmatic unit in this case since the vendor in question was required to provide nasal swab diagnostic testing for COVID-19 and upload the test results immediately, as the tests were for specific DHHR programs and initiatives that were an absolute priority at the time. For these and other types of billings, the spending unit receives the invoice from the vendor, conducts an initial review for completeness and accuracy, and approves [or denies] the invoice for payment pursuant to the internal specifications at the spending unit level. If approved for payment, the invoice must be certified by the spending unit. Per the Code of State Rules, Title 155, Series 1, Standards for Requisition for Payment Issued by State Officers on the Auditor, the term “certify” means, “To verify that pertinent information is true and accurate by affixation of a manual signature by an authorized person.” To comply with the verification requirement, 155CSR1-3.1.3 requires the invoice to be stamped with the following certification: “I hereby certify that the items or services contained in the foregoing have been received and approved for payment.” Within the DHHR, the certification must be dated and signed by an authorized representative at the spending unit level with authority to approve such payments. The spending unit then enters the information into wvOASIS, which is the statewide accounting system, and forwards the related documentation to the DHHR central finance office. The central finance office performs a secondary review for completeness and accuracy pursuant to the specifications at the DHHR central level and, if acceptable, approves the documents within the wvOASIS workflow to the WV State Auditor’s Office for final review, approval, and processing of the payment pursuant to the specifications at the statewide level. For the invoices in question, the person authorized to certify the invoices and approve the payments was an upper-level supervisor, and his duties in that position had included reviewing and verifying the accuracy of certain invoices submitted to the DHHR by vendors supplying the aforementioned COVID-19 testing and mitigation services prior to certifying the invoices for payment. The supervisor originally proclaimed that he certified the invoices only after two individuals working with the program verified the invoices. The supervisor subsequently admitted that he certified the invoices without actually making any effort to verify their accuracy. The supervisor is no longer employed by the DHHR. It is important to note that although the supervisor certified the invoices without making any effort to verify their accuracy, it has yet to be determined if the vendor’s invoices were correct or erroneous. Currently, there are several internal and external organizations investigating the vendor and the overall condition that led to this finding. Those investigations began prior to the period of the audit. Once complete, the investigations will disclose additional details surrounding the validity of the invoices and the costs in question.
View Audit 293105 Questioned Costs: $1
INTERNAL CONTROLS OVER ALLOWABILITY West Virginia Military Authority (the Authority) Assistance Listing Number 97.036, COVID-19 97.036 The Authority is working internally to establish appropriate internal controls to document the review and approval of all West Virginia National Guard members’ ti...
INTERNAL CONTROLS OVER ALLOWABILITY West Virginia Military Authority (the Authority) Assistance Listing Number 97.036, COVID-19 97.036 The Authority is working internally to establish appropriate internal controls to document the review and approval of all West Virginia National Guard members’ timecard records to ensure that the members’ time is accurately reported and entered into the Oasis payroll system at the correct pay rates and amounts. The new internal controls will be implemented by April 1, 2024.
ALLOWABILITY AND ELIGIBILITY Department of Health and Human Resources (DHHR) Assistance Listing Number 93.489, 93.575, 93.596, COVID-19 93.575 For the one payment out of 40 whereby the provider requested and was paid for 13 non-traditional days although records indicated that only 11 of the days...
ALLOWABILITY AND ELIGIBILITY Department of Health and Human Resources (DHHR) Assistance Listing Number 93.489, 93.575, 93.596, COVID-19 93.575 For the one payment out of 40 whereby the provider requested and was paid for 13 non-traditional days although records indicated that only 11 of the days were non-traditional, the West Virginia Department of Health and Human Resources, Bureau for Family Assistance (BFA), agrees that the condition resulted in an overpayment of $12.00. The BFA Case Manager entered 13 non-traditional days in the Family and Children Tracking System (FACTS), but the record indicated that only 11 days were non-traditional days. Per WV Child Care Policy and Procedures: 8.3.1. Worker Error Improper payments due to worker error are defined as payments that should not have been made, or that were made in an incorrect amount due to worker error in determining and verifying eligibility, and/or calculation and input of information into the Family and Children’s Tracking System (FACTS). Incorrect amounts include overpayments, underpayments and inappropriate denials of payment. 8.3.1.1. Examples of worker error: A. The child care regulatory specialist enables the “accreditation” box, allowing the provider to receive an extra $4 per day, when the provider has not achieved accreditation, and is not entitled to the enhanced rate. B. The case manager enters an incorrect number of days when entering information from the payment form into FACTS. C. The case manager enters more time on the child care assessment than the client’s work or school schedule supports. D. The case manager fails to verify income, school enrollment, or special needs status. 8.3.1.2. Repayment of an improper payment due to CCR&R worker error is not mandatory regardless of the amount. The BFA Division of Early Care and Education employs Child Care Policy Specialists who visit contracted Resource and Referral Agencies to monitor and audit both electronic and hard records. Training and coaching also takes place during these visits. These visits continued throughout the reporting period. The BFA will evaluate the effectiveness of the current training programs for the use of the FACTS system (and subsequently for the West Virginia People's Access to Help (PATH) system) for CCDF payments. Furthermore, the BFA will follow established policies and procedures to ensure client information is appropriately obtained and maintained and that all data is input accurately. For the payment whereby the $3.00 daily supplement was not included in the calculation or paid, although the documentation in the eligibility system indicated that the child was covered under a CPS Safety Plan, this was not in fact a CPS Safety Plan case. The CPS Safety Plan was being used as a temporary means to address an executive order regarding COVID-19 and grant eligibility to essential workers who would otherwise not have qualified for the child care subsidy assistance due to their monthly income being above the Federal Poverty Level but below 85% of the State Median Income. The payment in question was in March 2023. Via a case assessment on November 1, 2023, this case [and other similar cases] were approved in the eligibility system as formalized Policy Exceptions rather than being selected as part of a CPS Safety Plan.
View Audit 293105 Questioned Costs: $1
ALLOWABILITY OF EXPENDITURES, SPECIAL TEST AND PROVISIONS – PROVIDER ENROLLMENT & SPECIAL TEST AND PROVISIONS: PROVIDER HEALTH AND SAFETY STANDARDS (MEDICAID ONLY) Department of Health and Human Resources (DHHR) Assistance Listing Number 93.775, 93.777, COVID-19 93.777, 93.778 The West Virginia De...
ALLOWABILITY OF EXPENDITURES, SPECIAL TEST AND PROVISIONS – PROVIDER ENROLLMENT & SPECIAL TEST AND PROVISIONS: PROVIDER HEALTH AND SAFETY STANDARDS (MEDICAID ONLY) Department of Health and Human Resources (DHHR) Assistance Listing Number 93.775, 93.777, COVID-19 93.777, 93.778 The West Virginia Department of Health and Human Resources, Bureau for Medical Services (BMS), has developed a form to document internal review of the service organization’s SOC 1 Type 2 report for such matters as the control environment, system development and maintenance, logical security, physical access, computer operations, and input controls. The form also has dedicated sections for exceptions within the SOC 1 Type 2 report as noted by the reviewer(s) and for questions/comments that the reviewer(s) might have. As of the date of this writing, the BMS is still working on the instructions for completing the form and processing the form to the next level within the BMS as may be necessary (e.g., answering any questions or comments that the initial reviewer denoted on the form; evaluating whether any exceptions noted within the SOC 1 Type 2 report could have a negative effect on the MMIS or the Medicaid program in general; and eventually closing the SOC 1 Type 2 report and documenting the review, the overall effect, the resulting actions, and any pending actions within the appropriate system files).
ALLOWABILITY AND ELIGIBILITY Department of Health and Human Resources (DHHR) Assistance Listing Number 93.659 The issues identified in the finding were due to a broad number of child welfare workers having access to select “Non-Recurring Adoption Expense” (NRAE) when issuing a demand payment throu...
ALLOWABILITY AND ELIGIBILITY Department of Health and Human Resources (DHHR) Assistance Listing Number 93.659 The issues identified in the finding were due to a broad number of child welfare workers having access to select “Non-Recurring Adoption Expense” (NRAE) when issuing a demand payment through the eligibility system, causing the incorrect funding to be used. Two of the payments identified were manually entered to replace lost payments. The initial payments covered multiple children, but the replacement payment only identified one child’s name. For the Adoption Program, the DHHR phased in a new information technology system for determining eligibility, making payments, maintaining documentation, etc. during the State Fiscal Year 2023. The name of the new system is PATH (People & Access to Help). The PATH system replaced the Family and Children & Tracking System (FACTS). The PATH system will have additional controls and levels of review as compared with the FACTS system. For example, as specific to this finding, the ability to select NRAE when issuing a demand through PATH has been localized to adoption subsidy unit staff within the central office of the DHHR Bureau for Social Services.
View Audit 293105 Questioned Costs: $1
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