Corrective Action Plans

Finding 44881 (2022-001)

Significant Deficiency 2022

Alight

MN

Subrecipient Monitoring Allowable Costs / Cost Principles Reporting

Views of Responsible Officials and Planned Corrective Actions: Executive leadership at Alight determined that the investigation uncovered an extensive breakdown in values and culture within the Alight Uganda program. At this time, Alight has taken the following actions: ? Immediate action was taken ...

Views of Responsible Officials and Planned Corrective Actions: Executive leadership at Alight determined that the investigation uncovered an extensive breakdown in values and culture within the Alight Uganda program. At this time, Alight has taken the following actions: ? Immediate action was taken to terminate employment with all staff involved in the malfeasance. ? The Uganda leadership team is in the process of being rebuilt. An interim Country Director was appointed and vacancies recruited and hired. ? Fraud training was provided and attended by almost 60 staff across Alight including Ugandan staff. ? Alight?s anonymous global reporting portal was upgraded with communication and training provided to all Alight country programs. ? Alight?s executive leaders conducted policy, procedures and fraud notification training with the Uganda staff including how to report suspected incidence of fraud. ? Executive leaders and Uganda leaders are routinely traveling to field offices to review operations and provide staff the opportunity to report issues. Executive leadership at Alight believes these actions have re-established appropriate values, culture and processes within Uganda and reinforced their importance across Alight countries. Additional fraud training and reporting will be scheduled in fiscal year 2023.

View Audit 44660

Finding 44825 (2022-002)

Significant Deficiency 2022

Corona-Norco Family Young Men's Christian Association

CA

Matching / Level of Effort / Earmarking Allowable Costs / Cost Principles Reporting § 200.430

U.S. Department of Health and Human Service Corona-Norco Family Young Men's Christian Association respectfully submits the following corrective action plan for the year ended June 30, 2022. Audit period: July 1, 2021 through June 30, 2022 The findings from the schedule of findings and questioned cos...

U.S. Department of Health and Human Service Corona-Norco Family Young Men's Christian Association respectfully submits the following corrective action plan for the year ended June 30, 2022. Audit period: July 1, 2021 through June 30, 2022 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS?FINANCIAL STATEMENT AUDIT 2022 ? 001 ? Significant Deficiency ? Financial Statements Closing and Reporting Recommendation: We recommend improving the independent review of monthly financial statements, in particular to the area of collectability of receivable. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Our organization moved from one accounting system to another causing an error in entry/recording. Our organization has implemented the following: Monthly financial reviews including receivable oversight. Review is conducted by organization?s outsourced accountant, Finance Committee as a board function, Department Program Directors, back office administrative person and the YMCA Leadership staff team. Line items are reviewed, and variances are reported in written format each month. Additionally, all receivables are reported and collected within 90 days with a 30-60-90 day follow up plan. Name(s) of the contact person(s) responsible for corrective action: Audrie Echnoz, Chief Executive Officer. Planned completion date for corrective action plan: Beginning July 1, 2022 FINDINGS?FEDERAL AWARD PROGRAMS AUDITS U.S. Department of Health and Human Service 2022 ? 002 ? Cost Principles: Compensation ? Personal Services Federal Program Name: Child Care and Development Block Grant Child Care Mandatory and Matching Funds of the Child Care and Development Fund Assistance Listing Number: 93.575, 93.576 Recommendation: We recommend the entity implement procedures to ensure that documentation in place as in accordance with the OMB's Uniform Guidance. In situation that it was reporting error from a third-party provider, we recommend the entity implement alternative procedures to maintain sufficient documentation. View of Responsible Officials: There is no disagreement with the audit finding. Explanation of disagreement with audit finding: Our organization moved from written time sheets to a digital payroll platform. The training and staff implementation has included ongoing training with policies being rolled out and followed up with each month. Human resources has since reminded all staff of the requirement to approve their timesheets and all supervisors were reminded of this in recent staff meeting. This will be reviewed each payroll period and strong adherence will be followed with follow up action in place. Name(s) of the contact person(s) responsible for corrective action: Audrie Echnoz, Chief Executive Officer. Planned completion date for corrective action plan: Beginning July 1, 2022 If the U.S Department of Health and Human Services has questions regarding this plan, please call Audrie Echnoz, Chief Executive Officer at 951-479-4779.

View Audit 46033

Finding 44821 (2022-001)

Significant Deficiency 2022

Pomona College

CA

Questioned Costs Allowable Costs / Cost Principles

Purpose: To document Pomona College's Corrective Action Plan relating to finding 2022-001 in its June 30, 2022 Single Audit report. Finding 2022-001 Allowable Costs Criteria: The 2022 OMB Compliance Supplement notes the excerpt below as one of the Allowable Cost criteria: c. Costs did not consist o...

Purpose: To document Pomona College's Corrective Action Plan relating to finding 2022-001 in its June 30, 2022 Single Audit report. Finding 2022-001 Allowable Costs Criteria: The 2022 OMB Compliance Supplement notes the excerpt below as one of the Allowable Cost criteria: c. Costs did not consist of improper payments, including (1) payments that should not have been made or that were made in incorrect amounts (including overpayments and underpayments) under statutory, contractual, administrative, or other legally applicable requirements; (2) payments that do not account for credit for applicable discounts; (3) duplicate payments; (4) payments that were made to an ineligible party or for an ineligible good or service; and (5) payments for goods or services not received (except for such payments where authorized by law). Statement of Condition: Management charged nonpayroll expenses that had not been incurred as of year-end to a federal grant. Stipends for an 8-week summer program relating to Grant 6117 (Pomona Research in Mathematics Experience), CFDA/ALN: 47.049, that ran from June 9, 2022 to August 6, 2022 were partially incurred by year-end (June 30, 2022), but charged entirely to the grant in FY22. Per the contract with the hired Research Assistants, stipends were to be made in two installments, whereby the second installment relates to the portion of expenditure incurred after year-end. The second installment was charged to the grant in FY22, before the Research Assistants completed their grant-related work. Corrective Action Planned: Finance staff are working with the Director of Sponsored Research to better align stipend payment schedules with our fiscal year-end. Appropriate schedules for the variety of grant- funded summer research will be communicated to the Primary Investigators and academic department staff. Accounts Payable staff will be instructed to reject any participant payment requests that are not in accordance with the approved schedules. Additionally, reviews of each grant payment will be performed at the time of the ?payment request and in July, as part of our year-end close process, to identify any grant expen?es that may have been charged to the incorrect fiscal year and reclassify them accordingly. Name of contact Person responsible for corrective action plan: Associate Treasurer and Controller Mary Lou Woods, and Director of Finance Victoria Roberts Anticipated Completion Date: April 2023

View Audit 44238 Questioned Costs: $1

Finding 44786 (2022-030)

Material Weakness 2022

State of Oregon

OR

Allowable Costs / Cost Principles Subrecipient Monitoring Material Weakness § 200.303

2022-030 Oregon Housing and Community Services Ensure controls over administrative expenditure limits are properly designed and sufficiently detailed to ensure compliance Federal Awarding Agency: U.S. Department of the Treasury Assistance Listing Number and Name: 21.023 Emergency Rental Assistance...

2022-030 Oregon Housing and Community Services Ensure controls over administrative expenditure limits are properly designed and sufficiently detailed to ensure compliance Federal Awarding Agency: U.S. Department of the Treasury Assistance Listing Number and Name: 21.023 Emergency Rental Assistance Program (COVID-19) Federal Award Numbers and Years: ERA 1, 2021; ERA 2, 2021 (COVID-19) Compliance Requirement: Allowable Costs/Cost Principles Type of Finding: Material Weakness Prior Year Finding: N/A Questioned Costs: N/A Criteria: 2 CFR 200.303(a), (c)-(d); 15 U.S.C. 9058a(c)(5)(A); 15 U.S.C. 9058c(d)(1)(C) Department management is responsible for establishing and maintaining effective internal control that provides reasonable assurance the department is managing, evaluating, and monitoring the federal award in compliance with the terms and conditions of the award and taking prompt action when instances of noncompliance are identified. Federal regulations limit the amount of federal funds that can be used for administrative expenditures. The department periodically prepared tracking spreadsheets during the fiscal year to monitor spending and ensure administrative expenditure limitations were not exceeded. We reviewed four randomly selected tracking spreadsheets and noted two tracking spreadsheets where there was insufficient detail to determine what category expenditures were associated with (administrative versus programmatic); and three tracking spreadsheets where there was no indication that the expenditures were within administrative expenditures limitations due to the periodic nature of the tracking. Without sufficiently designed and implemented controls, the department is at risk for exceeding their allowable administrative cost limits. We recommend department management ensure tracking spreadsheets are properly designed and sufficiently detailed to ensure compliance with administrative expenditures limitations. MANAGEMENT RESPONSE: We agree with this recommendation. This was a very fast-paced, complex award with multiple layers of funding. OHCS did have and continues to have a pulse on administrative costs from the various admin funding sources and has not exceeded those allowable limits. Reporting was routinely compiled to show the various allocations and expenditures to date, which included administrative costs. Reporting was not provided in a consistent manner as information from multiple systems was needed, however program and fiscal staff met regularly to review. OHCS is taking careful steps to design a system that will consistently track awards while ensuring spending is in alignment with requirements and is distributed in a timely fashion. In doing so we will create a more consistent framework for tracking new awards to ensure limits and expenditures are consistently documented. Anticipated Completion Date: December 31, 2023 Contact: Jill Smith, Director of Housing Stabilization Division or Beth Brown, Accounting Manager

View Audit 45093

Finding 44785 (2022-029)

Material Weakness 2022

State of Oregon

OR

Subrecipient Monitoring Allowable Costs / Cost Principles Eligibility § 200.302 § 200.332

2022-029 Oregon Housing and Community Services Ensure accessible documentation to evidence compliance with program requirements Federal Awarding Agency: U.S. Department of the Treasury Assistance Listing Number and Name: 21.023 Emergency Rental Assistance Program (COVID-19) Federal Award Numbers a...

2022-029 Oregon Housing and Community Services Ensure accessible documentation to evidence compliance with program requirements Federal Awarding Agency: U.S. Department of the Treasury Assistance Listing Number and Name: 21.023 Emergency Rental Assistance Program (COVID-19) Federal Award Numbers and Years: ERA 1, 2021 (COVID-19) Compliance Requirement: Activities Allowed or Unallowed; Allowable Costs/Cost Principles; Eligibility Type of Finding: Material Weakness Prior Year Finding: N/A Questioned Costs: N/A Criteria: 2 CFR 200.302(a); 2 CFR 200.332(a)(5) Department management is responsible for communicating to subrecipients that they are required to permit the department and auditors access to their records as necessary to ensure the department is compliant with program requirements. To ensure compliance with program requirements, subrecipient records must also be sufficiently detailed. The department passed through $140 million phase one program funds to community action agencies (subrecipients) to provide program delivery. The department performed limited fiscal monitoring during the audit period which included procedures to address compliance with activities allowed and allowable cost requirements for administrative costs. The department did not perform any program monitoring during the audit period which primarily addresses compliance with eligibility requirements. To determine whether the department complied with program requirements for the fiscal year, auditors attempted to reconcile detailed subrecipient ledgers with the intent of selecting and testing sample items at each individual subrecipient organization. We noted issues with two individual subrecipients, resulting in an inability to perform testing procedures over a total of $21,438,521 in program expenditures. For the first subrecipient we were able to reconcile their detailed ledgers to the department?s financial records, however their detailed ledger included pass-through payments to a third organization for program delivery. As a result of the combination of direct and pass-through payments, we were unable to obtain sufficiently detailed data that also reconciled to the department?s financial records to select individual transactions for testing. This subrecipient represents $19,877,962 of the unaudited expenditures. For the second subrecipient we were able to reconcile their detailed ledgers to the department?s financial records and select administrative and program transactions for testing. However, the subrecipient was unresponsive to documentation requests to substantiate expenditures. This subrecipient accounted for $1,560,559 of the unaudited expenditures. We recommend department management obtain and reconcile sufficiently detailed subrecipient ledgers and support to substantiate expenditures to allow for fiscal and program monitoring to ensure subrecipients are administering program funds in accordance with program requirements. MANAGEMENT RESPONSE: We agree with this recommendation. To effectively deliver much needed funds to maintain the housing stability of tens of thousands of Oregonians on the brink of experiencing homelessness during the pandemic, agency staff raced to stand up a first-of-its-kind ?single entry point? program for Oregonians to apply for assistance regardless of zip code. In our efforts to focus on speed we acknowledge that there was insufficient planning and capacity to stand up a large-scale emergency program including sufficient assurances our subrecipients could generate evidence of compliance with program requirements including transaction level details to assist with reconciliation. Oregon?s experience is in line with national findings. According to the January 2021 research brief conducted by the National Low Income Housing Coalition around key program challenges with administering emergency rental assistance programs. Survey respondents listed the two most common limitations to be staff capacity and the completeness of applications. Many agencies leaned on whatever local capacity was available to develop programs, review, and process applications, make payments and conduct outreach. Corrective action plan: OHCS had significant compliance monitoring staff turnover in FY22 leading to incomplete subrecipient monitoring reviews. OHCS completing these reviews would?ve ensured subrecipients had adequate time to produce necessary documentation to evaluate compliance, or if not, subrecipients would?ve been required to take corrective actions. For fiscal compliance, OHCS hired a contractor to perform fiscal monitoring of federal funded Grantees. OHCS also hired fiscal staff to pre-FY22 levels, fully trained them, conducted coordinated working sessions, and reached out to the CAA network for discussions on improving processes. OHCS continues to work with the contractor for much needed assistance in monitoring of back log while internal staff move forward to allow for all monitoring to be back on schedule and coordinating both fiscal and program compliance during future fiscal years. Program compliance employees have been hired and compliance efforts are underway. All providers will have internal compliance visits at regular intervals to ensure they have necessary documents and eligibility is being determined in compliance with program requirements. Additionally regular and ongoing check ins and trainings are being offered by program staff. Finally, program compliance teams are working with the Finance compliance team as well as a contracted expert to develop systems and processes in alignment with the Finance compliance team. As a result of program compliance efforts, a risk evaluation is being developed and incorporated into future contracting decisions. Efforts in hiring and systemic investments in infrastructure, processes, and procedures in addition to partner communications have taken place to ensure agency readiness in the event another emergency occurs. As part of our commitment to continual learning, our OHCS research team is collaborating closely with university and national partners to analyze our ERA program data and findings to see what themes emerge for improvement both nationally and in Oregon. Anticipated Completion Date: December 31, 2023 Contact: Jill Smith, Director of Housing Stabilization Division and Dean Criscola, Controller

View Audit 45093

Finding 44783 (2022-027)

Material Weakness 2022

State of Oregon

OR

Subrecipient Monitoring Allowable Costs / Cost Principles Eligibility § 200.302 § 200.303

2022-027 Oregon Housing and Community Services Ensure Monthly and Quarterly reports are accurate and adequately supported Federal Awarding Agency: U.S. Department of the Treasury Assistance Listing Number and Name: 21.023 Emergency Rental Assistance Program (COVID-19) Federal Award Numbers and Ye...

2022-027 Oregon Housing and Community Services Ensure Monthly and Quarterly reports are accurate and adequately supported Federal Awarding Agency: U.S. Department of the Treasury Assistance Listing Number and Name: 21.023 Emergency Rental Assistance Program (COVID-19) Federal Award Numbers and Years: ERA 1, 2021; ERA 2, 2021 (COVID-19) Compliance Requirement: Reporting Type of Finding: Material Weakness; Material Noncompliance Prior Year Finding: N/A Questioned Costs: N/A Criteria: 2 CFR 200.302(a) and (b)(3); 2 CFR 200.303(a), (c)-(d) Department management is responsible for establishing and maintaining effective internal control that provides reasonable assurance the department is managing, evaluating, and monitoring the federal award in compliance with the terms and conditions of the award and taking prompt action when instances of noncompliance are identified. Additionally, the department is responsible for maintaining records to allow for submission of reports that are accurate and adequately supported. We tested four randomly selected monthly reports and found one report did not accurately report the number of unique households assisted and the amount of the assistance based on the supporting documentation. The department stated the differences were likely due to a transition in subsystem reporting formats and delays in report processing. We tested four quarterly reports, two of which were randomly selected and two of which were judgmentally selected. We found one report where the cumulative obligation amount did not agree to supporting documentation and were not accurate, and one report where the cumulative obligation and cumulative expenditures amounts did not agree to supporting documentation and were not accurate. The department stated these errors were due to erroneously entered information in the federal awarding agency?s reporting portal. Information included in these reports is used by the federal awarding agency to determine whether the department qualifies for receiving reallocation payments, as well as how much of a reallocation would be awarded to the department. Errors in these reports could result in errors in the federal awarding agency?s determination of eligibility for funding, and/or the reallocation formula. We recommend department management update and correct erroneous reports and establish controls to ensure reported amounts are accurate and adequately supported. MANAGEMENT RESPONSE: We agree with this recommendation. Numerous Community Action Agencies (CAAs), after months of exponential growth in program resources without time to strategize and scale operations, reported major capacity issues a chronic backup of applications at the local level. OHCS took the unprecedented step to augment CAA staff to contract with a third-party vendor to clear the backlog. This approach rapidly increased production and moved the federal program closer in line with the state?s then 60-day safe harbor period but came with additional monitoring and reporting challenges. OHCS did meet the reporting timelines and requirements of US Treasury. OHCS relied on information within the applicant tracking system that does have some discrepancies when compared to our accounting records. These discrepancies are due to various factors such as dates within the system causing application activity to be pulled into the reporting detail more than once, or the application tracking system not being updated with the most current payment record information by some grantees disbursing payments. These variances were overcome by relying on our accounting system and records as a control source of actual disbursements. During the audit, it was brought to our attention that the compilation of the application tracking system data at a point in time was not stored to demonstrate the reconciliation with the accounting information. SOS was then not able to verify the application tracking system data figures in one monthly reporting instance that were used to support the numbers reported to US Treasury as the file had likely been overridden. Similarly in one instance, the quarterly cumulative report was also impacted, however future cumulative figures were reported correctly. Corrective action plan: While OHCS submitted monthly and quarterly reports since program inception that include program and fiscal information, we acknowledge that there were some discrepancies between systems when one file was overridden with new information and one other file contained an error. We have taken steps to ensure data integrity and records retention moving forward and future compilations of the application tracking system data will be stored to support the point in time reconciliations and figures reported to US Treasury. One quarterly report will also be refiled if allowable by US Treasury to ensure quarterly figures reported are accurate. Data integrity is of the utmost importance to the agency, and we appreciate the thorough review by the auditing team. Anticipated Completion Date: June 30, 2023 Contact: Beth Brown, Accounting Manager

View Audit 45093

Finding 44781 (2022-025)

Material Weakness 2022

State of Oregon

OR

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles § 200.332

2022-025 Oregon Housing and Community Services Perform fiscal monitoring for subrecipients administrative expenditures to ensure compliance Federal Awarding Agency: U.S. Department of the Treasury Assistance Listing Number and Name: 21.023 Emergency Rental Assistance Program (COVID-19) Federal Aw...

2022-025 Oregon Housing and Community Services Perform fiscal monitoring for subrecipients administrative expenditures to ensure compliance Federal Awarding Agency: U.S. Department of the Treasury Assistance Listing Number and Name: 21.023 Emergency Rental Assistance Program (COVID-19) Federal Award Numbers and Years: ERA 1, 2021 (COVID-19) Compliance Requirement: Activities Allowed or Unallowed; Allowable Costs/Cost Principles Type of Finding: Material Weakness; Material Noncompliance Prior Year Finding: N/A Questioned Costs: $121,463 (known) (COVID-19) Criteria: 2 CFR 200.332(a)(5) and (d) Department management is responsible for monitoring the activities of subrecipients to ensure subawards are used for authorized purposes and in compliance with federal requirements. Additionally, department management is responsible for communicating to subrecipients that they are required to permit the department and auditors access to their records as necessary to ensure the department is in compliance with program requirements. The department passed through program funds to community action agencies (subrecipients) to provide program delivery, including administrative costs. The department performed fiscal monitoring for only five of their 18 subrecipients during the audit period due to staff turnover. Fiscal monitoring includes procedures to address compliance with activities allowed and allowable cost requirements for administrative costs. Due to the limited fiscal monitoring performed, auditors performed additional procedures at the subrecipient level to determine whether the department was compliant with program requirements. We tested a total of 82 transactions, 70 randomly selected and 12 judgmentally selected from the 13 subrecipients that did not receive subrecipient monitoring during the fiscal year. We noted the following: One subrecipient did not respond to audit requests for documentation, resulting in an inability to test four transactions totaling $4,114. One subrecipient did not provide sufficiently detailed documentation to determine whether 7 transactions were for accurate amounts totaling $117,349. Of those seven transactions, we were unable to determine whether two transactions were for allowable activities or appropriately categorized as administrative expenditures. Without adequate monitoring of subrecipients, the department?s ability to ensure compliance with program requirements is diminished. We recommend department management perform fiscal monitoring to ensure subrecipients are expending administrative funds in accordance with program requirements. MANAGEMENT RESPONSE: We agree with this recommendation. Corrective action plan: OHCS had significant compliance monitoring staff turnover in FY22 which led to a lack of monitoring. OHCS has subsequently hired a contractor to perform fiscal monitoring of all ESG funded grantees. OHCS also hired staff to pre-FY22 levels, fully trained all staff and began developing internal working relationships with program staff to assure operational efficiencies. This includes an annual workshop with all grantees, internal training, and standardizations of monitoring processes. Anticipated Completion Date: June 30, 2023 Contact: Dean Criscola, Controller

View Audit 45093 Questioned Costs: $1

Finding 44778 (2022-064)

Significant Deficiency 2022

State of Oregon

OR

Allowable Costs / Cost Principles § 200.303

2022-064 Oregon Department of Transportation Management should ensure timely review of transfers is documented Federal Awarding Agency: U.S. Department of Transportation Assistance Listing Number and Name: 20.205 Highway Planning and Construction Federal Award Numbers and Years: Various Complian...

2022-064 Oregon Department of Transportation Management should ensure timely review of transfers is documented Federal Awarding Agency: U.S. Department of Transportation Assistance Listing Number and Name: 20.205 Highway Planning and Construction Federal Award Numbers and Years: Various Compliance Requirement: Activities Allowed or Unallowed; Allowable Costs/Cost Principles Type of Finding: Significant Deficiency Prior Year Finding: N/A Questioned Costs: N/A Criteria: 2 CFR 200.303; GAO-17-704G ?10.03, 12.05; ODOT FASM 3.7 The department is responsible for establishing and maintaining internal controls to ensure entries posted in the accounting records are for costs and activities allowable under the federal program. Journal entry review and approval should be clearly documented and readily available for examination. The department has established Financial Administration Standard 3.7, Expenditure Journal Entries, which requires management to transmit signed hard copy supporting documentation of journal entries to financial services after they?ve been reviewed and approved. We tested 40 transfer journal entries moving costs between federal project sub jobs and found that 19 did not have documentation of timely approval. In two cases, approval was documented more than a year after costs were transferred. The 19 entries were all lump sum transfers processed by Program and Funding Services (P&FS). P&FS is authorized to process transfers, moving costs between sub jobs of the same project. These transfers are necessary to align project costs with the appropriate funding source. Per P&FS management, transfers are generally reviewed within a few days. However, documentation of the review has not been occurring until much later due to challenges associated with remote work and policies requiring hard copy documentation. Over $90 million in program costs were transferred between sub jobs in this manner during fiscal year 2022. Without timely review and documentation available to support transfers, unallowable costs or activities could be transferred and billed erroneously to the Federal government. We recommend management ensure procedures for review of transfer journal entries result in timely documented approvals. MANAGEMENT RESPONSE: We agree with this recommendation. Until electronic signatures are implemented, a Federal Aid Funding staff member will be required to print the hard copies, in the office at least monthly; as well as a member of the Statewide Investments Section management team will need to be present to sign the hard copies. Anticipated Completion Date: May 4, 2023 Contact: Katie Parlette, Federal Aid Funding Manager

View Audit 45093

Finding 44764 (2022-062)

Significant Deficiency 2022

State of Oregon

OR

Allowable Costs / Cost Principles Significant Deficiency § 200.303

2022-062 Higher Education Coordinating Commission Improve controls over payroll Federal Awarding Agency: U.S. Department of Labor Assistance Listing Number and Name: 17.258 WIOA Adult Program 17.259 WIOA Youth Activities 17.278 WIOA Dislocated Workers Formula Grant Federal Award Numbers and Yea...

2022-062 Higher Education Coordinating Commission Improve controls over payroll Federal Awarding Agency: U.S. Department of Labor Assistance Listing Number and Name: 17.258 WIOA Adult Program 17.259 WIOA Youth Activities 17.278 WIOA Dislocated Workers Formula Grant Federal Award Numbers and Years: AA33251LN0; 2019, AA33251L70; 2019, AA33251L90; 2019, AA33251R70; 2019, AA33251R90; 2019, AA34789VS0; 2020, AA34789V90; 2020, AA34789VQ0; 2020, AA347893L0; 2020, AA347895P0; 2020, AA36341E10; 2021, AA36341D90; 2021, AA36341DQ0; 2021, AA36341KY0; 2021,AA36341LA0; 2021 Compliance Requirement: Allowable Costs/Cost Principles Type of Finding: Significant Deficiency Prior Year Finding: N/A Questioned Costs: N/A Criteria: 2 CFR 200.303 Federal regulations require recipients of federal awards to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. The department has implemented the following procedures to ensure payroll costs are correctly charged to the program. Managers approve monthly timesheets submitted by the employees in the state?s payroll system. When managers do not approve by a specified date, the payroll system will automatically approve the timesheet, shown with the words ?system approved.? Additionally, each employee should have a signed position description, which details the duties of the position and the amount of time to be charged for the duties. We selected a nonstatistical random sample of 20 employee timesheets related to 12 employees to ensure payroll was appropriately charged to the program. Additionally, we selected one employee who was on job rotation with the agency from January 2022 through June 2022. We verified payroll timesheets were reviewed by a manager and signed position descriptions were retained per state guidelines, and identified the following exceptions: Two timesheets for one employee did not have evidence of manager approval and 2 timesheets for two employees were reviewed over three months later. For all 12 employees, the position descriptions provided were unsigned or signed upon our request. We did not question these costs as department management verified job duties were appropriate to the program. For the employee on job rotation, 4 of the 6 timesheets were not reviewed and a signed position description was not signed by the employee. According to department management, timesheets were not always approved by the manager as the system will automatically lock and approve the timesheet. For position descriptions, supervisor did not always follow through on obtaining signed position descriptions and for longer term employees a number of boxes could not be located when the agency moved. There is a risk that employees could be improperly charging to the federal program. We recommend department management ensure timesheets are timely reviewed and positions descriptions are completed and retained. MANAGEMENT RESPONSE: We agree with this recommendation. To improve controls over payroll, the HECC and the State of Oregon switched its payroll system from the old Legacy Oregon State Payroll Application (OSPA ? Epay) to the new Workday Payroll as of December 1, 2022. The HECC has since created reminder emails to all Management Staff to submit their respective employees? timesheets in a timely manner. In addition, the new Workday Payroll does not have a feature that automatically locks an employee?s timesheet and auto-approves a timesheet. Each Manager must now manually approve a timesheet for any employee that enters specific time codes for particular grants or use of funds. To address the finding regarding unsigned position descriptions (PDs), the HECC has since ensured that all of the identified PDs have been signed. HECC?s Human Resources Unit (HR) has created a new process going forward requiring all managers to sign the PD at the time of the offer letter and HECC HR to collect the signature from the employee on their first day when HR meets with them. HECC HR also has reviewed all of its existing employees? position description in this process to ensure all positions descriptions are signed. Anticipated Completion Date: August 31, 2023 Contact: Christopher Bui, Budget and Fiscal Manager

View Audit 45093

Finding 44755 (2022-018)

Material Weakness 2022

State of Oregon

OR

Questioned Costs Allowable Costs / Cost Principles

2022-018 Oregon Housing and Community Services Controls are needed to ensure program expenditures are allowable Federal Awarding Agency: U.S. Department of Housing and Urban Development Assistance Listing Number and Name: 14.231 Emergency Solutions Grants Program (COVID-19) Federal Award Numbers and...

2022-018 Oregon Housing and Community Services Controls are needed to ensure program expenditures are allowable Federal Awarding Agency: U.S. Department of Housing and Urban Development Assistance Listing Number and Name: 14.231 Emergency Solutions Grants Program (COVID-19) Federal Award Numbers and Years: E-20-DW-41-0001, 2020 (COVID-19) Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Type of Finding: Material Weakness; Material Noncompliance Prior Year Finding: N/A Questioned Costs: $245,362 (known) (COVID-19) Criteria: 24 CFR 576.100; CPD-21-08 III.E.3 Emergency Solutions Grants-Cares Act (ESG-CV) funds may be used for the five regular Emergency Solutions Grants (ESG) program components, as well as administrative activities: street outreach, emergency shelter, homelessness prevention, rapid re-housing, and homeless management information systems (HMIS). They may also be used for additional activities including, but not limited to, temporary emergency shelter, hazard pay, handwashing stations, cell phones and internet, personal protective equipment, and laundry. The funds are disbursed to the subrecipients after reimbursement requests are submitted. Federal funds totaling $31,894,565 were distributed to 44 subrecipients during fiscal year 2022. We randomly selected 61 individual distributions made by the department to subrecipients. Subsequently, we randomly selected an expenditure from each disbursement request and then judgmentally selected additional expenditures from select disbursements. While gaining an understanding of the department?s internal control process, we learned the review process for subrecipient disbursement requests did not include a detailed verification that underlying expenditures were for allowable activities and costs. Given the department?s incomplete review process, we were unable to verify compliance by testing those reviews. The department requested supporting documentation from the subrecipients, documentation that should have been reviewed and retained by the department, for the required audit procedures to be performed. Our audit procedures were performed in three stages. First, we randomly selected 61 individual distributions made by the department to subrecipients, totaling $5,580,560. These disbursements generally consisted of reimbursement for multiple expenditures made by a subrecipient. Next, we asked the department to request a listing of expenditures from the subrecipients related to those disbursements. Finally, if provided, we agreed the listings to the disbursement and randomly and judgmentally selected individual expenditures from the listings for testing. We were unable to perform any review of 20 disbursements either because we did not receive a listing of the subrecipient?s expenditures, or the listing did not agree to the disbursement selected for testing. These disbursements related to 10 of the 44 subrecipients receiving funds in fiscal year 2022 and $1,475,345 of the $5,580,560 in disbursements selected for testing noted above. From the expenditure listings we did receive, we randomly and judgmentally selected individual expenditures to determine whether the supporting documentation agreed to the amount requested for reimbursement by the subrecipient. Of those 41 individual transactions selected for testing, there was inadequate or no supporting documentation provided for 29 items, and one instance where the request exceeded the support. These exceptions resulted in total questioned costs of $245,362. If requests for funds are not supported by documented expenditures, the department could be unknowingly reimbursing subrecipients for unallowable costs and activities. We recommend management implement internal controls to ensure subrecipient reimbursements are for allowable expendiures. MANAGEMENT RESPONSE: We agree with this recommendation. OHCS had significant staff turnover in FY22, and that coupled with the substantively increased number of subrecipients, lead to a lack of monitoring. OHCS has subsequently hired staff and established vendor relationships to perform fiscal monitoring as a backup for when staff vacancies exist. Additionally, OHCS is on track to complete fiscal and program monitoring for all subrecipients of ESG funds in FY23. Anticipated Completion Date: June 30, 2023 Contact: Dean Criscola, Controller

View Audit 45093 Questioned Costs: $1

Finding 44751 (2022-005)

Material Weakness 2022

Anoka County

MN

Questioned Costs Allowable Costs / Cost Principles Internal Control / Segregation of Duties

Finding Number: 2022-005 Finding Title: Allowable Costs/Cost Principles and Reporting Program: Medical Assistance Program 93.778 Name of Contact Person Responsible for Corrective Action: Nicole Hegge - Sr. Manager, Accounting - Finance and Central Services Corrective Action Planned: In order to appr...

Finding Number: 2022-005 Finding Title: Allowable Costs/Cost Principles and Reporting Program: Medical Assistance Program 93.778 Name of Contact Person Responsible for Corrective Action: Nicole Hegge - Sr. Manager, Accounting - Finance and Central Services Corrective Action Planned: In order to appropriately report the revenue offset that may impact federal programs, we have updated our quarterly process ensuring that any federal revenue offsets are included in the appropriate fund and report. In some instances, this may still require the County to file amendments to federal reports; however, they will be completed no later than eight weeks following the end of the quarter. Anticipated Completion Date: December 31, 2023

View Audit 43802 Questioned Costs: $1

Finding 44744 (2022-002)

Material Weakness 2022

Crookston Housing and Economic Development Authority

MN

Allowable Costs / Cost Principles HUD Housing Programs

1. Correcting Plan CHEDA staff are aware of allowable cost proper documentations, and will implement an internal control process. 2. Explanation of Disagreement with the Audit Finding There is essentially no disagreement with the finding. 3. Official Responsible for Ensuring CAP Karie Kirschbaum ? E...

1. Correcting Plan CHEDA staff are aware of allowable cost proper documentations, and will implement an internal control process. 2. Explanation of Disagreement with the Audit Finding There is essentially no disagreement with the finding. 3. Official Responsible for Ensuring CAP Karie Kirschbaum ? Executive Director 4. Planned Completion Date for CAP Immediately. 5. Plan to Monitor Completion of CAP The Executive Director will monitor completion of the CAP.

View Audit 43800

Finding 44732 (2022-004)

Significant Deficiency 2022

Parkview School District

WI

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles

Finding #2022-004 ? Services billed that were not identified in the student?s IEP. Medical Assistance Program (Medicaid; Title XIX) (93.778) Federal Grantor ? U.S. Department of Health and Human Services Pass-through Entity ? Wisconsin Department of Health Services Condition: Covered school based ...

Finding #2022-004 ? Services billed that were not identified in the student?s IEP. Medical Assistance Program (Medicaid; Title XIX) (93.778) Federal Grantor ? U.S. Department of Health and Human Services Pass-through Entity ? Wisconsin Department of Health Services Condition: Covered school based services billed to Medicaid must be identified within the child?s IEP. A child?s billing sampled during the audit included nursing and transportation services. These services were not listed in the child?s IEP. Questioned costs: $654.12 Criteria: Students with covered services billed to Medicaid must have the services listed within the child?s IEP. Effect: Potentially unallowable billings arise when services are not included within the IEP of students. Cause: Nursing and transportation services were omitted from the child?s IEP, yet were billed to Medicaid. The District did not review the child?s IEP against services billed to ensure compliance. Recommendation: The District should only bill Medicaid for covered services included in IEP. The IEP should be reviewed prior to services being provided and billed to Medicaid. Also, the District should be reviewing the files on a regular basis to ensure compliance with this requirement. Response: We will review the District?s requirements and procedures for billing Medicaid and make any necessary changes to ensure completeness and accuracy. Contact Person: Tracy Case Anticipated Completion: December 31, 2023

View Audit 39098 Questioned Costs: $1

Finding 44731 (2022-003)

Significant Deficiency 2022

Parkview School District

WI

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles

Finding #2022-003 ? Parental consent to bill Medicaid not present in student file Medical Assistance Program (Medicaid; Title XIX) (93.778) Federal Grantor ? U.S. Department of Health and Human Services Pass-through Entity ? Wisconsin Department of Health Services Condition: The Medicaid program r...

Finding #2022-003 ? Parental consent to bill Medicaid not present in student file Medical Assistance Program (Medicaid; Title XIX) (93.778) Federal Grantor ? U.S. Department of Health and Human Services Pass-through Entity ? Wisconsin Department of Health Services Condition: The Medicaid program requires parental consent to bill Medicaid for any billable services provided and to keep these consent forms on file at the District. A student file sampled during the audit did not have a signed parental consent form. Questioned costs: $334.66 Criteria: A signed parental consent form (M-5) must be received prior to billing Wisconsin Medicaid for school based services. All students with services billed to Medicaid should have the consent form (M-5) on file. Effect: Not having a signed form (M-5) would lead to potentially unallowable billings. Cause: The District either did not obtain parental consent to bill Medicaid or did not properly handle the consent form after it was received. The District did not review the student file to ensure compliance. Recommendation: The District should obtain parental consent to bill Medicaid for every student receiving and being billed for these services. The consent form should be obtained and filed prior to any billings being made to Medicaid. Also, the District should be reviewing the files on a regular basis to ensure compliance with this requirement. Response: We will review the District?s requirements and procedures for obtaining parental consent and make any necessary changes to ensure completeness and accuracy. Contact Person: Tracy Case Anticipated Completion: December 31, 2023

View Audit 39098 Questioned Costs: $1

Finding 44655 (2022-001)

Significant Deficiency 2022

Allegany County, Maryland

MD

Allowable Costs / Cost Principles HUD Housing Programs Reporting

Allegany County has developed an improved procedure to ensure financial reports are submitted within the due date. Plan includes discussions with department heads in order to better improve and understand the complex reporting process that is required by the funding agency.

View Audit 39764

Finding 44601 (2022-001)

Significant Deficiency 2022

Bellwood School District 88

IL

Questioned Costs Allowable Costs / Cost Principles Cash Management

The District will create better meal claim tracking procedures and create a summary spreadsheet to more easily report meal claims on a monthly basis.

View Audit 46026 Questioned Costs: $1

Finding 44600 (2022-008)

None 2022

Florida Rural Legal Services, Inc.

AL

Allowable Costs / Cost Principles Special Tests & Provisions

Finding 2022-008 ? Special Test & Provisions- Priorities in Use of Resources (Noncompliance) CORRECTIVE ACTION: As part of our transition to our Paylocity payroll/HR system, we have put in place an onboarding work flow that automatically has the employee sign a priority statement and retain that wit...

Finding 2022-008 ? Special Test & Provisions- Priorities in Use of Resources (Noncompliance) CORRECTIVE ACTION: As part of our transition to our Paylocity payroll/HR system, we have put in place an onboarding work flow that automatically has the employee sign a priority statement and retain that within the HR system. As a correction to this new process, FRLS CFO and management will create a company-wide checklist and perform a thorough internal audit to ensure that all employees have this statement in their HR files. We will complete this action by the fourth quarter of 2023.

View Audit 46024

Finding 44597 (2022-005)

Material Weakness 2022

Florida Rural Legal Services, Inc.

AL

Allowable Costs / Cost Principles Material Weakness

Finding 2022-005 ? Allowable Costs (Material Weakness and Non-compliance) CORRECTIVE ACTION: FRLS is evaluating our allocation method to ensure that finance and accounting works with grants management to ensure grant allowable expenses are followed. FRLS followed the corrective action plan and hired...

Finding 2022-005 ? Allowable Costs (Material Weakness and Non-compliance) CORRECTIVE ACTION: FRLS is evaluating our allocation method to ensure that finance and accounting works with grants management to ensure grant allowable expenses are followed. FRLS followed the corrective action plan and hired a grants manager to review and repair grant allocations. FRLS is aware that there have been numerous issues with grant allocations resulting in grant funding issues, which we have worked to correct. FRLS also reiterates to staff the importance of following existing accounting policies and procedures with respect to documenting and approval of expenditures. We are currently in the process of reviewing our policy with respect to the allocation of expenditures to specific grants to ensure that it meets the guidelines of various grants, as reported by grants management. We expect to complete this review and implement any necessary changes by the fourth of 2023.

View Audit 46024

Finding 44594 (2022-003)

Significant Deficiency 2022

Beck Center for the Arts

OH

Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking Reporting § 200.1 § 200.300 § 200.400

2022-003 Formal Policies for Federal Awards Auditor Recommendation: We recommend management attend federal award trainings to ensure the documented policies and procedures can be performed as necessary. This will ensure the Center is in compliance with compliance requirements surrounding Federal awa...

2022-003 Formal Policies for Federal Awards Auditor Recommendation: We recommend management attend federal award trainings to ensure the documented policies and procedures can be performed as necessary. This will ensure the Center is in compliance with compliance requirements surrounding Federal awards. Corrective Action: The year ended August 31, 2022 was the first year in which the Center expended federal awards in excess of the limit that requires a Single Audit. Management with the Center?s Audit Committee will review and document policies and procedures for managing federal awards to supplement existing policies and procedures associated with awards from non-federal funders. Name of Responsible Contacts: Larry Goodpaster, Director of Finance & Operations, and Kelly Martin, Accounting Manager Projected Implementation Date: August 31, 2023

View Audit 46015

Finding 44592 (2022-001)

Significant Deficiency 2022

Adna School District No. 226

WA

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles

Finding ref number: 2022-001 Finding caption: The District did not have adequate internal controls for ensuring compli-ance with federal requirements for allowable activities and costs. Name, address, and telephone of District contact person: Katrin Williams, Business Manager PO Box 118 Adna, WA 985...

Finding ref number: 2022-001 Finding caption: The District did not have adequate internal controls for ensuring compli-ance with federal requirements for allowable activities and costs. Name, address, and telephone of District contact person: Katrin Williams, Business Manager PO Box 118 Adna, WA 98522 (360)748-0362 Corrective action the auditee plans to take in response to the finding: The District concurs and will review the current and future year?s indirect cost rates for ESSER re-imbursements. Anticipated date to complete the corrective action: Completed

View Audit 45725 Questioned Costs: $1

Finding 44591 (2022-002)

Material Weakness 2022

Adna School District No. 226

WA

Questioned Costs Allowable Costs / Cost Principles Equipment & Real Property Management

Finding ref number: 2022-002 Finding caption: The District did not have adequate internal controls for ensuring compli-ance with allowable activities and costs and restricted purpose require-ments. Name, address, and telephone of District contact person: Katrin Williams, Business Manager PO Box 118 ...

Finding ref number: 2022-002 Finding caption: The District did not have adequate internal controls for ensuring compli-ance with allowable activities and costs and restricted purpose require-ments. Name, address, and telephone of District contact person: Katrin Williams, Business Manager PO Box 118 Adna, WA 98522 (360)748-0362 Corrective action the auditee plans to take in response to the finding: The District does not concur with the finding or questioned costs. SAO reviewed various types of documentation and chose not to accept any documentation presented by the District to even consider reducing questioned costs. The standard of documentation required by SAO to satisfy ?unmet? need in would have been hard to meet even if the District hadn?t been in the midst of a pandemic. The District has internal controls over asset inventory and provided equipment only to students and staff with unmet needs, and all costs were allowable, reasonable and necessary. We look forward to working with the FCC to resolve this finding and we appreciate the guidance that was provided by the FCC, as noted below. Guidance from the FCC Devices for remote learning could also be used at school. During the pandemic in Washington State we experienced times when classrooms, schools and or districts were closed by health department and state regulations because of outbreaks. Districts had to be prepared to support remote learning each day with constantly changing guidance on who was allowed to be in person. The following guidance from the Federal Communications Commission, titled ?Emergency Connec-tivity Fund Common Misconceptions?, ?Misconception #2: If schools have returned to in-class in-struction for the upcoming school year, they are not eligible to participate. Answer: This is false. Equipment and services provided to students or school staff who would otherwise lack sufficient access to connected devices, and/or broadband internet access connection while off campus are eligi-ble for Emergency Connectivity Fund Support.? From the Federal Communications Commission Order FCC-CIRC21-93-043021, question 77: ?We think schools are in the best position to determine whether their students and staff have devices and broadband services sufficient to meet their remote learning needs, and we recognize that they are making such decisions in the midst of a pandemic. We, therefore, will not impose any specific met-rics or process requirements on those determinations.? And from question 53: ??we are sensitive to the need to provide some flexibility during this uncertain time. If those connected devices were pur-chased for the purpose of providing students?with devices for off-campus use consistent with the rules we adopt today, we will not prohibit such on-campus use. Anticipated date to complete the corrective action: Completed

View Audit 45725 Questioned Costs: $1

Finding 44587 (2022-001)

Material Weakness 2022

Lagrange County

IN

Internal Control / Segregation of Duties Allowable Costs / Cost Principles Material Weakness § 200.303

FINDING 2022-001 Contact Person Responsible for Corrective Action: LaGrange County Auditor Contact Phone Number: (260) 499-6310 Views of Responsible Official: We concur with the findings from SBOA. Description of Corrective Action Plan: We will work towards segregation of duties to ensure preventing...

FINDING 2022-001 Contact Person Responsible for Corrective Action: LaGrange County Auditor Contact Phone Number: (260) 499-6310 Views of Responsible Official: We concur with the findings from SBOA. Description of Corrective Action Plan: We will work towards segregation of duties to ensure preventing, or detecting and correcting noncompliance. Once the P & E report is prepared, a separate employee will review the report prior to submission. Anticipated Completion Date: When the next report is filed we will implement these procedures.

View Audit 44103

Finding 44581 (2022-002)

Significant Deficiency 2022

South Shore Child Guidance Association, Inc.

NY

Allowable Costs / Cost Principles Internal Control / Segregation of Duties § 200.303 § 200.405

Audit Finding Reference Number: 2022-002 Recommendation - South Shore should enhance its internal control processes related to preparation and review of the monthly claim for reimbursement. Corrective Action Plan - We have adjusted our policies and procedures to assure that every claim submission i...

Audit Finding Reference Number: 2022-002 Recommendation - South Shore should enhance its internal control processes related to preparation and review of the monthly claim for reimbursement. Corrective Action Plan - We have adjusted our policies and procedures to assure that every claim submission is reviewed by both the Controller and CFO prior submission. Claim form and appropriate documentation will be submitted to the Controller who will give initial review. Review will consider timeliness of items claimed as well as appropriateness for the particular federal grant. CFO will then provide final authorization in writing to both grants accountant and controller at which time claim for reimbursement can be submitted by grant accountant.

View Audit 38529

Finding 44576 (2022-001)

Material Weakness 2022

Buck Owens Crystal Palace

CA

Allowable Costs / Cost Principles Internal Control / Segregation of Duties § 200.430

Finding 2022-001 Program: Shuttered Venue Operations Program Assisting Lister Number: 59.075 Federal Grantor: U.S. Small Business Administration Passed-through: N/A Award No. and Year: SBAHQ21SV002930.2 and 2022 Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs/Cost Princip...

Finding 2022-001 Program: Shuttered Venue Operations Program Assisting Lister Number: 59.075 Federal Grantor: U.S. Small Business Administration Passed-through: N/A Award No. and Year: SBAHQ21SV002930.2 and 2022 Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Type of Finding: Material Weakness in Internal Control and Instance of Non-Compliance Management?s Response or Department?s Response Management agrees with the recommendation. Views of Responsible Officials and Corrective Action Management has designed controls for the supervisors to show evidence of the approval of the timecards and ensure the costs are allowable costs and activities allowed. Anticipated Completion Date September 2023. Contact Information of Responsible Official Name: Jim Shaw Title: Director Phone: 661-665-1450

View Audit 47434

Finding 44556 (2022-006)

Significant Deficiency 2022

Community Chest, Inc.

NV

Allowable Costs / Cost Principles Significant Deficiency Matching / Level of Effort / Earmarking

Finding Summary: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) provides that amounts charged to Federal programs must be for allowable costs. To be allowable under Federal awards, ...

Finding Summary: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) provides that amounts charged to Federal programs must be for allowable costs. To be allowable under Federal awards, costs must be adequately documented and supported. Community Chest, Inc. does have an internal control system to properly differentiate between federal and nonfederal expenditures, however certain immaterial amounts were not properly classified within the system in accordance with their internal control system. Responsible Individuals: Erik Schoen, CEO; Amber Stanley, Business Manager Corrective Action Plan: We are in agreement with this finding. As part of our CAP, we have replaced our former business manager with a new employee, who is receives regular support and guidance from an independent accounting professional with decades of experience. Together, they are forming a point-by-point strategic approach so that this finding is corrected in the current FY. We believe that being more timely in everyday processes, month end closes and reconciliations will help prevent changes after the fact in regards to monthly billings provided to our grantors. As of 10/1/22, we have already doubled our pace of account reconciliation. We will continue to improve with the accuracy of billings and grant end closes internally. Anticipated Completion Date: June 30, 2023

View Audit 49210

Corrective Action Plans

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