Corrective Action Plans

Finding 15993 (2022-049)

Material Weakness 2022

State of Washington C/o Office of Financial Management

WA

Allowable Costs / Cost Principles Subrecipient Monitoring § 200.430

Finding: The Department of Children, Youth, and Families did not have adequate internal controls over and did not comply with some Public Assistance Cost Allocation Plan requirements. Questioned Costs: Assistance Listing # 93.658 93.658 COVID-19 93.659 93.659 COVID-19 Status: Corrective act...

Finding: The Department of Children, Youth, and Families did not have adequate internal controls over and did not comply with some Public Assistance Cost Allocation Plan requirements. Questioned Costs: Assistance Listing # 93.658 93.658 COVID-19 93.659 93.659 COVID-19 Status: Corrective action complete Corrective Action: The Random Moment Time Study (RMTS) is a federally approved cost allocation methodology to claim allowable federal funds. The Department?s use of the RMTS is included in its Public Assistance Cost Allocation Plan (PACAP) with the federal grantor. The Department maintains that the sampling universe is accurate and complete and complies with federal requirements. There is no known deficiency with the integrity of the RMTS, nor are unallowable costs allocated to federal programs. Effective October 2022, the Department contracted with the University of Massachusetts (UMass) for the design and implementation of the RMTS mechanism. UMass has updated the RMTS instructions for the new quarterly process, which remains in compliance with federal law while alleviating the department-imposed restrictions. It also addresses the auditor?s concerns regarding the internal controls applicable to the RMTS worker types included in the sampling universe. The Department has also taken additional actions to address system limitations caused by high staff turnover rates within the cost pools. These include: ? The Headquarters (HQ) RMTS Coordinator pulls an InfoFamLink worker list report that shows all workers with access to the FamLink system. The list is then reviewed by job class to verify the accuracy of RMTS group assignment and to identify the workers that are eligible to be included in the sample. ? The Cost Allocation and Grants Management Unit pulls a job classification report from the Human Resource Management System (HRMS) at the end of every pay cycle. The HQ RMTS Coordinator compares the HRMS report to the InfoFamLink worker list report to verify if they are eligible to be sampled and properly allocated in HRMS. The HRMS has additional information related to job class to assist in sample eligibility determination and strengthen the internal controls around RMTS samples pulled. ? The HQ RMTS Coordinator pulls a workload report from InfoFamLink to view worker caseloads and primary assignments. This is an additional tool to determine if a worker is eligible and assigned to the correct RMTS sample pool. The Department will continue to maintain internal controls over the monthly update process to ensure the RMTS sampling populations are complete. The Department will also work with the federal partners to ensure continued compliance with the PACAP. The conditions noted in this finding were previously reported in finding 2021-042, 2020-044 and 2019-044. Completion Date: October 2022 Agency Contact: Stefanie Niemela Audit Liaison PO Box 40970 Olympia, WA 98504-0970 (360) 725-4402 stefanie.niemela@dcyf.wa.gov

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Finding 15992 (2022-048)

Significant Deficiency 2022

State of Washington C/o Office of Financial Management

WA

Subrecipient Monitoring Allowable Costs / Cost Principles Internal Control / Segregation of Duties

Finding: The Department of Children, Youth, and Families did not have adequate internal controls to ensure payments to providers for travel and family visits were allowable and adequately supported for the Foster Care program. Questioned Costs: Assistance Listing # 93.658 93.658 COVID-19 St...

Finding: The Department of Children, Youth, and Families did not have adequate internal controls to ensure payments to providers for travel and family visits were allowable and adequately supported for the Foster Care program. Questioned Costs: Assistance Listing # 93.658 93.658 COVID-19 Status: Corrective action in progress Corrective Action: The Department is committed to strengthening internal controls and complying with grant requirements. In response to the auditor?s recommendations, the Department will work with the Financial and Business Services Division and Foster Care Program to review the fiscal monitoring procedures to ensure payments to providers for travel and family visits are allowable and adequately supported. The conditions noted in this finding were previously reported in finding 2021-040. Completion Date: Estimated December 2023 Agency Contact: Stefanie Niemela Audit Liaison PO Box 40970 Olympia, WA 98504-0970 (360) 725-4402 stefanie.niemela@dcyf.wa.gov

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Finding 15991 (2022-047)

Material Weakness 2022

State of Washington C/o Office of Financial Management

WA

Subrecipient Monitoring Allowable Costs / Cost Principles Internal Control / Segregation of Duties

Finding: The Department of Children, Youth, and Families did not have adequate controls over and did not comply with certain requirements of its Public Assistance Cost Allocation Plan. Questioned Costs: Assistance Listing # 93.658 93.658 COVID-19 Status: Corrective action complete Correct...

Finding: The Department of Children, Youth, and Families did not have adequate controls over and did not comply with certain requirements of its Public Assistance Cost Allocation Plan. Questioned Costs: Assistance Listing # 93.658 93.658 COVID-19 Status: Corrective action complete Corrective Action: The Department concurs with the finding and is committed to improving internal controls. During July through September 2021, the first three months of the audit period, the Department did not have adequate staffing levels to maintain the business processes for the Public Assistance Cost Allocation Plan (PACAP) cost base for administrative charges. Available staff focused on grant reconciliations and close-out of the prior fiscal year financial transactions. In October 2021, the Department began updating the monthly workbooks in accordance with the approved PACAP. To address the finding and audit recommendations, the Department: ? Reviewed the written base edit form procedures with staff. ? Added reminders for base edit entries to the Cost Allocation and Grants Management Unit calendar. Completion Date: April 2023 Agency Contact: Stefanie Niemela Audit Liaison PO Box 40970 Olympia, WA 98504-0970 (360) 725-4402 stefanie.niemela@dcyf.wa.gov

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Finding 15987 (2022-040)

Material Weakness 2022

State of Washington C/o Office of Financial Management

WA

Subrecipient Monitoring Reporting Allowable Costs / Cost Principles § 200.208 § 200.332 § 200.339 § 200.501 § 200.513

Finding: The Department of Commerce did not have adequate internal controls over and did not comply with requirements to issue management decisions for audit findings to subrecipients of the Low-Income Home Energy Assistance Program. Questioned Costs: Assistance Listing # 93.568 93.568 COVID-...

Finding: The Department of Commerce did not have adequate internal controls over and did not comply with requirements to issue management decisions for audit findings to subrecipients of the Low-Income Home Energy Assistance Program. Questioned Costs: Assistance Listing # 93.568 93.568 COVID-19 Status: Corrective action complete Corrective Action: The Department?s internal control officer is responsible for completing the monitoring of federal reporting and issuing management decisions for subrecipients who receive federal audit findings for programs funded with the Department?s federal pass-through funding. Beginning in December 2021, the internal control officer documented all findings, corrective action plans, and communication with subrecipients in a monitoring spreadsheet. This enabled the Department to ensure all efforts in monitoring subrecipients were taken. In May 2022, all management decisions were added to the monitoring spreadsheet which documented the Department?s management decisions. To ensure compliance with federal requirements for subrecipient monitoring, the Department has implemented the following process: ? Review all audit findings issued to Department subrecipients. ? Review each subrecipient?s corrective action plan. ? Review and discuss all findings and corrective action plans with subrecipients to identify and understand the basis for the deficiency and planned corrections. ? Create a management decision for each subrecipient finding, receive leadership approval, and formally communicate the decision to our subrecipient. ? All management decisions will be formally communicated to our pass-through subrecipients within the six-month federal deadline. Completion Date: September 2022 Agency Contact: Gena Allen Internal Control Officer PO Box 42525 Olympia, WA 98504-2525 (360) 480-5149 Gena.Allen@Commerce.wa.gov

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Finding 15981 (2022-037)

Material Weakness 2022

State of Washington C/o Office of Financial Management

WA

Subrecipient Monitoring Internal Control / Segregation of Duties Allowable Costs / Cost Principles

Finding: The Department of Social and Health Services did not have adequate internal controls over and did not comply with requirements to ensure staff properly considered the income information obtained from data matching when determining client eligibility and benefits for the Temporary Assistanc...

Finding: The Department of Social and Health Services did not have adequate internal controls over and did not comply with requirements to ensure staff properly considered the income information obtained from data matching when determining client eligibility and benefits for the Temporary Assistance for Needy Families program. Questioned Costs: Assistance Listing # 93.558 Amount $0 Status: Corrective action not taken Corrective Action: The Department does not concur with the finding. The Department has established processes in place to ensure income information is properly considered during client eligibility and benefits determination for the Temporary Assistance for Needy Families (TANF) Program. During eligibility determination at application intake, the eligibility worker: ? Interviews the client to determine income. ? Compares client reported information and cross matches against the Income Eligibility and Verification System (IEVS) per the Code of Federal Regulations (CFR). ? Resolves discrepancies for all new or previously unverified information received. ? Uses the information to determine if the client income is below the maximum earned income limits for TANF per WAC 388-478-0035. ? Verifies all circumstances as required in WAC 388-490-0005 and follows requirements when discrepancies exist, which include taking appropriate actions if the information is questionable, confusing, or outdated. The Department utilizes Spider, which is a tool that combines several different data matches including IEVS. In addition, the Department uses templates to appropriately and comprehensively document the eligibility determination to ensure consistency, accuracy, and that lean processes are followed. ? The Earned Income Template o Addresses income received within 30 days of the application date and any discrepancies found between the case record, online verification systems, previously projected income, and income type. o Does not require documentation if there is no income reported and when no discrepancy is found in cross matches. ? The Final Narrative Template o Includes completing check boxes to document types of cross matches reviewed during application intake and a summary of the transactions that occurred. In all seven exceptions identified by the auditors, the client?s situation did not require the eligibility workers to use the Earned Income Templates due to: ? No income reported. ? No income found in IEVS and other cross matches. ? No discrepancies. ? No changes within 30 days. The eligibility workers did create documentation using the Final Narrative Template for all seven cases with notation stating: ?Reviewed the following system(s): Spider.? All these actions were consistent and aligned with the Department?s "Standard Remarks and Narrative Documentation? procedures. Alerts are not generated for all income fluctuations but as appropriate when a review and potential action is required. This is to minimize creating unnecessary alerts which would take staff time away from other required and mission-critical actions. The Department asserts that the system is working as designed, which is evidenced by the fact that the Department accurately determined eligibility in all seven cases identified as exceptions by the auditors. The Department will continue to: ? Review IEVS information at application intake and verify and document any discrepancies between what is reported by the household and what is shown in the cross matches. ? Use templates to ensure documentation supports the eligibility decisions. ? Generate alerts when an applicant is budgeted with zero income, but the IEVS data match shows income. ? Use the final narrative documentation template, that includes check boxes, to notate cross matches reviewed during application intake. Completion Date: Not applicable Agency Contact: Rick Meyer External Audit Compliance Manager PO Box 45804 Olympia, WA 98504-5804 (360) 664-6027 Richard.Meyer@dshs.wa.gov

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Finding 15980 (2022-036)

Material Weakness 2022

State of Washington C/o Office of Financial Management

WA

Questioned Costs Allowable Costs / Cost Principles Subrecipient Monitoring § 200.1 § 200.410 § 200.516

Finding: The Department of Children, Youth, and Families did not have adequate internal controls over and did not comply with client eligibility requirements for child care services paid with the Child Care and Development Fund and Temporary Assistance for Needy Families funds. Questioned Costs:...

Finding: The Department of Children, Youth, and Families did not have adequate internal controls over and did not comply with client eligibility requirements for child care services paid with the Child Care and Development Fund and Temporary Assistance for Needy Families funds. Questioned Costs: Assistance Listing # 93.558 93.575 93.575 COVID-19 93.596 Amount $5,689 $5,078 Status: Corrective action in progress Corrective Action: The Child Care and Development Fund (CCDF) program was previously managed by the Department of Social and Health Services and the Department of Early Learning. Since the program transitioned in 2019, the Department has been making efforts to strengthen internal controls over payments to child care providers and other CCDF grant requirements. In response to the finding, the Department established overpayments and referred them to the Office of Financial Recovery for collection. As part of process and internal control improvements, the Department implemented the Fair Start for Kids Act (FSKA) on October 1, 2021, to simplify rules and expand eligibility. The FSKA: ? Raises the State Median Income threshold, increasing the number of eligible two-parent households. ? Caps copayments at $115 for applicants and $215 for reapplicants, reducing the copay amounts for two-parent households. ? Acts as disincentives for fraud as families are less likely to report the non-custodial parent who is not a household member. The Department continues to review cases for accuracy following these new rules and policies. In September 2022, the Office of Child Care (OCC) released a document to help CCDF lead agencies simplify the format and content of child care assistance applications, which includes guidance on defining, collecting, and verifying eligibility information. The Department continues to follow guidance from OCC to update policies and procedures within the authority under the Revised Code of Washington and Washington Administrative Code. This includes: ? Updating policies and procedures for cases with simplified eligibility such as families experiencing homelessness or families with children receiving protective services. Public Benefit Specialist (PBS) staff received training in the winter of 2022, which included the use of systems data to establish household composition. ? Developing a guide for staff to more effectively use the Employment Security Department (ESD) quarterly reported data for eligibility determinations. The ESD data is directly reported by the employer, secured, and reduces delays in benefits by eliminating the wait for employment verification. It is also simple to use for the PBS staff and the auditors, thereby reducing income calculation errors and removing the need for consumers to provide documentation to support the eligibility determination. This procedural change and training are expected to be completed by the summer of 2023. The conditions noted in this finding were previously reported in findings 2021-035, 2020-039, 2019-032, 2018-030, 2017-026, 2016-023, 2015-026, 2014-026, 2013-017 and 2012-30. Completion Date: Estimated October 2023 Agency Contact: Stefanie Niemela Audit Liaison PO Box 40970 Olympia, WA 98504-0970 (360) 725-4402 stefanie.niemela@dcyf.wa.gov

View Audit 23129 Questioned Costs: $1

Finding 15979 (2022-035)

Material Weakness 2022

State of Washington C/o Office of Financial Management

WA

Questioned Costs Allowable Costs / Cost Principles Subrecipient Monitoring § 200.1 § 200.403 § 200.410 § 200.53

Finding: The Department of Children, Youth, and Families did not have adequate internal controls over and did not comply with requirements to ensure payments to child care providers paid with Temporary Assistance for Needy Families funds were allowable and properly supported. Questioned Costs: A...

Finding: The Department of Children, Youth, and Families did not have adequate internal controls over and did not comply with requirements to ensure payments to child care providers paid with Temporary Assistance for Needy Families funds were allowable and properly supported. Questioned Costs: Assistance Listing # 93.558 Amount $67,699,429 Status: Corrective action in progress Corrective Action: The Working Connections Child Care (WCCC) program was previously managed by the Department of Social and Health Services (DSHS) and the Department of Early Learning. Since the program transitioned in 2019, the Department has been making efforts to strengthen internal controls over payments to child care providers and other grant requirements. The Department implemented grant-level management of all federal funds, including the Temporary Assistance for Needy Families (TANF) grant. The Department allocated the TANF grant to eligible clients and allowable activities in compliance with 45 CFR 98.67. For the fiscal year 2021 program audit, the State Auditor?s Office (SAO) issued a finding with $32 questioned costs for non-compliance with the CCDF eligibility requirement. No other findings, management letters, or exit items were reported in this compliance area or the cost allocation of funds based on eligibility for the CCDF or TANF grants. Given that eligibility or cost allocation has not been an area of concern, and transfers were processed between TANF and CCDF source of funds with the same eligibility criteria, the Department is assured that TANF funding was spent appropriately within federal regulations. The Department is committed to improving internal controls. The Department does not currently have the resources to develop and maintain the business process redesign, as well as the information technology initiatives necessary to meet the level of assurance recommended by SAO. In response to prior year?s audit recommendations, the Department has submitted a budget request to the Legislature in the 2023-2025 biennial budget for additional resources to process adjustments to include transaction-level data. As part of the audit resolution process, the Department of Health and Human Services (HHS), which oversees the CCDF program at the federal level, reviews all SAO findings and issues management decision letters. The letters will reflect the grantor?s determination of whether an audit finding is sustained, the reasons for the decision, and the required actions by the auditee. When a management decision is issued for the fiscal year 2021 finding, the Department will work with HHS and follow the audit resolution process. Completion Date: Agency Contact: The conditions noted in this finding were previously reported in finding 2021-028. Estimated December 2024 Stefanie Niemela Audit Liaison PO Box 40970 Olympia, WA 98504-0970 (360) 725-4402 stefanie.niemela@dcyf.wa.gov

View Audit 23129 Questioned Costs: $1

Finding 15976 (2022-034)

Material Weakness 2022

State of Washington C/o Office of Financial Management

WA

Subrecipient Monitoring Reporting Equipment & Real Property Management

Finding: The Department of Health did not have adequate internal controls over and did not comply with reporting requirements for the Epidemiology and Laboratory Capacity for Infectious Diseases program. Questioned Costs: Assistance Listing # 93.323 93.323 COVID-19 Status: Corrective action...

Finding: The Department of Health did not have adequate internal controls over and did not comply with reporting requirements for the Epidemiology and Laboratory Capacity for Infectious Diseases program. Questioned Costs: Assistance Listing # 93.323 93.323 COVID-19 Status: Corrective action in progress Corrective Action: The Department partially agrees with the finding. For the two reports on which the auditors took exceptions, the Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) program did discover the errors after the original reports were submitted. The Department notified the Centers for Disease Control and Prevention (CDC) about the reporting errors in February 2022, which was within the reporting period. However, due to a technical issue, the federal reporting system would not allow ELC program staff to input edits to the reports for the months of July through October 2021. After a discussion with CDC, program staff were advised to submit the corrected data of the previous reports via email, which was subsequently accepted by the grantor and the issue was resolved. The Department agrees there needs to be evidence of documented reviews of reports and is implementing steps to ensure review and approval of reports are well documented and retained before final submission to the federal grantor. Completion Date: Estimated December 2023 Agency Contact: Jeff Arbuckle External Audit Manager PO Box 47890 Olympia, WA 98504-7890 (360) 701-0798 Jeff.Arbuckle@doh.wa.gov

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Finding 15975 (2022-033)

Material Weakness 2022

State of Washington C/o Office of Financial Management

WA

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles § 200.00 § 200.516

Finding: The Department of Health did not have adequate internal controls over and did not comply with fiscal monitoring requirements to ensure subrecipients of the Epidemiology and Laboratory Capacity for Infectious Diseases program only used funds for allowable activities and met cost principles....

Finding: The Department of Health did not have adequate internal controls over and did not comply with fiscal monitoring requirements to ensure subrecipients of the Epidemiology and Laboratory Capacity for Infectious Diseases program only used funds for allowable activities and met cost principles. Questioned Costs: Assistance Listing # 93.323 93.323 COVID-19 Amount $1,644,873 Status: Corrective action in progress Corrective Action: The Department partially concurs with the finding. The Department agrees with the auditors? recommendation over subrecipient monitoring to require transactions that were previously coded as ?COVID? to be recorded with the specific revenue source and will do so in future monitoring visits. The Department does not agree with the auditors? assessment of a material weakness in internal controls over subrecipient monitoring. When staff conduct fiscal monitoring site visits, key control systems including payroll and disbursements are reviewed and documented. These monitoring activities ensure internal controls are operating effectively and providing assurance that reimbursements are allowable and accurate. The Department acknowledges that internal controls can be strengthened over provider payments and will take the following actions: ? Require payments to providers be adequately supported by the appropriate backup documentation and subrecipient risk assessments. ? Update the documentation requirements to align with the identified risk levels and federal guidance. ? Develop tracking sheets, which enable staff to record details from backup documentation reviews and payment approvals. ? Provide additional training to staff in the Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) program responsible for reviewing invoices. The Department disagrees with the SAO?s assessment of a material weakness in internal controls over the consolidated contract provider payment process for the ELC program. The Department has established processes in place to ensure payments are allowable and meet cost principles for the program. These include: ? Perform annual review and approval of detailed subrecipient budgets. ? Compare invoice amounts to budgeted amounts for reasonableness before payment approval. ? Provide subrecipients regular technical assistance and training on applicable policies related to fiscal and programmatic processes. ? Conduct biennial program and fiscal monitoring visits to subrecipients as part of the Department?s monitoring procedures. In addition, the ELC program has monitoring controls in place and evidence of review at the program level. Program staff maintain a detailed spreadsheet that documents review and approval and includes any amounts that need to be withheld until issues with invoice support are resolved. These reviews are to be completed within the 10-day period before payment is released. The Department is planning on meeting with federal grantors to work through the exceptions and questioned costs identified in the finding. Completion Date: Estimated March 2024 Agency Contact: Jeff Arbuckle External Audit Manager PO Box 47890 Olympia, WA 98504-7890 (360) 701-0798 Jeff.Arbuckle@doh.wa.gov

View Audit 23129 Questioned Costs: $1

Finding 15969 (2022-031)

Material Weakness 2022

State of Washington C/o Office of Financial Management

WA

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles § 200.00 § 200.1 § 200.410 § 200.516

Finding: The Department of Health did not have adequate internal controls over and did not comply with requirements to ensure payments to providers were allowable, met cost principles, and were within the period of performance for the Immunization Cooperative Agreements program. Questioned Costs:...

Finding: The Department of Health did not have adequate internal controls over and did not comply with requirements to ensure payments to providers were allowable, met cost principles, and were within the period of performance for the Immunization Cooperative Agreements program. Questioned Costs: Assistance Listing # 93.268 93.268 COVID-19 Status: Corrective action in progress Corrective Action: The Department partially agrees with the finding. The Department agrees that internal controls can be strengthened over provider payments to ensure funds are allowable and spent within the period of performance. The following actions were taken: ? Required payments to providers contain adequate support in line with the A19 matrix and subrecipients? risk assessments. ? Provided additional training to staff in the immunization unit responsible for reviewing invoices. ? Developed tracking sheets which enable staff to record details from backup documentation reviews and payment approvals. The Department will review the control weaknesses identified in the audit related to the consolidated contract payment process and will determine if changes need to be made. The Department disagrees with the audit exceptions and questioned costs identified in the finding. The Department will work with the federal grantor to resolve any questioned costs. Completion Date: Estimated December 2023 Agency Contact: Jeff Arbuckle External Audit Manager PO Box 47890 Olympia, WA 98504-7890 (360) 701-0798 Jeff.Arbuckle@doh.wa.gov

View Audit 23129 Questioned Costs: $1

Finding 15948 (2022-005)

Significant Deficiency 2022

Chesapeake Research Consortium, Inc.

MD

Allowable Costs / Cost Principles Reporting Significant Deficiency

Environmental Protection Agency Chesapeake Bay Program - Grant No. CB96343601; Grant period - Year ended June 30, 2022 FINDING 2022-005: Internal Controls Over Financial Reporting Recommendation: Accounting processes and procedures should be reviewed and revised to include the process of all...

Environmental Protection Agency Chesapeake Bay Program - Grant No. CB96343601; Grant period - Year ended June 30, 2022 FINDING 2022-005: Internal Controls Over Financial Reporting Recommendation: Accounting processes and procedures should be reviewed and revised to include the process of allocating and recording credit card bills to corresponding grants. Action Taken: We concur with the recommendation and will adjust our processes accordingly.

View Audit 19565

Finding 15941 (2022-004)

None 2022

Syracuse Model Neighborhood Facility, Inc.

NY

Allowable Costs / Cost Principles

Control Deficiency 2022-004 Allocation of Functional Expenses Contact Person Responsible for Corrective Action Plan: Lawrence Williams, Chief Executive Officer. Corrective Action Plan: The Chief Executive Officer and Chief Financial Officer will ensure a detailed review is performed of expenses be...

Control Deficiency 2022-004 Allocation of Functional Expenses Contact Person Responsible for Corrective Action Plan: Lawrence Williams, Chief Executive Officer. Corrective Action Plan: The Chief Executive Officer and Chief Financial Officer will ensure a detailed review is performed of expenses between program expense and administrative expenses. Anticipated Completion Date of Corrective Action Plan: December 31, 2023

View Audit 19559

Finding 15901 (2022-002)

Material Weakness 2022

Woodland School District No. 404

WA

Subrecipient Monitoring Internal Control / Segregation of Duties Special Tests & Provisions

Finding ref number: 2022-002 Finding caption: The District did not have adequate internal controls for ensuring compliance with wage rate requirements. Name, address, and telephone of District contact person: Stacy Brown, Director of Business Services 800 Second St Woodland, WA 98674-8467 (360) 8...

Finding ref number: 2022-002 Finding caption: The District did not have adequate internal controls for ensuring compliance with wage rate requirements. Name, address, and telephone of District contact person: Stacy Brown, Director of Business Services 800 Second St Woodland, WA 98674-8467 (360) 841-2715 Corrective action the auditee plans to take in response to the finding: (If the auditee does not concur with the finding, the auditee must list the reasons for disagreement). The current vendor invoices do not break out when we are getting equipment and when there are staff onsite working. The work has been sporadic, so in the Business Office, we do not know when they are onsite and therefore not sure when payrolls are required. We are working with the maintenance department to keep us apprised when we have contractors onsite working on the HVAC (ESSER) projects. We originally thought we could get the weekly payrolls from the L&I website, but are finding that they are not posted timely and sometimes not at all. We are working directly with the vendors to provide weekly payrolls when they are working. The district has implemented a review log for all Federal projects requiring review of weekly payrolls. The Purchasing and Benefits Coordinator will document the vendor, week and certify that she has received and reviewed the payrolls received. Payment will be withheld if we do not receive the payrolls in a timely manner. Anticipated date to complete the corrective action: 6/12/23

View Audit 19549

Finding 15889 (2022-004)

Material Weakness 2022

Memorial Health and Subsidiaries

IL

Subrecipient Monitoring Allowable Costs / Cost Principles Cash Management § 200.303

? Finding 2022-004 ? In October 2022, Management enhanced its maintained supporting documentation to provide evidence of review and approval of FEMA expenditures and financial reporting for future FEMA submissions. o Responsible Party: Amanda Zentefis

View Audit 19521

Finding 15883 (2022-002)

Material Weakness 2022

Memorial Health and Subsidiaries

IL

Questioned Costs Reporting Allowable Costs / Cost Principles § 200.303

? Finding 2022-002 ? On or before September 30, 2023, Management will review all time & effort reporting covering its fiscal year 2023 and implement updates to its certification reporting to ensure calculations are accurately derived and verified through independent review for 100% of each employee?...

? Finding 2022-002 ? On or before September 30, 2023, Management will review all time & effort reporting covering its fiscal year 2023 and implement updates to its certification reporting to ensure calculations are accurately derived and verified through independent review for 100% of each employee?s time and effort and ensure amounts charged to the grant in fiscal year 2023 are supported by these certified records. o Responsible Party: Peggy Wisher

View Audit 19521 Questioned Costs: $1

Finding 15833 (2022-030)

Material Weakness 2022

State of Washington C/o Office of Financial Management

WA

Subrecipient Monitoring Procurement, Suspension & Debarment Allowable Costs / Cost Principles § 200.208 § 200.332 § 200.339 § 200.501 § 200.513

Finding: The University of Washington did not have adequate internal controls over and did not comply with federal requirements to ensure subrecipients of the Global AIDS program received required single or program-specific audits, and that it followed up on findings and issued management decisions...

Finding: The University of Washington did not have adequate internal controls over and did not comply with federal requirements to ensure subrecipients of the Global AIDS program received required single or program-specific audits, and that it followed up on findings and issued management decisions. Questioned Costs: Assistance Listing # 93.067 93.067 COVID-19 Amount $0 Status: Corrective action in progress Corrective Action: The University maintains that there are adequate internal controls to ensure the Global AIDS program complies with the requirements for pass-through entities as outlined in Uniform Guidance 2 CFR ? 200.332 and the university policy incorporated in Grants Information Memorandum 8. As noted in the finding, the University uses a certification process to obtain information and documentation needed, such as audited financial statements, from each subrecipient and perform a risk assessment using standard risk criteria. For the one exception identified by the auditors, the University misinterpreted the response provided by the subrecipient regarding whether it expended $750,000 or more in federal awards during the fiscal year. Although the single or program specific audit report was not obtained and reviewed, a risk assessment was performed on the subrecipient. With a medium risk rating, the subrecipient was subject to monitoring at the program level throughout the project during the period in question, in accordance with University policy. The University will: ? Update the certification process with all subrecipients to confirm if federal expenditures during a fiscal year exceed the $750,000 threshold to require a single or program-specific audit. ? Issue written management decisions for all applicable audit findings. ? Ensure subrecipients develop and perform acceptable corrective actions to address all audit recommendations, if applicable. Completion Date: Estimated September 2023 Agency Contact: Erick Winger Controller 4300 Roosevelt Way NE Seattle, WA 98195 (206) 543-5322 erickw@uw.edu

View Audit 23129

Finding 15831 (2022-028)

Material Weakness 2022

State of Washington C/o Office of Financial Management

WA

Subrecipient Monitoring Allowable Costs / Cost Principles § 200.516

Finding: The University of Washington did not establish adequate internal controls to ensure payments to contractors and subrecipients for the Global AIDS program were allowable, properly supported and within the period of performance. Questioned Costs: Assistance Listing # 93.067 93.067 COV...

Finding: The University of Washington did not establish adequate internal controls to ensure payments to contractors and subrecipients for the Global AIDS program were allowable, properly supported and within the period of performance. Questioned Costs: Assistance Listing # 93.067 93.067 COVID-19 Amount $0 Status: Corrective action complete Corrective Action: The University partially concurs with the finding. The University disagrees with the auditors? assertion that internal controls were inadequate to ensure payments to contractors and subrecipients of the Global AIDS program were allowable, properly supported, and within the period of performance. Payments to country offices The University administers the program through its International Training and Education Center for Health (I-TECH), a center in the University?s Department of Global Health, with staff in various locations worldwide. I-TECH country offices are not contractors but are an extension of the University. The audit identified one of 58 payments in the test sample (1.7 percent) that did not meet the approval requirements set forth in I-TECH?s standard operating procedures. Based on the error percentage, the University disagrees with this part of the finding. Payments to contractors The University?s current payment process to contractors has multiple approval requirements. Upon receipt, program/budget manager reviews and approves individual invoices prior to input into the University?s procurement system by the I-TECH accounts payable administrator. The system requires compliance approval from the account payable supervisor or other manager, as well as funding approval from the budget manager prior to payment. Approvals of Budget Activity Reports (BARS) are not part of the approval process for contractor payments, but are post-payment reviews by budget managers of monthly expenses posted to the budget to ensure they are within expectations. The University disagrees with the exceptions identified in the finding related to payments to contractors. The exceptions noted were payments made to country offices instead of contractors, the supporting approvals of which were provided to the auditors on April 26, 2023, prior to the completion of fieldwork. Subrecipient reimbursements Contract managers review each subrecipient invoice for reasonableness, allowability and allocability, and require approval by both budget managers and principal investigators (PI) prior to payment in the University?s procurement system. The auditors reviewed and verified PI approvals for each selected subrecipient with no exception identified. It should be noted that approvals of BARS are also not part of the approval process for payments to subrecipients. The University acknowledges that documentation related to BARS reviews by budget managers was not available for 52 of the transactions tested and agrees that improvement is needed for retaining documentation of monthly reviews. In response to the finding, the University has started saving BARS review documentation on the server to ensure the documents are readily available. Completion Date: April 2023 Agency Contact: Erick Winger Controller 4300 Roosevelt Way NE Seattle, WA 98195 (206) 543-5322 erickw@uw.edu

View Audit 23129

Finding 15816 (2022-027)

Material Weakness 2022

State of Washington C/o Office of Financial Management

WA

Subrecipient Monitoring Internal Control / Segregation of Duties Matching / Level of Effort / Earmarking

Finding: The Office of Financial Management did not have adequate internal controls over and did not comply with federal level of effort requirements for the Education Stabilization Fund program. Questioned Costs: Assistance Listing # 84.425D COVID-19 84.425R COVID-19 94.425U COVID-19 84.425...

Finding: The Office of Financial Management did not have adequate internal controls over and did not comply with federal level of effort requirements for the Education Stabilization Fund program. Questioned Costs: Assistance Listing # 84.425D COVID-19 84.425R COVID-19 94.425U COVID-19 84.425V COVID-19 Amount $0 Status: Corrective action not taken Corrective Action: The Office does not concur with the finding. The Office performed the maintenance of effort (MOE) calculations in accordance with the guidance provided by the U.S. Department of Education (ED). Based on appropriations and past funding, it was determined that the fiscal year 2022 expenditure level did not meet the MOE requirement. The Office followed the federal guidance and directions from a legislative proviso in the enacted state budget (Chapter 334, Laws of 2021, Sec. 954) and submitted a waiver request for fiscal years 2022 and 2023. The waiver was submitted before ED?s stipulated deadline of December 31, 2021. ED?s website confirmed an MOE waiver request was received from Washington state and the status of the request is currently listed as ?under review.? The Office maintains adequate internal controls and has followed all federal and state requirements with due diligence in requesting the MOE waiver. The approval process rests with the federal grantor, and the waiver has not been disapproved. In addition, the Office has been meeting with ED on a monthly basis and is already consulting with the grantor regarding the pending waiver request. The Office will also continue to work with the Legislature, which is the state-level authority for state appropriations, to monitor any updates to federal requirements. Completion Date: Not applicable Agency Contact: Brian Tinney Statewide Accounting Director PO Box 43127 Olympia, WA 98504-3127 (564) 999-1781 brian.tinney@ofm.wa.gov

View Audit 23129

Finding 15690 (2022-001)

Material Weakness 2022

Winslow Residential Hall, Inc.

AZ

Allowable Costs / Cost Principles § 200.403

Finding Number: 2022-001 Program Names/Assistance Listing Titles: Assistance Listing Numbers: Indian School Equalization 15.042 Education Stabilization Fund 84.425 Contact Person: Vada Begay, Business Manager, Sylvia Largo, Homeliving Department Supervisor, and School Board Members Anticipated Compl...

Finding Number: 2022-001 Program Names/Assistance Listing Titles: Assistance Listing Numbers: Indian School Equalization 15.042 Education Stabilization Fund 84.425 Contact Person: Vada Begay, Business Manager, Sylvia Largo, Homeliving Department Supervisor, and School Board Members Anticipated Completion Date: March 31, 2023 Planned Corrective Action: All financial activities were processed per 2 CFR 200.403 to ensure they were allowable, necessary, and reasonable. WRHI as a Tribally Controlled Organization did expend funds under a self-determination contract in support of a residential program servicing students during the COVID-19 pandemic. Management did communicate with the Board to ensure that the proper expenditure of allocated funds for the board was paid out of the Administrative cost grant.

View Audit 18830

Finding 15689 (2022-001)

Significant Deficiency 2022

Jacksonville/north Pulaski School District

AR

Questioned Costs Allowable Costs / Cost Principles Internal Control / Segregation of Duties § 200.439

Finding 1: The District did not obtain prior written approval from the Department of Elementary and Secondary Education (DESE) for the purchase of two pieces of equipment with unit costs greater than the $5,000 threshold as required by COM-22- 047. Corrective Action: The District will comply with al...

Finding 1: The District did not obtain prior written approval from the Department of Elementary and Secondary Education (DESE) for the purchase of two pieces of equipment with unit costs greater than the $5,000 threshold as required by COM-22- 047. Corrective Action: The District will comply with all federal purchasing requirements, including obtaining written approval for equipment with unit costs greater than $5,000. Person Responsible for Corrective Actions: Federal Programs Coordinator Completion Date: This practice will go into effect immediately. Supplemental Findings

View Audit 18563 Questioned Costs: $1

Finding 15687 (2022-001)

None 2022

Monarch Services - Servicios Monarca

CA

Allowable Costs / Cost Principles

N/A

View Audit 18407

Finding 14430 (2022-006)

Material Weakness 2022

Saint Louis University

MO

Allowable Costs / Cost Principles Reporting Matching / Level of Effort / Earmarking § 200.303

Two transaction level controls will be implemented. A review of the IDX payer class grouping will be performed to validate the allocation of the report used to enter the key line items and a separate review will be performed on the line-item data in the portal compared to the reports. These controls...

Two transaction level controls will be implemented. A review of the IDX payer class grouping will be performed to validate the allocation of the report used to enter the key line items and a separate review will be performed on the line-item data in the portal compared to the reports. These controls will address each financial line item in the portal; regardless of whether it contributes to the portal financial calculation. Tammy Burton, Associate Dean of School of Medicine, is responsible for addressing the above items by March 31, 2023.

View Audit 17372

Finding 14422 (2022-011)

Material Weakness 2022

Saint Louis University

MO

Questioned Costs Allowable Costs / Cost Principles § 200.303 § 200.430

The Office of Vice President of Research and the Controller?s Office will collaborate to ensure effort verification reports are returned no later than 30 calendar days after they have been distributed, including escalating noncompliance to appropriate University leadership. These improvements are ex...

The Office of Vice President of Research and the Controller?s Office will collaborate to ensure effort verification reports are returned no later than 30 calendar days after they have been distributed, including escalating noncompliance to appropriate University leadership. These improvements are expected to be completed by December 2023. Tara Thomason, Controller and Assistance Vice President, is responsible for addressing the above items by December 2023.

View Audit 17372 Questioned Costs: $1

Finding 13201 (2022-004)

Material Weakness 2022

Saint Louis University

MO

Questioned Costs Matching / Level of Effort / Earmarking Allowable Costs / Cost Principles § 200.303 § 200.403

The Office of Vice President of Research and the Controller?s Office worked with the University?s Workday Finance team to configure its accounting system with an automated control that prevents general (nonpayroll) expenditures from being charged to the grant after the period of performance end date...

The Office of Vice President of Research and the Controller?s Office worked with the University?s Workday Finance team to configure its accounting system with an automated control that prevents general (nonpayroll) expenditures from being charged to the grant after the period of performance end date, one root cause of cost transfers. In addition, for payroll expenditures, the above teams updated grant labor costing allocations in its accounting system to contain an end date that coincides with the period of performance end date which restricts labor costs from being charged after the period of performance. The post award specialists will begin reviewing the labor costing allocations on a periodic basis. Also implemented in fiscal year 2023, before each payroll is processed by the Director of Payroll within the accounting system, grants that have ended are identified by the Assistant Controller and Director of Sponsored Program Accounting and the payroll expenditures are removed from the feed and not charged to the grant. The University has also hired individuals whose sole responsibility is to review general (non-payroll) expenditures charged to grants. Further, the University?s post award specialists are continually trained on the importance of allowed and unallowed expenditures and are now reviewing grant level budget versus actual reporting on a periodic basis to identify noncompliance. Tara Thomason, Controller and Assistance Vice President, is responsible for addressing the above items by December 2023.

View Audit 17372 Questioned Costs: $1

Finding 13200 (2022-003)

Material Weakness 2022

Saint Louis University

MO

Equipment & Real Property Management Procurement, Suspension & Debarment Allowable Costs / Cost Principles § 200.303 § 200.313

The Controller?s Office is amending our capital equipment policy to include the escalation for violations of noncompliance to Deans and/or Vice Presidents. In addition, we are improving our processes and internal controls to ensure additions, transfers and disposals are appropriately recorded in Wor...

The Controller?s Office is amending our capital equipment policy to include the escalation for violations of noncompliance to Deans and/or Vice Presidents. In addition, we are improving our processes and internal controls to ensure additions, transfers and disposals are appropriately recorded in Workday. We continue to improve our utilization of Workday Financials to ensure timely updates are made to the property records and are exploring additional automation tools. These changes are expected to be in place by December 2023. Tara Thomason, Controller and Assistance Vice President, is responsible for addressing the above items by December 2023.

View Audit 17372

Corrective Action Plans

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