Corrective Action Plans

Finding 20101 (2022-001)

Material Weakness 2022

WA

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

Finding ref number: 2022-001 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: Andrea Nokell 2689 Hoover Ave SE Port Orchard, WA 98366 360-874-7015 Corrective action th...

Finding ref number: 2022-001 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: Andrea Nokell 2689 Hoover Ave SE Port Orchard, WA 98366 360-874-7015 Corrective action the auditee plans to take in response to the finding: The District will obtain weekly certified payroll reports from all contractors and subcontractors performing public works projects funded with Federal funds. Anticipated date to complete the corrective action: Immediately.

View Audit 21474

Finding 20093 (2022-001)

Material Weakness 2022

Siouxland Community Health Center

IA

Allowable Costs / Cost Principles Reporting

In completing the annual financial audit for Siouxland Community Health Center (SCHC), and in particular the Provider Relief Fund dollars in the amount of $463,105 received in April and June 2020, staff at FORVIS determined SCHC had made an error in reporting its use of funds. SCHC chose Option 3, w...

In completing the annual financial audit for Siouxland Community Health Center (SCHC), and in particular the Provider Relief Fund dollars in the amount of $463,105 received in April and June 2020, staff at FORVIS determined SCHC had made an error in reporting its use of funds. SCHC chose Option 3, which included a comparison between actual lost patient revenue and budgeted patient revenue for each of the six quarters from 1/1/20 to 6/30/21, and inadvertently entered incorrect actual dollars spent compared to budgeted dollars. The total amount of lost revenue reported was originally reported as $1,542,234, but the revised amount is $1,340,781, a difference of $201,453. This error did not result in any funds be returned. Jan Anderson, CFO, corrected the report on the Provider Relief portal in July 2022.

View Audit 19443

Finding 20079 (2022-001)

Significant Deficiency 2022

District 7 Human Resources Development Council

MT

Allowable Costs / Cost Principles § 200.447

Re: Management Response to - Section Ill - Federal Awards Findings & Questioned Costs During Fiscal Year 2022 HRDC management acknowledges that there were key changes within the organizational structure including changes to personnel within the employment & training department, as well as, various o...

Re: Management Response to - Section Ill - Federal Awards Findings & Questioned Costs During Fiscal Year 2022 HRDC management acknowledges that there were key changes within the organizational structure including changes to personnel within the employment & training department, as well as, various other operating changes. Included below is management's response to Section Ill - Federal Awards Findings & Questioned Costs for the Fiscal Audit ended June 30, 2022. 2022 - 001 INSURANCE COVERAGE - ALLOWABLE COSTS PRINCIPLES The agency carries adequate insurance coverage for all vehicles and property as required by the Code of Federal Regulations. The agency has a written vehicle inspection and maintenance procedure which includes detailed procedures for vehicle inspection, maintenance, reporting of problems, cleaning procedures, and recordkeeping. The agency followed its procedures for vehicle inspections and maintenance and minor observable damage was noted to the vehicle. Shortly after the inspection, key staffing changes occurred and the manager failed to follow up on the report nor continue to note the damage on subsequent monthly reports. Upon return of the leased vehicle to the dealership, the dealership noted hail damage. While the damage was noted in our inspection reports, the length of time to report such a claim to insurance had expired and would not be covered through an insurance claim. Under CFR Section 200.447 Insurance and Indemnification, losses which could have been covered by permissible insurance are unallowable, however costs incurred because of losses not covered under nominal insurance coverage provided in keeping with sound management practice, and minor losses not covered by insurance are allowable. The agency has interpreted this provision as a loss not covered under nominal insurance coverage provided in keeping with sound management practices which would be an allowable cost under CFR 200.447. The Auditors disagreed with our interpretation of the regulations. The agency will continue to inspect vehicles on a regular basis under procedures that have been in effect and are part of our control systems. In addition program managers and directors will be instructed to continue to include any damage on vehicle inspections reports until fixed. The agency believes this is an isolated instance but will continue to try to ensure that all outstanding items are resolved during any staff transition period. The agency also will consider the interpretation of CFR 200.447 for further clarification on what may be included as allowable costs from granting Agencies and federal regulations.

View Audit 18603

Finding 19943 (2022-005)

Material Weakness 2022

Floyd County

IN

Internal Control / Segregation of Duties Allowable Costs / Cost Principles Material Weakness § 200.1 § 200.303

FINDING 2022-005 Contact Person: Donald Lopp, Director of Operations and Planning Contact Phone Number: (812) 948.4110 Views of Responsible Official: Corrective Action As Director of Operations and Planning, the American Rescue Plan quarterly reports are submitted through the office. During the audi...

FINDING 2022-005 Contact Person: Donald Lopp, Director of Operations and Planning Contact Phone Number: (812) 948.4110 Views of Responsible Official: Corrective Action As Director of Operations and Planning, the American Rescue Plan quarterly reports are submitted through the office. During the audit, it appears eight of the ten audit items had the correct cumulative expenditure but those figures were not also applied to the current quarter expenditures. The US Treasury portal will not allow for the submission of the quarterly report unless the cumulative obligations and expenditures match. Description of Corrective Action Plan: Prior to submission, quarterly reports will be printed and reviewed by secondary staff in Office to review submission correctness. Anticipated Completion Date: This method will be instituted at the July 2023 quarterly report submission.

View Audit 23517

Finding 19926 (2022-002)

Material Weakness 2022

Vigo County

IN

Questioned Costs Allowable Costs / Cost Principles § 200.302 § 200.303 § 200.403

FINDING 2022-002 Finding Subject: Child Support Enforcement - Activities Allowed or Unallowed, Allowable Costs/Cost Principles Summary of Finding: An effective internal control system was not in place at the County to ensure compliance with the requirements related to the grant agreement and the Act...

FINDING 2022-002 Finding Subject: Child Support Enforcement - Activities Allowed or Unallowed, Allowable Costs/Cost Principles Summary of Finding: An effective internal control system was not in place at the County to ensure compliance with the requirements related to the grant agreement and the Activities Allowed or Unallowed and Allowable Costs/Cost Principles compliance requirements. The payment of the Deputy Court Clerk?s wages and benefits out of the Clerk?s Incentive Fund supplanted not supplemented the employee?s salary which is unallowable. Contractual payment did not match the amount stated in the contract. The County did not have an allowable cost policy. Contact Person Responsible for Corrective Action: James W. Bramble Contact Phone Number and Email Address: 812-462-3361 james.bramble@vigocounty.in.gov Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Internal control procedures will be evaluated to determine needed changes to correct the above noted compliance requirements over Child Support. Changes will be made to the 2024 budget to correct the payroll related issue so the Clerk?s Incentive Fund. Contracts will be reviewed to ensure the contract amounts are current. The County will develop an allowable cost policy. Anticipated Completion Date: January 1, 2024

View Audit 23400 Questioned Costs: $1

Finding 19870 (2022-001)

None 2022

Commonwealth of Puerto Rico Department of Natural and Environmental Resources

PR

Subrecipient Monitoring Allowable Costs / Cost Principles Reporting § 200.512

Finding No. 2022-001 Audit Requirements for Auditees ? Report Submission Condition found The data collection form and the reporting package for the year ended on June 30, 2022 was not submitted to the Federal Audit Clearinghouse within the timeframe prescribed by the Uniform Guidance. Views of Res...

Finding No. 2022-001 Audit Requirements for Auditees ? Report Submission Condition found The data collection form and the reporting package for the year ended on June 30, 2022 was not submitted to the Federal Audit Clearinghouse within the timeframe prescribed by the Uniform Guidance. Views of Responsible Officials and Corrective Action Plan Department of Natural and Environmental Resources (DNER), Puerto Rico Infrastructure Financing Authority (PRIFA), Puerto Rico Aqueduct and Sewer Authority (PRASA), entered on December 27, 2016, into a Memorandum of Understanding (MOU), subsequently amended on June 21, 2018, to include the Fiscal Agency and Financial Advisory Authority (FAFAA). Under the MOU, as amended, each party has agreed to assume specific responsibilities in connection with the operations of the Revolving Fund pursuant to the Operating Agreement entered between the EPA and the DNER on July 25, 2018. Pursuant to the MOU, as amended, DNER will remain as the administrator for the Revolving Fund, PRIFA will act as the operating agent to provide assistance with the financial and accounting activities, and FAFAA will conduct the financial capabilities analysis of any eligible assistance recipient of funds, provide the necessary information to the DNER and PRIFA to the extent as possible for the development of the different programs compliance reports reviews, provide oversight as fiscal agent, financial advisor and information agent of the Commonwealth to ensure that the monies are safeguarded in a trust structure and to ensure the proper administration. The data collection form and the reporting package were not file on time due to lack and availability of funds to cover expenses related to the audit process and other expenses related to the administrative responsibilities assigned in the Memo of Understanding to PRIFA. Management is currently working with DNER a Subaward, as required by the Environmental Protection Agency (EPA) and as established in the MOU, as amended, in order to respond to the lack of funding to cover all the related expenses for the administrative responsibilities assigned to PRIFA. EPA has been informed and communication will be maintained until the Subaward is in force. Management plans are to file the data collection form for the fiscal year ended on June 30, 2022 on or before June 30, 2023 and the data collection form for the fiscal year ending on June 30, 2023 on or before December 31, 2023, which will result in the elimination of the finding. Name (s) of the Contact Person (s) Responsible for Corrective Action Francisco Pares, Secretary of the Treasury Department, Eduardo Rivera Cruz, Executive Director Puerto Rico Infrastructure Financing Authority and Anais Rodriguez Vega, Secretary Puerto Rico Department of Natural and Environmental Resources Anticipated Completion Date June 2023

View Audit 23582

Finding 19851 (2022-002)

Material Weakness 2022

Highlands School District

PA

Allowable Costs / Cost Principles Cash Management Reporting

2022-002 Activities Allowed or Unallowed Response Highlands School District agrees with the finding and the recommended procedures and is attempting to implement improvements over reporting.

View Audit 23491

Finding 19812 (2022-011)

Material Weakness 2022

State of Washington C/o Office of Financial Management

WA

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

Finding: The Washington State Department of Transportation did not have adequate internal controls over and did not comply with quality assurance program requirements to ensure materials conformed to approved plans and specifications, and that only qualified personnel performed testing for projects...

Finding: The Washington State Department of Transportation did not have adequate internal controls over and did not comply with quality assurance program requirements to ensure materials conformed to approved plans and specifications, and that only qualified personnel performed testing for projects funded by the Highway Planning and Construction Cluster. Questioned Costs: CFDA # 20.205 20.205 COVID-19 20.219 20.224 Amount $0 Status: Corrective action in progress Corrective Action: The Department is committed to ensuring that our grant programs comply with federal regulations related to quality assurance (QA) requirements and safeguarding that materials and workmanship conform to approved plans and specifications through testing, inspections, or certifications. The Department continues to work closely with the Federal Highway Administration (FHWA) on the QA program and has received positive feedback on the strength of the program. In addition, the Department is currently investing in the Unifier software to replace separate QA legacy systems, which will allow shared data and provide built-in controls to help prevent the issues identified in the audit. Depending on funding and programming times, the Department estimates Unifier to be online for the QA program within five years. To address the audit recommendations, the Department?s Construction Division will examine current policies and procedures/practices related to the audit issues. The Department will: ? Update policies and procedures, including the Department?s Construction Manual (M46-01), as needed to ensure staff practices meet federal regulations. Updates will also include other clarifications to address documentation and evidence of compliance, and a reasonable level of controls regarding materials testing, inspections, certification, acceptance, and tester certifications. ? Obtain approval of updates to the Construction Manual from the FHWA. ? Communicate changes in policies and procedures to division staff and stakeholders. ? Provide training to Project Engineering Office staff to emphasize QA program requirements. The conditions noted in this finding were previously reported in findings 2021-011, 2020-017 and 2019-019. Completion Date: Estimated June 2024 Agency Contact: Jesse Daniels External Audit Liaison PO Box 47320 Olympia, WA 98504-7320 (360) 705-7035 danielje@wsdot.wa.gov

View Audit 23129

Finding 19809 (2022-008)

Significant Deficiency 2022

State of Washington C/o Office of Financial Management

WA

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

Finding: The Washington State Department of Transportation did not have adequate internal controls to ensure supervisors reviewed and approved payroll journals for the Highway Planning and Construction Cluster. Questioned Costs: Assistance Listing # 20.205 20.205 COVID-19 20.219 20.224 Amoun...

Finding: The Washington State Department of Transportation did not have adequate internal controls to ensure supervisors reviewed and approved payroll journals for the Highway Planning and Construction Cluster. Questioned Costs: Assistance Listing # 20.205 20.205 COVID-19 20.219 20.224 Amount $0 Status: Corrective action in progress Corrective Action: The Department is committed to ensuring adequate internal controls are established for processing payroll journals. Currently, the Department: ? Sends payroll journals electronically via Adobe Acrobat Sign on day four of payroll processing. ? Generates system automated emails, which are sent to the reviewer each day the journal is unsigned. ? Reconciles unsigned payroll journals and will follow up with responsible staff. To further improve controls over timely approval and return of payroll journals, the Department will: ? Continue to review existing internal controls to assess their effectiveness and make improvements as needed. ? Review the Payroll Manual to ensure directions, guidelines, and expectations around the payroll journal approval are clearly defined. ? Evaluate the appropriateness of establishing a timeline for returning signed payroll journals for incorporation into the Payroll Manual. Completion Date: Estimated June 2024 Agency Contact: Jesse Daniels External Audit Liaison PO Box 47320 Olympia, WA 98504-7320 (360) 705-7035 danielje@wsdot.wa.gov

View Audit 23129

Finding 19718 (2022-062)

Material Weakness 2022

State of Washington C/o Office of Financial Management

WA

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

Finding: The Health Care Authority did not have adequate internal controls over and did not comply with requirements to report recoveries of fraudulent overpayments on the CMS-64 report. Questioned Costs: Assistance Listing # 93.775 93.777 93.777 COVID-19 93.778 93.778 Amount $977,612 Stat...

Finding: The Health Care Authority did not have adequate internal controls over and did not comply with requirements to report recoveries of fraudulent overpayments on the CMS-64 report. Questioned Costs: Assistance Listing # 93.775 93.777 93.777 COVID-19 93.778 93.778 Amount $977,612 Status: Corrective action in progress Corrective Action: The Authority partially concurs with the finding. The Authority has established a process to ensure information concerning the status of Medicaid Fraud Control Unit (MFCU) cases is communicated timely to the Authority from the Attorney General?s Office. The Authority has documented the process to ensure recoveries of fraudulent overpayments are reported on the CMS-64 report appropriately and any federal share is returned timely to the Centers for Medicaid & Medicare Services (CMS). The Authority agrees that $1,032 needs to be repaid to CMS and will initiate return of those funds. The Authority does not concur that the remaining $976,580 needs to be returned to CMS. The state pursued assets through its available means and the court. The provider in question has been out of business since 2017 and a final court ruling was made in June 2022. In April 2023, the Attorney General?s Office certified the defaulted corporation had no identifiable assets. In accordance with 42 CFR 433.318(d), the provider is out of business and the Authority is not required to return the overpayment to CMS. The Authority will provide the court documentation and Attorney General?s certification to CMS Audit Resolution. The conditions noted in this finding were previously reported in findings 2021-052 and 2020-050. Completion Date: Estimated September 2023 Agency Contact: Kari Summerour, CPA External Audit Compliance Manager PO Box 45502 Olympia, WA 98504-5502 (360) 725-9586 Kari.Summerour@hca.wa.gov

View Audit 23129 Questioned Costs: $1

Finding 19717 (2022-061)

Material Weakness 2022

State of Washington C/o Office of Financial Management

WA

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

Finding: The Health Care Authority did not have adequate internal controls over and did not comply with requirements to ensure it performed procedures to safeguard against unnecessary utilization of care and services for the Medicaid program. Questioned Costs: Assistance Listing # 93.775 93.7...

Finding: The Health Care Authority did not have adequate internal controls over and did not comply with requirements to ensure it performed procedures to safeguard against unnecessary utilization of care and services for the Medicaid program. Questioned Costs: Assistance Listing # 93.775 93.777 93.777 COVID-19 93.778 93.778 COVID-19 Status: Corrective action in progress Corrective Action: The Authority partially concurs with the finding. The Authority has received guidance from the Centers for Medicare & Medicaid Services (CMS) and will adjust the state plan based on CMS requirements. Per CMS guidance, this adjustment will not include separately listing the methods and procedures it uses to safeguard against unnecessary utilization of care and services. The Authority does not concur with the auditor?s conclusion regarding its statewide surveillance and utilization control program not meeting federal program integrity requirements. The Authority?s program meets CMS standards and requirements and provides reasonable oversight. The Authority will update its policies and procedures related to the program. The Authority concurs that the two providers of the Program of All-inclusive Care for the Elderly (PACE) were not monitored for their compliance with the False Claims Act (FCA) during the fiscal year. The Department of Social and Health Services (DSHS) manages the contracts for the PACE program, but payments to these providers are routed through the Authority?s ProviderOne system. The process for PACE provider monitoring has been clarified with DSHS who is responsible for providing FCA oversight for these contracts. The conditions noted in this finding were previously reported in findings 2021-050, 2020-047, 2020-048, 2019-052, 2019-053 and 2018-047. Completion Date: Estimated December 2023 Agency Contact: Kari Summerour, CPA External Audit Compliance Manager PO Box 45502 Olympia, WA 98504-5502 (360) 725-9586 Kari.Summerour@hca.wa.gov

View Audit 23129

Finding 19716 (2022-060)

Material Weakness 2022

State of Washington C/o Office of Financial Management

WA

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

Finding: The Health Care Authority did not have adequate internal controls over and did not comply with requirements to ensure it periodically audited cost report data for rate setting, hospital billings, and other financial and statistical records for inpatient hospital services. Questioned Cost...

Finding: The Health Care Authority did not have adequate internal controls over and did not comply with requirements to ensure it periodically audited cost report data for rate setting, hospital billings, and other financial and statistical records for inpatient hospital services. Questioned Costs: Assistance Listing # 93.775 93.777 93.777 COVID-19 93.778 93.778 COVID-19 Status: Corrective action in progress Corrective Action: The Authority partially concurs with the finding. The Authority does not agree it did not comply with federal requirements related to audits of inpatient hospitals. The Authority performs the following procedures: Cost report data for rate setting: ? Audits Medicaid cost report schedules and supporting documentation used for the Certified Public Expenditure Program. ? Audits critical access hospital data and uses final audited Medicare cost reports for settlement. ? Reviews and audits hospital cost reports using the ratio of costs-to-charges payment method. Hospital billings: ? Annual audits of hospital billings. Other financial and statistical records: ? Audits disproportionate share hospital reimbursements. The Authority concurs that documentation of the different hospital audits performed could be more clearly defined and will formalize procedures related to the conduct of the required audits. The conditions noted in this finding were previously reported in findings 2021-051 and 2020-049. Completion Date: Estimated December 2023 Agency Contact: Kari Summerour, CPA External Audit Compliance Manager PO Box 45502 Olympia, WA 98504-5502 (360) 725-9586 Kari.Summerour@hca.wa.gov

View Audit 23129

Finding 19715 (2022-059)

Material Weakness 2022

State of Washington C/o Office of Financial Management

WA

Subrecipient Monitoring Procurement, Suspension & Debarment Allowable Costs / Cost Principles

Finding: The Department of Social and Health Services did not have adequate internal controls over and did not comply with federal provider eligibility requirements for the Medicaid Program. Questioned Costs: Assistance Listing # 93.775 93.777 93.777 COVID-19 93.778 93.778 COVID-19 Amount $0...

Finding: The Department of Social and Health Services did not have adequate internal controls over and did not comply with federal provider eligibility requirements for the Medicaid Program. Questioned Costs: Assistance Listing # 93.775 93.777 93.777 COVID-19 93.778 93.778 COVID-19 Amount $0 Status: Corrective action complete Corrective Action: The Department concurs with the finding. As of June 2022, individual providers are no longer contracted through the Department and now contract with Consumer Direct of Washington. As a result of this change, this type of error will not occur for individual providers moving forward. As of March 2023, the Department reviewed all providers in the monthly exclusion report. The Department verified that the provider identified in the finding for missing enrollment documentation was never employed and did not receive any payments. Completion Date: March 2023 Agency Contact: Richard Meyer External Audit Compliance Manager PO Box 45804 Olympia, WA 98504-5804 (360) 664-6027 Richard.Meyer@dshs.wa.gov

View Audit 23129

Finding 19714 (2022-058)

Material Weakness 2022

State of Washington C/o Office of Financial Management

WA

Subrecipient Monitoring Special Tests & Provisions Procurement, Suspension & Debarment

Finding: The Department of Social and Health Services did not have adequate internal controls over False Claims Act requirements. Questioned Costs: Assistance Listing # 93.775 93.777 93.777 COVID-19 93.778 93.778 COVID-19 Amount $0 Status: Corrective action in progress Corrective Action:...

Finding: The Department of Social and Health Services did not have adequate internal controls over False Claims Act requirements. Questioned Costs: Assistance Listing # 93.775 93.777 93.777 COVID-19 93.778 93.778 COVID-19 Amount $0 Status: Corrective action in progress Corrective Action: The Department concurs with the finding. As of April 2023, the Department: ? Generated and tested a new internal report that will include all Aging and Long-Term Support Administration and Developmental Disabilities Administration Medicaid providers. ? Mailed correspondence to the one provider who was missing documentation to request the False Claims Act (FCA) attestation, policy, and procedures. ? Updated process to include follow up with providers monthly until the FCA attestations and other documents are received. By October 2023, the Department will ensure all outstanding FCA attestations and documents are returned to ensure compliance with the FCA requirement. Completion Date: Estimated October 2023 Agency Contact: Richard Meyer External Audit Compliance Manager PO Box 45804 Olympia, WA 98504-5804 (360) 664-6027 Richard.Meyer@dshs.wa.gov

View Audit 23129

Finding 19713 (2022-057)

Material Weakness 2022

State of Washington C/o Office of Financial Management

WA

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

Finding: The Department of Social and Health Services? Aging and Long-Term Support Administration did not have adequate internal controls over and did not comply with requirements to ensure timely investigation of complaints of client abuse and neglect at Medicaid residential facilities. Questio...

Finding: The Department of Social and Health Services? Aging and Long-Term Support Administration did not have adequate internal controls over and did not comply with requirements to ensure timely investigation of complaints of client abuse and neglect at Medicaid residential facilities. Questioned Costs: Assistance Listing # 93.775 93.777 93.777 COVID-19 93.778 93.778 COVID-19 Amount $0 Status: Corrective action in progress Corrective Action: The Department partially agrees with the finding. The Department agrees that not all complaint investigations were initiated within the required timeframes. However, the Department does not agree that noncompliance was due to inadequate internal controls. Residential Care Services (RCS) has effectively used current internal controls since fiscal year 2017 when we received the State Auditor?s Office Stewardship Award related to this audit area. Compliance with required complaint investigation timeframes decreased due to an increase in complaints from the previous fiscal year that were assigned for investigation. In addition, the effects of the COVID-19 pandemic increased staff vacancy rates to 24% due to exposure, illness, and staff resignation caused by vaccination mandates. By December 2023, the Department will: ? Extend the contract with Health Care Management Solutions to assist with surveys. This will allow RCS staff to return the focus to complaint investigations, complaint backlog, and compliance with required investigation timeframes. ? Condense and streamline Nursing Home Surveyor Training to enable staff to complete survey training faster than previous timeframes. ? Provide training to staff that were recently hired to fill the vacant positions to ensure compliance with investigation timeframes. The conditions noted in this finding were previously reported in finding 2021-054. Completion Date: Estimated December 2023 Agency Contact: Richard Meyer External Audit Compliance Manager PO Box 45804 Olympia, WA 98504-5804 (360) 664-6027 Richard.Meyer@dshs.wa.gov

View Audit 23129

Finding 19712 (2022-056)

Material Weakness 2022

State of Washington C/o Office of Financial Management

WA

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles

Finding: The Department of Social and Health Services, Developmental Disabilities Administration, did not have adequate internal controls over and did not comply with requirements to ensure Medicaid payments to supported living providers were allowable and adequately supported. Questioned Costs:...

Finding: The Department of Social and Health Services, Developmental Disabilities Administration, did not have adequate internal controls over and did not comply with requirements to ensure Medicaid payments to supported living providers were allowable and adequately supported. Questioned Costs: Assistance Listing # 93.775 93.777 93.777 COVID-19 93.778 93.778 COVID-19 Amount $237,404,150 Status: Corrective action not taken Corrective Action: The Department does not concur with the finding. The Department performed payment reconciliations, cost report reviews, and settlement assessments for all 140 cost reports received during the first half of fiscal year 2022 (July 1, 2021, through December 31, 2021). Of the cost reports received, 66 providers (47 percent) were subject to the Developmental Disabilities Administration (DDA) payroll verification review. The State Auditor?s Office (SAO) did not question any of the costs that were associated with the 66 providers. However, SAO is questioning all payments made to the 74 providers who did not receive a payroll verification review in the first half of the fiscal year. For the second half of the fiscal year (January 1, 2022, through June 30, 2022), even though the Department had the same internal controls in place, SAO asserted that every payment during this time frame was a questioned cost because the cost reports for calendar year 2022 had not yet been submitted for department review. The Department strongly disagrees that all these costs should be questioned. The Department reconciles payments on a calendar year basis, while SAO audits on a fiscal year basis and does not consider activities that fall outside of the audit period. The Developmental Disabilities Administration has numerous internal controls in place which provide sufficient assurance that the services paid for were provided. These include: ? Medicaid service verifications, ? Allowable costs payment reconciliations, ? Payroll verification processes, ? Review of rate payments and increases, ? Quality assurance reviews, ? Duplicate payment reports, ? Residential Care Services certification processes, ? Contract monitoring, ? Reconciliation processes for rates, cost reports, and settlements, ? Segregation of duties and other verification and approval processes. The Department strongly believes that its current oversight and monitoring procedures adequately confirm that services received by clients meet the certification standards for supported living providers. The Department continues its efforts to bring quality services to clients who receive habilitative residential support while following all program requirements, including reconciling the settlement amounts that were issued to providers in the cost report settlement process. Based on the information provided above, the Department maintains that the questioned costs for this audit finding are not substantiated. Unfortunately, SAO did not choose a more collaborative approach aimed at supporting the Department in its continuing quality improvement efforts. The Department continues to adjust its processes openly and appropriately as needed and remains open to partnering with SAO to resolve disagreements in this audit area and find common ground. The Department intends to send a request to the Centers for Medicare & Medicaid Services, through the audit resolution process, requesting the questioned costs reported by the SAO be rescinded. The conditions noted in this finding were previously reported in findings 2021-049, 2020-051, 2019-054, 2018-058, 2017-044, 2016-041, 2016-045, 2015-049, 2015-052, 2014-041, 2014-042, 2013-036, 2013-038 and 2012-039. The auditors determined findings 2016-041, 2015-052, 2014-041 and 2013-038 were resolved in fiscal year 2018. Completion Date: Not applicable Agency Contact: Richard Meyer External Audit Compliance Manager PO Box 45804 Olympia, WA 98504-5804 (360) 664-6027 Richard.Meyer@dshs.wa.gov

View Audit 23129 Questioned Costs: $1

Finding 19652 (2022-045)

Material Weakness 2022

State of Washington C/o Office of Financial Management

WA

Questioned Costs Subrecipient Monitoring Reporting

Finding: The Department of Children, Youth, and Families did not have adequate internal controls over and did not comply with health and safety requirements for the Child Care and Development Fund program. Questioned Costs: Assistance Listing # 93.575 93.575 COVID-19 93.596 Amount $412 Sta...

Finding: The Department of Children, Youth, and Families did not have adequate internal controls over and did not comply with health and safety requirements for the Child Care and Development Fund program. Questioned Costs: Assistance Listing # 93.575 93.575 COVID-19 93.596 Amount $412 Status: Corrective action in progress Corrective Action: The Department is strongly committed to ensuring the health, safety, and well-being of all children in care. The Department concurs with the finding and has taken the following actions: ? In September 2020, in response to the COVID-19 pandemic, the Department obtained grantor?s approval to revise the Child Care and Development Fund (CCDF) State Plan to waive the annual unannounced monitoring requirement and allowing for virtual monitoring, through September 30, 2021, but some providers were unable to participate in the virtual process resulting in monitoring visits not being conducted during state fiscal year 2022. ? In the fall of 2022, to address staff turnover issues, the Department began recruiting new staff and providing training on child care licensing rules and regulations. This included adding a new position in November 2022 to assist supervisors with onboarding and training new staff hired during the audit period. ? The Department implemented a data driven, phased in approach, to return staff to in-person field work after the COVID-19 pandemic: o In July 2022, began authorizing staff, subject to pandemic related restrictions, to visit providers on-site to provide assistance with meeting health and safety requirements. o In the spring of 2023, prioritized monitoring visits to return to compliance with CCDF health and safety requirements. ? Established an overpayment for the questioned costs and referred to the Office of Financial Recovery for collection. ? For license-exempt family, friend, and neighbor (FFN) providers, the Department: o Requested approval from the Office of Child Care for a hybrid monitoring approach (in-person and virtual visits). o Dedicated staff resources to update WA Compass to include all health and safety requirements for FFNs and address data format issues. The Department will continue to strengthen internal controls as follows: For licensed providers: ? Continue to implement return to in-person field work by reducing pandemic level requirements. ? Prioritize new staff training to first focus on monitoring visits and health and safety requirements. ? Continue to track and monitor health and safety requirements with available tools until all WA Compass system development is completed. ? Create an in-training licensing position to assist staff recruitment efforts and add additional lead worker positions to assist supervisors with training and caseload management. ? Conduct a root cause analysis to determine other underlying causes for missed monitoring visits and untimely follow-ups, and how to address them. ? Examine ways to secure resources to add additional full-time staff to support caseload needs. For FFN providers: ? Continue to track and monitor FFN health and safety requirements with available tools until all WA Compass system development is completed. The conditions noted in this finding were previously reported in findings 2021-039, 2020-042, 2019-039, 2018-035, 2017-025, 2016-022 and 2015-024. Completion Date: Estimated July 2024 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 19651 (2022-044)

Material Weakness 2022

State of Washington C/o Office of Financial Management

WA

Subrecipient Monitoring Matching / Level of Effort / Earmarking Allowable Costs / Cost Principles

Finding: The Department of Children, Youth, and Families did not have adequate internal controls over and did not comply with financial reporting requirements for the Child Care and Development Fund Cluster. Questioned Costs: Assistance Listing # 93.575 93.575 COVID-19 93.596 Status: Correc...

Finding: The Department of Children, Youth, and Families did not have adequate internal controls over and did not comply with financial reporting requirements for the Child Care and Development Fund Cluster. Questioned Costs: Assistance Listing # 93.575 93.575 COVID-19 93.596 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. The Department implemented grant-level management of all federal funds, including the CCDF grant. The Department allocated the CCDF 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. Given that eligibility or cost allocation has not been an area of concern, and transfers were processed between CCDF source of funds with the same eligibility criteria, the Department is assured that CCDF 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. The conditions noted in this finding were previously reported in finding 2021-038. Completion Date: Agency Contact: 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

Finding 19650 (2022-043)

Material Weakness 2022

State of Washington C/o Office of Financial Management

WA

Matching / Level of Effort / Earmarking Subrecipient Monitoring Allowable Costs / Cost Principles

Finding: The Department of Children, Youth, and Families did not have adequate internal controls over and did not comply with period of performance requirements for the Child Care and Development Fund. Questioned Costs: Assistance Listing # 93.575 93.575 COVID-19 93.596 Amount $0 Status: C...

Finding: The Department of Children, Youth, and Families did not have adequate internal controls over and did not comply with period of performance requirements for the Child Care and Development Fund. Questioned Costs: Assistance Listing # 93.575 93.575 COVID-19 93.596 Amount $0 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. The Department implemented grant-level management of all federal funds, including the CCDF grant. The Department allocated the CCDF 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. Given that eligibility or cost allocation has not been an area of concern, and transfers were processed between CCDF source of funds with the same eligibility criteria, the Department is assured that CCDF 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. The conditions noted in this finding were previously reported in finding 2021-037 and 2020-041. Completion Date: Estimated December 2024 Agency Contact: Stefanie Niemela Audit Liaison PO Box 40970 Olympia, WA 98504-0970 (360) 725-4402 stefanie.niemela@dcyf.wa.gov

View Audit 23129

Finding 19649 (2022-042)

Material Weakness 2022

State of Washington C/o Office of Financial Management

WA

Matching / Level of Effort / Earmarking Subrecipient Monitoring Allowable Costs / Cost Principles

Finding: The Department of Children, Youth, and Families did not have adequate internal controls over and did not comply with matching, level of effort, and earmarking requirements for the Child Care and Development Fund Cluster. Questioned Costs: Assistance Listing # 93.575 93.575 COVID-19 9...

Finding: The Department of Children, Youth, and Families did not have adequate internal controls over and did not comply with matching, level of effort, and earmarking requirements for the Child Care and Development Fund Cluster. Questioned Costs: Assistance Listing # 93.575 93.575 COVID-19 93.596 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. The Department implemented grant-level management of all federal funds, including the CCDF grant. The Department allocated the CCDF 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. Given that eligibility or cost allocation has not been an area of concern, and transfers were processed between CCDF source of funds with the same eligibility criteria, the Department is assured that CCDF 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. The conditions noted in this finding were previously reported in findings 2021-036 and 2020-040. Completion Date: Estimated December 2024 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 19648 (2022-041)

Material Weakness 2022

State of Washington C/o Office of Financial Management

WA

Questioned Costs Matching / Level of Effort / Earmarking Subrecipient Monitoring

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 for the Child Care and Development Fund Cluster programs 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 for the Child Care and Development Fund Cluster programs were allowable and properly supported. Questioned Costs: Assistance Listing # 93.575 93.575 COVID-19 93.596 Amount $260,552,979 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. The Department implemented grant-level management of all federal funds, including the CCDF grant. The Department allocated the CCDF 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. Given that eligibility or cost allocation has not been an area of concern, and transfers were processed between CCDF source of funds with the same eligibility criteria, the Department is assured that CCDF 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. The conditions noted in this finding were previously reported in findings 2021-033, 2020-038, 2019-035, 2018-034, 2017-024, 2016-021, 2015-023, 2014-023, 2013-016, 12-28, 11-23, 10-31, 9-12 and 8-13. Completion Date: Estimated December 2024 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 19633 (2022-025)

Material Weakness 2022

State of Washington C/o Office of Financial Management

WA

Questioned Costs Allowable Costs / Cost Principles Subrecipient Monitoring

Finding: The Office of Superintendent of Public Instruction did not have adequate controls over and did not comply with requirements to ensure it met the earmarking requirements for the Special Education program. Questioned Costs: Assistance Listing # 84.027 84.027 COVID-19 84.173 Amount $18...

Finding: The Office of Superintendent of Public Instruction did not have adequate controls over and did not comply with requirements to ensure it met the earmarking requirements for the Special Education program. Questioned Costs: Assistance Listing # 84.027 84.027 COVID-19 84.173 Amount $188,873 Status: Corrective action complete Corrective Action: When the Special Education program underwent a fiscal leadership transition in 2021, the incoming director identified necessary changes in agency procedures for closing out the fiscal year for the program. Since that time, the Office has fully implemented internal controls to ensure spending plans do not exceed the maximum allowable amounts earmarked for administration and other state-level activities. The updated procedures require the director of Operations and the budget analyst to perform the following: ? Review criteria for spending plans at the beginning of the fiscal year. ? Review the Grant Award Notice and Grants to States Summary Table and Preschool Grants to States Summary Table. ? Review spending plans and update the maximum allowable amounts earmarked for administration and other state-level activities in the spending plan throughout the fiscal year. ? Meet weekly to review spending plans and update plans as requests are received. ? Review monthly expenditure reports during weekly meetings. These updated procedures have contributed to increased communication and partnership between the director of Operations and the budget analyst. These internal controls provide assurance that maximum allowable amounts earmarked for administration and other state-level activities will be in compliance with federal rules. The Office will consult with the federal grantor to discuss whether the questioned costs identified in the audit should be repaid. Completion Date: March 2023 Agency Contact: Tania May Assistant Superintendent, Special Education PO Box 47200 Olympia, WA 98504-7200 (360) 725-6075 tania.may@k12.wa.us

View Audit 23129 Questioned Costs: $1

Finding 19624 (2022-007)

Material Weakness 2022

State of Washington C/o Office of Financial Management

WA

Subrecipient Monitoring Reporting Internal Control / Segregation of Duties § 200.303 § 200.328

Finding: The Employment Security Department did not have adequate internal controls over and did not comply with requirements to ensure it submitted complete and accurate quarterly performance reports for the Workforce Innovation and Opportunity grant. Questioned Costs: Assistance Listing # ...

Finding: The Employment Security Department did not have adequate internal controls over and did not comply with requirements to ensure it submitted complete and accurate quarterly performance reports for the Workforce Innovation and Opportunity grant. Questioned Costs: Assistance Listing # 17.258 17.259 17.278 Amount $0 Status: Corrective action in progress Corrective Action: In response to the finding, the Department is in the process of developing a comprehensive system and set of protocols to strengthen internal controls over the completion and submission of quarterly performance reports for the Workforce Innovation and Opportunity Act (WIOA) grant. The Department: ? Executed a Workforce Integrated Technology Replacement Project that focuses on improving case management and data management internal controls. The Department estimates the project will be completed by December 2024. ? Initiated and is in the process of a statewide implementation of the U.S. Department of Labor (DOL) Quarterly Report Analysis data integrity and data quality internal controls system. The Department will: ? Continue to execute the Data Element Validation policy update for the Participant Individual Record Layout (PIRL) report per DOL expectations. ? Continue to provide technical assistance, training, and one-on-one coaching for the local areas, which cover WIOA Title I and WIOA Title III, PIRL reporting, data management, validation, quality, and integrity systems and processes. The conditions noted in this finding were previously reported in findings 2021-007 and 2020-012. Completion Date: Estimated December 2024 Agency Contact: Jay Summers External Audit Manager PO Box 9046 Olympia, WA 98507-9046 (360) 529-6718 Joshua.Summers@esd.wa.gov

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Finding 19617 (2022-003)

Significant Deficiency 2022

State of Washington C/o Office of Financial Management

WA

School Nutrition Programs Subrecipient Monitoring Equipment & Real Property Management

Finding: The Office of Superintendent of Public Instruction did not have adequate internal controls over accountability for USDA-donated foods. Questioned Costs: Assistance Listing # 10.553 10.555 10.555 COVID-19 10.556 10.559 10.582 Amount $0 Status: Corrective action in progress Correc...

Finding: The Office of Superintendent of Public Instruction did not have adequate internal controls over accountability for USDA-donated foods. Questioned Costs: Assistance Listing # 10.553 10.555 10.555 COVID-19 10.556 10.559 10.582 Amount $0 Status: Corrective action in progress Corrective Action: The Office has taken the following corrective action to strengthen internal controls over accounting for USDA-donated foods: ? Reviewed current process for monthly inventory. ? Reviewed process for inventory discrepancies follow up. ? Implemented a process for documenting follow-up efforts. The Office is following the USDA requirements for conducting annual inventory and reconciliation in June of each year. In addition, the Office has contracted with a vendor for a new and updated Food Distribution Management System. The current timeline for system launch is as follows: ? November 2023 ? Data migration and system set up ? February 2024 ? Survey period ? August 2024 ? Ordering of food, receiving, and inventory management The conditions noted in this finding were previously reported in findings 2021-003, 2020-004 and 2019-005. Completion Date: Estimated July 2023 Agency Contact: Leanne Eko Chief Nutrition Officer PO Box 47200 Olympia, WA 98504-7200 (360) 725-0410 leanne.eko@k12.wa.us

View Audit 23129

Finding 19554 (2022-022)

None 2022

State of Washington C/o Office of Financial Management

WA

Questioned Costs Student Financial Aid Allowable Costs / Cost Principles § 200.1 § 200.410 § 200.516

Finding: Washington State University did not ensure that returns of Title IV funds were accurate for the Student Financial Assistance programs. Questioned Costs: Assistance Listing # 84.007 84.033 84.038 84.063 84.268 84.379 Amount $2,582 Status: Corrective action complete Corrective Act...

Finding: Washington State University did not ensure that returns of Title IV funds were accurate for the Student Financial Assistance programs. Questioned Costs: Assistance Listing # 84.007 84.033 84.038 84.063 84.268 84.379 Amount $2,582 Status: Corrective action complete Corrective Action: The University has improved processes for the return of Title IV funds. The University: ? Included a standard calculation in workbooks to quickly identify whether amounts to be returned for withdrawn students will exceed the amounts disbursed. ? Implemented a quality check to review these exceptions, and to investigate and correct as necessary. The University has returned all questioned costs to the sponsors. Completion Date: May 2023 Agency Contact: Heather Lopez Chief Audit Executive PO Box 641221 Pullman, WA 99164-1221 (509) 335-2001 hlopez@wsu.edu

View Audit 23129 Questioned Costs: $1

Corrective Action Plans

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