Corrective Action Plans

Finding 1208575 (2024-004)

Material Weakness 2024

Calhoun, Greene, Jersey, and Macoupin Counties Regional Office of Education No. 40

IL

Allowable Costs / Cost Principles

The ROE will use time and effort documentation to distribute salary and benefit costs for all employees. The ROE will implement the necessary controls over payroll to ensure that payroll is being properly prepared and calculated.

View Audit 399505

Finding 1208377 (2024-015)

Material Weakness 2024

City of Danbury

CT

Subrecipient Monitoring Allowable Costs / Cost Principles Material Weakness

Finding 2024-015 Material Weakness in Internal Control and Material Noncompliance – Reporting Condition: For the Education Stabilization Fund- Elementary and Secondary School Emergency Relief (84.425D), American Rescue Plan Elementary and Secondary School Emergency Relief (84.425U), the City provide...

Finding 2024-015 Material Weakness in Internal Control and Material Noncompliance – Reporting Condition: For the Education Stabilization Fund- Elementary and Secondary School Emergency Relief (84.425D), American Rescue Plan Elementary and Secondary School Emergency Relief (84.425U), the City provided supporting documentation that was unable to be agreed to the amounts that were submitted to the State in the annual performance report ESF - ESSER Recipient Data Collection Form OMB PRA Number: OMB No. 1810-0749 for the key line items: Line 3.b1 LEA expenditures by ESSER Subgrant fund, expenditure category, and object code, Line 3.b10 Number of specific positions supported with ESSER Funds, 3. Line 3.c Allocation of ESSER funds to schools and criteria used to allocate funds to schools, and Line 5.a Full Time Equivalent positions. Contact Person: Michael Weaver, CFO, Danbury Public Schools Corrective Actions Planned: We agree with the finding. The District acknowledges that a formal reconciliation process did not exist at the time of submission to verify that data entered into the annual ESF-ESSER Recipient Data Collection Form (OMB No. 1810-0749) was agreed to underlying financial records and supporting documentation prior to submission to the State. The District will proactively strengthen internal controls over federal reporting by implementing a formal reconciliation policy and establishing designated review prior to submission. Completion Date: 6/30/2025

View Audit 399363

Finding 1208308 (2024-008)

Material Weakness 2024

Bertie County

NC

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

Name of Contact Person: Willie Mack Carawan, Jr., Finance Director Corrective Action/Management's Response: This finding is primarily the result of turnover/ transition/ reporting access of key personnel. Management is working with staff member to establish contact with reporting agencies and to gai...

Name of Contact Person: Willie Mack Carawan, Jr., Finance Director Corrective Action/Management's Response: This finding is primarily the result of turnover/ transition/ reporting access of key personnel. Management is working with staff member to establish contact with reporting agencies and to gain the necessary access for reporting purposes, as well as reporting requirements. Proposed Completion Date: As soon as the discrepancy was identified by the auditor, management began working with staff to list their points of contact in the likelihood they are not available to meet reporting requirements for the year ending June 30, 2024.

View Audit 399334

Finding 1208242 (2024-004)

Material Weakness 2024

Wateree Community Actions, Inc.

SC

Allowable Costs / Cost Principles Period of Performance

Management will implement procedures to identify and properly allocate prepaid and multi-period expenses across the applicable benefit periods. Prepaid expenses will be recorded and amortized over the service period in accordance with GAAP and federal cost principles.

View Audit 399214

Finding 1208174 (2024-004)

Material Weakness 2024

College for Social Innovation

MA

Allowable Costs / Cost Principles Internal Control / Segregation of Duties

Person Responsible for Corrective Action: Edward S. Churchill Jr., Chief Operating Officer Corrective Action Plan: College for Social Innovation’s inability to properly retain documentation relating to the noted selection was due in large part to rapid staff turnover at the senior level and an inabi...

Person Responsible for Corrective Action: Edward S. Churchill Jr., Chief Operating Officer Corrective Action Plan: College for Social Innovation’s inability to properly retain documentation relating to the noted selection was due in large part to rapid staff turnover at the senior level and an inability to access records from previous employees. Following the 2024 grant year, College for Social Innovation made updates to our accounting manual and segregation of duties protocols to ensure redundancy in the event of staff turnover. Additionally, College for Social Innovation has instituted new document storage and record keeping practices including the use of Google Drive and DropBox to securely store critical records and ensure access by relevant financial staff. At all times, at least two current staff members maintain access to record keeping digital drives and folders to ensure access redundancy. These policies and practices were first implemented in the beginning of the 2026 fiscal year and remain ongoing. Anticipated Completion Date: 7/1/2025

View Audit 399023

Finding 1208173 (2024-003)

Material Weakness 2024

College for Social Innovation

MA

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

Person Responsible for Corrective Action: Edward S. Churchill Jr., Chief Operating Officer Corrective Action Plan: Following the 2024 grant year, College for Social Innovation made updates to our internal controls procedures to ensure greater oversight of financial calculation and appropriate segreg...

Person Responsible for Corrective Action: Edward S. Churchill Jr., Chief Operating Officer Corrective Action Plan: Following the 2024 grant year, College for Social Innovation made updates to our internal controls procedures to ensure greater oversight of financial calculation and appropriate segregation of duties. These updates include additional steps for review and approval of drawdown submissions, training for supervisory staff, and procedures for updating controls procedures as our staff grows and changes. These updates were completed as part of our Corrective Action Plan administered through AmeriCorps’ Office of Monitoring and confirmed as resolved in a notice dated 11/25/2025 [Re: Notification of Corrective Action Plan Closed – 23NDFMA002]. In considering the recommendations provided in this report, College for Social Innovation will further amend our internal controls procedures to include an additional layer of review, reconciliation, and approval of staff time and salary calculations related to AmeriCorps grant activities. In addition to the existing process of compilation by the Chief Operating Officer and review and approval by the Chief Executive Officer, staff time and salary calculations will now also be conducted by the Director of People Operations independently. This secondary calculation will be used for review and reconciliation by the Chief Operating Officer and Director of People Operations to ensure alignment and compliance to AmeriCorps and general accounting standards. Anticipated Completion Date: 2/23/26

View Audit 399023

Finding 1208172 (2024-002)

Material Weakness 2024

College for Social Innovation

MA

Procurement, Suspension & Debarment Allowable Costs / Cost Principles Reporting

Person Responsible for Corrective Action: Edward S. Churchill Jr., Chief Operating Officer Corrective Action Plan: College for Social Innovation’s corrective action plan to ensure timely preparedness for auditing is twofold. First, we are developing a new “Financial Command Center” tool to allow gre...

Person Responsible for Corrective Action: Edward S. Churchill Jr., Chief Operating Officer Corrective Action Plan: College for Social Innovation’s corrective action plan to ensure timely preparedness for auditing is twofold. First, we are developing a new “Financial Command Center” tool to allow greater speed, accuracy, and regularity in tracking account balances and transactions. This new tool better consolidates our tracking processes and allows for regular reconciliations across tracking platforms including Expensify, QuickBooks, Excel, and BambooHR. Second, College for Social Innovation is currently seeking the support services of a Certified Public Accountant. As of February 2, 2026, we have identified a list of potential candidates, are developing a formal request for proposals, and expect to enter a contracted agreement in early March of 2026. This new supporting role will assist in ensuring that our accounting practices fully align with accounting principles generally accepted in the United States. Anticipated Completion Date: 3/30/2026

View Audit 399023

Finding 1207094 (2024-048)

Material Weakness 2024

State of Illinois

IL

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

Finding Number: 2024-048 Finding Name: Inadequate Review of Cash Draw Calculations Finding Condition(s): The Illinois Criminal Justice Information Authority (ICJIA) did not adequately document its review of cash draw calculations for the Crime Victim Assistance (CVA) program. Name of Contact Person(...

Finding Number: 2024-048 Finding Name: Inadequate Review of Cash Draw Calculations Finding Condition(s): The Illinois Criminal Justice Information Authority (ICJIA) did not adequately document its review of cash draw calculations for the Crime Victim Assistance (CVA) program. Name of Contact Person(s): • Hemant Modi, Chief Fiscal Officer – Illinois Criminal Justice Information Authority, Office of Fiscal Management • Precious Taylor, Accounting Supervisor – Illinois Criminal Justice Information Authority, Office of Fiscal Management Corrective Action(s): ICJIA re-implemented reviews and approvals of its cash draw calculations in fiscal year 2025. Proposed Completion Date: October 22, 2024 – Completed

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Finding 1207038 (2024-023)

Material Weakness 2024

State of Illinois

IL

Allowable Costs / Cost Principles § 200.303 § 200.403 § 200.430

Finding Number: 2024-023 Finding Name: Failure to Provide Supporting Documentation for Payroll and Related Costs Finding Condition(s): The Illinois Department of Child and Family Services (DCFS) could not provide adequate supporting documentation to substantiate payroll and related costs claimed for...

Finding Number: 2024-023 Finding Name: Failure to Provide Supporting Documentation for Payroll and Related Costs Finding Condition(s): The Illinois Department of Child and Family Services (DCFS) could not provide adequate supporting documentation to substantiate payroll and related costs claimed for federal reimbursement under the Foster Care – Title IV-E (Foster Care), Adoption Assistance, and Temporary Assistance for Needy Families (TANF) programs. Additionally, the auditors noted the controls to ensure required documentation is obtained to support payroll and related costs and maintained to evidence management approval of payroll information were not operating effectively. Finally, the auditors noted adequate internal controls have not been established to ensure the data included in the timekeeping system and used to allocate personal services expenditures to Foster Care, Adoption Assistance, TANF, and other programs operated by DCFS is consistent with the hours reported on manual timesheets prepared by the employees and approved by supervisor. Name of Contact Person(s): David Riley, Director – Illinois Department of Child and Family Services, Budget and Finance Division Corrective Action(s): The new quality controls introduced have helped to identify and correct errors, but system modernization is needed to fully implement. The DCFS is working with the Illinois Department of Innovation and Technology to implement the systems to shift to electronic timesheets. Proposed Completion Date: October 31, 2026

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Finding 1207034 (2024-022)

Material Weakness 2024

State of Illinois

IL

Allowable Costs / Cost Principles § 200.303 § 200.403

Finding Number: 2024-022 Finding Name: Inadequate Process for Foster Care Daycare Maintenance Assistance Payments Finding Condition(s): The Illinois Department of Child and Family Services (DCFS) does not have an adequate process in place to ensure Foster Care daycare maintenance assistance payments...

Finding Number: 2024-022 Finding Name: Inadequate Process for Foster Care Daycare Maintenance Assistance Payments Finding Condition(s): The Illinois Department of Child and Family Services (DCFS) does not have an adequate process in place to ensure Foster Care daycare maintenance assistance payments are accurately paid based on its approved rate schedule. Name of Contact Person(s): Stacy Mixon, Daycare Eligibility Administrator – Illinois Department of Child and Family Services, Office of Contract Administration Corrective Action(s): In July 2025, the daycare eligibility program discontinued the use of certification rate forms. As a result, all childcare providers now receive the state established reimbursement rate, regardless of the rate they charge private-paying families. This change ensures that all childcare providers receive the funding that they are entitled to. Proposed Completion Date: July 1, 2025 – Completed

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Finding 1207028 (2024-020)

Material Weakness 2024

State of Illinois

IL

Allowable Costs / Cost Principles Special Tests & Provisions § 200.303

Finding Number: 2024-020 Finding Name: Inadequate Procedures to Determine Provider Eligibility Finding Condition(s): The Illinois Department of Healthcare and Family Services (DHFS) did not adequately screen providers of the Children’s Health Insurance Program (CHIP) and the Medicaid Cluster program...

Finding Number: 2024-020 Finding Name: Inadequate Procedures to Determine Provider Eligibility Finding Condition(s): The Illinois Department of Healthcare and Family Services (DHFS) did not adequately screen providers of the Children’s Health Insurance Program (CHIP) and the Medicaid Cluster programs to ensure that Medicaid providers were not on the USDHHS Office of the Inspector General’s (OIG) List of Excluded Individuals/Entities (LEIE) at the time the vouchers for the related services performed were paid. Name of Contact Person(s): Susie Brown, Interim Bureau Chief - Illinois Department of Healthcare and Family Services, Provider Enrollment Services Corrective Action(s): The Illinois Medicaid Program Advanced Cloud Technology (IMPACT) system is used by the DHFS for the enrollment and screening of CHIP and Medicaid providers. On a monthly basis, IMPACT automatically checks providers enrolled within IMPACT to the LEIE to verify the provider is not on the LEIE. The IMPACT system is updated through quarterly system releases. As part of the 1.6 quarterly release, the DHFS’ Provider Enrollment Services (PES) updated the system to address the monthly screening check box defect causing the issue. In the Lexis Nexis monthly job, as part of license information, the DHFS receives files from the American Board of Medical Specialties (ABMS), the Clinical Laboratory Improvement Amendments (CLIA), the Drug Enforcement Administration (DEA), and the NCPDP (National Council for Prescription Drug Programs (NCPDP) and other states (out-of-state license/medical license files). Only the corresponding license check boxes are checked for the provider. As an example, for a provider with an ABMS license, the corresponding ABMS check box would be checked. Furthermore, as part of sanction information, the DHFS receives a discipline file, which has the information from the Excluded Parties List System (EPLS), the LEIE, the Medicaid Services Administration (MSA), and other federal and state databases to ensure all databases are checked for active providers in a monthly batch. Any sanctions identified from the sources during the monthly batch screenings will be marked based on the corresponding data source where the sanction was found. If a sanction is found, the system generates an email to the OIG that the provider has been identified as having a potential sanction through the Medicaid Management Information System (MMIS) automated validation process. The email contains the provider name, the National Provider Identifier (NPI), the IMPACT provider identifier, the provider’s address, and the sanction type. The email instructs the OIG to verify the sanction and proceed with the appropriate administrative action. The OIG will provide the necessary administrative action to provider enrollment staff to handle appropriately. Proposed Completion Date: June 30, 2024 - Completed

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Finding 1207014 (2024-018)

Material Weakness 2024

State of Illinois

IL

Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.303 § 200.400

Finding Number: 2024-018 Finding Name: Improper Calculation of Qualified Incentive Payments Claimed under the Medicaid Cluster Finding Condition(s): The Illinois Department of Healthcare and Family Services (DHFS) incorrectly calculated qualified incentive payments charged to the Medicaid Cluster pr...

Finding Number: 2024-018 Finding Name: Improper Calculation of Qualified Incentive Payments Claimed under the Medicaid Cluster Finding Condition(s): The Illinois Department of Healthcare and Family Services (DHFS) incorrectly calculated qualified incentive payments charged to the Medicaid Cluster program using the enhanced federal medical assistance percentage (FMAP) rate applicable to payments under the Affordable Care Act (ACA) rather than its regular FMAP rate. Additionally, the auditors noted the supervisory review procedures related to the calculation of the qualified incentive payments were not designed to and did not operate at a level of precision to identify an error of this nature. Name of Contact Person(s): Rene Corso, Senior Public Service Administrator - Illinois Department of Healthcare and Family Services, Long Term Care (LTC) Rate Setting Unit Corrective Action(s): The LTC Rate Setting Unit has updated the spreadsheet for calculating the Quality Incentive Payment (QIP) to ensure the percentages for the ACA and the FMAP are distinguishable. Peer checking has also been implemented to ensure amounts are correct before processing Proposed Completion Date: April 16, 2025

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Finding 1207009 (2024-017)

Material Weakness 2024

State of Illinois

IL

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

Finding Number: 2024-017 Finding Name: Inadequate Procedures to Determine and Document Beneficiary Eligibility Finding Condition(s): The Illinois Department of Healthcare and Family Services (DHFS) does not have adequate procedures to determine and document eligibility for beneficiaries of the Child...

Finding Number: 2024-017 Finding Name: Inadequate Procedures to Determine and Document Beneficiary Eligibility Finding Condition(s): The Illinois Department of Healthcare and Family Services (DHFS) does not have adequate procedures to determine and document eligibility for beneficiaries of the Children’s Health Insurance Program (CHIP) and the Medicaid Cluster programs. Additionally, the auditors noted that the DHFS does not have adequate resources to perform and document eligibility determinations. Finally, the auditors noted that the DHFS has not established appropriate monitoring procedures to ensure eligibility determinations are properly documented in accordance with program requirements. Name of Contact Person(s): • Jacqueline Myers, Interim Deputy Administrator - Illinois Department of Healthcare and Family Services, Eligibility Data and Systems • Pam Winsel, Bureau Chief, Waiver Operations Management - Illinois Department of Healthcare and Family Services, Division of Medical Programs • Jeremy Thomas, Impact Technical Lead - Illinois Department of Healthcare and Family Services, Bureau of Technical Support Corrective Action(s): A report will be created to identify those enrolled in the waiver program, but not receiving full Medicaid that makes them ineligible for payment. This report will be run monthly and worked on manually until a system edit is implemented to reject claims when there is no match on full Medicaid coverage coding. Program staff at the waiver operating agencies will also be trained to assist them in identifying certain criteria that would exclude a waiver program enrollee from being eligible for payment. Rules have been modified (PIR #53483) to make sure eligibility in the RDB (Medicaid Management Information System (MMIS)) gets closed. In addition, a monthly report has been developed and is run monthly to identify any case with the eligibility closed in the IES, yet open in the Recipient Database (RDB). Cases shown on this report are worked to ensure both the Integrated Eligibility System (IES) and the RDB (MMIS) match. Proposed Completion Date: September 1, 2026

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Finding 1207002 (2024-016)

Material Weakness 2024

State of Illinois

IL

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

Finding Number: 2024-016 Finding Name: Failure to Discontinue CHIP Benefits for Ineligible Individuals Finding Condition(s): The Illinois Department of Healthcare and Family Services (DHFS) improperly continued providing benefits under the Children’s Health Insurance Program (CHIP) program to indivi...

Finding Number: 2024-016 Finding Name: Failure to Discontinue CHIP Benefits for Ineligible Individuals Finding Condition(s): The Illinois Department of Healthcare and Family Services (DHFS) improperly continued providing benefits under the Children’s Health Insurance Program (CHIP) program to individuals who were over the age of 18. In addition, the auditors noted that the DHFS has not established adequate controls to identify and remove individuals over the age of 18 from the CHIP program and to determine if they are eligible for benefits under the Medicaid Cluster program. Name of Contact Person(s): • Katherine A. Yager, Administrator, Illinois Department of Healthcare and Family Servies, Division of Eligibility • George Jacaway, Deputy Administrator - Illinois Department of Healthcare and Family Services, Eligibility Operations • Jacqueline Myers, Interim Deputy Administrator - Illinois Department of Healthcare and Family Services, Eligibility Data and Systems Corrective Action(s): Currently, the DHFS identifies and redetermines eligibility for this population each month. Each month, DHFS systemically identifies this population and provides a report to both DHFS and DHS to redetermine eligibility. Previously, this population was not being systematically identified. The amount of medical payments have decreased by 85% from fiscal year 2024 to 2025. A review of FY26 data indicates a continual decrease, currently at 93%. The DHFS will continue to identity and redetermine eligibility for this population group on a monthly basis. Proposed Completion Date: April 30, 2025 - Completed

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Finding 1206967 (2024-011)

Material Weakness 2024

State of Illinois

IL

Allowable Costs / Cost Principles § 200.303 § 200.403

Finding Number: 2024-011 Finding Name: Unallowable Costs Charged to the TANF and CCDF Cluster Programs Finding Condition(s): The Illinois Department of Human Services (IDHS) could not provide documentation to support payments made on behalf of beneficiaries of the Temporary Assistance for Needy Fami...

Finding Number: 2024-011 Finding Name: Unallowable Costs Charged to the TANF and CCDF Cluster Programs Finding Condition(s): The Illinois Department of Human Services (IDHS) could not provide documentation to support payments made on behalf of beneficiaries of the Temporary Assistance for Needy Families (TANF) and Child Care and Development Fund (CCDF) Cluster programs. Additionally, the auditors noted that the IDHS does not have adequate controls in place to ensure information provided by providers is accurate and the related child care payments made were appropriate. Name of Contact Person(s): Maureen Bilek, Audit Compliance and Programmatic Monitoring Administrator – Illinois Department of Human Services, Division of Early Childhood (DEC) Corrective Action(s): The IDHS will (1) develop and implement internal procedures to conduct quarterly reviews of billing certificates for payments entered through the Interactive Voice Response (IVR) system, (2) assess existing deliverables, its Child Care Assistance Program (CCAP) policy and its CCDF State Plan responses related to IVR payments and determine and implement any necessary revisions, (3) develop external guidance for providers and Child Care Resource & Referral (CCR&R) agencies outlining IVR payment requirements, documentation standards, record-retention expectations, and the review process, (4) initiate and continue implementation of a communication plan to announce upcoming reviews, including the Service Employees International Union (SEIU), the Division of Early Childhood (DEC), CCR&Rs, and all providers utilizing IVR (additional communications will be issued as the process is refined), (5) commence IVR payment reviews in June 2026 and continue on a quarterly basis, and (6) Establish and maintain a master tracking log of provider reviews by year, subject to management review and oversight. Proposed Completion Date: June 30, 2026

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Finding 1206962 (2024-010)

Material Weakness 2024

State of Illinois

IL

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

Finding Number: 2024-010 Finding Name: Improper TANF Beneficiary Payments Finding Condition(s): The Illinois Department of Human Services (IDHS) made improper payments to beneficiaries of the Temporary Assistance for Needy Families (TANF) program. In addition, the IDHS identified a system error in J...

Finding Number: 2024-010 Finding Name: Improper TANF Beneficiary Payments Finding Condition(s): The Illinois Department of Human Services (IDHS) made improper payments to beneficiaries of the Temporary Assistance for Needy Families (TANF) program. In addition, the IDHS identified a system error in June 2025 impacting beneficiaries whose benefit payments were calculated using diverted income. Finally, the IDHS did not establish control procedures at an adequate level of precision to ensure TANF program benefits were accurately calculated based on the beneficiary’s case file supporting documentation. Name of Contact Person(s): Kasey Reagan, Interim Director – Illinois Department of Human Services, Division of Family and Community Services Corrective Action(s): The IDHS has submitted a repair ticket to repair the system it uses to calculate its diverted income. Additionally, the cases affected by the diverted income error are being reviewed and referend to the Bureau of Collections for overpayment, as needed. The cases with incorrect beneficiary payments, outside of the diverted income errors, have been corrected and overpayment/supplements have been completed. Finally, the IDHS will require its TANF managers to conduct a monthly review of TANF cases to include all components of the cases. Proposed Completion Date: June 30, 2026

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Finding 1206960 (2024-009)

Material Weakness 2024

State of Illinois

IL

Eligibility Matching / Level of Effort / Earmarking Special Tests & Provisions § 200.303

Finding Number: 2024-009 Finding Name: Missing Documentation in Beneficiary Files Finding Condition(s): The Illinois Department of Human Services (IDHS) could not locate case file documentation supporting certain eligibility and special test requirements for beneficiaries of the Temporary Assistance...

Finding Number: 2024-009 Finding Name: Missing Documentation in Beneficiary Files Finding Condition(s): The Illinois Department of Human Services (IDHS) could not locate case file documentation supporting certain eligibility and special test requirements for beneficiaries of the Temporary Assistance for Needy Families (TANF) program. Also, the auditors noted that the IDHS does not have adequate resources to perform and document eligibility determinations. Additionally, the auditors noted that the IDHS has not established appropriate monitoring procedures to ensure eligibility determinations are properly documented in accordance with program requirements. Name of Contact Person(s): Kasey Reagan, Interim Director – Illinois Department of Human Services, Division of Family and Community Services (FCS) Corrective Action(s): The IDHS’ TANF Managers will conduct a monthly review of TANF cases to include all components of the TANF cases. Additionally, an Integrated Eligibility System (IES) enhancement will be implemented to allow telephonic signatures for TANF Responsibility and Service Plans. This will eliminate the need to use a paper process. Proposed Completion Date: March 21, 2027

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Finding 1206947 (2024-007)

Material Weakness 2024

State of Illinois

IL

Subrecipient Monitoring Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking § 200.303 § 200.332

Finding Number: 2024-007 Finding Name: Failure to Follow Established Program Subrecipient Monitoring Procedures Finding Condition(s): The Illinois Department of Human Services (IDHS) did not follow its established program monitoring policies and procedures for subrecipients of the Temporary Assistan...

Finding Number: 2024-007 Finding Name: Failure to Follow Established Program Subrecipient Monitoring Procedures Finding Condition(s): The Illinois Department of Human Services (IDHS) did not follow its established program monitoring policies and procedures for subrecipients of the Temporary Assistance for Needy Families (TANF), Child Care Development Fund Cluster (CCDF), Social Services Block Grant (SSBG), and Block Grants for Prevention and Treatment of Substance Abuse (SAPT) programs. Further, the auditors noted that the IDHS did not have adequate policies or procedures to ensure fiscal and administrative reviews were completed timely to detect potential non-compliance. Name of Contact Person(s): • Kasey Reagan, Interim Director – Illinois Department of Human Services, Division of Family and Community Services (FCS) • Christina Miller, Fund Disbursement Manager – Illinois Department of Human Services, Division of Behavioral Health and Recovery (IDHS-SAPT-Program) • Maureen Bilek, Audit Compliance and Programmatic Monitoring Administrator – Illinois Department of Human Services, Division of Early Childhood (DEC) • Brian Bond, Director – Illinois Department of Human Services, Office of Contract Administration (OCA) Corrective Action(s): The IDHS has completed or will take the following actions within four of its divisions/offices: Division of Family and Community Services (FCS) The FCS (1) has worked to identify the late subrecipient monitoring reviews and created a plan to address the backlog, (2) will utilize the plan to eliminate the back log of subrecipient monitoring reviews, (3) will meet with staff to reinforce the importance of adhering to the agreed upon monitoring processes and timeframes, (4) will update and circulate to staff the revised monitoring standard operating procedure, and (5) will review staff adherence to monitoring SOP timeframes during weekly meetings with staff who conduct monitoring. Division of Behavioral Health and Recovery (IDHS-SAPT PROGRAM) The IDHS-SAPT PROGRAM will (1) hire an administrative assistant to assist with compliance monitoring tracking activities to maintain communication about important deadlines, (2) hire compliance monitors to engage in conducting compliance reviews, (3) meet weekly to track monitoring activities to ensure deadlines are met, (4) review policy and procedures to assess timelines associated with the monitoring process, and (5) train all monitors to use the updated tool, templates and updated policies and procedures and the new electronic system. Division of Early Childhood (DEC) The DEC will (1) develop and implement a standardized deadline tracking tool to monitor review completion dates and required subrecipient notifications, including documented supervisory review and management oversight to ensure timeliness, (2) establish and implement internal Corrective Action Plan (CAP) procedures that outline standardized processes for CAP tracking, documentation, and escalation efforts and define protocols when subrecipients fail to submit required CAPs within established timeframes, (3) initiate and implement a CAP tracking tool to monitor review dates, findings issuance, subrecipient notification dates, CAP receipt, and implementation follow-up activities, with documented management oversight and approval to ensure timeliness, accountability, and consistent monitoring, and (4) conduct formal staff training on procedures for accurately completing and maintaining the CAP tracking tool, including documentation standards, required data elements, and supervisory review expectations to ensure consistent and compliant use. Office of Contract Administration (OCA) The OCA (1) has formally briefed leadership and management the issues noted in the finding and initiated a cross-division review of current subrecipient monitoring execution to identify gaps, inconsistencies, and needed revisions, (2) will complete a structured validation of monitoring expectations to ensure programmatic on-site reviews and expenditure/performance report reviews are occurring at the required frequency and depth, consistent with pass-through monitoring responsibilities, (3) will review minimum documentation standards and supervisory quality control checkpoints for review workpapers, expenditure/performance report review evidence, and monitoring report issuance, to strengthen internal controls over compliance, (4) will standardize and revise the data tracking definitions to ensure program findings from subrecipient monitoring are issued, tracked, and followed through to corrective action completion, including defined escalation steps when responses are delinquent or incomplete, (5) will align enforcement actions with the Statewide Grantee Compliance Enforcement System (GCES) framework (e.g., stop-payment status triggers, notices, objection windows, and resolution and closure steps), and ensure staff understand how and when to apply GCES in response to unresolved monitoring deficiencies, (6) finalize recommendations to streamline Fiscal Administrative Review (FAR) production triggers (pre-draft and post-draft), clarify program engagement in special condition processing post-FAR, and reduce reliance on informal technical assistance in CAP in favor of documented compliance correction and closure, (7) revised procedures and controls will be implemented for FARs scheduled on/after August 1, 2026 (target), with interim guidance applied as feasible to active cases prior to that date, and (8) will conduct structured database integrity review and update process aligned with official guidance and source documentation to ensure accuracy, completeness, consistency, and reliability of all FAR database records. Proposed Completion Date: December 31, 2026

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Finding 1206939 (2024-006)

Material Weakness 2024

State of Illinois

IL

Subrecipient Monitoring Allowable Costs / Cost Principles Reporting § 200.303 § 200.502 § 200.510

Finding Number: 2024-006 Finding Name: Inadequate Process for Monitoring Interagency Program Expenditures Finding Condition(s): The Illinois Department of Human Services (IDHS) does not have an adequate process for monitoring interagency expenditures claimed under or used to meet maintenance of effo...

Finding Number: 2024-006 Finding Name: Inadequate Process for Monitoring Interagency Program Expenditures Finding Condition(s): The Illinois Department of Human Services (IDHS) does not have an adequate process for monitoring interagency expenditures claimed under or used to meet maintenance of effort (MOE) requirements of the Temporary Assistance for Needy Families (TANF) and Child Care Development Fund (CCDF) Cluster programs. Name of Contact Person(s): Sarah Eves, Deputy Chief Financial Officer – Illinois Department of Human Services Corrective Action(s): The IDHS will request quarterly certifications, control assessments, and program expenditure questionnaires for those agencies receiving funds from federal awards. Additionally, the IDHS will sample interagency expenditures and request that the agency provide supporting documentation for the expenses. This documentation will be reviewed by the IDHS to ensure that the expenditures meet federal program requirements. Proposed Completion Date: October 1, 2026

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Finding 1206600 (2024-002)

Material Weakness 2024

Urban League of Greater Pittsburgh

PA

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

Executive Committee Actions and Finance Next Steps The Urban League of Greater Pittsburgh’s Executive Committee convened to identify key areas of significance and outline the next steps for the organization’s financial operations. The primary focus of the discussion was on empowering individuals to ...

Executive Committee Actions and Finance Next Steps The Urban League of Greater Pittsburgh’s Executive Committee convened to identify key areas of significance and outline the next steps for the organization’s financial operations. The primary focus of the discussion was on empowering individuals to lead the organization and establishing modernized, well-managed financial systems, procedures, and practices. Policies and Procedures The Committee recognized that the Urban League of Greater Pittsburgh of Greater Pittsburgh maintains a long-established Policies and Procedures Manual, which incorporates controls mandated under the Uniform Guidance. This manual serves as the foundation for the organization’s financial management and ensures compliance with regulatory requirements. Leadership and Staffing To strengthen financial oversight, the Committee recommended recruiting a full-time Vice President of Finance. This position has been successfully filled, bringing dedicated leadership to the finance department. Strengthening Internal Controls Immediate next steps include a thorough review and enhancement of internal controls to ensure that financial risks are appropriately managed. These measures are being implemented with the aim of safeguarding the organization's assets and maintaining the integrity of financial reporting. Third-Party Involvement The Urban League of Greater Pittsburgh has engaged a third-party provider to assist with documenting key deliverables, organizing and convening meetings, and overseeing daily executions. This partnership is designed to enable more timely financial reporting and the development of a comprehensive plan that documents roles, responsibilities, procedures, and practices—including necessary approvals—for managing billings, receivables, cash flow, and other critical accounting and finance functions. Role of the Treasurer The Treasurer of the Urban League of Greater Pittsburgh has played a vital role in the implementation of these initiatives. The Treasurer actively participates in regularly scheduled weekly meetings, helping to ensure ongoing oversight and the effective execution of improvements to the organization’s financial management practices. Staff Roles and Responsibilities In Order to improve performance, collaboration, and to distribute the workload effectively. The Urban League has defined individuals and their role to strengthen Internal Controls. The staff responsible for the administration and oversight include: President/CEO Responsible for signing checks, authorizing payroll, approving transfers between bank accounts, and endorsing all Account Clearing House transactions. VP/Finance Reviews bank reconciliations and co-signs check with a second signatory. Approves Positive Pay transactions, initiates and completes transfers between accounts, reviews and authorizes payroll, enters Automatic Clearing House transactions, and oversees Accounts Payable approvals. This position will provide internal oversight to ensure financial reporting is timely and accurate. Accountant Records transactions in the accounting software. All payment requests to vendors require approval from both the Vice President of Finance and Program Managers. Prepares checks, inputs them into Positive Pay, requests Automated Clearing House payments, reconciles bank statements, and processes payroll. The accountant also initials inter-account bank transfers, manages deposit entries (stamps, records, and distributes check copies), and ensures proper authorization for Accounts Payable entries in the software. Executive Assistant Opens and logs checks into a tracking spreadsheet.

View Audit 398676

Finding 1206574 (2024-003)

Material Weakness 2024

Town of Natick, Massachusetts

MA

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

2024-003 Document Policies and Procedures Over Federal Awards Cluster/Program: All federal programs Type of Finding Compliance – Other Matters Internal Control over Compliance – Significant Deficiency Condition: The Town has not formalized written policies and procedures related to federal awards re...

2024-003 Document Policies and Procedures Over Federal Awards Cluster/Program: All federal programs Type of Finding Compliance – Other Matters Internal Control over Compliance – Significant Deficiency Condition: The Town has not formalized written policies and procedures related to federal awards required under the Uniform Guidance. Criteria: OMB’s Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requirements stipulate that federal award recipients must document their policies and procedures over certain aspects of financial and program management. Specifically, written policies are required for the following: • Cash management • Determination of allowable costs • Employee travel • Procurement • Conflicts of interest • Subrecipient monitoring and management Cause: The Town has not developed written formal documentation of internal controls to encompass all required areas per the Uniform Guidance. Effect: The Town is not in compliance with the requirements of the Uniform Guidance as it relates to the requirement to have documented policies and procedures pertaining to the management of federal awards. No questioned costs are reported as this requirement is procedural in nature. Recommendation: Written policies and procedures should be implemented in accordance with the Uniform Guidance. Views of Responsible Official: The reconciliations of retirement board accounts were handled through a third party prior to January 2024. There have been delays in obtaining the files from the third party. With the hiring of the new director in January 2024, the reconciliations are now performed in the Retirement office, by the retirement staff. We anticipate that the records will be available upon request in the future.

View Audit 398631

Finding 1206534 (2024-001)

Material Weakness 2024

Housing Authority of the City of Michigan City, Indiana

IN

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

The Authority concurs with the Auditor’s recommendation. The Authority has made a number of employee changes as well as administrative and accounting-related improvements. The Authority will continue its efforts to further strengthen its administration of the federal programs/funds. The Executive Di...

The Authority concurs with the Auditor’s recommendation. The Authority has made a number of employee changes as well as administrative and accounting-related improvements. The Authority will continue its efforts to further strengthen its administration of the federal programs/funds. The Executive Director will continue to oversee the process of updating the Authority’s policies and procedures. The Executive Director will oversee the correction by September 30, 2025.

View Audit 398610

Finding 1206462 (2024-006)

Material Weakness 2024

Regional School Unit #54 - Msad #54

ME

Allowable Costs / Cost Principles Internal Control / Segregation of Duties

Management Response/Corrective Action Plan: Management agrees with the recommendation and acknowledges the importance of implementing stronger internal controls to ensure that all wage rates charged are properly documented and approved. The District is currently reviewing its written policies and pr...

Management Response/Corrective Action Plan: Management agrees with the recommendation and acknowledges the importance of implementing stronger internal controls to ensure that all wage rates charged are properly documented and approved. The District is currently reviewing its written policies and procedures to strengthen its internal controls. These updates will be communicated to the staff involved. Targeted training will be provided to reinforce federal compliance requirements, the importance of accurate documentation, and the roles and responsibilities in the review and approval process.

View Audit 398467

Finding 1206446 (2024-003)

Material Weakness 2024

Regional School Unit #54 - Msad #54

ME

Allowable Costs / Cost Principles Internal Control / Segregation of Duties

Management’s Response/Corrective Action Plan: Management has communicated directly with all staff responsible for student recordkeeping and cohort tracking at the high school level. The District procedural form for documenting student removals will be required in all cases. This form will serve as t...

Management’s Response/Corrective Action Plan: Management has communicated directly with all staff responsible for student recordkeeping and cohort tracking at the high school level. The District procedural form for documenting student removals will be required in all cases. This form will serve as the official record and must be completed, signed, and retained in accordance with district policy and audit requirements. No student will be removed from the cohort without completed and verifiable documentation.

View Audit 398467

Finding 1206387 (2024-006)

Material Weakness 2024

Association for Energy Affordability, Inc.

NY

Allowable Costs / Cost Principles § 200.405

1. Document formal allocation methodologies for shared non-personnel costs using rational and supportable bases such as square footage, FTEs, usage, or other proportional benefit measures depending on the cost. 2. Review and approve methodologies by management and update them when operational realit...

1. Document formal allocation methodologies for shared non-personnel costs using rational and supportable bases such as square footage, FTEs, usage, or other proportional benefit measures depending on the cost. 2. Review and approve methodologies by management and update them when operational realities change. 3. Maintain allocation schedules and supporting documentation for audit and grant compliance purposes. 4. Incorporate the methodology into policy and periodic review procedures.

View Audit 398386

Corrective Action Plans

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