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March 27, 2024 2023-004: Material Weakness in Internal Control/Material Noncompliance- Eligibility Condition: The Consortium did not provide documentation that all eligibility related conditions were met for each participant selected for testing. Corrective Action: We agree with the finding. The con...
March 27, 2024 2023-004: Material Weakness in Internal Control/Material Noncompliance- Eligibility Condition: The Consortium did not provide documentation that all eligibility related conditions were met for each participant selected for testing. Corrective Action: We agree with the finding. The consortium recognizes the importance of having support documentation for all eligibility determinations. During COVID-19 staff were allowed to work from home, as a result two staff were not following document saving protocol and saved vital documentation on their local drive (desktop). Upon the transition back into the office, those individuals did not follow protocol and ensure all files were backed up/saved to the networked database. Once of the individuals no longer worked for MWSE and the other as well as their manager both were made aware of the issue. After further conversations with the manager, management was assured this will not happen again. A process for spot checking and compliance sign-off by managers has been implemented to work to ensure this issue does not arise again. Contact Person: Shamar Herron: Sherron@mwse.org Anticipated Completion Date: Completed January 2024 Respectfully, Shamar Herron
Finding: As described in 34 CFR 668.171, the U.S. Department of Education (ED) requires institutions of higher education to report the occurance of specific events, known as triggering events, to them within ten days of the event. The notification of the vote by the Massachusetts Board of Registrati...
Finding: As described in 34 CFR 668.171, the U.S. Department of Education (ED) requires institutions of higher education to report the occurance of specific events, known as triggering events, to them within ten days of the event. The notification of the vote by the Massachusetts Board of Registration in Nursing (BORN) to withdraw the approval of the College's Associate Degree Nursing Program is a triggering event that should have been reported to the ED within ten days of occurance of the event. ED requirements for reporting triggering events. The triggering event occurred on June 20, 2023 and communication was not made to the ED until August 2023. Corrective Action Plan. The College has implemented procedures to ensure triggering events are identified and reported to the ED in a timely mannger. The Financial Aid Director: Erin Hanlon or VP of Administration and Finance: William McDonald is responsible for communicating triggering events once identified.
Views of Responding Officials: The Department agrees with the finding and will implement corrective action. Corrective Action Taken or Planned: The Supplemental Nutrition and Assistance Program office has worked with Statewide Branch and Staff Development offices to address refresher training ass...
Views of Responding Officials: The Department agrees with the finding and will implement corrective action. Corrective Action Taken or Planned: The Supplemental Nutrition and Assistance Program office has worked with Statewide Branch and Staff Development offices to address refresher training associated with budget calculations including the documentation and input of all data correctly. The Department is also in process of finalizing the new eligibility system – Benefit Eligibility Solution – slated to rollout statewide by late October 2024. As a condition of system rollout, all staff will be required to go through system training which will include a reinforcement of data entry practices and documentation requirements as a condition of eligibility determination. Expected Completion Date: October 31, 2024 Responding Officials: Ginet Hayes, Supplemental Nutrition and Assistance Administrator
View Audit 302108 Questioned Costs: $1
Views of Responding Officials: The Department agrees with the finding and will implement corrective action. Corrective Action Taken of Planned: The Department has identified a gap in training and education, that caused a failure to enforce the contract requirements for plans to submit audited fin...
Views of Responding Officials: The Department agrees with the finding and will implement corrective action. Corrective Action Taken of Planned: The Department has identified a gap in training and education, that caused a failure to enforce the contract requirements for plans to submit audited financial statements pursuant to 42 CFR 438.3(m). Training and education were completed. The Department has engaged with a vendor to implement our new online provider enrollment system HOKU on August 3, 2020 and started the process to have all providers re register their information in the new online system. All providers were given a deadline to do this by December 31, 2023 and if missed they would be terminated in 2024. Expected Completion Date: April 30, 2024 Responding Official: Marvin Malohi, Med-QUEST Division Supervising Contracts Specialist
View Audit 302108 Questioned Costs: $1
Views of Responding Officials: The Department agrees with the finding and will implement corrective action, however, notes the following: Letter dated April 29, 2022 was sent to ACF notifying of the temporary amendment to the Hawaii TANF State Plan, Part B, Section 10.1, suspending the interview re...
Views of Responding Officials: The Department agrees with the finding and will implement corrective action, however, notes the following: Letter dated April 29, 2022 was sent to ACF notifying of the temporary amendment to the Hawaii TANF State Plan, Part B, Section 10.1, suspending the interview requirement for TANF applications and annual recertification. The temporary suspension of the interview requirement aligned with the waiver granted by the Food and Nutrition Service for the Supplemental Nutrition Assistance Program (“SNAP”). The letter also informed ACF the interview requirement will resume for new TANF applications by July 31, 2022. No date was provided as to when the interview requirement will resume for annual recertifications. The Department received a letter dated May 9, 2022 from ACF that acknowledged the temporary amendment to the Hawaii TANF State Plan. A subsequent letter dated March 16, 2023 was sent to inform ACF that the suspended interview resumed for TANF applications effective July 1, 2022, however, will continue to be suspended for annual eligibility recertifications for TANF recipients. The Department received a letter dated March 29, 2023 from ACF that acknowledged the temporary State Plan amendment. A letter dated July 25, 2023 informed ACF that TANF will continue to align with SNAP and extend its suspended interview requirement for annual recertifications until May 31, 2024. The Department received a letter dated August 3, 2023 from ACF that acknowledged the extended temporary amendment to the State Plan. The Department did not need guidance from ACF on whether a particular action is allowable under program requirements. Pursuant to section 402 of the Social Security Act, ACF has the authority to determine whether a state’s TANF State Plan is complete but does not have the authority to approve or disapprove a plan. ACF acknowledged the temporary amendments made to the Hawaii TANF State Plan and expressed no concerns or determined that the temporary amendments were not allowable. Corrective Action Taken or Planned: No corrective action. The temporary amendment to the Hawaii TANF State Plan will end effective June 1, 2024, as noted in the July 25, 2023 letter to ACF. Expected Completion Date: Not applicable Responding Officials: Catherine Scardino, Temporary Assistance for Needy Families Program Administrator
View Audit 302108 Questioned Costs: $1
Views of Responding Officials: The Department does not agree with this finding. According to 45 CFR section 205.55, it states, “…the State agency will request through the IEVS…”. However, the policy does not specify the State agency must “properly use IEVS information to evaluate benefit amounts…...
Views of Responding Officials: The Department does not agree with this finding. According to 45 CFR section 205.55, it states, “…the State agency will request through the IEVS…”. However, the policy does not specify the State agency must “properly use IEVS information to evaluate benefit amounts…” as notated in this finding under “Effect.” Unless IEVS provides the necessary information for the applicable benefit month(s) used to determine a TANF applicant’s or recipient’s (“client”) eligibility, information obtained will only validate whether a household received an income source, after the fact, but will not verify the dollar amount. Hard-copy verification is obtained from the client to verify income source and dollar amount, for the applicable benefit months, to determine eligibility in accordance with §17 676 51, Hawaii Administrative Rules. For example, if a client applied for TANF on January 31, 2024, and the Department processes the application on February 29, 2024 (current month), verification of the household’s income received in January 2024 and received thus far in February 2024, must be obtained to determine eligibility for the month of application (January 2024) and subsequent months (based on projected income). Data obtained from IEVS are not current. For example, wage information through SWICA becomes available on a quarterly basis. The most current SWICA information available would have been for quarter ending December 31, 2023, for an application that was processed on February 29, 2024. Eligibility determination would have been improperly made if SWICA information was applied. Corrective Action Taken or Planned: The Department will continue to conduct IEVS check and utilize information obtained to determine eligibility if the information is applicable, otherwise, IEVS information will continue to be used to validate any source of income. Expected Completion Date: Ongoing Responding Officials: Catherine Scardino, Temporary Assistance for Needy Families Program Administrator
View Audit 302108 Questioned Costs: $1
Views of Responding Officials: The Department agrees with the finding and will implement corrective action. Corrective Action Taken of Planned: The Department has identified a gap in training and education, that caused a failure to enforce the contract requirements for plans to submit audited fin...
Views of Responding Officials: The Department agrees with the finding and will implement corrective action. Corrective Action Taken of Planned: The Department has identified a gap in training and education, that caused a failure to enforce the contract requirements for plans to submit audited financial statements pursuant to 42 CFR 438.3(m). Training and education were completed. The Department has engaged with a vendor to implement our new online provider enrollment system HOKU on August 3, 2020 and started the process to have all providers re register their information in the new online system. All providers were given a deadline to do this by December 31, 2023 and if missed they would be terminated in 2024. Expected Completion Date: April 30, 2024 Responding Official: Marvin Malohi, Med-QUEST Division Supervising Contracts Specialist
View Audit 302108 Questioned Costs: $1
Views of Responding Officials: The Department agrees with the finding and will implement corrective action. Corrective Action Taken or Planned: 1. Child Welfare Service (“CWS”) staff will be informed of the audit findings, the importance of diligent compliance of policies and procedures, records m...
Views of Responding Officials: The Department agrees with the finding and will implement corrective action. Corrective Action Taken or Planned: 1. Child Welfare Service (“CWS”) staff will be informed of the audit findings, the importance of diligent compliance of policies and procedures, records maintenance and this corrective action plan. 2. Unit staff (Licensing, CWS, and FPPEU) who manage cases identified with errors in this audit will be retrained, ensuring familiarity with grant requirements and related policies and procedures. • Staff will be given coaching/supervisory support to correctly complete documentation. 3. Case specific audit findings and corrective action taken will be noted in each record where there was a finding. • Secure a copy of the missing modified guardianship/permanency assistance agreement, demonstrating support for the monthly assistance paid. • Document the qualifying need for Difficulty of Care (“DOC”) determination for the records, showing how DOC was calculated. • Investigate whether the child who attained the age of 14 was consulted regarding the kinship guardianship agreement. Discuss this with the youth and document. • Locate missing clearances or re run them if not located, placing note in record about audit re run. Note: Not all clearances are secured prior to placement; FBI clearances come later and are NOT required prior to placement in a “provisionally licensed” home. • Secure documentation for case regarding continuation of monthly subsidy payments after the child’s 18th birthday. 4. The identified errors and the related corrective action steps proposed above will be reviewed by CWS Administrators, staff supervisors, and the Management Information Compliance Unit (“MICU”) within 90 days to ensure missing documentation has been secured and/or properly noted in record. 5. MICU staff will audit records with findings to ensure errors have been documented and corrected. • MICU will work with Branch Administrators, Social Services Assistants (“SSA”), and program personnel to ensure file updates with completion of missing information. 6. As CWS implements this corrective action plan and monitors the results, the action steps proposed in 1 – 5 may be modified, based on input from CWS Administrators or exploration groups with line staff who complete this documentation. Expected Completion Date: May 31, 2024 and on-going Responding Officials: Kisha C. Raby, Social Services Division, Child Welfare Services Program Development Office, Administrator
View Audit 302108 Questioned Costs: $1
Views of Responding Officials: The Department agrees with the finding and will implement corrective action; however, notes the following: Adoption Assistance is an incentive program with payment beginning prior to the finalization of an adoption. The adoption decree is not required for payment as ...
Views of Responding Officials: The Department agrees with the finding and will implement corrective action; however, notes the following: Adoption Assistance is an incentive program with payment beginning prior to the finalization of an adoption. The adoption decree is not required for payment as the Adoption Assistance Agreement must be entered into prior to the finalization of an adoption. Corrective Action Taken or Planned: 1. Child Welfare Service (“CWS”) staff will be informed of the audit findings, the importance of diligent compliance of policies and procedures, records maintenance and this corrective action plan. 2. Unit staff (Licensing, CWS, and FPPEU) who manage cases identified with errors in this audit will be retrained, ensuring familiarity with grant requirements and related policies and procedures. • Staff will be given coaching/supervisory support to correctly complete documentation. 3. Case specific audit findings and corrective action taken will be noted in each record where there was a finding. • Research/review and document why licensing approval was granted to a household with an individual who was convicted of spousal abuse. i. If review determines that Adoption Assistance Agreement (“AAA”) was inappropriately authorized, provide family with an adverse action notice discontinuing the AAA and explaining the appeals process. • Investigate whether supporting documentation regarding whether the State determined that the child cannot or should not be returned to the home of his or her parents can be located and added to the record. • Secure a copy of the missing adoption decree, although adoption assistance is an incentive program with payment beginning prior to the finalization of an adoption. • Document the qualifying need for Difficulty of Care (“DOC”) determination for the records, showing how DOC was calculated. • Document how income eligibility was verified. • Secure missing modified adoption agreements. • Locate missing clearances or re run them if not located. Note: Not all clearances are secured prior to placement; FBI clearances come later and are NOT required prior to placement in a “provisionally licensed” home. 4. The identified errors and the related corrective action steps proposed above will be reviewed by CWS Administrators, staff supervisors, and the Management Information Compliance Unit (“MICU”) within 90 days to ensure missing documentation has been secured and/or properly noted in record. 5. MICU staff will audit records with findings to ensure errors have been documented and corrected. • MICU will work with Branch Administrators, Social Services Assistants (“SSA”), and program personnel to ensure file updates with completion of missing information. 6. As CWS implements this corrective action plan and monitors the results, the action steps proposed in 1 – 5 may be modified, based on input from CWS Administrators or exploration groups with line staff who complete this documentation. Expected Completion Date: May 31, 2024 and on going Responding Officials: Kisha C. Raby, Social Services Division, Child Welfare Services Program Development Office, Administrator, and Tonia Mahi, Social Services Division, Child Welfare Services Program Development Office, Assistant Branch Administrator
View Audit 302108 Questioned Costs: $1
Views of Responding Officials: The Department agrees with the finding and will implement corrective action. Corrective Action Taken or Planned: 1. Child Welfare Service (“CWS”) staff will be informed of the audit findings, the importance of diligent compliance of policies and procedures, records m...
Views of Responding Officials: The Department agrees with the finding and will implement corrective action. Corrective Action Taken or Planned: 1. Child Welfare Service (“CWS”) staff will be informed of the audit findings, the importance of diligent compliance of policies and procedures, records maintenance and this corrective action plan. 2. Unit staff (Licensing, CWS, and FPPEU) who manage cases identified with errors in this audit will be retrained, ensuring familiarity with grant requirements and related policies and procedures. • Staff will be given coaching/supervisory support to correctly complete documentation. 3. Case specific audit findings and corrective action taken will be noted in each record where there was a finding. • Locate Police Protective Custody form, Voluntary Foster Custody Agreement, or other documentation which clarifies whether the child was removed as part of a voluntary placement agreement or judicial determination. • Locate missing clearances or re-run them if not located, placing note in record about audit re run. Note: Not all clearances are secured prior to placement; FBI clearances come later and are not required prior to placement in a “provisionally licensed” home. • Document the qualifying need for Difficulty of Care (“DOC”) determination for the records, showing how DOC was calculated. • Review resource caregiver licensing status and locate missing license or reissue license. • Investigate the case where the Judicial Determination was missing and therefore did not support the removal of the child was contrary to the welfare of the child, if the Department made reasonable efforts to prevent removal and finalize the permanency plan, and if the determination was within 60 days from removal. i. Locate court order documenting “contrary to welfare” language, verifying timelines, place in record and document findings. • Locate missing Imua Kakou minutes or secure additional documentation validating monthly meeting requirement was met. 4. The identified errors and the related corrective action steps proposed above will be reviewed by CWS Administrators, staff supervisors, and the Management Information Compliance Unit (“MICU”) within 90 days to ensure missing documentation has been secured and/or properly noted in record. 5. MICU staff will audit records with findings to ensure errors have been documented and corrected. • MICU will work with Branch Administrators, Social Services Assistants (“SSA”) and program personnel to ensure file updates with completion of missing information. 6. As CWS implements this corrective action plan and monitors the results, the action steps proposed in 1 – 5 may be modified, based on input from CWS Administrators or exploration groups with line staff who complete this documentation. Expected Completion Date: May 31, 2024 and on-going Responding Officials: Kisha C. Raby, Social Services Division, Child Welfare Services Program Development Office, Administrator
View Audit 302108 Questioned Costs: $1
The system is being reviewed to ensure flags are set not only from the Central Process System (CPS) on the ISIR as an alert, but to implement secondary measures in PowerFaids to flag the student’s electronic file record as part of the communication process that the counseling unit must review. Staff...
The system is being reviewed to ensure flags are set not only from the Central Process System (CPS) on the ISIR as an alert, but to implement secondary measures in PowerFaids to flag the student’s electronic file record as part of the communication process that the counseling unit must review. Staff will be counseled and additional training is being provided to ensure all staff are knowledgeable and conscientious of policy, review and the calculation process when determining yearly and aggregate loan limits. The University will be implementing Transfer Monitoring which has been discussed as preparation of bringing up a new system.
View Audit 302079 Questioned Costs: $1
Corrective Action Plan: The University experienced significant staffing changes in the TRIO programs. The changes in staffing lead to a loss of institutional knowledge, and interrupted policy and process enforcement. In many instance the documentation wasn’t available due to the transition of key ...
Corrective Action Plan: The University experienced significant staffing changes in the TRIO programs. The changes in staffing lead to a loss of institutional knowledge, and interrupted policy and process enforcement. In many instance the documentation wasn’t available due to the transition of key individuals. During the period of staff transition for the McNair program, original communication showing previous approval from the Program Officer was not accessible. While the Department of Education provided correspondence granting McNair projects permission to reallocate travel funding to increase stipends for participants, given the limitations on travel capabilities due to the COVID-19 pandemic, which was subsequently confirmed by the Program Officer, we encountered difficulty locating explicit documentation approving the specific stipend increase amount. Continuous monitoring of program records will be implemented to ensure compliance with federal, Institutional and program requirements. The programs will review existing program operating procedures manuals to identify needed updates to current policies and procedures to align with federal, Institutional and program requirements. The program stall will also engage in professional development opportunities to improve grant management. Anticipated Completion Date: July 31, 2024
View Audit 302075 Questioned Costs: $1
April 1, 2024 Finding Number 50000 (2023-001) Noncompliance and Internal Control over Federal Compliance Federal Program – Child Care and Development Fund Cluster – Assistance Listing 93.575 and 93.576, Federal Alternative Payment Corrective Action Plan: Anticipated Completion Date April 30, 2024...
April 1, 2024 Finding Number 50000 (2023-001) Noncompliance and Internal Control over Federal Compliance Federal Program – Child Care and Development Fund Cluster – Assistance Listing 93.575 and 93.576, Federal Alternative Payment Corrective Action Plan: Anticipated Completion Date April 30, 2024 Prior to Mono County Office of Education (MCOE) taking over this program, another agency was responsible for the original eligibility determinations and special tests and provisions, including the files selected for this audit. After discussion about the audit findings, MCOE investigated further, and it was noted that the staff at the time were not following the procedures and forms that were in place. Items were either not completed or filled out correctly in many instances. Since this discovery, MCOE has developed a corrective action plan as follows to adhere to the program’s requirements: • MCOE will ensure that existing and new staff are trained to adhere to the policies and procedures for the program. • MCOE will be conducting annual reviews of all service providers and children served to ensure MCOE is maintaining the required documents on file. • MCOE has developed a double-check procedure to ensure that staff is keeping the required documentation on file for both providers and children served moving forward. I, Jennifer Weston, CBO, will be responsible for the implementation and monitoring of the corrective action plan. Sincerely, Jennifer Weston Chief Business Officer Mono County Office of Education
View Audit 302045 Questioned Costs: $1
Finding 391584 (2023-007)
Significant Deficiency 2023
Finding No. 2023-007 Department(s): New York City Administration for Children’s Services Program(s): Assistance Listing Number 93.658, Foster Care – Title IV - E Corrective Action(s): • ACS will review all outstanding non-finalized Redetermination packages and re-request outstanding Court Order...
Finding No. 2023-007 Department(s): New York City Administration for Children’s Services Program(s): Assistance Listing Number 93.658, Foster Care – Title IV - E Corrective Action(s): • ACS will review all outstanding non-finalized Redetermination packages and re-request outstanding Court Orders. • Moving forward, if the hard copy Court Order has not been received by ACS within 90 days of the Permanency Hearing, ACS will request a court transcript of the Permanency Hearing. • ACS will finalize IV-E Redetermination packages if a Reasonable Effort determination finding has not been conferred within four months of the request for court action. • ACS will work with the Office of Court Administration to address challenges in timely completion of hearings and receipt of Court Orders. Anticipated Completion Date: September 2024 Person(s) Responsible for Implementation: Andrew Martin, Executive Director, Central Eligibility Office (212)-341-2816
Finding No. 2023-013 Department(s): New York City Administration for Children’s Services and New York City Human Resources Administration Program(s): Assistance Listing Number 93.575, Child Care and Development Block Grant Corrective Action(s): ACS: ACS will work with other agencies to promote co...
Finding No. 2023-013 Department(s): New York City Administration for Children’s Services and New York City Human Resources Administration Program(s): Assistance Listing Number 93.575, Child Care and Development Block Grant Corrective Action(s): ACS: ACS will work with other agencies to promote compliance and internal controls going forward. HRA: In response to the findings, HRA made the following training requests to address the specific findings identified in this audit: 1. Training ID 2344 - Childcare liaisons and Childcare Review Team (CCRT) require training for the appropriate documentation necessary for the approval and provision of childcare. Audit findings confirmed that the staff charged with approval and authorizing childcare will take refresher training about the appropriate documentation requirements (i.e., CS-274w, LDSS 4699, LDSS 4700, etc.). The training will emphasize the requirement that any approved childcare must have support underlying employment/education documentation to justify the provision of the childcare. Childcare is a supportive service, so any childcare must have employment/engagement/education as a condition precedent. 2. Training ID 2343 - The training will include information about the client's employment, rate of pay, frequency of pay, and getting the appropriate documentation into the case records. Audits confirmed that 1) when the agency budgeted income and approved supportive services (i.e., childcare), the record did not have supporting income and employment related documents; 2) training will include the process for budgeting the earned income and applied any earned income disregards. Anticipated Completion Date: April 2024 and ongoing Person(s) Responsible for Implementation: ACS: Rahel Getachew, Associate Commissioner (212)-676-8818. HRA: Ramon E. Flores, Deputy Commissioner, Family Independence Administration (FIA) floresra@hra.nyc.gov
View Audit 302042 Questioned Costs: $1
Finding No. 2023-016 Department(s): New York City Housing Preservation & Development Program(s): Assistance Listing Number 14.871, Housing Voucher Cluster: Section 8 Housing Choice Vouchers Corrective Action(s): During the pandemic, HPD adopted HUD CARES Act waivers, intended to minimize health ...
Finding No. 2023-016 Department(s): New York City Housing Preservation & Development Program(s): Assistance Listing Number 14.871, Housing Voucher Cluster: Section 8 Housing Choice Vouchers Corrective Action(s): During the pandemic, HPD adopted HUD CARES Act waivers, intended to minimize health and safety risks to applicants, participants, owners and staff, and which included the temporary suspension of adverse actions. Although HPD continued to request recertification packages during the period of the waivers until today, from February 2020 through December 2021, HPD did not penalize families who did not submit complete recertification packages. Additionally, HPD is among the City agencies that experienced a staff retention crisis, with attrition rates among its Rental Subsidy Program administrative teams swelling from 12 percent in 2020 to 27 percent in 2022. During the audit period, HPD was experiencing its highest vacancy rate. This meant standard recertifications were delayed because participants did not respond to recertification packages they were asked to complete, HPD did not have the capacity to revoke subsidies for those who did not comply, and the agency had significant backlog as a result of staff vacancies. Though HPD’s vacancy rate improved, it takes significant time to train and prepare staff to do the work. Finally, even though HPD’s COVID-era policies involving adverse action have ceased and normal processes are now in effect, due process requires intensive tracking and follow up to ideally have participants comply with requirements but if necessary to terminate assistance for those who do not comply. Therefore, there will be a significant lag between the re-implementation of HPD’s policy to take enforcement actions when recertification packages are not completed or missing and HPD’s actually terminating assistance. Corrective Action(s): 1. Build on existing systems to more closely track recertifications that are mailed and not returned. 2. Develop more robust digital operations that were started during the pandemic leading to reporting capabilities that will help with tracking overdue recertifications. 3. Work more closely with Community Based Organizations that can assist participants complete and return recertification package. 4. Continue close coordination to implement the Housing Access and Stability staffing plan and identify priority hires to onboard critically needed staff timely. 5. Invest in a training team to meet the training needs of new staff. Anticipated Completion Date: April 2025 Person(s) Responsible for Implementation: Dinsiri Fikru, Assistant Commissioner, Division of Program Policy and Innovation, Office of Housing Access and Stability FIKRUD@hpd.nyc.gov
Finding No. 2023-014 Department(s): New York City Housing Preservation & Development Program(s): Assistance Listing Numbers: 14.249, Section 8 Project-Based Cluster: Section 8 Moderate Rehabilitation Single Room Occupancy 14.856, Section 8 Project-Based Cluster: Lower Income Housing Assistance P...
Finding No. 2023-014 Department(s): New York City Housing Preservation & Development Program(s): Assistance Listing Numbers: 14.249, Section 8 Project-Based Cluster: Section 8 Moderate Rehabilitation Single Room Occupancy 14.856, Section 8 Project-Based Cluster: Lower Income Housing Assistance Program – Section 8 Moderate Rehabilitation Corrective Action(s): During the pandemic, HPD adopted HUD CARES Act waivers, intended to minimize health and safety risks to applicants, participants, owners and staff, and which included the temporary suspension of adverse actions. Although HPD continued to request recertification packages during the period the waivers, February 2020 through December 2021, HPD did not penalize families who did not submit complete recertification packages at that time until more recently. Additionally, HPD is among the City agencies that experienced a staff retention crisis, with attrition rates among its Rental Subsidy Program administrative teams swelling from 12 percent in 2020 to 27 percent in 2022. During the audit period, HPD was experiencing its highest vacancy rate. This meant standard recertifications were delayed because participants did not respond to recertification packages they were asked to complete, HPD did not have the capacity to revoke subsidies for those who did not comply, and the agency had significant backlog as a result of staff vacancies. Though HPD’s vacancy rate improved, it takes significant time to train and prepare staff to do the work. Finally, even though HPD’s COVID-era policies involving adverse action have ceased and normal processes are now in effect, due process requires intensive tracking and follow-up to ideally have participants comply with requirements (but if necessary to terminate assistance for those who do not comply). Therefore, there will be a significant lag between the re-implementation of HPD’s policy to take enforcement actions when recertification packages are not completed or missing and HPD’s actually terminating assistance. Corrective Action(s): 1. Build on existing systems to more closely track recertifications that are mailed and not returned. 2. Develop more robust digital operations that were started during the pandemic leading to reporting capabilities that will help with tracking overdue recertifications. 3. Work more closely with Community Based Organizations that can assist participants complete and return recertification package. 4. Continue close coordination to implement the Housing Access and Stability staffing plan and identify priority hires to onboard critically needed staff timely. 5. Invest in a training team to meet the training needs of new staff. Anticipated Completion Date: April 2025 Person(s) Responsible for Implementation: Dinsiri Fikru, Assistant Commissioner, Division of Program Policy and Innovation, Office of Housing Access and Stability FIKRUD@hpd.nyc.gov
Finding 391561 (2023-005)
Significant Deficiency 2023
Finding No. 2023-005 Department(s): New York City Human Resources Administration Program(s): Assistance Listing Numbers 14.241, Housing Opportunities for Persons with AIDS (HOPWA) Corrective Action(s): HASA will enhance its data management system to flag housing units where rent amounts are repor...
Finding No. 2023-005 Department(s): New York City Human Resources Administration Program(s): Assistance Listing Numbers 14.241, Housing Opportunities for Persons with AIDS (HOPWA) Corrective Action(s): HASA will enhance its data management system to flag housing units where rent amounts are reportedly above the prevailing Fair Market Rent (FMR) limits per bedroom size, and document follow up activities accordingly. Staff will continue to review support documentation during monitoring visits to ensure client rent calculations are current and accurately completed. HASA will continue facilitating monthly technical assistance meetings and convene training sessions with housing providers to address emerging issues and contract compliance findings from monitoring visits. Anticipated Completion Date: April 1, 2024 and ongoing Person(s) Responsible for Implementation: Xiomara Pamela Farquhar, Assistant Deputy Commissioner farquharx@hra.nyc.gov
Finding No. 2023-002 Department(s): New York City Human Resources Administration Program(s): Assistance Listing Number 14.239, HOME Investment Partnerships Program Corrective Action(s): This FY23 audit was conducted on the heels of the FY22 audit where the questioned cost finding is a similar er...
Finding No. 2023-002 Department(s): New York City Human Resources Administration Program(s): Assistance Listing Number 14.239, HOME Investment Partnerships Program Corrective Action(s): This FY23 audit was conducted on the heels of the FY22 audit where the questioned cost finding is a similar error type but significantly decreased to $296 from over $18,000. Included in the FY22 recommended Corrective Action was the onboarding of the Executive Director to shepherd the charge with strengthening the teams’ internal governance, appropriate monitoring and future compliance. Adversely, the onboarding of the executive director was lengthy and only recently finalized in the 2nd quarter of FY24. HRA agrees to strengthen internal controls and the new Executive Director is working with the team to ensure they are intentional in appropriately applying the correct formula for calculating allowable cost, particularly the inclusion of “gross” and not “net” income. The Quality Assurance Tool has been updated including specific sub-items to ensure allowable cost is correctly calculated as well as the other deliverables. Corrective Action(s) • Strengthen internal governance and future compliance. • Executive Director for the Home-TBRA now on board. • Update the Quality Assurance tool that includes sub-items information that supports improved review and approval. • Provide refresher training for staff involved with TBRA to improve performance and outcomes. Anticipated Completion Date: June 30, 2024 and ongoing Person(s) Responsible for Implementation: Dori Hopkins-Figeroux, Director - HTBRA hopkinsfigerouxd@hra.nyc.gov 929-252-6089 Jordan Worrell, Executive Director RAP/HTBRA worrellj@hra.nyc.gov 929-252- 5403 Dwana Abraham, Assistant Deputy Commissioner abrahamd@hra.nyc.gov 929-221-6726
View Audit 302042 Questioned Costs: $1
Views of Responsible Officials and Planned Corrective Actions: The City disagrees with the finding. A project was determined to be ineligible and was adjusted accordingly in the third quarter report due October 30, 2023. The original first quarter submission report did not tie to the balance after t...
Views of Responsible Officials and Planned Corrective Actions: The City disagrees with the finding. A project was determined to be ineligible and was adjusted accordingly in the third quarter report due October 30, 2023. The original first quarter submission report did not tie to the balance after the entries were made to reclass the expenditures. Staff was not able to recreate the report from the first quarter to tie to the ending balances charged to the fund as of June 30, 2023. When the original first quarter report was filed, the financial system expenditure reports reconciled to what was submitted. Finance Department personnel have established procedures to prevent the need for corrections and resubmissions to prior period quarterly Project and Expenditure submissions and will properly document the changes for verification if corrections occur.
The Finance Department personnel will carefully review vendor status in the System for Award Management and produce documentation of eligibility for use of Federal Funds before procurement of goods and services.
The Finance Department personnel will carefully review vendor status in the System for Award Management and produce documentation of eligibility for use of Federal Funds before procurement of goods and services.
View Audit 302016 Questioned Costs: $1
Identifying Number: 2023-002 – Eligibility Finding: The Code of Federal Regulations (CFR) Section 200.303(a) states the non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the feder...
Identifying Number: 2023-002 – Eligibility Finding: The Code of Federal Regulations (CFR) Section 200.303(a) states the non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). The State of Florida’s Department of Financial Services’ State Projects Compliance Supplement Part Five: Internal Controls Section D. Eligibility states that recipients should develop Control Objectives to provide reasonable assurance that only eligible individuals and organizations receive assistance under state projects, that subawards are made only to eligible subrecipients, and that amounts provided to or on behalf of eligibles were calculated in accordance with project requirements. During our testing of participant eligibility, we noted that supervisory personnel did not properly review and approve their eligibility documentation prior to the participant entering the program for ten of 80 participants selected for eligibility testing. Corrective Actions Taken or Planned: Corrective measures were taken with the Program Leadership responsible for the eligibility documentation noted above. The following corrective actions are in the process of being implemented: • CHS’s Program Leadership and their teams will conduct a review of respective intake forms completed after July 1, 2023 to ensure that all were properly reviewed and approved. Any unapproved intake forms identified will be verified and retroactively approved by the designated supervisor. • In cases where there are instances of unapproved intake forms, the Program Leadership will collaborate with the respective Talent Business Partner to follow up with formal corrective action. Such corrective action will include: o A thorough review of the CHS policies and practices relative to the management and approval of intake forms. o Mandatory refresher education and training with all staff to ensure they understand the steps required to document review and approval of the intake process, as well as the importance of maintaining evidence that the process was adequately performed. Person(s) Responsible for Corrective Actions: Barbara McDonald, Chief Financial Officer and Chief Administrative Officer and Heather Brungardt, Chief Program and Clinical Officer Anticipated Completion Date for Corrective Actions: Implementation of the Corrective Actions outlined above will begin immediately to be completed by June 30, 2024.
FINDING 2023-3- Overawarded Federal Direct Loan Amounts The Institute had not correctly calculated the federal loan eligibility for two (2) students. A.Comments on Findings and Recommendations: The Institute agrees with the finding and Auditor's recommendation. B.Actions Taken or Planned Previous FA...
FINDING 2023-3- Overawarded Federal Direct Loan Amounts The Institute had not correctly calculated the federal loan eligibility for two (2) students. A.Comments on Findings and Recommendations: The Institute agrees with the finding and Auditor's recommendation. B.Actions Taken or Planned Previous FA administrator failed to consistently calculate student enrollment hours. This caused incorrect loan awards to be prorated and disbursed. We have revised our method of requesting aid and the enrollment status of each student will be verified individually prior to requesting loans. We have also removed FA administrator (effective 12/2023) and third-party servicer from their role (effective 4/2024). We will be returning $1,056 to the Department of Education. Signed Betsy Bremke, Administrative Campus Director Date: _3/29/2024__
View Audit 301753 Questioned Costs: $1
FINDING 2023-4- Untimely Paid and Unpaid Credit Balances The Institute had Untimely Paid and Unpaid Credit Balances while Participating under the Zone Alternative and the Heightened Cash Monitoring 1 Payment Method A.Comments on Findings and Recommendations: The Institute agrees with the finding and...
FINDING 2023-4- Untimely Paid and Unpaid Credit Balances The Institute had Untimely Paid and Unpaid Credit Balances while Participating under the Zone Alternative and the Heightened Cash Monitoring 1 Payment Method A.Comments on Findings and Recommendations: The Institute agrees with the finding and Auditor's recommendation. B.Actions Taken or Planned We have revised the process of student stipends ofdisbursements. Each student whose account receives a disbursement whom results in a credit balance, will be given stipend prior to any draw down. We shall also make process and procedures with new third-party servicer to ensure stipend is sent prior to drawdown. Signed Betsy Bremke, Administrative Campus Director Date: _3/29/2024__
View Audit 301753 Questioned Costs: $1
FINDING2023-2- Incorrect Pell Grants The Institute incorrectly calculated Pell Grants for thirteen (13) students. A.Comments on Findings and Recommendations: The Institute agrees with the finding and Auditor's recommendation. B.Actions Taken or Planned Previous FA administrator failed to consistentl...
FINDING2023-2- Incorrect Pell Grants The Institute incorrectly calculated Pell Grants for thirteen (13) students. A.Comments on Findings and Recommendations: The Institute agrees with the finding and Auditor's recommendation. B.Actions Taken or Planned Previous FA administrator failed to consistently update student enrollment status in software. This caused incorrect Pell awards to be requested and disbursed. We have revised our method of requesting aid and the enrollment status of each student will be verified individually prior to requesting Pell. We have also removed FA administrator (effective 12/2023) and third-party servicer from their role (effective 4/2024). We will be refunding $3,097 to the Department of Education and crediting $4,239 to the affected student accounts. Signed Betsy Bremke, Administrative Campus Director Date: _3/29/2024__
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