Corrective Action Plans

Finding 561279 (2023-004)

Material Weakness 2023

WA

HUD Housing Programs Eligibility

Prior RHA staff were not ensuring that the Utility Allowance schedules were being completed correctly and matching up to the 50058, which made the HAP incorrect. Of the 40 tenant files sampled by the auditors, 29 files did not have correct utility allowances calculated; 9 files had 50058’s that did...

Prior RHA staff were not ensuring that the Utility Allowance schedules were being completed correctly and matching up to the 50058, which made the HAP incorrect. Of the 40 tenant files sampled by the auditors, 29 files did not have correct utility allowances calculated; 9 files had 50058’s that did not agree with the HAP payments being paid to the landlords and 22 files had rents that did not fall between 90% and 110% of the HUD FMR for the areas. Staff have been replaced and there are no original HCV staff left that were at RHA when the new CEO took over on March 1, 2023. Staff are consistently being trained every week for a minimum of 1 hour a week for 52 weeks out of the year. An HCV Director has been added to supervise the HCV Staff and audits of the files are being completed by the Director of Housing along with the CEO. These issues should be limited and not commonly found by Auditors during future audits.

View Audit 356918

Finding 561278 (2023-003)

Significant Deficiency 2023

Housing Authority of the City of Renton

WA

HUD Housing Programs Allowable Costs / Cost Principles Eligibility

Prior RHA administrative staff were not getting the PHA’s Single Audit completed nor submitted by the deadline. RHA was 3 years behind when the new CEO took over on March 31, 2023. FY2020, FY2021 and FY2022 were not completed and submitted. By the time that these three were caught up, completed...

Prior RHA administrative staff were not getting the PHA’s Single Audit completed nor submitted by the deadline. RHA was 3 years behind when the new CEO took over on March 31, 2023. FY2020, FY2021 and FY2022 were not completed and submitted. By the time that these three were caught up, completed and submitted, that pushed FY2023 Audit to be late. The audit for FY2023 should be completed by the end of April 2025 and then we will be on task to start FY2024 in May and completed by the deadline of September 30, 2025. Then, RHA will stay on task and get these completed within its deadline timeline.

View Audit 356918

Finding 561211 (2023-003)

Significant Deficiency 2023

National Indian Youth Council, Inc.

NM

Eligibility

NIYC has developed new policies and procedures that clearly state that two signers are required for each check and who is authorized to sign checks. Furthermore, NIYC has had a transition of leadership. During the transition, it was communicated the requirement of having two signatures for each chec...

NIYC has developed new policies and procedures that clearly state that two signers are required for each check and who is authorized to sign checks. Furthermore, NIYC has had a transition of leadership. During the transition, it was communicated the requirement of having two signatures for each check as well as any additional corrective action plans.

View Audit 356835

Finding 561089 (2023-004)

Significant Deficiency 2023

Aid for Aids of Nevada

NV

Eligibility § 200.303

2023-004 Internal Control Over Eligibility and Compliance Over Eligibility - U.S. Department of Housing and Urban Development, Housing Opportunities for Persons with AIDS, Assistance Listing Number 14.241, Passed Through the City of Las Vegas, Nevada. Criteria: As defined in 2 CFR 200.303, auditee...

2023-004 Internal Control Over Eligibility and Compliance Over Eligibility - U.S. Department of Housing and Urban Development, Housing Opportunities for Persons with AIDS, Assistance Listing Number 14.241, Passed Through the City of Las Vegas, Nevada. Criteria: As defined in 2 CFR 200.303, auditee is required to maintain a system of internal control over compliance designed to provide reasonable assurance that federal award transactions executed are in compliance with the terms and conditions of the federal award. For services to be provided under the Housing Opportunities for Persons with AIDS, individuals requesting services must meet criteria under the grant which includes providing identification and validating proof of HIV/AIDS diagnosis, income, rent or mortgage payment, and need for assistance. A full validation of these criteria is required to be performed for any individual receiving assistance. Condition: Of 21 files selected for individuals who received assistance under the grant, one selection included two copies of the same support for the client’s need for assistance that contained differing amounts for that client’s earnings during the same period which may be indictive of fraud in the application process. No documentation was included in the client file addressing the inconsistency and related risk of fraud for the earnings and the client was determined to be eligible for assistance when the existence of duplicative information that was not addressed or resolved would make it not possible to determine eligibility for this client. Cause: AFAN had designed controls such that each client file would be reviewed by the lead case manager for proper support of eligibility requirements. However, this internal control system did not detect the duplicative eligibility support that may have been indicative of fraud in the application process, nor did the internal control system identify the individual as being ineligible before providing assistance to the individual. Context: Management failed to consistently and effectively perform an internal control to address the risk of ineligible individuals receiving financial assistance. Effect: Failure to properly perform controls over the review of the client files could result in providing assistance to individuals who are not eligible. The allowance of individuals to receive or continue receiving services without ensuring they meet the eligibility criteria is a violation of the terms of the federal grant agreement. Repeat Finding: No Recommendation: We recommend management design and implement a system of internal controls whereby a review of client files to ensure eligibility is properly supported is performed before any grant funds are disbursed and that management ensures proper documentation of this review is maintained to support the performance of the control. Views of Responsible Officials and Planned Corrective Actions: Management intends to put in place additional training for case managers to identify eligibility of clients and ensure proper backup is submitted. Supervisors will ensure all backup is included in the case file before being submitted.

View Audit 356711

Finding 560679 (2023-004)

Significant Deficiency 2023

Community Action Committee of the Lehigh Valley, Inc. and Subsidiaries

PA

Allowable Costs / Cost Principles Eligibility School Nutrition Programs

U.S. Department of Agriculture Significant Deficiency in Internal Control over Compliance The Emergency Food Assistance Program (Administrative); Commodity Supplemental Food Program (Administrative)– Assistance Listing No. 10.569 and 10.565 Condition: CACLV does not have formal procedures in plac...

U.S. Department of Agriculture Significant Deficiency in Internal Control over Compliance The Emergency Food Assistance Program (Administrative); Commodity Supplemental Food Program (Administrative)– Assistance Listing No. 10.569 and 10.565 Condition: CACLV does not have formal procedures in place to determine the Second Harvest Food Bank expenses incurred during the fiscal year that should be allocated to the TEFAP/CSFP administrative revenue received. CACLV has historically recognized revenue based on when cash is received which is not appropriate. Recommendation: We recommend the allocation of allowable costs and activities be completed at a minimum on a quarterly basis. Also, any direct expenses related to program activities should be recorded to the respective identifying program fund number within the accounting software. The amount of revenue recognized for the programs should be reflected of the expenses incurred up to the administrative funds received from the respective funders. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: The organization will implement a standard allocation to be completed on a quarterly basis at the minimum. This process will be reviewed by management to ensure implementation. Name(s) of the contact person(s) responsible for corrective action: Dawn Godshall, Executive Director Planned completion date for corrective action plan: Planned completion date is June 2025.

View Audit 356548

Finding 560668 (2023-003)

Material Weakness 2023

Community Action Committee of the Lehigh Valley, Inc. and Subsidiaries

PA

Eligibility Subrecipient Monitoring Allowable Costs / Cost Principles

U.S. Department of Agriculture Material Weakness in Internal Control over Compliance Food Distribution Cluster– Assistance Listing No. 10.569 Condition: During our testing, we identified there was no monitoring performed for 2 out of the 21 agencies tested which distributed TEFAP commodities duri...

U.S. Department of Agriculture Material Weakness in Internal Control over Compliance Food Distribution Cluster– Assistance Listing No. 10.569 Condition: During our testing, we identified there was no monitoring performed for 2 out of the 21 agencies tested which distributed TEFAP commodities during fiscal year 2023. Recommendation: The Organization should prioritize the timely monitoring of participating agencies to allow for changes in food distributions if any ineligible participants are discovered. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: The organization developed a schedule to complete monitoring and created a checklist to ensure that all documentation is in the appropriate folder. In addition, the organization began conducting internal audits to ensure the developed processes are being followed. Name(s) of the contact person(s) responsible for corrective action: Dawn Godshall, Executive Director Planned completion date for corrective action plan: Planned completion date is May 2024.

View Audit 356548

Finding 560645 (2023-008)

Material Weakness 2023

Shenandoah School Corporation

IN

School Nutrition Programs Internal Control / Segregation of Duties Eligibility § 200.303

FINDING 2023-008 Finding Subject: Child Nutrition Cluster – Special Tests & Provisions - Verification Summary of Finding: One individual performs the verification process without documented review/oversight by a second employee not involved in this process. The lack of controls resulted in non-compl...

FINDING 2023-008 Finding Subject: Child Nutrition Cluster – Special Tests & Provisions - Verification Summary of Finding: One individual performs the verification process without documented review/oversight by a second employee not involved in this process. The lack of controls resulted in non-compliance in which the procedures performed at the School Corporation and the resulting supporting documentation provided were insufficient to verify the student's eligibility status of one of three students which were verified during the audit period. Contact Person Responsible for Corrective Action: Drew Cooper, Business Manager Contact Phone Number and Email Address: 765-425-7889 dcooper@shenandoah.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The verification process will be performed by Pam Frost and reviewed by the Business Manager. Anticipated Completion Date: December 31, 2024

View Audit 356534

Finding 560633 (2023-005)

Material Weakness 2023

Shenandoah School Corporation

IN

School Nutrition Programs Eligibility Cash Management § 200.303

FINDING 2023-005 Finding Subject: Child Nutrition Cluster - Eligibility Summary of Finding: The School Corporation stated that 100% of Free/Reduced lunch applications were reviewed during the audit period. However, testing of controls indicated that 100% of Free/Reduced lunch applications were not b...

FINDING 2023-005 Finding Subject: Child Nutrition Cluster - Eligibility Summary of Finding: The School Corporation stated that 100% of Free/Reduced lunch applications were reviewed during the audit period. However, testing of controls indicated that 100% of Free/Reduced lunch applications were not being reviewed by an individual other than the individual making the initial determination. As a result, three of forty sampled students received the incorrect eligibility status in the system software when compared to supporting documentation (Direct Certifications and/or income-based applications). Contact Person Responsible for Corrective Action: Drew Cooper, Business Manager Contact Phone Number and Email Address: 765-425-7889 dcooper@shenandoah.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Currently all income based applications for free/reduced lunch status are processed by Pam Frost and then reviewed by the Business Manager. Beginning in the 2024-2025 school year Direct Certification students will also be reviewed by the Business Manager. Anticipated Completion Date: August 31, 2024

View Audit 356534

Finding 560566 (2023-004)

Significant Deficiency 2023

Town of Coventry, Rhode Island

RI

Procurement, Suspension & Debarment Questioned Costs Subrecipient Monitoring § 200.213 § 200.303

Finding 2023-004 - Significant Deficiency in Internal Control over Compliance, Other Matters Description of Finding The Town of Coventry and Coventry Public School Department do not have policies and procedures in place to ensure that they do not contract with or make subawards to parties that are ...

Finding 2023-004 - Significant Deficiency in Internal Control over Compliance, Other Matters Description of Finding The Town of Coventry and Coventry Public School Department do not have policies and procedures in place to ensure that they do not contract with or make subawards to parties that are suspended or debarred. Statement of Concurrence or Nonconcurrence Management concurs with the finding. Corrective Action Management of the Town and School Department will review the district’s suspension and debarment policy and make sure that it is following the criteria as set out in the 2 CFR section 180 of the Uniform Guidance. The policy will then be updated and communicated to all personnel involved in the procurementprocess. Name of Contact Person Robert J. Civetti, CPA, Town Finance Director; Christopher Deverna, CPA, Director of Finance, Coventry Public Schools Projected Completion Date June 30, 2025

View Audit 356492

Finding 560404 (2023-002)

Significant Deficiency 2023

The Pines Housing, Inc.

OR

Eligibility HUD Housing Programs Reporting

Finding Reference Number: 2023-002 Condition: As of December 12, 2024, management was unable to provide tenant income documents for 2 tenant files of 7 tenant files sampled out of the population (66 total tenant files). Management was unable to provide tenant security deposit documents for all 3 mov...

Finding Reference Number: 2023-002 Condition: As of December 12, 2024, management was unable to provide tenant income documents for 2 tenant files of 7 tenant files sampled out of the population (66 total tenant files). Management was unable to provide tenant security deposit documents for all 3 move-ins and move-outs sampled out of the population (9 total move-ins and 13 total move-outs during the audit period). Recommendation: We recommend that control systems are put in place to ensure there are regular reviews of tenant files to enable management to identify deficiencies and provide training, guidance, and procedures to eliminate errors and issues of noncompliance in the future. Reporting views of responsible officials Our Just Future, on behalf of The Pines Housing, Inc., both concurs with these findings and agrees with auditor recommendations. Completion date or proposed completion date: December 18, 2024 Action(s) taken or planned on the finding To address this finding, OJF will take the following actions: 1. Implement regular tenant file reviews at least semi-annually beginning January 15, 2025 a. Responsible party: OJF asset management director and property management portfolio manager 2. Develop a mandatory training program on compliance requirements for property management site staff to follow by February 15, 2025 a. Responsible party: OJF asset management director and property management portfolio manager 3. Revise and distribute existing tenant file management procedures by February 15, 2025 a. Responsible party: OJF asset management director and property management portfolio manager 4. Establish a monitoring and feedback system by March 15, 2025 for site staff to seek guidance on or report challenges of file management so that advice can be given and/or corrective action taken a. Responsible party: OJF asset management director and property management portfolio manager 5. Conduct quarterly management reviews beginning 4/15/2025 to discuss and evaluate the effectiveness of above actions a. Responsible party: OJF asset management director and property management portfolio manager

View Audit 356309

Finding 560385 (2023-002)

Significant Deficiency 2023

Public Housing Authority of Butte

MT

HUD Housing Programs Eligibility Reporting

The Public Housing Authority of Butte will contract with the Certified Public Accounting firm to assist with timely submission of the FY 2024 unaudited Financial Data Schedule. This will provide su icient time for the audit to get completed by the audited FASSPHA deadline.

View Audit 356277

Finding 560309 (2023-002)

Material Weakness 2023

Windsor Housing Authority

CT

HUD Housing Programs Subrecipient Monitoring Eligibility

2023-002- ELIGIBILITY Material Weakness/Noncompliance Auditee’s Response and Planned Corrective Action We follow HUD guidelines where required and Untimely recertifications are typically not within the control of the Housing Authority. Encompassing HUD guidelines, the recertification process for ten...

2023-002- ELIGIBILITY Material Weakness/Noncompliance Auditee’s Response and Planned Corrective Action We follow HUD guidelines where required and Untimely recertifications are typically not within the control of the Housing Authority. Encompassing HUD guidelines, the recertification process for tenants begins 90 days prior to the recert date, but if tenants do not provide all the requested information, the recertification will be delayed until the information is provided, tenant is converted to a market rate rent, or we begin the termination process for termination of the voucher. We will continue to follow the HUD process for the management of the Housing Choice Voucher Programs/Mainstream voucher programs. Planned Implementation Date of Corrective Action: Immediately Person Responsible for Corrective Action: Maria DeMarco, President of DeMarco Management Corporation

View Audit 356224

Finding 559943 (2023-005)

Material Weakness 2023

Kings Mountain Housing Authority

NC

Cash Management HUD Housing Programs Procurement, Suspension & Debarment

Name of Contact Person: Veronica Williams, Interim Executive DirectorCorrective Action:KHMA’s Board has approved new written policies and procedures and are in place now.Appropriate staff have begun taking proper safeguards for Capital Fund Program management to ensure proper accountability. This in...

Name of Contact Person: Veronica Williams, Interim Executive DirectorCorrective Action:KHMA’s Board has approved new written policies and procedures and are in place now.Appropriate staff have begun taking proper safeguards for Capital Fund Program management to ensure proper accountability. This includes the oversight of processing payments of CFP expenditures, which includes the following procedures for: 1) payment of invoices; 2) requisition of funds; 3) monitoring; and 4) reporting of CFP funds.payment of InvoicesAll CFP invoices will be reviewed and clearly marked as approved and documented to show that the source of funds for payment are CFP grant funds by the Executive Director prior to payment. The Executive Director will specify the general ledger code, including the BLI account to be used for payment processing on the invoice before providing the invoice to the accounts payable clerk.Under no circumstances will a payment be made if KMHA has not drawdown and received the respective CFP funds.With the exception of funds associated with BLI 1406 “Operations”, PHAs have three (3) business days to issue and mail the check once the CFP funds are received.The Executive Director/accounts payable clerk will specify the BLI account and CFP grant year on the check voucher prior to sending the check voucher to the fee accountant for financial statement processing.Requisition of FundsFor each drawdown, the Executive Director will print the associated eLOCCS Voucher Payment form from the eLOCCS system.The Executive Director will document the check number(s) and vendor(s) associated with each CFP draw (i.e., the eLOCCS Voucher Payment form). In addition, each individual draw shall be numbered for reference purposes.A copy of each draw shall be submitted to the fee accountant to ensure proper reporting of the grant drawdown.With the exception of funds associated with BLI 1406 “Operations”, in no case shall a draw be made without the proper approved invoices.MonitoringThe fee accountant's monthly financial statements will include a CFP report for each grant which will be reviewed by the Executive Director for proper coding and accuracy.Folder has been created to track all required information in the management of a CFP grant to include correspondence to and from HUD, expenses, grant reimbursements, budgets, closeout documentation and EPIC management.Proposed Completion Date: Immediately

View Audit 355868

Finding 559265 (2023-002)

Significant Deficiency 2023

Oklahoma City Innovation District, Inc.

OK

Eligibility Reporting Matching / Level of Effort / Earmarking § 200.512

Recommendation: We recommend that management implement processes to ensure timely completion and submission of the Single Audit report in future years. This could include setting internal deadlines, increasing oversight, and coordinating with the audit firm to identify and address potential delays e...

Recommendation: We recommend that management implement processes to ensure timely completion and submission of the Single Audit report in future years. This could include setting internal deadlines, increasing oversight, and coordinating with the audit firm to identify and address potential delays earlier in the audit process. Action Taken: Management agrees with the finding and will take steps to improve the timeliness of the audit process. Anticipated completion date: June 30, 2025 Name of contact person and title: Jeffrey Seymour, President / CEO

View Audit 355490

Finding 555922 (2023-001)

Material Weakness 2023

Cheyenne and Arapaho Tribes Department of Housing

OK

Questioned Costs Eligibility HUD Housing Programs

2023-001 Condition: Deficiencies Noted in Maintenance of Tenant Files Steps to resolve: Management agrees with the audit finding and the auditor’s recommendation. We will implement procedures and changes to ensure that this finding will be cleared by the subsequent fiscal year audit. Individua...

2023-001 Condition: Deficiencies Noted in Maintenance of Tenant Files Steps to resolve: Management agrees with the audit finding and the auditor’s recommendation. We will implement procedures and changes to ensure that this finding will be cleared by the subsequent fiscal year audit. Individual responsible for correction: Mr. Damon Dunbar, Executive Director Timeframe: As of December 31, 2025

View Audit 354589

Finding 555823 (2023-003)

Material Weakness 2023

Open Cities Health Center, Inc. and Affiliate

MN

Eligibility Special Tests & Provisions Subrecipient Monitoring

Finding 2023-003 Compliance Requirement: Special Tests and Provisions-Sliding Fee Discounts Material Weakness Assistance Living Number 93.224 Health Center Programs Grant Award Number H80CS00112 US Department of Health and Human Services Condition and Context: Documents to verify income could not ...

Finding 2023-003 Compliance Requirement: Special Tests and Provisions-Sliding Fee Discounts Material Weakness Assistance Living Number 93.224 Health Center Programs Grant Award Number H80CS00112 US Department of Health and Human Services Condition and Context: Documents to verify income could not be located for six of the twenty-five patients selected for testing. Also, there was no documentation of family size for five of the patients in this sample. The result is that we were unable to determine eligibility for a total of seven of the fourteen tested. Action Planned in Response to the Finding: Procedures will be implemented and actively monitored to ensure that all supporting documentation used to determine patient eligibility is properly collected, maintained, and retained. These procedures will help ensure compliance with applicable guidelines and support the accuracy and integrity of eligibility determinations. Official Responsible for Ensuring the CAP: Sabrina SalazarPlanned Completion Date: December 2024

View Audit 354532

Finding 555632 (2023-013)

Significant Deficiency 2023

Sullivan County Community College

NY

Eligibility

The College will seek to update the Satisfactory Academic Progress policy to include all required criteria. The College will also ensure that a periodic review of this policy is made known on its budget calendar. This will be accomplished by 4‐25‐2025

View Audit 354200

Finding 555499 (2023-005)

Significant Deficiency 2023

Sacramento Housing and Revelopment Agency

CA

HUD Housing Programs Subrecipient Monitoring Eligibility

Recommendation: We recommend management should designate one person to review a sample of the files that have been recertified each month. The purpose of the review is to determine if the tenant files were prepared in accordance with internal policies and verify the compliance deficiencies have been...

Recommendation: We recommend management should designate one person to review a sample of the files that have been recertified each month. The purpose of the review is to determine if the tenant files were prepared in accordance with internal policies and verify the compliance deficiencies have been corrected. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: To prevent a recurrence of the issue, we have implemented a comprehensive corrective action plan. Staff developed a Public Housing File Order Checklist, written Standard operating Procedures (SOP’s) for interviewing tenants; conducting income examinations and re-examinations; verifying income eligibility using third-party verification; and determining income eligibility and calculating the tenant’s rent payment. Additionally, SHRA developed an Intake Caseworker Training Schedule to assist staff with accurately determining program eligibility. Detailed supporting documentation can be found at the following link: https://sachousing.box.com/s/or3rc8z1hml3hhxmp9f0e2t31yv6odyo Name(s) of the contact person(s) responsible for corrective action: Irene De Jong, DIRECTOR OF FINANCE Planned completion date for corrective action plan: December 31, 2025

View Audit 354004

Finding 555491 (2023-002)

Material Weakness 2023

Sacramento Housing and Revelopment Agency

CA

Questioned Costs HUD Housing Programs Subrecipient Monitoring

Recommendation: We recommend that management should designate one person to review a sample of the files that have been recertified each month. The purpose of the review is to determine if the tenant files were prepared in accordance with internal policies and verify the compliance deficiencies have...

Recommendation: We recommend that management should designate one person to review a sample of the files that have been recertified each month. The purpose of the review is to determine if the tenant files were prepared in accordance with internal policies and verify the compliance deficiencies have been corrected. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: To prevent a recurrence of the issue, we have implemented a comprehensive corrective action plan. Specifically, we developed a comprehensive Standard Operating Procedure (SOP) for file reviews related to recertification. Additionally, the HCV Operations Unit is reviewing a sample of completed recertifications monthly to ensure compliance. Detailed supporting documentation can be found at the following link: https://sachousing.box.com/s/fiqoaoddr7ae6nydf63f1mhwfnrpzfr6 Name(s) of the contact person(s) responsible for corrective action: MaryLiz Paulson, Director, Housing Choice Vouchers Planned completion date for corrective action plan:: December 31, 2025

View Audit 354004 Questioned Costs: $1

Finding 554140 (2023-013)

Material Weakness 2023

State of California

CA

Subrecipient Monitoring Internal Control / Segregation of Duties Questioned Costs § 200.303

The CDSS disagrees with the finding. California’s subsidized child care system is locally operated. The CDSS relies on hundreds of local county offices and nonprofit agencies to administer child care and development programs at the local level, rather than having the State pay subsidized providers d...

The CDSS disagrees with the finding. California’s subsidized child care system is locally operated. The CDSS relies on hundreds of local county offices and nonprofit agencies to administer child care and development programs at the local level, rather than having the State pay subsidized providers directly. As a result, CDSS required Alternative Payment Programs, direct-service contractors that administer Family Child Care Home Education Networks, and fiscal partners to track survey completion as a prerequisite for awarding American Rescue Plan Act (ARPA) subgrants. This local infrastructure and the size of California’s subsidized child care and development system separates California from other states. As a result, CDSS worked very closely with the federal grantor, the Administration for Children and Families, to ensure that the ARPA survey methodology met federal monitoring requirements and tracked data elements required by the federal government. For this reason, CDSS believes it has fulfilled its responsibility and does not need to further establish a monitoring program. Estimated Implementation Date: Will not implement Contact: Jeff Fowler, Staff Services Manager III Child Care and Development Program California Department of Social Services

View Audit 352774 Questioned Costs: $1

Finding 554133 (2023-017)

Significant Deficiency 2023

State of California

CA

Eligibility Internal Control / Segregation of Duties Questioned Costs § 200.303

Public Health’s Office of AIDS (OA) agrees with the finding and recommendation. OA introduced and fully implemented an internal Secondary Review (SR) process for all AIDS Drug Assistance Program (ADAP) applications in March 2018. This SR process enables ADAP staff to verify that contracted and certi...

Public Health’s Office of AIDS (OA) agrees with the finding and recommendation. OA introduced and fully implemented an internal Secondary Review (SR) process for all AIDS Drug Assistance Program (ADAP) applications in March 2018. This SR process enables ADAP staff to verify that contracted and certified enrollment workers across California are consistently adhering to eligibility and documentation requirements. However, due to staffing challenges caused by the redirection of staff during the state of emergency declared for the COVID-19 pandemic, ADAP faced significant workforce shortages from March 2020 through much of 2023. This caused a backlog in SR processing, which delayed tasks, including the review of this client’s application. The client’s eligibility lapsed after 130 days, before SR could be conducted. The Eligibility Operations Section (EOS) of ADAP which conducts SR, is now fully staffed and has successfully addressed the backlog. As of early 2024, SR processing has returned to normal operations and is current. Estimated Implementation Date: Already implemented as of April 2024 Contact: Joseph Lagrama, ADAP Branch Chief California Department of Public Health

View Audit 352774

Finding 554128 (2023-007)

Material Weakness 2023

State of California

CA

Subrecipient Monitoring Eligibility Matching / Level of Effort / Earmarking § 200.303 § 200.322 § 200.332

The Chancellor’s Office established and implemented SLFRF emergency financial assistance grants policies and procedures. The policies and procedures can be found on the following website: State Fiscal Recovery Funds - Emergency Financial Assistance for California Community College Students. These po...

The Chancellor’s Office established and implemented SLFRF emergency financial assistance grants policies and procedures. The policies and procedures can be found on the following website: State Fiscal Recovery Funds - Emergency Financial Assistance for California Community College Students. These policies and procedures included a self-certification process to certify that students met SLFRF eligibility requirements, expenditure tracking and management information system data reporting, a monitoring plan, and state compliance procedures through the annual Contracted District Audit Manual for the 2021-22, 2022-23, and 2023-24 fiscal years. The Chancellor’s Office intends to include SLFRF compliance procedures in the upcoming 2024-25 fiscal year Contracted District Audit Manual. The intent of both the policies and procedures as well as the Audit requirements are intended to address the Chancellor’s Office need to: (1) maintain effective internal controls regarding its use of the applicable SLFRF Federal award funding, (2) assess each community college’s risk of potential noncompliance with SLFRF subaward federal statutes, regulations and terms and conditions, and (3) validate that community colleges expended the SLFRF resources in accordance with federal statutes, regulations and terms and conditions. The Chancellor’s Office will coordinate with the Department of Finance as needed to revise the funding source of expenditures that are determined to be ineligible to be supported by SLFRF resources. The Chancellor’s Office will also work with community college districts to ensure any SLFRF funds awarded to ineligible students are adjusted in districts’ accounting records to the proper state funding source. The Chancellor’s Office will continue to communicate the SLFRF emergency financial assistance grants policies and procedures to California Community districts as needed. Additionally, the Chancellor’s Office will continue to receive copies of each district’s annual audit and audit findings as determined through the Contracted District Audit Manual process. The Chancellor’s Office will also continue to review and revise the SLFRF policies and procedures, and memorandums as needed to ensure the required federal award identification information and retention process information is available to community college districts. In conclusion, the Chancellor’s Office appreciates the focus toward ensuring the successful implementation of the emergency financial assistance grant program and in support of our students’ success. The SLFRF grants provided low-income students who were disproportionately impacted by the COVID-19 pandemic emergency support to continue with their enrollment, improve their economic mobility, complete their educational goals, and contribute to California’s economy in a meaningful way. Estimated Implementation Date: December 15, 2025 Contact: Chris Ferguson Executive Vice Chancellor of Finance and Strategic Initiatives California Community Colleges Chancellor’s Office

View Audit 352774

Finding 554122 (2023-005)

Significant Deficiency 2023

State of California

CA

Eligibility Reporting Internal Control / Segregation of Duties § 200.303

As reported in the prior year’s response, since fiscal year 2020-21, the Employment Development Department (EDD) has implemented dozens of strict anti-fraud measures and has continued to evaluate and enhance its fraud detection. EDD has also developed internal fraud working groups and a multiagency ...

As reported in the prior year’s response, since fiscal year 2020-21, the Employment Development Department (EDD) has implemented dozens of strict anti-fraud measures and has continued to evaluate and enhance its fraud detection. EDD has also developed internal fraud working groups and a multiagency fraud task force that reviews fraud data and fraud reports on a continual basis and recommends adjustments to filters and tools as necessary. EDD has successfully halted two large fraud scheme attempts over the previous two years and continues to work towards immediate detection and prevention of fraud attempts. EDD will continue to analyze and assess our processes to stay ahead of the ever-evolving fraud landscape. As previously described, EDD implemented the following measures to address the nationwide fraud attempts perpetrated against the new emergency federal benefit programs in 2020-21: • Implemented additional cross-matches in September 2020 to detect multiple claims per address. • Ceased automatically backdating PUA claims under federal rules in September 2020. • Strengthened identity verification procedures in October 2020 by implementing ID.me. • Implemented additional cross-matches in November 2020 against state inmate information. • Vetted applications against law enforcement databases and other tools provided by Thomson Reuters in December 2020 to further curb identity and non-identity fraud. • Established a 1099-G call center to help victims of identity theft deal with any tax-related questions. • Ceased printing Social Security numbers on mailed documents to reduce identity theft risk. • Enhanced benefit card security with Bank of America. • Partnered with state, local and federal law enforcement agencies to support thousands of criminal investigations, arrests, prosecutions and convictions. Estimated Implementation Date: Completed September 2024 Contact: Diane Underwood, Division Chief Unemployment Insurance Branch California Employment Development Department

View Audit 352774 Questioned Costs: $1

Finding 554121 (2023-004)

Material Weakness 2023

State of California

CA

Eligibility Internal Control / Segregation of Duties Questioned Costs § 200.303

As reported in the prior year’s response, given the unprecedented volume of unemployment insurance claims during the federal disaster—approximately 20 million claims compared to 3.8 million during the Great Recession—EDD took action to speed payments to eligible claimants whenever possible. For exam...

As reported in the prior year’s response, given the unprecedented volume of unemployment insurance claims during the federal disaster—approximately 20 million claims compared to 3.8 million during the Great Recession—EDD took action to speed payments to eligible claimants whenever possible. For example, EDD launched in July 2021 a Conditional Payment Program to speed payments to claimants who certified for benefits and already received at least one week of benefits in the past but whose payments were later pending for more than two weeks. EDD also boosted its capacity to process workloads, prioritized timely payments, and employed automation among other measures. EDD began automatically cross-matching EDD wage records and Franchise Tax Board records in November 2020 to assist in verifying the income of PUA claimants who could not be automatically verified through these procedures. Such claimants were required to submit additional documentation to EDD for a manual review. Regarding the manual processing of the income documents to substantiate the PUA weekly benefit amounts that have been increased above the minimum California WBA of $167, and the verification of employment or self-employment substantiation (known in California as “Self-employment/Employment Substantiation” or “SEES”), based on the U.S. Department of Labor’s (DOL) guidance in Unemployment Insurance Program Letter 05 24, EDD notified DOL on February 6, 2024, that California Unemployment Insurance Code (CUIC) section 1376 bars EDD from resolving the wage verification and self-employment verification items. Section 1376 provides that EDD cannot establish overpayments more than one year after the close of the benefit year in which the overpayment was made unless the overpayment is found to be a result of fraud, misrepresentation, or willful nondisclosure. Given that there is no fraud in creating these overpayments on the part of the individuals identified in these populations, EDD is no longer able to establish overpayments for these populations. On May 31, 2024, DOL notified EDD that the February 6, 2024, submission regarding how California’s finality laws affect the actions required to correct the wage verification and self-employment findings is sufficient to close these findings. Estimated Implementation Date: Completed May 2024 Contact: Diane Underwood, Division Chief Unemployment Insurance Branch California Employment Development Department

View Audit 352774 Questioned Costs: $1

Finding 554120 (2023-003)

Significant Deficiency 2023

State of California

CA

Eligibility Reporting Questioned Costs § 200.303

Reference No. 2023-003: The EDD resumed adjudicating all potential eligibility issues as of January 2021 and completed the retroactive determination workload on April 30, 2023. Estimated Implementation Date: Completed April 2024 Contact: Diane Underwood, Division Chief Unemployment Insurance Branch ...

Reference No. 2023-003: The EDD resumed adjudicating all potential eligibility issues as of January 2021 and completed the retroactive determination workload on April 30, 2023. Estimated Implementation Date: Completed April 2024 Contact: Diane Underwood, Division Chief Unemployment Insurance Branch California Employment Development Department

View Audit 352774 Questioned Costs: $1

Corrective Action Plans

Filters