Corrective Action Plans

Finding 504182 (2023-002)

Significant Deficiency 2023

Life Source International Charter School

CA

Questioned Costs Eligibility Subrecipient Monitoring § 200.308 § 200.309 § 200.403

3. Staff Training and Capacity Building: Our staff has received training on federal grant compliance, including the specific criteria governing the period of performance and allowable costs under federal awards. Additionally, with the Sage system in place, staff are now better equipped to manage com...

3. Staff Training and Capacity Building: Our staff has received training on federal grant compliance, including the specific criteria governing the period of performance and allowable costs under federal awards. Additionally, with the Sage system in place, staff are now better equipped to manage compliance and reporting accurately.

View Audit 326634 Questioned Costs: $1

Finding 504182 (2023-002)

Significant Deficiency 2023

Life Source International Charter School

CA

Questioned Costs Eligibility Subrecipient Monitoring § 200.308 § 200.309 § 200.403

4. Commitment to Ongoing Compliance: We are committed to continually improving our internal control processes to ensure compliance with all federal regulations.

View Audit 326634 Questioned Costs: $1

Finding 504090 (2023-008)

None 2023

Cottey College

MO

Questioned Costs Student Financial Aid Eligibility

2023-008 Student Financial Aid Cluster (a) Federal Supplemental Educational Opportunity Grant (b) Federal Work Study Grant (c) Federal Pell Grant Program (d) Federal Direct Loan Program, Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.063 (d) 84.268 - Year Ended June 30, 2023 Condition: During o...

2023-008 Student Financial Aid Cluster (a) Federal Supplemental Educational Opportunity Grant (b) Federal Work Study Grant (c) Federal Pell Grant Program (d) Federal Direct Loan Program, Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.063 (d) 84.268 - Year Ended June 30, 2023 Condition: During our testing of thirty-seven student files, we noted one individual (2.7%) received an excess of $1,969 over the maximum undergraduate level of $23,000 in Federal Direct Subsidized Loans. Corrective Action Plan: During the 2022-23 school year, an employee who retired in May 2023 awarded all returning student institutional aid and federal aid. Upon her retirement, Hannah Masters, Executive Director of Financial Aid and Student Accounts, took over awarding all students (incoming and returning students). Starting in June 2023, Hannah awards all students based on enrollment status from Jenzabar 1 (Cottey's ERP) for returning students and Salesforce for incoming students. Then on census date, the Registrar sends an updated final report of student grade level and attempted credit hours. Hannah then reviews all student accounts manually and confirms the enrollment, grade level, and loan levels for each student. This ensures no student is under or over awarded for the term based on grade level or financial need. Responsible Person for Correction Action Plan: Hannah Masters Implementation Date for Corrective Action Plan: June 2023

View Audit 326482 Questioned Costs: $1

Finding 504085 (2023-006)

None 2023

Cottey College

MO

Questioned Costs Student Financial Aid Eligibility

2023-006 Student Financial Aid Cluster (a) Federal Supplemental Educational Opportunity Grant (b) Federal Work Study Grant (c) Federal Pell Grant Program (d) Federal Direct Loan Program, Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.063 (d) 84.268 - Year Ended June 30, 2023 Condition: During o...

2023-006 Student Financial Aid Cluster (a) Federal Supplemental Educational Opportunity Grant (b) Federal Work Study Grant (c) Federal Pell Grant Program (d) Federal Direct Loan Program, Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.063 (d) 84.268 - Year Ended June 30, 2023 Condition: During our testing of thirty-seven student files, we noted two individuals (5%) did not receive the full amount of their Federal Direct Subsidized Loans. We consider this condition to be an instance of non-compliance relating to the Eligibility compliance requirement. Statistical sampling was not used in making sample selections. Corrective Action Plan: During the 2022-23 school year, an employee who retired in May 2023 awarded all returning student institutional aid and federal aid. Upon her retirement, Hannah Masters, Executive Director of Financial Aid and Student Accounts, took over awarding all students (incoming and returning students). Starting in June 2023, Hannah awards all students based on enrollment status from Jenzabar 1 (Cottey's ERP) for returning students and Salesforce for incoming students. Then on census date, the Registrar sends an updated final report of student grade level and attempted credit hours. Hannah then reviews all student accounts manually and confirms the enrollment, grade level, and loan levels for each student. This ensures no student is under or over awarded for the term based on grade level or financial need. With the staffing changes, we are also now reviewing each package every time a FAFSA update is imported. This gives us another round of reviews to ensure students are not over or under awarded based on financial need. Responsible Person for Correction Action Plan: Hannah Masters Implementation Date for Corrective Action Plan: June 2023

View Audit 326482 Questioned Costs: $1

Finding 504082 (2023-004)

Significant Deficiency 2023

Cottey College

MO

Questioned Costs Student Financial Aid Eligibility

2023-004 Student Financial Aid Cluster (a) Federal Supplemental Educational Opportunity Grant (b) Federal Work Study Grant (c) Federal Pell Grant Program (d) Federal Direct Loan Program, Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.063 (d) 84.268 - Year Ended June 30, 2023 Condition: The Coll...

2023-004 Student Financial Aid Cluster (a) Federal Supplemental Educational Opportunity Grant (b) Federal Work Study Grant (c) Federal Pell Grant Program (d) Federal Direct Loan Program, Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.063 (d) 84.268 - Year Ended June 30, 2023 Condition: The College did not report actual loan disbursement dates to the Common Origination and Disbursement (COD) system for 5 of the 37 students in the sample (13.5%). We consider this condition to be a significant deficiency in internal control over compliance relating to the Eligibility compliance requirement and is a repeat finding shown in Section IV of this report as prior year finding 2022-003. Statistical sampling was not used in making sample selections. Corrective Action Plan: During the 2022-23 school year, an employee who retired in May 2023 worked in the financial aid office. After retiring, a new position was created that is split between the Business Office and Financial Aid and Student Accounts office. This position now reviews student accounts weekly, and during that review they compare the date of disbursement to the student account and the date of disbursement in COD. Through this process, any mismatched dates are corrected and updated to COD. Due to the audit completion delay, our action plan for the previous audit could not be put into place before the year had already been completed. Below is the previous audit plan to show that it was implemented, however, timing meant implementation happened after the 2022-23 year had ended. The financial aid office is currently hiring for a new position that will oversee student accounts. Once this position is filled, we will implement our updated policy and procedure that requires review and collaboration to monitor COD disbursement date, financial aid software disbursement date and student billing statement disbursement date. This will ensure both financial aid staff and student accounts staff will confirm each date in all areas. Planned completion date for corrective action plan: 06/30/2023 Responsible Person for Correction Action Plan: Hannah Masters Implementation Date for Corrective Action Plan: June 2023

View Audit 326482 Questioned Costs: $1

Finding 504081 (2023-003)

None 2023

Cottey College

MO

Questioned Costs Student Financial Aid Eligibility

2023-003 Student Financial Aid Cluster (a) Federal Supplemental Educational Opportunity Grant (b) Federal Work Study Grant (c) Federal Pell Grant Program (d) Federal Direct Loan Program, Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.063 (d) 84.268 - Year Ended June 30, 2023 Condition: During o...

2023-003 Student Financial Aid Cluster (a) Federal Supplemental Educational Opportunity Grant (b) Federal Work Study Grant (c) Federal Pell Grant Program (d) Federal Direct Loan Program, Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.063 (d) 84.268 - Year Ended June 30, 2023 Condition: During our testing of thirty-seven student files, we noted three individuals (8%) received a subsidized loan in excess of need. We consider this condition to be an instance of non-compliance relating to the Eligibility compliance requirement. Statistical sampling was not used in making sample selections. Corrective Action Plan: During the 2022-23 school year, an employee who retired in May 2023 awarded all returning student institutional aid and federal aid. Hannah Masters, Executive Director of Financial Aid and Student Accounts, took over awarding all students (incoming and returning students). Starting in June 2023, Hannah awards all students based on enrollment status from Jenzabar 1 (Cottey's ERP) for returning students and Salesforce for incoming students. Upon census date, the Registrar sends an updated final report of student grade level and attempted credit hours. Hannah then reviews all student accounts manually and confirms the enrollment, grade level, and loan levels for each student. This ensures no student is under or over awarded for the term based on grade level or financial need. With the staffing changes, we are also now reviewing each package every time a FAFSA update is imported. This gives us another round of reviews to ensure students are not over or under awarded based on financial need. Responsible Person for Correction Action Plan: Hannah Masters Implementation Date for Corrective Action Plan: June 2023

View Audit 326482 Questioned Costs: $1

Finding 504040 (2023-003)

Material Weakness 2023

MacOnaquah School Corporation

IN

School Nutrition Programs Internal Control / Segregation of Duties Subrecipient Monitoring § 200.303 § 200.334

FINDING 2023-003 Finding Subject: Child Nutrition Cluster - Eligibility Summary of Finding: The School Corporation had not properly designed or implemented a system of internal controls, which would include appropriate segregation of duties, that would likely be effective in preventing, or detecting...

FINDING 2023-003 Finding Subject: Child Nutrition Cluster - Eligibility Summary of Finding: The School Corporation had not properly designed or implemented a system of internal controls, which would include appropriate segregation of duties, that would likely be effective in preventing, or detecting and correcting, noncompliance related to the eligibility determination of a child receiving meals. The School Corporation could not provide documentation supporting the eligibility for 10 of 40 students that received free or reduced-price meals for fiscal year 2022-2023. Of the 30 students for which documentation was provided, the School Corporation could not provide documentation that the one student’s benefits were calculated properly. Due to the lack of supporting documentation we were unable to determine the School Corporation's compliance with the Eligibility compliance requirement. Contact Person Responsible for Corrective Action: Juli Windsor Contact Phone Number:765-689-9131 Views of Responsible Official: We concur with the finding Description of Corrective Action Plan: This will include all reimbursements which are submitted to the treasurer must be signed by the school cafeteria managers and the food service director. The school will also implement policies to ensure that the Verification of Free and Reduced-Price applications have an adequate internal control to ensure the validity of the free and reduced applications. This will provide for segregation of duties to ensure appropriate reviews, approvals, and oversight are taking place. Anticipated Completion Date: April 2024

View Audit 326469

Finding 503828 (2023-003)

Material Weakness 2023

City of Framingham

MA

Eligibility Material Weakness Internal Control / Segregation of Duties

Recommendation: We recommend procedures to maintain records related to eligibility determinations be implemented/strengthened. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Adult Education department will now...

Recommendation: We recommend procedures to maintain records related to eligibility determinations be implemented/strengthened. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Adult Education department will now scan in the physical intake form that Adult ESL students self-report their eligibility status for MA DESE ACLS as well as have the student sign that form. This form will be stored electronically in addition to the information from the form being entered into the Adult ESL Access database and LACES . Name(s) of the contact person(s) responsible for corrective action: Dr. Kevin O’Connor, Claudia Castro Alves and Kate Fiore Planned completion date for corrective action plan: Effective as of 08/01/2024

View Audit 326124

Finding 503579 (2023-002)

Material Weakness 2023

Coalition on Homelessness and Housing in Ohio

OH

Questioned Costs Allowable Costs / Cost Principles Subrecipient Monitoring

Finding Reference Number: 2023-002 Name of Responsible Person: Amy Reigel, Executive Director Reporting Views of Responsible Officials: We concur that multiple grants are being tracked in the same accounts making it difficult to determine if the expenditures billed to the specific federal award to ...

Finding Reference Number: 2023-002 Name of Responsible Person: Amy Reigel, Executive Director Reporting Views of Responsible Officials: We concur that multiple grants are being tracked in the same accounts making it difficult to determine if the expenditures billed to the specific federal award to were charged to the grants in the period of performance. Concur or Do Not Concur with this Finding: Concur Agree or Disagree with Auditor Recommendations: Agree Completion Date or Proposed Completion Date: December 31, 2024 Actions Taken or Planned on this Finding: COHHIO's chart of accounts / financial management system will be updated to track each grant in a separately.

View Audit 325755 Questioned Costs: $1

Finding 503071 (2023-006)

Material Weakness 2023

Point of Freedom

OH

Matching / Level of Effort / Earmarking Subrecipient Monitoring Eligibility

Finding 2023-006 Supporting Documents for Eligibility Requirements During September 2024, POF updated its Housing Procedures Manual in compliance with Section 200.303 of Uniform Guidance and Ohio Recovery House Regulations. This document now more fully addresses, among other things, eligibility and...

Finding 2023-006 Supporting Documents for Eligibility Requirements During September 2024, POF updated its Housing Procedures Manual in compliance with Section 200.303 of Uniform Guidance and Ohio Recovery House Regulations. This document now more fully addresses, among other things, eligibility and required minimum documentation standards. POF has already begun to build individual client files to retain and periodically update these required supporting documents for all Its affected residential clients.

View Audit 325057

Finding 503035 (2023-008)

Material Weakness 2023

County of Orangeburg

SC

Internal Control / Segregation of Duties Allowable Costs / Cost Principles Eligibility

The County is in the process of hiring a Grants Administrator who will be responsible for the allowable cost compliance requirement of State and Local Fiscal Recovery (SLFRF). The Grants Administrator, along with the Chief Financial Officer and Financial Services Division Director will review and up...

The County is in the process of hiring a Grants Administrator who will be responsible for the allowable cost compliance requirement of State and Local Fiscal Recovery (SLFRF). The Grants Administrator, along with the Chief Financial Officer and Financial Services Division Director will review and update the policies and procedures to ensure all internal controls are being followed in order to be compliant with the Uniform Guidance and SLFRF Program.

View Audit 325007

Finding 502955 (2023-005)

Significant Deficiency 2023

Urban League of Metropolitan Seattle

WA

Allowable Costs / Cost Principles Eligibility Significant Deficiency

Finding Number 2023-005 Contact Person(s): Mansour Camara, CFO, Carmelle Palomino, Controller Corrective Action Planned: Management reviewed the document retention policy with all program managers and directors and IT created online files for each department to retain program documents as per the ...

Finding Number 2023-005 Contact Person(s): Mansour Camara, CFO, Carmelle Palomino, Controller Corrective Action Planned: Management reviewed the document retention policy with all program managers and directors and IT created online files for each department to retain program documents as per the policy. Management will conduct implementation audits for each department. Anticipated Completion Date: Date completed 10/31/2024

View Audit 324915

Finding 502738 (2023-007)

Significant Deficiency 2023

Martin University

IN

Questioned Costs Eligibility Significant Deficiency § 200.303

United States Department of Education 2023-007 Student Financial Aid Cluster – Assistance Listing No. 84.063 Condition: Students were disbursed Pell funds inaccurately. Auditors’ Recommendation: We recommend the University implement policies to review all student award packages at the start of the ...

United States Department of Education 2023-007 Student Financial Aid Cluster – Assistance Listing No. 84.063 Condition: Students were disbursed Pell funds inaccurately. Auditors’ Recommendation: We recommend the University implement policies to review all student award packages at the start of the academic year to ensure no over and under awards exist. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Summer 2023 Martin University’s main power source was struck by lightning. This caused all Summer processing, that had not yet been backed up on our servers, to be deleted from the system. All transactions that took place at that time had to be manually re-entered. During that manual process, there appears to be a human error in inputting the dates. SIS dates will be corrected to original and actual COD disbursement dates. Name(s) of the contact person(s) responsible for corrective action: Qiana Hall, Associate VP of Enrollment Services Planned completion date for corrective action plan: November 30, 2024

View Audit 324814 Questioned Costs: $1

Finding 502578 (2023-008)

Material Weakness 2023

Okanogan Behavioral Healthcare

WA

Allowable Costs / Cost Principles Eligibility Material Weakness

Action taken in response to finding: OBHC implemented new payroll software in March 2023. During FY24, staff were trained to directly allocate their time to programs in their electronic timecard. Effective Feb 2024, time and effort reporting was used to allocate salaries to the SOR program. Additio...

Action taken in response to finding: OBHC implemented new payroll software in March 2023. During FY24, staff were trained to directly allocate their time to programs in their electronic timecard. Effective Feb 2024, time and effort reporting was used to allocate salaries to the SOR program. Additionally, the OBHC team is currently working with the HCA in restructuring the rate schedule to incorporate the payroll costs into the direct service rates for the SOR/SABG grants. This effectively removes this issue going forward in FY25 once approved by the HCA. Name(s) of the contact person(s) responsible for corrective action: Patty Brandt Planned completion date for corrective action plan: Feb 2024 & Sep 2024

View Audit 324580

Finding 502502 (2023-003)

Material Weakness 2023

Catholic Charities West Michigan

MI

Questioned Costs Special Tests & Provisions Eligibility

Action Taken: The Senior Programs have undergone significant improvements in the last 6 months following an audit by the federal funder which resulted in a corrective action plan (CAP) and a repayment of $54,228. Plans were implemented during the spring of 2024 in response to the CAP which resulted...

Action Taken: The Senior Programs have undergone significant improvements in the last 6 months following an audit by the federal funder which resulted in a corrective action plan (CAP) and a repayment of $54,228. Plans were implemented during the spring of 2024 in response to the CAP which resulted in an overhaul of the processes in place to properly develop the volunteer checklists and assure all records for staff and volunteers are now compliant. Our Quality and Compliance and Finance team worked closely with the new Program Manager to assure that we will be fully compliant and remain so.

View Audit 324497 Questioned Costs: $1

Finding 501988 (2023-001)

Significant Deficiency 2023

Meadow Lane Housing Development Fund Company, Inc.

NY

Eligibility HUD Housing Programs

An age waiver has been submitted to HUD and is currently being reviewed. We are awaiting their decision. While we await a decision, Meadow Lane will review all existing application for eligibility and advise any existing applicants who are not of age that they are no longer eligible via mail. Antic...

An age waiver has been submitted to HUD and is currently being reviewed. We are awaiting their decision. While we await a decision, Meadow Lane will review all existing application for eligibility and advise any existing applicants who are not of age that they are no longer eligible via mail. Anticipated Completion Date: Pending HUD approval of age waiver

View Audit 324170

Finding 501987 (2023-001)

None 2023

Amistad Community Health Center, Inc.

TX

Eligibility

1) Revisit our training materials provided to our Patient Access Representatives upon being hired and revise such materials to emphasize sliding fee requirements more thoroughly. Provide testing to new hires after training to establish if training was eﬀective. a. Anticipated completion date: 10/31/...

1) Revisit our training materials provided to our Patient Access Representatives upon being hired and revise such materials to emphasize sliding fee requirements more thoroughly. Provide testing to new hires after training to establish if training was eﬀective. a. Anticipated completion date: 10/31/2024 for revisions, ongoing with new hire training 2) Establish front desk (Patient Access Coordinator) supervisor “recap” trainings establishing the requirements for sliding fee designations. During this training, allow for on-hands role-playing of scenarios conducted both at group and individual levels. a. Anticipated completion date: 10/31/2024 3) Establish routine spot audits. Our Patient Access Coordinator will do spot audits on a monthly routine, and more a formal process at the CFO level completed quarterly. a. Anticipated completion date: Ongoing

View Audit 324161

Finding 501981 (2023-003)

Material Weakness 2023

Danville Redevelopment & Housing Authority

VA

Questioned Costs HUD Housing Programs Eligibility

Authority Response and Planned Corrective Action: The Authority agrees with the finding and will increase oversight related to the maintenance of tenant files to better monitor adequacy with compliance requirements. Donald Paredez, Executive Director, is responsible for implementing this corrective ...

Authority Response and Planned Corrective Action: The Authority agrees with the finding and will increase oversight related to the maintenance of tenant files to better monitor adequacy with compliance requirements. Donald Paredez, Executive Director, is responsible for implementing this corrective action by December 31, 2024.

View Audit 324142 Questioned Costs: $1

Finding 501918 (2023-001)

Significant Deficiency 2023

City of Clifton

NJ

Eligibility HUD Housing Programs

The Clifton Public Housing Agency has contracted with PHA-Web as the software system managing the Housing Choice Voucher Program. This system allows the PHA to put "on hold" any landlord/tenant payments that are not to be processed due to outstanding requirements such as lease documents, tenant inco...

The Clifton Public Housing Agency has contracted with PHA-Web as the software system managing the Housing Choice Voucher Program. This system allows the PHA to put "on hold" any landlord/tenant payments that are not to be processed due to outstanding requirements such as lease documents, tenant income verification, inspection failures or any other missing information that the PHA may need to process the monthly payment. Therefore, "on Hold" checks are not processed until the tenant/landloard complies with all the requirements. Also, any checks that are released are forwarded to the City's positive pay file for processing.

View Audit 324075

Finding 501839 (2023-001)

Significant Deficiency 2023

Athens Housing Authority

GA

HUD Housing Programs Eligibility Reporting

2023-001 - Determination of Contract Rents, Maintenance of Tenant Files Condition: Eligibility recertification procedures required as a part of the annual recertification have not been performed or not performed sufficiently for tenants housed as of December 31, 2023. Corrective Action Planned: ...

2023-001 - Determination of Contract Rents, Maintenance of Tenant Files Condition: Eligibility recertification procedures required as a part of the annual recertification have not been performed or not performed sufficiently for tenants housed as of December 31, 2023. Corrective Action Planned: Staff has worked diligently to get all tenants housed at the Housing Authority recertified with sufficient documentation. Management believes all issues with tenant files to be corrected as of the report date. Staff are to receive continued education training on the operations of the RAD program and the compliance requirements. Person responsible for corrective action: Akinola Popoola, Executive Director Telephone: (256) 232-5300 x 8 Trudi Harris, Property Manager Anticipated Completion Date: Management believes files have been corrected as of the 2023 year-end audit report date.

View Audit 323958

Finding 501744 (2023-001)

None 2023

Highland House, Inc. 023-Eh-276

MA

HUD Housing Programs Subrecipient Monitoring Eligibility

FINDINGS - MAJOR FEDERAL AWARD PROGRAM AUDIT Department of Housing and Urban Development Finding, 2023-001: Major Programs: Major Program: Section 202 Supportive Housing for the Elderly, Federal Assistance Listing Number 14.157 RECOMMENDATION The auditor recommends ensuring all tenants’ 90-day E...

FINDINGS - MAJOR FEDERAL AWARD PROGRAM AUDIT Department of Housing and Urban Development Finding, 2023-001: Major Programs: Major Program: Section 202 Supportive Housing for the Elderly, Federal Assistance Listing Number 14.157 RECOMMENDATION The auditor recommends ensuring all tenants’ 90-day EIV reports are generated within the required time period to verify tenant information promptly and help reduce errors in subsidy payments. ACTION TAKEN The Project will be monitoring use of the EIV system for move ins and recertifications.

View Audit 323817

Finding 501724 (2023-001)

Significant Deficiency 2023

County of Passaic

NJ

Questioned Costs HUD Housing Programs Eligibility

Finding – Of a sample size of 21 tenant files, income was miscalculated on one file resulting in questioned costs of $304. This is considered a significant deficiency in internal controls over the compliance for the eligibility type of compliance related to the maintenance of tenant files. The Agenc...

Finding – Of a sample size of 21 tenant files, income was miscalculated on one file resulting in questioned costs of $304. This is considered a significant deficiency in internal controls over the compliance for the eligibility type of compliance related to the maintenance of tenant files. The Agency has not properly considered, designed, implemented, maintained and monitored a system of internal controls that reasonably assures the program is in compliance. Recommendation – The Agency design and implement internal control procedures that will reasonably assure compliance with Uniform Guidance and the compliance supplement. Corrective Action - The Agency will increase oversight in the Section 8 Housing Choice voucher Program with respect to calculated income to ensure that established internal control policies are being followed on a timely basis. Implementation Date -August 1, 2024

View Audit 323806 Questioned Costs: $1

Finding 501655 (2023-001)

Significant Deficiency 2023

Brazos Valley Community Action Agency, Inc.

TX

Special Tests & Provisions Eligibility

Additional training will be provided to staff regarding the process for verifying patient sliding fee scale status and eligibility to ensure the sliding fee scale documentation and assignment procedures are followed correctly.

View Audit 323700

Finding 501252 (2023-002)

Material Weakness 2023

First Ame Housing Association

WA

HUD Housing Programs Reporting Eligibility

Finding 2023-002 – Federal Award Finding Name of Official Responsible for Corrective Action: Earl Richardson, First AME Housing Association Interim Executive Director Corrective Action Planned: Explanation: We acknowledge the oversight and would like to provide context to understand better the circu...

Finding 2023-002 – Federal Award Finding Name of Official Responsible for Corrective Action: Earl Richardson, First AME Housing Association Interim Executive Director Corrective Action Planned: Explanation: We acknowledge the oversight and would like to provide context to understand better the circumstances that led to the delay. We had internal challenges when our previous management company departed, leaving us with incomplete files and late recertifications or recertifications that never started, making it next to impossible to catch up promptly. Next, staff staffing issues contributed to the delays because staff members were not properly trained. Despite these challenges, we recognize the importance of adhering to HUD regulations and are committed to taking corrective measures. Corrective Actions Taken: We initiated immediate corrective actions to rectify the situation upon discovering the late recertifications. We have instituted the following measures to prevent the recurrence of late annual recertifications. 1. Created a recertification schedule and calendar with the annual recertification date, specific dates to notify residents that their annual recertification is due, and dates for submitting the information to CMS and to trac. The schedule and calendar are submitted to the executive director every two weeks to monitor progress, and a meeting is scheduled with staff every two weeks to review recertification issues. 2. We hired a consultant specializing in recertification to train the staff and work with staff daily to answer questions concerning our certification. This is not a one-anddone; our recertification consultant is permanently on call to answer certification issues and continuous staff training. These measures are designed to ensure timely compliance with HUD regulations and to strengthen our internal processes.

View Audit 323533

Finding 501224 (2023-006)

Material Weakness 2023

State of Alabama

AL

Questioned Costs Eligibility Matching / Level of Effort / Earmarking § 200.00 § 200.303

Finding: According to the Uniform Guidance, 2 CFR 200.303(a), non-Federal entities receiving Federal awards must establish and maintain effective internal controls over these awards. These controls must provide reasonable assurance that the entity manages the Federal award in compliance with applica...

Finding: According to the Uniform Guidance, 2 CFR 200.303(a), non-Federal entities receiving Federal awards must establish and maintain effective internal controls over these awards. These controls must provide reasonable assurance that the entity manages the Federal award in compliance with applicable Federal statutes, regulations, and the terms and conditions of the award. The Uniform Guidance, 2 CFR Part 200, Appendix XI Compliance Supplement, May 2023, requires the Alabama Department of Labor to operate a Worker Profiling and Reemployment Services (WPRS) or Reemployment Services and Eligibility Assessments (RESEA) program. The Alabama Department of Labor operates a RESEA program. Under the RESEA program, Alabama Department of Labor staff must be promptly and appropriately notified of any eligibility issues identified during any review of a claimant’s information. Claimants are also required to attend appointments for reemployment to maintain their eligibility status. The Alabama Department of Labor has controls in place to provide notification of claimants who failed to report to scheduled RESEA appointments, however those controls were not operating as designed. While reviewing 25 claimant’s information, we noted that 8 claimants failed to report to their scheduled appointments for reemployment. These failures to appear are reported to staff at the Alabama Department of Labor and should prompt a stop of benefit payments; however, the Alabama Department of Labor did not stop payment on these 8 claimants which resulted in overpayments totaling $8,884.00. There was also one instance where Alabama Department of Labor could not provide documentation to support staff was appropriately notified of the eligibility status for a claimant. The Alabama Department of Labor’s policies and procedures did not operate as designed to prevent payments to ineligible claimants. Because the Alabama Department of Labor’s internal controls were not operating as designed, this caused benefits to be paid to ineligible claimants. Recommendation: The Alabama Department of Labor should ensure internal controls are operating as designed to help ensure payments are not made to ineligible claimants. Response/Views: ADOL does not agree with this finding as explained in the Request for Views CAP letter. Corrective Action Planned: Issues reported were beyond ADOL control due to another system shared by multiple state agencies being brought down due to cyberattack. The shared system is not the system of record for UI benefit payments. UI claim records were manually reviewed by UI staff and noted accordingly upon review. Additional measures and procedures have already been implemented in case of future occurrences. Anticipated Completion Date: Already corrected. System processes implemented in October 2023 Contact Person(s): Thomas Daniel, ADOL Unemployment Compensation Division Director

View Audit 323486 Questioned Costs: $1

Corrective Action Plans

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