Corrective Action Plans

Finding 479029 (2023-001)

Significant Deficiency 2023

KS

Reporting Internal Control / Segregation of Duties

Federal Program Coronavirus State and Local Fiscal Recovery Funds – 21.027 Compliance Requirements Reporting Condition During review of the annual program reporting, it was noted that project expenditures incurred and current period project obligations were not properly noted. Recommendation We reco...

Federal Program Coronavirus State and Local Fiscal Recovery Funds – 21.027 Compliance Requirements Reporting Condition During review of the annual program reporting, it was noted that project expenditures incurred and current period project obligations were not properly noted. Recommendation We recommend the County review its grant reporting procedures and implement controls to ensure that grant reports are completed accurately. Comments on the Finding Recommendation Ellis County staff concur, and we will improve our quality control processes to ensure that reported amounts are accurate. It proves a great point to have these reports checked and double checked by another individual for quality control processes. Actions Taken Prior to completing the next annual reporting period, staff involved with the reporting process will review information provided by the Treasury about the items to be reported upon. We will also have a second person review the numerical values to ensure they are correct per Ellis County reports. Before final submittals to the U.S. Treasury, staff will also meet with the auditor to ensure that all definitions are understood. At that time, any questions that arise will be addressed with an appropriate source before completing the submission.

View Audit 315532

Finding 479025 (2023-003)

Significant Deficiency 2023

Catholic Social Services

NE

Reporting Internal Control / Segregation of Duties Significant Deficiency

CSS management will improve its system of internal controls in order to actively track and adhere to reporting requirements outlined in its award agreements.

View Audit 315529

Finding 479024 (2023-002)

Significant Deficiency 2023

Catholic Social Services

NE

Reporting Internal Control / Segregation of Duties Significant Deficiency § 200.512

CSS management will improve staffing and internal controls to ensure compliance with the timely reporting requirements stated in 2 CFR §200.512.

View Audit 315529

Finding 479023 (2023-001)

Material Weakness 2023

Catholic Social Services

NE

Internal Control / Segregation of Duties Material Weakness Reporting

Catholic Social Services' management will improve its system of internal controls to correctly identify and present a complete and accurate schedule of expenditures of federal awards.

View Audit 315529

Finding 479014 (2023-002)

Significant Deficiency 2023

Arapahoe County, Colorado

CO

Special Tests & Provisions HUD Housing Programs Significant Deficiency

HOME Investment Partnerships Program and COVID-19 HOME Investment Partnerships Program - Significant Deficiency Condition: The County did not conduct the required inspections of the HOMEassisted rental housing units during the year ended December 31, 2023. Recommendation: We recommend the County con...

HOME Investment Partnerships Program and COVID-19 HOME Investment Partnerships Program - Significant Deficiency Condition: The County did not conduct the required inspections of the HOMEassisted rental housing units during the year ended December 31, 2023. Recommendation: We recommend the County continue to train personnel so that the inspections are completed timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: In 2023, performance issues with the administration of the HOME program were discovered, to include the absence of required inspections. With significant turnover of tenured leadership and employees within the Community Resources Department, Arapahoe County Community Resources took proactive measures in 2023 for review of the Community Development Housing and Homeless Services (CDHHS) programs by recognized consultants within the field. Community Resources has contracted with two consultants, to assist in a full review and re-development of policies and procedures (Civitas) for the CDBG and HOME programs as well as a full review of all case files (Affordable Housing Consultants). Included with this response are the contracts with both Civitas and Affordable Housing Consultants for verification purposes. The County anticipates their work to be completed and an implementation of updated policies and procedures for these programs by fall of 2024. The role of Program Administrator over the HOME program was not filled until April of 2024. This role will be responsible for all future HOME program inspections. Community Resources CDHHS employees will be taking part in a two-day training in June 2024 (June 11th and 12th, 2024) for the following:  Davis Bacon & Related Acts (Applicability, wage determinations, payroll review, interviews, common errors and how to correct)  Section 3 (Applicability, Safe Harbor benchmarks, documenting compliance, qualitative efforts)  TBRA Inspections (National Standards for the Physical Inspection of Real Estate (NSPIRE) administrative procedures)  HOME Program - Implementation and Best Practices - Arapahoe County, CO - June 12, 2024  This HOME training is an introductory course focusing on underwriting and subsidy layering requirements.  Eligible Activities (Homeowner rehab programs, Homebuyer programs, Rental housing)  Underwriting (Subsidy layering and underwriting requirements and best practices)  Community Housing Development Organization (CHDO) (Requirements, best practices, management, etc)  Long-term Compliance (HOME Match, eligible beneficiaries, income limits, subsidy layering & limits, affordability, written agreements, etc)  IDIS and Reporting Arapahoe County staff will be conducting monitoring of the two Tenant Based Rental Assistance (TBRA) programs and projects within in the affordability period (20-year span) between mid-June to mid-August of 2024. The remaining HOME program projects, within the affordability period (20-year span) will have audits completed by the end of our 2023 grant cycle, September 30th, 2024. Name of the contact person responsible for corrective action: Katherine Smith Planned completion date for corrective action plan: September 30, 2024

View Audit 315527

Finding 478996 (2023-037)

Material Weakness 2023

Commonwealth of Massachusetts

MA

Subrecipient Monitoring Material Weakness Reporting § 200.303

DEPARTMENT OF PUBLIC HEALTH 2023-037 Block Grants for Prevention and Treatment of Substance Abuse, COVID-19 - Block Grants for Prevention and Treatment of Substance Abuse - Assistance Listing No. 93.959 Action taken in response to the finding: All subrecipient FFATA information will be batch upload...

DEPARTMENT OF PUBLIC HEALTH 2023-037 Block Grants for Prevention and Treatment of Substance Abuse, COVID-19 - Block Grants for Prevention and Treatment of Substance Abuse - Assistance Listing No. 93.959 Action taken in response to the finding: All subrecipient FFATA information will be batch uploaded to FSRS within 30 days of execution of subcontracts. The majority of BSAS subrecipient contracts are executed as of July 1. A batch upload of data will be completed each year in that period. All outlying contracts not executed on June 30 will have their FFATA data uploaded to FSRS within 30 days of contract execution throughout the year. These uploads will be conducted by the BSAS Grants coordinator. Once successfully uploaded the Grants coordinator will receive a FFATA submission receipt from FSRS for each FFATA submission. They will share this with their supervisor and the Fiscal Director for confirmation. These records will be kept on file in the BSAS Grant Teams file for future reference. Our internal Fiscal Compliance Auditor will review batches of these submission quarterly to ensure compliance. Name of the contact person responsible for corrective action: Shannon McEneaney-Farron, BSAS Fiscal Director Planned completion date for corrective action plan: July 31, 2024 If the Department of Health and Human Services has questions regarding this plan, please call David Godin at 617-721-6200.

View Audit 315520

Finding 478992 (2023-033)

Material Weakness 2023

Commonwealth of Massachusetts

MA

Subrecipient Monitoring Material Weakness Reporting § 200.303

DEPARTMENT OF PUBLIC HEALTH 2023-033 Opioid – STR - Assistance Listing No. 93.788 Action taken in response to the finding: All subrecipient FFATA information will be batch uploaded to FSRS within 30 days of execution of subcontracts. The majority of BSAS subrecipient contracts are executed as of Ju...

DEPARTMENT OF PUBLIC HEALTH 2023-033 Opioid – STR - Assistance Listing No. 93.788 Action taken in response to the finding: All subrecipient FFATA information will be batch uploaded to FSRS within 30 days of execution of subcontracts. The majority of BSAS subrecipient contracts are executed as of July 1. A batch upload of data will be completed each month over the grant period so that all outlying contracts not executed on June 30 will have their FFATA data uploaded to FSRS within 30 days of contract execution throughout the year. These uploads will be conducted by the BSAS Grants coordinator. Once successfully uploaded the Grants coordinator will receive a FFATA submission receipt from FSRS for each FFATA submission. They will share this with their supervisor and the Fiscal Director for confirmation. These records will be kept on file in the BSAS Grant Teams file for future reference. Our internal Fiscal Compliance Auditor will review batches of these submission quarterly to ensure compliance. Name of the contact person responsible for corrective action: Shannon McEneaney-Farron, BSAS Fiscal Director Planned completion date for corrective action plan: Ongoing. This process will commence as of July 1, 2024.

View Audit 315520

Finding 478987 (2023-032)

Significant Deficiency 2023

Commonwealth of Massachusetts

MA

Questioned Costs Special Tests & Provisions Significant Deficiency § 200.303

EXECUTIVE OFFICE OF HEALTH AND HUMAN SERVICES 2023-032 Medicaid Cluster, COVID-19 – Medicaid Cluster - Assistance Listing No. 93.775, 93.777, 93.778 Action taken in response to the finding: In response to the finding, MassHealth will • Implement corrective measures to ensure workbooks are revamped ...

EXECUTIVE OFFICE OF HEALTH AND HUMAN SERVICES 2023-032 Medicaid Cluster, COVID-19 – Medicaid Cluster - Assistance Listing No. 93.775, 93.777, 93.778 Action taken in response to the finding: In response to the finding, MassHealth will • Implement corrective measures to ensure workbooks are revamped and that processes are implemented to automate and improve the importation of data and to allow more time for quality control review. • Work with staff to develop additional checks to ensure the correct federal share is reported and returned. • Return the identified federal share in the QE 03.2024 CMS 64. Name of the contact person responsible for corrective action: Janet Chin, Director Federal Revenue Claiming, Title XIX & XXI Planned completion date for corrective action plan: Immediate and ongoing

View Audit 315520 Questioned Costs: $1

Finding 478982 (2023-031)

Significant Deficiency 2023

Commonwealth of Massachusetts

MA

Special Tests & Provisions Reporting Significant Deficiency § 200.303

EXECUTIVE OFFICE OF HEALTH AND HUMAN SERVICES 2023-031 Medicaid Cluster, COVID-19 – Medicaid Cluster - Assistance Listing No. 93.775, 93.777, 93.778 Action taken in response to the finding: The Executive Office of Health and Human Services (EOHHS) has reviewed the required elements of reports submi...

EXECUTIVE OFFICE OF HEALTH AND HUMAN SERVICES 2023-031 Medicaid Cluster, COVID-19 – Medicaid Cluster - Assistance Listing No. 93.775, 93.777, 93.778 Action taken in response to the finding: The Executive Office of Health and Human Services (EOHHS) has reviewed the required elements of reports submitted by managed care providers with EOHHS staff and reviewed the steps that EOHHS staff should take when any element of those reports is missing. Name of the contact person responsible for corrective action: Robert Roche, FP&A Analyst Planned completion date for corrective action plan: May 2, 2024

View Audit 315520

Finding 478977 (2023-030)

Material Weakness 2023

Commonwealth of Massachusetts

MA

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

EXECUTIVE OFFICE OF HEALTH AND HUMAN SERVICES 2023-030 Medicaid Cluster, COVID-19 – Medicaid Cluster - Assistance Listing No. 93.775, 93.777, 93.778 Action taken in response to the finding: EOHHS is developing a standardized checklist, using CLA’s guidance as a template, to ensure that SOC reports ...

EXECUTIVE OFFICE OF HEALTH AND HUMAN SERVICES 2023-030 Medicaid Cluster, COVID-19 – Medicaid Cluster - Assistance Listing No. 93.775, 93.777, 93.778 Action taken in response to the finding: EOHHS is developing a standardized checklist, using CLA’s guidance as a template, to ensure that SOC reports are reviewed and that such reviews are documented. Name of the contact person responsible for corrective action: Conduent – Jacob Guggenheim, Director of Healthcare Information and Analysis DentaQuest - Tomaso Calicchio, Director of Specialty Provider Networks Maximus – Janice Wadsworth, Director of Provider Operations Planned completion date for corrective action plan: July 2024

View Audit 315520

Finding 478968 (2023-027)

Material Weakness 2023

Commonwealth of Massachusetts

MA

Material Weakness Reporting Matching / Level of Effort / Earmarking § 200.303

EXECUTIVE OFFICE OF HOUSING AND LIVABLE COMMUNITIES 2023-027 Low-Income Home Energy Assistance, COVID-19 – Low-Income Home Energy Assistance - Assistance Listing No. 93.568 Action taken in response to the finding: The Executive Office of Housing and Livable Communities (EOHLC), which was formerly t...

EXECUTIVE OFFICE OF HOUSING AND LIVABLE COMMUNITIES 2023-027 Low-Income Home Energy Assistance, COVID-19 – Low-Income Home Energy Assistance - Assistance Listing No. 93.568 Action taken in response to the finding: The Executive Office of Housing and Livable Communities (EOHLC), which was formerly the Department of Housing and Community Development (DHCD or Department), has implemented the recommended measures and will continue them going forward. EOHLC has reviewed their policies and procedures for LIHEAP reporting requirements and is committed to making any enhancements that are necessary to ensure the reports are submitted timely and accurately, and that the information reported agrees to the supporting documentation. In addition, EOHLC Management or their designees will review deadlines and other requirements for LIHEAP reports on an ongoing basis. Name of the contact person responsible for corrective action: Edward Kiely Planned completion date for corrective action plan: October 1, 2024

View Audit 315520

Finding 478966 (2023-026)

Material Weakness 2023

Commonwealth of Massachusetts

MA

Subrecipient Monitoring Material Weakness Reporting § 200.303

EXECUTIVE OFFICE OF HOUSING AND LIVABLE COMMUNITIES 2023-026 Low-Income Home Energy Assistance, COVID-19 – Low-Income Home Energy Assistance - Assistance Listing No. 93.568 Action taken in response to the finding: The Executive Office of Housing and Livable Communities (EOHLC), which was formerly t...

EXECUTIVE OFFICE OF HOUSING AND LIVABLE COMMUNITIES 2023-026 Low-Income Home Energy Assistance, COVID-19 – Low-Income Home Energy Assistance - Assistance Listing No. 93.568 Action taken in response to the finding: The Executive Office of Housing and Livable Communities (EOHLC), which was formerly the Department of Housing and Community Development (DHCD or Department), has implemented the recommended measures and will continue them going forward. As a result of the original finding, 2022-018, EOHLC had previously put policies and procedures in place to ensure that all required subawards are reported timely and accurately to FSRS, and the Federal Funding Accountability and Transparency Act (FFATA) reports are reported timely and accurately. EOHLC’s FFATA report procedure was developed in September of 2023 and submitted on November 20, 2023. Although EOHLC acknowledges why this has resulted in this finding, EOHLC notes that policies and procedures have already been put in place to remedy this issue. Name of the contact person responsible for corrective action: Kristen Crowley Planned completion date for corrective action plan: FFATA report procedure developed September 12, 2023 and LIHEAP submitted November 20, 2023

View Audit 315520

Finding 478959 (2023-023)

Material Weakness 2023

Commonwealth of Massachusetts

MA

Subrecipient Monitoring Material Weakness Reporting § 200.303

DEPARTMENT OF PUBLIC HEALTH 2023-023 Immunization Cooperative Agreements, COVID-19 - Immunization Cooperative Agreements - Assistance Listing No. 93.268 Action taken in response to the finding: The Bureau of Infectious Disease and Laboratory Sciences (BIDLS) will put in place starting June 1, 2024 ...

DEPARTMENT OF PUBLIC HEALTH 2023-023 Immunization Cooperative Agreements, COVID-19 - Immunization Cooperative Agreements - Assistance Listing No. 93.268 Action taken in response to the finding: The Bureau of Infectious Disease and Laboratory Sciences (BIDLS) will put in place starting June 1, 2024 a process to review obligations for subawards under Immunization, Assistance Listing No. 93.268 to identify subawards that fall under the rules set forth by Federal Funding Accountability and Transparency Act (FFATA) and report the appropriate obligations to FSRS according to the above-mentioned recommendations. Name of the contact person responsible for corrective action: Cheryl Bernard-Dort, Director of Administration and Finance or her designee. Planned completion date for corrective action plan: The completion date for this correction action plan is September 30, 2024.

View Audit 315520

Finding 478944 (2023-020)

Material Weakness 2023

Commonwealth of Massachusetts

MA

Subrecipient Monitoring Material Weakness Reporting § 200.303

EXECUTIVE OFFICE OF ELDER AFAIRS 2023-020 COVID-19 – Aging Cluster - Assistance Listing No. 93.044, 93.045, 93.053 Action taken in response to the finding: EOEA will establish a process to ensure that all required subawards are reported timely and accurately to FSRS no later than the end of the mon...

EXECUTIVE OFFICE OF ELDER AFAIRS 2023-020 COVID-19 – Aging Cluster - Assistance Listing No. 93.044, 93.045, 93.053 Action taken in response to the finding: EOEA will establish a process to ensure that all required subawards are reported timely and accurately to FSRS no later than the end of the month following the month of issuance of each subaward. Name of the contact person responsible for corrective action: Sheila Tunney, EOEA CFO Planned completion date for corrective action plan: EOEA will complete this corrective action plan following issuance of the final FFY24 federal award, which is expected in August 2024.

View Audit 315520

Finding 478932 (2023-018)

Significant Deficiency 2023

Commonwealth of Massachusetts

MA

Subrecipient Monitoring Reporting Significant Deficiency § 200.303

DEPARTMENT OF ELEMENTARY AND SECONDARY EDUCATION 2023-018 COVID-19 – Elementary and Secondary School Emergency Relief Fund (ESSER), COVID-19 – American Rescue Plan – Elementary and Secondary School Emergency Relief (ARP ESSER) – Assistance Listing No. 84.425D, 84.425U Action taken in response to the...

DEPARTMENT OF ELEMENTARY AND SECONDARY EDUCATION 2023-018 COVID-19 – Elementary and Secondary School Emergency Relief Fund (ESSER), COVID-19 – American Rescue Plan – Elementary and Secondary School Emergency Relief (ARP ESSER) – Assistance Listing No. 84.425D, 84.425U Action taken in response to the finding: In FY24, internal controls and procedures were implemented to ensure that all required subawards are reported timely to FSRS no later than the end of the month following the month of issuance. Name of the contact person responsible for corrective action: Robert Curtain, Chief Officer for Data and Accountability Planned completion date for corrective action plan: July 1, 2023

View Audit 315520

Finding 478931 (2023-017)

Significant Deficiency 2023

Commonwealth of Massachusetts

MA

Subrecipient Monitoring Reporting Significant Deficiency § 200.303

DEPARTMENT OF ELEMENTARY AND SECONDARY EDUCATION 2023-017 Title I Grants to Local Educational Agencies – Assistance Listing No. 84.010 Action taken in response to the finding: In FY24, internal controls and procedures were implemented to ensure that all required subawards are reported timely to FSR...

DEPARTMENT OF ELEMENTARY AND SECONDARY EDUCATION 2023-017 Title I Grants to Local Educational Agencies – Assistance Listing No. 84.010 Action taken in response to the finding: In FY24, internal controls and procedures were implemented to ensure that all required subawards are reported timely to FSRS no later than the end of the month following the month of issuance. Name of the contact person responsible for corrective action: Robert Curtain, Chief Officer for Data and Accountability Planned completion date for corrective action plan: July 1, 2023

View Audit 315520

Finding 478923 (2023-013)

Material Weakness 2023

Commonwealth of Massachusetts

MA

Subrecipient Monitoring Material Weakness Reporting § 200.303

EXECUTIVE OFFICE OF LABOR AND WORKFORCE DEVELOPMENT 2023-013 WIOA Cluster– Assistance Listing No. 17.258, 17.259, 17.278 Action taken in response to the finding: EOLWD Finance is drafting a Standard Operating Procedure (SOP) that includes the necessary controls to ensure subawards subject to Federa...

EXECUTIVE OFFICE OF LABOR AND WORKFORCE DEVELOPMENT 2023-013 WIOA Cluster– Assistance Listing No. 17.258, 17.259, 17.278 Action taken in response to the finding: EOLWD Finance is drafting a Standard Operating Procedure (SOP) that includes the necessary controls to ensure subawards subject to Federal Funding Accountability and Transparency Act (FFATA) reporting are reviewed, approved, and submitted timely to FSRS. EOLWD Finance will also conduct training for staff. Name of the contact person responsible for corrective action: Malachy Rice, Director of Federal Grants Management Planned completion date for corrective action plan: July 1, 2024

View Audit 315520

Finding 478913 (2023-011)

Significant Deficiency 2023

Commonwealth of Massachusetts

MA

Reporting Significant Deficiency Matching / Level of Effort / Earmarking § 200.303

EXECUTIVE OFFICE OF LABOR AND WORKFORCE DEVELOPMENT 2023-011 WIOA Cluster, Employment Service Cluster – Assistance Listing No. 17.258, 17.259, 17.278, 17.207, 17.801 Action taken in response to the finding: In FY 2023, a Corrective Action Plan (CAP) was drafted and implemented to address prior aud...

EXECUTIVE OFFICE OF LABOR AND WORKFORCE DEVELOPMENT 2023-011 WIOA Cluster, Employment Service Cluster – Assistance Listing No. 17.258, 17.259, 17.278, 17.207, 17.801 Action taken in response to the finding: In FY 2023, a Corrective Action Plan (CAP) was drafted and implemented to address prior audit findings related to Federal Financial Reports (FFR). Prior audit findings were a result of extraordinary turnover within EOLWD’s Finance Office, which resulted in having no staff who were fully dedicated to filing Federal Financial Reports (FFR). The CAP included: (1) filling vacant positions; (2) training new staff in the federal reporting process and requirements; (3) automating business practices; and (4) drafting and implementing an FFR Standard Operating Procedure (SOP). The first three corrective actions identified in the CAP were implemented throughout FY 2023. The SOP for Federal Financial Reporting was developed throughout FY 2023 and implemented in FY 2024. The necessary controls for ensuring that ETA 9130 reports reflect earmarking requirements and are accurately supported by documentation that support reported balances were implemented with the implementation of the FFR SOP in FY 2024. In addition, the automated business practices cited in the CAP were refined throughout FY 2023 to ensure data in supporting documentation correlates to what is reported on an ETA 9130 report. Name of the contact person responsible for corrective action: Malachy Rice, Director of Federal Grants Management Planned completion date for corrective action plan: October 1, 2023

View Audit 315520

Finding 478902 (2023-007)

Material Weakness 2023

Commonwealth of Massachusetts

MA

Subrecipient Monitoring Material Weakness Reporting § 200.303

EXECUTIVE OFFICE OF LABOR AND WORKFORCE DEVELOPMENT 2023-007 Employment Service Cluster – Assistance Listing No. 17.207, 17.801 Action taken in response to the finding: EOLWD Finance is drafting a Standard Operating Procedure (SOP) that includes the necessary controls to ensure subawards subject to...

EXECUTIVE OFFICE OF LABOR AND WORKFORCE DEVELOPMENT 2023-007 Employment Service Cluster – Assistance Listing No. 17.207, 17.801 Action taken in response to the finding: EOLWD Finance is drafting a Standard Operating Procedure (SOP) that includes the necessary controls to ensure subawards subject to Federal Funding Accountability and Transparency Act (FFATA) reporting are reviewed, approved, and submitted timely to FSRS. EOLWD Finance will also conduct training for staff. Name of the contact person responsible for corrective action: Malachy Rice, Director of Federal Grants Management Planned completion date for corrective action plan: July 1, 2024

View Audit 315520

Finding 478900 (2023-006)

Significant Deficiency 2023

Commonwealth of Massachusetts

MA

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

EXECUTIVE OFFICE OF LABOR AND WORKFORCE DEVELOPMENT 2023-006 Unemployment Insurance, COVID-19 – Unemployment Insurance – Assistance Listing No. 17.225 Action taken in response to the finding: While Massachusetts BAM unit (MBAM) had been making progress in meeting timeliness deadlines, it began suff...

EXECUTIVE OFFICE OF LABOR AND WORKFORCE DEVELOPMENT 2023-006 Unemployment Insurance, COVID-19 – Unemployment Insurance – Assistance Listing No. 17.225 Action taken in response to the finding: While Massachusetts BAM unit (MBAM) had been making progress in meeting timeliness deadlines, it began suffering setbacks in or around July 2022. MBAM was experiencing difficulties with the SUN server not accepting data and the system adding additional edits that should not have existed. Consistent work with the USDOL Hotline resolved the issues and/or created workarounds. Ultimately the SUN server failed after degrading for a year. The server was unavailable for use sporadically through the year and for four full separate weeks in May, June, and July 2023. Not only were staff unable to submit DCI data but it took additional organizational work of handling unentered cases, additional time to work with the Hotline and test fixes, while needing additional steps to implement work arounds for items that could not be fixed. MBAM continues to utilize work arounds for BAM data entry. Since SWA’s SUN server has become functional again, MBAM has been improving timeliness. MBAM also continues to work with ETA Hotline to report and resolve defects within the SUN system. MBAM management also developed an organizational strategy for the unit to provide its investigators with weekly updates on what cases should be worked on based on batch due dates. A case status report has been developed to provide unit supervisors with the status of each case assigned, expected date of completion, work completed to date on case, and cause for delay. Additionally, MBAM management has developed in-house reporting to track individual investigators. The reports track each investigator, telling management the number of cases closed each week and tracking the aging of Investigations. The manager uses these reports to identify cases to be prioritized based on aging and to quickly identify if a specific investigator is lagging in their case closure. Based on performance, the Manager has coaching sessions with individual investigators a minimum of every two weeks where work prioritization, organization, and any other additional necessary issues are reviewed and discussed. A meeting with all investigators is held weekly to provide education, discuss change to policy/procedure, and provide an open forum for BAM program implementation questions. Monitoring also occurs at the end of each quarter. Based on outcome, discussion of weaknesses and development of new levels of support are discussed and implemented. Name of the contact person responsible for corrective action: Susan Saulnier, Director of UI Performs Planned completion date for corrective action plan: September 30, 2024

View Audit 315520

Finding 478886 (2023-002)

Significant Deficiency 2023

Housing Authority of the City of Seattle

WA

Questioned Costs HUD Housing Programs Internal Control / Segregation of Duties § 200.302

Moving to Work Demonstration Program – Assistance Listing No. 14.881 Recommendation: We recommend the Authority review their process and internal controls over HQS inspections to ensure compliance with HUD requirements and their administrative plan. Furthermore, management should ensure no HAP payme...

Moving to Work Demonstration Program – Assistance Listing No. 14.881 Recommendation: We recommend the Authority review their process and internal controls over HQS inspections to ensure compliance with HUD requirements and their administrative plan. Furthermore, management should ensure no HAP payments are issued for units that have not passed HQS housing inspections. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Housing Choice Voucher department is addressing inspection controls in multiple ways. The Department has added additional staffing and also has created new tracking that makes it easier to review and identify units that have not passed inspection and not been abated. The Department has also instituted an ongoing process that has the inspections manager conducting a monthly review of units moving through the abatement process to ensure timely processing and cessation of HAP payments as needed. As part of this review the Department is also conducting a comprehensive review of units that have prior failed inspections to ensure abatement occurred. Name of the contact person responsible for corrective action: Mark La Brayere Planned completion date for corrective action plan: Three elements are continuous with no final completion date. The singular comprehensive review is scheduled to be completed within three months.

View Audit 315516 Questioned Costs: $1

Finding 478873 (2023-003)

Significant Deficiency 2023

Harvest Against Hunger

WA

Allowable Costs / Cost Principles Significant Deficiency Matching / Level of Effort / Earmarking

Federal Agency: U.S. Department of the Treasury Federal Program Name: Coronavirus State and Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: K3422 & K3724 - 2021 Pass-Through Agency: Washington State Department of Agriculture Pass-Through Number(s...

Federal Agency: U.S. Department of the Treasury Federal Program Name: Coronavirus State and Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: K3422 & K3724 - 2021 Pass-Through Agency: Washington State Department of Agriculture Pass-Through Number(s): E128H7X5KWX5 Award Period: 7/1/21-6/30/23; 11/19/21-6/30/23 Type of Finding: • Significant Deficiency in Internal Control over Compliance Section III – Findings and Questioned Costs – Major Federal Programs Condition: Harvest Against Hunger allocates costs to the program based on the available funding and number of employees working on the project. They do not use the timesheet to record the operating hours for the program, but rather management makes a judgmental decision based on their understanding of program operations during the payroll period. Questioned costs: None Cause: The Organization lacks documentation supporting the allocation determination used to determine payroll amounts charged to the major program. Views of responsible officials: There is no disagreement with the finding. Criteria or specific requirement: Per §200.303, non-Federal entities must "establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non- Federal entity is managing the Federal award in compliance with Federal statues, regulations, and the terms and conditions of the Federal awards." Additionally, non-Federal entities must charge salaries and wages "based on records that accurately reflect the work performed" (§200.430(i)). Effect: Without proper documentation of the payroll allocation used, the Organization could charge time to a federal program that does not reflect true expenditures incurred by that program. Repeat Finding: This is not a repeated finding. Recommendation: The Organization should implement policies for consistently determining time allocation to the federal program, and ensure internal controls help to ensure this allocation is correct and consistently documented

View Audit 315495

Finding 478786 (2023-001)

Material Weakness 2023

County of Commissioners of Calvert County, Maryland

MD

Subrecipient Monitoring Reporting Internal Control / Segregation of Duties

Point of Contact (POC): the Deputy Director of Accounting (vacant) will oversee the corrective action plan with assistance from an Accountant III (Casey Waldron)  Resource Requirements: the main resources will be the Deputy Director of Accounting and an Accountant III. It is anticipated that the no...

Point of Contact (POC): the Deputy Director of Accounting (vacant) will oversee the corrective action plan with assistance from an Accountant III (Casey Waldron)  Resource Requirements: the main resources will be the Deputy Director of Accounting and an Accountant III. It is anticipated that the non-recurring milestones will take no more than 40 hours to complete.  Planned Milestones: o Create a tracker for balance sheet account reconciliations – completed 05/24 o Every June and July, send out reminders on transitioning to the new fiscal year while the prior fiscal year is being closed to ensure expenses/revenue are accounted for properly. o Staff complete monthly balance sheet account reconciliations by the 15th of the following month o As part of each balance sheet account reconciliation, staff will prepare a document for each account (by 08/24 and updated annually) that includes the following information:  Name/Title of account  General Ledger account number  Fund (if applicable)  Purpose  Types of transactions  Transaction flow o Tracker and reconciliations are discussed monthly at a meeting led by either POC or the Director of Finance (Bruce Miller), meetings will be held the week that includes the 15th, if possible o Create a checklist for a quarterly review of revenue and expenses by 10/24 o Using the above checklist, perform a quarterly review of the revenue and expense data for quarters 1 through 3 no later than 30 days after the end of the quarter.  Actual-to-budget comparison for expenses/revenue  Cost centers used with the wrong fund  Negative expense balances  Positive revenue balances  Adjustments for issues identified during the quarterly review will be posted prior to the next quarterly review Maryland Relay for Impaired Hearing or Speech: 1-800-735-2258 o Consolidate year-end checklists into a master checklist by 08/24. The checklist must include the following information:  Procedure to be performed  Where instructions for the procedure are located  Responsibility Party  Date Due  Date Completed  Reviewing Party  Date Due  Date Completed o Hold bi-weekly year-end status meetings starting the 2nd week in July through the issuance of the audited financial statements  Scheduled Completion Date: the target completion date for non-recurring milestones is 10/24. As part of the CAP, we will be implementing recurring milestones that will be completed within the timelines specified above.  Status Date: o The tracker for balance sheet account reconciliations was completed in 05/24. o Staff is working daily on account reconciliations for Fiscal Year (FY) 2024. o The June reminder regarding the end of FY 2024 and the start of FY 2025 was sent on 06/30/24.

View Audit 315436

Finding 478781 (2023-003)

None 2023

Community Action Partnership of North Dakota Inc.

ND

Subrecipient Monitoring Internal Control / Segregation of Duties § 200.331

2023-003 – Subrecipient Monitoring Compliance Person responsible for corrective action – Andrea Olson, Executive Director Responsible official’s response – Management is in agreement with this finding. Corrective action planned – CAPND has subsequently requested all audit reports from all subrecipie...

2023-003 – Subrecipient Monitoring Compliance Person responsible for corrective action – Andrea Olson, Executive Director Responsible official’s response – Management is in agreement with this finding. Corrective action planned – CAPND has subsequently requested all audit reports from all subrecipients. Additionally, CAPND has changed subaward formatting to ensure that all required information is included within the award. Planned implementation date of corrective action – July 10, 2024

View Audit 315423

Finding 478774 (2023-005)

Significant Deficiency 2023

Alameda Health System, A Public Hospital Authority

CA

Reporting Significant Deficiency Matching / Level of Effort / Earmarking § 200.303

Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. The Health System will review, modify, and implement policies and procedures over the program to ensure that required reports are prepared and reviewed by separate individuals. Documentation will be mai...

Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. The Health System will review, modify, and implement policies and procedures over the program to ensure that required reports are prepared and reviewed by separate individuals. Documentation will be maintained by the program to evidence preparation and review processes and timely filing of required reports.

View Audit 315421

Corrective Action Plans

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