Corrective Action Plans

Finding 386629 (2023-002)

Significant Deficiency 2023

CO

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Condition: During testing of underlying enrollment information, we identified the following: • One student’s status change was not submitted to the NSLDS within 60 days. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action in Response to Finding: ...

Condition: During testing of underlying enrollment information, we identified the following: • One student’s status change was not submitted to the NSLDS within 60 days. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action in Response to Finding: The College will coordinate with their third-party servicer to identify the underlying cause and identify remediation to prevent this reporting error going forward. Name of the contact person responsible for corrective action: Phillip Apodaca, Registrar Planned completion date for corrective action plan: June 30, 2024

View Audit 298956

Finding 386613 (2023-006)

Significant Deficiency 2023

Municipality of Coamo

PR

Significant Deficiency Internal Control / Segregation of Duties

COMMONWEALTH OF PUERTO RICO MUNICIPALITY OF COAMO Corrective Action Plan For the Fiscal Year Ended June 30, 2023 _____________________________________________________________________________________________________________________ Audit Report: Reports on Compliance and Internal Control in Acc...

COMMONWEALTH OF PUERTO RICO MUNICIPALITY OF COAMO Corrective Action Plan For the Fiscal Year Ended June 30, 2023 _____________________________________________________________________________________________________________________ Audit Report: Reports on Compliance and Internal Control in Accordance with Government Auditing Standards and OMB Super Circular Uniform Guidance Audit Period: July 1, 2022 – June 30, 2023 Fiscal Year: 2022-2023 Principal Executive: Hon. Juan C. García Padilla, Mayor Contact Person: Mrs. Miraisa David Esparra, Finance and Budget Director Phone: (787) 825-1150 Original Finding Number: 2023-006 Statement of Concurrence or Non concurrence: We concur with the finding. Corrective Action: The participant mentioned in the finding is an exceptional case; a very low-income older adult participant who has limitations to complete your housing unit repairs. But we gave instructions to the Program Director to identify alternatives to provide assistance to the participant in order to complete the housing repairs.. Implementation Date: March 21, 2024 Responsible Person: Mr. Héctor R. Sanjurjo Rodríguez Federal Programs Director

View Audit 298919

Finding 386600 (2023-001)

Significant Deficiency 2023

Aguila Elementary School District No. 63

AZ

Internal Control / Segregation of Duties

Contractors will be required to submit weekly ce rtified payrolls for any construction jobs funded with federal dollars.

View Audit 298906

Finding 386594 (2023-001)

Significant Deficiency 2023

Boscobel Area School District

WI

Internal Control / Segregation of Duties Procurement, Suspension & Debarment Matching / Level of Effort / Earmarking

Finding #2023-001 - Limited Segregation of Duties (Prior Year Finding #2022-001) Condition: The available office staff precludes a proper segregation of duties in the control areas reviewed. Effect: Because of the lack of segregation of duties, errors or irregularities could occur and not be dete...

Finding #2023-001 - Limited Segregation of Duties (Prior Year Finding #2022-001) Condition: The available office staff precludes a proper segregation of duties in the control areas reviewed. Effect: Because of the lack of segregation of duties, errors or irregularities could occur and not be detected on a timely basis. Cause: The condition is due to limited staff available.Criteria: Internal controls should be in place that provide adequate segregation of duties. Generally, a system of internal control contemplates separation of duties such that no individual has responsibility to execute a transaction, have physical access to the related assets, and have responsibility or authority to record the transaction. Recommendation: Procedures should be implemented segregating duties among different employees. Management should continue to maintain a working knowledge of matters relating to the district's operations. Response: We agree with this finding and continue to work to achieve segregation of duties whenever cost effective. The cash disbursements process includes approval of purchase orders and matching of approved purchase orders with invoices. Review of account coding is performed by the district accounting staff. The payroll disbursement process includes approval of timesheets and review of coding on an ongoing basis. The Board of Education reviews budget to actual information along with disbursement information on a monthly basis.

View Audit 298878

Finding 386588 (2023-017)

Significant Deficiency 2023

State of Mississippi Institutions of Higher Learning

MS

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

Department of Education 2023-017 Education Stabilization Fund – Assistance Listing No. 84.425E, F, J, T (MUW) Condition: Annual Reporting: MUW could not provide evidence of review over the annual report submitted March 24, 2023. Quarterly Reporting: MUW submitted an out-of-date quarterly form for t...

Department of Education 2023-017 Education Stabilization Fund – Assistance Listing No. 84.425E, F, J, T (MUW) Condition: Annual Reporting: MUW could not provide evidence of review over the annual report submitted March 24, 2023. Quarterly Reporting: MUW submitted an out-of-date quarterly form for the quarter ending September 30, 2022. In addition, MUW could not provide evidence of review over the quarterly report submitted for the quarter ended September 30, 2022. Recommendation: We recommend the institutions strengthen their understanding of the reporting requirements established by the grant and ensure supporting documentation is maintained to substantiate amounts reported. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Grant Accountant will strengthen their understanding of the reporting requirements established by the grant and stay abreast of any changes/revisions to those reporting requirements. They will work in conjunction with the Director of Sponsored Programs. Additionally, the Grant Accountant has created a cover sheet that will be signed by the Vice President of Finance and Administration upon review of the report being submitted. The completed and signed form will serve as evidence that accompanying report has been reviewed. All documentation will be retained in University Accounting. Name(s) of the contact person(s) responsible for corrective action: Rachel Sudduth. Planned completion date for corrective action plan: March 21, 2024. If the Department of Education has questions regarding this plan, please call Susan Sobley at(662) 329-7214. 2023-017 Education Stabilization Fund - Assistance Listing No. Assistance Listing No. 84.425E, F, J, T (MVSU) Condition: Quarterly Reporting: MVSU could not provide evidence of review over the quarterly report submitted for the quarter ended June 30, 2022. Annual Reporting: MVSU could not provide evidence of review over the annual report submitted March 25, 2023. Recommendation: We recommend the institutions strengthen their understanding of the reporting requirements established by the grant and ensure supporting documentation is maintained to substantiate amounts reported. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The quarterly reports with supporting documentation have been submitted to the Director of Accounting and Vice President for Business and Finance review prior to the posting deadline. This action started with the quarterly report submitted for the quarter ending June 30, 2023. The deadline for posting this quarterly report was July 10, 2023. Additionally, the annual reports with supporting documentation will be submitted to the Director of Accounting and Vice President for Business and Finance in a timely manner for review and verification prior to the submission deadline. Name(s) of the contact person(s) responsible for corrective action: Samuel Melton Planned completion date for corrective action plan: July 10, 2023 If the U.S. Department of Education has questions regarding this plan, please call Samuel Melton at 662.254.3882.

View Audit 298874

Finding 386575 (2023-011)

Significant Deficiency 2023

State of Mississippi Institutions of Higher Learning

MS

Student Financial Aid Significant Deficiency Matching / Level of Effort / Earmarking § 200.303

Department of Education 2023–011 Outstanding Student Refund Checks Student Financial Aid Cluster – Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Auditors’ Recommendation: During CLA testing of Special Tests and Provisions. CLA noted that the University was not in compliance with the federal ...

Department of Education 2023–011 Outstanding Student Refund Checks Student Financial Aid Cluster – Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Auditors’ Recommendation: During CLA testing of Special Tests and Provisions. CLA noted that the University was not in compliance with the federal financial aid regulations requirement that any Title IV federal funds disbursed to a student or parent that have not received or negotiated must be returned to the appropriated federal financial aid program no later than 240 days after the check or electronic fund transfer (EFT) was issued. CLA recommends that the University review the requirement and implement a monitoring control to monitor the checks throughout the year. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Create a policy to address the following: Returned or unclaimed Title IV Refunds will be successfully delivered to recipients (students or parents) or returned to the appropriate federal agency after 180 days outstanding. Additional attempts may be made to contact recipients; however, all unclaimed funds will be returned to the appropriate aid program no later than 240 days after the initial disbursement. The Accounting Office will maintain an “Outstanding Title IV Refund Checks/EFT Returns” list that will be provided to the Bursar’s Office every month. The Bursar’s Office will review the “Outstanding Title IV Refund Checks/EFT Returns” list every month and follow the procedures below regarding the outstanding checks/EFT returns.  The Bursar’s Office will use all reasonable means to locate the student or parent whose Title IV refund checks or returns have become 120 days old.  If all attempts are not successful, any outstanding Title IV refunds checks that have become stale dated (over 180 days) will be voided. The Bursar’s Office will make an entry, after a check has been voided, debiting the student account, and crediting a designated account that the Accounting’s Office will specify. This entry will then be interfaced to the Finance General Ledger debiting Student AR and crediting “Unclaimed Title IV Account”.  The Bursar’s Office will then send an e-mail notice to the Financial Aid Office containing the student’s name, student ID number, Title IV program(s), aid year and dollar amount that has been credited to the “Unclaimed Title IV Account”.  Based on the information provided, funds will be returned to the appropriate aid program within 210 – 240 days.  The Financial Aid Office will make the appropriate change(s) to the Fiscal Operations Report and Application to Participate (FISAP).  The Accounting’s Office will reconcile the “Unclaimed Title IV Account” every month. Name(s) of the contact person(s) responsible for corrective action: Charlette Mock, Director of Accounting and Lucreta Tribune, Associate Vice President for Finance Planned completion date for corrective action plan: This plan will be implemented no later than April 2024, with ongoing review of the process. This process should be completely in effect by the end of the current fiscal year, June 30, 2024. If the U.S. Department of Education has questions regarding these plans, please call Juanita Edwards at 601-877-6672.

View Audit 298874

Finding 386573 (2023-010)

Significant Deficiency 2023

State of Mississippi Institutions of Higher Learning

MS

Student Financial Aid Reporting Significant Deficiency § 200.303

Department of Education 2023-010 NSLDS Enrollment Reporting (ASU) Student Financial Aid Cluster – Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Auditors’ Recommendation: During CLA testing of Special Tests and Provisions. CLA noted that the University was not in compliance with the federal f...

Department of Education 2023-010 NSLDS Enrollment Reporting (ASU) Student Financial Aid Cluster – Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Auditors’ Recommendation: During CLA testing of Special Tests and Provisions. CLA noted that the University was not in compliance with the federal financial aid regulations. The school is required to report changes in the student’s enrollment status, the effective date of the status and an anticipated completion date. Changes in enrollment to less than half-time, graduated, or withdrawn status must be reported within 30 days. However, if a Roster file is expected within 60 days, you may provide the data on that Roster file (34CFR section 682.610). Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We have made significant changes during fiscal year 2024 in the Office of Student Records to address controlled and non-compliance Title IV regulations. While significant changes were made, we recognize that additional improvements are needed. The Registrar will implement internal controls to ensure all Title IV requirements are met regarding enrollment reporting. In addition, the Registrar will create a student enrollment procedures manual and implement a monitoring process to ensure that enrollment statuses are reported accurately and timely to NSLDS. Name(s) of the contact person(s) responsible for corrective action: Kisha Bond Planned completion date for corrective action plan: The planned completion date for this corrective action will be August 2024. If the U.S. Department of Education has questions regarding these plans, please call Juanita Edwards at 601-877-6672. 2023-010 NSLDS Enrollment Reporting (JSU) Student Financial Aid Cluster – Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Auditors’ Recommendation: During CLA testing of Special Tests and Provisions. CLA noted that the University was not in compliance with the federal financial aid regulations the school is required to report changes in the student’s enrollment status, the effective date of the status and an anticipated completion date. Changes in enrollment to less than half-time, graduated, or withdrawn status must be reported within 30 days. However, if a Roster file is expected within 60 days, you may provide the data on that Roster file (34CFR section 682.610). Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Jackson State University has an established and published academic calendar which guides the day-to-day academic operations and functions of the University. In some instances, the census and financial purge deadlines are extended to ensure students complete their registration requirements. When extensions are provided, the enrollment file is unable to be submitted timely and also causes delays in processing the Enrollment Error report. To alleviate the untimely submission of the Enrollment Report, different practices have been established to aid students in completing their registration before the published deadline and subsequently ensuring the Enrollment file is submitted by the deadline. The University will adhere to published deadlines to prevent delays in reporting and error resolution. The University will enhance semester onboarding by: • Begin purge process earlier in the semester to ensure timely enrollment verification for each semester. • Increase communications between Office of the Registrar and Office of Financial Aid to weekly checks to discover and resolve resolutions within a 5-day window. This ensures we will meet the 10-day resolution deadline. Name(s) of the contact person(s) responsible for corrective action: Ozie Ratcliff, Director of Financial Aid and Lekesha Tubbs, University Registrar. Planned completion date for corrective action plan: Updated process will begin 3/25/2024. If the U.S. Department of Education has questions regarding these plans, please call Ozie Ratcliff at 601-979-3347. 2023-010 NSLDS Enrollment Reporting (UMMC) Student Financial Aid Cluster – Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Auditors’ Recommendation: During CLA testing of Special Tests and Provisions. CLA noted that the University was not in compliance with the federal financial aid regulations the school is required to report changes in the student’s enrollment status, the effective date of the status and an anticipated completion date. Changes in enrollment to less than half-time, graduated, or withdrawn status must be reported within 30 days. However, if a Roster file is expected within 60 days, you may provide the data on that Roster file (34CFR section 682.610). Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Office of Enrollment Management worked with DIS to create a supplement report (UMC RPT ST Student Academic Program Status Withdrawn, Dismissed or LOA-V2) to capture students whose enrollment status changes but is not picked up through monthly clearinghouse submissions. This report will run in tandem with our monthly clearinghouse report and any student with a status change not pulled on the clearinghouse report will be manually updated within the National Student Clearinghouse database by our Associate Director of Enrollment Services. These updates will then be reported to NSLDS, along with our monthly enrollment report. Name of the contact person responsible for corrective action: Dr. Emily Cole, Executive Director of Enrollment Management Planned completion date for corrective action plan: Effective immediately. The Office of Enrollment Management will begin utilizing the new report with the March enrollment file submitted to clearinghouse. If the U.S. Department of Education has questions regarding these plans, please call Julie Schwindt at 601-984-1058.

View Audit 298874

Finding 386571 (2023-008)

Significant Deficiency 2023

State of Mississippi Institutions of Higher Learning

MS

Reporting Significant Deficiency Equipment & Real Property Management § 200.303

Department of Health and Human Services 2023-008 Head Start Program – Assistance Listing No. 93.600 Condition: The University filed the Real Property Status Report SF-429 after the deadline. Recommendation: We recommend the institutions review and revise its current reporting procedures and review r...

Department of Health and Human Services 2023-008 Head Start Program – Assistance Listing No. 93.600 Condition: The University filed the Real Property Status Report SF-429 after the deadline. Recommendation: We recommend the institutions review and revise its current reporting procedures and review requirements to ensure that the reports are submitted accurately and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Mississippi State University will review and revise the current reporting procedures for the SF 429: Real Property Status Report to ensure reports are submitted in accordance with established deadlines. Name(s) of the contact person(s) responsible for corrective action: Tucker, Director Sponsored Programs Planned completion date for corrective action plan: June 30, 2024 If the Department of Health and Human Services has questions regarding this plan, please call Jonathan Tucker at 662-325-1930.

View Audit 298874

Finding 386570 (2023-007)

Significant Deficiency 2023

State of Mississippi Institutions of Higher Learning

MS

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

Department of Health and Human Services 2023-007 FFATA Reporting – Reports filed past the deadline – Assistance Listing No. 93.211 Condition: FFATA reporting was not submitted timely Auditors’ Recommendation: We recommend the institution strengthens their understanding of the reporting requirements ...

Department of Health and Human Services 2023-007 FFATA Reporting – Reports filed past the deadline – Assistance Listing No. 93.211 Condition: FFATA reporting was not submitted timely Auditors’ Recommendation: We recommend the institution strengthens their understanding of the reporting requirements established by the grant and ensure reports are filed timely Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The respective Supervisor of Post-Award Accounting or the Accounting Specialist position which handles this responsibility reviews a fully executed sub-agreement and they identify or determine if the applicable award, whether new or an amendment, meets the FFATA threshold. If the award meets the prescribed threshold, essential data are compiled from each applicable sub-agreement(s) via an internal Post-Award sub-award tracking spreadsheet for entry into the FSRS.gov. Effective September 2023, the above stated process is being completed no more frequently than weekly, and no less frequently than monthly. Once all data has been successfully entered and uploaded, the Supervisor, Accounting Specialist, or designee will confirm that the report has been successfully submitted via an email. Beginning March 2024, submitted reports are saved on the shared drive in a FFATA folder organized by fiscal year and month. The submission date will be incorporated into the name of the file to specifically identify the date the report was successfully submitted. Effective March 2024, once the FFATA reporting process is complete, notification is also made via email to the appropriate management personnel regarding the completion of this entire process as an additional internal control and to ensure compliance of this reporting requirement as identified in 2 CFR Part 170. Name(s) of the contact person(s) responsible for corrective action: Julie Schwindt, Director, Post-Award Accounting Planned completion date for corrective action plan: March 31, 2024 If the Department of Health and Human Services has questions regarding this plan, please call Julie Schwindt at 601-984-1058.

View Audit 298874

Finding 386544 (2023-001)

Material Weakness 2023

M.c. Preparatory School of Wisconsin, Inc.

WI

Cash Management Internal Control / Segregation of Duties

CORRECTIVE ACTION PLAN February 27, 2024 M.C. College Preparatory School of Wisconsin, Inc. respectfully submits the following corrective action plan for the year ended June 30,2023. Walkowicz, Boczkiewicz & Co., S.C. 1800 East Main Street, Suite 100 Waukesha, WI 53186 Audit period: June 30, 2023 Th...

CORRECTIVE ACTION PLAN February 27, 2024 M.C. College Preparatory School of Wisconsin, Inc. respectfully submits the following corrective action plan for the year ended June 30,2023. Walkowicz, Boczkiewicz & Co., S.C. 1800 East Main Street, Suite 100 Waukesha, WI 53186 Audit period: June 30, 2023 The findings from the June 30, 2023 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS-FEDERAL AWARD PROGRAMS AUDITS DEPARTMENT OF EDUCATION MATERIAL WEAKNESS 2023-001 Elementary and Secondary School Emergency Relief Fund - COVID 19 – CFDA No. 84.425 Condition: Claims are not reviewed by management prior to requesting reimbursement. Criteria: Internal controls should be in place to ensure the claims are reviewed prior to requesting reimbursement. Auditor’s recommendation: Internal controls procedures should be established to ensure the claims are properly completed prior to requesting reimbursement. Action Taken: M.C. College Preparatory School of Wisconsin, Inc.’s current procedures controlling the qualification, classification, and documentation of grant claims will be augmented by adding the following requirement of a formal review and recorded acknowledgment by the CEO of each claim prior to submission. “Final Review and Approval: All claims and documentation will be compiled by the Controller into a final submission package and presented to the CFO and CEO for final approval prior to submitting the claim to the appropriate agency. A record of such approval by both officers should be maintained in the permanent archive file for the claim.” If the Department of Education has questions regarding this plan, please call Alfred Keith IV at 414-264-6000. Sincerely yours, Alfred Keith IV Chief Education Officer

View Audit 298849

Finding 386539 (2023-001)

Significant Deficiency 2023

Menomonie Housing Authority

WI

Internal Control / Segregation of Duties Reporting

Corrective Action Planned: Due to the Authority's size, it is cost-prohibitive and impractical to achieve the ideal level of segregation of duties. The Authority has implemented as many controls and segregation of duties as practically possible for an organization of this size. Completion Date: Ongo...

Corrective Action Planned: Due to the Authority's size, it is cost-prohibitive and impractical to achieve the ideal level of segregation of duties. The Authority has implemented as many controls and segregation of duties as practically possible for an organization of this size. Completion Date: Ongoing

View Audit 298833

Finding 386538 (2023-007)

Material Weakness 2023

Metropolitan School District of Warren County

IN

Special Tests & Provisions Subrecipient Monitoring Material Weakness § 200.303

Finding 2023-007 – Education Stabilization Fund – Special Tests and Provisions - Wage Rate Requirements Contact Person Responsible for Corrective Action: Matthew Parkinson, CFO Contact Phone Number: 317-869-4364 Views of Responsible Official: We concur with the finding. Description of Corrective ...

Finding 2023-007 – Education Stabilization Fund – Special Tests and Provisions - Wage Rate Requirements Contact Person Responsible for Corrective Action: Matthew Parkinson, CFO Contact Phone Number: 317-869-4364 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: MSD Warren has construction projects at two sites payable out of ARP. MSD Warren’s contracts for those projects contain Davis-Bacon provisions. MSD Warren will collect payroll data to verify compliance with Davis-Bacon. Anticipated Completion Date: 12/15/24

View Audit 298830

Finding 386537 (2023-006)

Significant Deficiency 2023

Metropolitan School District of Warren County

IN

Internal Control / Segregation of Duties Reporting Significant Deficiency § 200.302 § 200.303 § 200.328

Finding 2023-006 – Education Stabilization Fund – Reporting Contact Person Responsible for Corrective Action: Matthew Parkinson, CFO Contact Phone Number: 317-869-4364 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: MSD Warren will submit a revis...

Finding 2023-006 – Education Stabilization Fund – Reporting Contact Person Responsible for Corrective Action: Matthew Parkinson, CFO Contact Phone Number: 317-869-4364 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: MSD Warren will submit a revised ESSER data report to DOE. Anticipated Completion Date: Completed as of the date of this report.

View Audit 298830

Finding 386533 (2023-004)

Significant Deficiency 2023

Metropolitan School District of Warren County

IN

Internal Control / Segregation of Duties Significant Deficiency Matching / Level of Effort / Earmarking

Finding 2023-004 – Title I Grants to Local Educational Agencies - Special Test and Provisions – Annual Report Card, High School Graduation Rate Audit Contact Person Responsible for Corrective Action: Matthew Parkinson, CFO Contact Phone Number: 317-869-4364 Views of Responsible Official: We concur...

Finding 2023-004 – Title I Grants to Local Educational Agencies - Special Test and Provisions – Annual Report Card, High School Graduation Rate Audit Contact Person Responsible for Corrective Action: Matthew Parkinson, CFO Contact Phone Number: 317-869-4364 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The CFO and Associate Superintendent will send a memo to principals and registrars defining documentation that must be maintained for mobility purposes. Anticipated Completion Date: 6/30/24

View Audit 298830

Finding 386522 (2023-002)

Significant Deficiency 2023

Metropolitan School District of Warren County

IN

Questioned Costs School Nutrition Programs Internal Control / Segregation of Duties § 200.303

Finding 2023-002 – Child Nutrition Cluster – Activities Allowed or Unallowed, Allowable Costs/Cost Principles Contact Person Responsible for Corrective Action: Matthew Parkinson, CFO Contact Phone Number: 317-869-4364 Views of Responsible Official: We concur with the finding. Description of Corre...

Finding 2023-002 – Child Nutrition Cluster – Activities Allowed or Unallowed, Allowable Costs/Cost Principles Contact Person Responsible for Corrective Action: Matthew Parkinson, CFO Contact Phone Number: 317-869-4364 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Business Office and Payroll staff will review a Labor Distribution Report to verify that the staff is only paying appropriate personnel from the Food Service Fund. Anticipated Completion Date: 6/30/24

View Audit 298830 Questioned Costs: $1

Finding 386517 (2023-001)

Significant Deficiency 2023

Howard County

MD

Significant Deficiency Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Views of Responsible Officials and Planned Corrective Action: The County agrees with the finding and recommendation. The County was awarded $32M in new funding to address the housing needs of low- and moderate-income residents facing eviction and/or homelessness during the COVID pandemic. Staff was ...

Views of Responsible Officials and Planned Corrective Action: The County agrees with the finding and recommendation. The County was awarded $32M in new funding to address the housing needs of low- and moderate-income residents facing eviction and/or homelessness during the COVID pandemic. Staff was focused on effectively managing the COVID funding during that time to help keep residents safely housed; therefore, the monitoring tasks for HOME-assisted TBRA were not completed as required. The Department is creating additional Standard Operating Procedures (SOPs) to ensure all steps are being taken to meet monitoring requirements, even if current personnel changes so the process can continue effectively and on time. Action taken in response to finding: The participating jurisdiction must perform on-site inspections of rental housing occupied by tenants receiving HOME/HOME-ARP-assisted tenant-based rental assistance to determine compliance with housing quality standards (24 CFR sections 92.209(i), 92.251(f), and 92.504(d)). 1. Completion of a HOME/HOME-ARP Training Plan 2. Completion of a HOME/HOME-ARP Monitoring Completion Plan 3. Ongoing prioritizing of progress as part of the regular agenda in twice monthly Finance & Grants meetings 4. Completion of an SOP for current and future continuity of function Regarding HOME-ARP funds: the rental units must comply with the same requirements as HOME per 24 CFR 92.251 for (a) new construction, (b)rehabilitation projects, (c)(1) and (2) acquisition of standard housing, (e) manufactured housing, and (f) on-going property condition standards. 1. These requirements are being added to the HOME/HOME-ARP Reports, as part of the Monitoring Completion Plan 2. Ongoing prioritizing of progress as part of the regular agenda in twice monthly Finance & Grants meetings 3. Completion of an SOP for current and future continuity of function Name of contact person (s) responsible for the corrective action plan: Kim Zanti, Division Chief, Community Planning and Grants

View Audit 298820

Finding 386497 (2023-033)

Significant Deficiency 2023

State of Arkansas

AR

Reporting Internal Control / Segregation of Duties

Views of Responsible Officials and Planned Corrective Action: Due to the prior year finding, management set a goal to ensure reporting deadlines are met by hiring an additional grants accounting staff member dedicated to monitor the head start program regulations and ensure reports are completed an...

Views of Responsible Officials and Planned Corrective Action: Due to the prior year finding, management set a goal to ensure reporting deadlines are met by hiring an additional grants accounting staff member dedicated to monitor the head start program regulations and ensure reports are completed and filed timely. Grants accounting staff planned to utilize checklist functionality in the new financial system that will send required task notifications prior to reporting due dates to assist in meeting reporting deadlines. A new staff member was hired in July 2023. The responsibilities of the new staff member required several months of training and additional time to reconcile the head start accounts causing the January 30, 2023, report to be filed 3 days late. New processes have been implemented where the staff member assigned to the head start program meets weekly with the head start finance manager and director to discuss expenses allocated to the grants, assign tasks to be complete each week, and discuss reporting needs and deadlines. The new implemented processes have proven to assist in proper oversight and accurate financial management of the grants and allowed us to meet the last reporting deadline in November 2023. Anticipated Completion Date: Implemented Contact Person: Name: Kristy L. Walters, MBA, CPA, CHFP, CISA Title: Associate Vice Chancellor for Finance & Treasurer Agency: University of Arkansas for Medical Sciences Address: UAMS, 4301 W. Markham St, Slot 632 City, State, Zip: Little Rock, AR 72205 Phone Number: 501-682-6836, (501) 686-8137 Email Address: walterskristy@uams.edu

View Audit 298801

Finding 386496 (2023-032)

Material Weakness 2023

State of Arkansas

AR

Questioned Costs Subrecipient Monitoring Eligibility § 200.303 § 200.516

Views of Responsible Officials and Planned Corrective Action: Due to the health concerns of the pandemic as well as unprecedented claims volume, claimants were not required to come into a local office for identity verification, the waiting week was waived for 2020, and the requirements for work sear...

Views of Responsible Officials and Planned Corrective Action: Due to the health concerns of the pandemic as well as unprecedented claims volume, claimants were not required to come into a local office for identity verification, the waiting week was waived for 2020, and the requirements for work search were adjusted in order to protect employees and claimants. Before the pandemic, all claimants were required to come to the local office to verify their identity. Removing these process controls resulted in several consequences as itemized below: • By waiving the waiting week, the claimant was able to receive payment the following week. For example, a fraudster could file a claim on Friday, then receive payment on Sunday, removing the typical week that an employer would respond to validate the separation from employment. • The information mailed to the employer and claimant were not received before payments were made due to the lack of waiting week. • Businesses were closed at that time and did not respond to the unemployment paperwork timely to report fraudulent claims. • Identity theft fraudsters often changed the address of the individuals for which they had filed claims in order to prevent the victims from being notified and reporting the fraud. In 2020, the work search requirement was reinstated. In 2021, all claimants had to verify their identity in-person at the local office before the claim was opened for a regular unemployment claim. The UIdentify program was utilized for identity verification for the PUA claims filed after January 1, 2021. The waiting week was reinstated in January 2021, which lengthened the time period for employers to respond before payment was issued. In addition, Internal Audit created the Fraud Investigation Unit and hired additional staff to focus on investigating the identity theft fraud claims. When the perpetrator is identified, a determination is issued and an overpayment is established in the perpetrator’s name/SSN for collection. The NASWA Integrity Data Hub (IDH) crossmatch was implemented in July 2020 as well in an effort to identify additional fraudulent claims for investigation. ADWS was the first UI program to implement 2 projects with the Department of Labor for identity verification. One is using Login.gov and the other involves the United States Postal Service where they verify the identity of claimants for using multifactor authentication and in person presentation of ID. The Login.gov pilot started in 2022 and the USPS pilot project started in 2023. 1. The Login.gov project uses the current system that Federal agencies use to verify identity and went into service in Arkansas as of March 2022. A link is given to the claimant, when they select verify ID through login.gov and go through the steps to verify their identity through the federal government system. If they are approved, we are sent an IA2 verification to the UI processing system to allow staff to match back to the claim to prove ID verification. 2. The United States Postal Service project, implements in Arkansas March 2023, offers the claimant the same link as Login.gov, but grants the additional option to verify their identity at any US Post Office in the country. A barcode is created and must be taken with a valid government-issued ID (they are given examples) along with proof of current address to the post office in person. If they are approved, we are sent an IA2 verification to the UI processing system to allow staff to match back to the claim to prove ID verification. Anticipated Completion Date: Corrective action was taken for the ALA staff recommendations. Contact Person: Name: Sheri Rooney Title: Program Administrator Agency: Division of Workforce Services Address: 2 Capitol Mall City, State, Zip: Little Rock, AR 72201 Phone Number: 501-682-3382 Email Address: Sheri.Rooney@arkansas.gov

View Audit 298801 Questioned Costs: $1

Finding 386495 (2023-031)

Material Weakness 2023

State of Arkansas

AR

Special Tests & Provisions Subrecipient Monitoring Material Weakness

Views of Responsible Officials and Planned Corrective Action: DHS concurs with the finding. The agency will request that CMS grant a full exemption from the requirement that a state enter a contract with a Medicaid Recovery Audit Contractor. Anticipated Completion Date: 5/31/2024 Contact Person: ...

Views of Responsible Officials and Planned Corrective Action: DHS concurs with the finding. The agency will request that CMS grant a full exemption from the requirement that a state enter a contract with a Medicaid Recovery Audit Contractor. Anticipated Completion Date: 5/31/2024 Contact Person: Name: Elizabeth Pitman Title: Director, Division of Medical Services Agency: Department of Human Services Address: 700 Main Street City, State, Zip: Little Rock, AR 72201 Phone Number: 501-244-3944 Email Address: Elizabeth.Pitman@dhs.arkansas.gov

View Audit 298801

Finding 386493 (2023-029)

Material Weakness 2023

State of Arkansas

AR

Questioned Costs Subrecipient Monitoring Eligibility

Views of Responsible Officials and Planned Corrective Action: DHS concurs with the finding. The agency is in the process of developing an MMIS change that will automatically update member profiles to accurately reflect incarceration dates. This will ensure capitated payments are paused and reinstat...

Views of Responsible Officials and Planned Corrective Action: DHS concurs with the finding. The agency is in the process of developing an MMIS change that will automatically update member profiles to accurately reflect incarceration dates. This will ensure capitated payments are paused and reinstated in a timely manner and that recoupments and repayments are subsequently processed. The agency is conducting an ARIES system review to determine the root cause of the incorrect eligibility determinations and will identify and implement any needed updates to the automatic renewal process. Anticipated Completion Date: 6/30/2024 Contact Person: Name: Mary Franklin Title: Director, Division of County Operations Agency: Department of Human Services Address: 700 Main Street City, State, Zip: Little Rock, AR 72201 Phone Number: 501-681-8377 Email Address: Mary.Franklin@dhs.arkansas.gov

View Audit 298801 Questioned Costs: $1

Finding 386486 (2023-023)

Material Weakness 2023

State of Arkansas

AR

Subrecipient Monitoring Special Tests & Provisions Matching / Level of Effort / Earmarking

Views of Responsible Officials and Planned Corrective Action: DHS concurs, in part, and disputes, in part, the finding. DHS has submitted and received approval from CMS for changes to the Dental Managed Care contract that requires the completion of annual audited financial reports. The agency disa...

Views of Responsible Officials and Planned Corrective Action: DHS concurs, in part, and disputes, in part, the finding. DHS has submitted and received approval from CMS for changes to the Dental Managed Care contract that requires the completion of annual audited financial reports. The agency disagrees that the audited financial reports submitted by the PASSE and Dental Managed Care Organizations (DMO) do not comply with 42 CFR 438.3(M). CMS guidance pertaining to that regulation provides that states have the flexibility to specify the applicable generally accepted accounting and auditing principles for the audited financial reports in the managed care plan contracts. The Arkansas Insurance Department also requires insurers to submit annual audited financial statements. Ark. Code Ann. 23-61-108 requires PASSE’s and DMO’s to follow the National Association of Insurance Commissioners Accounting Practices and Procedures Manual. DHS interprets 42 CFR 438.3(M) and its related guidance to permit the State Medicaid Agency flexibility to adopt the same accounting principles as the State Insurance Agency. As a practical matter, DHS reviewed the use of the audited financial statements and the information necessary to be contained within those statements. DMS discussed the use of the audited financial statements with the External Quality Review Organization (EQRO) that performs our External Quality Review. The EQRO confirmed that audited financial statements that complied with the Arkansas statutory basis would be satisfactory for review purposes. Anticipated Completion Date: Complete Contact Person: Name: Elizabeth Pitman Title: Director, Division of Medical Services Agency: Department of Human Services Address: 700 Main Street City, State, Zip: Little Rock, AR 72201 Phone Number: 501-244-3944 Email Address: Elizabeth.Pitman@dhs.arkansas.gov

View Audit 298801

Finding 386484 (2023-022)

Material Weakness 2023

State of Arkansas

AR

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles

Views of Responsible Officials and Planned Corrective Action: DHS concurs with the finding. The agency will update its written reporting instructions for Medicaid and CHIP to cover all items in the report workbooks. After the conclusion of the audit testing, the agency confirmed that the noted vari...

Views of Responsible Officials and Planned Corrective Action: DHS concurs with the finding. The agency will update its written reporting instructions for Medicaid and CHIP to cover all items in the report workbooks. After the conclusion of the audit testing, the agency confirmed that the noted variance between the agency’s accounting system and reported expenditures for the quarter ended September 30, 2022, was below the 5% threshold which requires an explanation to be provided to CMS financial analysts. The agency has reassigned resources to the Medicaid reporting section which will allow for additional time to spend researching variances identified in quarterly reconciliations. The agency also confirmed that the understatement of the federal portion of the September 30, 2022, CMS-64 report was $10,582, and the overstatement of the federal portion of the of the March 31, 2023, CMS-64 report was $30,664. The agency will correct these errors through an adjustment on an upcoming submission of the CMS-64 report. Anticipated Completion Date: 7/31/2024 Contact Person: Name: Jason Callan Title: Medicaid Chief Financial Officer Agency: Department of Human Services Address: 700 Main Street City, State, Zip: Little Rock, AR 72201 Phone Number: 501-320-6540 Email Address: Jason.Callan@dhs.arkansas.gov

View Audit 298801 Questioned Costs: $1

Finding 386459 (2023-009)

Significant Deficiency 2023

State of Arkansas

AR

Student Financial Aid Subrecipient Monitoring Special Tests & Provisions

Views of Responsible Officials and Planned Corrective Action: Management understands the recommendations provided in the finding. We are planning on updating our 2021 Risk Assessment with our campus community in the near future. In accordance with ALA's recommendation, we will focus on GLBA 16 CFR...

Views of Responsible Officials and Planned Corrective Action: Management understands the recommendations provided in the finding. We are planning on updating our 2021 Risk Assessment with our campus community in the near future. In accordance with ALA's recommendation, we will focus on GLBA 16 CFR 314 elements and financial aid data. As with our 2021 Risk Assessment, our plan will be reviewed and accepted by our Chancellor. We intend to have the Risk Assessment updated and reviewed by June 30, 2024. We will also coordinate the risks identified with the extensive list of controls and policies that currently protect student’s financial aid information. These include: Acceptable Use Policy_V7_3.pdf Antivirus and Malware Policy_V2_1.pdf Cloud Services Policy_V1_2.pdf Confluence Screenshots Of Contact Information For Critical Systems (1).pdf Data Classification Policy_V1_2.pdf Data Encryption Policy_V7_1.pdf Data Management Use Protection Policy_V7_2.pdf Data Protection Policy_V7_2 Data Protection Policy_V7_2.pdf Disaster Recovery Business Continuity System Recovery Prioritization List_V1_2.pdf Disaster Recovery Procedure_V1_5.pdf Drive Data Deletion Policy_V7_2.pdf E-Learning Policies_V7_1.pdf Email and Digital Communication Policy_V8_2.pdf Email and Digital Communication Policy_V8_2.pdf Employee Data Deletion Policy_V7_2.pdf Encryption of Sensitive Data on Transmission Policy_V7_2.pdf Faculty Senate Legislation Reference_V6.1.pdf Firewall Blacklist and Whitelist Policy_V7_2.pdf Firewall Management Procedure_V7_2.pdf GLBA Risk assessment.docx Incident Response and Forensic Analysis Procedures_V7_5.pdf IT Employee Departure Procedures_V7_2.pdf IT Security Awareness and Competencies Policy_V1_5.pdf IT Services System Administration Privileged Access Management Policy_V7_2.pdf IT System Backup Procedures_V7_2.pdf IT System Patching Process_V7_3.pdf Lab / Classroom Administrative Rights Exception Request_V6_1.pdf Local Firewall Procedures for Workstations and Mobile Devices_V7_2.pdf Log Review Policy_V2_1.pdf Mobile Device Security - Remote Email Destruction Process_V1_1.pdf Mobile Device Security Policy_V2_1.pdf Multi-factor Authentication - Information Technology Services - UA Little Rock.pdf Network Patching Process_V1_1.pdf PCI Compliance _ Training Policy_V7_2.pdf Physical Security Policy_V1_3.pdf Retention of Records Policies_V7_2.pdf Security and Incident Response Team Policy_V1_3.pdf Security and IT System Access Policy_V1_2.pdf Student Account Deletion Policy_V7_2.pdf System Log Requirements_V8_2.pdf UALR Change Management Policy 2.2.pdf Vendor Remote Access Policy_V1_1.pdf Vulnerability Scan Policy_V7_2.pdf Wireless Network Guest Security Policy_V1_1.pdf Wireless Security Policy_V1_2.pdf Workstation Administrative Rights Exception Request_V6_1.pdf Anticipated Completion Date: June 30, 2024 Contact Person: Name: Gerald J. Ganz, Jr. Title: Vice Chancellor for Finance & Administration Agency: University of Arkansas at Little Rock Address: 2801 S. University Avenue City, State, Zip: Little Rock, AR, 72204 Phone Number: 501-916-5622 Email Address: GJGanz@ualr.edu

View Audit 298801

Finding 386455 (2023-005)

Significant Deficiency 2023

State of Arkansas

AR

Questioned Costs Subrecipient Monitoring Eligibility § 200.303 § 200.516

Views of Responsible Officials and Planned Corrective Action: Due to the health concerns of the pandemic as well as unprecedented claims volume, claimants were not required to come into a local office for identity verification, the waiting week was waived for 2020, and the requirements for work sear...

Views of Responsible Officials and Planned Corrective Action: Due to the health concerns of the pandemic as well as unprecedented claims volume, claimants were not required to come into a local office for identity verification, the waiting week was waived for 2020, and the requirements for work search were adjusted in order to protect employees and claimants. Before the pandemic, all claimants were required to come to the local office to verify their identity. Removing these process controls resulted in several consequences as itemized below: • By waiving the waiting week, the claimant was able to receive payment the following week. For example, a fraudster could file a claim on Friday, then receive payment on Sunday, removing the typical week that an employer would respond to validate the separation from employment. • The information mailed to the employer and claimant were not received before payments were made due to the lack of waiting week. • Businesses were closed at that time and did not respond to the unemployment paperwork timely to report fraudulent claims. • Identity theft fraudsters often changed the address of the individuals for which they had filed claims in order to prevent the victims from being notified and reporting the fraud. In 2020, the work search requirement was reinstated. In 2021, all claimants had to verify their identity in-person at the local office before the claim was opened for a regular unemployment claim. The UIdentify program was utilized for identity verification for the PUA claims filed after January 1, 2021. The waiting week was reinstated in January 2021, which lengthened the time period for employers to respond before payment was issued. In addition, Internal Audit created the Fraud Investigation Unit and hired additional staff to focus on investigating the identity theft fraud claims. When the perpetrator is identified, a determination is issued and an overpayment is established in the perpetrator’s name/SSN for collection. The NASWA Integrity Data Hub (IDH) crossmatch was implemented in July 2020 as well in an effort to identify additional fraudulent claims for investigation. ADWS was the first UI program to implement 2 projects with the Department of Labor for identity verification. One is using Login.gov and the other involves the United States Postal Service where they verify the identity of claimants for using multifactor authentication and in person presentation of ID. The Login.gov pilot started in 2022 and the USPS pilot project started in 2023. 1. The Login.gov project uses the current system that Federal agencies use to verify identity and went into service in Arkansas as of March 2022. A link is given to the claimant, when they select verify ID through login.gov and go through the steps to verify their identity through the federal government system. If they are approved, we are sent an IA2 verification to the UI processing system to allow staff to match back to the claim to prove ID verification. 2. The United States Postal Service project, implements in Arkansas March 2023, offers the claimant the same link as Login.gov, but grants the additional option to verify their identity at any US Post Office in the country. A barcode is created and must be taken with a valid government-issued ID (they are given examples) along with proof of current address to the post office in person. If they are approved, we are sent an IA2 verification to the UI processing system to allow staff to match back to the claim to prove ID verification. Anticipated Completion Date: Corrective action was taken for the controls the ALA staff recommended. Contact Person: Name: Sheri Rooney Title: Program Administrator Agency: Division of Workforce Services Address: 2 Capitol Mall City, State, Zip: Little Rock, AR 72201 Phone Number: 501-682-3382 Email Address: Sheri.Rooney@arkansas.gov

View Audit 298801 Questioned Costs: $1

Finding 386450 (2023-001)

Material Weakness 2023

Kimball School District No. 7-2

SD

Internal Control / Segregation of Duties Material Weakness

Dr. Chris Noid is the contract person responsible for the corrective action plan for this finding. This finding is due to the limited number (one) of employees in the district's business office. Staffing the office at an efficient and financially feasible level precludes the hiring of enough perso...

Dr. Chris Noid is the contract person responsible for the corrective action plan for this finding. This finding is due to the limited number (one) of employees in the district's business office. Staffing the office at an efficient and financially feasible level precludes the hiring of enough personnel to provide an ideal environment for the internal controls. Kimball School District adopted an Internal Controls and Procedures policy in December 2017 and was updated in June 2021. We are aware of the weakness in internal controls and will adhere to policies and procedures we have in place while providing compensating controls to reduce the risk. This will be an ongoing process.

View Audit 298800

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