Corrective Action Plans

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October 5, 2023 To: United States Department of Health and Human Services Generations Family Health Center, Inc. respectfully submits the following corrective action plan for the year ended June 30, 2023. CohnReznick LLP 350 Church Street Hartford, CT 06103 Audit Period: June 30, 2023 The findings f...
October 5, 2023 To: United States Department of Health and Human Services Generations Family Health Center, Inc. respectfully submits the following corrective action plan for the year ended June 30, 2023. CohnReznick LLP 350 Church Street Hartford, CT 06103 Audit Period: June 30, 2023 The findings from the June 30, 2023 schedule of findings and questioned costs are discussed below. The finding is numbered consistently with the numbers assigned in the schedule. FINANCIAL STATEMENT FINDINGS: Finding 2023.001- Sliding Fee Scale Documentation Recommendation The Center should establish a system of internal controls to ensure that all sliding fee discounts are properly calculated based on family size and income. Action Taken: Upon review of the finding, it was determined that the system calculated the slide correctly, but the procedure code was assigned to the incorrect procedure class, creating the error. Beginning July 1, 2023, Management has: • Reviewed the entire fee schedule, schedule of discounts and procedure groupings in the practice management system compared to the board approved fee schedule. Only one procedure group required correction of one procedure code. • In addition, the Director of Patient Revenue will work with the Electronic Health Record vendor to organize the system procedure classes for all procedure codes and financial classes to decrease any crosswalk issues or redundancies. In addition, the Director of Patient Revenue will work with the EHR vendor to upload fee schedules and sliding fee discount groups electronically. Previous internal controls adopted include: • Upon creating adding a new charge to the system, the Director of Patient Revenue posts the charge into a test patient account to confirm that the standard and slide rates match those entered on the fee schedule • At the annual review and/or revision of the Agency’s fee schedule, the Billing Manager assists the Director of Patient Revenue in reviewing every charge on the updated/approved year’s fee schedule to confirm the rates and slide assignment match the Fee Schedule. • A quarterly audit of insured and self-pay patients occur to review that adjustments are correct per agency policy. This action decreases chances of system issues that cause erroneous adjustments going unnoticed. If the Cognizant or Oversight Agency for Audit has questions regarding this plan, please call: Debra Savoie, CFO at (860) 456-6271.
FINDINGS- MAJOR FEDERAL AWARD PROGRAMS Material Weakness U.S. DEPARTMENT OF Transportation- Airport Improvement Program- AL Number 20.106 Finding No.: 2023-003 Condition: The Authority's accounting function is controlled by a limited number of individuals resulting in the inadequate segregati...
FINDINGS- MAJOR FEDERAL AWARD PROGRAMS Material Weakness U.S. DEPARTMENT OF Transportation- Airport Improvement Program- AL Number 20.106 Finding No.: 2023-003 Condition: The Authority's accounting function is controlled by a limited number of individuals resulting in the inadequate segregation of duties. Recommendation: The Authority should segregate duties where possible. The Board should be aware of this problem and closely review and approve all financial related information. Action Taken: The Authority concurs with the recommendation. The Authority has reviewed and continues to review its financial policies and procedures to better segregate duties where possible. The Treasurer continually reminds the Board of their responsibility in regards to reviewing and approving financial items and asking questions. It is not cost feasible to hire additional personnnel. Anticipated Date of Completion: Ongoing
ESTABLISH INTERNAL CONTROL OVER FINANCIAL STATEMENT PREPARATION AND REVIEW Recommendation: The District should review and approve the proposed auditor adjusting entries and the adequacy of schedule of the expenditures of federal awards disclosures prepared by the auditors and apply analytic proc...
ESTABLISH INTERNAL CONTROL OVER FINANCIAL STATEMENT PREPARATION AND REVIEW Recommendation: The District should review and approve the proposed auditor adjusting entries and the adequacy of schedule of the expenditures of federal awards disclosures prepared by the auditors and apply analytic procedures to the draft financial statements, among other procedures as considered necessary by management. Action Taken: The District will prepare of schedule of federal expenditures based on expenditure categories as found in the District's general ledger and value of commodities for lunch program. This will be prepared using an excel spreadsheet. The District will review the audit adjustments as presented by the external auditors including those related to the federal expenditures and the related worksheet. We will ensure the adjustments made to federal award expenditures are appropriate by examining the nature and amount of the adjustments. Questionable items will be discussed and agreed upon between the District and the auditors. After review and approval of the entries, they will be input into the District's general ledger and the SEFA spreadsheet will be updated. This will be compared to the SEFA that is included in the audit report and if they are in agreement, this will be approved by management. All variances will be addressed prior to finalization of the audit report and submission to the Nebraska. If the Nebraska Department of Education has questions regarding this plan, please call Dr. Heather Nebesniak at 308.728.5013. Department of Education as well as to the Federal Audit Clearinghouse.
Familiarize our staff with financial reporting requirements and segregate duties to the extent possible.
Familiarize our staff with financial reporting requirements and segregate duties to the extent possible.
Finding 2023-1 - Lack of Segregation of Duties The District understands that this is a significant deficiency but feels it is not cost-effective at this time to hire additional employees to properly segregate duties. We feel that the oversight performed by the Superintendent and Board of Educatio...
Finding 2023-1 - Lack of Segregation of Duties The District understands that this is a significant deficiency but feels it is not cost-effective at this time to hire additional employees to properly segregate duties. We feel that the oversight performed by the Superintendent and Board of Education over the financial statement activity and reports of the District is adequate to help mitigate the lack of segregation of duties. We believe it would be inefficient and cost prohibitive to hire the additional employees needed to properly segregate duties so at this time we do not plan on making any changes. However, we will continue to monitor this situation and periodically determine if it is cost-effective for us to properly segregate duties.
Finding 2129 (2023-001)
Significant Deficiency 2023
The District will improve segregation of grant expenditures to ensure the amounts claimed agree to the general ledger. The District will also increase review and oversight of grant reporting to ensure accuracy.
The District will improve segregation of grant expenditures to ensure the amounts claimed agree to the general ledger. The District will also increase review and oversight of grant reporting to ensure accuracy.
The entity's Board continually evaluates the distribution of duties to employees and closely monitors all accounting functions. The School District has implemented controls within its accounting functions to mitigate the lack of segregation of duties but recognizes that this should still be a concer...
The entity's Board continually evaluates the distribution of duties to employees and closely monitors all accounting functions. The School District has implemented controls within its accounting functions to mitigate the lack of segregation of duties but recognizes that this should still be a concern for the School District and the Board.
The Senior Accountant responsible for this property, Corey Krajewski (krajewski@wdchoc.org) will ensure that appropriate fees will be allocated and charged.
The Senior Accountant responsible for this property, Corey Krajewski (krajewski@wdchoc.org) will ensure that appropriate fees will be allocated and charged.
View Audit 3649 Questioned Costs: $1
The Asset Manager/Financial Analyst, Ellen Quinn (quinn@wdchoc.org) and Senior Accountant responsible for this property, Corey Krajewski (krajewski@wdchoc.org) will ensure that replacement reserve withdrawals will be supported by actual expenses.
The Asset Manager/Financial Analyst, Ellen Quinn (quinn@wdchoc.org) and Senior Accountant responsible for this property, Corey Krajewski (krajewski@wdchoc.org) will ensure that replacement reserve withdrawals will be supported by actual expenses.
Management has reviewed all files, obtained the required information, and corrected calculations. Site staff will be trained in correct procedures.
Management has reviewed all files, obtained the required information, and corrected calculations. Site staff will be trained in correct procedures.
Management has reviewed all files, obtained the required information, and corrected calculations. Site staff will be trained in correct procedures.
Management has reviewed all files, obtained the required information, and corrected calculations. Site staff will be trained in correct procedures.
2023-002 Department of Justice Housing – Assistance Listing No. 16.320 Recommendation: We recommend reimbursement requests be reviewed and traced back to supporting documentation prior to the filing of the reimbursement request. Explanation of disagreement with audit finding: There is no disagreemen...
2023-002 Department of Justice Housing – Assistance Listing No. 16.320 Recommendation: We recommend reimbursement requests be reviewed and traced back to supporting documentation prior to the filing of the reimbursement request. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: A second staff person has completed the Department of Justice Grants Financial Management Training and is now qualified to work on the federal grants. This will allow the agency to have someone other than that the person creating the reimbursement material to request the reimbursement. This adds an additional layer of control over the amount requested for reimbursement. Name(s) of the contact person(s) responsible for corrective action: Peter Hermann Planned completion date for corrective action plan: November 6, 2023
View Audit 3565 Questioned Costs: $1
Finding 2019 (2023-001)
Significant Deficiency 2023
October 24, 2023 Corrective Action Plan for University of San Diego Audit finding 2023-001 FINDING 2023-001 – Special Tests and Provisions – Borrower Data Transmission and Reconciliation: Significant Deficiency in Internal Control Over Compliance Criteria –34 CFR section 685.300(b)(5): On a monthly ...
October 24, 2023 Corrective Action Plan for University of San Diego Audit finding 2023-001 FINDING 2023-001 – Special Tests and Provisions – Borrower Data Transmission and Reconciliation: Significant Deficiency in Internal Control Over Compliance Criteria –34 CFR section 685.300(b)(5): On a monthly basis, the University of San Diego must reconcile institutional records with Direct Loan funds received from the Secretary and Direct Loan disbursement records submitted to and accepted by the Secretary. Condition/Context – The University of San Diego operates a law school and an undergraduate and graduate school. A sample of 6 direct loan reconciliations were selected from the population of all reconciliations performed by the University, under both schools during the year ended June 30, 2023. We obtained the supporting schedules used to reconcile the disbursed direct loan funds to the federal government’s records. The University did not complete reconciliations of its direct loan program disbursements for the law school between December 2022 and June 2023. Cause – There was turnover in the position responsible for reconciling this data, and the responsibility did not transfer to another individual, and as a result, the reconciliations were not completed. Effect – There is a chance that the University of San Diego’s records may not match the federal government’s records of direct loan disbursement. Recommendation – The auditors recommend the University of San Diego revise the existing policies and procedures to ensure when a change in personnel occurs, responsibilities appropriately transfer to a new individual. Corrective action plan – Management concurs with this finding. This exception was due to the monthly reconciliation not being part of the established policies and procedures for the Law School Financial Aid Office. As a result, during staff turnover the interim staff were unaware of the responsibilities and requirements for the monthly reconciliation. Management updated the direct lending servicing system reconciliation procedures for the Law School to clearly delineate the responsible parties. Management believes these enhancements will be sufficient to prevent future errors. Anticipated completion date: October 2023 Persons responsible: Mike Chavez, Director of JD Admissions, Financial Aid & Diversity Initiatives
The Agency is updating its process to calculate the indirect costs in accordance with the revised notice of award (NOA) dated March 10, 2023. Additionally, the Agency will provide further training to all individuals involved in the financial management of federal awards. On a monthly basis, the ca...
The Agency is updating its process to calculate the indirect costs in accordance with the revised notice of award (NOA) dated March 10, 2023. Additionally, the Agency will provide further training to all individuals involved in the financial management of federal awards. On a monthly basis, the calculation of indirect costs eligible for reimbursement under this award will be compared to the indirect costs allowed for in the NOA. This calculation will be secondarily reviewed by an individual having financial oversight on federal awards to ensure that any reimbursement request is computed in accordance with the NOA. The reimbursement request will then be submitted only after this verification has been completed. Contact person responsible for corrective action: Scott Moore, Chief Financial Officer Anticipated completion date: December 31, 2023
Finding 1984 (2023-001)
Significant Deficiency 2023
Finding: 2023-001 Name of contact person: "Brittany Majors (Program Manager), Donna Rimmer (AM Supervisor), Joanna Thompson and Meredith Farmer (Leadworkers)" Corrective Action: The County continues to revise the procedural requriement regarding document management and ...
Finding: 2023-001 Name of contact person: "Brittany Majors (Program Manager), Donna Rimmer (AM Supervisor), Joanna Thompson and Meredith Farmer (Leadworkers)" Corrective Action: The County continues to revise the procedural requriement regarding document management and retention of verification used to determine eligibility. Each supervisor continues to conduct individual and unit meeting/trainings to inform parties of the errors discovered and how to reduce/eliminate in future processing. The County would like to notate that these errors discovered was during COVID where individuals could not be reduced/terninated. Staff has also completed the State Mastering Medicaid Policy Training that is provided monthly. The supervisor has also conducted an Income and Deductible training. Proposed Completion Date: 10/20/2023
Management has reviewed all files, obtained the required information, and corrected calculations. Site staff will be trained in correct procedures.
Management has reviewed all files, obtained the required information, and corrected calculations. Site staff will be trained in correct procedures.
Management has reviewed all files, obtained the required information, and corrected calculations. Site staff will be trained in correct procedures.
Management has reviewed all files, obtained the required information, and corrected calculations. Site staff will be trained in correct procedures.
Management has corrected the error.
Management has corrected the error.
Management has moved funds to provide for full insurance coverage.
Management has moved funds to provide for full insurance coverage.
Management has corrected the error.
Management has corrected the error.
Return of Title IV (R2T4) Errors Planned Corrective Action: Our process for identifying unofficial withdrawals begins with a report from our Workday software to identify students who had unearned credits in a semester at the conclusion of that semester, after the grade due date. We then reach out to...
Return of Title IV (R2T4) Errors Planned Corrective Action: Our process for identifying unofficial withdrawals begins with a report from our Workday software to identify students who had unearned credits in a semester at the conclusion of that semester, after the grade due date. We then reach out to the individual professors of the courses and/or the Instructional Design team to determine if each student completed the semester or if (s)he had unearned credits having ceased attending at some point during the semester. If the student ceased attending, we would determine if a Return of Title IV (R2T4) calculation was needed and would complete it if necessary. The report was corrected for AY 2022/2023 to include No Credit (NC), Incomplete (I) and Failed (F) grades to enable PLNU to identify all the students who need to be reviewed going forward. In addition, we have added to our process instructions to run this report after the grades for module 1 are due, and after the grades for module 2 are due, rather than at the end of each semester. This was intended to ensure the review of any unofficial withdrawals in a timelier manner, meeting the 45-day deadline for any possible returns that must be made. The modified report, however, produced a far greater number of students for review, which was too broad of a selection and was unmanageable. We are working to refine the reporting criteria further to accurately identify students who require review and we have assigned additional staff for the review process. Person Responsible for Corrective Action Plan: Daniel Reed, Director of Financial Aid; Joanna Castro, Associate Director of Financial Aid; Jamie Asche, Director of Student Financial Services Business Analysis and Compliance Anticipated Date of Completion: 1/1/2024
Current Year Findings Corrective Action Plan 2023-001 Improper application of sliding fee discount CFDA Nos. – 93.224 and 93.527 Federal Award ID # and Year – 5 H80CS00744-21-00 Program Year 2023 Federal Agency Name: U.S. Department of Health and Human Services Type of finding Significant deficiency...
Current Year Findings Corrective Action Plan 2023-001 Improper application of sliding fee discount CFDA Nos. – 93.224 and 93.527 Federal Award ID # and Year – 5 H80CS00744-21-00 Program Year 2023 Federal Agency Name: U.S. Department of Health and Human Services Type of finding Significant deficiency in internal control over compliance (recurring) Criteria or Specific Requirement Special Tests and Provisions: Sliding Fee Discounts per Title 42 Chapter 1 Subchapter D Section 51c303(f) Condition The Organization’s sliding fee program provides discounts on patient services based upon the individual’s level of income. However, the Organization applied the incorrect discount based upon the individual’s income per the Organizations sliding fee discount policy. Cause Clerical error in applying the sliding fee discount adjustment in the billing system for the patient. Effect or Potential Effect Improper sliding fee discounts given to patients. Questioned Costs None Context or Perspective Information A sample of 40 patients were tested out of the total population of 2,283 encounters. The sampling methodology used is not statistically valid. Two patients received the incorrect sliding fee discount based upon their income level. Recommendation We recommend that the Organization implement a verification process to ensure the sliding fee discounts being applied are in accordance with their sliding fee policy. Corrective Action Plan Hidalgo Medical Services (HMS) will implement an enhanced training program to ensure the sliding fee discounts are applied in accordance with the current sliding fee policy. A comprehensive re-training of current Patient Financial Services (PFS) Claims Reviewing staff will occur by December 2023. A training manual will be developed to include competency validation for each Claims Reviewer staff person, and the new training model will be used for all future Claims Reviewer staff. In addition, HMS will continue to use the training manual for all incoming Community Health Workers to ensure the sliding fee assessment continues to stay in compliance. 35 Main Clinic & Administration P.O. Box 550 530 DeMoss Street Lordsburg, NM 88045 Secondly, HMS will implement an enhanced training program and verification process to ensure the sliding fee discounts are applied in accordance with the current sliding fee policy. The Claims Reviewer Supervisor will randomly select at least 30% of SFS patient visits monthly to ensure billing adjustment accuracy. HMS has been working diligently over the last year to improve the sliding fee assessments, and all proper documentation has been obtained (the new auditing requirement will occur immediately). There were no findings this year on assessments, and we will apply a similar audit process and follow-up action plan to the billing adjustment process. Also, all errors found will be fixed right away. The Claims Reviewer Supervisor will report each month to the Chief Operating Officer (COO) the audit results, and the COO will report to the Chief Executive Officer (CEO) any findings and required corrections, if applicable. In addition, the Finance Director will continue randomly auditing the sliding fee assessments each month to ensure compliance with the program. The Chief Financial Officer will report each month to the CEO any findings and required correction, if applicable. Person Responsible: Sonia Jacquez, Claims Reviewer Supervisor, Teresa Carrasco, Patient Specialist Services Director, Amanda Frost, Chief Operating Officer, Jamie McMahen, Finance Director, and Gretchen Cannon, Chief Financial Officer. Anticipated Completion Date: December 31, 2023.
Name of Contact Person: Daniel Schuler, Business and Operations Manager Corrective Action Plan: The District did identify in late spring/early summer that the existing relationship with US Foods had not been bid in the prior year. In order to address this issue, the District Administration identifi...
Name of Contact Person: Daniel Schuler, Business and Operations Manager Corrective Action Plan: The District did identify in late spring/early summer that the existing relationship with US Foods had not been bid in the prior year. In order to address this issue, the District Administration identified, recommended and received Board of Education approval to access a US Foods State of Alaska Contract with the State of Alaska Department of Corrections. This action, coupled with the one-year extension of an existing agreement with Alaskan & Proud Markets for the purchase of milk, will bring the District into compliance with procurement procedures as outlined by the National School Lunch Program and DEED. Proposed Completion Date: December 2023.
Name of Contact: Daniel Schuler, Business and Operations Manager Corrective Action Plan: The corrective action plan noted above for Finding 2023-001 will resolve Finding 2023-002 as well. The prior Business and Operations Manager started the annual verification process, however, did not follow thro...
Name of Contact: Daniel Schuler, Business and Operations Manager Corrective Action Plan: The corrective action plan noted above for Finding 2023-001 will resolve Finding 2023-002 as well. The prior Business and Operations Manager started the annual verification process, however, did not follow through on finishing the process prior to her resignation from the District. Upon her departure from the District, she did not communicate that the process had not been completed. I am currently working on the annual verification process as prescribed by DEED and the National School Lunch Program and that process will be completed in accordance with the applicable November 15th deadline. In addition, the District has been selected and is currently working on an Onsite Review of the Child Nutrition Program which includes covering the same population of students that should have been verified during the FY2022-2023 verification process. Proposed Completion Date: December 2023.
Name of Contact Person: Daniel Schuler, Business and Operations Manager Corrective Action Plan: The prior Business and Operations Manager started the annual verification process, however, did not follow through on finishing the process prior to her resignation from the District. Upon her departure ...
Name of Contact Person: Daniel Schuler, Business and Operations Manager Corrective Action Plan: The prior Business and Operations Manager started the annual verification process, however, did not follow through on finishing the process prior to her resignation from the District. Upon her departure from the District, she did not communicate that the process had not been completed. I am currently working on the annual verification process as prescribed by the State of Alaska, Department of Education and Early Development (DEED) and the National School Lunch Program and that process will be completed in accordance with the applicable November 15th deadline. In addition, the District has been selected and is currently working on an Onsite Review of the Child Nutrition Program which includes covering the same population of students that should have been verified during the FY2022-2023 verification process. That review will be completed in December 2023. Proposed Completion Date: December 2023
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