Corrective Action Plans

Finding 19944 (2022-002)

Material Weakness 2022

City of Malvern

IA

Internal Control / Segregation of Duties

We will continue to review our procedures and implement controls when possible.

View Audit 23556

Finding 19943 (2022-005)

Material Weakness 2022

Floyd County

IN

Internal Control / Segregation of Duties Allowable Costs / Cost Principles Material Weakness § 200.1 § 200.303

FINDING 2022-005 Contact Person: Donald Lopp, Director of Operations and Planning Contact Phone Number: (812) 948.4110 Views of Responsible Official: Corrective Action As Director of Operations and Planning, the American Rescue Plan quarterly reports are submitted through the office. During the audi...

FINDING 2022-005 Contact Person: Donald Lopp, Director of Operations and Planning Contact Phone Number: (812) 948.4110 Views of Responsible Official: Corrective Action As Director of Operations and Planning, the American Rescue Plan quarterly reports are submitted through the office. During the audit, it appears eight of the ten audit items had the correct cumulative expenditure but those figures were not also applied to the current quarter expenditures. The US Treasury portal will not allow for the submission of the quarterly report unless the cumulative obligations and expenditures match. Description of Corrective Action Plan: Prior to submission, quarterly reports will be printed and reviewed by secondary staff in Office to review submission correctness. Anticipated Completion Date: This method will be instituted at the July 2023 quarterly report submission.

View Audit 23517

Finding 19932 (2022-001)

Significant Deficiency 2022

Independent Living Horizons Four, Inc.

GA

Questioned Costs HUD Housing Programs Reporting

Finding 2022-001 Section 811 Supportive Housing for Persons with Disabilities CFDA 14.181 Recommendation: We recommend the owner implement procedures to ensure the project?s surplus cash funds be transferred to a federally insured residual receipts account within 60 days following year-end. Action T...

Finding 2022-001 Section 811 Supportive Housing for Persons with Disabilities CFDA 14.181 Recommendation: We recommend the owner implement procedures to ensure the project?s surplus cash funds be transferred to a federally insured residual receipts account within 60 days following year-end. Action Taken: The Project transferred the surplus cash funds to the residual receipts account on September 15, 2022. If the U.S. Department of Housing and Urban Development has questions regarding the plan, please call me at 706-823-8505. Sincerely, /s/ Dennis B. Skelley Dennis B. Skelley, President/CEO

View Audit 23476 Questioned Costs: $1

Finding 19931 (2022-001)

Material Weakness 2022

M.c. Preparatory School of Wisconsin, Inc.

WI

Cash Management Internal Control / Segregation of Duties

CORRECTIVE ACTION PLAN January 24, 2023 M.C. College Preparatory School of Wisconsin, Inc. respectfully submits the following corrective action plan for the year ended June 30,2022. Walkowicz, Boczkiewicz & Co., S.C. 1800 East Main Street, Suite 100 Waukesha, WI 53186 Audit period: June 30, 2022 The...

CORRECTIVE ACTION PLAN January 24, 2023 M.C. College Preparatory School of Wisconsin, Inc. respectfully submits the following corrective action plan for the year ended June 30,2022. Walkowicz, Boczkiewicz & Co., S.C. 1800 East Main Street, Suite 100 Waukesha, WI 53186 Audit period: June 30, 2022 The findings from the June 30, 2022 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 2022-1 Elementary and Secondary School Emergency Relief Fund - COVID 19 ? CFDA No. 84.425D 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 CFO into a final submission package and presented to the CEO for final approval prior to submitting the claim to the appropriate agency. A record of such approval should be maintained in the permanent file for the claim.? If the Department of Education has questions regarding this plan, please call me at 414-264-6000. Sincerely yours, Robert Rauh Chief Education Officer

View Audit 23458

Finding 19918 (2022-006)

Material Weakness 2022

Pana Community Unit School District 8

IL

Questioned Costs Reporting Internal Control / Segregation of Duties

Corrective Action Plan Finding No.: 2022-_ 006_ Condition: Expenditure functions and objects used to record grant expenditures in the general ledger are not consistent with the expenditure functions and objects used for grant reporting and general ledger support for each expenditure report filed ...

Corrective Action Plan Finding No.: 2022-_ 006_ Condition: Expenditure functions and objects used to record grant expenditures in the general ledger are not consistent with the expenditure functions and objects used for grant reporting and general ledger support for each expenditure report filed is not complete and readily available. Plan: Grant expenditures should be recorded in the same general ledger expenditure functions as are used for grant reporting and supporting general ledger reports should be maintained in District files for all expenditure reports filed. The employees assigned to code grant expenditures and prepare grant expenditure reports should work together to accomplish this. Anticipated Date of Completion: 06/30/2023 Name of Contact Person: Jason Bauer Management Response: Management will implement the auditor's recommendation for the year ended June 30, 2023.

View Audit 22354 Questioned Costs: $1

Finding 19902 (2022-001)

Significant Deficiency 2022

Ave Maria School of Law and Ave Maria School of Law Foundation

FL

Reporting Internal Control / Segregation of Duties Questioned Costs

Pursuant to federal regulations, Uniform Administrative Requirements Section 200.511, the following are the findings as noted in the Ave Maria School of Law and Ave Maria School of Law Foundation Single Audit Act Compliance report for the year June 30, 2022, and corrective actions to be completed. ...

Pursuant to federal regulations, Uniform Administrative Requirements Section 200.511, the following are the findings as noted in the Ave Maria School of Law and Ave Maria School of Law Foundation Single Audit Act Compliance report for the year June 30, 2022, and corrective actions to be completed. 2022-001 - Special Tests and Provisions - Enrollment Reporting Auditor Description of Condition and Effect. We noted that six students out of a testing population of 14 were not reported timely to NSLDS and did not have the correct status change reported. As a result of this condition, the Organization was exposed to an increased risk that incorrect and untimely information would be reported to NSLDS. Auditor Recommendation. We recommend that the Organization consistently apply their enrollment reporting procedures to prevent untimely status change reporting in the future. Corrective Action. Management concurs with the finding. The Organization will ensure the enrollment reporting procedures are being followed. Responsible Person. Kaye Castro Anticipated Completion Date: June 30, 2023

View Audit 18305

Finding 19885 (2022-003)

Significant Deficiency 2022

Wild Rose School District

WI

Reporting Internal Control / Segregation of Duties

Significant Deficiency 2022-003 Financial Reporting for Federal and State Assistance Management Views ? Management agrees with the finding and the recommendation. Corrective Action Planned - Management and the Board will continue to designate competent staff to oversee and review the financial rep...

Significant Deficiency 2022-003 Financial Reporting for Federal and State Assistance Management Views ? Management agrees with the finding and the recommendation. Corrective Action Planned - Management and the Board will continue to designate competent staff to oversee and review the financial reports and approve them before issuance. However, it is not feasible or cost effective to add staff with the competence to prepare these reports. Anticipated Completion Date ? This action will be ongoing.

View Audit 18021

Finding 19884 (2022-002)

Significant Deficiency 2022

Wild Rose School District

WI

Internal Control / Segregation of Duties

Management Views ? Management agrees with the finding and the recommendation. Corrective Action Planned ? Management and the Board will continue to be aware of this condition and continue to be involved in the matters relating to the Organization?s operations. However, it is not feasible or cost e...

Management Views ? Management agrees with the finding and the recommendation. Corrective Action Planned ? Management and the Board will continue to be aware of this condition and continue to be involved in the matters relating to the Organization?s operations. However, it is not feasible or cost effective to add staff to achieve the desired level of internal control. Anticipated Completion Date ? This action will be on going.

View Audit 18021

Finding 19870 (2022-001)

None 2022

Commonwealth of Puerto Rico Department of Natural and Environmental Resources

PR

Subrecipient Monitoring Allowable Costs / Cost Principles Reporting § 200.512

Finding No. 2022-001 Audit Requirements for Auditees ? Report Submission Condition found The data collection form and the reporting package for the year ended on June 30, 2022 was not submitted to the Federal Audit Clearinghouse within the timeframe prescribed by the Uniform Guidance. Views of Res...

Finding No. 2022-001 Audit Requirements for Auditees ? Report Submission Condition found The data collection form and the reporting package for the year ended on June 30, 2022 was not submitted to the Federal Audit Clearinghouse within the timeframe prescribed by the Uniform Guidance. Views of Responsible Officials and Corrective Action Plan Department of Natural and Environmental Resources (DNER), Puerto Rico Infrastructure Financing Authority (PRIFA), Puerto Rico Aqueduct and Sewer Authority (PRASA), entered on December 27, 2016, into a Memorandum of Understanding (MOU), subsequently amended on June 21, 2018, to include the Fiscal Agency and Financial Advisory Authority (FAFAA). Under the MOU, as amended, each party has agreed to assume specific responsibilities in connection with the operations of the Revolving Fund pursuant to the Operating Agreement entered between the EPA and the DNER on July 25, 2018. Pursuant to the MOU, as amended, DNER will remain as the administrator for the Revolving Fund, PRIFA will act as the operating agent to provide assistance with the financial and accounting activities, and FAFAA will conduct the financial capabilities analysis of any eligible assistance recipient of funds, provide the necessary information to the DNER and PRIFA to the extent as possible for the development of the different programs compliance reports reviews, provide oversight as fiscal agent, financial advisor and information agent of the Commonwealth to ensure that the monies are safeguarded in a trust structure and to ensure the proper administration. The data collection form and the reporting package were not file on time due to lack and availability of funds to cover expenses related to the audit process and other expenses related to the administrative responsibilities assigned in the Memo of Understanding to PRIFA. Management is currently working with DNER a Subaward, as required by the Environmental Protection Agency (EPA) and as established in the MOU, as amended, in order to respond to the lack of funding to cover all the related expenses for the administrative responsibilities assigned to PRIFA. EPA has been informed and communication will be maintained until the Subaward is in force. Management plans are to file the data collection form for the fiscal year ended on June 30, 2022 on or before June 30, 2023 and the data collection form for the fiscal year ending on June 30, 2023 on or before December 31, 2023, which will result in the elimination of the finding. Name (s) of the Contact Person (s) Responsible for Corrective Action Francisco Pares, Secretary of the Treasury Department, Eduardo Rivera Cruz, Executive Director Puerto Rico Infrastructure Financing Authority and Anais Rodriguez Vega, Secretary Puerto Rico Department of Natural and Environmental Resources Anticipated Completion Date June 2023

View Audit 23582

Finding 19852 (2022-003)

Material Weakness 2022

Highlands School District

PA

Material Weakness Reporting Internal Control / Segregation of Duties

2022-003 Funding Source Reports and Expenditure Reporting Response Highlands School District agrees with the finding and the recommended procedures and is attempting to implement improvements over reporting.

View Audit 23491

Finding 19843 (2022-005)

Significant Deficiency 2022

Palm Beach County Housing Authority

FL

HUD Housing Programs Reporting Significant Deficiency

Recommendation: The Authority should implement processes to ensure HUD-50058 submissions are completed timely.

View Audit 23451

Finding 19842 (2022-004)

Material Weakness 2022

Palm Beach County Housing Authority

FL

HUD Housing Programs Subrecipient Monitoring Eligibility

2022-004 ? Selection from the Waiting List Housing Choice Voucher Cluster ? Assistance Listing No. 14.871 and 14.879 Recommendation: We recommend that the Authority designate an individual to maintain the waiting list and track all correspondence with potential tenants. Explanation of disagreement w...

2022-004 ? Selection from the Waiting List Housing Choice Voucher Cluster ? Assistance Listing No. 14.871 and 14.879 Recommendation: We recommend that the Authority designate an individual to maintain the waiting list and track all correspondence with potential tenants. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The PBCHA acknowledges the continuing issues associated with this finding. The COVID-19 pandemic has placed unprecedented stress on companies across the country. The PBCHA was no exception. This stress negatively impacted the PBCHA?s management, workforce and operations which resulted in sudden changes in working arrangements, shortages due to workforce sickness, staffing vacancies and turnover all while dealing with increased housing demand due rising rental costs, and decreased housing supply and housing instability. Despite these challenges, the PBCHA remains strongly focused on continued and improved operations, increased compliance, and accountability. The PBCHA will continue to develop, train, and enforce procedures related to efficient waitlist management for families placed on the list for the HCV programs; the ongoing maintenance of the waiting lists; and selection of enough families from the list to maximize the PBCHA?s use of available funding. The PBCHA has elected to open its waiting lists beginning in June 2022 for its HCV programs and to leave lists open indefinitely to accurately depict the demand for affordable housing. This will require that PBCHA staff ae trained and annually comply with the procedures outlined in the Administrative Plan related to updating, removal and selection from the wait lists, admission, and eligibility, and that all steps are documented within the tenant file and agency business system accordingly. The PBCHA make decisions, develop strategies, implement policies/procedures, and utilize all available resources during this period of prevailing uncertainty and volatility. Any action taken to address the noted deficiency will be based on careful analysis, innovative thinking, restructuring, flexibility and/or revised strategies to adapt to everchanging business circumstances. Name(s) of the contact person(s) responsible for corrective action: Tyler Rasmussen. Carol Jones-

View Audit 23451

Finding 19841 (2022-003)

Material Weakness 2022

Palm Beach County Housing Authority

FL

HUD Housing Programs Material Weakness Internal Control / Segregation of Duties

2022-003 ? Rent Reasonableness Housing Choice Voucher Cluster ? Assistance Listing No. 14.871 and 14.879 Recommendation: We recommend that the Authority designate an individual to review tenant files to determine if a rent reasonableness has been performed. Explanation of disagreement with audit fin...

2022-003 ? Rent Reasonableness Housing Choice Voucher Cluster ? Assistance Listing No. 14.871 and 14.879 Recommendation: We recommend that the Authority designate an individual to review tenant files to determine if a rent reasonableness has been performed. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The PBCHA acknowledges the continuing issues associated with this finding. The COVID-19 pandemic has placed unprecedented stress on companies across the country. The PBCHA was no exception. This stress negatively impacted the PBCHA?s management, workforce and operations which resulted in sudden changes in working arrangements, shortages due to workforce sickness, staffing vacancies and turnover all while dealing with increased housing demand due rising rental costs, and decreased housing supply and housing instability. Despite these challenges, the PBCHA remains strongly focused on continued and improved operations, increased compliance, and accountability. The agency will continue to develop, train, and enforce procedures to ensure rent reasonableness is performed on a timely basis as required by federal regulations and documentation is maintained in the tenant file. The agency utilizes an external resource to conduct rent comparison. The PBCHA will continue to train and instruct Housing Specialists on the responsibility to perform the rent reasonableness determination at the time of initial leasing, when there is an increase in rent to owner and at HAP contract anniversary if applicable under HUD rules and regulations. The PBCHA make decisions, develop strategies, implement policies/procedures, and utilize all available resources during this period of prevailing uncertainty and volatility. Any action taken to address the noted deficiency will be based on careful analysis, innovative thinking, restructuring, flexibility and/or revised strategies to adapt to everchanging business circumstances. Name(s) of the contact person(s) responsible for corrective action:

View Audit 23451

Finding 19840 (2022-002)

Material Weakness 2022

Palm Beach County Housing Authority

FL

Questioned Costs HUD Housing Programs Material Weakness

2022-002 ? HQS Enforcements Housing Choice Voucher Cluster ? Assistance Listing No. 14.871 and 14.879 Recommendation: We recommend management should designate one person to oversee the inspection process to ensure that all inspections are being performed in a timely manner. Furthermore, management s...

2022-002 ? HQS Enforcements Housing Choice Voucher Cluster ? Assistance Listing No. 14.871 and 14.879 Recommendation: We recommend management should designate one person to oversee the inspection process to ensure that all inspections are being performed in a timely manner. 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 PBCHA acknowledges the continuing issues associated with this finding. The COVID-19 pandemic has placed unprecedented stress on companies across the country. The PBCHA was no exception. This stress negatively impacted the PBCHA?s management, workforce and operations which resulted in sudden changes in working arrangements, shortages due to workforce sickness, staffing vacancies and turnover all while dealing with increased housing demand due rising rental costs, and decreased housing supply and housing instability. Despite these challenges, the PBCHA remains strongly focused on continued and improved operations, increased compliance, and accountability. The PBCHA continues to utilize its third-party vendor to complete all HQS inspections. The PBCHA will also utilize the technology available to make its HQS inspections and enforcement process as efficient as possible. This includes improved functionality within its new software system, new guidelines, and handheld technology and RVI methods as appropriate. The PBCHA make decisions, develop strategies, implement policies/procedures, and utilize all available resources during this period of prevailing uncertainty and volatility. Any action taken to address the noted deficiency will be based on careful analysis, innovative thinking, restructuring, flexibility and/or revised strategies to adapt to everchanging business circumstances. Name(s) of the contact person(s) responsible for corrective action: Tyler Rasmussen, Carol Jones- Gilbert

View Audit 23451 Questioned Costs: $1

Finding 19839 (2022-001)

Material Weakness 2022

Palm Beach County Housing Authority

FL

HUD Housing Programs Subrecipient Monitoring Eligibility

Eligibility 2022-001 ? Eligibility Housing Choice Voucher Cluster ? Assistance Listing No. 14.871 and 14.879 Recommendation: We recommend management should designate one person to review a sample of the files that have been recertified each month, to determine if the tenant files were prepared in ac...

Eligibility 2022-001 ? Eligibility Housing Choice Voucher Cluster ? Assistance Listing No. 14.871 and 14.879 Recommendation: We recommend management should designate one person to review a sample of the files that have been recertified each month, to determine if the tenant files were prepared in accordance with internal policies and unit the compliance deficiencies have been corrected. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The PBCHA acknowledges the continuing issues associated with this finding. The COVID-19 pandemic has placed unprecedented stress on companies across the country. The PBCHA was no exception. This stress negatively impacted the PBCHA?s management, workforce and operations which resulted in sudden changes in working arrangements, shortages due to workforce sickness, staffing vacancies and turnover all while dealing with increased housing demand due rising rental costs, and decreased housing supply and housing instability. Despite these challenges, the PBCHA remains strongly focused on continued and improved operations, and increased compliance and accountability. The PBCHA will continue to utilize all available resources to recruit, retain and train HCVP staff on the HCV program guidelines, to include training to determine what is included and excluded from annual income, how to identify and calculate assets, correctly calculate adjusted income by applying the HUD defined allowances and expenses, recognize the requirements for verification of income, allowances, and expenses and calculate total tenant payment and housing assistance payment (HAP). The PBCHA make decisions, develop strategies, implement policies/procedures, and utilize all available resources during this period of prevailing uncertainty and volatility. Any action taken to address the noted deficiencies will be based on careful analysis, innovative thinking, restructuring, flexibility and/or revised strategies to adapt to everchanging business circumstances. Board of Commissioners Paul Dumars, Chairman Phyllis Choy, Vice Chair Digna Mejia Charlie Fetscher CEO and Executive Director Carol Jones-Gilbert 3432 West 45th Street West Palm Beach, Florida 33407 Office: (561) 684-2160 ext. 104 Mobile: (561) 628-9387 Fax: (561) 455-9965 Name(s) of the contact person(s) responsible for corrective action: Tyler Rasmussen, Carol Jones- Gilbert

View Audit 23451

Finding 19833 (2022-002)

Significant Deficiency 2022

Isd #2899 - Plainview-Elgin-Millville Public Schools

MN

Procurement, Suspension & Debarment Internal Control / Segregation of Duties

SEE ATTACHED

View Audit 23246

Finding 19812 (2022-011)

Material Weakness 2022

State of Washington C/o Office of Financial Management

WA

Subrecipient Monitoring Internal Control / Segregation of Duties Special Tests & Provisions

Finding: The Washington State Department of Transportation did not have adequate internal controls over and did not comply with quality assurance program requirements to ensure materials conformed to approved plans and specifications, and that only qualified personnel performed testing for projects...

Finding: The Washington State Department of Transportation did not have adequate internal controls over and did not comply with quality assurance program requirements to ensure materials conformed to approved plans and specifications, and that only qualified personnel performed testing for projects funded by the Highway Planning and Construction Cluster. Questioned Costs: CFDA # 20.205 20.205 COVID-19 20.219 20.224 Amount $0 Status: Corrective action in progress Corrective Action: The Department is committed to ensuring that our grant programs comply with federal regulations related to quality assurance (QA) requirements and safeguarding that materials and workmanship conform to approved plans and specifications through testing, inspections, or certifications. The Department continues to work closely with the Federal Highway Administration (FHWA) on the QA program and has received positive feedback on the strength of the program. In addition, the Department is currently investing in the Unifier software to replace separate QA legacy systems, which will allow shared data and provide built-in controls to help prevent the issues identified in the audit. Depending on funding and programming times, the Department estimates Unifier to be online for the QA program within five years. To address the audit recommendations, the Department?s Construction Division will examine current policies and procedures/practices related to the audit issues. The Department will: ? Update policies and procedures, including the Department?s Construction Manual (M46-01), as needed to ensure staff practices meet federal regulations. Updates will also include other clarifications to address documentation and evidence of compliance, and a reasonable level of controls regarding materials testing, inspections, certification, acceptance, and tester certifications. ? Obtain approval of updates to the Construction Manual from the FHWA. ? Communicate changes in policies and procedures to division staff and stakeholders. ? Provide training to Project Engineering Office staff to emphasize QA program requirements. The conditions noted in this finding were previously reported in findings 2021-011, 2020-017 and 2019-019. Completion Date: Estimated June 2024 Agency Contact: Jesse Daniels External Audit Liaison PO Box 47320 Olympia, WA 98504-7320 (360) 705-7035 danielje@wsdot.wa.gov

View Audit 23129

Finding 19811 (2022-010)

Material Weakness 2022

State of Washington C/o Office of Financial Management

WA

Subrecipient Monitoring Internal Control / Segregation of Duties § 200.501

Finding: The Washington State Department of Transportation did not have adequate internal controls over and did not comply with requirements to issue management decisions for audit findings to subrecipients of the Highway Planning and Construction Cluster. Questioned Costs: Assistance Listing # ...

Finding: The Washington State Department of Transportation did not have adequate internal controls over and did not comply with requirements to issue management decisions for audit findings to subrecipients of the Highway Planning and Construction Cluster. Questioned Costs: Assistance Listing # 20.205 20.205 COVID-19 20.219 20.224 Status: Corrective action complete Corrective Action: The Department is committed to ensuring our programs comply with federal regulations related to subrecipient monitoring. The Department?s Local Programs Division typically issues Management Decision Letters (Decision Letters) to all subrecipients that receive single audit findings related to WSDOT federal grant awards. For the subrecipient in question, the subrecipient had contacted the Division upon realizing a discrepancy in their advertisement practices, which was prior to the auditors issuing the single audit finding. The Division reviewed the subrecipient?s advertisement practices, evaluated and approved the corrective action plan, and implemented a training plan with the subrecipient. Since these activities preceded the issuance of the subrecipient?s single audit finding and resolved the deficiency, the Department elected to forgo a formal Decision Letter. Based on the audit recommendations, the Department will continue to review all single audit findings issued for subrecipients and send Decision Letters. The conditions noted in this finding were previously reported in findings 2021-010, 2020-015 and 2019-017. Completion Date: December 2022 Agency Contact: Jesse Daniels External Audit Liaison PO Box 47320 Olympia, WA 98504-7320 (360) 705-7035 danielje@wsdot.wa.gov

View Audit 23129

Finding 19810 (2022-009)

Material Weakness 2022

State of Washington C/o Office of Financial Management

WA

Subrecipient Monitoring Internal Control / Segregation of Duties

Finding: The Washington State Department of Transportation did not have adequate internal controls over and did not comply with requirements to conduct program monitoring of subrecipients of the Highway Planning and Construction Cluster. Questioned Costs: Assistance Listing # 20.205 20.205...

Finding: The Washington State Department of Transportation did not have adequate internal controls over and did not comply with requirements to conduct program monitoring of subrecipients of the Highway Planning and Construction Cluster. Questioned Costs: Assistance Listing # 20.205 20.205 COVID-19 20.219 20.224 Amount $0 Status: Corrective action in progress Corrective Action: The Department is committed to ensuring that our grant programs comply with federal regulations related to subrecipient monitoring. In July 2022, the Department executed a memo agreement with the Federal Highway Administration (FHWA) to update the risk-based review process to a leading practice. This new process will improve the effectiveness of subrecipient monitoring efforts which will focus reviews and resources on the high-risk agencies or projects rather than a three-year review cycle. However, FHWA is reluctant to formally open the Stewardship and Oversight (S&O) Agreement for revisions, as a new nationwide ?template? is under development. Based on the existing language in the S&O Agreement with FHWA, the finding was issued for fiscal year 2022. With FHWA?s approval to implement the risk-based approach, the Department will: ? Conduct baseline Project Management Reviews (PMR) for each Certification Acceptance (CA) agency. This process began in September 2022, with 13 PMRs completed, 22 near completion, and 9 in process. ? Analyze CA PMRs and assign a risk rating, which will be used in the PMR selection process. ? Update risk-based approach policies to complete PMRs, as needed. ? Update the Local Agency Guidelines Manual to reflect the risk-based approach to complete PMRs, as needed. ? Communicate changes to policies and procedures to Local Program staff and stakeholders, as needed. The conditions noted in this finding were previously reported in findings 2021-008, 2020-016 and 2019-015. Completion Date: Estimated September 2023 Agency Contact: Jesse Daniels External Audit Liaison PO Box 47320 Olympia, WA 98504-7320 (360) 705-7035 danielje@wsdot.wa.gov

View Audit 23129

Finding 19809 (2022-008)

Significant Deficiency 2022

State of Washington C/o Office of Financial Management

WA

Subrecipient Monitoring Internal Control / Segregation of Duties Allowable Costs / Cost Principles

Finding: The Washington State Department of Transportation did not have adequate internal controls to ensure supervisors reviewed and approved payroll journals for the Highway Planning and Construction Cluster. Questioned Costs: Assistance Listing # 20.205 20.205 COVID-19 20.219 20.224 Amoun...

Finding: The Washington State Department of Transportation did not have adequate internal controls to ensure supervisors reviewed and approved payroll journals for the Highway Planning and Construction Cluster. Questioned Costs: Assistance Listing # 20.205 20.205 COVID-19 20.219 20.224 Amount $0 Status: Corrective action in progress Corrective Action: The Department is committed to ensuring adequate internal controls are established for processing payroll journals. Currently, the Department: ? Sends payroll journals electronically via Adobe Acrobat Sign on day four of payroll processing. ? Generates system automated emails, which are sent to the reviewer each day the journal is unsigned. ? Reconciles unsigned payroll journals and will follow up with responsible staff. To further improve controls over timely approval and return of payroll journals, the Department will: ? Continue to review existing internal controls to assess their effectiveness and make improvements as needed. ? Review the Payroll Manual to ensure directions, guidelines, and expectations around the payroll journal approval are clearly defined. ? Evaluate the appropriateness of establishing a timeline for returning signed payroll journals for incorporation into the Payroll Manual. Completion Date: Estimated June 2024 Agency Contact: Jesse Daniels External Audit Liaison PO Box 47320 Olympia, WA 98504-7320 (360) 705-7035 danielje@wsdot.wa.gov

View Audit 23129

Finding 19717 (2022-061)

Material Weakness 2022

State of Washington C/o Office of Financial Management

WA

Subrecipient Monitoring Internal Control / Segregation of Duties Special Tests & Provisions

Finding: The Health Care Authority did not have adequate internal controls over and did not comply with requirements to ensure it performed procedures to safeguard against unnecessary utilization of care and services for the Medicaid program. Questioned Costs: Assistance Listing # 93.775 93.7...

Finding: The Health Care Authority did not have adequate internal controls over and did not comply with requirements to ensure it performed procedures to safeguard against unnecessary utilization of care and services for the Medicaid program. Questioned Costs: Assistance Listing # 93.775 93.777 93.777 COVID-19 93.778 93.778 COVID-19 Status: Corrective action in progress Corrective Action: The Authority partially concurs with the finding. The Authority has received guidance from the Centers for Medicare & Medicaid Services (CMS) and will adjust the state plan based on CMS requirements. Per CMS guidance, this adjustment will not include separately listing the methods and procedures it uses to safeguard against unnecessary utilization of care and services. The Authority does not concur with the auditor?s conclusion regarding its statewide surveillance and utilization control program not meeting federal program integrity requirements. The Authority?s program meets CMS standards and requirements and provides reasonable oversight. The Authority will update its policies and procedures related to the program. The Authority concurs that the two providers of the Program of All-inclusive Care for the Elderly (PACE) were not monitored for their compliance with the False Claims Act (FCA) during the fiscal year. The Department of Social and Health Services (DSHS) manages the contracts for the PACE program, but payments to these providers are routed through the Authority?s ProviderOne system. The process for PACE provider monitoring has been clarified with DSHS who is responsible for providing FCA oversight for these contracts. The conditions noted in this finding were previously reported in findings 2021-050, 2020-047, 2020-048, 2019-052, 2019-053 and 2018-047. Completion Date: Estimated December 2023 Agency Contact: Kari Summerour, CPA External Audit Compliance Manager PO Box 45502 Olympia, WA 98504-5502 (360) 725-9586 Kari.Summerour@hca.wa.gov

View Audit 23129

Finding 19716 (2022-060)

Material Weakness 2022

State of Washington C/o Office of Financial Management

WA

Subrecipient Monitoring Special Tests & Provisions Internal Control / Segregation of Duties

Finding: The Health Care Authority did not have adequate internal controls over and did not comply with requirements to ensure it periodically audited cost report data for rate setting, hospital billings, and other financial and statistical records for inpatient hospital services. Questioned Cost...

Finding: The Health Care Authority did not have adequate internal controls over and did not comply with requirements to ensure it periodically audited cost report data for rate setting, hospital billings, and other financial and statistical records for inpatient hospital services. Questioned Costs: Assistance Listing # 93.775 93.777 93.777 COVID-19 93.778 93.778 COVID-19 Status: Corrective action in progress Corrective Action: The Authority partially concurs with the finding. The Authority does not agree it did not comply with federal requirements related to audits of inpatient hospitals. The Authority performs the following procedures: Cost report data for rate setting: ? Audits Medicaid cost report schedules and supporting documentation used for the Certified Public Expenditure Program. ? Audits critical access hospital data and uses final audited Medicare cost reports for settlement. ? Reviews and audits hospital cost reports using the ratio of costs-to-charges payment method. Hospital billings: ? Annual audits of hospital billings. Other financial and statistical records: ? Audits disproportionate share hospital reimbursements. The Authority concurs that documentation of the different hospital audits performed could be more clearly defined and will formalize procedures related to the conduct of the required audits. The conditions noted in this finding were previously reported in findings 2021-051 and 2020-049. Completion Date: Estimated December 2023 Agency Contact: Kari Summerour, CPA External Audit Compliance Manager PO Box 45502 Olympia, WA 98504-5502 (360) 725-9586 Kari.Summerour@hca.wa.gov

View Audit 23129

Finding 19715 (2022-059)

Material Weakness 2022

State of Washington C/o Office of Financial Management

WA

Subrecipient Monitoring Procurement, Suspension & Debarment Allowable Costs / Cost Principles

Finding: The Department of Social and Health Services did not have adequate internal controls over and did not comply with federal provider eligibility requirements for the Medicaid Program. Questioned Costs: Assistance Listing # 93.775 93.777 93.777 COVID-19 93.778 93.778 COVID-19 Amount $0...

Finding: The Department of Social and Health Services did not have adequate internal controls over and did not comply with federal provider eligibility requirements for the Medicaid Program. Questioned Costs: Assistance Listing # 93.775 93.777 93.777 COVID-19 93.778 93.778 COVID-19 Amount $0 Status: Corrective action complete Corrective Action: The Department concurs with the finding. As of June 2022, individual providers are no longer contracted through the Department and now contract with Consumer Direct of Washington. As a result of this change, this type of error will not occur for individual providers moving forward. As of March 2023, the Department reviewed all providers in the monthly exclusion report. The Department verified that the provider identified in the finding for missing enrollment documentation was never employed and did not receive any payments. Completion Date: March 2023 Agency Contact: Richard Meyer External Audit Compliance Manager PO Box 45804 Olympia, WA 98504-5804 (360) 664-6027 Richard.Meyer@dshs.wa.gov

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Finding 19714 (2022-058)

Material Weakness 2022

State of Washington C/o Office of Financial Management

WA

Subrecipient Monitoring Special Tests & Provisions Procurement, Suspension & Debarment

Finding: The Department of Social and Health Services did not have adequate internal controls over False Claims Act requirements. Questioned Costs: Assistance Listing # 93.775 93.777 93.777 COVID-19 93.778 93.778 COVID-19 Amount $0 Status: Corrective action in progress Corrective Action:...

Finding: The Department of Social and Health Services did not have adequate internal controls over False Claims Act requirements. Questioned Costs: Assistance Listing # 93.775 93.777 93.777 COVID-19 93.778 93.778 COVID-19 Amount $0 Status: Corrective action in progress Corrective Action: The Department concurs with the finding. As of April 2023, the Department: ? Generated and tested a new internal report that will include all Aging and Long-Term Support Administration and Developmental Disabilities Administration Medicaid providers. ? Mailed correspondence to the one provider who was missing documentation to request the False Claims Act (FCA) attestation, policy, and procedures. ? Updated process to include follow up with providers monthly until the FCA attestations and other documents are received. By October 2023, the Department will ensure all outstanding FCA attestations and documents are returned to ensure compliance with the FCA requirement. Completion Date: Estimated October 2023 Agency Contact: Richard Meyer External Audit Compliance Manager PO Box 45804 Olympia, WA 98504-5804 (360) 664-6027 Richard.Meyer@dshs.wa.gov

View Audit 23129

Finding 19713 (2022-057)

Material Weakness 2022

State of Washington C/o Office of Financial Management

WA

Subrecipient Monitoring Internal Control / Segregation of Duties Special Tests & Provisions

Finding: The Department of Social and Health Services? Aging and Long-Term Support Administration did not have adequate internal controls over and did not comply with requirements to ensure timely investigation of complaints of client abuse and neglect at Medicaid residential facilities. Questio...

Finding: The Department of Social and Health Services? Aging and Long-Term Support Administration did not have adequate internal controls over and did not comply with requirements to ensure timely investigation of complaints of client abuse and neglect at Medicaid residential facilities. Questioned Costs: Assistance Listing # 93.775 93.777 93.777 COVID-19 93.778 93.778 COVID-19 Amount $0 Status: Corrective action in progress Corrective Action: The Department partially agrees with the finding. The Department agrees that not all complaint investigations were initiated within the required timeframes. However, the Department does not agree that noncompliance was due to inadequate internal controls. Residential Care Services (RCS) has effectively used current internal controls since fiscal year 2017 when we received the State Auditor?s Office Stewardship Award related to this audit area. Compliance with required complaint investigation timeframes decreased due to an increase in complaints from the previous fiscal year that were assigned for investigation. In addition, the effects of the COVID-19 pandemic increased staff vacancy rates to 24% due to exposure, illness, and staff resignation caused by vaccination mandates. By December 2023, the Department will: ? Extend the contract with Health Care Management Solutions to assist with surveys. This will allow RCS staff to return the focus to complaint investigations, complaint backlog, and compliance with required investigation timeframes. ? Condense and streamline Nursing Home Surveyor Training to enable staff to complete survey training faster than previous timeframes. ? Provide training to staff that were recently hired to fill the vacant positions to ensure compliance with investigation timeframes. The conditions noted in this finding were previously reported in finding 2021-054. Completion Date: Estimated December 2023 Agency Contact: Richard Meyer External Audit Compliance Manager PO Box 45804 Olympia, WA 98504-5804 (360) 664-6027 Richard.Meyer@dshs.wa.gov

View Audit 23129

Corrective Action Plans

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