Corrective Action Plans

Finding 1160271 (2023-002)

Material Weakness 2023

Heart of Georgia Regional Airport Authority

GA

Procurement, Suspension & Debarment Subrecipient Monitoring Matching / Level of Effort / Earmarking

THE BOARD WILL DOCUMENT THE PROCUREMENT PROCEDURES FOR FEDERAL AWARDS AND SUBAWARDS.

View Audit 370658

Finding 1160204 (2023-001)

Material Weakness 2023

Franklin Home for the Aged D/b/a Peabody Place

NH

Questioned Costs Student Financial Aid Matching / Level of Effort / Earmarking

Condition Found: In accordance with the loan terms, Peabody Place is required to annually fund a capital asset replacement reserve of $100,000, debt payment reserve in the amount of $111,696, and a resident asset depletion reserve and facility fill reserve each for $50,000. The Organization did not ...

Condition Found: In accordance with the loan terms, Peabody Place is required to annually fund a capital asset replacement reserve of $100,000, debt payment reserve in the amount of $111,696, and a resident asset depletion reserve and facility fill reserve each for $50,000. The Organization did not make the required annual deposits into the debt payment reserve, capital asset replacement reserve, resident asset depletion reserve and the facility fill reserve. Individual(s) Responsible for Corrective Action: Lynda P. Goldthwaite, Executive Director and Stacey Matott, Director of Finance Planned Corrective Action: Peabody Place sought a debt work out in 2025 that would allow for deferral of required deposits for six months until January 1, 2026. Anticipated Completion Date: December 31, 2024

View Audit 370570 Questioned Costs: $1

Finding 1160115 (2023-013)

Material Weakness 2023

Twin Oaks Juvenile Development, Inc.

FL

Matching / Level of Effort / Earmarking Student Financial Aid Subrecipient Monitoring § 200.303

Benjie Read CFO and Felecia Read Staff Accountant, will update the policies and procedures for all program reports and the review of each before submission. We will also negotiate with the grantors for appropriate time frams as some of these time frames are impossible for us to meet in an accurate m...

Benjie Read CFO and Felecia Read Staff Accountant, will update the policies and procedures for all program reports and the review of each before submission. We will also negotiate with the grantors for appropriate time frams as some of these time frames are impossible for us to meet in an accurate manner. These policies will be done within 90 days of audit completion.

View Audit 370516

Finding 1160099 (2023-010)

Material Weakness 2023

Twin Oaks Juvenile Development, Inc.

FL

Allowable Costs / Cost Principles Subrecipient Monitoring Matching / Level of Effort / Earmarking § 200.1 § 200.303

Benjie Read CFO and Felecia Read Staff Accountant, will develop a policy and establish procedures for calculating the MTDC in accordance with Uniform Guidance for federal contracts and reviwing the indirect cost allocations. We will also educate ourselves and all financial staff on these requirement...

Benjie Read CFO and Felecia Read Staff Accountant, will develop a policy and establish procedures for calculating the MTDC in accordance with Uniform Guidance for federal contracts and reviwing the indirect cost allocations. We will also educate ourselves and all financial staff on these requirements. These efforts will be complete within 90 days of audit completion.

View Audit 370516

Finding 1160085 (2023-009)

Material Weakness 2023

Twin Oaks Juvenile Development, Inc.

FL

Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking § 200.303 § 200.430

Twin Oaks has updated their payroll provider to Paylocity as of 4/1/2024. This change has given us better oversight and documentation of hours worked at all our programs. Benjie Read CFO and Felecia Read Staff Accountant, will educate the payroll staff on federal and state requirements for payroll a...

Twin Oaks has updated their payroll provider to Paylocity as of 4/1/2024. This change has given us better oversight and documentation of hours worked at all our programs. Benjie Read CFO and Felecia Read Staff Accountant, will educate the payroll staff on federal and state requirements for payroll allocations within 90 days of audit completion.

View Audit 370516

Finding 1160059 (2023-007)

Material Weakness 2023

Twin Oaks Juvenile Development, Inc.

FL

Reporting Matching / Level of Effort / Earmarking Subrecipient Monitoring § 200.303

Benjie Read CFO and Felecia Read Staff Accountant, will update procedures for documented review of the program reports prior to submission to the grantors. Also see 2023-013 for timely submission. These updates will be completed within 90 days of audit submission.

View Audit 370516

Finding 1160057 (2023-006)

Material Weakness 2023

Twin Oaks Juvenile Development, Inc.

FL

Cash Management Matching / Level of Effort / Earmarking Subrecipient Monitoring § 200.302 § 200.303 § 200.305

Benjie Read CFO and Felecia Read Staff Accountant, will update written policies and procedures to implement the requirements of 2 CFR 200.305 to include a review and documentation of the cash draw requests prior to submission. This will be completed within 90 days of audit completion. In addition, w...

Benjie Read CFO and Felecia Read Staff Accountant, will update written policies and procedures to implement the requirements of 2 CFR 200.305 to include a review and documentation of the cash draw requests prior to submission. This will be completed within 90 days of audit completion. In addition, we no longer operate the only Federal program where cash draws were allowed.

View Audit 370516

Finding 1159893 (2023-006)

Material Weakness 2023

Jefferson Parish

LA

Questioned Costs Eligibility Internal Control / Segregation of Duties § 200.113 § 200.331

With the support of a new leadership team, Jefferson Parish is committed to strengthening oversight and monitoring federal grants financial and compliance activities. To enhance reliability, the Parish has engaged Deloitte & Touche LLP as a consultant to assist with improving documentation procedure...

With the support of a new leadership team, Jefferson Parish is committed to strengthening oversight and monitoring federal grants financial and compliance activities. To enhance reliability, the Parish has engaged Deloitte & Touche LLP as a consultant to assist with improving documentation procedures and strengthen internal controls supporting financial and compliance activities going forward. As part of this effort Jefferson Parish and Deloitte are working across Finance, Accounting, and programmatic departments to establish improved federal grants governance and policy. This includes quarterly oversight and review processes and procedures to monitor the use of federal funds and confirm that compliance activities are occurring. This also includes improved preventative controls to require the performance of due diligence activities for each federal fund sub-recipient or individuals receiving federal assistance prior to the awarding or disbursement of federal funds. The Parish will also develop a policy and communicate annually to all departments the requirements to report to the appropriate authorities, including the Louisiana Legislative Auditor's Office and the Jefferson Parish District Attorney's Office. Community Development Director Stephanie Brumfield, Interim Finance Director Victor LaRocca and Risk Management Director Maria Leon will develop and communicate the policy for reporting fraud which should be enacted by January of 2026.

View Audit 370431 Questioned Costs: $1

Finding 1159806 (2023-001)

Material Weakness 2023

Henry County Board of Education

AL

Questioned Costs Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking § 200.303 § 200.326

Finding 2023-001 - Special Tests and Provisions: Wage Rate Requirements Responsible Individual: Arlene Dickens, Chief School Financial Officer Corrective Action: Wage rate clauses will be included in all federally funded construction contracts. Contractors and subcontractors will be notified in writ...

Finding 2023-001 - Special Tests and Provisions: Wage Rate Requirements Responsible Individual: Arlene Dickens, Chief School Financial Officer Corrective Action: Wage rate clauses will be included in all federally funded construction contracts. Contractors and subcontractors will be notified in writing of prevailing wage requirements, and certified payrolls will be required and reviewed for all weeks for which construction work is performed. Anticipated Completion Date: October 1, 2025

View Audit 370343 Questioned Costs: $1

Finding 1159793 (2023-007)

Material Weakness 2023

Program of Academic Exchange

NY

Matching / Level of Effort / Earmarking § 200.306

PAX implemented a dedicated cost center in the books and records specifically for tracking cost shared expenses midyear during FY23 rather than the previous practice of recognition of cost share at year end closing. Full implementation of contemporaneous tracking of cost share was implemented in FY2...

PAX implemented a dedicated cost center in the books and records specifically for tracking cost shared expenses midyear during FY23 rather than the previous practice of recognition of cost share at year end closing. Full implementation of contemporaneous tracking of cost share was implemented in FY24. Additionally, PAX now reconciles against this cost center to ensure that the expenses reported to the grantor and budgetary allocations align with the actual expenditures.

View Audit 370335

Finding 1159730 (2023-005)

Material Weakness 2023

City of Woodland

CA

Reporting Material Weakness Matching / Level of Effort / Earmarking § 200.500

Management’s Response and Corrective Action: The City recently went through implementation of a new financial software, which has allowed for development of some documentation and assignment of roles and responsibilities with the new system. Staff will make efforts to enhance and update this documen...

Management’s Response and Corrective Action: The City recently went through implementation of a new financial software, which has allowed for development of some documentation and assignment of roles and responsibilities with the new system. Staff will make efforts to enhance and update this documentation to provide specific details about the annual financial reporting. The City has also struggled with vacancies in key positions, as well as challenges in completing successful recruitments to fill the positions; staff exploring options for third party assistance with financial reporting functions.

View Audit 370313

Finding 1159708 (2023-001)

Material Weakness 2023

Niagara Area Management Corporation

NY

Allowable Costs / Cost Principles Reporting Matching / Level of Effort / Earmarking

Niagara Area Management Corporation is recruiting a new Chief Financial Officer and has a new Director of Finance. NAMC has also engaged a new public accounting firm. It is NAMC policy to submit the annual audited financial statements and the data collection form to the Federal Audit Clearinghouse w...

Niagara Area Management Corporation is recruiting a new Chief Financial Officer and has a new Director of Finance. NAMC has also engaged a new public accounting firm. It is NAMC policy to submit the annual audited financial statements and the data collection form to the Federal Audit Clearinghouse within 9 months after year-end.

View Audit 370289

Finding 1158234 (2023-001)

Material Weakness 2023

Grady Memorial Hospital Corporation

GA

Reporting Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

To: FY2023 Uniform Guidance Reporting Package From: Gina Smith, VP, Fiscal Service/Controller RE: 2023 Uniform Guidance Audit Corrective Action Plan Date: 9/27/2024 Finding 2023-001 – Reporting Federal Program: Provider Relief Fund and American Rescue Plan Rural Distribution ALN: 93.498 Grady Memori...

To: FY2023 Uniform Guidance Reporting Package From: Gina Smith, VP, Fiscal Service/Controller RE: 2023 Uniform Guidance Audit Corrective Action Plan Date: 9/27/2024 Finding 2023-001 – Reporting Federal Program: Provider Relief Fund and American Rescue Plan Rural Distribution ALN: 93.498 Grady Memorial Hospital Corporation’s (Grady) CFO and VP of Fiscal Services/Controller have reviewed the reporting from KPMG relating to the Uniform Guidance. We understand the recommendation set forth by KPMG and will revamp our controls and processes to include additional management review of the SEFA to include the prior of any submission and to provide evidence of the related review Grady’s corrective action plan: Grady Memorial Hospital Corporation has implemented a new review policy for the submissions of PRF reports which also includes a new reporting and review procedure that are performed by the Controller and Tax & Technical Accounting Manager. GMHC will implement controls and processes to ensure grant reports are reviewed prior to submission and that evidence of review is maintained within the timeline it was signed. Contact person/s responsible for the correction action: Gina Smith, VP, Fiscal Service/Controller Anticipated Completion Date: Grady Memorial Hospital Corporation has implemented controls and processes to ensure grant reports are reviewed prior to submission and that evidence of review is maintained

View Audit 370125

Finding 1155970 (2023-005)

Material Weakness 2023

Incline Village General Improvement District

NV

Internal Control / Segregation of Duties Reporting Matching / Level of Effort / Earmarking § 200.512

(2023-005) Late Submission of Single Audit Reporting Package Criteria Per 2 CFR § 200.512(l), non-federal entities must submit the Single Audit reporting package to the Federal Audit Clearinghouse within the earlier of 30 calendar days after receipt of the auditor’s report or nine months after the f...

(2023-005) Late Submission of Single Audit Reporting Package Criteria Per 2 CFR § 200.512(l), non-federal entities must submit the Single Audit reporting package to the Federal Audit Clearinghouse within the earlier of 30 calendar days after receipt of the auditor’s report or nine months after the fiscal year-end. Condition The District’s reporting package for the fiscal year ended June 30, 2023, was not submitted to the Federal Audit Clearinghouse within the required timeframe. As of the date of this report, the reporting package has not yet been submitted. Cause The District did not have adequate procedures in place to ensure timely completion of the financial audit and preparation of the reporting package. Effect The District did not comply with the Uniform Guidance submission deadline, which may impact the timeliness of federal oversight and potentially affect future federal funding decisions. Questioned Costs No questioned costs were identified as a result of our procedures. Context/Sampling The FY2023 Single audit was performed in 2025 after it was determined that the grant funds were expended on eligible activities, triggering the Single Audit requirement. The delay was due to the District not identifying the requirement timely and lacking procedures to ensure prompt submission. Recommendation We recommend that the District implement processes and internal controls to ensure future Single Audits are completed and submitted within the required timeframe. Management’s Corrective Action Planned Management concurs with the recommendation. IVGID will establish a procedure to review and reconcile grants both federal and state at year-end to determine the need for a single audit and submission to the required agencies.

View Audit 368379

Finding 1155814 (2023-004)

Material Weakness 2023

The International Center for Journalists, Inc.

DC

Cash Management Matching / Level of Effort / Earmarking § 200.303

Views of Responsible Officials: The cause is related to the digital nature of the drawdown process and staff turnover. ICFJ will institute a procedure to capture drawdown information and/or create a documentation at the time of drawdown. Storage of the documentation will be incorporated into ICFJ’s ...

Views of Responsible Officials: The cause is related to the digital nature of the drawdown process and staff turnover. ICFJ will institute a procedure to capture drawdown information and/or create a documentation at the time of drawdown. Storage of the documentation will be incorporated into ICFJ’s digital records storage.

View Audit 368202

Finding 1155805 (2023-005)

Material Weakness 2023

The International Center for Journalists, Inc.

DC

Matching / Level of Effort / Earmarking Subrecipient Monitoring § 200.306

Views of Responsible Officials: ICFJ will implement procedures and control processes to track cost share requirements and the progress towards the requirements. Support for the cost share claimed should also be available upon request.

View Audit 368202

Finding 1155489 (2023-004)

Material Weakness 2023

Oak Hill United School Corporation

IN

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

FINDING 2023-004 Finding Subject: COVID-19-Education Stabilization Fund - Special Tests and Provisions – Wage Rate Requirements Summary of Finding: Construction contracts in excess of $2,000 financed by federal assistance funds must pay wages not less than those established for the locality of the p...

FINDING 2023-004 Finding Subject: COVID-19-Education Stabilization Fund - Special Tests and Provisions – Wage Rate Requirements Summary of Finding: Construction contracts in excess of $2,000 financed by federal assistance funds must pay wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL) to their laborers and mechanics. Nonfederal entities are to include in their construction contracts subject to the Wage Rate Requirements a provision that the contractor or subcontractor comply with these requirements and the DOL regulations. This would include a requirement to submit a copy of the payroll and statement of compliance to the entity for each week in which contract work was performed. The School Corporation had not designed nor implemented a system of internal controls to ensure that construction contracts in excess of $2,000 paid from federal grant funds included a prevailing wage rate clause. One construction contract, totaling$149,995, was paid for with COVID-19 – Education Stabilization Fund grant funds during the audit period. The contract did not include the required prevailing wage rate clause, nor were the certified payrolls submitted by the contractor. Contact Person Responsible for Corrective Action: Leslie Rittenhouse Contact Phone Number and Email Address: 765-395-3341 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The district has no plans nor approved budget for any remaining ESSER funds to be used a manner which would relate to the prevailing wage rate clause. Should the district amend the use of ESSER funding to include such activity the prevailing wage clause requirements will be completed in full. Anticipated Completion Date: Immediately.

View Audit 367782

Finding 1155487 (2023-003)

Material Weakness 2023

Oak Hill United School Corporation

IN

Internal Control / Segregation of Duties Subrecipient Monitoring Material Weakness § 200.302 § 200.303 § 200.328 § 200.329

FINDING 2023-003 Finding Subject: COVID-19-Education Stabilization Fund - Reporting Summary of Finding: The School Corporation was required to submit an annual data report to the Indiana Department of Education (IDOE) via JotForm, a form/report builder. Data to be submitted included, but was not lim...

FINDING 2023-003 Finding Subject: COVID-19-Education Stabilization Fund - Reporting Summary of Finding: The School Corporation was required to submit an annual data report to the Indiana Department of Education (IDOE) via JotForm, a form/report builder. Data to be submitted included, but was not limited to, current period expenditures, prior period expenditures, and expenditures per activity. During the audit period the School Corporation submitted two ESSER I reports, two ESSER II reports and two ESSER III reports, for a total of six reports. The annual data reports were prepared by the Treasurer. Due to the lack of effective internal controls one of the six annual data reports was not supported by the School Corporation’s records. For the ESSER III, Year 2 report, which covered the period of July 1, 2021 to June 30, 2022, total expenses per the report were $688,778. However, the School Corporation’s ledger had total expenses for the award, for that time period, of $784,638. The lack of controls and noncompliance were isolated to the ESSER III, Year 2 report. Contact Person Responsible for Corrective Action: Leslie Rittenhouse Contact Phone Number and Email Address: 765-395-3341 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: As the finding and error occurred in one entry of one report the district will continue the practice of having a second party review financial system data against report entries. The error in this instance was a misunderstanding of the entry. A secondary review of reporting guidelines and entries will take place prior to submission of any ESSER Data Reporting. Anticipated Completion Date: Upon the next submission of ESSER Data reporting.

View Audit 367782

Finding 1155311 (2023-017)

Material Weakness 2023

The City of Frederick, Maryland

MD

Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking Subrecipient Monitoring

The City has developed a Personnel Activity Report (PAR) that has each federal grant program available as a drop-down menu item. Employees will be required to indicate time spent on grant activities daily. This PAR will be reviewed an approved by the employees' supervisor and then submitted to Payro...

The City has developed a Personnel Activity Report (PAR) that has each federal grant program available as a drop-down menu item. Employees will be required to indicate time spent on grant activities daily. This PAR will be reviewed an approved by the employees' supervisor and then submitted to Payroll for allocation to appropriate grant funds. The PAR will be retained by Payroll as backup.

View Audit 367551

Finding 1155305 (2023-011)

Material Weakness 2023

The City of Frederick, Maryland

MD

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

The City has developed a Personnel Activity Report (PAR) that has each federal grant program available as a drop-down menu item. Employees will be required to indicate time spent on grant activities daily. This PAR will be reviewed an approved by the employees' supervisor and then submitted to Payro...

The City has developed a Personnel Activity Report (PAR) that has each federal grant program available as a drop-down menu item. Employees will be required to indicate time spent on grant activities daily. This PAR will be reviewed an approved by the employees' supervisor and then submitted to Payroll for allocation to appropriate grant funds. The PAR will be retained by Payroll as backup.

View Audit 367551

Finding 1155207 (2023-001)

Material Weakness 2023

Town of Granby

NY

Procurement, Suspension & Debarment Reporting Matching / Level of Effort / Earmarking

Corrective Action Plan: To address this issue and prevent recurrence, the Town has implemented the following measures: 1. Reconciliation Procedures: Finance Department staff will reconcile all expenditures reported on USDA Form E – RD Project Budget/Cost Certification Reporting to the general ledger...

Corrective Action Plan: To address this issue and prevent recurrence, the Town has implemented the following measures: 1. Reconciliation Procedures: Finance Department staff will reconcile all expenditures reported on USDA Form E – RD Project Budget/Cost Certification Reporting to the general ledger, ensuring both the accuracy of amounts and the correct vendor attribution. 2. Vendor Verification: A vendor cross-check process will be added to the review, requiring staff to match each reported expenditure to the appropriate invoice, purchase order, and vendor record before submission. 3. Review & Approval Controls: A supervisory review will be conducted prior to submission of Form E reports to verify vendor accuracy, in addition to ensuring no duplicate or misclassified expenditures are reported. The Town is committed to ensuring compliance with all USDA reporting requirements. By strengthening reconciliation, vendor verification, and review processes, we will reduce the risk of reporting errors and maintain accurate, reliable financial reporting moving forward.

View Audit 367451

Finding 1155059 (2023-008)

Material Weakness 2023

Muskogee County

OK

Questioned Costs Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking

The Board of County Commissioners will work with all elected officials, the new county grant administrator, and federal, state and local partners to develop policies, procedures, and internal controls designed to accurately track grants, including the application process, verification, oversight, an...

The Board of County Commissioners will work with all elected officials, the new county grant administrator, and federal, state and local partners to develop policies, procedures, and internal controls designed to accurately track grants, including the application process, verification, oversight, and reporting of grant requirements. The Board of County Commissioners will work with the new county grant administrator to ensure proper grant administration.

View Audit 367368 Questioned Costs: $1

Finding 1155052 (2023-006)

Material Weakness 2023

County of Columbia, Pennsylvania

PA

Subrecipient Monitoring Allowable Costs / Cost Principles Reporting

2024-006 - Reporting - Significant Deficiency/Noncompliance Federal Program: Assistance Listing #21.027, COVID-19 - Coronavirus State and Local Fiscal Recovery Funds, U.S. Department of Treasury, Passed Through Pennsylvania Department of Community and Economic Development, Pass-Through Entity Identi...

2024-006 - Reporting - Significant Deficiency/Noncompliance Federal Program: Assistance Listing #21.027, COVID-19 - Coronavirus State and Local Fiscal Recovery Funds, U.S. Department of Treasury, Passed Through Pennsylvania Department of Community and Economic Development, Pass-Through Entity Identifying Number: not available Condition/Context: The County’s required reports for the quarters ended June 30, 2023, September 30, 2023, and December 31, 2023, were due to be filed by the end of the month after the report end date (July 31, 2023, October 31, 2023, and January 31, 2024, respectively). The County filed its report on August 23, 2023, November 17, 2023, and February 15, 2024 (23, 17, and 15 days, respectively), after the required due date. Views of Responsible Officials and Planned Corrective Actions: Management understands and will seek to implement procedures to ensure future reports are submitted timely. Individual Responsible: Finance Department Timeline for corrective action: By December 31, 2024

View Audit 367366

Finding 1154791 (2023-071)

Material Weakness 2023

Oklahoma Water Resources Board

OK

Eligibility Subrecipient Monitoring Matching / Level of Effort / Earmarking

Finding Number 2023-071 Subject Heading (Financial) or AL no. and program name (Federal) 93.778 Medicaid Cluster Planned Corrective Action OKDHS Response: The agency will manually load the workflow queues using the monitoring transactions for the G1dx discrepancies, and we will continuously work to ...

Finding Number 2023-071 Subject Heading (Financial) or AL no. and program name (Federal) 93.778 Medicaid Cluster Planned Corrective Action OKDHS Response: The agency will manually load the workflow queues using the monitoring transactions for the G1dx discrepancies, and we will continuously work to improve the system failures preventing automatic workload management. This includes bi-weekly updates to ensure all items are properly queued for resolution until the system can fully resume this functionality. OHCA Member Audit Response: Member Audit began receiving Medicaid G1DX files monthly in September of 2023. Files are continuing to be received from DHS each month. Audits are completed monthly and will continue indefinitely. Any discrepancies are discussed with OKDHS to determine the cause and remedy put in place to ensure any failed jobs were resolved. Anticipated Completion Date 9/30/2025 Responsible Contact Person Jennifer McSparrin, OKDHS Programs Administrator of Business Intelligence April Anonsen, Deputy State Medicaid Director Ginger Clayton, Director of Member Audits

View Audit 367158

Finding 1154790 (2023-037)

Material Weakness 2023

Oklahoma Water Resources Board

OK

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

Finding Number 2023-037 Subject Heading (Financial) or AL no. and program name (Federal) 93.778 Medicaid Cluster 93.767 Children’s Health Insurance Program Planned Corrective Action OHCA MAGI Response: OHCA implemented system changes to begin income verification requests for all selfattested income ...

Finding Number 2023-037 Subject Heading (Financial) or AL no. and program name (Federal) 93.778 Medicaid Cluster 93.767 Children’s Health Insurance Program Planned Corrective Action OHCA MAGI Response: OHCA implemented system changes to begin income verification requests for all selfattested income from sources unable to be verified through existing data exchange. The system changes went to production on January 13, 2022 but were impacted by Public Health Emergency (PHE) requirements prohibiting termination of eligibility. The system changes became effective at the end of the PHE and have resulted in appropriate verification of income that was previously unverified. Guidance from Centers for Medicare and Medicaid Services (CMS) during the PHE prohibited the agency from requiring verification, renewals, or termination of Medicaid during the PHE. The agency followed the requirements and guidance of CMS throughout the PHE to ensure maintenance of coverage. OHCA is in the process of implementing system changes to ensure only previously verified income is removed and to ensure that applications in a pending status due to incomplete information from the Federal Marketplace continue to receive new data exchange information. OHCA continues to improve zero income self-attestation procedures as the value of the attestations in ensuring accurate eligibility decisions is recognized, and upgrades went to Production on April 17, 2025. Guidance from Centers for Medicare and Medicaid Services (CMS) during the PHE prohibited the agency from requiring verification, renewals, or termination of Medicaid during the PHE. The agency followed the requirements and guidance of CMS throughout the PHE to ensure maintenance of coverage. OHCA concurs with the Soon-to-be-Sooners (STBS) exception. The questioned costs will be reported on the CMS 64.9P line 10A on Cost of Service (COS) line 5 for the quarter ending June 30, 2025. OHCA Member Audit MAGI Response: Member Audit will complete three months of post-corrective action audits to ensure completion. If corrective action results are not sufficient, additional corrective action will be requested, and post- corrective action audit will be repeated. OKDHS Non-MAGI Response: For the non-MAGI deficiencies, OKDHS has addressed case issues through the establishment of a committee responsible for monitoring corrective actions and provided training to all appropriate employees. Additional informational webpages utilized by eligibility staff have been updated. OHCA Member Audit Non-MAGI Response: OHCA Member Audit has been monitoring these issues through monthly case reviews and provides feedback to OKDHS leadership. This process will continue until the issues have been corrected. Additional steps to correct issues are requested as deemed necessary by Member Audit. Anticipated Completion Date 8/31/2025 Responsible Contact Person Chris Dees, Eligibility and Coverage Services Technical Director April Anonsen, Deputy State Medicaid Director Ginger Clayton, OHCA Director of Member Audits Aubrey McDonald , OKDHS Medicaid Program Administrator Ginger Clayton, OHCA Director of Member Audits

View Audit 367158 Questioned Costs: $1

Corrective Action Plans

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