Corrective Action Plans

Finding 386573 (2023-010)

Significant Deficiency 2023

State of Mississippi Institutions of Higher Learning

MS

Student Financial Aid Reporting Significant Deficiency § 200.303

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

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 Changes in enrollment to less than half-time, graduated, or withdrawn status must be reported within 30 days.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

View Audit 298874

Finding 386572 (2023-009)

Significant Deficiency 2023

State of Mississippi Institutions of Higher Learning

MS

Student Financial Aid Reporting Significant Deficiency § 200.303

Department of Education 2023–009 Common Origination and Disbursement (COD) Student Financial Aid Cluster – Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Condition: The Fall 2022 and Spring 2023 disbursement dates in COD for Parent Plus Direct Loans did not match the disbursement date on the ...

Department of Education 2023–009 Common Origination and Disbursement (COD) Student Financial Aid Cluster – Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Condition: The Fall 2022 and Spring 2023 disbursement dates in COD for Parent Plus Direct Loans did not match the disbursement date on the student ledgers. Auditors’ Recommendation: During CLA testing of Eligibility. CLA noted that the University was not in compliance with the federal financial aid regulations COD reporting requirements, including reporting disbursements, adjustments, and cancellations in a timely and accurate manner. CLA recommend that the entity strengthen its internal controls to ensure that all disbursement dates are reported to COD correctly. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The financial aid office will conduct bi-weekly reviews of enrollment changes, including university withdrawals. In addition, bi- weekly reviews of adjustment completion will be done to ensure banner adjustments are sent to COD within 10-14 business days. Name of the contact person responsible for corrective action: Ozie Ratcliff – Director of Financial Aid Planned completion date for corrective action plan: Updated process will begin 3/25/2024. If the Department of Education has questions regarding this plan, please call Ozie Ratcliff at 601-979-3347.

View Audit 298874

Finding 386571 (2023-008)

Significant Deficiency 2023

State of Mississippi Institutions of Higher Learning

MS

Reporting Significant Deficiency Equipment & Real Property Management § 200.303

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

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

View Audit 298874

Finding 386570 (2023-007)

Significant Deficiency 2023

State of Mississippi Institutions of Higher Learning

MS

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

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

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

View Audit 298874

Finding 386569 (2023-006)

Significant Deficiency 2023

State of Mississippi Institutions of Higher Learning

MS

Matching / Level of Effort / Earmarking § 200.303

Department of Health and Human Services 2023-006 Value-Based Medical Student Education Training Program – Assistance Listing No. 93.680 Condition: Federal cost share is not being tracked separately. Auditors’ Recommendation: We recommend the institution track cost share expenditures in a separate fu...

Department of Health and Human Services 2023-006 Value-Based Medical Student Education Training Program – Assistance Listing No. 93.680 Condition: Federal cost share is not being tracked separately. Auditors’ Recommendation: We recommend the institution track cost share expenditures in a separate fund and perform periodic reviews to ensure the matching requirement is being met. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Campus grant administrators will be reminded that all mandatory and voluntary committed cost must be captured in Workday within the appropriate fund. Additionally, campus grant administrators will receive a Workday job aid to provide detailed instructions on how to allocate applicable cost share expenditures to the respective funds. Name(s) of the contact person(s) responsible for corrective action: Julie Schwindt, Director, Post-Award Accounting Planned completion date for corrective action plan: March 31, 2024 If the Department of Health and Human Services has questions regarding this plan, please call Julie Schwindt at 601-984-1058.

View Audit 298874

Finding 386568 (2023-005)

Significant Deficiency 2023

State of Mississippi Institutions of Higher Learning

MS

Matching / Level of Effort / Earmarking § 200.300 § 200.303 § 200.306 § 200.309 § 200.403

Department of Health and Human Services 2023-005 Value-Based Medical Student Education Training Program – Assistance Listing No. 93.680 Condition: Indirect cost expense was improperly calculated. Auditors’ Recommendation: We recommend the institution strengthen its internal controls to ensure that c...

Department of Health and Human Services 2023-005 Value-Based Medical Student Education Training Program – Assistance Listing No. 93.680 Condition: Indirect cost expense was improperly calculated. Auditors’ Recommendation: We recommend the institution strengthen its internal controls to ensure that calculations are reviewed and adjusted for, if necessary, in a timely manner. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: UMMC’s transition to Workday resulted in the need for multiple F&A bases to be created in Workday to accommodate our DHHS negotiated agreement. However, since our go-live we have only been using one modified total direct cost base to calculate F&A. UMMC is in the process of engaging a Workday Certified consulting firm to review the operational efficiency of Workday for Post-Award Accounting. The scope of this engagement will be to align our usage of Workday to industry best practices, including best practices for F&A calculation. During the scope of this project, we will review these established bases to ensure they meet the needs of our negotiated rate agreement provisions. In the meantime, we are reviewing the F&A calculations on existing projects when an invoice or financial report is prepared to ensure accuracy. F&A will be recalculated with each invoice and/or financial report and any necessary adjustments will be made before the invoice or financial report is submitted to the sponsor. Name(s) of the contact person(s) responsible for corrective action: Julie Schwindt, Director, Post-Award Accounting Planned completion date for corrective action plan: June 30, 2024 If the Department of Health and Human Services has questions regarding this plan, please call Julie Schwindt at 601-984-1058.

View Audit 298874

Finding 386551 (2023-003)

Material Weakness 2023

Yolo County Transportation District

CA

Questioned Costs Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking § 200.303 § 200.516

Finding 2023-003 – Material Weakness AL No: 20.507 Federal Grantor: U.S. Department of Transportation, Federal Transit Administration, Federal Transit Formula Grants - Direct Award Compliance Requirements: Activities Allowed or Unallowed and Allowable Costs/Cost Principles. Condition: The District’s...

Finding 2023-003 – Material Weakness AL No: 20.507 Federal Grantor: U.S. Department of Transportation, Federal Transit Administration, Federal Transit Formula Grants - Direct Award Compliance Requirements: Activities Allowed or Unallowed and Allowable Costs/Cost Principles. Condition: The District’s internal controls over compliance requirements did not identify ineligible costs applied to four separate Federal Transit Administration (FTA) grants as follows. • Section 5307 Grant Award CA-2020-173-01: The District overclaimed Route 42 and Woodland fixed route operating expenses that should have been reimbursed by a local match as required by other FTA grants applied to the same routes, resulting in ineligible costs of $1,073,260 being charged to the program. Questioned Costs: $1,073,260. • Section 5307 Grant Award CA-2022-140-01: The District overclaimed Route 42 expansion fixed route operating expenses that should have been reimbursed by a local match as the wrong federal percentage was applied in the claims, resulting in ineligible costs of $33,129 being charged to the program. Questioned Costs: $33,129. Section 5307 Grant Award CA-2022-147-04: The District overclaimed communication expenses for Woodland paratransit operating routes, resulting in ineligible costs of $12,513 being charged to the program. Questioned Costs: Ineligible costs were below the $25,000 floor for questioned costs under 2 CFR Part 200, Subpart F (Uniform Guidance), Section 200.516. • Section 5307 Grant Awards CA-2022-204-01 and CA-2021-162-03: The District claimed engine overhaul expenses that did not qualify as preventative maintenance costs allowed by the terms and conditions of the grant, resulting in ineligible costs of $17,902 being charged to the program. Questioned Costs: Ineligible costs were below the $25,000 floor for questioned costs under 2 CFR Part 200, Subpart F (Uniform Guidance), Section 200.516. Criteria: 2 CFR Part 200, Subpart E (Uniform Guidance) Section 200.303 states that “The nonfederal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.” Cause: Several federal grants applied to these routes had local match requirements that were not captured by the District’s review procedures due to recent staff turnover and lack of documented procedures to track expenses charged to all funding sources combined. Not all paratransit operating expenses were reported and tracked separately in the allocation spreadsheet leading to expenses being double claimed under different grants for different purposes. This is due to the allocation spreadsheet not having a summary page totaling all expenses charged to programs to make sure the total expenses allocated agree to the total population of expenses allocated. Effect: Expenses were charged to more than one grant when filing claims and ineligible costs were applied, resulting in the overclaimed amounts cited above. Context: The ineligible costs were discovered through reconciliation of the operating expenses and capital costs from the claims to the general ledger. It was noted that the District did not have any FTA awards for capital maintenance during the year. The overclaimed amounts of $1,073,260, $33,129, and $12,513 have been removed from revenue as the FTA has currently approved the District claiming the expenses under different grants. There were potentially additional operating expenses under Paratransit services that could have offset some of these overclaimed amounts. The ineligible costs of $17,902 have been submitted to the FTA through a budget revision to allow for capital funding under the two related awards and is currently pending FTA approval. Recommendation: We recommend the District develop written procedures for allocating expenses to routes and purposes used to claim expenses under federal grants and to track the different funding sources applied. A summary tab should be added to the allocation spreadsheet to sum amounts for each route computed on separate tabs on the spreadsheet to make it easier to reconcile total operating expenses, preventive maintenance, insurance, communications and other expenses allocated to the population of expenses in the general ledger. View of Responsible Officials and Planned Corrective Action: Management acknowledges the audit finding and agrees with the recommendation. The District is taking immediate corrective action by training staff and seeking temporary assistance to support operations during ongoing training and improvement. While the new financial system aimed to enhance our processes and efficiencies, we recognize the need to modify the general ledger processes to better detect required transactions. The District will focus promptly on resolving these issues to prevent future errors and oversights. Further, we will prioritize reviewing all grant award agreements and collaborating closely with our grant program coordinators to ensure compliance and accuracy in grant-related activities.

View Audit 298872 Questioned Costs: $1

Finding 386538 (2023-007)

Material Weakness 2023

Metropolitan School District of Warren County

IN

Special Tests & Provisions Subrecipient Monitoring Material Weakness § 200.303

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

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

View Audit 298830

Finding 386537 (2023-006)

Significant Deficiency 2023

Metropolitan School District of Warren County

IN

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

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

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

View Audit 298830

Finding 386533 (2023-004)

Significant Deficiency 2023

Metropolitan School District of Warren County

IN

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

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

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

View Audit 298830

Finding 386522 (2023-002)

Significant Deficiency 2023

Metropolitan School District of Warren County

IN

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

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

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

View Audit 298830 Questioned Costs: $1

Finding 386521 (2023-003)

Significant Deficiency 2023

St. Giles Manor, Inc.

AL

HUD Housing Programs Matching / Level of Effort / Earmarking

SPM terminated the employment of the person responsible for this oversight and has implemented an internal control for its Financial Planning & Analysis department to monitor the management team’s compliance with these deadlines.

View Audit 298828

Finding 386517 (2023-001)

Significant Deficiency 2023

Howard County

MD

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

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

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

View Audit 298820

Finding 386496 (2023-032)

Material Weakness 2023

State of Arkansas

AR

Questioned Costs Subrecipient Monitoring Eligibility § 200.303 § 200.516

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

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

View Audit 298801 Questioned Costs: $1

Finding 386495 (2023-031)

Material Weakness 2023

State of Arkansas

AR

Special Tests & Provisions Subrecipient Monitoring Material Weakness

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

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

View Audit 298801

Finding 386493 (2023-029)

Material Weakness 2023

State of Arkansas

AR

Questioned Costs Subrecipient Monitoring Eligibility

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

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

View Audit 298801 Questioned Costs: $1

Finding 386492 (2023-028)

Material Weakness 2023

State of Arkansas

AR

Questioned Costs Subrecipient Monitoring Eligibility

Views of Responsible Officials and Planned Corrective Action: DHS concurs with the finding. Since June 2023, DYS has made multiple changes to improve monitoring of suspension and reinstatement of Medicaid eligibility for incarcerated juveniles. For juveniles with SSI Medicaid, the Social Security A...

Views of Responsible Officials and Planned Corrective Action: DHS concurs with the finding. Since June 2023, DYS has made multiple changes to improve monitoring of suspension and reinstatement of Medicaid eligibility for incarcerated juveniles. For juveniles with SSI Medicaid, the Social Security Administration (SSA) is responsible for suspending Medicaid coverage. All incarcerations for cases noted in the findings involving SSI Medicaid were reported timely to SSA by the agency. DYS closely monitors these cases and continues to send closure requests to SSA until the cases are closed out. DYS has also updated its communication processes with DCO to ensure cases are suspended and reinstated in a timely manner. All payments noted as occurring during the incarceration period were capitated payments made for the PASSE, Dental Managed Care, NET, and PCCM programs. Some audit findings highlighted payments made for members during their month of incarceration, which is acceptable for all programs. The full monthly rate is paid for Dental Managed Care, NET, and PCCM even if the member is only eligible for part of the month. The PASSE program operates on a per-diem basis and any payments made for days when the member is ineligible are recouped as part of a monthly reconciliation. The agency currently has a reconciliation process for all four programs that identifies payments made after a member’s incarceration date that should be recouped. Some payments noted in the findings will be recouped as part of a reconciliation process that has yet to run. In addition to the current reconciliation process, the agency is in the process of developing an MMIS change that will automatically update member profiles to accurately reflect incarceration dates. This will ensure capitated payments are paused and reinstated in a timely manner and that recoupments and repayments are subsequently processed. Anticipated Completion Date: 6/30/2024 Contact Person: Name: Elizabeth Pitman Title: Director, Division of Medical Services Agency: Department of Human Services Address: 700 Main Street City, State, Zip: Little Rock, AR 72201 Phone Number: 501-244-3944 Email Address: Elizabeth.Pitman@dhs.arkansas.gov

View Audit 298801 Questioned Costs: $1

Finding 386489 (2023-025)

Material Weakness 2023

State of Arkansas

AR

Questioned Costs Eligibility Subrecipient Monitoring

Views of Responsible Officials and Planned Corrective Action: DHS concurs with the finding. The agency is conducting an ARIES system review to determine the root cause of the incorrect eligibility determinations and will identify and implement any needed updates to the automatic renewal process. ...

Views of Responsible Officials and Planned Corrective Action: DHS concurs with the finding. The agency is conducting an ARIES system review to determine the root cause of the incorrect eligibility determinations and will identify and implement any needed updates to the automatic renewal process. Anticipated Completion Date: 4/30/2024 Contact Person: Name: Mary Franklin Title: Director, Division of County Operations Agency: Department of Human Services Address: 700 Main Street City, State, Zip: Little Rock, AR 72201 Phone Number: 501-681-8377 Email Address: Mary.Franklin@dhs.arkansas.gov

View Audit 298801 Questioned Costs: $1

Finding 386486 (2023-023)

Material Weakness 2023

State of Arkansas

AR

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

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

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

View Audit 298801

Finding 386484 (2023-022)

Material Weakness 2023

State of Arkansas

AR

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles

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

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

View Audit 298801 Questioned Costs: $1

Finding 386482 (2023-021)

Material Weakness 2023

State of Arkansas

AR

Questioned Costs Matching / Level of Effort / Earmarking Subrecipient Monitoring

Views of Responsible Officials and Planned Corrective Action: DHS disputes this finding. All funds used as match for administrative and program expenditures were from an allowable funding source. The agency confirmed that the Arkansas Medicaid Program Trust Fund, which funds all bank accounts used ...

Views of Responsible Officials and Planned Corrective Action: DHS disputes this finding. All funds used as match for administrative and program expenditures were from an allowable funding source. The agency confirmed that the Arkansas Medicaid Program Trust Fund, which funds all bank accounts used for administrative and program expenditures for Medicaid and CHIP, is only funded with statutorily allowed revenues. The complex nature of Medicaid and CHIP finance and frequency of transactions necessitates paying accounts be sufficiently funded to pay all costs associated with administering the programs. This often results in accounts carrying a fund balance that does not require the agency to draw down additional state general revenue or other non-federal funds to meet its state match obligation. While the agency disagrees that a dollar-for-dollar reconciliation of funding draws is the appropriate way to confirm program expenditures are from an allowable source, we continue to update our general ledger system to improve the ability to monitor state general revenues and other non-federal federal revenue sources used to match federal funding. Anticipated Completion Date: Complete Contact Person: Name: Misty Eubanks Title: Deputy Secretary for Operations and Budget and Interim Chief Financial Officer Agency: Department of Human Services Address: P.O. Box 1437, Slot S201 City, State, Zip: Little Rock, AR, 72203-1437 Phone Number: 501-320-6327 Email Address: misty.eubanks@dhs.arkansas.gov

View Audit 298801 Questioned Costs: $1

Finding 386480 (2023-020)

Material Weakness 2023

State of Arkansas

AR

Matching / Level of Effort / Earmarking Eligibility

Views of Responsible Officials and Planned Corrective Action: DHS concurs with the finding. ARIES system logic has been updated to consider all information recorded in the PARIS match reports when identifying cases for review. Anticipated Completion Date: Complete Contact Person: Name: Mary F...

Views of Responsible Officials and Planned Corrective Action: DHS concurs with the finding. ARIES system logic has been updated to consider all information recorded in the PARIS match reports when identifying cases for review. Anticipated Completion Date: Complete Contact Person: Name: Mary Franklin Title: Director, Division of County Operations Agency: Department of Human Services Address: 700 Main Street City, State, Zip: Little Rock, AR 72201 Phone Number: 501-681-8377 Email Address: Mary.Franklin@dhs.arkansas.gov

View Audit 298801

Finding 386477 (2023-018)

Material Weakness 2023

State of Arkansas

AR

Matching / Level of Effort / Earmarking Subrecipient Monitoring

Views of Responsible Officials and Planned Corrective Action: DHS concurs with the finding. The agency will develop a procedure to monitor and accurately report adoption savings activities and will submit an updated Adoption Savings Report to correct any previously incorrectly reported amounts. A...

Views of Responsible Officials and Planned Corrective Action: DHS concurs with the finding. The agency will develop a procedure to monitor and accurately report adoption savings activities and will submit an updated Adoption Savings Report to correct any previously incorrectly reported amounts. Anticipated Completion Date: 3/31/2024 Contact Person: Name: Tiffany Wright Title: Director, Division of Children and Family Services Agency: Department of Human Services Address: 700 Main Street City, State, Zip: Little Rock, AR 72201 Phone Number: 501-396-6477 Email Address: Tiffany.Wright@dhs.arkansas.gov

View Audit 298801

Finding 386476 (2023-017)

Material Weakness 2023

State of Arkansas

AR

Matching / Level of Effort / Earmarking Subrecipient Monitoring

Views of Responsible Officials and Planned Corrective Action: DHS concurs with the finding. The agency will develop a procedure to monitor and accurately report adoption savings activities and will submit an updated Adoption Savings Report to correct any previously incorrectly reported amounts. A...

Views of Responsible Officials and Planned Corrective Action: DHS concurs with the finding. The agency will develop a procedure to monitor and accurately report adoption savings activities and will submit an updated Adoption Savings Report to correct any previously incorrectly reported amounts. Anticipated Completion Date: 3/31/2024 Contact Person: Name: Tiffany Wright Title: Director, Division of Children and Family Services Agency: Department of Human Services Address: 700 Main Street City, State, Zip: Little Rock, AR 72201 Phone Number: 501-396-6477 Email Address: Tiffany.Wright@dhs.arkansas.gov

View Audit 298801

Finding 386475 (2023-016)

Material Weakness 2023

State of Arkansas

AR

Questioned Costs Subrecipient Monitoring Eligibility

Views of Responsible Officials and Planned Corrective Action: DHS concurs with the finding. The agency has updated its internal controls procedures to require enhanced review of payments made after the death of a provider or a client and enhanced monitoring of when a client is removed from an adopt...

Views of Responsible Officials and Planned Corrective Action: DHS concurs with the finding. The agency has updated its internal controls procedures to require enhanced review of payments made after the death of a provider or a client and enhanced monitoring of when a client is removed from an adoptive parent’s home. The Accounts Receivable Unit in the Office of Finance has implemented systems changes that ensures all claims will generate a collections notice with the correct claims data. The noted outstanding collection notices have been sent and data entry errors have been corrected. Anticipated Completion Date: Complete Contact Person: Name: Tiffany Wright Title: Director, Division of Children and Family Services Agency: Department of Human Services Address: 700 Main Street City, State, Zip: Little Rock, AR 72201 Phone Number: 501-396-6477 Email Address: Tiffany.Wright@dhs.arkansas.gov

View Audit 298801 Questioned Costs: $1

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