Corrective Action Plans

Finding 478994 (2023-035)

Significant Deficiency 2023

MA

Reporting Matching / Level of Effort / Earmarking Procurement, Suspension & Debarment § 200.303

DEPARTMENT OF PUBLIC HEALTH 2023-035 Opioid – STR - Assistance Listing No. 93.788 Action taken in response to the finding: Reporting - GRPA Submission evidence: Per recommendations of the auditing team the Project PI will review all data provided to them by the project staff before submitting to SP...

DEPARTMENT OF PUBLIC HEALTH 2023-035 Opioid – STR - Assistance Listing No. 93.788 Action taken in response to the finding: Reporting - GRPA Submission evidence: Per recommendations of the auditing team the Project PI will review all data provided to them by the project staff before submitting to SPARS. When review is finalized the PI will submit the reports to SPARS. At this time the PI will screenshot an image of each report submission page to SPARS for each GPRA report and save the file as a pdf. (This will need to be done as the reporting system does not return a confirmation report for filings.) Any subsequent updates of data will similarly be reviewed, compared to previous submissions to ensure accuracy, and logged. The same documentation will be recorded and stored with the previous submission data to keep accurate record of any changes. Data to create/compile the report (back up, supporting documentation to match the report) process. These pdf records documenting the time and date of initial report submissions and any edits will be kept on file with both the PI in their Teams program file, and with the BSAS Grant Teams SOR grant file for the corresponding grant year for future reference. Our internal Fiscal Compliance Auditor will review batches of these submission quarterly to ensure compliance. Evidence of Review & Approval process: These records will be reviewed both by the Grant PI and the BSAS Grants specialist to ensure accuracy, in particular where changes are being made. If changes have been made to data that may require future explanation the cause of the variances will be noted by the PI and documentation will be include with the submission records. Reporting – Programmatic Progress Reports Submission evidence: Per recommendations of the auditing team the Project PI will review all data provided to them by the project staff before submitting to eRA Commons. When review is finalized the PI will submit the reports to eRA Commons. At this time the PI will screenshot an image of each report submission page to eRA Commons for each PPR and save the file as a pdf. (This will need to be done as the reporting system does not return a confirmation report for filings.) Any subsequent updates of data will similarly be reviewed, compared to previous submissions to ensure accuracy, and logged. The same documentation will be recorded and stored with the previous submission data to keep accurate record of any changes. Data to create/compile the report (back up, supporting documentation to match the report) process. These pdf records documenting the time and date of initial report submissions and any edits will be kept on file with both the PI in their Teams program file, and with the BSAS Grant Teams SOR grant file for the corresponding grant year for future reference. Our internal Fiscal Compliance Auditor will review batches of these submission quarterly to ensure compliance. Evidence of Review & Approval process: These records will be reviewed both by the Grant PI and the BSAS Grants specialist to ensure accuracy, in particular where changes are being made. If changes have been made to data that may require future explanation the cause of the variances will be noted by the PI and documentation will be included with the submission records. Name of the contact person responsible for corrective action: Shannon McEneaney-Farron, BSAS Fiscal Director, Nicole Schmitt, Director of the Office of Strategy and Innovation (Grant PI) Planned completion date for corrective action plan: Ongoing. This process will commence as of July 1, 2024.

View Audit 315520

Finding 478992 (2023-033)

Material Weakness 2023

Commonwealth of Massachusetts

MA

Subrecipient Monitoring Material Weakness Reporting § 200.303

DEPARTMENT OF PUBLIC HEALTH 2023-033 Opioid – STR - Assistance Listing No. 93.788 Action taken in response to the finding: All subrecipient FFATA information will be batch uploaded to FSRS within 30 days of execution of subcontracts. The majority of BSAS subrecipient contracts are executed as of Ju...

DEPARTMENT OF PUBLIC HEALTH 2023-033 Opioid – STR - Assistance Listing No. 93.788 Action taken in response to the finding: All subrecipient FFATA information will be batch uploaded to FSRS within 30 days of execution of subcontracts. The majority of BSAS subrecipient contracts are executed as of July 1. A batch upload of data will be completed each month over the grant period so that all outlying contracts not executed on June 30 will have their FFATA data uploaded to FSRS within 30 days of contract execution throughout the year. These uploads will be conducted by the BSAS Grants coordinator. Once successfully uploaded the Grants coordinator will receive a FFATA submission receipt from FSRS for each FFATA submission. They will share this with their supervisor and the Fiscal Director for confirmation. These records will be kept on file in the BSAS Grant Teams file for future reference. Our internal Fiscal Compliance Auditor will review batches of these submission quarterly to ensure compliance. Name of the contact person responsible for corrective action: Shannon McEneaney-Farron, BSAS Fiscal Director Planned completion date for corrective action plan: Ongoing. This process will commence as of July 1, 2024.

View Audit 315520

Finding 478987 (2023-032)

Significant Deficiency 2023

Commonwealth of Massachusetts

MA

Questioned Costs Special Tests & Provisions Significant Deficiency § 200.303

EXECUTIVE OFFICE OF HEALTH AND HUMAN SERVICES 2023-032 Medicaid Cluster, COVID-19 – Medicaid Cluster - Assistance Listing No. 93.775, 93.777, 93.778 Action taken in response to the finding: In response to the finding, MassHealth will • Implement corrective measures to ensure workbooks are revamped ...

EXECUTIVE OFFICE OF HEALTH AND HUMAN SERVICES 2023-032 Medicaid Cluster, COVID-19 – Medicaid Cluster - Assistance Listing No. 93.775, 93.777, 93.778 Action taken in response to the finding: In response to the finding, MassHealth will • Implement corrective measures to ensure workbooks are revamped and that processes are implemented to automate and improve the importation of data and to allow more time for quality control review. • Work with staff to develop additional checks to ensure the correct federal share is reported and returned. • Return the identified federal share in the QE 03.2024 CMS 64. Name of the contact person responsible for corrective action: Janet Chin, Director Federal Revenue Claiming, Title XIX & XXI Planned completion date for corrective action plan: Immediate and ongoing

View Audit 315520 Questioned Costs: $1

Finding 478982 (2023-031)

Significant Deficiency 2023

Commonwealth of Massachusetts

MA

Special Tests & Provisions Reporting Significant Deficiency § 200.303

EXECUTIVE OFFICE OF HEALTH AND HUMAN SERVICES 2023-031 Medicaid Cluster, COVID-19 – Medicaid Cluster - Assistance Listing No. 93.775, 93.777, 93.778 Action taken in response to the finding: The Executive Office of Health and Human Services (EOHHS) has reviewed the required elements of reports submi...

EXECUTIVE OFFICE OF HEALTH AND HUMAN SERVICES 2023-031 Medicaid Cluster, COVID-19 – Medicaid Cluster - Assistance Listing No. 93.775, 93.777, 93.778 Action taken in response to the finding: The Executive Office of Health and Human Services (EOHHS) has reviewed the required elements of reports submitted by managed care providers with EOHHS staff and reviewed the steps that EOHHS staff should take when any element of those reports is missing. Name of the contact person responsible for corrective action: Robert Roche, FP&A Analyst Planned completion date for corrective action plan: May 2, 2024

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Finding 478977 (2023-030)

Material Weakness 2023

Commonwealth of Massachusetts

MA

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

EXECUTIVE OFFICE OF HEALTH AND HUMAN SERVICES 2023-030 Medicaid Cluster, COVID-19 – Medicaid Cluster - Assistance Listing No. 93.775, 93.777, 93.778 Action taken in response to the finding: EOHHS is developing a standardized checklist, using CLA’s guidance as a template, to ensure that SOC reports ...

EXECUTIVE OFFICE OF HEALTH AND HUMAN SERVICES 2023-030 Medicaid Cluster, COVID-19 – Medicaid Cluster - Assistance Listing No. 93.775, 93.777, 93.778 Action taken in response to the finding: EOHHS is developing a standardized checklist, using CLA’s guidance as a template, to ensure that SOC reports are reviewed and that such reviews are documented. Name of the contact person responsible for corrective action: Conduent – Jacob Guggenheim, Director of Healthcare Information and Analysis DentaQuest - Tomaso Calicchio, Director of Specialty Provider Networks Maximus – Janice Wadsworth, Director of Provider Operations Planned completion date for corrective action plan: July 2024

View Audit 315520

Finding 478972 (2023-029)

Significant Deficiency 2023

Commonwealth of Massachusetts

MA

Questioned Costs Eligibility Special Tests & Provisions § 200.303

EXECUTIVE OFFICE OF HEALTH AND HUMAN SERVICES 2023-029 Medicaid Cluster, COVID-19 – Medicaid Cluster - Assistance Listing No. 93.775, 93.777, 93.778 Action taken in response to the finding: Dental: In response to the finding MassHealth required DentaQuest to: • Implement a corrective action plan to...

EXECUTIVE OFFICE OF HEALTH AND HUMAN SERVICES 2023-029 Medicaid Cluster, COVID-19 – Medicaid Cluster - Assistance Listing No. 93.775, 93.777, 93.778 Action taken in response to the finding: Dental: In response to the finding MassHealth required DentaQuest to: • Implement a corrective action plan to review and improve internal controls for the retention of provider enrollment documentation. • Ensure that all required documents are obtained and retained during validation and revalidation (i.e., “provider eligibility recertification”) processes for both individual dental providers and dental group practices. • Provide additional training to its provider enrollment staff on document retention. DentaQuest has implemented the above requirements to ensure provider license and revalidation dates are verified and maintained in MassHealth’s Medicaid Management Information System (MMIS) upon enrollment and subsequent revalidation. However, MassHealth anticipates that due to a backlog in the dental group practice revalidation process, dental group practice revalidation will not be complete January 2025. In the event that a MassHealth-enrolled provider or group practice does not timely respond to MassHealth revalidation requests, MassHealth initiates the process of terminating the provider’s MassHealth contract. BSS: For the one out of state provider that MassHealth did not revalidate, once identified, the provider was immediately put into a revalidation process. The provider did not respond to requests from MassHealth to revalidate and the provider’s MassHealth contract was terminated effective 1/21/2024 for failure to revalidate. MassHealth and BSS will continue to review and ensure that all providers who are required to revalidate are completed within the CMS required timeframes. Name of the contact person responsible for corrective action: Tuyen Vu, Deputy Director, Dental Janice Wadsworth, Director of Provider Operations Planned completion date for corrective action plan: Dental: January 1, 2025 BSS: January 21, 2024

View Audit 315520 Questioned Costs: $1

Finding 478968 (2023-027)

Material Weakness 2023

Commonwealth of Massachusetts

MA

Material Weakness Reporting Matching / Level of Effort / Earmarking § 200.303

EXECUTIVE OFFICE OF HOUSING AND LIVABLE COMMUNITIES 2023-027 Low-Income Home Energy Assistance, COVID-19 – Low-Income Home Energy Assistance - Assistance Listing No. 93.568 Action taken in response to the finding: The Executive Office of Housing and Livable Communities (EOHLC), which was formerly t...

EXECUTIVE OFFICE OF HOUSING AND LIVABLE COMMUNITIES 2023-027 Low-Income Home Energy Assistance, COVID-19 – Low-Income Home Energy Assistance - Assistance Listing No. 93.568 Action taken in response to the finding: The Executive Office of Housing and Livable Communities (EOHLC), which was formerly the Department of Housing and Community Development (DHCD or Department), has implemented the recommended measures and will continue them going forward. EOHLC has reviewed their policies and procedures for LIHEAP reporting requirements and is committed to making any enhancements that are necessary to ensure the reports are submitted timely and accurately, and that the information reported agrees to the supporting documentation. In addition, EOHLC Management or their designees will review deadlines and other requirements for LIHEAP reports on an ongoing basis. Name of the contact person responsible for corrective action: Edward Kiely Planned completion date for corrective action plan: October 1, 2024

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Finding 478966 (2023-026)

Material Weakness 2023

Commonwealth of Massachusetts

MA

Subrecipient Monitoring Material Weakness Reporting § 200.303

EXECUTIVE OFFICE OF HOUSING AND LIVABLE COMMUNITIES 2023-026 Low-Income Home Energy Assistance, COVID-19 – Low-Income Home Energy Assistance - Assistance Listing No. 93.568 Action taken in response to the finding: The Executive Office of Housing and Livable Communities (EOHLC), which was formerly t...

EXECUTIVE OFFICE OF HOUSING AND LIVABLE COMMUNITIES 2023-026 Low-Income Home Energy Assistance, COVID-19 – Low-Income Home Energy Assistance - Assistance Listing No. 93.568 Action taken in response to the finding: The Executive Office of Housing and Livable Communities (EOHLC), which was formerly the Department of Housing and Community Development (DHCD or Department), has implemented the recommended measures and will continue them going forward. As a result of the original finding, 2022-018, EOHLC had previously put policies and procedures in place to ensure that all required subawards are reported timely and accurately to FSRS, and the Federal Funding Accountability and Transparency Act (FFATA) reports are reported timely and accurately. EOHLC’s FFATA report procedure was developed in September of 2023 and submitted on November 20, 2023. Although EOHLC acknowledges why this has resulted in this finding, EOHLC notes that policies and procedures have already been put in place to remedy this issue. Name of the contact person responsible for corrective action: Kristen Crowley Planned completion date for corrective action plan: FFATA report procedure developed September 12, 2023 and LIHEAP submitted November 20, 2023

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Finding 478959 (2023-023)

Material Weakness 2023

Commonwealth of Massachusetts

MA

Subrecipient Monitoring Material Weakness Reporting § 200.303

DEPARTMENT OF PUBLIC HEALTH 2023-023 Immunization Cooperative Agreements, COVID-19 - Immunization Cooperative Agreements - Assistance Listing No. 93.268 Action taken in response to the finding: The Bureau of Infectious Disease and Laboratory Sciences (BIDLS) will put in place starting June 1, 2024 ...

DEPARTMENT OF PUBLIC HEALTH 2023-023 Immunization Cooperative Agreements, COVID-19 - Immunization Cooperative Agreements - Assistance Listing No. 93.268 Action taken in response to the finding: The Bureau of Infectious Disease and Laboratory Sciences (BIDLS) will put in place starting June 1, 2024 a process to review obligations for subawards under Immunization, Assistance Listing No. 93.268 to identify subawards that fall under the rules set forth by Federal Funding Accountability and Transparency Act (FFATA) and report the appropriate obligations to FSRS according to the above-mentioned recommendations. Name of the contact person responsible for corrective action: Cheryl Bernard-Dort, Director of Administration and Finance or her designee. Planned completion date for corrective action plan: The completion date for this correction action plan is September 30, 2024.

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Finding 478949 (2023-021)

Significant Deficiency 2023

Commonwealth of Massachusetts

MA

Questioned Costs Matching / Level of Effort / Earmarking § 200.303

EXECUTIVE OFFICE OF ELDER AFAIRS 2023-021 COVID-19 – Aging Cluster - Assistance Listing No. 93.044, 93.045, 93.053 Action taken in response to the finding: EOEA will review internal processes to ensure that federal requirements are met for the applicable grants in the scope of this audit as well as...

EXECUTIVE OFFICE OF ELDER AFAIRS 2023-021 COVID-19 – Aging Cluster - Assistance Listing No. 93.044, 93.045, 93.053 Action taken in response to the finding: EOEA will review internal processes to ensure that federal requirements are met for the applicable grants in the scope of this audit as well as all Title III grants. Name of the contact person responsible for corrective action: Sheila Tunney, EOEA CFO Planned completion date for corrective action plan: EOEA will complete this corrective action plan action in advance of the FFY25 federal award issuance, expected in October 2024.

View Audit 315520 Questioned Costs: $1

Finding 478944 (2023-020)

Material Weakness 2023

Commonwealth of Massachusetts

MA

Subrecipient Monitoring Material Weakness Reporting § 200.303

EXECUTIVE OFFICE OF ELDER AFAIRS 2023-020 COVID-19 – Aging Cluster - Assistance Listing No. 93.044, 93.045, 93.053 Action taken in response to the finding: EOEA will establish a process to ensure that all required subawards are reported timely and accurately to FSRS no later than the end of the mon...

EXECUTIVE OFFICE OF ELDER AFAIRS 2023-020 COVID-19 – Aging Cluster - Assistance Listing No. 93.044, 93.045, 93.053 Action taken in response to the finding: EOEA will establish a process to ensure that all required subawards are reported timely and accurately to FSRS no later than the end of the month following the month of issuance of each subaward. Name of the contact person responsible for corrective action: Sheila Tunney, EOEA CFO Planned completion date for corrective action plan: EOEA will complete this corrective action plan following issuance of the final FFY24 federal award, which is expected in August 2024.

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Finding 478932 (2023-018)

Significant Deficiency 2023

Commonwealth of Massachusetts

MA

Subrecipient Monitoring Reporting Significant Deficiency § 200.303

DEPARTMENT OF ELEMENTARY AND SECONDARY EDUCATION 2023-018 COVID-19 – Elementary and Secondary School Emergency Relief Fund (ESSER), COVID-19 – American Rescue Plan – Elementary and Secondary School Emergency Relief (ARP ESSER) – Assistance Listing No. 84.425D, 84.425U Action taken in response to the...

DEPARTMENT OF ELEMENTARY AND SECONDARY EDUCATION 2023-018 COVID-19 – Elementary and Secondary School Emergency Relief Fund (ESSER), COVID-19 – American Rescue Plan – Elementary and Secondary School Emergency Relief (ARP ESSER) – Assistance Listing No. 84.425D, 84.425U Action taken in response to the finding: In FY24, internal controls and procedures were implemented to ensure that all required subawards are reported timely to FSRS no later than the end of the month following the month of issuance. Name of the contact person responsible for corrective action: Robert Curtain, Chief Officer for Data and Accountability Planned completion date for corrective action plan: July 1, 2023

View Audit 315520

Finding 478931 (2023-017)

Significant Deficiency 2023

Commonwealth of Massachusetts

MA

Subrecipient Monitoring Reporting Significant Deficiency § 200.303

DEPARTMENT OF ELEMENTARY AND SECONDARY EDUCATION 2023-017 Title I Grants to Local Educational Agencies – Assistance Listing No. 84.010 Action taken in response to the finding: In FY24, internal controls and procedures were implemented to ensure that all required subawards are reported timely to FSR...

DEPARTMENT OF ELEMENTARY AND SECONDARY EDUCATION 2023-017 Title I Grants to Local Educational Agencies – Assistance Listing No. 84.010 Action taken in response to the finding: In FY24, internal controls and procedures were implemented to ensure that all required subawards are reported timely to FSRS no later than the end of the month following the month of issuance. Name of the contact person responsible for corrective action: Robert Curtain, Chief Officer for Data and Accountability Planned completion date for corrective action plan: July 1, 2023

View Audit 315520

Finding 478930 (2023-016)

Significant Deficiency 2023

Commonwealth of Massachusetts

MA

Questioned Costs Eligibility Significant Deficiency § 200.303

EXECUTIVE OFFICE OF HOUSING AND LIVABLE COMMUNITIES 2023-016 COVID-19 – Emergency Rental Assistance Program – Assistance Listing No. 21.023 Action taken in response to the finding: EOHLC has notified Nan McKay of the income ineligibility. Nan McKay and EOHLC agreed with the finding. In February 202...

EXECUTIVE OFFICE OF HOUSING AND LIVABLE COMMUNITIES 2023-016 COVID-19 – Emergency Rental Assistance Program – Assistance Listing No. 21.023 Action taken in response to the finding: EOHLC has notified Nan McKay of the income ineligibility. Nan McKay and EOHLC agreed with the finding. In February 2024 Nan McKay sent payment recoupment letters to the landlord and the utility company to attempt to recoup the funds paid on behalf of an ineligible household. EOHLC met with Nan McKay leadership staff on 04/18/2024 to review income eligibility steps for emergency rental assistance programs. Name of the contact person responsible for corrective action: Amy Mullen Planned completion date for corrective action plan: April 18, 2024

View Audit 315520 Questioned Costs: $1

Finding 478926 (2023-014)

Significant Deficiency 2023

Commonwealth of Massachusetts

MA

Matching / Level of Effort / Earmarking § 200.303

EXECUTIVE OFFICE OF LABOR AND WORKFORCE DEVELOPMENT 2023-014 WIOA Cluster– Assistance Listing No. 17.258, 17.259, 17.278 Action taken in response to the finding: In FY 2023, a Corrective Action Plan (CAP) was drafted and implemented to address prior audit findings related to Federal Financial Repor...

EXECUTIVE OFFICE OF LABOR AND WORKFORCE DEVELOPMENT 2023-014 WIOA Cluster– Assistance Listing No. 17.258, 17.259, 17.278 Action taken in response to the finding: In FY 2023, a Corrective Action Plan (CAP) was drafted and implemented to address prior audit findings related to Federal Financial Reports (FFR). Prior audit findings were a result of extraordinary turnover within EOLWD’s Finance Office, which resulted in having no staff who were fully dedicated to filing Federal Financial Reports (FFR). The CAP included: (1) filling vacant positions; (2) training new staff in the federal reporting process and requirements; (3) automating business practices; and (4) drafting and implementing an FFR Standard Operating Procedure (SOP). The first three corrective actions identified in the CAP were implemented in FY 2023. The SOP for Federal Financial Reporting was developed in FY 2023 and implemented in FY 2024. The necessary controls for ensuring ETA 9130 reports reflect earmarking requirements and are accurately supported by documentation that support reported balances were implemented with the implementation of the FFR SOP in FY 2024. Name of the contact person responsible for corrective action: Malachy Rice, Director of Federal Grants Management Planned completion date for corrective action plan: October 1, 2023

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Finding 478923 (2023-013)

Material Weakness 2023

Commonwealth of Massachusetts

MA

Subrecipient Monitoring Material Weakness Reporting § 200.303

EXECUTIVE OFFICE OF LABOR AND WORKFORCE DEVELOPMENT 2023-013 WIOA Cluster– Assistance Listing No. 17.258, 17.259, 17.278 Action taken in response to the finding: EOLWD Finance is drafting a Standard Operating Procedure (SOP) that includes the necessary controls to ensure subawards subject to Federa...

EXECUTIVE OFFICE OF LABOR AND WORKFORCE DEVELOPMENT 2023-013 WIOA Cluster– Assistance Listing No. 17.258, 17.259, 17.278 Action taken in response to the finding: EOLWD Finance is drafting a Standard Operating Procedure (SOP) that includes the necessary controls to ensure subawards subject to Federal Funding Accountability and Transparency Act (FFATA) reporting are reviewed, approved, and submitted timely to FSRS. EOLWD Finance will also conduct training for staff. Name of the contact person responsible for corrective action: Malachy Rice, Director of Federal Grants Management Planned completion date for corrective action plan: July 1, 2024

View Audit 315520

Finding 478913 (2023-011)

Significant Deficiency 2023

Commonwealth of Massachusetts

MA

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

EXECUTIVE OFFICE OF LABOR AND WORKFORCE DEVELOPMENT 2023-011 WIOA Cluster, Employment Service Cluster – Assistance Listing No. 17.258, 17.259, 17.278, 17.207, 17.801 Action taken in response to the finding: In FY 2023, a Corrective Action Plan (CAP) was drafted and implemented to address prior aud...

EXECUTIVE OFFICE OF LABOR AND WORKFORCE DEVELOPMENT 2023-011 WIOA Cluster, Employment Service Cluster – Assistance Listing No. 17.258, 17.259, 17.278, 17.207, 17.801 Action taken in response to the finding: In FY 2023, a Corrective Action Plan (CAP) was drafted and implemented to address prior audit findings related to Federal Financial Reports (FFR). Prior audit findings were a result of extraordinary turnover within EOLWD’s Finance Office, which resulted in having no staff who were fully dedicated to filing Federal Financial Reports (FFR). The CAP included: (1) filling vacant positions; (2) training new staff in the federal reporting process and requirements; (3) automating business practices; and (4) drafting and implementing an FFR Standard Operating Procedure (SOP). The first three corrective actions identified in the CAP were implemented throughout FY 2023. The SOP for Federal Financial Reporting was developed throughout FY 2023 and implemented in FY 2024. The necessary controls for ensuring that ETA 9130 reports reflect earmarking requirements and are accurately supported by documentation that support reported balances were implemented with the implementation of the FFR SOP in FY 2024. In addition, the automated business practices cited in the CAP were refined throughout FY 2023 to ensure data in supporting documentation correlates to what is reported on an ETA 9130 report. Name of the contact person responsible for corrective action: Malachy Rice, Director of Federal Grants Management Planned completion date for corrective action plan: October 1, 2023

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Finding 478904 (2023-008)

Material Weakness 2023

Commonwealth of Massachusetts

MA

Matching / Level of Effort / Earmarking § 200.303

EXECUTIVE OFFICE OF LABOR AND WORKFORCE DEVELOPMENT 2023-008 Employment Service Cluster – Assistance Listing No. 17.207, 17.801 Action taken in response to the finding: The MassHire Department of Career Services (MDCS) budgets WIOA Adult, Youth, and Dislocated Worker funds in accordance with the De...

EXECUTIVE OFFICE OF LABOR AND WORKFORCE DEVELOPMENT 2023-008 Employment Service Cluster – Assistance Listing No. 17.207, 17.801 Action taken in response to the finding: The MassHire Department of Career Services (MDCS) budgets WIOA Adult, Youth, and Dislocated Worker funds in accordance with the Department of Labor’s (DOL) earmarking requirements. This finding is a result of reporting deficiencies cited in the FY 2022 audit. The FY 2022 audit findings were a result of extraordinary turnover within EOLWD’s Finance Office, which resulted in having no staff fully dedicated to filing Federal Financial Reports (FFR). In FY 2023, a Corrective Action Plan (CAP) was drafted and implemented by new staff to address the FY 2022 findings related to reporting. The CAP included developing a Standard Operating Procedure (SOP) for Federal Financial Reports, which was done throughout FY 2023. The SOP was implemented in September of 2023, and should resolve the underlying reporting issues that resulted in this finding. Name of the contact person responsible for corrective action: Malachy Rice, Director of Federal Grants Management Planned completion date for corrective action plan: October 1, 2023

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Finding 478902 (2023-007)

Material Weakness 2023

Commonwealth of Massachusetts

MA

Subrecipient Monitoring Material Weakness Reporting § 200.303

EXECUTIVE OFFICE OF LABOR AND WORKFORCE DEVELOPMENT 2023-007 Employment Service Cluster – Assistance Listing No. 17.207, 17.801 Action taken in response to the finding: EOLWD Finance is drafting a Standard Operating Procedure (SOP) that includes the necessary controls to ensure subawards subject to...

EXECUTIVE OFFICE OF LABOR AND WORKFORCE DEVELOPMENT 2023-007 Employment Service Cluster – Assistance Listing No. 17.207, 17.801 Action taken in response to the finding: EOLWD Finance is drafting a Standard Operating Procedure (SOP) that includes the necessary controls to ensure subawards subject to Federal Funding Accountability and Transparency Act (FFATA) reporting are reviewed, approved, and submitted timely to FSRS. EOLWD Finance will also conduct training for staff. Name of the contact person responsible for corrective action: Malachy Rice, Director of Federal Grants Management Planned completion date for corrective action plan: July 1, 2024

View Audit 315520

Finding 478900 (2023-006)

Significant Deficiency 2023

Commonwealth of Massachusetts

MA

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

EXECUTIVE OFFICE OF LABOR AND WORKFORCE DEVELOPMENT 2023-006 Unemployment Insurance, COVID-19 – Unemployment Insurance – Assistance Listing No. 17.225 Action taken in response to the finding: While Massachusetts BAM unit (MBAM) had been making progress in meeting timeliness deadlines, it began suff...

EXECUTIVE OFFICE OF LABOR AND WORKFORCE DEVELOPMENT 2023-006 Unemployment Insurance, COVID-19 – Unemployment Insurance – Assistance Listing No. 17.225 Action taken in response to the finding: While Massachusetts BAM unit (MBAM) had been making progress in meeting timeliness deadlines, it began suffering setbacks in or around July 2022. MBAM was experiencing difficulties with the SUN server not accepting data and the system adding additional edits that should not have existed. Consistent work with the USDOL Hotline resolved the issues and/or created workarounds. Ultimately the SUN server failed after degrading for a year. The server was unavailable for use sporadically through the year and for four full separate weeks in May, June, and July 2023. Not only were staff unable to submit DCI data but it took additional organizational work of handling unentered cases, additional time to work with the Hotline and test fixes, while needing additional steps to implement work arounds for items that could not be fixed. MBAM continues to utilize work arounds for BAM data entry. Since SWA’s SUN server has become functional again, MBAM has been improving timeliness. MBAM also continues to work with ETA Hotline to report and resolve defects within the SUN system. MBAM management also developed an organizational strategy for the unit to provide its investigators with weekly updates on what cases should be worked on based on batch due dates. A case status report has been developed to provide unit supervisors with the status of each case assigned, expected date of completion, work completed to date on case, and cause for delay. Additionally, MBAM management has developed in-house reporting to track individual investigators. The reports track each investigator, telling management the number of cases closed each week and tracking the aging of Investigations. The manager uses these reports to identify cases to be prioritized based on aging and to quickly identify if a specific investigator is lagging in their case closure. Based on performance, the Manager has coaching sessions with individual investigators a minimum of every two weeks where work prioritization, organization, and any other additional necessary issues are reviewed and discussed. A meeting with all investigators is held weekly to provide education, discuss change to policy/procedure, and provide an open forum for BAM program implementation questions. Monitoring also occurs at the end of each quarter. Based on outcome, discussion of weaknesses and development of new levels of support are discussed and implemented. Name of the contact person responsible for corrective action: Susan Saulnier, Director of UI Performs Planned completion date for corrective action plan: September 30, 2024

View Audit 315520

Finding 478896 (2023-003)

Significant Deficiency 2023

Commonwealth of Massachusetts

MA

Allowable Costs / Cost Principles Subrecipient Monitoring Period of Performance § 200.303 § 200.308 § 200.309 § 200.403

DEPARTMENT OF ELEMENTARY PUBLIC HEALTH 2023-003 WIC Special Supplemental Nutrition Program for Women, Infants, and Children – Assistance Listing No. 10.557 Action taken in response to the finding: The Department and the WIC Nutrition Program will have all fiscal staff review the Operating Procedur...

DEPARTMENT OF ELEMENTARY PUBLIC HEALTH 2023-003 WIC Special Supplemental Nutrition Program for Women, Infants, and Children – Assistance Listing No. 10.557 Action taken in response to the finding: The Department and the WIC Nutrition Program will have all fiscal staff review the Operating Procedures to refresh themselves of the procedures surrounding Purchase Orders and Expenditures. (Excerpt from Operating Procedures) All Staff should complete a “Request for Purchase” form with all pertinent information such as quotes, renewal notices, conference registration, etc. and submit it to supervisor or Director for initial approval. Once the request is approved, the form is given to a fiscal staff to start the process of encumbering funds through MMARS and preparing a PURCHASE ORDER. At the very least, staff will identify that the service performed is correct and that funds are available and already encumbered to process the payment. All federal payments require a Program Code, and so the fiscal staff need to be sure the appropriate one is entered based on the dates of service or the date of the Purchase Order. Once all documents have been uploaded and submitted, then either the WIC State Director or the Fiscal Director will need to electronically approve the transaction in the Tracking System. The Fiscal Director and the State Director will more thoroughly review the assignment of Program Codes as they pertain to the Federal grant award dates before approving payment documents. This review will involve verifying: • The type of service • Date of service or receipt of item • Date of Purchase Order • Program Codes Name of the contact person responsible for corrective action: Beverly Andrew and Rachel Colchamiro Planned completion date for corrective action plan: April 30, 2024

View Audit 315520

Finding 478895 (2023-001)

Significant Deficiency 2023

National Urban League, Inc.

NY

Matching / Level of Effort / Earmarking Subrecipient Monitoring

Audit Finding Reference: 2023-001 Planned Corrective Action: This finding represents a typo and is attributable to a human error. The error was corrected immediately after the auditor brought it to our attention. The League has strengthened its internal controls over timely submission of subaward...

Audit Finding Reference: 2023-001 Planned Corrective Action: This finding represents a typo and is attributable to a human error. The error was corrected immediately after the auditor brought it to our attention. The League has strengthened its internal controls over timely submission of subaward data in FFATA (Federal Funding Accountability and Transparency Act) reports. NUL Legal Department used to be responsible for generating FFATA reports, as they are authorized with review of new grant agreements as well as related contracts/subrecipients agreements submitted for approval. In prior years some reports were not submitted in time because of continuous turnover in the department in 2021-22. The regular workflow was sometimes interrupted, and new appointees had to catch up following their priority lists. Eventually, at the end of February 2023, the function was moved to the Finance department and a specific position designated for completing FFATA reports. All pending FFATA reports have been completed immediately after that. We keep submitting FFATA reports for new grants as soon as subaward amounts are finalized. In view of the above error, we will establish an additional layer of control over FFATA report accuracy, so the reports are thoroughly reviewed, once entered into the system, and approved by either VP/Director, Budget & Grants or CFO. Overall, we believe the strength of our internal control ensures a timely and complete submission of FFATA reports. Name and Title of Contact Persons: Sidney Evans, Chief Financial Officer; Lisa Davis, Vice-President for Financial Operations; Triva John, Vice-President for Budget & Grants, Konstantin Yurashkevich, Director for Budget & Grants Name of Official: Sidney Evans Title: Chief Financial Officer Date: 05/30/2024

View Audit 315517

Finding 478877 (2023-001)

Significant Deficiency 2023

Housing Authority of the City of Seattle

WA

Questioned Costs Allowable Costs / Cost Principles Reporting § 200.303 § 200.430

Moving to Work Demonstration Program – Assistance Listing No. 14.881 Recommendation: We recommend the Authority implements an adequate review process to ensure costs charged to the grant are reasonable, accurate, and properly allocated. We recommend the Authority perform and document this review qua...

Moving to Work Demonstration Program – Assistance Listing No. 14.881 Recommendation: We recommend the Authority implements an adequate review process to ensure costs charged to the grant are reasonable, accurate, and properly allocated. We recommend the Authority perform and document this review quarterly at minimum. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Budget division will continue to send an annual summary at the beginning of the fiscal year for all employees who have split funding for federal and non-federal funds. During the MSS process there will be a coding added if the payroll certification is required by a comment in the system. Monthly the Budget and Payroll Division will have a monthly review of all MSS employee changes during the month to evaluate the payroll certifications for the changes are accurate. Name(s) of the contact person(s) responsible for corrective action: Jared Cummer, CFO and Olivia Hunsinger, Controller Planned completion date for corrective action plan: Progress has been made and full completion is expected 06/30/2024.

View Audit 315516 Questioned Costs: $1

Finding 478873 (2023-003)

Significant Deficiency 2023

Harvest Against Hunger

WA

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

Federal Agency: U.S. Department of the Treasury Federal Program Name: Coronavirus State and Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: K3422 & K3724 - 2021 Pass-Through Agency: Washington State Department of Agriculture Pass-Through Number(s...

Federal Agency: U.S. Department of the Treasury Federal Program Name: Coronavirus State and Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: K3422 & K3724 - 2021 Pass-Through Agency: Washington State Department of Agriculture Pass-Through Number(s): E128H7X5KWX5 Award Period: 7/1/21-6/30/23; 11/19/21-6/30/23 Type of Finding: • Significant Deficiency in Internal Control over Compliance Section III – Findings and Questioned Costs – Major Federal Programs Condition: Harvest Against Hunger allocates costs to the program based on the available funding and number of employees working on the project. They do not use the timesheet to record the operating hours for the program, but rather management makes a judgmental decision based on their understanding of program operations during the payroll period. Questioned costs: None Cause: The Organization lacks documentation supporting the allocation determination used to determine payroll amounts charged to the major program. Views of responsible officials: There is no disagreement with the finding. Criteria or specific requirement: Per §200.303, non-Federal entities must "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 statues, regulations, and the terms and conditions of the Federal awards." Additionally, non-Federal entities must charge salaries and wages "based on records that accurately reflect the work performed" (§200.430(i)). Effect: Without proper documentation of the payroll allocation used, the Organization could charge time to a federal program that does not reflect true expenditures incurred by that program. Repeat Finding: This is not a repeated finding. Recommendation: The Organization should implement policies for consistently determining time allocation to the federal program, and ensure internal controls help to ensure this allocation is correct and consistently documented

View Audit 315495

Finding 478779 (2023-010)

Significant Deficiency 2023

Alameda Health System, A Public Hospital Authority

CA

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

Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. The Health System will review, modify, and implement policies and procedures over the program to ensure that required reports are prepared and reviewed by separate individuals. Documentation will be mai...

Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. The Health System will review, modify, and implement policies and procedures over the program to ensure that required reports are prepared and reviewed by separate individuals. Documentation will be maintained by the program to evidence preparation and review processes and timely filing of required reports.

View Audit 315421

Corrective Action Plans

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