Corrective Action Plans

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

Finding 386473 (2023-014)

Significant Deficiency 2023

State of Arkansas

AR

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

Views of Responsible Officials and Planned Corrective Action: The agency agrees with the finding. We found an error in the formula of the worksheet used for the preparation and submission of the quarterly expenditure report. The error resulted in not properly reporting the CARES Act reimbursement. ...

Views of Responsible Officials and Planned Corrective Action: The agency agrees with the finding. We found an error in the formula of the worksheet used for the preparation and submission of the quarterly expenditure report. The error resulted in not properly reporting the CARES Act reimbursement. The agency will report to the federal Child Support Services program to account for the over-reimbursement of federal share of expenditures. The error in the specific worksheet that resulted in the over-reporting of allowed expenditures has been corrected. Further, the agency will perform a review of all other subsidiary reports and worksheets that are used in preparation of the federal expenditure reports. This will be done in order to ensure that the federal reports are prepared accurately. Additionally, procedures for review of report preparation will be enhanced to further strengthen internal controls. Anticipated Completion Date: Correction of the specific worksheet deficiency has been completed. Corrections to the federal reports to account for the over-reimbursement will be completed in the next federal reporting cycle due on May 15, 2024. Review of all other subsidiary reports and worksheets and the enhanced report preparation review is part of an ongoing project to be completed no later than August 15, 2024. Contact Person: Name: Robert Hallmark Title: Agency Controller II Agency: Department of Finance and Administration-Office of Child Support Enforcement Address: 322 S Main St, Suite 100 City, State, Zip: Little Rock, AR 72201 Phone Number: 501-682-6306 Email Address: Robert.hallmark@ocse.arkansas.gov

View Audit 298801 Questioned Costs: $1

Finding 386470 (2023-013)

Material Weakness 2023

State of Arkansas

AR

Matching / Level of Effort / Earmarking Subrecipient Monitoring Material Weakness § 200.302 § 200.303

Views of Responsible Officials and Planned Corrective Action: Arkansas Department of Education recognizes this finding. ADE Finance understands the importance of supporting documentation for non-LEAs and has implemented a plan for FY23 communications. Furthermore, ADE Finance conducted follow-up com...

Views of Responsible Officials and Planned Corrective Action: Arkansas Department of Education recognizes this finding. ADE Finance understands the importance of supporting documentation for non-LEAs and has implemented a plan for FY23 communications. Furthermore, ADE Finance conducted follow-up communication with the U.S. Department of Education (ED) on March 1, 2024. It was concluded that FTE position data for non-LEAs were optional for Years 1 and 2 Annual Performance Reports per the ESSER Form Review Webinar Guidance. ADE was further instructed to omit non-LEA information from the template should it be unreasonable to provide for the FY22 reporting year in question. ADE will ensure non-LEA entities provide the requested 5.a – Full-Time Equivalent (FTE) Compliance Supplement information for supporting documentation with FY23 and subsequent Reporting Periods. Anticipated Completion Date: May 2024. ADE Finance is coordinating communication with non-Local Educational Agencies (non-LEAs) in effort to revise the data for FY22, however will omit the related data per U.S. Department of Education (ED) guidance provided on March 1, 2024, should non-LEAs be unable to provide quality data. Contact Person: Name: Amy Thomas Title: Accounting Operations Manager Agency: Arkansas Department of Education Address: Four Capitol Mall, Room 204 City, State, Zip: Little Rock, AR, 72201 Phone Number: 501-682-3636 Email Address: Amy.Thomas@ade.arkansas.gov

View Audit 298801

Finding 386469 (2023-012)

Material Weakness 2023

State of Arkansas

AR

Questioned Costs Subrecipient Monitoring Matching / Level of Effort / Earmarking § 200.302

Views of Responsible Officials and Planned Corrective Action: Arkansas Department of Education recognizes this finding. The ADE Finance unit utilized data extracted from the statewide Local Educational Agencies (LEAs) system, APSCN, for the majority of parameters reported. However, APSCN does not h...

Views of Responsible Officials and Planned Corrective Action: Arkansas Department of Education recognizes this finding. The ADE Finance unit utilized data extracted from the statewide Local Educational Agencies (LEAs) system, APSCN, for the majority of parameters reported. However, APSCN does not have the ability to cross-reference financial expenses with Local Educational Agency’s (LEAs) personnel data, which led to the creation of the survey. LEAs were expected to report data during a subsequent school year post COVID-19 Pandemic. ADE gathered state total expenses for requested categories from the system compiled with the requested breakdowns by position type obtained in the manual survey. The two data sets did not align, thus seen in Questioned Costs which reflects the difference between the two datasets. LEA actual expenses, associated drawdowns, and disbursements were not affected by the amounts reported in the annual ESSER data. ADE Finance is currently working with APSCN personnel to explore options for assembling data without manual input from LEAs. When implemented, discrepancies in the state data reported to federal systems and LEAs data should not exist. ADE has the goal of utilizing this method for FY23 reporting in May 2024. Anticipated Completion Date: ADE Finance will revise its uploaded FY22 ESSER data template during the allowable period of July 29, 2024, through August 15, 2024. Contact Person: Name: Amy Thomas Title: Accounting Operations Manager Agency: Arkansas Department of Education Address: Four Capitol Mall, Room 204 City, State, Zip: Little Rock, AR, 72201 Phone Number: 501-682-3636 Email Address: Amy.Thomas@ade.arkansas.gov

View Audit 298801 Questioned Costs: $1

Finding 386468 (2023-011)

Material Weakness 2023

State of Arkansas

AR

Questioned Costs Subrecipient Monitoring Matching / Level of Effort / Earmarking § 200.302

Views of Responsible Officials and Planned Corrective Action: Arkansas Department of Education recognizes this finding. ADE Finance completed the named report which contained a subtotal error that overstated the totals when provided to Legislative Auditors. However, logic verifications built into t...

Views of Responsible Officials and Planned Corrective Action: Arkansas Department of Education recognizes this finding. ADE Finance completed the named report which contained a subtotal error that overstated the totals when provided to Legislative Auditors. However, logic verifications built into the Federal System disallowed the items mentioned to be submitted. Therefore, the data reflected in Federal reporting for Arkansas was not overstated nor actual expenses and associated drawdowns completed erroneously. This information was confirmed with the U.S. Department of Education (ED) on February 21, 2024. ADE Finance assures that revisions to the FY23 ESSER data template will be made and uploaded to the Federal Reporting System during the allowable period of July 29, 2024, and August 15, 2024. Anticipated Completion Date: Data was effectively corrected at the time of reporting within the Federal System. ADE Finance will revise its uploaded FY23 ESSER data template during the allowable period of July 29, 2024, through August 15, 2024. Contact Person: Name: Amy Thomas Title: Accounting Operations Manager Agency: Arkansas Department of Education Address: Four Capitol Mall, Room 204 City, State, Zip: Little Rock, AR, 72201 Phone Number: 501-682-3636 Email Address: Amy.Thomas@ade.arkansas.gov

View Audit 298801 Questioned Costs: $1

Finding 386459 (2023-009)

Significant Deficiency 2023

State of Arkansas

AR

Student Financial Aid Subrecipient Monitoring Special Tests & Provisions

Views of Responsible Officials and Planned Corrective Action: Management understands the recommendations provided in the finding. We are planning on updating our 2021 Risk Assessment with our campus community in the near future. In accordance with ALA's recommendation, we will focus on GLBA 16 CFR...

Views of Responsible Officials and Planned Corrective Action: Management understands the recommendations provided in the finding. We are planning on updating our 2021 Risk Assessment with our campus community in the near future. In accordance with ALA's recommendation, we will focus on GLBA 16 CFR 314 elements and financial aid data. As with our 2021 Risk Assessment, our plan will be reviewed and accepted by our Chancellor. We intend to have the Risk Assessment updated and reviewed by June 30, 2024. We will also coordinate the risks identified with the extensive list of controls and policies that currently protect student’s financial aid information. These include: Acceptable Use Policy_V7_3.pdf Antivirus and Malware Policy_V2_1.pdf Cloud Services Policy_V1_2.pdf Confluence Screenshots Of Contact Information For Critical Systems (1).pdf Data Classification Policy_V1_2.pdf Data Encryption Policy_V7_1.pdf Data Management Use Protection Policy_V7_2.pdf Data Protection Policy_V7_2 Data Protection Policy_V7_2.pdf Disaster Recovery Business Continuity System Recovery Prioritization List_V1_2.pdf Disaster Recovery Procedure_V1_5.pdf Drive Data Deletion Policy_V7_2.pdf E-Learning Policies_V7_1.pdf Email and Digital Communication Policy_V8_2.pdf Email and Digital Communication Policy_V8_2.pdf Employee Data Deletion Policy_V7_2.pdf Encryption of Sensitive Data on Transmission Policy_V7_2.pdf Faculty Senate Legislation Reference_V6.1.pdf Firewall Blacklist and Whitelist Policy_V7_2.pdf Firewall Management Procedure_V7_2.pdf GLBA Risk assessment.docx Incident Response and Forensic Analysis Procedures_V7_5.pdf IT Employee Departure Procedures_V7_2.pdf IT Security Awareness and Competencies Policy_V1_5.pdf IT Services System Administration Privileged Access Management Policy_V7_2.pdf IT System Backup Procedures_V7_2.pdf IT System Patching Process_V7_3.pdf Lab / Classroom Administrative Rights Exception Request_V6_1.pdf Local Firewall Procedures for Workstations and Mobile Devices_V7_2.pdf Log Review Policy_V2_1.pdf Mobile Device Security - Remote Email Destruction Process_V1_1.pdf Mobile Device Security Policy_V2_1.pdf Multi-factor Authentication - Information Technology Services - UA Little Rock.pdf Network Patching Process_V1_1.pdf PCI Compliance _ Training Policy_V7_2.pdf Physical Security Policy_V1_3.pdf Retention of Records Policies_V7_2.pdf Security and Incident Response Team Policy_V1_3.pdf Security and IT System Access Policy_V1_2.pdf Student Account Deletion Policy_V7_2.pdf System Log Requirements_V8_2.pdf UALR Change Management Policy 2.2.pdf Vendor Remote Access Policy_V1_1.pdf Vulnerability Scan Policy_V7_2.pdf Wireless Network Guest Security Policy_V1_1.pdf Wireless Security Policy_V1_2.pdf Workstation Administrative Rights Exception Request_V6_1.pdf Anticipated Completion Date: June 30, 2024 Contact Person: Name: Gerald J. Ganz, Jr. Title: Vice Chancellor for Finance & Administration Agency: University of Arkansas at Little Rock Address: 2801 S. University Avenue City, State, Zip: Little Rock, AR, 72204 Phone Number: 501-916-5622 Email Address: GJGanz@ualr.edu

View Audit 298801

Finding 386455 (2023-005)

Significant Deficiency 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 controls the ALA staff recommended. 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 386454 (2023-004)

Material Weakness 2023

State of Arkansas

AR

Procurement, Suspension & Debarment Subrecipient Monitoring Matching / Level of Effort / Earmarking § 200.214 § 200.303

Views of Responsible Officials and Planned Corrective Action: Department of Human Services Response DHS concurs with the finding. The SNP database has been updated to reflect that a National Disqualified List (NDL) search was run on the 15 providers that were reviewed. The Health and Nutrition Uni...

Views of Responsible Officials and Planned Corrective Action: Department of Human Services Response DHS concurs with the finding. The SNP database has been updated to reflect that a National Disqualified List (NDL) search was run on the 15 providers that were reviewed. The Health and Nutrition Unit for the Office of Early Childhood conducted a staff training on the written application procedure with an emphasis on performing and documenting NDL searches prior to approval of the application. (Note: Effective August 1, 2023, DHS DCCECE has transitioned to Arkansas Department of Education.) Arkansas Department of Education Response Arkansas Department of Education’s Office of Early Childhood, Health and Nutrition unit conducted training December 2023 and continues to maintain staff training on the written application procedure to ensure providers are reviewed against the National Disqualified List (NDL) database and prior to approval. Anticipated Completion Date: Department of Human Services Response Complete Arkansas Department of Education Response Continuous Contact Person: Name: Pamela Burton Title: Director, Health and Nutrition Unit, Division of Elementary and Secondary Education Agency: Arkansas Department of Education Address: 700 Main Street, Room 1216 City, State, Zip: Little Rock, AR, 72203 Phone Number: 501-320-8978 Email Address: Pamela.Burton@ade.arkansas.gov

View Audit 298801

Finding 386449 (2023-001)

Significant Deficiency 2023

John F. Kennedy Center for Performing Arts

DC

Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking § 200.303 § 200.308 § 200.403

Contacts: Alex Antkowiak, David Kilpatrick, and Katherine Robinson Titles: VP Accounting and Senior Director, Education Programs & Productions, and Payroll Manager, respectively Anticipated Completion Date: September 2024 Corrective Action: The Center is committed to ensuring the appropriate documen...

Contacts: Alex Antkowiak, David Kilpatrick, and Katherine Robinson Titles: VP Accounting and Senior Director, Education Programs & Productions, and Payroll Manager, respectively Anticipated Completion Date: September 2024 Corrective Action: The Center is committed to ensuring the appropriate documentation is in place to adhere to federal regulations regarding activities allowed or unallowed and allowable costs. In response to the audit finding, the Center is taking the following corrective actions to address the audit recommendations: • Accounting will convene meetings with Production and Operations Managers to communicate the Fiscal Year 2023 Federal Award Findings, study and strengthen internal controls in place, review the general criteria within 2 CFR Section 200.403 for manager awareness, and reinforce the importance of accuracy and timeliness of pay rates. • Production and Operations Managers will enact recommendations from Accounting Personnel to strengthen internal controls, proactively communicate with Unions throughout the year and prior to year-end to stay informed of any changes to rates established in Collective Bargaining Agreements and apply changes in pay rates prospectively from date of notice and retrospectively when required. • The Payroll Department, in collaboration with Accounting, will establish a schedule to sample support from managers for compliance with transparency initiatives. Status as of February 2024: The Theater for Young Audience Touring Production and Operations Manager in charge of payroll processing has updated processes to create an audit trail for pay rate calculation, update payroll submission form to include a PDF copy of the audit trail for Payroll Department’s inspection.

View Audit 298795

Finding 386440 (2023-004)

Significant Deficiency 2023

T.a. Lawson State Community College

AL

Subrecipient Monitoring Reporting Significant Deficiency § 200.328

Management’s Response: The College will strengthen its policies and procedures to ensure documentation of review and approvals for reporting to ensure reporting compliance. Anticipated Completion Date: February 28, 2024

View Audit 298782

Finding 386431 (2023-003)

Significant Deficiency 2023

Elkhart and St. Joseph Counties Head Start Consortium

IN

Internal Control / Segregation of Duties Reporting Significant Deficiency § 200.303

Finding 2023-003 – Head Start Cluster – Reporting Contact Person Responsible for Corrective Action: Brenda Overton Contact Phone Number: 574.393.5866 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: We will ensure all required federal reports h...

Finding 2023-003 – Head Start Cluster – Reporting Contact Person Responsible for Corrective Action: Brenda Overton Contact Phone Number: 574.393.5866 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: We will ensure all required federal reports have a documented, formal review of the reports before they are submitted to ensure the information submitted is accurate Anticipated Completion Date: April 2024

View Audit 298777

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