Corrective Action Plans

Finding 36828 (2022-004)

Material Weakness 2022

NJ

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

The University agrees with the finding and to ensure compliance with the federal requirements that disbursement data be reported within the 15-calendar window, the Financial Aid Director is in the process of developing a new Policy that will address the review of rejected or denied Pell Disbursement...

The University agrees with the finding and to ensure compliance with the federal requirements that disbursement data be reported within the 15-calendar window, the Financial Aid Director is in the process of developing a new Policy that will address the review of rejected or denied Pell Disbursement. Any Pell Award that is disbursed but rejected or denied on COD will be cancelled off student accounts while the Financial Aid Office resolves the reason why a Pell Grant disbursement was rejected or denied. Some situations cannot be resolved within the 15-day window. It is therefore prudent for the University to remove the Pell disbursement and resolve the issue before re-disbursing the award. The new Policy will also include a pre-disbursement authorization process to confirm that the disbursement once requested will be accepted on COD, therefore reducing the risk of the University disbursing a Pell Award that will be rejected on COD. The University has also contracted with a PeopleSoft consultant to address the manual processes and develop a more automated business process.

View Audit 35370

Finding 36826 (2022-001)

Significant Deficiency 2022

Kingsbridge Heights Community Center, Inc.

NY

Questioned Costs Subrecipient Monitoring Cash Management § 200.303

Finding: 2022-001 ? Reporting Program: AL# 93.600 ? Head Start Sponsor Award Number: CT9259071 Sponsor Agency: US Department of Health and Human Services Corrective Action Plan: KHCC strives to meet all reporting requirements through-out the year. As such, KHCC will put a system in place to ensu...

Finding: 2022-001 ? Reporting Program: AL# 93.600 ? Head Start Sponsor Award Number: CT9259071 Sponsor Agency: US Department of Health and Human Services Corrective Action Plan: KHCC strives to meet all reporting requirements through-out the year. As such, KHCC will put a system in place to ensure timely and accurate submission of all required reports. The vouchers are prepared by a staff accountant based on books and records of KHCC. The senior manager will review the vouchers for completeness and accuracy before submission. Further, budget vs actual analysis will be reviewed on a monthly basis by the Program Director or Chief Program Officer, and the Chief Executive Officer.

View Audit 32322

Finding 36823 (2022-001)

Material Weakness 2022

Shiloh Neighborhood Development Corporation

OH

Subrecipient Monitoring Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.326

Contact Person: Leslie Sutera, Business Manager/Clerk Expected Completion Date of Corrective Action Plan: This corrective action plan will be completed by the end fiscal year, June 30, 2023 CORRECTIVE ACTION PLAN FINDING 2022-001: Prevailing Wage Rate Internal Control and Compliance Response: I...

Contact Person: Leslie Sutera, Business Manager/Clerk Expected Completion Date of Corrective Action Plan: This corrective action plan will be completed by the end fiscal year, June 30, 2023 CORRECTIVE ACTION PLAN FINDING 2022-001: Prevailing Wage Rate Internal Control and Compliance Response: Include a clause requiring prevailing wage and weekly certified payrolls in any federal funded construction contract. Request weekly certified payrolls to correspond with invoices at the time they are received. STATUS OF PRIOR AUDIT FINDINGS FINDING 2021-001: Unrecorded Accounts Payable Response: Implemented

View Audit 32320

Finding 36822 (2022-005)

Significant Deficiency 2022

Milford Housing Authority

NE

Allowable Costs / Cost Principles Internal Control / Segregation of Duties Significant Deficiency § 200.303

Corrective Action Planned: The Milford Housing Authority understands the need to review and approve disbursements and has implemented procedures to provide for the review and approval of all invoices at a detailed level which will be evidenced by an initial or other documentation. Anticipated Compl...

Corrective Action Planned: The Milford Housing Authority understands the need to review and approve disbursements and has implemented procedures to provide for the review and approval of all invoices at a detailed level which will be evidenced by an initial or other documentation. Anticipated Completion Date: December 31, 2023. Responsible: Management and Board of Commissioners.

View Audit 24037

Finding 36821 (2022-004)

Significant Deficiency 2022

Milford Housing Authority

NE

Internal Control / Segregation of Duties Special Tests & Provisions Reporting

Corrective Action Planned: The Milford Housing Authority will evaluate its system of internal control over special tests and provisions to determine how the Authority can better monitor and comply with reserve requirements of its award agreement. Anticipated Completion Date: December 31, 2023. Res...

Corrective Action Planned: The Milford Housing Authority will evaluate its system of internal control over special tests and provisions to determine how the Authority can better monitor and comply with reserve requirements of its award agreement. Anticipated Completion Date: December 31, 2023. Responsible: Management and Board of Commissioners.

View Audit 24037

Finding 36819 (2022-002)

Material Weakness 2022

Darke County Educational Service Center

OH

Questioned Costs Allowable Costs / Cost Principles Period of Performance § 200.303 § 200.430

The Darke County Educational Service Center?s management will continue to review payroll calculations and believes this was an isolated error.

View Audit 26899

Finding 36817 (2022-001)

Material Weakness 2022

Herron High School, Inc.

IN

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

Charter Schools ? AL #84.282 Education Stabilization Fund ? AL #84.425C, 84.425D & 84.425U 2022-001 Risk Assessment Process Related to Compliance Requirements (Repeat Finding 2021-001) Material Weakness Recommendation: The Auditor recommended additional resources be allocated to federal award compli...

Charter Schools ? AL #84.282 Education Stabilization Fund ? AL #84.425C, 84.425D & 84.425U 2022-001 Risk Assessment Process Related to Compliance Requirements (Repeat Finding 2021-001) Material Weakness Recommendation: The Auditor recommended additional resources be allocated to federal award compliance to review federal award provisions and requirements, evaluate risks of noncompliance, and respond to such risks through internal controls. The process should include methods to identify and communicate changes to federal award requirements to all key individuals within the Organization and to verify internal controls are implemented correctly and are operating effectively. Planned Corrective Action: As the organization has grown, compliance of federal programs has become decentralized. We agree that additional resources need to be added to ensure compliance with all state and federal awards. The Organization is adding additional capacity to the Business Office to centralize the compliance and reporting responsibilities. The Organization has recently had the opportunity to redesign the job description of the Controller. To allow the Controller more capacity for compliance and reporting responsibilities, an accounts payable position will be added by the end of Fiscal Year 2023. The Controller will attend appropriate trainings to ensure a full understanding of all requirements. This should be fully implemented by mid-2023.

View Audit 35401

Finding 36809 (2022-001)

Significant Deficiency 2022

North Fourth Art Center

NM

Questioned Costs Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.303

Corrective Action Plan: North Fourth Art Center will incorporate and communicate to Board President changes to our policy and procedures to ensure additional controls are established in regards to grant requirements. These internal controls will require that Board President reviewed and approve time...

Corrective Action Plan: North Fourth Art Center will incorporate and communicate to Board President changes to our policy and procedures to ensure additional controls are established in regards to grant requirements. These internal controls will require that Board President reviewed and approve timesheets of Executive Director or Associate Director (when Executive Director is not in the Office Associate Director is in charge) in timelier manner. Board President will sign Executive Director?s timesheets every two months. When Associate Director is Acting Director, Acting Director?s timesheets will be signed within two weeks of her time as acting Executive Director. Responsible Official: Executive Director, Marjerie Neset Timeline for Implementation: Effective January 2023

View Audit 30709

Finding 36724 (2022-021)

Significant Deficiency 2022

Government of the District of Columbia

DC

Internal Control / Segregation of Duties Questioned Costs Special Tests & Provisions § 200.303

DHCF concurs with these findings. At issue in this finding is a pricing discrepancy of .36 cents less per item than indicated in the applicable contract for the subject services between DHCF and its QIO, Comagine Health, LLC (Comagine). Effective June 2023, DHCF confirms that it is paying the appro...

DHCF concurs with these findings. At issue in this finding is a pricing discrepancy of .36 cents less per item than indicated in the applicable contract for the subject services between DHCF and its QIO, Comagine Health, LLC (Comagine). Effective June 2023, DHCF confirms that it is paying the appropriate contracted rate for all services rendered under its contract and has confirmed that Comagine has corrected its invoice billing rate to match the contracted amount. To ensure that DHCF continues to reimburse its QIO at the applicable contracted rate, it will draft and implement a QIO invoice reimbursement checklist containing the contracted rate(s) for applicable items, and a check box to confirm that the amount billed in the invoice corresponds to the contracted rate. This checklist will be completed by the Division of Clinician, Pharmacy, and Acute Provider Services within the Health Care Delivery Management Administration, which is responsible for payment of invoices submitted by Comagine. See Corrective Action Plan for chart/table

View Audit 31369

Finding 36723 (2022-020)

Significant Deficiency 2022

Government of the District of Columbia

DC

Internal Control / Segregation of Duties Questioned Costs Eligibility § 200.303

DHCF and DHS concur with the findings. For bullet point #1 of the findings noted: Fourteen (14) of the cases were delayed because of caseworker inaction within 45 days. However, of those (14) cases, all were sent notices. There were system tickets created for multiple cases listed however they wer...

DHCF and DHS concur with the findings. For bullet point #1 of the findings noted: Fourteen (14) of the cases were delayed because of caseworker inaction within 45 days. However, of those (14) cases, all were sent notices. There were system tickets created for multiple cases listed however they were created well after the 45 days. As a corrective action DHS will provide refresher training and reinforce oversight controls to ensure caseworkers and supervisors are processing applications within federally required timeframes. DHCF is working on enhancing the medical application in the District Direct resident portal to ensure a user-friendly experience for residents to submit applications online. As a result, we expect to see a decrease in delays to application processing as well as a decrease in caseworkers having to trigger notices as the online forum will automate the mailing of notices. For bullet point #2 of the findings noted: One (1) of the cases sighted for lack of verification of SSN was an improper caseworker application of the death process. On 12/09/22 the agency received a death certificate for the beneficiary confirming the decease date of 11/26/22. An application was later received on 12/22/23 with no indication of need for retro- services. The application was improperly processed due to the death notification date. As a corrective action refresher training will be provided to caseworker to ensure the proper application of the death process. For bullet point #3 of the findings noted: One (1) of the cases sighted for lack of verification of SSN was an improper caseworker application of the death process. On 12/09/22 the agency received a death certificate for the beneficiary confirming the decease date of 11/26/22. An application was later received on 12/22/23 with no indication of need for retro- services. The application was improperly processed due to the death notification date. As a corrective action refresher training will be provided to caseworker to ensure the proper application of the death process. One (1) of the cases sighted for lack of verification was a result of improper application of COVID procedures. A request was made to the hub to match SSN and citizenship information attested to by the beneficiary. No match was returned by the hub; RFI /General communication was issued to request citizenship verification; no response was received however COVID PHE rules prohibited closure of case; eligibility was extended on the back end. Although the RFI /General communication was issued correctly, the COVID process to clear the verification to prevent termination was not. The process to clear verifications was not applicable to SSN and Citizenship and this case should have been denied for failure to verify. Although COVID processes are no longer in place as a corrective action the district will incorporate the manual citizenship process into the refresher training related to beneficiaries whose hub ping returns as null. See Corrective Action Plan for chart/table

View Audit 31369

Finding 36719 (2022-017)

Material Weakness 2022

Government of the District of Columbia

DC

Questioned Costs Student Financial Aid Eligibility § 200.303

CFSA concurs with the findings as stated. For bullet point #1 of the findings noted: This appears to be a data entry error that occurred during the eligibility team?s preparation for the single audit. The room & board costs that occurred during the erroneous ?Eligible Not Reimbursable? period on t...

CFSA concurs with the findings as stated. For bullet point #1 of the findings noted: This appears to be a data entry error that occurred during the eligibility team?s preparation for the single audit. The room & board costs that occurred during the erroneous ?Eligible Not Reimbursable? period on the redetermination form were claimed to title IV-E in real time during CFSA?s quarterly claiming process. The Supervisory Eligibility Specialist has already begun a 10% quarterly quality review process of all eligibility determinations. For bullet point #2 of the findings noted: The youths in question were enrolled in high school at the start of the school year (and reflected as such in the FACES system) but were actually chronically truant. CFSA?s Business Services Administration and the Office of Youth Empowerment have implemented a joint quarterly review of the educational/employment/incapacity status of 18-to-21-year-old youth who are IV-E eligible to ensure that they meet federal requirements to support IV-E claims on their behalf. For bullet point #3 of the findings noted: The issues with background checks pertained to ?other adults residing in the home? who were not the licensed foster parents. The corrective action going forward is to produce source documentation during the audit that identifies the household composition of the foster family home so that the auditors have a clear picture of those who are adults and therefore require evidence that background checks were completed satisfactorily for IV-E eligibility purposes. CFSA will include the sections of the applications/re-applications for foster family home licensure, as appropriate, into the digital catalogue of readily available licensure documentation available for audit retrieval. These documents corroborate household composition for the purpose of identifying who, within the household, requires background checks. See Corrective Action Plan for chart/table

View Audit 31369 Questioned Costs: $1

Finding 36718 (2022-016)

Significant Deficiency 2022

Government of the District of Columbia

DC

Allowable Costs / Cost Principles Questioned Costs Student Financial Aid § 200.303

CFSA concurs with the finding as stated. In the three (3) instances of overtime payments in the sample, the employees in question were designated ?on-call? staff during non-business hours. In the event of emergency situations involving child protection or child placement, the ?on-call? staff are r...

CFSA concurs with the finding as stated. In the three (3) instances of overtime payments in the sample, the employees in question were designated ?on-call? staff during non-business hours. In the event of emergency situations involving child protection or child placement, the ?on-call? staff are required to report to work to assist with resolution to the child-based emergency. Their overtime is essentially pre-approved by their management team. CFSA will orient staff to a uniform process to record and account for staff-specific, day-specific, and duration-specific instances of overtime. CFSA will train and monitor usage, and full implementation will occur by September 30, 2023. See Corrective Action Plan for chart/table

View Audit 31369

Finding 36712 (2022-015)

Significant Deficiency 2022

Government of the District of Columbia

DC

Matching / Level of Effort / Earmarking § 200.303

DOEE agrees with the conditions and recommendations of this finding. Beginning in May 2023, the Grants Management Specialist created a report that allows program and budget staff to review the year-to-date spending in the categories with earmarking limits, compare it to the limits based on the amou...

DOEE agrees with the conditions and recommendations of this finding. Beginning in May 2023, the Grants Management Specialist created a report that allows program and budget staff to review the year-to-date spending in the categories with earmarking limits, compare it to the limits based on the amount awarded by the grantor, and see the available balance in each category. See Corrective Action Plan for chart/table

View Audit 31369

Finding 36711 (2022-014)

Material Weakness 2022

Government of the District of Columbia

DC

Questioned Costs Student Financial Aid Eligibility § 200.303

DOEE agrees with the conditions and recommendations of this finding. DOEE proposes to strengthen its controls in the following manner: ? DOEE?s third party database developer updated the code in fiscal year 2022 to prevent occurrences of incorrect benefit amounts generated due to an error in ident...

DOEE agrees with the conditions and recommendations of this finding. DOEE proposes to strengthen its controls in the following manner: ? DOEE?s third party database developer updated the code in fiscal year 2022 to prevent occurrences of incorrect benefit amounts generated due to an error in identifying correctly inputted income amounts. The overall operations and maintenance of the eligibility systems ensure the code remains updated with accurate information. ? In fiscal year 2022, DOEE implemented a quality assurance (Q/A) check of benefit payments to identify database errors and duplicate benefits before submitting benefit payments to Utility vendors. DOEE continues this process today to ensure that database errors are identified and addressed in a timely manner. DOEE?s database developer will create and modify the second review report that is exportable to formats that can be read and understood and inclusive of all signed second application reviews. ? DOEE will conduct, and require participation by staff in, quarterly system demonstration and refresher trainings in order to strengthen existing policies and procedures to ensure the review of applications and household size are correctly recorded into the system. See Corrective Action Plan for chart/table

View Audit 31369

Finding 36709 (2022-013)

Material Weakness 2022

Government of the District of Columbia

DC

Eligibility Questioned Costs Special Tests & Provisions § 200.303

The Department of Human Services (DHS) agrees with the finding in this report. The DCAS System is currently configured to receive the Title II benefit information via the SSA BENDEX periodic data match process. However, the Title II benefit information is shared with DCAS only when the benefit info...

The Department of Human Services (DHS) agrees with the finding in this report. The DCAS System is currently configured to receive the Title II benefit information via the SSA BENDEX periodic data match process. However, the Title II benefit information is shared with DCAS only when the benefit information with the SSA changes. In the scenario where a TANF benefit is certified on a new application, the BENDEX PDM process will not provide the Title II benefit information to DCAS. Hence, we have seen evidence of the data matches not happening up until the point when the benefit information recorded with SSA has changed. The SSA SolQi interface does provide a customer?s Title II and Title XVI benefit information at the time of the initial application, however, this interface in DCAS is configured as a verification interface. In other words, if the customer has reported income from the Social Security Administration, then the DCAS System uses the data match with the SolQi interface to verify the information reported. If a verification is outstanding on the reported benefit from the SSA, and the information received from SolQi matches, then DCAS system is configured to systematically resolve the verification. Hence, there has been evidence of the record received via SolQi, however, the record was not used to update the internal evidence which is used by the eligibility rules. DHCF DCAS teams are tracking system enhancements, logged in internal JIRA tickets ? DSM-3185 and DSM-3186 to enhance DCAS? interface with SolQi to leverage the interface at initial application and during the recertification process to ensure that the DCAS System has the most up to date income information from SSA to determine eligibility. These tickets are currently scoped for the FNS-AWL-CAP-5 releases planned for fiscal year 2024. See Corrective Action Plan for chart/table

View Audit 31369

Finding 36708 (2022-012)

Material Weakness 2022

Government of the District of Columbia

DC

Questioned Costs Special Tests & Provisions Subrecipient Monitoring § 200.303

The Department of Human Services (DHS) agrees with the findings and will work with the DCAS and the Division of Innovation and Change Management (DICM) teams to mitigate the causes of the findings. This corrective action plan has multiple layers in which ESA will collaborate efforts between multipl...

The Department of Human Services (DHS) agrees with the findings and will work with the DCAS and the Division of Innovation and Change Management (DICM) teams to mitigate the causes of the findings. This corrective action plan has multiple layers in which ESA will collaborate efforts between multiple units within DHS/ ESA that includes the Division of Customer Workforce, Employment and Training (DCWET), the Division of Program Operations (DPO), and DICM. The Office of Performance Monitoring (OPM) has a process in place to monitor and confirm the hours reported from CATCH. OPM Monitors will continue to randomly generate 60 sample cases from Q5i monthly, review them and if they find any discrepancies would refer them to either OWO, DPO, or TEP Providers for resolution. When OPM conducts their review of DCAS hours, and identifies income and hour differences, the Department of Program Operations (DPO) is informed and/or the Office of Work Opportunity (OWO) requesting their assistance with resolving the discrepancy. While this would be a short-term solution it will go a long way to resolving some of the discrepancies in reported work hours that are being transmitted to Q5i. The Office of Work Opportunity (OWO) conducts outreach to customers come in for assessment and assignment to a TEP Providers. This process would eliminate instances where hours found in the DCAS system is unknown to the CATCH system. ESA will work with DCAS to enhance the system to tie the income evidence in the income support case to the employment evidence in the person record to allow the employment hours to end date once the income evidence is end dated. This will automate the process by connecting the 2-step process into one task. This automation process would be a permanent solution to curbing stale of unsubstantiated hours from migrating to Q5i.Once the system enhancement is in place, training will be conducted for all DPO Social Service Representatives on the DCAS screens which require action to confirm employment. See Corrective Action Plan for chart/table

View Audit 31369

Finding 36707 (2022-011)

Material Weakness 2022

Government of the District of Columbia

DC

Eligibility Questioned Costs Reporting § 200.303

Department of Human Services (DHS)/Economic Security Administration (ESA) concur with the findings. DHS Division of Program Operations (DHS/DPO) have embarked on a partnership with Office of Information Systems (OIS) and the Division of Innovation and Change (DICM) to create a unique identifier in ...

Department of Human Services (DHS)/Economic Security Administration (ESA) concur with the findings. DHS Division of Program Operations (DHS/DPO) have embarked on a partnership with Office of Information Systems (OIS) and the Division of Innovation and Change (DICM) to create a unique identifier in DC Access System (DCAS) which will be utilized to properly associate case documents with the appropriate Integrated Case number in DIMS. This process will reduce and/or eliminate unassociated documents in DIMS. In addition, DPO/ESA and OIS will partner to conduct refresher training for staff on how to properly scan and tag case documents as well as how to conduct searches for case documents in DIMS. See Corrective Action Plan for chart/table

View Audit 31369 Questioned Costs: $1

Finding 36700 (2022-002)

Material Weakness 2022

Buckeye Local School District

OH

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

The School District will implement internal controls to ensure that all contractors working on federally funded projects for which wage rate requirements apply, are notified and the School District will obtain necessary documentation to verify compliance. In addition, the School District will implem...

The School District will implement internal controls to ensure that all contractors working on federally funded projects for which wage rate requirements apply, are notified and the School District will obtain necessary documentation to verify compliance. In addition, the School District will implement internal controls to ensure the necessary language is included in all future solicitations for quotes or bids for which prevailing wage requirements apply.

View Audit 32734

Finding 36698 (2022-003)

Significant Deficiency 2022

African Development Center

MN

Questioned Costs Reporting Subrecipient Monitoring § 200.329

2022-003 Performance Reporting Microloan Program ? Assistance Listing No. 59.046 Recommendation: We recommend management develop procedures to ensure the required reporting is completed within the timeline allowed by the granting agency. Explanation of disagreement with audit finding: There is no di...

2022-003 Performance Reporting Microloan Program ? Assistance Listing No. 59.046 Recommendation: We recommend management develop procedures to ensure the required reporting is completed within the timeline allowed by the granting agency. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: New staff has been trained and the reporting calendar updated. CFO/COO to monitor and submit in a timely manner. Name(s) of the contact person(s) responsible for corrective action: Nasibu Sareva (CEO) and Felicia Ravelomanantsoa (CFO/COO) Planned completion date for corrective action plan: 12/31/2023

View Audit 36926

Finding 36693 (2022-004)

Material Weakness 2022

Crawford County

IN

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

FINDING 2022-004 Contact Person Responsible for Corrective Action: Wendy Marples, County Auditor Contact Phone Number: 812-338-2142 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: All future reporting of the Coronavirus State and Local Fiscal Recover...

FINDING 2022-004 Contact Person Responsible for Corrective Action: Wendy Marples, County Auditor Contact Phone Number: 812-338-2142 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: All future reporting of the Coronavirus State and Local Fiscal Recovery Funds will be reviewed for accuracy by a second staff member of the Auditor?s office prior to submission. The report will be signed and dated by both the preparer and reviewer. All documentation will be maintained to help prevent any future inconsistencies. Anticipated Completion Date: April 2024

View Audit 34823

Finding 36683 (2022-001)

Significant Deficiency 2022

Webster University

MO

Student Financial Aid Questioned Costs Special Tests & Provisions

The Financial Aid Office and the Registrar's Office will work closely together to resolve the NSLDS reporting discrepancies. We are currently in the process of hiring a Compliance Coordinator that will serve as a bridge between the Financial Aid Office and the Registrar's office that will monitor a...

The Financial Aid Office and the Registrar's Office will work closely together to resolve the NSLDS reporting discrepancies. We are currently in the process of hiring a Compliance Coordinator that will serve as a bridge between the Financial Aid Office and the Registrar's office that will monitor and audit the reporting process for errors and discrepancies monthly. From here, if there are any discrepancies or inconsistencies, the Financial Aid Office and the Registrar's Office will work together to understand any patterns that exist so that our processes can be reevaluated and tightened to ensure ongoing compliance. Based on the review of information from last year's similar finding (2021), it was determined after the fact that Webster University had both reported the enrollment information correctly and in a timely manner to the Clearinghouse, however, the Clearinghouse frequently reported glitches and outages that prevented reporting to NSLDS in a timely manner. Going forward the Compliance Coordinator will monitor enrollment reporting, as well as the timing of the Clearinghouse's enrollment reporting to NSLDS. If it is determined that enrollment reporting via the Clearinghouse continues to be discrepant, Webster University will explore other methods of reporting that are more conducive to timely and accurate enrolment reporting to NSLDS.

View Audit 35724

Finding 36674 (2022-015)

Significant Deficiency 2022

City of New Albany, Mississippi

MS

Reporting Matching / Level of Effort / Earmarking

CFDA# 21.027 ? COVID-19 Coronavirus State and Local Recovery Funds Finding 2022-015 The Annual Project Expenditure Report required as a Tier 5 reporter under the American Recovery Plan (ARP) State and Local Fiscal Recovery Funds (SLFRF) was not submitted. City?s Response: City personnel thought the...

CFDA# 21.027 ? COVID-19 Coronavirus State and Local Recovery Funds Finding 2022-015 The Annual Project Expenditure Report required as a Tier 5 reporter under the American Recovery Plan (ARP) State and Local Fiscal Recovery Funds (SLFRF) was not submitted. City?s Response: City personnel thought they had successfully submitted the required report in a timely fashion. Views of Responsible Officials and Corrective Action: The City Clerk thought that the report had been submitted in a timely fashion, ut could not produce documentation to verify the submission. Since the City?s expenditures are not included on the download of annual reporting data, the City assumes that the report was not properly submitted. Future report submissions will be made on a timely basis with documentation retained to demonstrate compliance with those reporting requirements. Name of Responsible Person: Frankie Roberts, City Clerk Name of City Contact: Frankie Roberts, City Clerk Projected Implementation Date: April 30, 2023

View Audit 27788

Finding 36661 (2022-004)

Material Weakness 2022

Academy of America

MI

Questioned Costs Subrecipient Monitoring Material Weakness § 200.303

View of Responsible Officials and Corrective Action Plan ? The Academies have procedures in place requiring review and approval. Management believes that it was a limited number of items that may not have had written approval from a school administrator or the controller. Management will ensure th...

View of Responsible Officials and Corrective Action Plan ? The Academies have procedures in place requiring review and approval. Management believes that it was a limited number of items that may not have had written approval from a school administrator or the controller. Management will ensure that review and approval is properly documented by signature or an electronic approval.

View Audit 34863

Finding 36627 (2022-024)

Significant Deficiency 2022

State of Georgia/state Accounting Office-Ein Noted

GA

Allowable Costs / Cost Principles Period of Performance Reporting § 200.303 § 200.403 § 200.77

2022-024 Improve Controls over Period of Performance Federal Agency: U.S. Department of Health and Human Services State Entity: Department of Behavioral Health and Developmental Disabilities (DBHDD) Corrective Action Plans: The Department will continue to improve the internal controls to ensure tha...

2022-024 Improve Controls over Period of Performance Federal Agency: U.S. Department of Health and Human Services State Entity: Department of Behavioral Health and Developmental Disabilities (DBHDD) Corrective Action Plans: The Department will continue to improve the internal controls to ensure that expenditures are liquidated within 90 days of the end of the period of performance as required. The Department will update processes and procedures associated with period of performance requirements and provide training that outlines close-out processes associated with the specific grant awards. DBHDD will update the internal controls related to period of performance no later than June 30, 2023. Estimated Completion Date: June 30, 2023 Contact Person: Kenneth Ward, Director of Internal Audit Telephone: 404-884-5486; E-mail: kenneth.ward@dbhdd.ga.gov

View Audit 26105 Questioned Costs: $1

Finding 36600 (2022-032)

Material Weakness 2022

State of Georgia/state Accounting Office-Ein Noted

GA

Subrecipient Monitoring Allowable Costs / Cost Principles Eligibility § 200.303 § 200.53

2022-032 Improve Controls over Employer-Filed Claims Federal Agency: Various Federal Agencies: U.S. Department of Homeland Security U.S. Department of Labor State Entity: Department of Labor (GDOL) Corrective Action Plans: The Georgia Department of Labor disagrees with this finding. The Em...

2022-032 Improve Controls over Employer-Filed Claims Federal Agency: Various Federal Agencies: U.S. Department of Homeland Security U.S. Department of Labor State Entity: Department of Labor (GDOL) Corrective Action Plans: The Georgia Department of Labor disagrees with this finding. The Employer Filed (Partial) Claims (EFC) program originated in the late 1960?s and was designed to allow employers with short term, temporary periods of lack of work for their employees to retain their workforce when work resumes. This is a program that many large manufacturers in Georgia rely on when they have temporary plant shutdowns and have for decades. When GDOL has attempted in the past to limit this program, we have met strong resistance from Georgia?s manufacturers. This program optimizes our ability to process and pay mass numbers of claims more quickly, such as what occurred at the beginning of the pandemic. EFCs may be filed by an employer with respect to any complete pay-period week during which an otherwise full-time employee works less than full-time, due to lack of work only, and earns an amount not exceeding his/her unemployment insurance weekly benefit amount. Such claims shall not be submitted or allowed for vacation days regardless of whether such vacation days were requested by the employee or established by the employer. Effective March 19, 2020, a temporary, Emergency Rule 300-2-4-05(1), containing Rule 300-2-4-.09(1) was signed which required employers to electronically submit EFCs on behalf of their employees whenever it is necessary to temporarily reduce work hours or there was no work available for a short period of time. Employers were allowed to file such claims for full and part time employees whose earnings had been reduced. In July 2020, the Rule was sunset and employers were no longer required to file EFCs. EFCs may be filed online by single entry or upload or paper. An employer may submit EFCs for regular state unemployment insurance programs including available extended benefits programs with the same eligibility requirements as regular UI, such as Pandemic Emergency Unemployment Compensation (PEUC) and State Extended Benefits (SEB), given all regular UI entitlement is exhausted. By electing to submit EFCs on behalf of the individuals, the employer is responsible for attesting to the employment status and weekly earnings of the individual for the EFC submitted. An affidavit certifying that the employer has obtained earnings from other employment as well as other requirements must be completed before EFCs can be entered or uploaded. Individuals for which EFCs are submitted are considered to be still attached to the employer and are exempt from the requirement to register for employment services per Georgia Employment Security Law Rules 300-2-4-.02. Such individuals are not required to be nor certify on a weekly basis to be able, available and actively seeking work. The GDOL disagrees that we would not provide the requested information to the auditors. The data requested relates to an ongoing federal criminal investigation. GDOL did not provide the data with concerns that dissemination of the data to a third party could jeopardize the ongoing criminal investigation and create legal risk for GDOL. GDOL stated that the auditors should obtain permission from the United States Department of Justice as a condition to dissemination of the data. GDOL did not receive any confirmation that the auditors had discussed the matter or coordinated with the US Department of Justice. Even though there have been some publicized indictments, the US Department of Justice has confirmed to GDOL that the investigation is ongoing and future indictments are anticipated. Notwithstanding, GDOL reiterates it would be happy to share the relevant data in its possession with assurances that the auditors will not publicize or disseminate any of the audit data without first consulting with the US Department of Justice. GDOL is also happy to cooperate with the auditors and provide information relating to how GDOL discovered the methods and schemes used by the fraudsters; however, GDOL has serious concerns about any publication of such information or of any other specific vulnerabilities in GDOL?s systems that would serve to encourage or perpetuate additional unemployment insurance fraud. Summary When we identified employer fraud schemes, we followed the guidance issued by United States Department of Labor (USDOL) and collaborated with the United States Department of Labor Office of Inspector General (OIG) to investigate these cases. Effective December 6, 2021, the EFC process was revised to require individuals (employees) to complete an EFC profile to include a real-time identity verification before payments can be made. Employers are responsible for submitting the request for the payment to certify to the individual?s employment status, but the individuals must certify their identity and personal information for the claim to be processed. Employees are notified when a claim is filed on their behalf and provided instructions for their portion of completing the EFC process. The MyUI Customer Portal dashboard provides all the EFC correspondence sent to the individual as well as a status of the profile set up and identify verification. Prior to the implementation of the EFC profile requirement, GDOL utilized the Social Security Administration (SSA) crossmatch and Systematic Alien Verification for Entitlement (SAVE) verification processes to verify the identity of claimants where employers submit claims on their behalf. GDOL has no plans to stop utilizing the EFC program as it is an effective and popular program among employers with a successful 60-year track record. GDOL greatly appreciates the feedback and recommendations and will consider this information in future endeavors to modernize and update system and business processes. Estimated Completion Date: December 6, 2021 Contact Person: Crystal Singleton, Policy and Procedure Manager Telephone: 404-232-3183; E-mail: Crystal.Singleton@gdol.ga.gov

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