Corrective Action Plans

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Root Cause Analysis: The condition resulted from a lapse in the execution of an established control rather than the absence of a control framework. The EPI Center had formal memoranda of understanding in place with participating districts that defined match requirements, including in-kind contributi...
Root Cause Analysis: The condition resulted from a lapse in the execution of an established control rather than the absence of a control framework. The EPI Center had formal memoranda of understanding in place with participating districts that defined match requirements, including in-kind contributions of personnel time and effort, and contemplated periodic certification of those contributions. While the MOUs indicated that districts would confirm match contributions on a quarterly basis, The EPI Center did not consistently obtain those confirmations during the audit period. Since the audit period, The EPI Center has obtained written attestations from participating districts confirming the source and amount of the personnel contributions used as match and has implemented procedures to ensure that such certifications are collected and retained based on funder requirements. Response, with details: ☒Corrective Active Plan ☒Clarification 46 Management believes the match contributions reported are valid, reasonable, and allocable to the program. Match was calculated using verifiable district salary schedules and a consistently applied methodology (e.g., 25% effort allocation tied to program outcomes, participation, and service delivery). No evidence was identified indicating that federal funds were used to meet match requirements or that match contributions were applied to other federal programs. Importantly: There is no evidence that these salaries were charged to federal funds, mitigating the risk of double counting or supplanting. All personnel included as match were employees of public-school districts, whose compensation structures are governed by transparent, state- and locally- funded salary schedules. Services provided by these personnel supported program implementation and intended outcomes (e.g., coaching, mentoring, instructional support aligned with grant objectives). This finding reflects a documentation and control execution gap rather than a deficiency in the allowability or validity of match contributions. Corrective Actions The EPI Center has implemented, or is in the process of implementing, the following corrective actions to ensure full compliance moving forward: 1. Retroactive Certification (Completed - March 2026) Developed standardized district attestation forms for match contributions. Initiated collection of retroactive certifications from all participating districts to formally validate previously reported match. 2. Match Verification Process (Completed - April 2026) Established a certification process requiring district-level verification of match contributions. Management will align match verification with financial reconciliation and reporting in accordance with funder requirements. 3. Strengthened Partner Guidance and Agreements (Completed - April 2026) Updated MOUs and partnership agreement templates to include explicit federal documentation requirements for match that align to reporting requirements. Provided technical assistance to district partners to ensure consistent understanding and compliance. While the reported questioned cost exposure (approximately $3.4M) is acknowledged, The EPI Center notes that the condition relates to documentation rather than the underlying validity of the costs. There is no indication of unallowable costs, fraud, or misuse of funds, and no evidence that federal funds were used to meet match requirements. 47 All match contributions are based on public school district salary structures, which are subject to established oversight and accountability. Accordingly, the underlying match amounts are supported by objective and verifiable data sources. This finding reflects a documentation and timing matter, rather than concerns related to allowability, allocability, or program integrity. The EPI Center requests that this distinction be considered in assessing the overall severity and classification of the finding. Responsible Party: Project Lead, Finance Specialist Timeline for Completion: Ongoing with an expected completion date for all items by April 2026
Management will immediately reimburse the property’s operating account for the unauthorized $10,000 distribution. Procedures will be implemented to ensure that all future loan repayments and cash distributions comply with HUD surplus cash requirements and the regulatory agreement. Surplus cash calcu...
Management will immediately reimburse the property’s operating account for the unauthorized $10,000 distribution. Procedures will be implemented to ensure that all future loan repayments and cash distributions comply with HUD surplus cash requirements and the regulatory agreement. Surplus cash calculations will be reviewed and approved prior to authorizing any distributions. Staff responsible for financial oversight will receive additional training on HUD surplus cash rules to prevent recurrence.
Action Taken: The Organization has re-evaluated its internal controls related to grant budgeting with Federal agencies and cost billing expectations. The updated controls will be implemented in the next fiscal year.
Action Taken: The Organization has re-evaluated its internal controls related to grant budgeting with Federal agencies and cost billing expectations. The updated controls will be implemented in the next fiscal year.
We created a procedure and ensured the appropriate staff members know their responsibilities in filing time and effort documentation
We created a procedure and ensured the appropriate staff members know their responsibilities in filing time and effort documentation
The foundation is working on completing audits for FY21. The OSA included foundation audits for FY22, FY23, and now FY24. At the conclusion of the FY21 foundation audit, the foundation and Mesalands will meet with the OSA to determine next steps. The foundation and the college will work to reconcile...
The foundation is working on completing audits for FY21. The OSA included foundation audits for FY22, FY23, and now FY24. At the conclusion of the FY21 foundation audit, the foundation and Mesalands will meet with the OSA to determine next steps. The foundation and the college will work to reconcile the balance of this endowment and get the correct amount recorded. Responsible staff: Director of Finance and MCC Foundation Coordinator. Expected date of compliance: June 30, 2026.
Finding # 2024-001 Response - UNHS experienced turnover in a key position within the finance department, which resulted in delays in the completion of the annual financial statement audit and SF-SAC filing. UNHS will implement additional internal controls to prevent future late submissions to the SF...
Finding # 2024-001 Response - UNHS experienced turnover in a key position within the finance department, which resulted in delays in the completion of the annual financial statement audit and SF-SAC filing. UNHS will implement additional internal controls to prevent future late submissions to the SF-SAC. Responsible Party - Andrew Evans, Chief Financial Officer Estimated Completion Date - On or before June 30, 2026
The Program agrees and has established internal controls to ensure that all Federal Funding Accountability and Transparency Act (FFATA) subaward reports exceeding 30,000 are submitted timely and reviewed by the Territorial Public Assistance Officer. Although the SAM.GOV system implemented in FY 2024...
The Program agrees and has established internal controls to ensure that all Federal Funding Accountability and Transparency Act (FFATA) subaward reports exceeding 30,000 are submitted timely and reviewed by the Territorial Public Assistance Officer. Although the SAM.GOV system implemented in FY 2024 does not track individual FFATA filing dates, VITEMA remains committed to submitting all required reports by the last day of the month following each award. A certification process has also been implemented to verify the date reports are filed and reviewed.
The Program Integrity Unit has established SOPPs which identifies the method for identifying fraud cases, investigating cases, and developed procedures in collaborating and cooperating with legal authorities, for referring credible allegations of fraud cases to law enforcement officials.
The Program Integrity Unit has established SOPPs which identifies the method for identifying fraud cases, investigating cases, and developed procedures in collaborating and cooperating with legal authorities, for referring credible allegations of fraud cases to law enforcement officials.
To address these challenges and strengthen program integrity, DHS implemented the Provider Enrollment Application (PEA) Portal on March 2, 2026. The PEA Portal modernizes provider enrollment and revalidation by electronically collecting, storing, and maintaining required documentation in a centraliz...
To address these challenges and strengthen program integrity, DHS implemented the Provider Enrollment Application (PEA) Portal on March 2, 2026. The PEA Portal modernizes provider enrollment and revalidation by electronically collecting, storing, and maintaining required documentation in a centralized system. The portal supports retention of Medicaid Provider Agreements, screening documentation, ownership disclosures, licensure information, and other enrollment records within a single electronic repository. The PEA Portal improves document retention and accessibility, creates an electronic audit trail, and enables staff to retrieve enrollment and screening records more efficiently. It also strengthens oversight by standardizing enrollment workflows, reducing reliance on paper files, and improving documentation consistency. These enhancements better position DHS to demonstrate compliance during future audits and monitoring reviews. DHS recognizes the importance of maintaining complete, accurate, and accessible provider enrollment records. In addition to implementing the PEA Portal, DHS is strengthening policies and procedures related to provider file maintenance, document retention, and quality assurance reviews. Staff training and periodic monitoring will help ensure required enrollment documents and exclusion screening records are consistently maintained and available for inspection. DHS is committed to maintaining compliance with federal Medicaid and CHIP provider enrollment requirements and believes the corrective actions implemented, including deployment of the PEA Portal, will improve documentation controls, strengthen program integrity, and reduce the risk of similar findings in the future.
During the audit period, the Department did not complete the required ADP Risk Analysis and System Security Review for systems supporting the Medicaid Program, and certain monitoring controls were not operating at a sufficient level of precision to ensure compliance with federal requirements. To add...
During the audit period, the Department did not complete the required ADP Risk Analysis and System Security Review for systems supporting the Medicaid Program, and certain monitoring controls were not operating at a sufficient level of precision to ensure compliance with federal requirements. To address this finding, the Department recently issued Requests for Qualifications (RFQs) to seven qualified vendors to perform comprehensive security risk assessments of the Medicaid Enterprise Systems (MES), including the VIBES Eligibility and Enrollment System, Provider Enrollment Application (PEA), Pharmacy Benefit Management (PBM) solution, and related supporting systems. Vendor responses are due within three weeks, after which the Department will evaluate submissions and proceed with the procurement process. The selected vendor will conduct the required risk assessments, identify control deficiencies and security vulnerabilities, and provide recommendations to strengthen the Department's security posture and compliance framework. The Department will work collaboratively with its technology partners, system vendors, and oversight entities to implement corrective actions identified through the assessments and enhance monitoring controls to ensure ongoing compliance with applicable federal requirements.
The Department has strengthened its oversight of Medicaid financial reporting through the establishment of a Director of Audits position in September 2025. The Director of Audits will work collaboratively with the Medicaid Program, Fiscal Office, and other applicable stakeholders to monitor complian...
The Department has strengthened its oversight of Medicaid financial reporting through the establishment of a Director of Audits position in September 2025. The Director of Audits will work collaboratively with the Medicaid Program, Fiscal Office, and other applicable stakeholders to monitor compliance with federal reporting requirements and ensure that adequate supporting documentation is maintained for Medicaid cost reporting activities.
Currently, reports are submitted for review via email. The CMS-64 as well as the CMS-37 is prepared by a consulting firm who submits the copy of the reports for review and approval. Once the Medicaid Director is satisfied, an email is sent approving the report, for further entering into the MBES (CM...
Currently, reports are submitted for review via email. The CMS-64 as well as the CMS-37 is prepared by a consulting firm who submits the copy of the reports for review and approval. Once the Medicaid Director is satisfied, an email is sent approving the report, for further entering into the MBES (CMS system of record) and certification. To ensure access for audit purposes, the Department has implemented a shared folder where copies of approval emails and any time extension requests are stored, since the submission portal does not allow for attachments. Additionally, a Director of Federal Grants has been on-boarded who will assume the role of preparing the reports.
Conversion from VIMS to VIBES allowed system generated ex parte extensions beyond 12 months without requiring updated member contact or documentation. No process was in place to proactively require updated documentation when extensions exceeded one year, resulting in eligibility continuing without c...
Conversion from VIMS to VIBES allowed system generated ex parte extensions beyond 12 months without requiring updated member contact or documentation. No process was in place to proactively require updated documentation when extensions exceeded one year, resulting in eligibility continuing without current proof in file. DHS will: 1. Implementation of Annual In Person/Active Renewal for Extended Cases 2. If members fail to provide required documentation or complete the renewal process, the case is closed for failure to verify eligibility. Appropriate adverse action notices are issued in accordance with policy and timelines. 3. Staff have been instructed that eligibility determinations must not be maintained solely on a system generated extension; supporting documentation must be present in the electronic case record and/or document management system. A brief standard note template is used in VIBES to reference what documents were received, and the date eligibility was rerun. 4. System Configuration Changes with Vendor (RedMane). Worked with RedMane to adjust system logic so that eligibility cannot be approved or extended if no completed application (or renewal) is on record. 5. Updated written procedure includes, staff must confirm that a completed application (paper, phone, online, or converted electronic record) is present and imaged/recorded before approving eligibility. If the individual fails to submit required information by the due date, staff must proceed with denial/closure and document the action in case notes. 6. Conducted targeted staff training on, requirement for a completed application before approval/extension; proper use of pending status and timeframes; correct closure/denial procedures. Provided written job aids illustrating compliant workflows. 7. Implementation of Review Tracking in SharePoint, as of July 2025, an Excel tracking file housed on SharePoint is used to document: case worker name; member name and address; case number; type of case (new application, renewal, newborn, etc.). Each case is entered when assigned to the worker. 8. The supervisor reviews the case directly in VIBES, confirms eligibility determinations, and applies any needed updates. VIBES records the supervisor’s actions with date, time stamp, and staff ID to show who reviewed and approved the case. The supervisor also applies changes and documents a brief note in the VIBES notes section (e.g., “Supervisor [Name/ID] reviewed and approved eligibility determination; OK to issue Notice of Decision.”). After review, the supervisor updates the SharePoint tracker to reflect that review is complete.
The exceptions identified were limited in nature and did not result in questioned costs. In the instance where the project code on the employee's Notice of Personnel Action (NOPA) had not been updated, program personnel made the necessary adjustments to ensure payroll costs were charged to the appro...
The exceptions identified were limited in nature and did not result in questioned costs. In the instance where the project code on the employee's Notice of Personnel Action (NOPA) had not been updated, program personnel made the necessary adjustments to ensure payroll costs were charged to the appropriate grant. To strengthen internal controls, the Department transitioned from manual timekeeping to a biometric finger-punch time and attendance system utilizing TimeForce in the fall of 2024. This system provides enhanced tracking, reporting, and record retention capabilities and reduces the risk of discrepancies associated with manual timekeeping processes. The Department will continue to strengthen its review and documentation procedures to ensure compliance with federal requirements. The Department of Human Services (DHS) adopted the electronic Timeforce (STATS) system for payroll, replacing manual processes. Time and attendance are approved through management levels, with payroll based on Notice of Personnel Action (NOPA) cost centers. Financial Analysts now assigned to the grant reconciles the payroll. Additionally, in order to ensure that Notices of Personnel Actions are updated on a timely basis, ensuring that salaries are charged to the respective account, DHS has implemented the following process: - Provisional Payroll Codes are requested prior to the close of the Fiscal Year by the Department of Finance through the Office of Management and Budget through the established process. - Once the codes are received, the Division of Human Resources will update the most current Personnel Distribution Sheets to reflect active employees. - The sheets will be submitted to Fiscal for certification by the CFO. - NOPA’s are updated with the provisional codes.
Once payroll is processed by the Department of Finance (DOF), a Flex Earnings Report is generated by the Analyst on each payday. A reconciliation is then performed to ensure that all employees, along with their respective fringe benefits, are accurately captured and drawn. Following this process, DO...
Once payroll is processed by the Department of Finance (DOF), a Flex Earnings Report is generated by the Analyst on each payday. A reconciliation is then performed to ensure that all employees, along with their respective fringe benefits, are accurately captured and drawn. Following this process, DOF posts the payroll to the accounting system. However, staffing has identified that deficiencies can occur in DOF’s postings, sometimes arising in periods subsequent to the actual payday. To address this, the Department of Human Services (DHS) has incorporated an internal control requiring retrospective reconciliation of accounts against the Flex Earnings Report to verify accuracy. Additionally, DHS plans to engage with DOF to better understand the underlying factors and nuances that result in discrepancies between DOF postings and the account coding reflected in the Flex Earnings Report. The Federal Grants Financial Analyst also plays a key role in ensuring that transactions are recorded in the appropriate accounting period and that costs are properly allocated. In this particular instance, no federal funds were drawn.
The Government concurs with the auditor’s findings and recommendations. Management will conduct a comprehensive review of existing internal controls related to non-payroll expenditures. DHS will update policies and procedures to ensure all costs are properly documented and comply with federal allowa...
The Government concurs with the auditor’s findings and recommendations. Management will conduct a comprehensive review of existing internal controls related to non-payroll expenditures. DHS will update policies and procedures to ensure all costs are properly documented and comply with federal allowable cost principles. DHS is committed to addressing the identified issues and maintaining ongoing compliance with federal regulations. DHS will conduct a thorough review of current internal controls and procedures related to non-payroll expenditures to identify gaps and areas for improvement. Policies will be updated to ensure all costs are properly documented and comply with federal allowable cost principles. Staff responsible for processing and approving expenditures will receive targeted training on documentation and compliance requirements. DHS will implement periodic internal audits to monitor adherence to updated procedures and promptly address any exceptions.
The Government concurs with the auditor’s findings and recommendations. Management will review current procedures to strengthen monitoring and documentation of provider eligibility for ARP Act stabilization funds. DHS is committed to improving internal controls and ensuring compliance with all progr...
The Government concurs with the auditor’s findings and recommendations. Management will review current procedures to strengthen monitoring and documentation of provider eligibility for ARP Act stabilization funds. DHS is committed to improving internal controls and ensuring compliance with all program requirements. An internal programmatic audit process is actively utilized. Subsidy determinations are cross-checked by different workers according to federally and locally established policies. Additionally, DHS is in the process of developing an internal audit and compliance unit. With the requisite staffing, internal audits will be conducted to ensure alignment with the Federal mandates in addition to ensuring overall compliance.
Internal audits will be conducted quarterly by having OCCRS subsidy staff and Administrators review files for accuracy of eligibility and subsidy determinations. Quality staff will conduct at least 2 unannounced visits per child care facility to monitor attendance. DHS will implement a centralized, ...
Internal audits will be conducted quarterly by having OCCRS subsidy staff and Administrators review files for accuracy of eligibility and subsidy determinations. Quality staff will conduct at least 2 unannounced visits per child care facility to monitor attendance. DHS will implement a centralized, secure tracking matrix. This log will track all fraud referrals, audit start/end dates, findings, total funds identified for recovery, amounts recovered to date, and case closure signatures.
DHS has onboarded additional licensing staff which has built increased capacity to conduct provider visits for the purpose of assessing compliance with health and safety requirements. Efforts to recruit additional staff continue. A visual tracker of provider visits will be utilized to ensure visits ...
DHS has onboarded additional licensing staff which has built increased capacity to conduct provider visits for the purpose of assessing compliance with health and safety requirements. Efforts to recruit additional staff continue. A visual tracker of provider visits will be utilized to ensure visits are conducted across all providers.
A Federal Grants Financial Analyst for CCDF program has been hired and is tasked with ensuring the accuracy and submission of financial reports. Additionally, a Director of Federal Grants has been added to oversee the reporting process. Internal controls have been established, requiring final review...
A Federal Grants Financial Analyst for CCDF program has been hired and is tasked with ensuring the accuracy and submission of financial reports. Additionally, a Director of Federal Grants has been added to oversee the reporting process. Internal controls have been established, requiring final review and approval by the supervisor with final approval by the CFO or designee. Additionally, an Audit and Compliance unit has been established. Once staffed, regular monitoring will occur within the various divisions.
DHS, has upgraded the child care database to more efficiently produce monthly vouchers without the historical connectivity disruptions that prevented an uninterrupted listing of provider vouchers and the associated subsidy payments. An independent audit will be conducted to verify processes, review ...
DHS, has upgraded the child care database to more efficiently produce monthly vouchers without the historical connectivity disruptions that prevented an uninterrupted listing of provider vouchers and the associated subsidy payments. An independent audit will be conducted to verify processes, review files and make recommendations. Additionally, An Audit and Compliance Unit has been established within the Fiscal Division. Staffing will include a program compliance monitor to work with the Child Care program to ensure compliance to Federal mandates.
To address the non-compliance related to the failure DHS will strengthen internal controls and governance oversight processes to ensure full compliance with Head Start Act requirements and Uniform Guidance. Specifically, DHS will: 1. Implement Monthly Financial Reporting • Develop and implement a st...
To address the non-compliance related to the failure DHS will strengthen internal controls and governance oversight processes to ensure full compliance with Head Start Act requirements and Uniform Guidance. Specifically, DHS will: 1. Implement Monthly Financial Reporting • Develop and implement a standardized process requiring monthly financial statements, including credit card expenditures, to be prepared and presented to both the Governing Board and Policy Council • Establish a recurring meeting schedule to ensure timely review • Maintain meeting minutes documenting review and approval 2. Establish Governance Training Program • Develop and implement an annual training plan for the governing body and Policy Council covering: • Financial statements and reporting • Roles and responsibilities under Head Start regulations • Oversight of Federal funds and internal controls • Maintain sign-in sheets, agendas, and training materials as documentation 3. Strengthen Audit Oversight Procedures • Require documented discussion in governing body meeting minutes demonstrating active monitoring and oversight to include: • Audit findings • Status of corrective actions
To address the non-compliance related to the failure to document and record the required Notices of Federal Interest (NFI) for facilities with major renovations, program management will implement the following corrective measures: 1. Immediate Remediation of Identified Facilities: The Program Admini...
To address the non-compliance related to the failure to document and record the required Notices of Federal Interest (NFI) for facilities with major renovations, program management will implement the following corrective measures: 1. Immediate Remediation of Identified Facilities: The Program Administrator conducted a review of the two facilities cited in the audit and took immediate steps to prepare and record the required Notices of Federal Interest in accordance with 45 CFR §§1303.46–1303.47. Documentation of recording in the appropriate jurisdiction was obtained and maintained in the official grant files. 2. Comprehensive Facilities Compliance Review: A full inventory and review of all facilities that have undergone purchase, construction, or major renovation using Head Start funds was conducted to ensure that all required NFIs are properly recorded. 3. Designation of Roles and Oversight Responsibility: Program Administrator will be assigned responsibility for ensuring compliance with all federal property requirements, including preparation, submission, and recordation of the NFI. A secondary level of review by senior management will be required to ensure accountability. 4. Training and Technical Assistance: Relevant program and fiscal staff will receive targeted training on Head Start facilities regulations (45 CFR Part 1303) and Uniform Guidance requirements, with emphasis on: o When an NFI is required o Proper preparation and recording procedures o Documentation and record retention requirements 5. Ongoing Monitoring and Internal Review: The development of an audit unit will perform periodic internal compliance reviews (at least annually) of facilities files to ensure adherence to federal requirements. Any issues identified will be addressed immediately to prevent recurrence.
DHS will: 1. Establish a Reporting Calendar and Tracking System: A comprehensive reporting calendar will be developed that clearly outlines all required federal reports (e.g., SF-429, SF-429A, SF-428 series), including submission deadlines. This calendar will be centrally maintained and shared with ...
DHS will: 1. Establish a Reporting Calendar and Tracking System: A comprehensive reporting calendar will be developed that clearly outlines all required federal reports (e.g., SF-429, SF-429A, SF-428 series), including submission deadlines. This calendar will be centrally maintained and shared with all relevant staff. Automated reminders will be implemented to ensure deadlines are met. 2. Assign Clear Roles and Responsibilities: Fiscal Analyst has been formally assigned responsibility for the preparation of each required report. Review and submission of the SF429 and 428 will be completed by the Program Administrator/designee. 3. Training and Capacity Building: Program staff will receive refresher training on federal reporting requirements, including timelines, documentation standards, and compliance expectations under 2 CFR §200.303 (Internal Controls). This will ensure a clear understanding of the importance of timely and accurate reporting. 4. Ongoing Monitoring and Compliance Review: The development of an audit unit will conduct periodic internal reviews (quarterly spot checks) to verify that reports are prepared and submitted timely. Any delays or issues identified will be addressed promptly to prevent recurrence. 5. Documentation and Record Retention: All submitted reports and supporting documentation will be retained in an organized, centralized filing system (electronically) to ensure accessibility for audit and monitoring purposes.
The Government concurs with the auditor’s findings and recommendations. Management will review current internal control procedures to determine if enhancements are needed. DHS is committed to ensuring compliance with Federal regulations and will take appropriate action as necessary. DHS will review ...
The Government concurs with the auditor’s findings and recommendations. Management will review current internal control procedures to determine if enhancements are needed. DHS is committed to ensuring compliance with Federal regulations and will take appropriate action as necessary. DHS will review and update its policies and procedures to ensure all non-payroll expenditures are approved by authorized personnel, provide staff training on proper approval processes and internal control requirements, and conduct periodic checks to monitor compliance and promptly address any exceptions.
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