Corrective Action Plans

Finding 395515 (2023-009)

Material Weakness 2023

AR

Questioned Costs Student Financial Aid Eligibility

Management concurs with this finding. The College will adhere to its policies, procedures, processes, and federal guidelines as it relates to calculating and awarding Pell. The College will return any ineligible funds accordingly. Responsible Administrators: Director of Financial Aid & Chief Fin...

Management concurs with this finding. The College will adhere to its policies, procedures, processes, and federal guidelines as it relates to calculating and awarding Pell. The College will return any ineligible funds accordingly. Responsible Administrators: Director of Financial Aid & Chief Financial Officer Effective: Immediately and ongoing

View Audit 305169 Questioned Costs: $1

Finding 395513 (2023-008)

Material Weakness 2023

Arkansas Baptist College

AR

Questioned Costs Student Financial Aid Eligibility

Management concurs with this finding. The College will adhere to its policies, procedures, processes, and federal guidelines as it relates to over awarding students. The College will return any ineligible funds accordingly. Responsible Administrators: Director of Financial Aid & Chief Financial ...

Management concurs with this finding. The College will adhere to its policies, procedures, processes, and federal guidelines as it relates to over awarding students. The College will return any ineligible funds accordingly. Responsible Administrators: Director of Financial Aid & Chief Financial Officer Effective: Immediately and ongoing

View Audit 305169 Questioned Costs: $1

Finding 395511 (2023-007)

Material Weakness 2023

Arkansas Baptist College

AR

Questioned Costs Student Financial Aid Procurement, Suspension & Debarment

Management concurs with this finding. The College will review and adhere to its practices, policies, and procedures along with federal guidelines as it relates to students meeting satisfactory academic progress. The College has an SAP appeal committee in place to enforce and abide by the College's...

Management concurs with this finding. The College will review and adhere to its practices, policies, and procedures along with federal guidelines as it relates to students meeting satisfactory academic progress. The College has an SAP appeal committee in place to enforce and abide by the College's policy. The College will return any ineligible funds accordingly. Responsible Administrators: Director of Financial Aid Effective: Immediately and ongoing

View Audit 305169 Questioned Costs: $1

Finding 395510 (2023-006)

Material Weakness 2023

Arkansas Baptist College

AR

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

Management concurs with this finding. The College will review and adhere to its practices, policies, and procedures along with federal guidelines as it relates to disbursing and administering federal aid. The College will return any ineligible funds accordingly. Responsible Administrators: Direct...

Management concurs with this finding. The College will review and adhere to its practices, policies, and procedures along with federal guidelines as it relates to disbursing and administering federal aid. The College will return any ineligible funds accordingly. Responsible Administrators: Director of Financial Aid, Chief Financial Officer & V.P. of Academic Affairs Effective: Immediately and ongoing

View Audit 305169 Questioned Costs: $1

Finding 395503 (2023-002)

Material Weakness 2023

Arkansas Baptist College

AR

Questioned Costs Student Financial Aid Eligibility

Management concurs with this finding. The College will keep accurate attendance and participation records. The College will calculate R2T4s accurately and will return the funds in a timely manner. The College will review and adhere to its practices, policies, and procedures along with federal gui...

Management concurs with this finding. The College will keep accurate attendance and participation records. The College will calculate R2T4s accurately and will return the funds in a timely manner. The College will review and adhere to its practices, policies, and procedures along with federal guidelines as it relates to R2T4 regulations. The College will return any ineligible funds accordingly. Responsible Administrators: Director of Financial Aid & Chief Financial Officer Effective: Immediately and ongoing

View Audit 305169 Questioned Costs: $1

Finding 395394 (2023-005)

Significant Deficiency 2023

Lancaster County Career and Technology Center

PA

Questioned Costs Subrecipient Monitoring Cash Management

The Center did not retain the eligibility documentation for one student and there was an incorrect computation for one student. Response and Planned Corrective Action: The Center acknowledges this finding, and will take the steps necessary to ensure that the information in the system is updated regu...

The Center did not retain the eligibility documentation for one student and there was an incorrect computation for one student. Response and Planned Corrective Action: The Center acknowledges this finding, and will take the steps necessary to ensure that the information in the system is updated regularly. Planned Corrective Action: to be implemented immediately. o The Director of Food Service will review the controls currently in place and revise accordingly to ensure that accuracy and completeness of data is maintained. o Proper documentation will be maintained by school staff and will be reviewed regularly by the Director of Food Services and or the Business Manager/Asst. Business Manager.

View Audit 305132 Questioned Costs: $1

Finding 395379 (2023-024)

Significant Deficiency 2023

State of Oregon

OR

Questioned Costs Allowable Costs / Cost Principles § 200.1 § 200.400

2023-024 Oregon Department of Human Services/Oregon Health Authority Strengthen review over direct costs charged to the program MANAGEMENT RESPONSE: We agree with this recommendation. The ODHS Office of Facilities Management coordinates care of a 168-building portfolio. Part of this work is coord...

2023-024 Oregon Department of Human Services/Oregon Health Authority Strengthen review over direct costs charged to the program MANAGEMENT RESPONSE: We agree with this recommendation. The ODHS Office of Facilities Management coordinates care of a 168-building portfolio. Part of this work is coordination of furniture reconfiguration, minor and major remodels of office spaces and other building maintenance work. For these projects we rely on program staff with understanding of their funding sources to provide us with accurate coding to support the project related costs. Our office does not work directly with funding source management only coding and billing. To better track who is providing us the coding and maintain a record of payment approval we have revised our workorder form to include who from the program is providing the coding and what authority they have to provide the coding. This will allow us to assure that important details are captured regarding funding application and coding for billing and protect from funds being drawn from sources that do not support and/or are not appropriate for a given project. The questioned costs of $3,849 were corrected and refunded to CMS using document BTCL1485 with a April 17, 2024 effective date. The refund will be reported on the Q3 FFY 2024 CMS 64 which will be submitted by June 30, 2024. Anticipated Completion Date: June 30, 2024 Contact person: Karuna Thompson, Construction and Facilities Maintenance Manager; Travis Labrum, Grant Accounting Manager

View Audit 305129 Questioned Costs: $1

Finding 395378 (2023-023)

Material Weakness 2023

State of Oregon

OR

Questioned Costs Eligibility Special Tests & Provisions

2023-023 Oregon Department of Human Services/Oregon Health Authority Improve documentation for provider eligibility determinations and revalidations MANAGEMENT RESPONSE: We agree with this recommendation. The authority will provide two separate training modules to enrollment staff and staff respo...

2023-023 Oregon Department of Human Services/Oregon Health Authority Improve documentation for provider eligibility determinations and revalidations MANAGEMENT RESPONSE: We agree with this recommendation. The authority will provide two separate training modules to enrollment staff and staff responsible for the CCO enrollment and validation regarding complete ownership and disclosure documents. We will perform the trainings on April 18, 2024, during our monthly staff meeting and a separate ownership form only training on May 30, 2024. The Office of Developmental Disability Services has implemented new contractual language for our fiscal intermediary to review I-9 for providers with stricter criteria. This was added earlier this year and is already in place in the contract and implemented. Further, upon enrollment, state staff are validating older I-9s for providers who have submitted their I-9 historically. The Office of Aging and People with Disabilities is committed to ensuring Provider Enrollment Agreements and accurate I-9 forms are on file and ensuring records are stored and retained properly for all Home Care Workers. The department will reinforce the requirements concerning the collection and storage of agreements at both the Quarterly Home Care Coordinators meeting on May 30, 2024, and at the AAA/APD Local Line Leadership meeting on May 16, 2024. The department will also create a reference guide in the new ODHS Field Business Procedure Manual implemented in February 2024. The department will make provider enrollment agreements and I-9 forms available statewide via DocuSign as an optional tool for state staff that guides them through accurately completing information on the form and capturing electronic signatures. This will ensure that all required fields in forms are filled out correctly including ensuring the presence of required documentation to mitigate human error. Additionally, we will continue to explore developing a training module for front office staff and office managers as well as a peer review process on business procedures and exploring ways that we can leverage technology such as the replacement Electronic Data Management System (EDMS) "Laserfiche" implemented by Imaging and Records Management Services (IRMS) to store provider records electronically. The questioned costs of $1,786 will be refunded to CMS and reported on the CMS 64 by 6/30/2024. Of note, the prior year finding with questioned costs of $1,843 has since been found as the provider being eligible. No corrective action is needed. Anticipated Completion Date: August 30, 2024 Contact person: Todd Howard, Business Operations Supervisor; Vanessa Richkind, Provider Administration Manager; Jennifer Stallsworth, Chief of Staff; Travis Labrum, Grant Accounting Manager

View Audit 305129 Questioned Costs: $1

Finding 395367 (2023-037)

Significant Deficiency 2023

State of Oregon

OR

Questioned Costs Allowable Costs / Cost Principles

2023-037 Department of Early Learning and Care Improve controls over payroll MANAGEMENT RESPONSE: We agree with this recommendation. DELC concurs with the findings with the following clarification: position descriptions are typically retained for employees even after they leave employment. Howev...

2023-037 Department of Early Learning and Care Improve controls over payroll MANAGEMENT RESPONSE: We agree with this recommendation. DELC concurs with the findings with the following clarification: position descriptions are typically retained for employees even after they leave employment. However, for the two employees referenced, we were unable to locate their position descriptions. DELC agrees with the stated recommendations and will take the following corrective action steps: • Human Resources will audit all DELC employee records to ensure that positions descriptions are signed, and in the employee’s Workday personnel file. • Human Resources will reiterate expectations to managers to ensure that timesheets are reviewed and approved by managers before the deadline each month. • Budget will monitor payroll charges to identify when time has been incorrectly charged. • DELC will reimburse the federal agency for the known unallowable costs. The anticipated completion date for having signed position descriptions for all DELC employees is December 31, 2024. The agency has already messaged to managers the expectations and importance of reviewing and approving employees time before the deadline each month and will continue to do so monthly prior to each deadline. Anticipated Completion Date: December 31, 2024 Contact person: Heather Thomas, Human Resources Manager; Connie Range, Fiscal Analyst

View Audit 305129 Questioned Costs: $1

Finding 395366 (2023-036)

Significant Deficiency 2023

State of Oregon

OR

Questioned Costs Allowable Costs / Cost Principles

2023-036 Department of Early Learning and Care Improve controls over family copay and child care hour calculations MANAGEMENT RESPONSE: We partially agree with this recommendation. DELC does not concur with the finding regarding a case with the copay amount not reflected in reimbursement between ...

2023-036 Department of Early Learning and Care Improve controls over family copay and child care hour calculations MANAGEMENT RESPONSE: We partially agree with this recommendation. DELC does not concur with the finding regarding a case with the copay amount not reflected in reimbursement between multiple providers. DELC sends out billing forms in advance of the month and providers are allowed to bill for anticipated hours of attendance. We do not require that the primary provider bill, nor can we retroactively reduce the secondary providers payment amount by the copay amount if the primary provider does not bill. DELC has the following language in our ruleset (5b) reflected below, which allows the copay to be zero if the provider to whom the copay is designated does not submit a billing for the month. 414-175-0051 Requirement to Make Copay or Satisfactory Arrangements 1) The Need Group must use a child care provider who meets the requirements in OAR 414-175-0080 and 414-175-0085. 2) The caretaker is responsible for paying the copayment to the primary provider of child care unless the Child Care Billing form was sent to the provider showing no copayment. 3) If the caretaker has only one provider during a month, that provider is the primary provider. If the caretaker uses more than one provider, the caretaker must designate one as the primary provider. Notwithstanding any designation by the caretaker, the Department considers a provider having the copayment amount (not to exceed the caretaker's established copayment amount) deducted from its valid billing statement the primary provider for that period. 4) If the copayment exceeds the amount billed by the primary provider, the Department may treat a different provider as the primary provider or split the copayment among the providers who bill for care. 5) The copayment amount due from the caretaker to the provider is the lesser of: a. The copayment amount determined by the Department based on family size and income. b. The total amount allowed by the Department on a provider claim. DELC does not concur with the finding regarding the overpayment for the months of January, February, and March when the parent changed providers. An overpayment referral was made to the Overpayment Writing Unit in the Oregon Department of Human Services when the new provider was set up. The provider in question did submit billing forms for payment for January, February, and March 2024. When the parent called in late March to end the previous provider, she gave the end date of 1/16/23. The provider was allowed to bill for absent days for the rest of January and the full month of February as absent days. The provider was unable to bill for March since it doesn’t not fall within OAR 414-175-0075 and is considered abandonment of care. DPU made an overpayment referral to the Overpayment Writing Unit when the new provider was set up. The provider was written up for an overpayment for March in the amount of $1,395.00. DELC concurs will all other findings in this area. DELC agrees with stated recommendations and will take the following corrective action steps: • The Child Care Assistance Program team will develop a training partially focused on error trends found in this report to educate staff on findings and preventative measures. • The Child Care Assistance Program team will provide case finding information to OPAR for recoupment purposes. • DELC will reimburse the federal agency for unallowable costs. Anticipated Completion Date: December 31, 2024 Contact person: Regina Siefert, Childcare Policy Analyst

View Audit 305129 Questioned Costs: $1

Finding 395365 (2023-035)

Significant Deficiency 2023

State of Oregon

OR

Questioned Costs Allowable Costs / Cost Principles

2023-035 Department of Early Learning and Care Use restricted indirect cost rate when required MANAGEMENT RESPONSE: We agree with this recommendation. DELC concurs with these findings; however, the findings are related to the indirect rate charged while the Early Learning Division was part of the...

2023-035 Department of Early Learning and Care Use restricted indirect cost rate when required MANAGEMENT RESPONSE: We agree with this recommendation. DELC concurs with these findings; however, the findings are related to the indirect rate charged while the Early Learning Division was part of the Oregon Department of Education. DELC will continue to work with the Oregon Department of Education to determine if any other indirect costs were incorrectly charged and will help make appropriate corrections to ensure federal grants were not overcharged. We will create processes and procedures to ensure expenditures are allowable before a federal draw is completed and that the correct indirect rate is charged. Anticipated Completion Date: December 31, 2024 Contact person: Natalie Day, Accounting Manager; Connie Range, Fiscal Analyst

View Audit 305129 Questioned Costs: $1

Finding 395354 (2023-017)

Significant Deficiency 2023

State of Oregon

OR

Questioned Costs Cash Management § 200.303

2023-017 Oregon Housing and Community Services Ensure review of federal cash draws are adequately documented to support the draws are for the immediate cash needs of the program MANAGEMENT RESPONSE: We agree with this recommendation. Additional training has been provided to new team members, to e...

2023-017 Oregon Housing and Community Services Ensure review of federal cash draws are adequately documented to support the draws are for the immediate cash needs of the program MANAGEMENT RESPONSE: We agree with this recommendation. Additional training has been provided to new team members, to ensure adequate documentation exists to support immediate cash needs. Two-step verification of all draws is also required. Refresher training has been provided to staff to ensure oversight is in place at all times. The funds inadvertently drawn were corrected the first week of March 2024. Anticipated Completion Date: June 20, 2024 Contact person: Dean Criscola, Controller

View Audit 305129 Questioned Costs: $1

Finding 395353 (2023-027)

Significant Deficiency 2023

State of Oregon

OR

Questioned Costs Special Tests & Provisions Eligibility

2023-027 Department of Human Services Improve controls to ensure eligibility criteria are met MANAGEMENT RESPONSE: We agree with this recommendation. The department previously submitted a work item (WI) to have a question in ONE that asks ‘yes/no’ if IEVS has been checked. The WI was approved and...

2023-027 Department of Human Services Improve controls to ensure eligibility criteria are met MANAGEMENT RESPONSE: We agree with this recommendation. The department previously submitted a work item (WI) to have a question in ONE that asks ‘yes/no’ if IEVS has been checked. The WI was approved and deployed into the system on April 17, 2024. The IEVS question will trigger and be required for TANF at certification, re-certification, and adding a person. The Quick Reference Guide for staff will be updated to reflect the new system functionality. Communication regarding the new system functionality will be provided to staff. The department previously submitted a change request (CR) to have the employability screening questions put into ONE as part of the TANF application/intake process. The CR has been approved and in final stages of design with the ONE system contractor, Deloitte. Once the WI is implemented into the system, the quick reference guide will be updated to reflect new system functionality. Communication regarding the new system functionality will be provided to staff. Anticipated Completion Date: December 31, 2024 Contact person: Xochitl Esparza, Program Administration Manager

View Audit 305129 Questioned Costs: $1

Finding 395352 (2023-026)

Significant Deficiency 2023

State of Oregon

OR

Questioned Costs Special Tests & Provisions Significant Deficiency

2023-026 Department of Human Services Improve controls relating to client not cooperating with child support requirements MANAGEMENT RESPONSE: We agree with this recommendation. The department previously identified the need for more training and has been taking steps to address the issue. Based o...

2023-026 Department of Human Services Improve controls relating to client not cooperating with child support requirements MANAGEMENT RESPONSE: We agree with this recommendation. The department previously identified the need for more training and has been taking steps to address the issue. Based on feedback from staff, the Child Support Quick Reference Guide has been updated to make it more user friendly and easier to follow. Training on processing child support tasks has been provided both statewide alongside Department of Child Support in November 2023 and with individual districts. In addition to materials and training, department policy is working reports of both outstanding child support tasks and tasks cleared without processing. The department continues to monitor the reports and provide follow up guidance to individual branches. The department has developed a take time for training (TT4T) that was delivered to staff on May 4, 2022, which is now outdated. The current TT4T will be removed, a new one will be created, and delivered to staff within the next 120 days. The department will also consider adding this material to the regional accuracy and timeliness training during the summer of 2024. The Oregon Eligibility Partnership (OEP) -Learning and Engagement Team (LET) reviewed the eligibility guide and will be revising materials within the next 120 days. OEP will review and revise the current lesson plan delivered to staff within the next 90 days. Anticipated Completion Date: September 30, 2024 Contact person: Xochitl Esparza, Program Administration Manager

View Audit 305129 Questioned Costs: $1

Finding 395339 (2023-032)

None 2023

State of Oregon

OR

Questioned Costs Allowable Costs / Cost Principles

2023-032 Oregon Commission for the Blind Seek clarification from federal awarding agency on appropriateness of legal fees MANAGEMENT RESPONSE: We agree with this recommendation. The agency believes it is allowable to use VR funds for legal fees based upon the guidance provided by 2 CFR § 200.459,...

2023-032 Oregon Commission for the Blind Seek clarification from federal awarding agency on appropriateness of legal fees MANAGEMENT RESPONSE: We agree with this recommendation. The agency believes it is allowable to use VR funds for legal fees based upon the guidance provided by 2 CFR § 200.459, which allows for professional service costs. The agency has previously asked for clarification regarding this issue from the Rehabilitation Services Administration, and we are awaiting their response. We will contact them again requesting clarification. The completion date for this finding is dependent upon receipt of clarification and guidance from the Rehabilitation Services Administration. Anticipated Completion Date: December 31, 2024 Contact person: Dacia Johnson, Executive Director

View Audit 305129 Questioned Costs: $1

Finding 395337 (2023-030)

Significant Deficiency 2023

State of Oregon

OR

Questioned Costs Allowable Costs / Cost Principles Significant Deficiency

2023-030 Department of Human Services Strengthen controls over payroll expenditures MANAGEMENT RESPONSE: We disagree with this finding. This finding pertained to two State Independent Living Council (SILC) board members paid with VR Innovation & Expansion funding. Upon review of the Rehabilitati...

2023-030 Department of Human Services Strengthen controls over payroll expenditures MANAGEMENT RESPONSE: We disagree with this finding. This finding pertained to two State Independent Living Council (SILC) board members paid with VR Innovation & Expansion funding. Upon review of the Rehabilitation Act and 34 CFR 361.35 section (a) part (2), funding may be used “To support the funding of the State Rehabilitation Council, if the State has a Council, consistent with the resource plan identified in § 361.17(i) “ The SILC State Plan cover 2021-2023 references Innovation and Expansion funding on pages 5 and 6. Based on the department’s review we believe the VR funding used is appropriate and that no further corrective action is required. Anticipated Completion Date: N/A Contact person: Keith Ozols, Vocational Rehabilitation Services Director

View Audit 305129 Questioned Costs: $1

Finding 395336 (2023-029)

Material Weakness 2023

State of Oregon

OR

Questioned Costs Allowable Costs / Cost Principles Material Weakness

2023-029 Department of Human Services Strengthen controls over program expenditures MANAGEMENT RESPONSE: We agree with this recommendation. Questioned costs consist of facility payments totaling $139 and a separate payment which exceeded costs of client services by $10. The agency agrees with th...

2023-029 Department of Human Services Strengthen controls over program expenditures MANAGEMENT RESPONSE: We agree with this recommendation. Questioned costs consist of facility payments totaling $139 and a separate payment which exceeded costs of client services by $10. The agency agrees with the finding and will refund those questioned costs. The agency will review the specific circumstances for each of the invoices paid to ensure staff receive the appropriate training as well as reiterate the need to review invoices carefully according to current policies and practices to avoid coding errors. Anticipated Completion Date: June 30, 2024 Contact person: Keith Ozols, Vocational Rehabilitation Services Director

View Audit 305129 Questioned Costs: $1

Finding 395332 (2023-045)

None 2023

State of Oregon

OR

Questioned Costs Subrecipient Monitoring § 200.332 § 200.501

2023-045 Oregon Housing and Community Services Obtain documentation to support expenditures or pursue cost recovery MANAGEMENT RESPONSE: We agree with this recommendation. OHCS is in the process of coordinating with agencies and contractor to resolve any outstanding compliance concerns. Expenses ...

2023-045 Oregon Housing and Community Services Obtain documentation to support expenditures or pursue cost recovery MANAGEMENT RESPONSE: We agree with this recommendation. OHCS is in the process of coordinating with agencies and contractor to resolve any outstanding compliance concerns. Expenses may be considered mitigated if documentation to support the questioned cost is obtained, or if agency is able to clarify policy and procedure to support existing documentation. If expenditure is not resolved and is identified as non-compliant with federal requirements, OHCS may pursue cost recovery. Anticipated Completion Date: July 31, 2024 Contact person: Liz Weber, Chief Policy Officer

View Audit 305129 Questioned Costs: $1

Finding 395329 (2023-039)

Significant Deficiency 2023

State of Oregon

OR

Questioned Costs Allowable Costs / Cost Principles § 200.413

2023-039 Oregon Health Authority Ensure program payroll costs are incurred only for program staff MANAGEMENT RESPONSE: We agree with this recommendation. WIC Leadership is dedicated to reviewing and integrating existing reports into their time review process and will also ensure that staff respon...

2023-039 Oregon Health Authority Ensure program payroll costs are incurred only for program staff MANAGEMENT RESPONSE: We agree with this recommendation. WIC Leadership is dedicated to reviewing and integrating existing reports into their time review process and will also ensure that staff responsible for employee time approval have been adequately trained on how to use those reports and features in Workday to review time. Questioned costs will be refunded. Anticipated Completion Date: September 30, 2024 Contact person: Tiare Sanna, Public Health Manager

View Audit 305129 Questioned Costs: $1

Finding 395290 (2023-065)

Significant Deficiency 2023

State of Rhode Island

RI

Questioned Costs Allowable Costs / Cost Principles Eligibility

Finding 2023-065 – Corrective Action Plan 2023-065a – EOHHS and DCYF have been working with St. Mary's on the submission of the SFY 23 cost report which EOHHS needs in order to set a FY 23 rate pursuant to the State Plan and reprice the previously paid claims. EOHHS has provided extensive support ...

Finding 2023-065 – Corrective Action Plan 2023-065a – EOHHS and DCYF have been working with St. Mary's on the submission of the SFY 23 cost report which EOHHS needs in order to set a FY 23 rate pursuant to the State Plan and reprice the previously paid claims. EOHHS has provided extensive support on allocation methodology and requirements to which St. Mary's must adhere in order to meet State Plan requirements. Once aligned with the SPA that was approved in July of 2023 for SFYs 23 and 24, EOHHS will prospectively establish rates to remain compliant with the approved methodology. Anticipated Completion Date: June 30, 2024 2023-065b – EOHHS requires that St. Mary's direct bill through the MMIS and the facility began billing in October 2023. EOHHS and DCYF are currently working on a plan to ensure all allowable medical services provided by DCYF providers are directly billed to the MMIS. Anticipated Completion Date: July 1, 2025 Contact Person: Dezeree Hodish, Assistant Director, Financial & Contract Management, Executive Office of Health & Human Services dezeree.hodish@ohhs.ri.gov

View Audit 305097 Questioned Costs: $1

Finding 395289 (2023-064)

Material Weakness 2023

State of Rhode Island

RI

Questioned Costs Eligibility Cash Management

Finding 2023-064 – Corrective Action Plan 2023-064a – Death reporting: Permanent system fix will deploy 28 June 2024; enhancement will trigger a 1A code from RI Bridges to send date of death to MMIS when date of death is added on a case with closed eligibility. This fix should remedy audit finding...

Finding 2023-064 – Corrective Action Plan 2023-064a – Death reporting: Permanent system fix will deploy 28 June 2024; enhancement will trigger a 1A code from RI Bridges to send date of death to MMIS when date of death is added on a case with closed eligibility. This fix should remedy audit finding plus financial impact in the MMIS when members are not closed properly. Anticipated Completion Date: June 28, 2024 2023-064b – Death reporting addressed in response to 2023-064a. Residency/Out of State: State resumed PARIS residency verifications and is pursuing secondary residency checks with Accruint/Lexis Nexis data and automation of manual NCOA database verification process. Additionally, State will benefit from future use of The Work Number Employee Address data to verify residency. Anticipated Completion Date: August 1, 2024 Contact Person: Brian Tichenor, RIBridges Medicaid Administrator, Executive Office of Health & Human Services brian.tichenor@ohhs.ri.gov 2023-064c – EOHHS will identify and return any potential ineligible costs by end of the current Federal Fiscal Year (FFY). Anticipated Completion Date: September 30, 2024 Contact Person: Allison Shartrand, Assistant Director, Financial & Contract Management, Executive Office of Health & Human Services allison.shartrand@ohhs.ri.gov

View Audit 305097 Questioned Costs: $1

Finding 395267 (2023-060)

Material Weakness 2023

State of Rhode Island

RI

Questioned Costs Special Tests & Provisions Eligibility

Finding 2023-060 – Corrective Action Plan Rhode Island Medicaid’s Provider Enrollment project went live on 2/01/2024. Any provider that isn’t screened and enrolled with the State Medicaid Agency will have claims deny. Additionally, MCOs have terminated providers in their network who are not scree...

Finding 2023-060 – Corrective Action Plan Rhode Island Medicaid’s Provider Enrollment project went live on 2/01/2024. Any provider that isn’t screened and enrolled with the State Medicaid Agency will have claims deny. Additionally, MCOs have terminated providers in their network who are not screened and redirected members to fully screened and enrolled providers. Rhode Island Medicaid continues to work with its fiscal agent and MMIS contractor, Gainwell Technologies, to ensure all edits are systematic. Anticipated Completion Date: Implemented February 1, 2024 Contact Persons: Kimberly Tebow, Senior Medical Care Specialist, Executive Office of Health & Human Services kimberly.tebow@ohhs.ri.gov Chantele Rotolo, Assistant Administrator for Family & Children Services, Executive Office of Health & Human Services chantele.rotolo@ohhs.ri.gov

View Audit 305097 Questioned Costs: $1

Finding 395265 (2023-058)

Significant Deficiency 2023

State of Rhode Island

RI

Questioned Costs Allowable Costs / Cost Principles

Finding 2023-058 – Corrective Action Plan EOHHS has hired an additional FTE to help support Medicaid Admin claiming. This FTE will document policies and procedures for reporting on the CMS-64 as well as the Cost Allocation Plan Reconciliation process to RIFANS. Cross-training is a goal across thr...

Finding 2023-058 – Corrective Action Plan EOHHS has hired an additional FTE to help support Medicaid Admin claiming. This FTE will document policies and procedures for reporting on the CMS-64 as well as the Cost Allocation Plan Reconciliation process to RIFANS. Cross-training is a goal across three different employees that way there is no delay in reporting/reconciliation. Internal controls will be strengthened with the addition of the staff support Central Management now has. Further, BHDDH concurs with this finding. During SFY 2024, BHDDH added staffing to the Medicaid Admin reconciliation and reporting process, staff have identified prior period corrections to be processed, and implemented reporting requirements as updated by OHHS in January 2024. By June 2024, written policies and procedures will be adopted. Anticipated Completion Date: July 31, 2024 Contact Person: Victoria Pavao, Assistant Director, Financial & Contract Management, Executive Office of Health & Human Services victoria.pavao@ohhs.ri.gov

View Audit 305097 Questioned Costs: $1

Finding 395264 (2023-057)

Material Weakness 2023

State of Rhode Island

RI

Questioned Costs Eligibility Cash Management

Finding 2023-057 – Corrective Action Plan 2023-057a – Residency/Out of State: Rhode Island resumed PARIS residency verifications and is pursuing secondary residency checks with Accruint/Lexis Nexis data and automation of manual NCOA database verification process. Additionally, the State will benef...

Finding 2023-057 – Corrective Action Plan 2023-057a – Residency/Out of State: Rhode Island resumed PARIS residency verifications and is pursuing secondary residency checks with Accruint/Lexis Nexis data and automation of manual NCOA database verification process. Additionally, the State will benefit from future use of The Work Number Employee Address data to verify residency. Income/Wage Validation: EOHHS completed implementation of an interface on 23 March 2024 between The Work Number (TWN) and RI Bridges. Contract and budget actions for TWN services are in progress with a goal of initiating TWN wage verifications in July-August 2024. Anticipated Completion Date: September 1, 2024 2023-057b – EOHHS will return any potential ineligible costs by end of the Federal Fiscal Year (FFY). Anticipated Completion Date: September 30, 2024 Contact Person: Brian Tichenor, RIBridges Medicaid Administrator, Executive Office of Health & Human Services brian.tichenor@ohhs.ri.gov

View Audit 305097 Questioned Costs: $1

Finding 395256 (2023-056)

Material Weakness 2023

State of Rhode Island

RI

Questioned Costs Subrecipient Monitoring Eligibility

Finding 2023-056 – Corrective Action Plan Management agrees with the finding. Regulation 4.5.1, RIW approved families are categorically eligible for CCAP services when they have an acceptable need for services related to fulfilling RIW program requirements. The determination of employment plan com...

Finding 2023-056 – Corrective Action Plan Management agrees with the finding. Regulation 4.5.1, RIW approved families are categorically eligible for CCAP services when they have an acceptable need for services related to fulfilling RIW program requirements. The determination of employment plan components including any combination of education and work-related activities in the approved plan are determined by RIW Regulations, section 2.11. The need for services in an RIW CCAP case is based on the employment plan. In situations where an applicant parent does not comply with the RIW employment plan, CCAP services would not be approved. Once CCAP services are approved based on an employment plan for an RIW recipient, the approval is for a 12-month certification period and would not be terminated, per ACF federal requirements, for a subsequent change in employment plan participation or change in income (unless in excess of 85% SMI). It should be noted that in all cases, the decortications were documented in Bridges. CCAP training has also been enhanced in many ways. CCAP training is delivered along with RIW training on a bi-monthly basis for new hires and/or existing ETs The CCAP training module was revised to include topics specific to improper payments. Office of Child Care also holds monthly CCAP office hours for operations staff to connect with program admins, policy and training specialist to answer/troubleshoot questions from the field. Monthly analysis by error type now includes location and worker ID for analysis of more targeted training. DHS also continues to look at system and process improvements. Weekly CCAP theme meetings are ongoing to identify and solution Bridges related incidents. The CCAP Regulations have been reviewed and were opened Q1 2024 for policy updates to streamline and simplify verification processes where possible. Anticipated Completion Date: July 1, 2024 Contact Person: Nicole Chiello, Assistant Director – Office of Child Care, Department of Human Services nicole.chiello@dhs.ri.gov

View Audit 305097 Questioned Costs: $1

Corrective Action Plans

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