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2022-056 Department of Human Services/Oregon Health Authority Return questioned costs related to 2019-014 audit finding Federal Awarding Agency: U.S. Department of Health and Human Services Assistance Listing Number and Name: 93.777 and 93.778 Medicaid Cluster Federal Award Numbers and Years: 18...
2022-056 Department of Human Services/Oregon Health Authority Return questioned costs related to 2019-014 audit finding Federal Awarding Agency: U.S. Department of Health and Human Services Assistance Listing Number and Name: 93.777 and 93.778 Medicaid Cluster Federal Award Numbers and Years: 1805OR5MAP, 2018; 1805OR5ADM, 2018; 1905OR5MAP, 2019; 1905OR5ADM, 2019 Compliance Requirement: Activities Allowed or Unallowed; Allowable Costs/Cost Principles Type of Finding: Noncompliance Prior Year Finding: 2019-014 Questioned Costs: $348,080 (known) Criteria: 42 CFR 433.32(a); 42 CFR 433.312(a); 42 CFR 447.45(f)(1)(iv) During our testing for the fiscal year 2019 we noted that the MMIS data tables did not agree to the rates established by CMS for 2 procedures codes. Using incorrect rates resulted in an overpayment of $348,080 to providers. This overpayment was first reported in the fiscal year-end June 30, 2019, Secretary of State audit report number 2020-14, finding number 2019-014. As of January 1, 2020, management updated the MMIS data tables to ensure all future provider payments were made at the correct rate. Additionally, management updated control procedures to ensure MMIS data tables are updated timely and accurately. However, as of May 1, 2023, the overpayment to providers has not been collected, federal funds have not been returned, and the planned repayment method has not been approved by CMS. Per authority management they plan to let these overpayments run through their cost settlement process which would be an unusual method to return federal funds. We recommend authority management reimburse the federal agency for unallowable costs. MANAGEMENT RESPONSE: We agree with this recommendation. As indicated in the report and as of January 1, 2020, authority management updated the MMIS data tables to ensure all future provider payments were made at the correct rate. Additionally, authority management updated control procedures to ensure MMIS data tables are updated timely and accurately. The recoupment of funds paid for incorrect rates will be completed through the FFS cost settlement process. We expect to have this completed on or before June 30, 2024. We will evaluate the use of alternate recoupment processes in the event of future corrections. Anticipated Completion Date: June 30, 2024 Contact: Mick Mitchell, Business Operations Manager
View Audit 45093 Questioned Costs: $1
Finding 47823 (2022-055)
Significant Deficiency 2022
2022-055 Department of Human Services/Oregon Health Authority Strengthen review over direct costs charged to the program Federal Awarding Agency: U.S. Department of Health and Human Services Assistance Listing Number and Name: 93.777 and 93.778 Medicaid Cluster Federal Award Numbers and Years: 2...
2022-055 Department of Human Services/Oregon Health Authority Strengthen review over direct costs charged to the program Federal Awarding Agency: U.S. Department of Health and Human Services Assistance Listing Number and Name: 93.777 and 93.778 Medicaid Cluster Federal Award Numbers and Years: 2105OR5MAP, 2021; 2105OR5ADM, 2021; 2205OR5MAP, 2022; 2205OR5ADM, 2022 Compliance Requirement: Activities Allowed or Unallowed; Allowable Costs/Cost Principles Type of Finding: Significant Deficiency; Noncompliance Prior Year Finding: N/A Questioned Costs: $47,942 (known) Criteria: 2 CFR 200.1(1); 2 CFR 200.400(a); 2 CFR 200.404; 42 CFR ? 433.32(a) Federal regulations only allow the Medicaid program to charge allowable program expenditures at the federal financial participation rate for various program costs at the time of payment for services provided. The Department of Human Services (department) and the Oregon Health Authority (authority) make payments to vendors other than providers through the state?s accounting system. We judgmentally selected payments to 28 vendors for our review. We identified the following 2 errors, which were not identified during their review process, that resulted in improper payment of Medicaid expenditures: Payments to one vendor charged expenditures related to a specific project unrelated to the Medicaid program, resulting in known federally funded questioned costs of $1,361. For one payment management was unable to provide a contract or support for bids collected for the project charged to the Medicaid program, resulting in known federally funded questioned costs of $46,581. The above issues occurred due to human error and inadequate record maintenance which could lead to unallowed activities/costs being charged to the Medicaid program. We recommend department and authority management strengthen controls over review to ensure transactions are adequately supported and reviewed. Additionally, we recommend the authority reimburse the federal agency for unallowable costs. MANAGEMENT RESPONSE: We agree with this recommendation. ODHS Facilities Management Response for Finding #1: The Office of Facilities Management (OFM) is committed to providing accurate coding for payments. Communications have been made with staff responsible for coding invoices and the need to conduct thorough reviews to ensure coding is accurate and charged to the appropriate funding source for the goods or services the agency is being invoiced for. OFM will be communicating with the programs that provide coding to confirm that the information provided appropriately aligns with the intended use of the funds. The department will review current processes and forms to ensure there is sufficient detail to verify accuracy. Questioned costs of $1,361 in Federal Funds (and $2,722 in Total Funds) paid with invoice number VP815455, was corrected on 4/26/2023 with document BTCL1412. ODHS, Aging and People with Disabilities (APD) Response for Finding #2: The department is committed to storing and retaining supporting documentation for all authorized payments. The processes and procedures on contract bidding and approval associated with payment authorization for 1915k services and support are being reviewed and improvements such as central repositories are being explored. Once analysis and improvements are complete, they will be documented and communicated to staff within the department and to the Office of Financial Services for awareness. Additionally, as part of succession plan development, the department will create intentional opportunities for knowledge transfer, shared document storage, and increased transparency amongst work teams, which will assist with document location in the context of unexpected personnel changes. The department will reimburse the federal agency for any unallowable costs. Anticipated Completion Date: June 30, 2024 Contact: Jennifer Stallsworth, Chief of Staff or David Hawkins, Construction and Facility Maintenance Manager
View Audit 45093 Questioned Costs: $1
2022-042 Oregon Health Authority Ensure expenditures of federal funds are for allowed activities Federal Awarding Agency: U.S. Department of Health and Human Services Assistance Listing Number and Name: 93.958 Block Grants for Community Mental Health Services Federal Award Numbers and Years: ...
2022-042 Oregon Health Authority Ensure expenditures of federal funds are for allowed activities Federal Awarding Agency: U.S. Department of Health and Human Services Assistance Listing Number and Name: 93.958 Block Grants for Community Mental Health Services Federal Award Numbers and Years: 1B09SM083823, 2021 Compliance Requirement: Activities Allowed or Unallowed Type of Finding: Material Weakness; Material Noncompliance Prior Year Finding: N/A Questioned Costs: $525,272 (known) Criteria: 42 USC 300x-5(a)(3) Mental Health Block Grant (MHBG) funds may not be expended on the purchase, construction, or permanent improvement of any building or other facility other than minor remodeling. Substance Abuse and Mental Health Services Administration?s (SAMHSA) standard funding restriction guidance defines minor alterations and renovations as the lesser of 25% of the budget period or $150 thousand. Additionally, all minor alterations and renovations must be approved by SAMHSA. During our testing of MHBG subrecipient contracts entered into during state fiscal year 2022, we noted one contract included payment for the remodeling of an existing building owned by the subrecipient. A payment of $525,272 was processed in December 2021 for the remodeling expenses as specified in the contract's payment provisions. However, this amount exceeds SAMHSA's threshold for minor alterations and renovations and is not allowed under the MHBG. We recommend department management ensure controls are properly designed and implemented to record only allowable expenditures to the MHBG. We further recommend department management seek SAMHSA approval for minor alterations and renovations. MANAGEMENT RESPONSE: We agree with this recommendation. OHA intended to have an interagency agreement with ODHS to co-fund an improvement to a much-needed treatment facility for children. OHA submitted the payment per our agreement with the vendor with the expectation that ODHS would fund the non-SAMHSA allowable expenses. The vendor used the funds for minor safety related renovations as one would expect them to prioritize before programmatic costs. But unfortunately, the ODHS payment was never made to OHA which prevented any additional funds from being sent to the vendor. Then, pandemic constraints along with a lack of funding prevented the vendor from being able to finalize their plan in the initial time frame. OHA sought a legal review, and the recommendation was made to cleave the contract from ODHS and allow the vendor additional time to finish their work. Upon cleaving the contract, the elements that OHA knows to be unallowable for SAMHSA funding were left in the contract because the contractor had already performed the work. OHA is awaiting a final review of expenditure reports and will request SAMHSA approval if warranted or adjust funding codes as needed to align with SAMHSA allowable charges. Anticipated Completion Date: September 30, 2023 Contact: Sarah Adelhart, Interim Manager
View Audit 45093 Questioned Costs: $1
Finding 47805 (2022-058)
Significant Deficiency 2022
2022-058 Department of Human Services Perform timely reconciliations of refinanced OR-Kids transactions Federal Awarding Agency: U.S. Department of Health and Human Services Assistance Listing Number and Name: 93.667 Social Services Block Grant Federal Award Numbers and Years: 2101ORSOSR, 2021; 22...
2022-058 Department of Human Services Perform timely reconciliations of refinanced OR-Kids transactions Federal Awarding Agency: U.S. Department of Health and Human Services Assistance Listing Number and Name: 93.667 Social Services Block Grant Federal Award Numbers and Years: 2101ORSOSR, 2021; 2201ORSOSR, 2022 Compliance Requirement: Period of Performance Type of Finding: Significant Deficiency; Noncompliance Prior Year Finding: N/A Questioned Costs: $1,308,457 (likely) Criteria: 42 USC 1397a(c); 45 CFR 75.386a(2); 45 CFR 96.30b(2) According to federal requirements, to be eligible for federal funding, expenditures must be expended in the fiscal year allotted or in the succeeding fiscal year (period of performance). Additionally, federal post-closeout requirements stipulate the return of any funds due because of later refunds, corrections, or other transactions. As part of the grant closeout process, block grants also require the grantees to report the total funds expended and the date of the last expenditure. Grant closeout is the process by which the federal awarding agency determines that all applicable administrative actions and all required work have been completed. Social Services Block Grant (SSBG) has expenditures originating from the child welfare system, OR-Kids. OR-Kids is used to manage placements, eligibility, payments, and other case information. When various corrections are initiated, OR-Kids can re-process transactions as far back as January 1, 2008. For some placement corrections, OR-Kids processed the recovery of the funds in a state grant (Miscellaneous Other Fund grant), instead of the federal grant. To date, the department has not completed permanent fixes to the OR-Kids system to prevent these re-processing errors from occurring. During fiscal year 2022, the department was reconciling the Miscellaneous Other Fund grant and identified refunds related to SSBG. The refinanced expenditures reduced the amount of SSBG expenditures originally reported in closed grant awards. Instead of submitting a refund, the department identified expenditures recorded in subsequent grants that could have been used to backfill the reduction of expenditures. Allowable expenditures, that met the period of performance, were subsequently moved. To illustrate, a total of $1.3 million of expenditures were moved in the accounting system from grant award 21 (federal fiscal year 2021) to grant award 20. The department then moved expenditures totaling $1.2 million from grant award 20 to grant award 19. This process continued for all grant awards going back to grant award 11 (federal fiscal year 2011). The table below illustrates the movement of expenditures between grant awards. ?See Corrective Action Plan for Table? Although the department only moved expenditures that qualified for each respective period of performance, we question whether the federal awarding agency would allow the department to backfill the $1.3 million of expenditures in question after grant closeout had been completed. We recommend department management conduct more timely reconciliations of OR-Kids refinancing adjustments to ensure adjustments are made during the related periods of performance. We further recommend management work with its federal awarding agency to determine if it is appropriate to backfill program expenditures between grants to account for the reduction in expenditures created by the reconciliation process. If not appropriate, the questioned costs should be repaid to the federal awarding agency. MANAGEMENT RESPONSE: The agency disagrees with this finding. SFMA grant phase is an internal tracking mechanism only and is not mandated by ACF. None of the expenditures observed were moved into or out of the period of performance for which they originally qualified for. SSBG awards have a two-year period of performance for claiming. As a result, there is an overlap between internal phases where expenditures qualify for two at any given time. Assignment of phase in SFMA is based on internal balancing needs to ensure claiming is not over or under the award for that period. Prior period adjustments occur periodically and are debited or credited to the phase they were originally recorded under. Should those adjustments cause a phase to become under or over reported, the assigned phase in SFMA is adjusted to maintain consistency between SFMA expenditures and the SF-425 report provided to ACF. If a prior period increasing expenditure is outside the period of performance, it is moved to non-reportable and state only funding. Anticipated Completion Date: N/A Contact: Fariborz Pakseresht, Oregon Department of Human Services Director
View Audit 45093 Questioned Costs: $1
Finding 47798 (2022-040)
Significant Deficiency 2022
2022-040 Department of Human Services Improve controls to ensure eligibility criteria are met Federal Awarding Agency: U.S. Department of Health and Human Services Assistance Listing Number and Name: 93.558 Temporary Assistance for Needy Families Federal Award Numbers and Years: 2021G996115, ...
2022-040 Department of Human Services Improve controls to ensure eligibility criteria are met Federal Awarding Agency: U.S. Department of Health and Human Services Assistance Listing Number and Name: 93.558 Temporary Assistance for Needy Families Federal Award Numbers and Years: 2021G996115, 2021; 2022G996115, 2022 Compliance Requirement: Eligibility Type of Finding: Significant Deficiency, Noncompliance Prior Year Finding: N/A Questioned Costs: $9,569 (known); $931,750 (likely) Criteria: 45 CFR 264.1; Oregon TANF State Plan The State of Oregon Temporary Assistance for Needy Families (TANF) State Plan (Plan) defines financial neediness criteria with its adjusted income limit tables. Federal regulations establish 60 cumulative months as the length of time a client may receive federal TANF assistance. The department uses its case management system, Oregon Eligibility (ONE), to count federal-eligible benefit months, and when 60 months is reached, an indicator is sent to the financial subsystem to change federal funding to state funding. From a population of 105,267 TANF benefit payments recorded in ONE, we randomly selected a sample of 40 and two additional individually significant payments for testing. We found: One sample?s financial eligibility information included a disaster relief benefit without details showing the date of payment and the covered time period. As a result, auditors and the department are unable to determine if this case met financial eligibility criteria, resulting in questioned costs of $1,311. One individually significant case?s child support and spousal support were entered incorrectly into ONE. The countable income at time of certification did not meet the adjusted income limit, making the client ineligible for TANF benefits. Questioned costs for this case total $8,258. We recommend department management ensure federally-funded client benefits are paid on behalf of eligible individuals, and documentation is retained to support eligibility decisions. We also recommend department management correct the identified error cases and reimburse the federal agency for questioned costs. MANAGEMENT RESPONSE: We agree with this recommendation. The Department will communicate to eligibility staff the importance of reviewing information reported by the applicant compared to information received from a third-party and direct staff to case note in the ONE system how the discrepancy was reconciled. The Department will also communicate the requirement to maintain eligibility records in both case notes and electronic file when applicable. The Department will review the cases cited and make an appropriate referral to the Overpayment Recovery Unit. Overpayments recouped can then be adjusted by Office of Financial Services to credit the TANF federal grant rather than reimbursing, per instructions outlined in TANF-ACF-PI-2006-03. Anticipated Completion Date: October 31, 2023 Contact: Annette Palmer, TANF Program Manager
View Audit 45093 Questioned Costs: $1
2022-035 Department of Human Services Improve controls over benefit time tracking and discontinuance of federal funding Federal Awarding Agency: U.S. Department of the Treasury Assistance Listing Number and Name: 93.558 Temporary Assistance for Needy Families Federal Award Numbers and Years: 202...
2022-035 Department of Human Services Improve controls over benefit time tracking and discontinuance of federal funding Federal Awarding Agency: U.S. Department of the Treasury Assistance Listing Number and Name: 93.558 Temporary Assistance for Needy Families Federal Award Numbers and Years: 2021G996115, 2021; 2022G996115, 2022 Compliance Requirement: Allowable Costs/Cost Principles Type of Finding: Material Weakness; Noncompliance Prior Year Finding: N/A Questioned Costs: $1,866 known Criteria: 45 CFR 264.1 Federal regulations prohibit federal funding to families that include an adult head-of-household who has received federal assistance for a cumulative of 60 months, and who do not have an allowed exception. The Oregon Department of Human Services? (department) case management system, Oregon Eligibility (ONE), tracks months counting towards the federal limit. When 60 months is reached, ONE sends an indicator to the financial subsystem containing funding coding. If Temporary Assistance for Needy Families (TANF) benefits continue, they are to be funded with state funds. The population of cases identified in ONE as having reached 60 cumulative federal months is obtained from the quarterly performance data reports compiled by a service provider. As stated in a separate finding, titled `Ensure performance data reports are complete and accurate,? we determined the data reports are not complete or accurate, therefore, the population of cases over 60 federal months is also incomplete. However, we tested some cases in the reports to verify ONE was accurately counting federal months and to determine if federal funding was appropriately discontinued. We randomly selected ten cases from an incomplete population of 3,193 and found one case where federal funding inappropriately continued after reaching 60 months due to a coding issue within the financial subsystem, resulting in federal overpayments of $1,944 for recurring monthly cash assistance benefits, and $1,866 for expenses related to seeking employment (JOBS) in fiscal year 2022. The department was aware of the cash assistance coding issue and the JOBS coding issue as early as October 2021. A $5.6 million correction for regular cash assistance was made in accounting records in September 30, 2022, which corrected the cash assistance benefits portion of the error noted above. The JOBS coding issue has yet to be corrected in accounting records and the department did not have an adjustment total readily available. As the regular cash assistance correction surpassed $5 million, we have reasonable assurance that the uncorrected federal JOBS payments also exceed $25,000 in likely questioned costs. We recommend department management make timely corrections to federal/state coding splits in the financial subsystem and also make timely corrections in state accounting records. We also recommend the department reimburse the federal agency for unallowable costs. MANAGEMENT RESPONSE: We agree with this recommendation. The Department will analyze and identify the missing indicators sent from ONE to the financial subsystems to determine the correct funding stream. The Strategic Systems Unit will put together a TANF funding matrix to be approved by program. Indicators will be corrected through a system defect, a Work Item, or Change Request, depending on the Level of effort to resolve. Financial adjustments will be made by Office of Financial Services to credit the TANF federal grant rather than reimbursing, per instructions outlined in TANF-ACF-PI-2006-03. Anticipated Completion Date: December 31, 2023 Contact: Annette Palmer, TANF Program Manager
View Audit 45093 Questioned Costs: $1
Finding 47790 (2022-052)
Significant Deficiency 2022
2022-052 Oregon Health Authority Improve review of expenditure transactions Federal Awarding Agency: U.S. Department of Health and Human Services Assistance Listing Number and Name: 93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (COVID-19) Federal Award Numbers and Years: 6 NU...
2022-052 Oregon Health Authority Improve review of expenditure transactions Federal Awarding Agency: U.S. Department of Health and Human Services Assistance Listing Number and Name: 93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (COVID-19) Federal Award Numbers and Years: 6 NU50CK000541, 2021 (COVID-19) Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Type of Finding: Significant Deficiency, Noncompliance Prior Year Finding: N/A Questioned Costs: $35,416 (known) (COVID-19) Criteria: 2 CFR 200.303 As part of our testing, we reviewed expenditures charged to the program to ensure they were properly approved and an appropriate use of program resources. We randomly selected 25 of 2,355 non-payroll transactions as the basis for our testing. For one of the transactions, there was no evidence the expenditures had been reviewed and approved as appropriate expenditures for the program. The specific transaction was for cell phones and data plans on wireless devices and consisted of 584 separate devices. Only 24 (2.5%) of those devices had been approved by a manager. The department will pay the vendor for the full amount of the invoice. Managers are expected to review the charges for their unit and verify they are directed to the proper cost center. The $35,416 in questioned costs represents the charges for the devices without approval. Also, during fiscal year 2022, payroll for the department was processed through the Oregon State Payroll Application (OSPA). As part of each monthly payroll cycle, managers are expected to review and approve employee?s reported hours to ensure expenditures are accurate and are billed to the correct program(s). Although state policy requires managers to review the timesheets, the automated controls in the system will process the payroll without a review, effectively making the managerial review optional. The OSPA was retired as of November 30, 2022; however, the replacement payroll system operates in a similar manner for managerial review. As part of our testing of payroll expenditures, we found one of 25 randomly selected timesheets were not reviewed by a manager prior to release into the payroll system. We were able to perform alternative procedures to verify the amounts charged to the program were appropriate and there are no questioned costs. The lack of review increases the risk that inappropriate costs may be charged to federal programs. We recommend management ensure wireless device charges are properly reviewed, and expenditures are charged to the correct cost center or program. We also recommend management implement procedures to ensure all employee payroll submissions are reviewed and approved by program management. MANAGEMENT RESPONSE: We agree with this recommendation. The questioned costs related to cell phone charges appear to have resulted from a lack of formal process in the Coronavirus Response and Recovery Unit. This unit has closed and departments have returned to standardized formal processes. Corrective action plan: ? Prior to ?COVID-19? processes and procedures will be followed ? Administrative staff will parse cell phone charges and code invoices according to employee payroll ? Approving manager will review coding for accuracy prior to approval Anticipated Completion Date: January 1, 2023 Contact: Merry Carlson, ELC Contracts Manager
View Audit 45093 Questioned Costs: $1
Finding 47789 (2022-051)
Significant Deficiency 2022
2022-051 Oregon Health Authority Correct expenditures charged to the incorrect program Federal Awarding Agency: U.S. Department of Health and Human Services Assistance Listing Number and Name: 93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (COVID-19) Federal Award Numbers and ...
2022-051 Oregon Health Authority Correct expenditures charged to the incorrect program Federal Awarding Agency: U.S. Department of Health and Human Services Assistance Listing Number and Name: 93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (COVID-19) Federal Award Numbers and Years: 6 NU50CK000541 (COVID-19) Compliance Requirements: Activities Allowed or Unallowed Type of Finding: Significant Deficiency, Noncompliance Prior Year Finding: N/A Questioned Costs: $356,050 (COVID-19) Criteria: 2 CFR 200.302 To address the COVID-19 pandemic, the Center for Disease Control (CDC) awarded the Oregon Health Authority (department) over $495 million in additional funding beyond the normal funding levels for the Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) program. The funding was awarded for specific purposes such as enhancing detection, reopening schools, and enhancing detection expansion. The purposes of these awards generally do not allow for expenditures directly related to operating the COVID-19 vaccine clinics. In our testing, we identified two payments totaling $356,050 relating to emergency medical technicians attending vaccine clinics to assist if those receiving the vaccine had adverse reactions and required medical attention. Per department management, the transactions should have been charged to a different grant provided by the Federal Emergency Management Agency (FEMA). The error was caused by incorrect account coding when the invoice was processed. Other transactions under this contract were properly charged to the FEMA grant. We recommend management correct the accounting error and ensure the expenditures are charged to the correct programs. We also recommend the department determine if there are additional questioned costs relating to the advanced cash draw as the federal programs have different timing for federal reimbursements. MANAGEMENT RESPONSE: We agree with this recommendation. Corrective action plan: ? Adjust the two identified payments charged to the grant in error ? Adjust the erroneous charges to the Federal Emergency Management Agency (FEMA) grant ? Complete internal audit of expenditures and adjust any non-grant compliant expenditures out of this grant prior to federal financial reporting and close-out. Anticipated Completion Date: June 30, 2023 Contact: Kim Riddell, Program Support Coordinator and Jeff Cartwright, ACDP Lead Fiscal Analyst
View Audit 45093 Questioned Costs: $1
Finding 47785 (2022-049)
Significant Deficiency 2022
2022-049 Oregon Health Authority Return overdraw of reclassified FEMA expenditures Federal Awarding Agency: U.S. Department of Health and Human Services Assistance Listing Number and Name: 93.268 Immunization Cooperative Agreements (COVID-19); 93.323 Epidemiology and Laboratory Capacity for Infe...
2022-049 Oregon Health Authority Return overdraw of reclassified FEMA expenditures Federal Awarding Agency: U.S. Department of Health and Human Services Assistance Listing Number and Name: 93.268 Immunization Cooperative Agreements (COVID-19); 93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (COVID-19) Federal Award Numbers and Years: 93.268: 5 NH23IP922626 (COVID-19); 93.268: 6 NH23IP922626 (COVID-19); 93.323: 6 NU50CK000541 (COVID-19) Compliance Requirement: Activities Allowed or Unallowed Type of Finding: Significant Deficiency, Noncompliance Prior Year Finding: N/A Questioned Costs: 93.268 - $36,783 (known) (COVID-19) 93.323 - $73,333 (known) (COVID-19) Criteria: 2 CFR 200.403 During the COVID-19 pandemic, the Oregon Health Authority (department) spent money from Federal Emergency Management Agency (FEMA) awards to address needs in addressing the pandemic. Due to delays in receiving federal reimbursement for the expenditures, the department reclassified the expenditures to other programs where reimbursements would occur timelier. In our testing of Activities Allowed or Unallowed, we reviewed two individually significant items in the accounting system reclassifying 398 and 914 individual expenditures from the FEMA grants to the Immunization Cooperative Agreements program and Epidemiology and Laboratory Capacity program, respectively. Based upon the account coding of the original transactions, all of the reclassifications were allowable and consistent with program requirements. However, we found several transactions were reclassified twice, resulting in an excess of $36,783 charged to the Immunization program and $73,333 charged to the Epidemiology program. The reclassifications were completed in two batches and the managerial review of the reclassifying transactions failed to detect some transactions were included in both batches. We recommend department management correct the entries and reimburse excess cash drawn to the federal agency for unallowable costs. We also recommend department management revise the review procedures to verify that the same expenditure transactions are not duplicated in multiple batches. MANAGEMENT RESPONSE: We agree with this recommendation. Corrective action plan: ? The agency has reviewed the questioned costs and has corrected the entries with BTCL7084 and reimbursed the federal programs. ? The department has regular processes to review for duplicate adjusting entries. However, this process was missed for this entry. ? Department management will work with department staff to reinforce their understanding of the need to follow these processes to ensure transactions are not adjusted more than once. Anticipated Completion Date: June 1, 2023 Contact: Nichole Petersen, Division Liaison ? PH/ HP&A/ OEBB/ PEBB
View Audit 45093 Questioned Costs: $1
South Central Housing, Inc. respectfully submits the following Corrective Action Plan for the year ended December 31, 2022. Name and address of the independent public accounting firm who conducted the related audit: Comer, Nowling And Associates, P.C. 10475 Crosspoint Blvd, Suite 200 Indianapol...
South Central Housing, Inc. respectfully submits the following Corrective Action Plan for the year ended December 31, 2022. Name and address of the independent public accounting firm who conducted the related audit: Comer, Nowling And Associates, P.C. 10475 Crosspoint Blvd, Suite 200 Indianapolis, Indiana 46256 Finding ? 2022-001 Corrective Action Planned ? No action needed. Management made the required deposit of $21,454 on July 26, 2022 into the residual receipts account. Contact Person(s) Responsible ? Robert Jones, Controller Anticipated Completion Date ? Completed 7/26/22. Auditee Disagreements ? N/A Finding ? 2022-002 Corrective Action Planned ? Management will deposit $5,835 into the reserve for replacement account immediately. Contact Person(s) Responsible ? Robert Jones, Controller Anticipated Completion Date ? 04/30/2023 Auditee Disagreements ? N/A This corrective action plan was prepared by Hayes Gibson Property Services, LLC, the management company, on behalf of South Central Housing, Inc.. Hayes Gibson Property Services, LLC 320 West 8th Street, Suite 216 Bloomington, IN 47404 812.876.5478 Signature _______________________________________ Date: March 20, 2023
View Audit 40843 Questioned Costs: $1
South Central Housing, Inc. respectfully submits the following Corrective Action Plan for the year ended December 31, 2022. Name and address of the independent public accounting firm who conducted the related audit: Comer, Nowling And Associates, P.C. 10475 Crosspoint Blvd, Suite 200 Indianapol...
South Central Housing, Inc. respectfully submits the following Corrective Action Plan for the year ended December 31, 2022. Name and address of the independent public accounting firm who conducted the related audit: Comer, Nowling And Associates, P.C. 10475 Crosspoint Blvd, Suite 200 Indianapolis, Indiana 46256 Finding ? 2022-001 Corrective Action Planned ? No action needed. Management made the required deposit of $21,454 on July 26, 2022 into the residual receipts account. Contact Person(s) Responsible ? Robert Jones, Controller Anticipated Completion Date ? Completed 7/26/22. Auditee Disagreements ? N/A Finding ? 2022-002 Corrective Action Planned ? Management will deposit $5,835 into the reserve for replacement account immediately. Contact Person(s) Responsible ? Robert Jones, Controller Anticipated Completion Date ? 04/30/2023 Auditee Disagreements ? N/A This corrective action plan was prepared by Hayes Gibson Property Services, LLC, the management company, on behalf of South Central Housing, Inc.. Hayes Gibson Property Services, LLC 320 West 8th Street, Suite 216 Bloomington, IN 47404 812.876.5478 Signature _______________________________________ Date: March 20, 2023
View Audit 40843 Questioned Costs: $1
FA 2022-001 Strengthen Controls over Expenditures Compliance Requirement: Activities Allowed or Unallowed Allowable Costs/Cost Principle Period of Performance Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of ...
FA 2022-001 Strengthen Controls over Expenditures Compliance Requirement: Activities Allowed or Unallowed Allowable Costs/Cost Principle Period of Performance Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education Assistance Listing Number and Title: COVID-19 - 84.425D - Elementary and Secondary School Emergency Relief Fund COVID-19 - 84.425U - American Rescue Plan Elementary and Secondary School Emergency Relief Fund COVID-19 - 84.425W - American Rescue Plan Elementary and Secondary School Emergency Relief Fund - Homeless Children and Youth Federal Award Number: S425D210012 (Year: 2021), S425U2120012 (Year: 2021) S425W210011 (Year: 2021) Questioned Costs: $108,220 Description: A review of expenditures charged to the Elementary and Secondary School Emergency Relief Fund program revealed that the School District's internal control procedures were not operating appropriately to ensure that expenditures were allowable for the program. Corrective Action Plans: We concur with this finding. A new Federal Programs Director began work during the period of the audit. The change in personnel coupled with the influx of new grants, large awards of grant dollars and new regulations and requirements contributed to the finding. To correct, staff meet and attend training on all federal grant funds received to ensure compliance on all reporting requirements. The federal programs director enters and monitors all grant budgets into the consolidated application and supplies all prior approval forms for those items for which it is required. The federal programs director also approves all purchase requisitions using federal funds before items can be purchased; she also reviews and approves request for reimbursement of federal funds before those funds are drawn down. (Superintendent approves as well.) Estimated Completion Date: June 30, 2023 Contact Person: Debbie Driggers Powell Telephone: (912) 557-3327 Email: dpowell@tattnall.k12.ga.us
View Audit 40842 Questioned Costs: $1
Finding 47746 (2022-003)
Material Weakness 2022
COMPLIANCE 2022-003 Controls Over Activities Allowed Recommendation: The City should review their established policies and procedures for effectiveness and ensure all employees adhere to all established procedures. Corrective Action Plan: The City of Scott will review financial policies and procedur...
COMPLIANCE 2022-003 Controls Over Activities Allowed Recommendation: The City should review their established policies and procedures for effectiveness and ensure all employees adhere to all established procedures. Corrective Action Plan: The City of Scott will review financial policies and procedures and make any necessary changes to ensure an effective control environment.
View Audit 53113 Questioned Costs: $1
Finding 47745 (2022-002)
Material Weakness 2022
INTERNAL CONTROL 2022-002 Controls Over Activities Allowed Recommendation: The City should review their established policies and procedures for effectiveness and ensure all employees adhere to all established procedures. Corrective Action Plan: The City of Scott will review financial policies and pr...
INTERNAL CONTROL 2022-002 Controls Over Activities Allowed Recommendation: The City should review their established policies and procedures for effectiveness and ensure all employees adhere to all established procedures. Corrective Action Plan: The City of Scott will review financial policies and procedures and make any necessary changes to ensure an effective control environment.
View Audit 53113 Questioned Costs: $1
Corrective Action Plan Lancaster Village Consumer Housing Cooperative For the Year Ended July 31, 2022 Lancaster Village Consumer Housing Cooperative respectfully submits the following Corrective Action Plan for the year ended July 31, 2022. Name and address of the independent public accounting f...
Corrective Action Plan Lancaster Village Consumer Housing Cooperative For the Year Ended July 31, 2022 Lancaster Village Consumer Housing Cooperative respectfully submits the following Corrective Action Plan for the year ended July 31, 2022. Name and address of the independent public accounting firm who conducted the related audit: Comer, Nowling And Associates, P.C. 10475 Crosspoint Boulevard, Suite 200 Indianapolis, Indiana 46256 Finding 2022-001 Corrective Action Planned ? Management will deposit $252 into the replacement reserve and confirm future deposits are made in accordance with HUD. Contact Person(s) Responsible ? Joe Holland, Director of Accounting, Kirkpatrick Management Anticipated Completion Date ? June 2023 Auditee Disagreements ? N/A Finding 2022-002 Corrective Action Planned ? None necessary ? REAC filed June 2023 Contact Person(s) Responsible ? Joe Holland, Director of Accounting, Kirkpatrick Management Anticipated Completion Date ? June 2023 Auditee Disagreements ? N/A This corrective action plan was prepared by Kirkpatrick Management, the management company, on behalf of Lancaster Village Consumer Housing Cooperative _______________________________ Joe Holland, Director of Accounting Kirkpatrick Management 5702 Kirkpatrick Way Indianapolis, Indiana 46220 317-570-4358
View Audit 52715 Questioned Costs: $1
Finding 2022-0003 Identification of federal program: US Department of Education 84.425C, 84.425D and 84.425U Education Stabilization Fund Criteria: Nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements (which still may be referenced as the Davis-Ba...
Finding 2022-0003 Identification of federal program: US Department of Education 84.425C, 84.425D and 84.425U Education Stabilization Fund Criteria: Nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements (which still may be referenced as the Davis-Bacon Act) a provision that the contractor or subcontractor comply with those requirements and the DOL regulations (29 CFR Part 5, Labor Standards Provisions Applicable to Contracts Governing Federally Financed and Assisted Construction) (2CFR section 200.327; Appendix II D to 2 CFR Part 200). This includes a requirement for the contractor or subcontractor to submit to the nonfederal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payroll) (29 CFR section 5.5 and 5.6; the A-102 Common Rule(section 36(i)(S)): 0MB Circular A-110 (2 CFR Part 215, Appendix A, Contract Provisions); 2 CFR Part 176, Subpart C; and 2 CFR section 200.327). Condition: A LEA must use ESF funds for minor remodeling, renovation or construction contracts that are over $2,000 and use laborers and mechanics that must meet Davis-Bacon prevailing wage requirements. Cause: The School failed to timely notify a certain contractor about the Davis-Bacon Act contract clause requirements related to the prevailing wage rate for contractors and subcontractors. As a result, the contractor did not provide the certified payrolls or statement of compliance. Potential Effect: The contractor may not have complied with the wage requirements. Questioned costs: $214,716.62. Context: A total sample of one (1) item related to a certain contractors HVAC project was selected as part of allowable cost testing for the Education Stabilization Fund. Recommendation: We recommend that the School provide timely communication related to the prevailing wage rate requirements for contracts with future contractors and subcontractors. The School should also ensure that the proper prevailing wage rate clauses are included in future contracts. We further recommend that the School ensure the contractors and subcontractors compliance with the required federal compliance requirements. Action: We concur with the recommendation and will implement the appropriate language identifying the prevailing wage rate requirements in future contracts with both contractors and subcontractors. Furthermore, certified payrolls and statements of compliance with be required and tracked for each project.
View Audit 53695 Questioned Costs: $1
Finding ref number: 2022-001 Finding caption: The District did not have adequate internal controls for ensuring compliance with allowable activities and costs and restricted purpose requirements Name, address, and telephone of District contact person: Amy Karcher, Finance Manager PO Box 8937 Vanco...
Finding ref number: 2022-001 Finding caption: The District did not have adequate internal controls for ensuring compliance with allowable activities and costs and restricted purpose requirements Name, address, and telephone of District contact person: Amy Karcher, Finance Manager PO Box 8937 Vancouver, WA 98668-8937 (360) 313-1348 Corrective action the auditee plans to take in response to the finding: (If the auditee does not concur with the finding, the auditee must list the reasons for disagreement). This audit finding related to unique rules associated with one-time, pandemic-necessitated funding, so VPS is extremely unlikely to have to navigate these compliance expectations ever again. However, VPS will aspire to slow down the procurement and deployment of grant-funded resources as long as possible in the future in order to learn more of what the final audit expectations may be. Anticipated date to complete the corrective action: Undeterminable based on rarity of event
View Audit 52811 Questioned Costs: $1
Condition: Three vendors were awarded a contract without a proper competitive procurement process. Corrective Action Planned: The City and School Department has implemented procedures to perform procurement procedures on all applicable contracts for goods and services that will be in compliance with...
Condition: Three vendors were awarded a contract without a proper competitive procurement process. Corrective Action Planned: The City and School Department has implemented procedures to perform procurement procedures on all applicable contracts for goods and services that will be in compliance with both Federal and State procurement laws. We feel the finding has been resolved going forward. Anticipated Completion Date: 2023-2024 school year Contact: Kenny Costa, City Auditor and Gary Frisch, School Chief Financial Officer
View Audit 52709 Questioned Costs: $1
Planned Corrective Actions: In its Provider Relief reporting submission for the year ended September 30, 2022, the District initially selected option 2 based on quarterly actuals to budget quarterly lost revenue. However, the District, including the nursing homes for which they operate, did not have...
Planned Corrective Actions: In its Provider Relief reporting submission for the year ended September 30, 2022, the District initially selected option 2 based on quarterly actuals to budget quarterly lost revenue. However, the District, including the nursing homes for which they operate, did not have a budget approved by the respective Board by March 27, 2020 as required under option 2. Technically, the District should have reported under option 3. Management spent significant amount of time and resources evaluating the reporting requirements and considered option 2 with a prorated budget for Q4 2020 and Q1 through Q4 2021 to be a reasonable methodology given the District?s budget cycle is on the fiscal year September 30 and not December 31. Additionally, the calculated budget revenue for the nursing homes were unable to be reconciled to supporting documentation files. During the single audit, it was determined option 3 would have been the more appropriate reporting option to select. Management has performed a detailed analysis of the reporting requirements in accordance with the final guidelines set for by HRSA for future reporting periods. During period 4 reporting, the District elected option 3 to report lost revenues, which was deemed to be a more accurate representation of the lost revenue methodology utilized. As deemed necessary, the District will modify policies and procedures over federal grant reporting. The District?s CFO will oversee this to ensure that this is accomplished.
View Audit 49870 Questioned Costs: $1
Finding ref number: 2022-001 Finding caption: The District did not have adequate internal controls for ensuring compliance with allowable activities and costs and restricted purpose requirements. Name, address, and telephone of District contact person: Sylvia Bazan, Business Manager 212 W. 3rd Str...
Finding ref number: 2022-001 Finding caption: The District did not have adequate internal controls for ensuring compliance with allowable activities and costs and restricted purpose requirements. Name, address, and telephone of District contact person: Sylvia Bazan, Business Manager 212 W. 3rd Street Wapato, WA 98951 (509) 877-4181 Corrective action the auditee plans to take in response to the finding: (If the auditee does not concur with the finding, the auditee must list the reasons for disagreement). During the COVID -19 pandemic, the District applied for ECF funding for hotspots and chrome books for our students. The Wapato School District was not a 1 to 1 District in regards to devices, but we had to pivot quickly to ensure our students had a device and connectivity. This would ensure we could provide instruction during remote learning and school closures during the pandemic. The District provided a survey to all students/parents seeking information regarding connectivity and devices. The survey results showed many of our students did not have adequate connectivity or a device to stream videos, which is needed for remote instruction. Also, the District did not receive responses from all families as they did not have connectivity to do so. The District used its library check out system to issue Chromebook and hot spots to students. The process was for students who needed a device to communicate this to their school building, then they would be directed to the library to obtain a device. The student?s requests were an unmet need. Although the student/parent did not sign a form to document unmet need, the District felt the request for a device was sufficient. As for the per location and per user limitation, the District?s library system was used to provide reports during the audit process, but it was determined the reports were not run at the time of reimbursement. The Wapato School District is a District with over 90% poverty level, the District?s priority was to ensure students were provided devices for instruction and connectivity during the pandemic. The District will strengthen its controls over documenting unmet need for students as well as maintaining reports that show per location/ per user limits at the time ECF funding is requested. Our IT department has started to implement a formal process, which includes a written application for our student/family to submit prior to receiving a device. They are also working on written instructions for the deployment of devices and documentation to be obtained. These instructions will be provided to all school buildings. Anticipated date to complete the corrective action: June 1, 2023
View Audit 49232 Questioned Costs: $1
Name of Contact Person: Ginger Loscavo, Program Specialist Corrective Action: Eligibility requirements regarding the Commodity Supplemental Food program (CSFP) are recognized by West Ohio Food Bank (WOFB) and WOFB continues making internal controls a top priority in the program?s operation. There ...
Name of Contact Person: Ginger Loscavo, Program Specialist Corrective Action: Eligibility requirements regarding the Commodity Supplemental Food program (CSFP) are recognized by West Ohio Food Bank (WOFB) and WOFB continues making internal controls a top priority in the program?s operation. There are currently more than 1,475 applications processed through WOFB and 40 site locations for CSFP. During the auditing process, there were 6 participants who did not sign the signature sheet to receive their box. They had a proxy sign and received the box for them that was not listed on their application as being a proxy eligible to do this. It was discovered for four of the participants that the pantry site administrator, who distributes the boxes monthly, signed for the participant because of a misunderstanding they had assuming they were automatically considered a proxy for those receiving boxes from their location. The remaining two participant?s boxes were signed for by another program participant who received her monthly box along with boxes for 2 other participants who were unable to get their box on their own because of not having transportation. The site administrator made an error allowing this person to sign for the boxes as that person was not listed as a proxy. Additional testing discovered 2 participants out of 25 were not eligible at the time of the distribution based on an invalid or expired application on file. One of the applications had the client put his annual income in the income field of the application but marked he received this monthly instead of annually. The other participant had an application that was not dated properly but was processed allowing him to receive a box. Effective January 1, 2023, WOFB will conduct a refresher course for all program sites and site administrators reviewing eligibility and program requirements for CSFP. The Program Specialist will oversee these training sessions. Any new sites that may develop throughout the year will be trained on all rules, regulations, and eligibility for the program. All new site staff and/or volunteers will be trained annually. Every six months, the Program Specialist will audit signature sheets from all site locations and make any necessary adjustments. This will be an ongoing corrective action plan throughout the existence of CSFP at WOFB. The process will be overseen by the Chief Operations Officer. In addition, all applications will be reviewed thoroughly ensuring the correct income field is marked by the applicant that coordinates with their stated income and dates will be reviewed on each application ensuring the client is eligible and using the correct annual application. The Program Specialist will review at least 10% of the applications currently on file each month. These will also be reviewed by the Chief Operations Officer to check for accuracy. Proposed Completion Date: WOFB?s fiscal year begins July 1 each year. The Program Specialist will conduct training with all program sites by October 30th of the current year. As new sites, staff and/or volunteers distribute food boxes for CSFP, training will be conducted before their first distribution. This process will be ongoing. Beginning January 1, 2023, the Program Specialist will begin reviewing 10% of CSFP applications monthly with the Chief Operations Officer doing a 2nd check and periodically spot-checking applications for the program. This will be ongoing.
View Audit 52669 Questioned Costs: $1
2022-001 Housing Voucher Cluster ? Assistance Listing No. 14.871 Recommendation: We recommend the Authority implements controls to ensure that required HQS and QC inspections are completed timely. We recommend the Authority implements controls to ensure abatement is timely for units that do not corr...
2022-001 Housing Voucher Cluster ? Assistance Listing No. 14.871 Recommendation: We recommend the Authority implements controls to ensure that required HQS and QC inspections are completed timely. We recommend the Authority implements controls to ensure abatement is timely for units that do not correct the cited HQS deficiencies within the required timeframe. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: HQS Inspections-The Housing Authority of Skagit County (HASC) experienced HQS Inspector turnover during the COVID-19 pandemic. Since the pandemic, HASC hired a new HQS Inspector who has attended and completed HQS Inspector Certification. The inspector is scheduling and completing the inspections according to regulations, including timeliness. The Section 8 Program Manager will monitor the HQS Inspector. Quality Control (QC) Inspections-HASC applied for a waiver to not administer Quality Control Inspections during FY 2022, but HUD did not process the waiver request due to the volume of requests. HASC did not confirm the waiver was approved, which was an oversight. Please see below for corrective action regarding approval of waivers. For FY 2023, Quality Control Inspections have already been initiated. Failed Inspections-A spreadsheet has been created that will be utilized by the HQS Inspector and monitored by the Section 8 Program Manager. Each failed inspection will be added to the spreadsheet. The spreadsheet will document when the re-inspection is due and when HAP abatement is scheduled to take place. The spreadsheet will be reviewed on a weekly basis, by the Program Manager. This spreadsheet will increase inter-department communication and assist in following through with landlord communication and abatement when abatement is required. Name(s) of the contact person(s) responsible for corrective action: Cathy Kerr Planned completion date for corrective action plan: July 11, 2023
View Audit 52922 Questioned Costs: $1
Finding 2022-002 Program: Formula Grants for Rural Areas, COVID-19 Formula Grants for Rural Areas Finding Summary: 2 CFR section 200.430, Compensation ? personal services, states that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performe...
Finding 2022-002 Program: Formula Grants for Rural Areas, COVID-19 Formula Grants for Rural Areas Finding Summary: 2 CFR section 200.430, Compensation ? personal services, states that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. The records must be support by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Responsible Individuals: Cheri Holsclaw, General Manager Corrective Action Plan: Basin Transit will review the Federal grants management procedures to ensure that costs incurred due to error or other types of unallowable costs are not included in subsequent reimbursement requests. Anticipated Completion Date: January 27, 2023 Cheri Holsclaw, General Manager
View Audit 52444 Questioned Costs: $1
Reference Number: 2022-004 Description: 84.010 A Title I - Activities allowed and Allowable Costs Corrective Action Plan: The Organization will obtain required staff credentials ? HR dept to obtain r equired staff credentials upon hiring and on boarding staff ? Finance dept to confirm with HR dept t...
Reference Number: 2022-004 Description: 84.010 A Title I - Activities allowed and Allowable Costs Corrective Action Plan: The Organization will obtain required staff credentials ? HR dept to obtain r equired staff credentials upon hiring and on boarding staff ? Finance dept to confirm with HR dept that staff assigned to grants have met eligible criteria, including proper licensure and or related qualifications Anticipated Corrective Action Plan Completion Date: Currently implementing process, effective January 2023 Contact Information: For additional information regarding this finding please contact Michael Bradley, Chief Financial and Operating Officer, at bradleym@carmenhighschool.org
View Audit 52014 Questioned Costs: $1
The county will review and update our procurement policies and provide additional training and education to all departments to ensure the minimum requirements of 2 CFR 200 and the procurement policies established by the Oconto County Board are being followed. Planned completion date for corrective a...
The county will review and update our procurement policies and provide additional training and education to all departments to ensure the minimum requirements of 2 CFR 200 and the procurement policies established by the Oconto County Board are being followed. Planned completion date for corrective action: December 31, 2023 Name of the contact person responsible for corrective action: Lisa Sherman, Finance Director
View Audit 51115 Questioned Costs: $1
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