Corrective Action Plans

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Corrective Action: The Organization agrees with the finding and has continued to implement strategies to address the finding. To address this finding, management has assembled and deployed a team of external consultants and temporary workers to assist site staff in completing tenant recertifications...
Corrective Action: The Organization agrees with the finding and has continued to implement strategies to address the finding. To address this finding, management has assembled and deployed a team of external consultants and temporary workers to assist site staff in completing tenant recertifications and hired a team of additional roving property management/compliance teams to cover open property management positions and to support site staff in completing tenant recertifications. Currently, management plans to transition 50% of its real estate portfolio to new property management in 2025. Proposed completion date: Management has begun the corrective action and is expected to have additional internal controls in place by December 31, 2025. Name of contact person: Jennifer Anderson, Interim CFO
Corrective Action: The Organization agrees with the finding and has continued to implement strategies to address the finding. To address this finding, management has assembled and deployed a team of external consultants and temporary workers to assist site staff in completing tenant recertifications...
Corrective Action: The Organization agrees with the finding and has continued to implement strategies to address the finding. To address this finding, management has assembled and deployed a team of external consultants and temporary workers to assist site staff in completing tenant recertifications and hired a team of additional roving property management/compliance teams to cover open property management positions and to support site staff in completing tenant recertifications. Currently, management plans to transition 50% of its real estate portfolio to new property management in 2025. Proposed completion date: Management has begun the corrective action and is expected to have additional internal controls in place by December 31, 2025. Name of contact person: Jennifer Anderson, Interim CFO
Corrective Action: The Organization agrees with the finding. Currently, management plans to transition 50% of its real estate portfolio to new property management in 2025. Management is working with the new property managers to ensure they have procedures in place to document and maintain tenant fil...
Corrective Action: The Organization agrees with the finding. Currently, management plans to transition 50% of its real estate portfolio to new property management in 2025. Management is working with the new property managers to ensure they have procedures in place to document and maintain tenant files in accordance with HUD and will have routine internal audits of tenant files to ensure compliance with HUD regulations. For properties not transitioning to new property management, management believes the reduced volume of properties at one property manager will reduce staff turnover and more efficiently provide the proper training to existing staff to improve compliance with tenant files. Proposed completion date: Management has begun the corrective action and is expected to have additional internal controls in place by December 31, 2025. Name of contact person: Jennifer Anderson, Interim CFO
Corrective Action: The Organization agrees with the finding and has continued to implement strategies to address the finding. To address this finding, management has assembled and deployed a team of external consultants and temporary workers to assist site staff in completing tenant recertifications...
Corrective Action: The Organization agrees with the finding and has continued to implement strategies to address the finding. To address this finding, management has assembled and deployed a team of external consultants and temporary workers to assist site staff in completing tenant recertifications and hired a team of additional roving property management/compliance teams to cover open property management positions and to support site staff in completing tenant recertifications. Currently, management plans to transition 50% of its real estate portfolio to new property management in 2025. Proposed completion date: Management has begun the corrective action and is expected to have additional internal controls in place by December 31, 2025. Name of contact person: Jennifer Anderson, Interim CFO
Corrective Action: The Organization agrees with the finding and has continued to implement strategies to address the finding. To address this finding, management has assembled and deployed a team of external consultants and temporary workers to assist site staff in completing tenant recertifications...
Corrective Action: The Organization agrees with the finding and has continued to implement strategies to address the finding. To address this finding, management has assembled and deployed a team of external consultants and temporary workers to assist site staff in completing tenant recertifications and hired a team of additional roving property management/compliance teams to cover open property management positions and to support site staff in completing tenant recertifications. Currently, management plans to transition 50% of its real estate portfolio to new property management in 2025. Proposed completion date: Management has begun the corrective action and is expected to have additional internal controls in place by December 31, 2025. Name of contact person: Jennifer Anderson, Interim CFO
This Corrective Action Plan is in response to Lancaster Bible College’s single audit report for the fiscal year ended June 30, 2024, prepared by Tait, Weller & Baker. Finding 2024-001 Recommendation: The College should review its procedures related to the request and disbursement of federal funds, i...
This Corrective Action Plan is in response to Lancaster Bible College’s single audit report for the fiscal year ended June 30, 2024, prepared by Tait, Weller & Baker. Finding 2024-001 Recommendation: The College should review its procedures related to the request and disbursement of federal funds, including controls over compliance, to ensure they are following the advance payment method and establish controls to ensure it complies with the federal requirement. Corrective Action: In July 2024, a new tracking system was implemented for daily reconciliation of award batch detail along with specific individual training to ensure staff follows compliance responsibilities and understand the requirements of the program. The Controller and Financial Aid Director meet monthly to discuss any potential gaps in compliance. Person Responsible for Corrective Action: Matthew Mason, Vice President of Finance Anticipated Completion Date: The Corrective Action Plan was corrected during July 2024.
View Audit 353450 Questioned Costs: $1
New management has taken over and will make the delinquent deposit to the replacement reserve of $770 and establish transfers for the monthly deposit amount.
New management has taken over and will make the delinquent deposit to the replacement reserve of $770 and establish transfers for the monthly deposit amount.
View Audit 353426 Questioned Costs: $1
Management agrees with the finding. Management has submitted the forms for HUD's approval.
Management agrees with the finding. Management has submitted the forms for HUD's approval.
View Audit 353416 Questioned Costs: $1
The District will implement a process to track the submission time of the data collection form and audit package.
The District will implement a process to track the submission time of the data collection form and audit package.
Condition – Peak Vista (“the Organization”) determines the sliding fee discount charged to the patients based on their annual gross income and household size. During our testing of sliding fee discounts, we found that two encounters selected where the patients were charged incorrect copays. Recommen...
Condition – Peak Vista (“the Organization”) determines the sliding fee discount charged to the patients based on their annual gross income and household size. During our testing of sliding fee discounts, we found that two encounters selected where the patients were charged incorrect copays. Recommendation – The Organization should strengthen processes surrounding the monitoring of the program to ensure the Organization’s policies are consistently and properly applied. Views of Responsible Officials and Planned Corrective Actions – Management agrees with the finding. The Organization has developed a plan for addressing this issue that includes updated procedures, training, and auditing. All teams engaged in the enrollment and eligibility process, including our Enrollment, Reception, and Billing teams will be retrained on the process with emphasis on proper documentation. The Organization management plans to incorporate into our quality assurance audits the documentation for single service date discount applications and provide feedback and retraining as necessary to staff as needed. Anticipated Date of Completion – In progress. Action Taken – We have reviewed the recommendation and have developed a plan for addressing this issue. Person Responsible for Corrective Action Plan – Ryan Spillane, Chief Financial Officer Corrective Action Plan – Ryan Spillane, Chief Financial Officer
View Audit 353387 Questioned Costs: $1
Replacement Reserve Deposits Recommendation: We recommend that management develop procedures to ensure replacement reserve deposits are updated timely to ensure compliance with the HUD regulatory agreement. Explanation of disagreement with audit finding: There is no disagreement with the audit fi...
Replacement Reserve Deposits Recommendation: We recommend that management develop procedures to ensure replacement reserve deposits are updated timely to ensure compliance with the HUD regulatory agreement. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management has developed processes to verify replacement reserve deposits are updated based on the regulatory agreement annually. Name(s) of contact person(s) responsible for corrective action: Nicole Chwala. Planned completion date for corrective action plan: Corrective action has been taken in March 2025.
View Audit 353384 Questioned Costs: $1
Finding 554816 (2024-001)
Significant Deficiency 2024
Replacement Reserve Deposits Recommendation: We recommend that management develop procedures to ensure replacement reserve deposits are updated timely to ensure compliance with the HUD regulatory agreement. Explanation of disagreement with audit finding: There is no disagreement with the audit fi...
Replacement Reserve Deposits Recommendation: We recommend that management develop procedures to ensure replacement reserve deposits are updated timely to ensure compliance with the HUD regulatory agreement. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management has developed processes to verify replacement reserve deposits are updated based on the regulatory agreement annually. Name(s) of contact person(s) responsible for corrective action: Nicole Chwala. Planned completion date for corrective action plan: Corrective action has been taken in February 2025.
View Audit 353383 Questioned Costs: $1
Planned Corrective Action: The Garland Housing Agency (GHA) relies on the certifications of the tenant and landlord, which states that there is not a familial relationship between the two parties. GHA will review applications for unusual items that could be indicative of a familial relationship and...
Planned Corrective Action: The Garland Housing Agency (GHA) relies on the certifications of the tenant and landlord, which states that there is not a familial relationship between the two parties. GHA will review applications for unusual items that could be indicative of a familial relationship and use online, public records to try to identify whether or not there is a familial relationship. GHA maintains a log of potential issues with the participants and will include potential familial relationships between the tenant and landlord in the log. Responsible officials: Steve Fitch, Director of Housing Planned completion date: September 30, 2025
View Audit 353380 Questioned Costs: $1
Corrective Action Plan To comply with the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, 2 CFR 320(a) the Board will obtain from multiple vendors on an animal basis price listings of commonly purchased items and or services to deternune lowest cost o...
Corrective Action Plan To comply with the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, 2 CFR 320(a) the Board will obtain from multiple vendors on an animal basis price listings of commonly purchased items and or services to deternune lowest cost of items and or services available to be purchased from qualified sources. Anticipated Completion Date: April 1, 2025 Contact Person(s): John N. Godwin, Chief School Finance Officer
View Audit 353371 Questioned Costs: $1
Finding 554772 (2024-001)
Significant Deficiency 2024
FINDINGS—FEDERAL AWARD PROGRAMS AUDITS U.S. Department of Housing and Urban Development 2024‐001 Section 202 Supportive Housing for the Elderly – Assistance Listing No. 14.157 Recommendation: The Auditors recommend that the Organization make the missed deposit to the replacement reserve escrow and ...
FINDINGS—FEDERAL AWARD PROGRAMS AUDITS U.S. Department of Housing and Urban Development 2024‐001 Section 202 Supportive Housing for the Elderly – Assistance Listing No. 14.157 Recommendation: The Auditors recommend that the Organization make the missed deposit to the replacement reserve escrow and establish internal controls to ensure required replacement reserve deposits are made in a timely manner. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The missed June 2024 replacement reserve deposit was made on March 11, 2025 Name(s) of the contact person(s) responsible for corrective action: Mary Sugrue Planned completion date for corrective action plan: March 25, 2025. If the U.S. Department of Housing and Urban Development has questions regarding this plan, please call Mary Sugrue at 857‐221‐8694.
Finding 554770 (2024-039)
Significant Deficiency 2024
2024-039 Oregon Department of Emergency Management Continue FFATA reporting improvements and make inquiries on FSRS functionality Management Response: The Oregon Department of Emergency Management (OEM) concurs with the finding and the recommendations as outlined in the letter and above. OEM has und...
2024-039 Oregon Department of Emergency Management Continue FFATA reporting improvements and make inquiries on FSRS functionality Management Response: The Oregon Department of Emergency Management (OEM) concurs with the finding and the recommendations as outlined in the letter and above. OEM has undertaken and continues the following corrective actions to address the recommendations made by the Secretary of State’s Audits Division: • OEM has developed procedures for capturing necessary information and ensuring FFATA reports are filed in compliance with federal criteria. • OEM has identified all awards since July 1st 2023 and is working to ensure 100% compliance from that date forward. • OEM will conduct timely follow up on all submissions that fail to successfully load into the system, and clearly document that follow up for inclusion in our files. • OEM will continue to review older awards to determine what actions should be taken. Anticipated completion date: June 30, 2025. Contact person: Amy Mettler, Chief Financial Officer.
2024-020 Oregon Department of Human Services Ensure nursing facility recertification surveys are completed Management Response: We agree with this recommendation. The department is committed to regaining full compliance with CMS Survey timelines. While staffing shortages, multiple changes to the CMS...
2024-020 Oregon Department of Human Services Ensure nursing facility recertification surveys are completed Management Response: We agree with this recommendation. The department is committed to regaining full compliance with CMS Survey timelines. While staffing shortages, multiple changes to the CMS Long-term Care Survey Process (LTCSP), COVID-19 disruptions and increased complaints have impacted recertification timeliness, we have taken significant steps to address these challenges over the last several years. Key strategies include: • Staffing & Recruitment – Streamlined hiring and onboarding by assigning a dedicated hiring manager to oversee recruitment, hiring onboarding and retention strategies which have reduced surveyor vacancies from 30% to 15% as of March 2025. • Efficiency Improvements – Streamlined workflows by adopting electronic documentation, reorganized teams to 3 regions that include a complaint team, adjusted team sizes to maximize survey completion rates, increased offsite reviews for certain types of revisits as allowed by State and CMS guidelines, prioritization of facilities with longest intervals since their last recertification to systemically lower the overall average survey interval. • Data-Driven performance evaluations – Ongoing evaluations reviewing survey and surveyor turnaround time using data. With these actions, we are confident in our ability to restore compliance and build a more resilient, effective survey system for Oregon’s nursing facilities. Anticipated Completion Date: October 30, 2026 Contact person: Jennifer Stallsworth, Chief of Staff, ODHS APD, April Gillette, OHA Medicaid Division, Strategic Operations & Improvement Director
Finding 554759 (2024-019)
Significant Deficiency 2024
2024-019 Oregon Department of Human Services Improve controls and compliance over long-term care facility auditsManagement Response: We agree with this recommendation and will make these changes on the July 1, 2025 cost report template. We will be adding a line item to distinguish between Total Admi...
2024-019 Oregon Department of Human Services Improve controls and compliance over long-term care facility auditsManagement Response: We agree with this recommendation and will make these changes on the July 1, 2025 cost report template. We will be adding a line item to distinguish between Total Administration overtime and Administrator only overtime. .Anticipated Completion Date: July 1, 2025 Contact person: Jennifer Stallsworth, Chief of Staff, ODHS APD, April Gillette, OHA Medicaid Division, Strategic Operations & Improvement Director
Finding 554758 (2024-018)
Significant Deficiency 2024
2024-018 Oregon Department of Human Services Strengthen Medicaid fraud hotline reporting mechanismsManagement Response: We agree with this recommendation and will work to develop a more effective public facing referral process.. Anticipated Completion Date: July 31, 2026 Contact person: Jennifer Sta...
2024-018 Oregon Department of Human Services Strengthen Medicaid fraud hotline reporting mechanismsManagement Response: We agree with this recommendation and will work to develop a more effective public facing referral process.. Anticipated Completion Date: July 31, 2026 Contact person: Jennifer Stallsworth, Chief of Staff, ODHS APD, April Gillette, OHA Medicaid Division, Strategic Operations & Improvement Director
Finding 554757 (2024-017)
Significant Deficiency 2024
2024-017 Oregon Department of Human Services/Oregon Health Authority Strengthen internal controls over the ONE system Management Response: We agree with this recommendation. ODHS will continue to work with our vendor to secure a SOC 2 Type II audit of our processes and oversight of the ONE system in...
2024-017 Oregon Department of Human Services/Oregon Health Authority Strengthen internal controls over the ONE system Management Response: We agree with this recommendation. ODHS will continue to work with our vendor to secure a SOC 2 Type II audit of our processes and oversight of the ONE system in 2025. Additionally, ODHS will work on amending the ONE M&O agreement with Deloitte for them to obtain a scoped SOC 2 Type II audit related to their work within the ONE system. ODHS would expect to negotiate this additional audit requirement in 2025 with the first audit then happening in 2026. In addition, the agency will request reports that will allow reconciliation of transactions between ONE and the mainframe system. Anticipated Completion Date: December 31, 2026 Contact person: Jennifer Stallsworth, Chief of Staff, ODHS APD, April Gillette, OHA Medicaid Division, Strategic Operations & Improvement Director
Finding 554756 (2024-016)
Significant Deficiency 2024
2024-016 Oregon Department of Human Services/Oregon Health Authority Improve documentation for provider eligibility determinations and revalidations Management Response: We agree with this recommendation. OHA – Medicaid (Todd Howard) - At the next Provider Enrollment meeting on April 17, 2025, we wi...
2024-016 Oregon Department of Human Services/Oregon Health Authority Improve documentation for provider eligibility determinations and revalidations Management Response: We agree with this recommendation. OHA – Medicaid (Todd Howard) - At the next Provider Enrollment meeting on April 17, 2025, we will conduct an additional training on the ownership and disclosure form, in particular the requirement around the managing employee disclosure. We will also work with our CCO contract administrator, unit lead worker and staff that process the annual CCO ownership disclosure forms to ensure all disclosures and attachments are obtained. ODHS-Aging & People with Disabilities (Jennifer Stallsworth) The Office of Aging and People with Disabilities is committed to ensuring the Provider Enrollment Agreements and I-9 forms are on accurate and records are stored and retained properly. Corrective Actions Taken & In Progress • Improved Provider Enrollment & Renewal Forms – On or before March 31, all new and renewing providers will have the option to complete the Provider Enrollment Application and Agreement (PEAA), I-9, W-4 (federal and state), and HCW Guide Agreement Form through DocuSign and submit them electronically through email, which will assist in the accuracy of forms completion and mitigate human errors in completing forms. • Local Office Verification Step – An Action Request (AR) transmittal will require local offices to verify that a properly completed I-9 is on file during provider renewal process. • Training & Resources – We will develop a Quick Resource Guide (QRG) with clear instructions and visual examples to help staff verify employment documents accurately and store them appropriately. • Quality Assurance Enhancements – The Provider Relations Unit (PRU) will implement a Quality Assurance check for I-9 forms during provider enrollment and renewal process. • E-Verify – The department is developing a proposal with an implementation plan using the Department of Homeland Security’s E-Verify+ system as an electronic verification tool for employment eligibility. We will seek leadership approval by July 1, 2025, with a plan to implement by March 31, 2026. Resolution of Questioned Costs The department has obtained the missing I-9 documentation and will not reimburse the federal agency for the questioned costs. We are confident these measures will ensure full compliance and improve the accuracy and efficiency of our provider enrollment process. Anticipated Completion Date: March 31, 2026 Contact person: Jennifer Stallsworth, Chief of Staff, ODHS APD, April Gillette, OHA Medicaid Division, Strategic Operations & Improvement Director
View Audit 353343 Questioned Costs: $1
Finding 554755 (2024-015)
Significant Deficiency 2024
2024-015 Oregon Department of Human Services/Oregon Health Authority Strengthen review over direct costs charged to the program Management Response: We agree with this recommendation. Interest related to past due amounts will be charged to general funds only. Expenditures will be reviewed both by st...
2024-015 Oregon Department of Human Services/Oregon Health Authority Strengthen review over direct costs charged to the program Management Response: We agree with this recommendation. Interest related to past due amounts will be charged to general funds only. Expenditures will be reviewed both by staff and approving parties to ensure only allowable expenditures are charged to the federal grants. The questioned costs of $68 will be refunded and reported to CMS on the CMS 64. The agency will ensure that future contracts that include any incentive funds for surveys will be structured such that incentives are billed under separate coding that will be charged to general funds only. The questioned costs of $28,801 will be refunded and reported to CMS on the CMS 64 Anticipated Completion Date: April 30, 2025 Contact person: Jennifer Stallsworth, Chief of Staff, ODHS APD, April Gillette, OHA Medicaid Division, Strategic Operations & Improvement Director
View Audit 353343 Questioned Costs: $1
Finding 554754 (2024-014)
Significant Deficiency 2024
2024-014 Oregon Department of Human Services/Oregon Health Authority Implement control procedures around cost allocation system inputs Management Response: We agree with this recommendation. The Office of Financial Services will review the existing controls in Cost Allocation system and identify are...
2024-014 Oregon Department of Human Services/Oregon Health Authority Implement control procedures around cost allocation system inputs Management Response: We agree with this recommendation. The Office of Financial Services will review the existing controls in Cost Allocation system and identify areas that need additional or new control procedures to ensure system inputs are appropriately identified and processed. In addition, we will review the noted errors and make appropriate corrections. Anticipated Completion Date: June 30,, 2025 Contact person: Jennifer Stallsworth, Chief of Staff, ODHS APD, April Gillette, OHA Medicaid Division, Strategic Operations & Improvement Director
View Audit 353343 Questioned Costs: $1
Finding 554753 (2024-013)
Significant Deficiency 2024
2024-013 Oregon Health Authority Improve documentation and controls over client eligibility Management Response: We agree with this recommendation. A specific case was discovered where the state failed to obtain a signature from an SSI individual. Due to the individual’s SSI status and being continu...
2024-013 Oregon Health Authority Improve documentation and controls over client eligibility Management Response: We agree with this recommendation. A specific case was discovered where the state failed to obtain a signature from an SSI individual. Due to the individual’s SSI status and being continuously on benefits, the ONE system attempts to passively approve renewals without requiring worker interaction, leading to potential gaps where signatures are not on file for cases that converted into the new system in 2020 and 2021. The operation lapse occurred because the SSI individual converted into the new system on continuous benefits going through passive renewal processes that do not require direct worker interaction. The State of Oregon is working with the local branch to obtain a verbal signature from the identified individual. Additionally, the State conducted a thorough review of current policies and procedures related to passive renewals for SSI individuals to ensure compliance with federal requirements. • Call center software recordings and verbal signatures has been updated as recently as February 2025 providing staff with clear direction on how to capture the verbal signatures and which recordings to play. • Establishing DOR/Filing Date Eligibility Guide was updated as recently as March 13, 2025, including a chart itemizing the signature types (electronic and paper forms), programs that accept each type, and the corresponding option to select in ONE • Rights and Responsibilities Eligibility Guide was enhanced on Oct. 7, 2024 to add detailed directions to staff on how to capture the signature in ONE, when rights and responsibilities are not issued automatically, the appropriate Rights and Responsibilities to provide for each program and where to find a current signature record on file. • Finally, the Case Action Eligibility Guide has been updated to include specific guidance and examples of when it's appropriate to extend processing timeframes for RFI's. Anticipated Completion Date: May 1, 2025 Contact person: Jennifer Stallsworth, Chief of Staff, ODHS APD, April Gillette, OHA Medicaid Division, Strategic Operations & Improvement Director
Finding 554752 (2024-012)
Significant Deficiency 2024
2024-012 Oregon Health Authority Ensure MMIS rates are accurate and updated timely Management Response: We agree with this recommendation. The conversion factor (CF) for Calendar Year (CY) 2023 was not properly updated in December 2022. The proposed CMS CF value of 86.7850 was incorrectly applied to...
2024-012 Oregon Health Authority Ensure MMIS rates are accurate and updated timely Management Response: We agree with this recommendation. The conversion factor (CF) for Calendar Year (CY) 2023 was not properly updated in December 2022. The proposed CMS CF value of 86.7850 was incorrectly applied to the Medicaid Management Information System (MMIS) instead of the finalized CMS CF value of 85.585. This error occurred due to confusion surrounding an earlier final rule announcement related to the outpatient prospective payment system (OPPS). Recent CMS OPPS publications have simplified the process of identifying the correct final conversion factor. For CY 2023, payments were processed using the proposed CF of 86.7850 rather than the finalized CF of 85.585, as it was the only rate available at the time. No adjustments have been made to date. To address this issue, we are partnering with our software vendor Gainwell to identify the total number of outpatient claims affected by the incorrect CF. We will then develop a timeline, communicate to impacted parties and prepare to implement a Standard Mass Adjustment Process (SMAP) to correct all impacted outpatient claims identified by Gainwell, which were processed with the wrong CF for CY 2023. Please see the timeline below for OHA actions. • Identify all CY 2023 outpatient claims that are impacted by the wrong conversion factor by May 20, 2025. • Change rate from 86.7850 to 85.585 by May 20, 2025. • Communicate with providers about the changes and next steps by May 20, 2025. • Implement a verification and validation process to confirm rates are accurately and delivered on time, completion deadline Dec. 31, 2025. Anticipated Completion Date: April 1, 2026 Contact person: Jennifer Stallsworth, Chief of Staff, ODHS APD, April Gillette, OHA Medicaid Division, Strategic Operations & Improvement Director
View Audit 353343 Questioned Costs: $1
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