Corrective Action Plans

Finding 518921 (2023-007)

Material Weakness 2023

IN

Questioned Costs Procurement, Suspension & Debarment § 200.317 § 200.327

Finding 2022-07 Failure to Create and Implement a Suitable Procurement Policy Condition: The Organization created and implemented a procurement policy to govern its federal expenditures. The procurement policy implemented by the Organization failed to include several key elements, including clearly...

Finding 2022-07 Failure to Create and Implement a Suitable Procurement Policy Condition: The Organization created and implemented a procurement policy to govern its federal expenditures. The procurement policy implemented by the Organization failed to include several key elements, including clearly establishing and governing the various expenditure purchasing thresholds, documenting a sufficient bid process for competitive bid proposals, and standards of conduct covering conflict of interest for employees involved in the bid evaluation process. Further, while the policy was in place, the Organization failed to implement the elements of the policy into its procurement process. As part of audit procedures, 12 transactions were included in the testing population and all 12 were tested. Of the testing group, the auditor identified 4 transactions that required competitive bid procedures for which the Organization failed to conduct. The Organization also failed to document its rationale to limit competition for all items tested. Corrective Actions Taken or Planned: - VOICES will revise and implement a formal Procurement Policy that fully aligns with Uniform Guidance and federal regulations. The updated policy will include: + Clear Purchasing Thresholds: Establish thresholds for micro-purchases, small purchases, and formal procurements (e.g., competitive bidding for purchases exceeding $10,000 or other appropriate limits) - Implement a structured bid process that requires: + Multiple bids for purchases exceeding established thresholds. + Documentation of vendor selection rationale, including why competition was limited, if applicable. - Conduct mandatory training for all staff involved in procurement. - Require all vendors and contractors to be checked against the System for Award Management (SAM.gov) to confirm eligibility and compliance with federal procurement requirements.

View Audit 337399 Questioned Costs: $1

Finding 518920 (2023-006)

Material Weakness 2023

Eclectic Soul Voices Corporation

IN

Allowable Costs / Cost Principles Internal Control / Segregation of Duties Questioned Costs § 200.430

Finding 2022-06 Unallowable and Improperly Documented Payroll Expenditures Condition: The Organization failed to establish critical processes and internal controls over payroll expenditures to ensure compliance with Uniform Guidance requirements and several compliance issues were identified. As par...

Finding 2022-06 Unallowable and Improperly Documented Payroll Expenditures Condition: The Organization failed to establish critical processes and internal controls over payroll expenditures to ensure compliance with Uniform Guidance requirements and several compliance issues were identified. As part of audit procedures, 44 transactions were selected in a testing sample from a population of 243 direct payroll transactions. Of the transactions tested, the auditors noted 8 instances of payroll costs overclaimed by way of claiming the same work effort for the same period on multiple grants. The auditors noted 18 instances of failure to properly calculate and allocate the work effort completed by employees that worked on multiple grants and programs. The auditors noted 9 instances of the Organization failing to have approved pay rates on file that matched the amounts paid to the employees. The auditors also noted a significant lack of supervisory approval on timesheets or other time allocation support. Corrective Actions Taken or Planned: - Conduct mandatory training for all supervisors to reinforce the importance of: + Accurate timesheet approval processes. + Proper time allocation for employees working on multiple grants or programs. + Ensuring timely and consistent documentation of payroll expenditures. - Engage Christy Paddock Advisors LLC (CPA firm) to: + Oversee payroll allocation processes to ensure employee time is properly distributed across grants and programs based on actual work effort. + Implement controls to flag and prevent duplicate payroll charges to multiple grants. + Payroll expense reports will be systematically reviewed and approved by the CPA firm and VOICES’ executive team prior to filing federal claims. - Ensure all approved pay rates are documented, signed, and filed for each employee. - Configure QuickBooks to ensure payroll costs and grant allocations are: + Clearly identifiable and traceable. + Linked to corresponding grants and federal claims. - Revise the PTO policy to address liability and improve tracking by: + Implementing a "use-it-or-lose-it" policy with a defined carryover limit. + Removing PTO payout upon termination to reduce financial exposure. + Communicate the updated policy clearly to staff and implement tracking in payroll systems.

View Audit 337399 Questioned Costs: $1

Finding 518919 (2023-005)

Material Weakness 2023

Eclectic Soul Voices Corporation

IN

Questioned Costs Procurement, Suspension & Debarment Allowable Costs / Cost Principles § 200.402

Finding 2022-05 Unallowable and Improperly Documented Direct Expenditures Condition: The Organization failed to establish critical processes and internal controls over direct expenditures to ensure compliance with Uniform Guidance requirements and several compliance issues were identified. As part ...

Finding 2022-05 Unallowable and Improperly Documented Direct Expenditures Condition: The Organization failed to establish critical processes and internal controls over direct expenditures to ensure compliance with Uniform Guidance requirements and several compliance issues were identified. As part of audit procedures, 81 transactions were selected in a testing sample from a population of 315 direct expense transactions. Of the transactions tested, the auditors noted 15 instances of payments to contractors for work that were not sufficiently documented to support the allocatable work efforts performed on the grants in which they were charged. The auditors noted 4 instances where the costs charged to the federal grant were determined to not be reasonable, as they were either unallowable per Uniform Guidance, or were outside of the allowable costs approved in the federal award budgets. The auditors noted 1 instance of a transaction being claimed twice on different federal grants. The auditors also noted a significant lack of approvals for costs spent, as well as a failure to maintain adequate documentation, as noted in Finding 2023-003. Corrective Actions Taken or Planned: - Develop and implement a formal procurement policy to ensure all contractor and vendor selections are based on program needs and comply with federal regulations. The procurement process will include: + Clear criteria for vendor selection and justification. + Requirement to document scope of work, deliverables, and costs before engaging contractors. + Verification of vendor eligibility against the Suspension and Debarment list. - VOICES’ executive team will formally review, approve, and sign off on all expenditures charged to federal grants. - A pre-approval process for all expenditures over a specific threshold (e.g., $500) will be enforced to ensure costs are allowable, reasonable, and allocable to the appropriate grant - Require all contractors to submit detailed invoices that include: + Specific tasks performed + Hours worked or deliverables completed + Allocation to the corresponding grant(s) - Implement procedures to ensure expenses are not claimed more than once on multiple grants. This will include: + Regular reconciliation of federal grant expenses. + Review of expenditures by the executive team and CPA firm to detect duplicates. - Create and enforce a policy for documentation that requires all expenditures over a specific amount to be supported by: + Invoices or receipts + Approved requisition forms + Proof of deliverables (for contractors)

View Audit 337399 Questioned Costs: $1

Finding 518915 (2023-008)

None 2023

Eclectic Soul Voices Corporation

IN

Reporting Questioned Costs § 200.512

Finding 2022-08 Late Issuance of 2023 Single Audit Reporting Package Condition: The Organization is required to submit the reporting package by the deadline required by Uniform Guidance, which was September 30, 2024, for the year ended December 31, 2023. The Organization failed to file their report...

Finding 2022-08 Late Issuance of 2023 Single Audit Reporting Package Condition: The Organization is required to submit the reporting package by the deadline required by Uniform Guidance, which was September 30, 2024, for the year ended December 31, 2023. The Organization failed to file their report by this deadline. Corrective Actions Taken or Planned: - VOICES has engaged a licensed CPA firm with expertise in Single Audit reporting and federal compliance. The CPA firm will work proactively with VOICES to ensure that all financial statements, schedules, and compliance documents are completed, reviewed, and filed well in advance of the reporting deadline. - VOICES’ executive team and the CPA firm will perform quarterly reviews to detect and resolve issues early, reducing delays during the annual audit process. - Assign internal staff responsibilities to ensure all documents are prepared and reviewed ahead of the audit.

View Audit 337399

Finding 518870 (2023-003)

Material Weakness 2023

The Astraea Foundation, Inc.

NY

Questioned Costs Allowable Costs / Cost Principles Material Weakness

Views of Responsible Officials: All Astraea staff members are required to complete timesheets. Astraea’s internal processes were reviewed and overhauled in December 2021 (midway through FY2022) with department heads determining how their direct reports would spend time on various Astraea work stream...

Views of Responsible Officials: All Astraea staff members are required to complete timesheets. Astraea’s internal processes were reviewed and overhauled in December 2021 (midway through FY2022) with department heads determining how their direct reports would spend time on various Astraea work streams and projects.This information is detailed in a level of effort (LOE) spreadsheet tracked against timesheets and budgets regularly. However, the processes for instituting regular updates to the LOE spreadsheet and timesheet allocations remained time-consuming and highly manual in FY2023 – which we believe resulted in misallocations. Astraea is currently reviewing internal processes to ensure, 1) that review and revision of the LOE spreadsheet and timesheet allocations can happen in a timely manner with less administrative burden, and 2) allowance of a more detailed review of the payroll allocation approval and entry process. As of November 2024, the Astraea Finance team was in the process of transitioning to a more sophisticated finance and accounting system. This system will allow for automation of the processes. Since this system is expected to be live starting in January of 2025, the anticipated completion date remains January 31, 2025.

View Audit 337275

Finding 518748 (2023-002)

Significant Deficiency 2023

Housing Authority of the City of Norwalk

CT

Questioned Costs HUD Housing Programs Eligibility

Finding 2023-002 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Section 8 Housing Choice Vouchers Program Federal Catalog Numbers: 14.871 Noncompliance – E. Eligibility - Tenant Files Non Compliance Material to the Financial Statements: No Significant Defici...

Finding 2023-002 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Section 8 Housing Choice Vouchers Program Federal Catalog Numbers: 14.871 Noncompliance – E. Eligibility - Tenant Files Non Compliance Material to the Financial Statements: No Significant Deficiency in Internal Control over Compliance for Eligibility Criteria: Tenant Files. The PHA must do the following: As a condition of admission or continued occupancy, require the tenant and other family member to provide necessary information, documentation, and releases for the PHA to verify income eligibility (24 CFR sections 5.230, 5.609, and 982.516). These files are required to be maintained and available for examination at the time of audit. Condition: Based upon inspection of the Authority’s files and on discussion with management, there were documents that were unavailable for examination at the time of audit. Context: Of a sample size of twenty-two (22) tenant files, the following information was unavailable for examination at the time of audit: • Biennial inspection reports were missing in two (2) files Our sample size is statistically valid. Known Questioned Costs: $21,520 Cause: There is a significant deficiency in internal controls over the compliance for the eligibility type of compliance related to the maintenance of tenant files. The Authority has not properly considered, designed, implemented, maintained, and monitored a system of internal controls that reasonably assures the program is in compliance. Effect: The Section 8 Housing Choice Vouchers program is in non-compliance with the eligibility type of compliance related to the maintenance of tenant files. Recommendation: We recommend the Authority design and implement internal control procedures that will reasonably assure compliance with the Uniform Guidance and the compliance supplement. Views of responsible officials and planned corrective action: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Section 8 Housing Choice Vouchers program to ensure that established internal control policies are being followed on a timely basis. Adam Bovilsky, Executive Director, is responsible for implementing this corrective action by March 31, 2024.

View Audit 337205 Questioned Costs: $1

Finding 518701 (2023-007)

Significant Deficiency 2023

State of Mississippi

MS

Subrecipient Monitoring Allowable Costs / Cost Principles Questioned Costs § 200.303 § 200.308 § 200.309 § 200.403

2023-007 Assistance Listing No. 96.001 , 96.006 and Social Security Disability lnsurance Cluster Type of Compliance Requirement: Period of Performance lnternal controls over period of performance were not consistentlv performed Response: Of the five instances noted in the auditor's "Period of Perfor...

2023-007 Assistance Listing No. 96.001 , 96.006 and Social Security Disability lnsurance Cluster Type of Compliance Requirement: Period of Performance lnternal controls over period of performance were not consistentlv performed Response: Of the five instances noted in the auditor's "Period of Performance" test work, we concur with four. With one of the sample items, however, we argue that since the service was invoiced on a State Fiscal Year, it was impractical to further split the invoice into the various appropriate Federal periods of performance, especially given the way those specific invoices are allocated between other shared program areas within our agency, etc. Corrective Action Plan: Our agency takes these findings seraously and will continue to evaluate ways of improving controls. At a minimum, it is our intent to increase and provide additional training to the staff overseeing and approving these types of transactions so that they can accurately apply transactions to the appropriate periods. This was something we had already begun (i.e. provrding additional guidance and training to stafD during the current fiscal year. So, we hope our agency is already on a corrective path. But, we will continue to push for more training in the immediate future and strive for improvement in all other aspects. We also think it is important to note that, of the findings identifled by the auditors related to "Period of Performance," those items were discovered out of a total sample size oI 120 items (i.e. 60 sample items related to thejr "Period of Performance" test work and 60 sample items related to "General Disbursements" test work). So, a slightly larger sample size than that of the 60 referenced in the auditor's schedule of flndings. Additionally, the auditor's sample appeared to selectively target the specific periods and transactions that would have been most susceptible to these types of potential errors. And, although we are not objecting to the way in which the sample was selected, we would.just point out that this approach of sample selection may not be truly reflective of a purely random sample covering all transactions across the entire fiscal year. Therefore, although we ultimately concur with the findings here, we do not necessarily believe these results paint the fairest picture on the overall effectiveness of our agency's controls across the more than '100,000 transactions that would have been processed during the period of audit for this program. Again, we take these findings seriously. But, based on the audit test work and results, we feel the controls we have in place are ultimately working adequately enough to mitigate the potential for material misstatements. Regardless, we will continue to monitor and evaluate our controls to help further reduce the risk of these types of issues moving forward. Planned completion date for corrective action plan: lmmediately. But, additional training for managers to be provided by September 30, 2024.

View Audit 337153 Questioned Costs: $1

Finding 518700 (2023-008)

Significant Deficiency 2023

State of Mississippi

MS

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles § 200.303

2023-008 Assistance Listing No. 96.001, 96.006 and Social Security Disability lnsurance Cluster Type of Compliance Requirement: Allowable Costs lnternal Controls gtver glant disbursements were not consistently performed Response: There is no disagreement with the audit finding. Corrective Action Pla...

2023-008 Assistance Listing No. 96.001, 96.006 and Social Security Disability lnsurance Cluster Type of Compliance Requirement: Allowable Costs lnternal Controls gtver glant disbursements were not consistently performed Response: There is no disagreement with the audit finding. Corrective Action Plan: Item is isolated and immaterial. And, we feel effective controls are in place to mitigate the likelihood of this type of error. We have also, since, reached out to the vendor to redeem the $14 associated with this transaction. However, we will continue to monitor and reinforce, with our managers, the importance of being vigilant during their review and approval processes for this type of situatlon. Planned completion date for corrective action plan: lmmediately Name(s) of the contact person(s) responsible for corrective actions: Andy Salin Finance Director 601-853-5220.

View Audit 337153 Questioned Costs: $1

Finding 518693 (2023-024)

Material Weakness 2023

State of Mississippi

MS

Eligibility Questioned Costs Material Weakness § 200.09

93.767 Children's Health Insurance Program (CHIP) 93.778 Medical Assistance Program (Medicaid; Title XIX) Eligibility 2023-024 Strengthen Controls to Ensure Compliance with Eligibility Requirements of the Children's Health Insurance Program (CHIP) and the Medical Assistance Program DOM Response: Use...

93.767 Children's Health Insurance Program (CHIP) 93.778 Medical Assistance Program (Medicaid; Title XIX) Eligibility 2023-024 Strengthen Controls to Ensure Compliance with Eligibility Requirements of the Children's Health Insurance Program (CHIP) and the Medical Assistance Program DOM Response: Use of Tax Return Resources Seven MAGI beneficiaries - DOM did not verify self-employment income reported on tax return DOM Does Not Concur. OSA compared eligibility data to state income tax returns. DOM is prohibited from accessing state income tax records per Mississippi Code Annotated §27-3-73 and currently, is not allowed to have access to federal income tax records. DOM maintains that for determining eligibility, it has complied with the CMS-approved state plan. Using the approved CMS MAGI Based Verification plan in effect during the audit time period, the state sought to verify the reported income to the standard of reasonable compatibility, as defined by CMS, through all available electronic data sources. Further, DOM is required to accept the information provided by the applicant and utilize the available verification methods as detailed in the CMS-approved state plan to evaluate the accuracy of the information provided. If an applicant does not report self-employment income, and the tools available to DOM do not reveal such, DOM has performed its due diligence in the eligibility process and complied with the requirements of CMS, DOM's federal regulatory and oversight agency. Additionally, tax return information is outdated and not deemed applicable to DOM. Four of the 180 MAGI beneficiaries - Income was not verified through Mississippi Department of Employment Security DOM Concurs. This oversight was reviewed with the employees. Additionally, DOM Eligibility staff will be reminded of the MOES response time to ensure that when a MOES request is generated the adequate response time is waited prior to processing an application. Two of the 300 beneficiaries - The beneficiary's case file did not contain a completed application. DOM Concurs. This file could not be located. One of the 300 beneficiaries - DOM could not provide a case file. DOM Concurs. This file could not be located. Fifteen ABD beneficiaries - Resources were not verified through A VS at the time of redetermination. DOM Concurs. This was a previous finding that DOM concurred with. In June 2022, the eligibility system change request list was updated to include asset checks within the system processing workflow to eliminate the manual request process and facilitate asset verification through A VS. This process was implemented June of 2022 for redetermination contacts. Application contacts are a manual process. DOM did not perform resource verification through A VS for the beneficiaries in question prior to this implementation. However, after being notified DOM ran A VS for all applicants, which resulted in no change in the eligibility determination. One hundred ninety-five beneficiaries were not included on all of the required quarterly Public Assistance Reporting Information System (PARIS) me transmissions for fiscal year 2023. Of the 195 beneficiaries, one beneficiary was not included on any quarterly PARIS me transmissions during fiscal year 2023. DOM Does not Concur. PARIS jobs run on February 1, May 1, August 1, and November 1. PARIS will not be pulled on a beneficiary if the case is closed at the time the file is generated or if there is no SSN on file. Additionally, while the records are sent, not all the cases return a match. Our vendor confirmed that a PARIS request was sent for the open cases with SSN numbers on file with one exception. One case was in COE 29-Family Planning. The omission was identified in a previous audit and was corrected in late 2023. DOM Corrective Action Plan: a. All issues identified will be reviewed with regional office staff. Examples of these issues will be included in annual training sessions performed by Eligibility staff. Further, DOM is implementing an electronic storage system to house all documents associated with applicants/beneficiary files. b. Cindy Bradshaw c. December 31, 2024

View Audit 337153 Questioned Costs: $1

Finding 518679 (2023-017)

Material Weakness 2023

State of Mississippi

MS

Subrecipient Monitoring Internal Control / Segregation of Duties Questioned Costs

SUBRECIPIENT MONITORING ALN Number 2023-017 Response: 93.568 Low Income Home Energy Assistance (LIH EAP) 93.489, 93.575, and 93 .596 Child Care Deve lopment Fund (CCDf-') Strenl.!.lhen Controls Over Onsite Monitorirw for the Low-Income Home Enerl.!.v Assistance Program ( LI HEAP). MOHS Concurs that ...

SUBRECIPIENT MONITORING ALN Number 2023-017 Response: 93.568 Low Income Home Energy Assistance (LIH EAP) 93.489, 93.575, and 93 .596 Child Care Deve lopment Fund (CCDf-') Strenl.!.lhen Controls Over Onsite Monitorirw for the Low-Income Home Enerl.!.v Assistance Program ( LI HEAP). MOHS Concurs that cont ro ls should be strengthened over On-Site monitoring for the LIHEAP and CCDF. Corrective Action Plan: I. Strengthen cont ro ls over the subrec ipienl monitoring process: A. The Office of Compliance, Division of Monitoring has made sign ifi cant strides in strength ening cont ro ls over the subreci pient monitor ing process. The Division continues to rev iew and update the processes and procedures as necessary to ensure processes are adeq uate and effective. Staff are constantly notified/trained on updates to poli cies, procedures, and regulations to ensure continued compliance with monitoring the agency's subgrant agreem ents. Additionally, the Division is in the process of implementing a case management system to ass ist in better track ing the status of monitoring reviews. B. Responsible Party: Kameron Harri s, Chief Compliance Officer, Director of Monitoring, Laketha Gilmore C. Completion Date: This corrective action has been implemented and is ongoi ng.

View Audit 337153

Finding 518675 (2023-018)

Material Weakness 2023

State of Mississippi

MS

Subrecipient Monitoring Questioned Costs Material Weakness § 200.331 § 200.501 § 200.512

SUBRECIPIENT MONITORING ALN Number 93.558 Temporary Assistance for Needy Families (TANF) 93.489, 93.575, 93.596 Child Care Development Fund (CCDF) 93.568 Low Income Household Energy Ass istance Program (LIHEAP) 2023-018 Strengthen Controls over Subrecipient to Ensure Compliance with Uniform Guidance...

SUBRECIPIENT MONITORING ALN Number 93.558 Temporary Assistance for Needy Families (TANF) 93.489, 93.575, 93.596 Child Care Development Fund (CCDF) 93.568 Low Income Household Energy Ass istance Program (LIHEAP) 2023-018 Strengthen Controls over Subrecipient to Ensure Compliance with Uniform Guidance Auditing Requirements. Response: MOHS concurs that it needs to strengthen controls over subrecipient monitoring for the Child Care Development Fund (CCDF) and Temporary Assistance for Needy f amilies (TANF) programs to conform with Uniform Guidance. Corrective Action Plan: I . Strengthen cont rol over the subrecipient to ensure compliance with Uniform Guidance Requirements: A. The Office of Compliance, Division of Monitoring has made significant strides in strengthening controls over the subrecipient monitoring process. The Division continues to review and update the processes and procedures as necessary to ensure processes are adequate and effective. Staff are constantly notified/trained on updates to policies, procedures. and regulations to ensure continued compliance with monitoring the agency's subgrant agreements. Additionally, the Division is in the process of implementing a case management system to assist with this process. 8. Responsible Parties: Kameron Harris, Chief Compliance Officer, Director of Monitoring, Laketha Gilmore C. Anticipated Completion Date: This corrective action has been implemented and is ongoing.

View Audit 337153

Finding 518674 (2023-016)

Material Weakness 2023

State of Mississippi

MS

Internal Control / Segregation of Duties Questioned Costs Subrecipient Monitoring

REPORTING ALN Number 2023-016 Response: 93.558 Temporary Assistance for Needy Families (TANI') 93.568 Low Income Home Energy Assistance (LIH EAP) 93.489, 93.596 and 93.575 Child Care Development Fund (CCDF) Strengthen Controls to Ensure Compliance with l'ecleral Fundinl.!. Accountabi litv and Transp...

REPORTING ALN Number 2023-016 Response: 93.558 Temporary Assistance for Needy Families (TANI') 93.568 Low Income Home Energy Assistance (LIH EAP) 93.489, 93.596 and 93.575 Child Care Development Fund (CCDF) Strengthen Controls to Ensure Compliance with l'ecleral Fundinl.!. Accountabi litv and Transparency Act ffF AT A) req uirements. MOHS concurs that controls should be strengthened over FF AT A reporting requirements. Corrective Action Plan: I. Strengthen controls to ensure compliance with FFATA reporting requirements. A. MOHS implemented a process as of January I. 2023, to ensure that FFATA reporting is being clone and verified on a periodic basis. After doing an initial submission of reports the first year and completing the process, Standard Operating Procedures were deve loped to ensure that the reports are entered, rev iewed and submitted within the required tim efram e. B. Responsible Parties: Debra Dixon, Deputy of Finance and Samuel Cole, Director of Procurement Services C. Anticipated Completion Date: This correct ive action has been implemented.

View Audit 337153

Finding 518670 (2023-014)

Significant Deficiency 2023

State of Mississippi

MS

Questioned Costs Subrecipient Monitoring Reporting

Single Audit Finding (1) Strengthen Controls to Ensure Compliance with Federal Funding Accountability and Transparency Act (FFATA) Requirements ALN: 84.425 Education Stabilization Fund Program: ARP —-Elementary and Secondary School Emergency Relief for Homeless Children and Youth (ARP-HCY) Type of C...

Single Audit Finding (1) Strengthen Controls to Ensure Compliance with Federal Funding Accountability and Transparency Act (FFATA) Requirements ALN: 84.425 Education Stabilization Fund Program: ARP —-Elementary and Secondary School Emergency Relief for Homeless Children and Youth (ARP-HCY) Type of Compliance Requirement: Reporting Audit Finding No.: 2023-014 Response: MDE concurs with the finding and recommendation related to strengthening its controls to ensure compliance with FFATA reporting requirements. During the audit period, the Office of Grants Management (OGM) at MDE determined FFATA reporting would be necessary after an application received the Local Educational Agency (LEA) Superintendent’s approval in MDE’s grants management system, MCAPS. However, in implementing this procedure, MDE determined this was an unsuccessful method to report FFATA, as the date of signature varied across different subrecipients, and thus would be too administratively burdensome to monitor effectively. As such, OGM has revised its FFATA reporting methodology to report on awards immediately at the time of allocation, rather than waiting for Superintendent signature within MCAPS. Corrective Action Plan: a. In June 2023, OGM updated its FFATA reporting methodology to require reporting immediately at the time of issuing subawards and distributed a memo on the updated procedures to all relevant staff. By June 15, 2023, all outstanding FFATA reports were submitted, demonstrating implementation of this updated process. OGM continues to monitor timely FFATA reporting, consistent with the updated procedures. b. OGM Staff, Shanika Jackson and Elisha Campbell, are responsible for overseeing this corrective action. c. These corrective actions have been implemented.

View Audit 337153

Finding 518668 (2023-025)

Material Weakness 2023

State of Mississippi

MS

Subrecipient Monitoring Internal Control / Segregation of Duties Questioned Costs § 200.303

2023-025 Response: Strengthen Controls to Ensure Compliance with Eligibility Requirements for the Emergency Rental Assistance Program (ERA). ALN# 21.023 We acknowledge the finding. The Mississippi Department of Finance and Administration was not appropriated funds for this program nor was the agency...

2023-025 Response: Strengthen Controls to Ensure Compliance with Eligibility Requirements for the Emergency Rental Assistance Program (ERA). ALN# 21.023 We acknowledge the finding. The Mississippi Department of Finance and Administration was not appropriated funds for this program nor was the agency given any authority for the administration for the program. As such, DFA was not in a position to assess eligibility determinations or perform monitoring. DFA drew down funds on behalf of Mississippi Home Corp in light of an impending federal deadline. Mississippi Home Corporation had eligibility and fraud prevention policies in place for the ARPA programs. These policies included, but are not limited to, contracting with a third-party law firm to review all applications with a three-tier review system, monitoring with random sample selections for every 10% completed, employing an internal, qualitycontrol auditor, and reviewing any applications submitted that were greater than $10,000. As a result of their monitoring, MHC was able to identify suspicious applications and report them to the Mississippi Attorney General for investigation. MHC continues to report all expenditures directly to U.S. Treasury on a quarterly basis. It is also worth noting that the program stopped taking applications in September of 2022 which was prior to the issuance of the 2022 Single Audit Report that was released on July 31, 2023. Thus, policies and controls in place could not be changed for this. DFA is taking the position that corrective action is no longer necessary for these funds. Corrective Action: A. The Mississippi Department of Finance and Administration is taking the position that corrective action is no longer necessary. The program stopped taking applications in September of 2022, which is prior to the current 2023 single audit report dated November 21, 2024. Policies and controls in place could not be changed for this. B . N/A C. N/A D. The Emergency Rental Assistance program stopped taking applications September of 2022.

View Audit 337153

Finding 518660 (2023-010)

Material Weakness 2023

State of Mississippi

MS

Questioned Costs Subrecipient Monitoring Material Weakness § 200.303

Reference Number: 2023-001 Prior Year Finding: No Federal Agency: U.S. Department of Labor Department Name: Mississippi Department of Employment Security Federal Program: WIOA Cluster Assistance Listing Number: 17.258, 17.259, 17.278 Award Number and Year: 7/1/22 – 6/30/23 Compliance Requirement: Re...

Reference Number: 2023-001 Prior Year Finding: No Federal Agency: U.S. Department of Labor Department Name: Mississippi Department of Employment Security Federal Program: WIOA Cluster Assistance Listing Number: 17.258, 17.259, 17.278 Award Number and Year: 7/1/22 – 6/30/23 Compliance Requirement: Reporting – Federal Funding Accountability and Transparency Act (FFATA) Type of Finding: Material Weakness in Internal Control Over Compliance, Material Noncompliance Criteria or specific requirement: Compliance: Per the Federal Funding Accountability and Transparency Act (FFATA), prime (direct) recipients of grants or cooperative agreements are required to report firsttier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Reports must be filed in FSRS by the end of the month following the month in which the prime recipient awards any sub-grant greater than or equal to $30,000. If the initial award is below $30,000 but subsequent grant modifications result in a total award equal to or over $30,000, the award will be subject to the reporting requirements as of the date the award exceeds $30,000. If the initial award equals or exceeds $30,000 but funding is subsequently de-obligated such that the total award amount falls below $30,000, the award continues to be subject to FFATA reporting requirements. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The Mississippi Department of Employment Security (MDES) did not report subaward information to FSRS within thirty days after issuing the subaward or subaward amendment. Context: Nine subawards were selected for testing which included five original subawards and four amendments. We noted the following exceptions:  1 of 9 subawards should have been reported by 11/30/2022 but was not reported before the end of FY 2023. The subaward was subsequently reported in February 2024.  3 of 9 subawards should have been reported by 5/31/2023 but were not reported before the end of FY 2023. The subawards were subsequently reported in February 2024.  4 of 9 subawards should have been reported no later than 2/28/2023 but they were reported on 3/29/2023, or 29 days late. Cause: MDES’s procedures and controls were not sufficient to ensure that subawards were reported to FSRS no later than the end of the month following the month of issuance. Effect: Subawards were not reported to FSRS in accordance with FFATA requirements. Questioned costs: None noted. Recommendation: We recommend MDES establish procedures and internal controls to ensure that all required subawards are reported timely to FSRS no later than the end of the month following the month of issuance of each subaward. Views of responsible officials: MDES Response MDES concurs that the program year 2022 subawards were not entered into the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS) within thirty days of subaward issuance. The practice of MDES has been to enter all subawards into the FSRS at one time and later perform a look back to determine the adjustments needed to bring the reported balances up or down based on subaward amendments made during the year. Specifically, for program year 2022 subawards, the initial entry into FSRS was on 3/29/2023 with the post award adjustment entry made February 23, 2024. Corrective Action Plan: a. MDES Plan: MDES will strengthen controls around FSRS reporting to ensure subawards are reported to FSRS within thirty days of issuance. MDES will also monitor subaward amendments and ensure they are reported within thirty days of issuance. Entries into the FSRS will be reviewed by the supervisor to ensure compliance. This process is effective immediately. b. Contact Person Responsible: Comptroller. c. Anticipated Corrective Action Plan Completion Date: July 15, 2024.

View Audit 337153

Finding 518659 (2023-012)

Significant Deficiency 2023

State of Mississippi

MS

Eligibility Questioned Costs Significant Deficiency § 200.303

Reference Number: 2023-003 Prior Year Finding: No Federal Agency: U.S. Department of Labor State Agency: Mississippi Department of Employment Security Federal Program: WIOA Cluster Assistance Listing Number: 17.258, 17.259, 17.278 Award Number and Year: 7/1/22 – 6/30/23 Compliance Requirement: Eligi...

Reference Number: 2023-003 Prior Year Finding: No Federal Agency: U.S. Department of Labor State Agency: Mississippi Department of Employment Security Federal Program: WIOA Cluster Assistance Listing Number: 17.258, 17.259, 17.278 Award Number and Year: 7/1/22 – 6/30/23 Compliance Requirement: Eligibility Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Compliance – Per 20 CFR parts 680, 681, 682, and 683, state workforce agencies must ensure that individuals are eligible to participate in the program. Control – Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The Mississippi Department of Employment Security (MDES) was unable to provide documentation that the eligibility determination for a participant had been reviewed and approved. Context: Documentation for one of forty participants selected for testing did not contain a supervisor’s signature indicating that it had been reviewed and approved. Questioned costs: Undetermined. Cause: Internal controls were not sufficient to ensure that documentation supporting participant eligibility was reviewed and approved by a supervisor. Effect: Failure to ensure that all eligibility documentation is properly reviewed and approved could result in ineligible individuals participating in the program. Recommendation: MDES should review and enhance internal controls and procedures to ensure that participant eligibility documentation is properly reviewed and approved by a supervisor. Views of responsible officials: MDES Response MDES concurs with this finding and recommendation. These incidents were isolated and non-reoccurring. MDES will implement procedures to require a review of all eligibility documents for completeness. Corrective Action Plan: a. MDES Action Plan: MDES will require, as a compensating control for each file to contain a checklist of required documentation that will be reviewed and approved by the supervisor responsible for the respective job center. MDES will verify internal compliance with these procedures over the next quarter. b. Contact Person Responsible: Director of Grant Management. c. Anticipated Corrective Action Plan Completion Date: MDES will complete this corrective action on or before September 30, 2024.

View Audit 337153

Finding 518656 (2023-009)

Significant Deficiency 2023

State of Mississippi

MS

Questioned Costs Special Tests & Provisions Significant Deficiency § 200.303

Reference Number: 2023-001 Prior Year Finding: No Federal Agency: U.S. Department of Labor Department Name: Mississippi Department of Employment Security Federal Program: Unemployment Insurance Assistance Listing Number: 17.225 Award Number and Year: 7/1/22 – 6/30/23 Compliance Requirement: Special ...

Reference Number: 2023-001 Prior Year Finding: No Federal Agency: U.S. Department of Labor Department Name: Mississippi Department of Employment Security Federal Program: Unemployment Insurance Assistance Listing Number: 17.225 Award Number and Year: 7/1/22 – 6/30/23 Compliance Requirement: Special Tests and Provisions – UI Benefit Payments Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Compliance: The State Workforce Agency (SWA) is required by 20 CFR section 602.11(d) to operate and maintain a quality control system. The Benefits Accuracy Measurement (BAM) program is DOL’s quality control system designed to assess the accuracy of UI benefit payments and denied claims, unless the SWA is exempted from such requirement (20 CFR section 602.22). The program estimates error rates, that is, numbers of claims improperly paid or denied, and dollar amounts of benefits improperly paid or denied, by projecting the results from investigations of statistically sound random samples to the universe of all claims paid and denied in a state. Specifically, the SWA’s BAM unit is required to draw a weekly sample of payments and denied claims, complete prompt, and in-depth investigations to determine if the administration of the UC program is consistent with state and federal law (20 CFR section 602.21(d)). As presented in the ET Handbook No. 395, the investigation involves a review of state agency records, as well as contacting the claimant, employers, and third parties (either inperson, by telephone, or by fax) to conduct new and original fact-finding related to all of the information pertinent to the paid or denied claim that was sampled. BAM investigators review cases for adherence to federal and state law as well as official policy. The following time limits are established for completion of all cases for the year. (The "year" includes all batches of weeks ending in the calendar year.): • a minimum of 70 percent of cases must be completed within 60 days of the week ending date of the batch; • 95 percent of cases must be completed within 90 days of the week ending date of the batch; • a minimum of 98 percent of cases for the year must be completed within 120 days of the ending date of the calendar year. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The Mississippi Department of Employment Security (MDES) was unable to provide documentation that case reviews were reviewed and approved by investigator staff. Context: One of forty cases selected for testing did not have documentation of investigator review and approval. Questioned costs: Undetermined. Cause: The Department’s internal controls were not sufficient to ensure that it maintained documentation of investigator review and approval for all BAM case reviews. Effect: Incomplete documentation of BAM case reviews could delay the detection and correction of inaccurate benefit payments and denied claims. Recommendation: We recommend the Department review and enhance procedures and controls to ensure that documentation of investigator review, and approval of all BAM case reviews is maintained. Views of responsible officials: MDES Response MDES concurs with this finding. Corrective Action Plan: a. MDES Plan: MDES will provide additional training to BAM investigative staff and supervisors to remind them of the importance of complying with federal regulations requiring all investigative staff to document their work on the final approved reviews of the BAM cases with a signature. b. Contact Person Responsible: Director Unemployment Insurance – Tax. c. Anticipated Corrective Action Plan Completion Date: July 31, 2024.

View Audit 337153

Finding 518634 (2023-007)

Significant Deficiency 2023

Mandaree Public School District No 36

ND

Questioned Costs Reporting

Contact Person: Business Manager Planned Corrective Action: The District hired a new Business Manager in October 2024 with the expectation that the District will return to compliance with the Uniform Guidance requirements. Planned Completion Date: March 31, 2025

View Audit 337094

Finding 518352 (2023-003)

Significant Deficiency 2023

West Baton Rouge Parish School Board

LA

Questioned Costs Subrecipient Monitoring Reporting

The School board will develop a formal process to monitor the submission of all required reports to ensure that all reports are submitted timely in compliace with te applicable requirements of grant agreements.

View Audit 336737

Finding 518327 (2023-003)

Material Weakness 2023

Community Action Team, Inc.

OR

Questioned Costs Procurement, Suspension & Debarment Subrecipient Monitoring § 200.303

2023-003 Federal Award Special Reporting – Federal Funding Accountability and Transparency Act (FFATA) – Material Non-Compliance and Material Weakness in Internal Controls over Compliance Recommendation: The Organization should establish written policies and procedures regarding review of grant agre...

2023-003 Federal Award Special Reporting – Federal Funding Accountability and Transparency Act (FFATA) – Material Non-Compliance and Material Weakness in Internal Controls over Compliance Recommendation: The Organization should establish written policies and procedures regarding review of grant agreements for compliance requirements along with written policies and procedures for first-tier subawards including tracking and proper internal control procedures. Action Taken: Management concurs with the finding and has defined corrective action to address it. We have identified gaps in our reporting processes and worked to implement changes to ensure compliance with special reporting requirements. Policies and procedures will be updated regarding special reporting requirements. The Fiscal department will also be responsible for reviewing all contracts to identify all compliance requirements. Tracking procedures will be implemented to ensure reports are filed timely. The above identified corrective action was implemented in July 2024. Stacey Wilson, Fiscal Director, has implemented a tracking system for the FFATA.

View Audit 336686

Finding 518155 (2023-002)

Material Weakness 2023

Nebraska Children's Home Society

NE

Questioned Costs Subrecipient Monitoring Material Weakness

NCHS has established a new structure, policy, and procedures. This new structure has the COO managing the accounting functions of Finance. We are currently fully staffed within our accounting department, with more SOP and a new software system that better supports the department. The COO and Account...

NCHS has established a new structure, policy, and procedures. This new structure has the COO managing the accounting functions of Finance. We are currently fully staffed within our accounting department, with more SOP and a new software system that better supports the department. The COO and Accounting team now adheres to protocols and timelines that ensure timely and accurate completion of accounting tasks. The COO will continue to work with our auditors to ensure NCHS meet the filing deadlines.

View Audit 336471

Finding 518154 (2023-001)

Material Weakness 2023

Nebraska Children's Home Society

NE

Subrecipient Monitoring Reporting Questioned Costs

To increase controls and improve preparation of accounting records. NCHS has reorganized the finance department. The accounting functions are now a part of Operations. With accounting reporting to operations, the Chief Operations Officer (COO) now oversees and provides support and leadership to this...

To increase controls and improve preparation of accounting records. NCHS has reorganized the finance department. The accounting functions are now a part of Operations. With accounting reporting to operations, the Chief Operations Officer (COO) now oversees and provides support and leadership to this division of Finance. The COO has created and implemented new Standard Operation Processes (SOP). These new SOPs clearly define, documents, and support all accounting activities. The SOPs cover critical areas, including contract and grants management, reconciliation processes and month-end closings. The responsibilities of the accounting team are now clearly delineated, providing more transparency and accountability. A formal schedule for processing and reconciliation tasks has been established and maintained by the Senior Accountant. These schedules are reviewed monthly with the COO to ensure accuracy and timely completion of accounting tasks are occurring.

View Audit 336471

Finding 518152 (2023-016)

Material Weakness 2023

Mental Health Association of Columbia-Greene Counties Inc.

NY

Allowable Costs / Cost Principles Questioned Costs Procurement, Suspension & Debarment

All management will be educated on the procurement policy as well as the information noted from the CFR sections indicated in the findings by the Director of Finance. The Director of Finance will research and provide education to the Executive Leadership related to this finding during the Executive ...

All management will be educated on the procurement policy as well as the information noted from the CFR sections indicated in the findings by the Director of Finance. The Director of Finance will research and provide education to the Executive Leadership related to this finding during the Executive Leadership meeting. All Grants and cooperative agreements must be filed with the fiscal department. All expenditures must be approved prior to purchase / payment with sign off from Executive Director or Director of Finance.

View Audit 336457

Finding 518146 (2023-014)

Material Weakness 2023

Mental Health Association of Columbia-Greene Counties Inc.

NY

Procurement, Suspension & Debarment Period of Performance Questioned Costs § 200.1 § 200.308 § 200.309 § 200.344

All management will be educated on the procurement policy as well as the information noted from the CFR sections indicated in the findings by the Director of Finance. The Director of Finance will research and provide education to the Executive Leadership related to this finding during the Executive ...

All management will be educated on the procurement policy as well as the information noted from the CFR sections indicated in the findings by the Director of Finance. The Director of Finance will research and provide education to the Executive Leadership related to this finding during the Executive Leadership meeting. All Grants and cooperative agreements must be filed with the fiscal department. All expenditures must be approved prior to purchase / payment with sign off from Executive Director or Director of Finance.

View Audit 336457

Finding 517982 (2023-001)

Material Weakness 2023

Arkansas Hospice, Inc.

AR

Questioned Costs Reporting Internal Control / Segregation of Duties

Responsible Party: Judy Wooten, President and CEO Finding 2023-001 (UG) The Organization chose to report under the alternative reporting methodology (option iii). Under this option, the Organization submitted a memo describing its reasonable method of estimated revenues. The methodology described i...

Responsible Party: Judy Wooten, President and CEO Finding 2023-001 (UG) The Organization chose to report under the alternative reporting methodology (option iii). Under this option, the Organization submitted a memo describing its reasonable method of estimated revenues. The methodology described in the memo does not agree with the amounts the Organization reported in the portal. The Organization's calculated lost revenue under its alternative reporting methodology was approximately $2,742,000 more than the amount the Organization reported in the PRF portal. Recommendation We recommend implementing controls to ensure amounts reported are accurate, complete and reviewed. Comments on the Finding and Recommendation Management is in agreement with this finding and the related recommendation. Action(s) Taken or Planned on the Finding Management will implement controls to ensure all reports are accurate, complete, and reviewed. Estimated completion date for the above-mentioned corrective action is September 30, 2024.

View Audit 336237

Corrective Action Plans

Filters