Corrective Action Plans

Finding 395394 (2023-005)

Significant Deficiency 2023

Lancaster County Career and Technology Center

PA

Questioned Costs Subrecipient Monitoring Cash Management

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

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

View Audit 305132 Questioned Costs: $1

Finding 395387 (2023-002)

Significant Deficiency 2023

Lancaster County Career and Technology Center

PA

Questioned Costs Subrecipient Monitoring

The Center did not file the required quarterly reports for June 2023 and had a late filing for September 2022 report for grant #224-21-1161. Also, the Center did not file quarterly reports for June 2023 and September 2022 for grant #380-23-0039 and #381-23-0014. Response and Planned Corrective Actio...

The Center did not file the required quarterly reports for June 2023 and had a late filing for September 2022 report for grant #224-21-1161. Also, the Center did not file quarterly reports for June 2023 and September 2022 for grant #380-23-0039 and #381-23-0014. Response and Planned Corrective Action: The Center has implemented a series of reminders in the email and calendar system for the Business Manager, the Assistant Business Manager, and the Administrative Director to ensure that timely submission of the quarterly reporting is completed. Planned Corrective Action: To be implemented immediately. · The Business Manager/Asst. Business Manager will establish additional procedures to ensure that the Center files all quarterly cash on hand within 10 days of quarter ending and final expenditure reports within 30 days after the funds are expended, but no later than 30 days after the ending date of the project. · This included calendar reminders and follow up and accountability to supervisors at the Center.

View Audit 305132

Finding 395379 (2023-024)

Significant Deficiency 2023

State of Oregon

OR

Allowable Costs / Cost Principles Questioned Costs § 200.1 § 200.400

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

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

View Audit 305129 Questioned Costs: $1

Finding 395378 (2023-023)

Material Weakness 2023

State of Oregon

OR

Eligibility Questioned Costs Special Tests & Provisions

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

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

View Audit 305129 Questioned Costs: $1

Finding 395377 (2023-022)

Significant Deficiency 2023

State of Oregon

OR

Special Tests & Provisions Questioned Costs Significant Deficiency

2023-022 Oregon Department of Human Services/Oregon Health Authority Ensure compliance with federal Medicaid hospital audit requirements MANAGEMENT RESPONSE: We agree with this recommendation. The authority agrees with this finding and has completed the work to reconstitute the required tools neces...

2023-022 Oregon Department of Human Services/Oregon Health Authority Ensure compliance with federal Medicaid hospital audit requirements MANAGEMENT RESPONSE: We agree with this recommendation. The authority agrees with this finding and has completed the work to reconstitute the required tools necessary to perform these audits. As of January 2024, the authority has sent cost statements to the hospitals for review and response and is working to collect other reports required for completing the audits from actuaries and intermediaries. The authority will begin processing full audits starting April 2024 for outstanding Fiscal Year 2016 forward. The authority anticipates that the audits through Fiscal year 2020 will be completed by Dec. 31, 2024. The authority also affirms that the corrective action for finding 2021-17 has been implemented and resolved. This can be validated as completed audits become available in 2024. Anticipated Completion Date: December 31, 2024 Contact person: April Gillette, Strategic Operations and Improvement Director

View Audit 305129

Finding 395368 (2023-038)

Significant Deficiency 2023

State of Oregon

OR

Questioned Costs Reporting Significant Deficiency § 200.303

2023-038 Department of Early Learning and Care Retain support and improve controls over reporting MANAGEMENT RESPONSE: We agree with this recommendation. DELC will work with the Department of Revenue to substantiate the amount of tax credits used in prior years to meet federal matching and mainte...

2023-038 Department of Early Learning and Care Retain support and improve controls over reporting MANAGEMENT RESPONSE: We agree with this recommendation. DELC will work with the Department of Revenue to substantiate the amount of tax credits used in prior years to meet federal matching and maintenance of effort requirements for FY 20 to FY 22 and ensure this information is retained appropriately outside beyond just email records. In addition, DELC will update processes and procedures to ensure that tax credit amounts used in future reports are properly documented and substantiated by the Department of Revenue. Anticipated Completion Date: October 31, 2024 Contact person: Ali Webb, Operations and Policy Analyst; Connie Range, Fiscal Analyst

View Audit 305129

Finding 395367 (2023-037)

Significant Deficiency 2023

State of Oregon

OR

Allowable Costs / Cost Principles Questioned Costs

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

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

View Audit 305129 Questioned Costs: $1

Finding 395366 (2023-036)

Significant Deficiency 2023

State of Oregon

OR

Allowable Costs / Cost Principles Questioned Costs

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

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

View Audit 305129 Questioned Costs: $1

Finding 395365 (2023-035)

Significant Deficiency 2023

State of Oregon

OR

Allowable Costs / Cost Principles Questioned Costs

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

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

View Audit 305129 Questioned Costs: $1

Finding 395356 (2023-019)

Significant Deficiency 2023

State of Oregon

OR

Questioned Costs Reporting Significant Deficiency § 200.303

2023-019 Oregon Housing and Community Services Ensure documentation is retained to support amounts reported MANAGEMENT RESPONSE: We agree with this recommendation. Staff have received training and documentation is now retained consistently to support reported figures. Anticipated Completion Date:...

2023-019 Oregon Housing and Community Services Ensure documentation is retained to support amounts reported MANAGEMENT RESPONSE: We agree with this recommendation. Staff have received training and documentation is now retained consistently to support reported figures. Anticipated Completion Date: June 30, 2024 Contact person: Dean Criscola, Controller

View Audit 305129

Finding 395355 (2023-018)

Significant Deficiency 2023

State of Oregon

OR

Matching / Level of Effort / Earmarking Questioned Costs Subrecipient Monitoring § 200.303

2023-018 Oregon Housing and Community Services Ensure grant management report control is performed and documented MANAGEMENT RESPONSE: We agree with this recommendation. A dedicated staff resource has been trained and has brought grant reconciliations and reporting current. Additional training h...

2023-018 Oregon Housing and Community Services Ensure grant management report control is performed and documented MANAGEMENT RESPONSE: We agree with this recommendation. A dedicated staff resource has been trained and has brought grant reconciliations and reporting current. Additional training has been provided for awareness of the earmarking and obligation requirements as well. Anticipated Completion Date: June 30, 2024 Contact person: Dean Criscola, Controller

View Audit 305129

Finding 395354 (2023-017)

Significant Deficiency 2023

State of Oregon

OR

Questioned Costs Cash Management § 200.303

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

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

View Audit 305129 Questioned Costs: $1

Finding 395353 (2023-027)

Significant Deficiency 2023

State of Oregon

OR

Questioned Costs Special Tests & Provisions Eligibility

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

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

View Audit 305129 Questioned Costs: $1

Finding 395352 (2023-026)

Significant Deficiency 2023

State of Oregon

OR

Questioned Costs Special Tests & Provisions Significant Deficiency

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

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

View Audit 305129 Questioned Costs: $1

Finding 395341 (2023-042)

Significant Deficiency 2023

State of Oregon

OR

Questioned Costs Procurement, Suspension & Debarment Subrecipient Monitoring § 200.303 § 200.439

2023-042 Oregon Department of Education Retain support for pre-approval of equipment purchases MANAGEMENT RESPONSE: We agree with this recommendation. ODE has already developed and implemented updates to the capital expenditure request review and approval process to ensure equipment approvals are...

2023-042 Oregon Department of Education Retain support for pre-approval of equipment purchases MANAGEMENT RESPONSE: We agree with this recommendation. ODE has already developed and implemented updates to the capital expenditure request review and approval process to ensure equipment approvals are retained. Early ESSER capital project tag requests were split between a committee for large projects and the individual grant finance manager. Approvals were primarily sent via email from the grant finance manager. Some of those messages are archived in the ESSER.ODE inbox, however some went out directly from staff email. Records are available for the committee decisions. When the smaller approvals moved from the finance manager to an ESSER team, many of those decisions were made in conjunction with other meetings. Some records are available; however, the Capital Expenditure Tracker was the primary location of decisions. In October 2022, staffing changes allowed the committee and team structure to become more formalized. Committee meeting decisions shifted from a “minute”- style agenda to being more systematized in an online log. Team meeting decisions followed a similar process update in April 2023. The online agenda/log allows for consistent tracking of projects that are up for discussion and which approval are put on hold for elevation approval, correction, or clarification from the district. Committee and team meetings have been established weekly. When all information is received from a district, the project is placed on the appropriate agenda for that week. Approvals are sent out within 2 business days. A column was added to the Capital Expenditure Tracker, which remains the primary location of records, to track when the approval emails were sent. Corrections have already been developed and implemented as of April 2024. Anticipated Completion Date: April 30, 2024 Contact person: Cynthia Stinson, Senior Manager of Federal Investments and Pandemic Renewal Effort

View Audit 305129

Finding 395340 (2023-041)

Significant Deficiency 2023

State of Oregon

OR

Questioned Costs Subrecipient Monitoring Reporting § 200.303

2023-041 Oregon Department of Education Improve FFATA reporting controls MANAGEMENT RESPONSE: We agree with this recommendation. ODE will implement the following corrective action to ensure monthly FFATA reports are independently reviewed to ensure accurate and complete reporting. 1. Review and u...

2023-041 Oregon Department of Education Improve FFATA reporting controls MANAGEMENT RESPONSE: We agree with this recommendation. ODE will implement the following corrective action to ensure monthly FFATA reports are independently reviewed to ensure accurate and complete reporting. 1. Review and update list of all FFATA eligible federal awards monthly. 2. Implement a new query tool that will reduce manual processes. 3. Collaborate with ODE partners to access agency-collected unique entity identifier (UEI) information for sub awardees. 4. Monthly review of FFATA reporting by a second accountant. Anticipated Completion Date: June 30, 2024 Contact person: Kristie Miller, Accounting Director

View Audit 305129

Finding 395339 (2023-032)

None 2023

State of Oregon

OR

Allowable Costs / Cost Principles Questioned Costs

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

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

View Audit 305129 Questioned Costs: $1

Finding 395338 (2023-031)

Significant Deficiency 2023

State of Oregon

OR

Questioned Costs Eligibility Period of Performance

2023-031 Oregon Commission for the Blind Improve controls over compliance reporting MANAGEMENT RESPONSE: We agree with this recommendation. The agency is committed to ensuring the RSA-911 client case information report is accurate and well supported. The agency’s practice is to maintain documenta...

2023-031 Oregon Commission for the Blind Improve controls over compliance reporting MANAGEMENT RESPONSE: We agree with this recommendation. The agency is committed to ensuring the RSA-911 client case information report is accurate and well supported. The agency’s practice is to maintain documentation that supports information contained in the case management system. This practice includes requesting information from clients regarding the start date of employment in the primary occupation and the hourly wage at exit. This information can be difficult to locate due to the numerous case notes in the case management system. Due to the difficulty locating this documentation in the tight timelines of the audit, the agency spent some additional time attempting to locate it after the audit testing period had closed. The agency did find the supporting documentation for one of the two clients that was not located during the audit. For the other client, the agency identified documentation showing that we had requested this information from the client through multiple methods, but it was never received. The agency has created a new case-note category for documenting client employment start date and wages at exit. The agency will provide training to staff on the use of this case note category to ensure this documentation is able to be located more easily and to reinforce the importance of maintaining documentation to support information contained in the case management system. Anticipated Completion Date: August 1, 2024 Contact person: Angel Hale, Director of Vocational Rehabilitation Services

View Audit 305129

Finding 395337 (2023-030)

Significant Deficiency 2023

State of Oregon

OR

Allowable Costs / Cost Principles Questioned Costs Significant Deficiency

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

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

View Audit 305129 Questioned Costs: $1

Finding 395336 (2023-029)

Material Weakness 2023

State of Oregon

OR

Allowable Costs / Cost Principles Questioned Costs Material Weakness

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

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

View Audit 305129 Questioned Costs: $1

Finding 395335 (2023-028)

Material Weakness 2023

State of Oregon

OR

Questioned Costs Eligibility Material Weakness § 200.303

2023-028 Department of Human Services Strengthen controls to ensure adequate supporting documentation and accuracy over reporting MANAGEMENT RESPONSE: We agree with the first recommendation. We disagree with the second recommendation. We agree with the first recommendation and will ensure adequa...

2023-028 Department of Human Services Strengthen controls to ensure adequate supporting documentation and accuracy over reporting MANAGEMENT RESPONSE: We agree with the first recommendation. We disagree with the second recommendation. We agree with the first recommendation and will ensure adequate supporting documentation is maintained and readily available to support information reported in the RSA-911. We disagree with the second recommendation. The RSA-17 is currently reviewed by both Program Leadership as well as the ODHS Grant Accounting Manager. Certification is evidenced by the signed RSA-17. This level of review meets federal requirements. Additional review and discussion may be had as a form of best practice but should not be considered a control mechanism. The Grant Accounting Unit will highlight the certification process in the RSA-17 desk manual to delineate between control functions and best practices. Anticipated Completion Date: June 30, 2024 Contact person: Keith Ozols, Vocational Rehabilitation Services Director; Travis Labrum, Grant Accounting Manager

View Audit 305129

Finding 395334 (2023-043)

Significant Deficiency 2023

State of Oregon

OR

Questioned Costs Reporting Significant Deficiency § 200.303

2023-043 Oregon Business Development Department Management should implement accounting review of quarterly reports before submitting to DAS MANAGEMENT RESPONSE: We agree with this recommendation. We agree with this finding. Business Oregon has gone through significant personnel change during the ...

2023-043 Oregon Business Development Department Management should implement accounting review of quarterly reports before submitting to DAS MANAGEMENT RESPONSE: We agree with this recommendation. We agree with this finding. Business Oregon has gone through significant personnel change during the period of American Rescue Plan Act (ARPA) grant disbursements, from January 2022 to June 2023. The Chief Financial Officer, Accounting Manager, and Accountants had moved on to other state agencies. The accounting positions were left vacant for months due to challenges in timely filling these positions with the right skill sets. Although there were only a few accounting staff left when majority of the grant disbursements were made, the remaining accounting processed the disbursements with very tight deadlines. The accounting staff processed grant disbursements through appropriate internal control procedures, reviewed supporting documents for appropriate signature approval on the requests, and made accounting entries for these grant activity transactions. Below is a list of staff hire dates to illustrate the turnover we faced during this time period: • Federal Grant Accountant – November 2023 • Chief Financial Officer – October 2023 • Deputy CFO/Accounting Manager – May 2023 • Program Accountant 2 – April 2023 • Accounting Technician – April 2023 • Debt Accountant 3 – March 2023 • Program Accountant 3 – January 2023 • Program Accountant 3 – August 2022 Due to the accounting team not having enough personnel at the time to prepare reports for the DAS ARPA Grant Program Coordinator, Business Oregon program staff (not accounting staff) took the initiative to complete the reports and submitted the periodic/quarterly reports to DAS. As the Business Oregon program staff did not have access to the SFMA (state accounting system), the program staff used data from another system (Salesforce, not an accounting system) to fill the needed information for the reports. The initial reports submitted to DAS were not reviewed by accounting staff. The program staff continued to complete the reports for DAS until first quarter of 2023, until accountant positions were filled in 2023. While preparing for the FY 2023 Year-End Closing process (June 2023 to July 2023), the newly hired accountants and Deputy CFO/Accounting Manager reviewed as many FY23 financial transactions as they could and made necessary adjustments and accounting entry corrections. Reporting discrepancies were identified between department accounting records and the reports submitted by program staff to DAS/US Dept of Treasury. Business Oregon accountants worked with DAS on revising the SEFA reports and identified ARPA grant-related items that needs to be corrected. The research continued even after the fiscal year 2023 reporting has closed. A reconciliation of records between department accounting and the reports submitted to the DAS Grant program coordinator was completed in January 2024, and the Business Oregon accounting team submitted a revised FY 2023 SEFA report corrections to the DAS SARS team. Going forward, management will ensure that the completion of quarterly financial reports for grant reporting is performed and submitted by the agency’s accounting team and not program staff to ensure data comes from the accounting system with the review by an accountant or accounting manager. Anticipated Completion Date: June 30, 2024 Contact person: Imee Anderson, Chief Financial Officer; Karl Mielke, Deputy Chief Financial Officer

View Audit 305129

Finding 395332 (2023-045)

None 2023

State of Oregon

OR

Questioned Costs Subrecipient Monitoring § 200.332 § 200.501

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

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

View Audit 305129 Questioned Costs: $1

Finding 395329 (2023-039)

Significant Deficiency 2023

State of Oregon

OR

Questioned Costs Allowable Costs / Cost Principles § 200.413

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

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

View Audit 305129 Questioned Costs: $1

Finding 395309 (2023-004)

Significant Deficiency 2023

School District of Thorp

WI

Internal Control / Segregation of Duties Questioned Costs Reporting

The Bookkeeper will look at and sign off on all final food service claims before being submitted.

View Audit 305106

Corrective Action Plans

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