Corrective Action Plans

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2023-003 MATERIAL WEAKNESS – SPECIAL TESTS AND PROVISIONS Condition: The District did not provide the wage rate clauses to contractors. In addition, the District did not obtain from contractors the certified payroll registers, nor did they perform testing to ensure contractors were paying the prevai...
2023-003 MATERIAL WEAKNESS – SPECIAL TESTS AND PROVISIONS Condition: The District did not provide the wage rate clauses to contractors. In addition, the District did not obtain from contractors the certified payroll registers, nor did they perform testing to ensure contractors were paying the prevailing wage rates. Contact Person: Duane Poitra, Business Manager Corrective Action Plan: The contractor indicated that he would not be using payroll in this particular contract, but rather work would be performed by independent contractors. It was not understood by the District that the contractor would be required to provide weekly certified payroll reports indicating that no payroll occurred during the weekly payroll reporting period. Contractors awarded future construction project contracts applicable to payroll reporting will be required to provide weekly certified payroll reports to the Belcourt School District. Anticipated Completion Date: Fiscal Year 2023-2024
Finding 392042 (2023-001)
Significant Deficiency 2023
Current Findings on the Schedule of Findings, Questioned Costs, and Recommendations Finding 2023-001: Surplus cash in the amount of $29,198 from the surplus cash calculation for the year ended December 31, 2022, was not deposited into the residual receipts account until January 2024. Comments on the...
Current Findings on the Schedule of Findings, Questioned Costs, and Recommendations Finding 2023-001: Surplus cash in the amount of $29,198 from the surplus cash calculation for the year ended December 31, 2022, was not deposited into the residual receipts account until January 2024. Comments on the Finding and Each Recommendation Management anticipated receiving formal notification from HUD for the amount due after the audit had been completed and submitted to the Agency. Management will implement procedures in order to remit surplus cash payments due to the residual receipts account within the 90 days following fiscal year end going forward. Actions Taken on the Finding Management remitted the payment due to the residual receipts account in January 2024. Management will remit surplus cash payments due to the residual receipts account within the 90 days following fiscal year end going forward. CAP prepared by: Joshua Sroka President Atlas Realty Management Company 814-536-3573 Anticipated completion date: March 31, 2024
View Audit 302169 Questioned Costs: $1
Program Name: Head Start – Assistance Listing 93.600 Condition: The School District did not provide Policy Council training for Policy Council members during the audit period. Corrective Action Plan: Management provided policy council training for the Head Start Policy Council members subsequent to ...
Program Name: Head Start – Assistance Listing 93.600 Condition: The School District did not provide Policy Council training for Policy Council members during the audit period. Corrective Action Plan: Management provided policy council training for the Head Start Policy Council members subsequent to the audit period in October 2023. Management will ensure the Head Start program complies with all program governance requirements moving forward. Person Responsible for Corrective Action: David Jones, Business Manager Anticipated Completion Date: October 2023
Finding: For ALN 93.498, The actual total revenues for the quarter ended June 30, 2023 reported on the PRF period 5 submission do not agree to underlying accounting records for fiscal year ended June 30, 2023 by approximately $1,768,704. This difference affects the amount of revenues reported but d...
Finding: For ALN 93.498, The actual total revenues for the quarter ended June 30, 2023 reported on the PRF period 5 submission do not agree to underlying accounting records for fiscal year ended June 30, 2023 by approximately $1,768,704. This difference affects the amount of revenues reported but does not affect other data within the report, including the amount of PRF funds received that were utilized. Recommendation: Under the requirements of 2 CFR 200.303 the entity must establish and maintain effective internal controls over federal awards that provides reasonable assurance that the entity is in compliance with federal statues, regulation, and terms and conditions of the Federal award. Under the requirements of the PRF program reporting for an entity that uses option 1 to calculate lost revenues, the entity must report quarterly actual revenue/net charges from patient care. Corrective Action: In order to ensure that total revenues (by quarter) agree to the underlying accounting records a customized accounting system report will be developed to accurately report total revenues/net charges from patient care by quarter. A reconciliation will be performed to ensure that revenues reported agree with amounts reflected in the Association’s general ledger. Person Responsible for Corrective Action: David Sunstrom, Controller Anticipated Completion Date for Corrective Action: The Corrective Action will be implemented by June 30, 2024.
The District has been monitoring and reporting expenditures accurately and timely on all active grants. It was a one-time issue and the District still has an overall solid internal control process in place. The District has since taken action and corrected the issues related to this finding. The Gra...
The District has been monitoring and reporting expenditures accurately and timely on all active grants. It was a one-time issue and the District still has an overall solid internal control process in place. The District has since taken action and corrected the issues related to this finding. The Grants and Claims Management Unit implemented additional controls over the year-end close processes to ensure that all expenditures are accrued for year-end and included in the SEFA. The District is now running a general ledger report quarterly for grants with semi-annual reporting requirements to ensure expenditures are captured within the fiscal year regardless of when construction activity has begun. In addition, the year-end checklist has been updated to ensure that the year-end expenditure review is completed by the project management team for each grant. The Finance department will provide more training and frequent communication with the project management team to ensure that all grant expenditures during the year are accounted for. The department will also continue to proactively enforce the existing policies and procedures requiring departments to complete expenditure reporting.
Individuals Responsible for Corrective Action Plan Daniel Hall (Interim Vice President for Finance and Administration) Libby Shull, CPA (Controller) April Baur (Director of Student Financial Aid) Kevin Crider (Chief Information Officer) Vicky Wilson (Registrar) Finding 2023-006 For 3 of 24 studen...
Individuals Responsible for Corrective Action Plan Daniel Hall (Interim Vice President for Finance and Administration) Libby Shull, CPA (Controller) April Baur (Director of Student Financial Aid) Kevin Crider (Chief Information Officer) Vicky Wilson (Registrar) Finding 2023-006 For 3 of 24 students selected for testing, the College was unable to locate Perkins master promissory note. Corrective Action Plan: The College maintains all Perkins promissory notes in alphabetical order, in a dedicated filing cabinet, in a fireproof vault. This finding relates to promissory notes that were signed in 1987, 2006, and 2016, and the College is not aware of what may have caused these promissory notes to be misplaced. No further action is planned by Management as the Perkins Loan Program expired on September 30, 2017 and no additional Perkins Loan disbursements were made by the College since the Program’s expiration.
Individuals Responsible for Corrective Action Plan Daniel Hall (Interim Vice President for Finance and Administration) Libby Shull, CPA (Controller) April Baur (Director of Student Financial Aid) Kevin Crider (Chief Information Officer) Vicky Wilson (Registrar) Finding 2023-003 For 4 of 40 studen...
Individuals Responsible for Corrective Action Plan Daniel Hall (Interim Vice President for Finance and Administration) Libby Shull, CPA (Controller) April Baur (Director of Student Financial Aid) Kevin Crider (Chief Information Officer) Vicky Wilson (Registrar) Finding 2023-003 For 4 of 40 students tested, the College did not send the required loan disbursement notification to the parent borrower for PLUS loans. Corrective Action Plan: For the 2023-2024 academic year, a PLUS Loan Form was created and sent to the parent borrower to confirm the amount requesting. As of March 6, 2023, notifications are created to notify parents with PLUS loans of disbursement and their rights.
Finding 391959 (2023-005)
Significant Deficiency 2023
Individuals Responsible for Corrective Action Plan Daniel Hall (Interim Vice President for Finance and Administration) Libby Shull, CPA (Controller) April Baur (Director of Student Financial Aid) Kevin Crider (Chief Information Officer) Vicky Wilson (Registrar) Finding 2023-005 For 1 of 2 student...
Individuals Responsible for Corrective Action Plan Daniel Hall (Interim Vice President for Finance and Administration) Libby Shull, CPA (Controller) April Baur (Director of Student Financial Aid) Kevin Crider (Chief Information Officer) Vicky Wilson (Registrar) Finding 2023-005 For 1 of 2 students selected for testing, the College did not return the correct amount to the ED in the required timeframe. Corrective Action Plan: This finding is in regards to a R2T4 return that was not returned within the 45 days. The Assistant Director of Financial Aid successfully took and passed the R2T4 course offered by the National Association for Student Financial Aid Administrators (NASFAA) in November 2023 and we have implemented the process to return funds in a timely manner.
Individuals Responsible for Corrective Action Plan Daniel Hall (Interim Vice President for Finance and Administration) Libby Shull, CPA (Controller) April Baur (Director of Student Financial Aid) Kevin Crider (Chief Information Officer) Vicky Wilson (Registrar) Finding 2023-004 In accordance with...
Individuals Responsible for Corrective Action Plan Daniel Hall (Interim Vice President for Finance and Administration) Libby Shull, CPA (Controller) April Baur (Director of Student Financial Aid) Kevin Crider (Chief Information Officer) Vicky Wilson (Registrar) Finding 2023-004 In accordance with the Gramm-Leach-Bliley Act requirements, the College did not maintain a written information security program that addresses the minimum elements set forth in 16 CFR 314.4. Corrective Action Plan: The college made good progress in 2022-2023 with its compliance and security planning by completing a Risk Assessment and an Incident Response Plan. The findings from those assessments are the foundation for developing an Information Security Plan.
Individuals Responsible for Corrective Action Plan Daniel Hall (Interim Vice President for Finance and Administration) Libby Shull, CPA (Controller) April Baur (Director of Student Financial Aid) Kevin Crider (Chief Information Officer) Vicky Wilson (Registrar) Finding 2023-008 The College did no...
Individuals Responsible for Corrective Action Plan Daniel Hall (Interim Vice President for Finance and Administration) Libby Shull, CPA (Controller) April Baur (Director of Student Financial Aid) Kevin Crider (Chief Information Officer) Vicky Wilson (Registrar) Finding 2023-008 The College did not have a formal procurement policy in place documenting procedures that conform to the procurement standards in the Uniform Guidance. Corrective Action Plan: The College obtained multiple quotes for a Wi-Fi refresh project. The Chief Information Officer, under the guidance of the Vice President of Finance and Administration, analyzed these quotes and determined that one of them most closely met the needs of the College. This quote was submitted to Laurens County as part of the ARP Infrastructure Application, prepared by the College’s Corporate & Foundation Relations Officer. After Laurens County granted the funding for the Wi-Fi project to the College, the College moved forward with the vendor and scope of work laid out in the quote. However, the College does recognize that it did not adhere to all aspects of the Federal Procurement Policy. The Vice President of Finance and Administration, along with the Controller, will both implement a procurement policy for any purchases made with Federal funds that satisfies the requirements laid out in the Federal Procurement Policy and also educate any faculty/staff involved in purchasing products/services involving Federal funds.
We observed the following conditions in connection with our testing of the various U.S. Department of Education, Title IV, Student Financial Assistance Programs: a. Two (2) out of 21 students did not complete exit counseling requirements upon graduating or dropping below half-time status. 34 CFR 685...
We observed the following conditions in connection with our testing of the various U.S. Department of Education, Title IV, Student Financial Assistance Programs: a. Two (2) out of 21 students did not complete exit counseling requirements upon graduating or dropping below half-time status. 34 CFR 685.304(b)(1) b. One (1) out of 21 students was awarded Federal Direct Loans at less than half-time status. 34 CFR 685.200 (a)(1)(i). Attributable questioned cost: $3,000 c. Documentation to support the Center’s reconciliation of the Federal Direct Loan program between Common Origination and Disbursement (COD) and the Office of Financial aid was not available. 34 CFR 685.300(b)(5) d. Documentation to support the Center’s reconciliation of the Federal Work-Study program was not available. 34 CFR Part 668 Subpart L e. One (1) out of 21 students did not have timely or accurate enrollment reporting to the National Student Loan Data System (NSLDS). 34 CFR685.309(b) f. Documentation to conduct Federal Work-Study compliance testing was not provided. 34 CFR Part 675 g. Documentation to support testing for withdrawals and the return of Title IV funds compliance was not provided. HEA Section 484B & 34 CFR 668.22 h. Documentation to support credit balance (student refund) testing was not provided. 34 CFR 668.164(h)(1) i. Two (2) out of 21 students were paid Federal Direct Loans and did not make satisfactory academic progress (SAP) for the academic year. Additionally, the school did not provide updated documents supporting successful appeals. 34 CFR 668.34. Attributable questioned cost: $30,730 j. One (1) out of 21 students did not have an undergraduate transcript to prove eligibility for the program they were enrolled within the institution. HEA Section 484(d) and 34 CFR 668.32. Attributable questioned cost: $20,500. Auditor's Recommendation – The Center should implement corrective actions to ensure that the above findings are resolved and do not recur in future periods. Moreover, internal controls over compliance with federal program regulations should be revisited to ensure adequate supervisory controls, quality assurance reviews of compliance steps, technical training of staff, and adequate procedures are being followed for compliance purposes. View of Responsible Officials – Management agrees.
View Audit 302135 Questioned Costs: $1
Management concurs with the findings regarding the delay and insufficient graduation reporting to NSLDS. The University Registrar is aware of the 6-day delinquency in reporting for summer term due to the timing of the degree awards for the May graduates on the East Falls campus. Degree audits will b...
Management concurs with the findings regarding the delay and insufficient graduation reporting to NSLDS. The University Registrar is aware of the 6-day delinquency in reporting for summer term due to the timing of the degree awards for the May graduates on the East Falls campus. Degree audits will be checked to ensure are awarded in a timely manner. We also will work with NSC to ensure all enrollment reporting schedules are updated in accordance with the academic calendar of the appropriate branch, limiting any issue with the 60-day certification date during our Summer term, as all other terms have been reported correctly. This will happen every semester on a 4–6week basis, in tandem with enrollment report submissions. This will resolve the 60-day certification issue. Academic Services makes every effort to report clean enrollments accurately and on time. However, we continue to find inconsistencies with the NSC transmissions to NSLDS and are aware of the need for additional oversight of the NSC process as well as the development of a process to audit NSC transmissions to NSLDS. This will also aid in the elimination of reporting errors between NSC and NSLDS, as in the case of the three graduation records. The Office of Academic Services is working to identify resources to address the above action plans. Spring 2024 update: The University Registrar has gained access directly to the NSLDS enrollment files. The University Registrar will audit enrollment files twice monthly to be certain that any errored NSLDS enrollment records created at the time of NSLDS roster submission, are corrected to negate the 65-day outstanding record (NSLDS ERROR 22). The University Registrars will continue to work with NSLDS and National Student Clearinghouse to locate cause of errored NSLDS roster records.
For expenditures made pursuant to the American Rescue Plan Act funds received pursuant to Act 2 of 2022, management concurs there were 26 payments totaling $25,836 made after the 90-day performance period ended and more than one retention payment was made to 34 qualified staff members amounting to $...
For expenditures made pursuant to the American Rescue Plan Act funds received pursuant to Act 2 of 2022, management concurs there were 26 payments totaling $25,836 made after the 90-day performance period ended and more than one retention payment was made to 34 qualified staff members amounting to $31,530. Management will contact the Pennsylvania Department of Human Services and inform them of this finding to determine the appropriate corrective measures.
Management concurs that the Period 4 PRF Reporting Portal Submission for Jefferson University Physicians included a duplicate reporting of expenses of $133,333 from Period 3 resulting in the reported amount of $24,889,847 for “Total Unused Lost Revenues Available for Future Reporting Periods” being ...
Management concurs that the Period 4 PRF Reporting Portal Submission for Jefferson University Physicians included a duplicate reporting of expenses of $133,333 from Period 3 resulting in the reported amount of $24,889,847 for “Total Unused Lost Revenues Available for Future Reporting Periods” being overstated by the $133,333 and the reported amount of $3,084,081 for “Total Payments Used for Lost Revenues in the Current Reporting Period” being understated by $133,333. Management identified the duplicate reporting in September 2023 and contacted HRSA in an attempt to amend the Period 4 submission. A HRSA representative advised the PRF Reporting Portal Submission for Period 4 could not be amended. Management will implement an enhanced review process to validate all amounts reported on the PRF Reporting Portal Submission.
Finding Number: 2023-003 Program: U.S. Department of Health and Human Services ALN Number: 93.243 ALN Name: Substance Abuse and Mental Health Service Projects of Regional and National Significance Grant Award Number: 1H79TI084507-01 Planned Corrective Action: Management has implemented a proc...
Finding Number: 2023-003 Program: U.S. Department of Health and Human Services ALN Number: 93.243 ALN Name: Substance Abuse and Mental Health Service Projects of Regional and National Significance Grant Award Number: 1H79TI084507-01 Planned Corrective Action: Management has implemented a process wherein the Human Resources department sends the Termination Log weekly to the Payroll Department for comparison with the Payroll Department’s records and ensure that status changes for employees are properly recorded. Further, an adjustment was made subsequent to year-end to adjust the overpayment and remove the amount from the cumulative charges to the grant funds. Person(s) Responsible: Mordechai Schechter, Chief Financial Officer Expected Completion Date: June 30, 2024
View Audit 302125 Questioned Costs: $1
Finding Number: 2023-002 Program: U.S. Department of Health and Human Services ALN Number: 93.243 ALN Name: Substance Abuse and Mental Health Service Projects of Regional and National Significance Grant Award Number: 1H79TI083607-01 Planned Corrective Action: Management will hire a HR Assistan...
Finding Number: 2023-002 Program: U.S. Department of Health and Human Services ALN Number: 93.243 ALN Name: Substance Abuse and Mental Health Service Projects of Regional and National Significance Grant Award Number: 1H79TI083607-01 Planned Corrective Action: Management will hire a HR Assistant to help review/ manage the review of timecards going forward. Person(s) Responsible: Mordechai Schechter, Chief Financial Officer Expected Completion Date: June 30, 2024
View Audit 302125 Questioned Costs: $1
Finding Number: 2023-001 Program: U.S. Department of Health and Human Services ALN Number: 93.243 ALN Name: Substance Abuse and Mental Health Service Projects of Regional and National Significance Grant Award Number: 1H79TI084507-01 Contract Period: 07/01/2022 - 6/30/2023 Planned Corrective ...
Finding Number: 2023-001 Program: U.S. Department of Health and Human Services ALN Number: 93.243 ALN Name: Substance Abuse and Mental Health Service Projects of Regional and National Significance Grant Award Number: 1H79TI084507-01 Contract Period: 07/01/2022 - 6/30/2023 Planned Corrective Action: Management will create a policy that all parties involved in preparing, reviewing and submitting the required report to Health Resources and Services Administration will have reviewed the report in conjunction with all relevant supporting documentation to ensure that amounts charged and allocated to the program are properly supported. Person(s) Responsible: Mordechai Schechter, Chief Financial Officer Expected Completion Date: June 30, 2024
View Audit 302125 Questioned Costs: $1
To ensure compliance with subrecipient agreements, The Grants Division will work with the Purchasing Division to include the federal assistance listing number of the grant funding being passed through in grant agreement templates.
To ensure compliance with subrecipient agreements, The Grants Division will work with the Purchasing Division to include the federal assistance listing number of the grant funding being passed through in grant agreement templates.
To ensure compliance for future reporting, The Grants Division will identify and maintain a tracking system that identifies federal awards where the City is the prime awardee. Grants Division Staff will notify the Management Analysts in applicable departments of their responsibility to report any su...
To ensure compliance for future reporting, The Grants Division will identify and maintain a tracking system that identifies federal awards where the City is the prime awardee. Grants Division Staff will notify the Management Analysts in applicable departments of their responsibility to report any subawards (grant related contracts) a $30,000 or above in the Federal Funding Accountability and Transparency Act (FFATA) Subaward Report System (FSRS) by the end of the following month of the subaward agreement effective date. The tracking log will include the contract information, the deadline date to report in the FSRS, and the date when it was completed and will request a copy of the filing for record keeping. This tracking log will be housed in the Grants Division folder on the City’s shared drive. As an added measure, the Grants Division will provide FFATA reporting training to staff as needed.
Finding 2023-002 – U.S. Department of Education (USDE) Higher Education Emergency Relief Fund (HEERF) Programs (material weakness): We observed the following conditions in connection with our testing of the various USDE, HEERF programs: a) The College did not obtain required approval before incurrin...
Finding 2023-002 – U.S. Department of Education (USDE) Higher Education Emergency Relief Fund (HEERF) Programs (material weakness): We observed the following conditions in connection with our testing of the various USDE, HEERF programs: a) The College did not obtain required approval before incurring costs from the HEERF HBCU grant on construction and renovation costs. Federal regulations under HEERF (a)(2) stipulates priorapproval from USDE for all construction and renovations projects must be received before commencing any bidding or incurring construction costs. The College incurred and capitalized construction and renovation costs funded by the HEERF HBCU grant totaling $3.6 million in fiscal year 2023. b) There were several construction and renovation costs incurred for the Health and Wellness Center such as roof replacement, HVAC unit replacement, etc. The Health and Wellness Center houses the gymnasium where athletic events are held. There was no allocable method provided to delineate which area benefitted from the project costs suggesting unallowed costs may have been incurred regarding the gymnasium space. Federal regulations under HEERF (a)(2) explicitly prohibits construction and renovation of athletic facilities, sectarian instruction or religious worship. c) A number of salaries and contractual services charged to the HEERF HBCU grant appeared to involve responsibilities and services not solely dedicated to the grant. Various positions within the business office were charged to the grant at 100% rate based on time and effort reports examined during testing. A portion of these expenses were subsequently reclassified to operational costs totaling $317,000 out of $1.3 million. Additionally, the full compensation for the director of another active grant was charged to the HEERF HBCU grant. Besides conflicting roles, discerning the allocation of costs associated with COVID-19 prevention, preparation, and response was not consistently apparent. Auditor’s Recommendation – The College should provide grant-compliant justification to substantiate the questioned costs as a resolution to this matter. A representative at USDE may offer some insight and consideration on retrospective approvals for construction and renovation projects. Also, the specific purpose for all salaries and contractual services charged to the HEERF grants should be documented for better clarity. Corrective Action – Procedures will be implemented to assure Federal Regulations are properly followed such that HEERF HBCU pre-approvals are obtained from the USDE for all construction and renovation projects. In addition, construction and renovation costs associated with the Health and Wellness Center will be adequately documented to better distinguish them from gymnasium-related expenditures. Time and effort reporting procedures will be more closely monitored for accurate documentation and segregation of unallowable costs from allowable costs. Contact will made to USDE specifically to remedy the disclosed findings noted above.
View Audit 302114 Questioned Costs: $1
Finding 2023-001 - U.S. Department of Education (USDE), Title IV Student Financial Aid Programs (Deficiency): We observed the following condition in connection with our testing of the various USDE, Title IV, Student Financial Assistance Programs. a) One (1) out of 15 files tested were missing offici...
Finding 2023-001 - U.S. Department of Education (USDE), Title IV Student Financial Aid Programs (Deficiency): We observed the following condition in connection with our testing of the various USDE, Title IV, Student Financial Assistance Programs. a) One (1) out of 15 files tested were missing official transcripts. The total questioned costs $9,415. 34 CFR 668.32 Auditor’s Recommendation – The College should implement corrective actions to ensure the above finding is resolved and will not recur in future periods. Corrective Action – Management will implement procedures to ensure that the above finding is resolved and will not recur in future periods. The files of Title IV student financial assistance recipients will be reviewed to ensure that they are properly completed and maintained, inclusive of official transcripts.
View Audit 302114 Questioned Costs: $1
Views of Responding Officials: The Department agrees with the finding and will implement corrective action. Corrective Action Taken or Planned: The Supplemental Nutrition and Assistance Program office has worked with Statewide Branch and Staff Development offices to address refresher training ass...
Views of Responding Officials: The Department agrees with the finding and will implement corrective action. Corrective Action Taken or Planned: The Supplemental Nutrition and Assistance Program office has worked with Statewide Branch and Staff Development offices to address refresher training associated with budget calculations including the documentation and input of all data correctly. The Department is also in process of finalizing the new eligibility system – Benefit Eligibility Solution – slated to rollout statewide by late October 2024. As a condition of system rollout, all staff will be required to go through system training which will include a reinforcement of data entry practices and documentation requirements as a condition of eligibility determination. Expected Completion Date: October 31, 2024 Responding Officials: Ginet Hayes, Supplemental Nutrition and Assistance Administrator
View Audit 302108 Questioned Costs: $1
Views of Responding Officials: The Department agrees with the finding and will implement corrective action. Corrective Action Taken of Planned: The Department has identified a gap in training and education, that caused a failure to enforce the contract requirements for plans to submit audited fin...
Views of Responding Officials: The Department agrees with the finding and will implement corrective action. Corrective Action Taken of Planned: The Department has identified a gap in training and education, that caused a failure to enforce the contract requirements for plans to submit audited financial statements pursuant to 42 CFR 438.3(m). Training and education were completed. The Department has engaged with a vendor to implement our new online provider enrollment system HOKU on August 3, 2020 and started the process to have all providers re register their information in the new online system. All providers were given a deadline to do this by December 31, 2023 and if missed they would be terminated in 2024. Expected Completion Date: April 30, 2024 Responding Official: Marvin Malohi, Med-QUEST Division Supervising Contracts Specialist
View Audit 302108 Questioned Costs: $1
Views of Responding Officials: The Department agrees with the finding and will implement corrective action, however, notes the following: Letter dated April 29, 2022 was sent to ACF notifying of the temporary amendment to the Hawaii TANF State Plan, Part B, Section 10.1, suspending the interview re...
Views of Responding Officials: The Department agrees with the finding and will implement corrective action, however, notes the following: Letter dated April 29, 2022 was sent to ACF notifying of the temporary amendment to the Hawaii TANF State Plan, Part B, Section 10.1, suspending the interview requirement for TANF applications and annual recertification. The temporary suspension of the interview requirement aligned with the waiver granted by the Food and Nutrition Service for the Supplemental Nutrition Assistance Program (“SNAP”). The letter also informed ACF the interview requirement will resume for new TANF applications by July 31, 2022. No date was provided as to when the interview requirement will resume for annual recertifications. The Department received a letter dated May 9, 2022 from ACF that acknowledged the temporary amendment to the Hawaii TANF State Plan. A subsequent letter dated March 16, 2023 was sent to inform ACF that the suspended interview resumed for TANF applications effective July 1, 2022, however, will continue to be suspended for annual eligibility recertifications for TANF recipients. The Department received a letter dated March 29, 2023 from ACF that acknowledged the temporary State Plan amendment. A letter dated July 25, 2023 informed ACF that TANF will continue to align with SNAP and extend its suspended interview requirement for annual recertifications until May 31, 2024. The Department received a letter dated August 3, 2023 from ACF that acknowledged the extended temporary amendment to the State Plan. The Department did not need guidance from ACF on whether a particular action is allowable under program requirements. Pursuant to section 402 of the Social Security Act, ACF has the authority to determine whether a state’s TANF State Plan is complete but does not have the authority to approve or disapprove a plan. ACF acknowledged the temporary amendments made to the Hawaii TANF State Plan and expressed no concerns or determined that the temporary amendments were not allowable. Corrective Action Taken or Planned: No corrective action. The temporary amendment to the Hawaii TANF State Plan will end effective June 1, 2024, as noted in the July 25, 2023 letter to ACF. Expected Completion Date: Not applicable Responding Officials: Catherine Scardino, Temporary Assistance for Needy Families Program Administrator
View Audit 302108 Questioned Costs: $1
Views of Responding Officials: The Department agrees with the finding and will implement corrective action. Hawaii implemented an upfront work participation requirement as a condition of eligibility for TANF applicants beginning 2009. The purpose of the upfront work participation is to prepare app...
Views of Responding Officials: The Department agrees with the finding and will implement corrective action. Hawaii implemented an upfront work participation requirement as a condition of eligibility for TANF applicants beginning 2009. The purpose of the upfront work participation is to prepare applicant families to engage in the TANF work program. Our state temporarily amended its TANF State Plan in response to the COVID 19 pandemic, suspending the upfront work participation requirements, described in Part B, section 15.1, effective March 27, 2020. This suspension coupled with relaxed administrative policies for all means-tested programs which included TANF, Supplemental Nutrition Assistance Program, and our state-funded General Assistance and Aid to the Aged, Blind and Disabled, and operational changes statewide allowed the Department to process applications expeditiously ensuring eligible families have access to their financial assistance benefits quickly. In March 2020, Hawaii’s unemployment rate was as low as 2.2% (seasonally adjusted) but it increased considerably to 22.6% in April 2020 following the state’s first shut-down due to the COVID 19 pandemic. The state’s TANF caseload increased by about 177%, from March 2020 with 3,969 recipient families to 7,040 families in December 2020 following the state’s second shut-down. While the upfront work program participation was suspended as a condition of eligibility for TANF applicants, Hawaii still required recipients to participate with the work program after they were determined eligible for TANF benefits. The good cause provision was exercised judiciously and to the extent allowable under TANF federal regulations and Hawaii administrative rules. Our TANF work program extended its services to provide families the opportunities to receive additional support such as case management and counseling services; to access information and referrals to community resources such as housing assistance and food distribution events; and to receive assistance in navigating through programs, benefits, and services that our department and other government agencies have available during this period of economic downturn resulting from the health emergency. It was not until March 25, 2022, when then Governor David Y. Ige ended the state’s emergency proclamation relating to COVID 19. The Department continued to suspend the upfront work participation requirements through May 31, 2023, allowing a transition period to adjustour operations. The upfront work participation requirement as a condition of eligibility was reinstated for families who applied for TANF financial assistance benefits beginning June 1, 2022, with only four months remaining in the fiscal year. Other administrative policies that were temporarily suspended or amended in response to the pandemic were reinstated effective July 1, 2022. The public health emergency and heightened period of COVID 19 restrictions forced the Benefit, Employment and Support Services Division (“BESSD”), who oversees the TANF and other means-tested public assistance programs, to immediately modify its operations statewide, ensuring the continuity of its programs and services and making them more accessible to the public. It was important to provide BESSD a transition period to review its policies and operational procedures and allow its staff of over 650 employees to adjust after two years of operating programs and services in a manner that was unprecedented for the division. On January 17, 2024, the TANF program office met with the Statewide Branch Administration (“SBA”), who oversees the state First To-Work (“FTW”) program staff, to discuss the concerns regarding the work participation rates, active TANF recipients who were referred to FTW but not yet participating in the program, and strategies to address the concerns. Subsequently, on January 25, 2024, SBA held a meeting with the state FTW unit supervisors to share the concerns raised on the work participation rates and to solicit comments and suggestions. TANF program administrator and lead program specialist were in attendance to notate comments and suggestions. Corrective Action Taken or Planned: Pursuant to 45 CFR 262.5, the Department requested consideration for reasonable cause from the Administration for Children and Families (“ACF”), for not meeting the two parent work participation rate for fiscal year 2022. Response and determination from ACF is pending. The FTW unit supervisors were instructed, during the January 25, 2024 meeting, to invite and schedule the active TANF recipients, who were referred but not yet participating, to attend a work program orientation as soon as possible. It is expected that remaining active TANF recipients will be invited to the FTW program by March 31, 2024. TANF program office is exploring the suggestions received during the January 25, 2024 meeting with SBA and FTW unit supervisors. For example, it was suggested that the FTW program provide additional supportive service payments to participants, who are in countable non employment related work activities, to incentivize them to maintain their program engagement. However, this suggestion has a fiscal impact and will require the FTW program administrative rules to be amended before it can be implemented. The TANF program office plans to require both parents of two parent households to participate in the FTW program. Due to capacity issues of both state and contract staff, only one parent is required to participate and meet work program requirements for the TANF recipient household. The TANF caseloads have declined; therefore, capacity is no longer a concern. Expected Completion Date: March 31, 2025 Responding Officials: Catherine Scardino, Temporary Assistance for Needy Families Program Administrator
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