Corrective Action Plans

Finding 383141 (2023-132)

Significant Deficiency 2023

State of Texas C/o Comptroller of Public Accounts

TX

Student Financial Aid Matching / Level of Effort / Earmarking Subrecipient Monitoring

Corrective Action Plan: The University has implemented significant process enhancements in this area. The policy manual has been revised to include detailed procedures. Management will conduct a second level review to ensure that the University is following the requirements. After the aid year activ...

Corrective Action Plan: The University has implemented significant process enhancements in this area. The policy manual has been revised to include detailed procedures. Management will conduct a second level review to ensure that the University is following the requirements. After the aid year activation for calendars is posted by the Office of Registrar, management will review calendar dates and other components reported to COD on a monthly schedule to ensure accuracy. COD reports are sent twice a week to ensure calendar and cost of attendance is updated correctly for all federal programs. Implementation Date: March 2024 Responsible Persons: Leanne Sikora, Associate Director Laurie Rosenkrantz, Associate Director

View Audit 296491

Finding 383138 (2023-128)

Significant Deficiency 2023

State of Texas C/o Comptroller of Public Accounts

TX

Student Financial Aid Special Tests & Provisions Reporting

Corrective Action Plan: We will work to reestablish access with NSLDS to ensure that all student statuses are reported correctly from NSC. We will also incorporate procedures to ensure we are capturing and reporting all students’ status changes accurately through Cognos reports and a newly developed...

Corrective Action Plan: We will work to reestablish access with NSLDS to ensure that all student statuses are reported correctly from NSC. We will also incorporate procedures to ensure we are capturing and reporting all students’ status changes accurately through Cognos reports and a newly developed enrollment reporting dashboard. Implementation Date: Summer 2024 Responsible Person: Amanda McSween, TTUHSC Registrar

View Audit 296491

Finding 383137 (2023-126)

Significant Deficiency 2023

State of Texas C/o Comptroller of Public Accounts

TX

Student Financial Aid Special Tests & Provisions Reporting

Corrective Action Plan: • The University has already implemented significant process enhancements in this area. • Additional checks are now in place to ensure that campus-level and program level reporting is accurate moving forward. • Additional checks have also been put in place to ensure that dual...

Corrective Action Plan: • The University has already implemented significant process enhancements in this area. • Additional checks are now in place to ensure that campus-level and program level reporting is accurate moving forward. • Additional checks have also been put in place to ensure that dual-majors graduation statuses are reporting accurately and in a more timely manner moving forward. Implementation Date: January 2024 Responsible Persons: Kyle Phillips and Bobbie Brown

View Audit 296491

Finding 383130 (2023-119)

Significant Deficiency 2023

State of Texas C/o Comptroller of Public Accounts

TX

Student Financial Aid Special Tests & Provisions Reporting

Corrective Action Plan: Texas Southern University agrees with the information that states the student’s program length was incorrectly reported to NSLDS for 10 of 60 students tested. To further enhance reporting accurate information, the Office of Student Records (formerly the Registrar’s Office) ha...

Corrective Action Plan: Texas Southern University agrees with the information that states the student’s program length was incorrectly reported to NSLDS for 10 of 60 students tested. To further enhance reporting accurate information, the Office of Student Records (formerly the Registrar’s Office) has updated our business practice regarding this matter in the following way. First, the Office of Student Records reached out to the Interim Dean of the Graduate School to provide the correct program length for Graduate Programs at TSU. Second, we gathered information regarding the total number of hours of each program offered and the total number of hours required to be considered a fulltime student at TSU. We then utilized this information to calculate the program length in years. (For example, the eMPA program at TSU is 36 hours and a full-time course load for a graduate student is 9 hours. We then divided the total hours of the program (36 hours) by the full-time load (9). This provided us with how many semesters a full-time student would take to complete the program. To finish the calculation and get the program length, we divided it into 2 to get the number of years required to complete the program. Implementation Date: January 2024 Responsible Person: Dr. Nickolaus Cioci, Dean of Student Records Corrective Action Plan: Texas Southern University also agrees with the information stating 17 of 38 student’s tested enrollment status was not reported to NSLDS in a timely manner. We agree with this information that states 13 of the students tested did not have their graduation effective date accurately reported to NSLDS in a timely manner. To combat this issue, the Office of Student Records has created a new business process to report these students to NSLDS in a timelier manner. First, the graduation coordinator has requested academic units to provide her with information regarding students whose degrees are 100% complete earlier to allow her to confer these degrees quicker. Second, the Office of Student Records has also changed their business practice and informed both the Graduation Coordinator and the Law School Registrar’s representative that all degrees must be conferred no later than 45 days after the semester ends. This will allow other staff time to turn in the graduation report to NSC in a timelier manner and review the rejected records/correct the rejected records before the 60-day deadline to help keep us in compliance. Implementation Date: January 2024 Responsible Person: Dr. Nickolaus Cioci, Dean of Student Records Corrective Action Plan: Texas Southern University also agrees with the information stating 4 students that did not have their withdrawal status or effective date of status change reported in a timely manner to NSLDS. In reviewing these records, it appears accurate attendance was not taken causing Texas Southern University to be out of compliance for reporting practices. To further enhance reporting capabilities, the Office of Student Records has created a new business process to correct this error. First, TSU no longer allows advisors to register students and students must register themselves and sign a financial acknowledgement form. Also, the Office of Student Records has collaborated with the Office of the Provost to effectively communicate with faculty the ramifications of inaccurate attendance reporting. In these communications, the faculty are also provided instructions on how to accurately report attendance using their MyTSU attendance portal. Also, the Office of Student Records worked in conjunction with the Office of Information Technology, to automate the process of dropping students for nonattendance as reported by their faculty. Furthermore, we are continuing to update our business processes, so these students are reported to NSC/NSLDS in a timely manner. Another issue involved students being reported as nonattending but attending the course. TSU’s Office of Student Records and Office of the Provost have also worked in conjunction to fix this issue as well. Several faculty members would not mark attendance causing their whole class to get dropped. We have worked in our process to inform instructors they must mark attendance for students to not create this issue in the future. Implementation Date: January 2024 Responsible Person: Dr. Nickolaus Cioci, Dean of Student Records

View Audit 296491

Finding 383125 (2023-114)

Significant Deficiency 2023

State of Texas C/o Comptroller of Public Accounts

TX

Student Financial Aid Special Tests & Provisions Reporting

Corrective Action Plan: The University, with the National Student Clearinghouse (NSC), has developed an expanded enrollment reporting schedule for reporting graduated students on special “Graduates Only” files after subsequent semester enrollment reporting has begun. Previously, we relied on the Deg...

Corrective Action Plan: The University, with the National Student Clearinghouse (NSC), has developed an expanded enrollment reporting schedule for reporting graduated students on special “Graduates Only” files after subsequent semester enrollment reporting has begun. Previously, we relied on the DegreeVerify file to report Graduated status. The Graduates Only files, which will include only students with an awarded credential for the semester and are a supplement to the regular Enrollment files sent during the semester, will ensure that Graduated statuses for Doctor of Veterinary Medicine students are reported accurately and in a timely manner. The use of a supplemental Graduates Only enrollment file will also eliminate warning files that currently result from the DegreeVerify reporting process. Should there be an issue with the Graduates Only file, an enrollment reporting warning/error file will be received and processed in a timely manner, as they are during the semester when an Enrollment file generates a warning/error report. The new process will be more consistent, efficient, and complete. The Graduates Only file transmission schedule for the current semester has been updated and procedures for setting the enrollment reporting schedule each year have been updated to include the expanded Graduates Only file transmission schedule. Discussion with the NSC resulted in a clear understanding of how the Graduates Only files should be processed to ensure accurate and complete reporting of Graduated statuses. All staff members responsible for processing of the Graduates Only files have been trained in this procedure, and additional information has been included in written procedures for processing the files. Implementation Date: November 2023 Responsible Person: Venesa Heidick, Registrar

View Audit 296491

Finding 383123 (2023-112)

Significant Deficiency 2023

State of Texas C/o Comptroller of Public Accounts

TX

Student Financial Aid Special Tests & Provisions Reporting

Corrective Action Plan: The Office of the Registrar will develop an action plan to evaluate the internal process changes which must occur considering the following implications: • There will be significant process changes of the reporting parameters that are run for the National Student Clearinghous...

Corrective Action Plan: The Office of the Registrar will develop an action plan to evaluate the internal process changes which must occur considering the following implications: • There will be significant process changes of the reporting parameters that are run for the National Student Clearinghouse jobs in Banner to ensure that the proper branch code is identified for each student; • Further research will be required to identify other areas which will be impacted by this change, including but not limited to IPEDS data submissions, CBM Reporting, SACSCOC notifications, etc.; • Will collaborate with College of Graduate Studies to remove degree plans that are listed as sought and are not actively being pursued by the student. This will ensure that correct degree sequencing is accounted for and reported on correctly each month to the National Student Clearinghouse; • Strengthen internal controls and communication channels to ensure consistent and accurate reporting of student statuses across all levels. Implementing additional validation checks in our reporting systems will ensure the accuracy of program begin dates before submission; • Update our standard operating procedures to indicate review of the National Student Clearinghouse EDI Rejection File to ensure all students are accurately being pulled into NSLDS; • Conduct a comprehensive review of our reporting procedures to identify the specific breakdown in the process that led to the failure to report enrollment status to NSLD; • Implement enhanced internal controls and validation checks to ensure that enrollment statuses are accurately reported to both NSC and NSLDS in a timely manner; and • The policies and procedures will be revised to include these updated procedures. Implementation Date: January 2024 Responsible Person: Erika Graham, University Registrar

View Audit 296491

Finding 383117 (2023-105)

Significant Deficiency 2023

State of Texas C/o Comptroller of Public Accounts

TX

Student Financial Aid Special Tests & Provisions Reporting

Corrective Action Plan: The University has formally documented the procedures that have been put in place. The University will address issues with National Student Clearinghouse (NSC) reporting and will attempt to fix each issue before sending to NSC, including Social Security Number, Name, and othe...

Corrective Action Plan: The University has formally documented the procedures that have been put in place. The University will address issues with National Student Clearinghouse (NSC) reporting and will attempt to fix each issue before sending to NSC, including Social Security Number, Name, and other miscellaneous issues. The procedures include three DegreeVerify files being sent that report graduates and the University will be adding three more DegreeVerify files to be sent two to three weeks after the end of the semester, part of term and end of mini to pick up remaining graduates for the term. The University will have the Information and Analysis team create a report each term of students that were enrolled in the previous semester but are not enrolled in the current semester so that they can be reported as withdrawn to NSC correctly. Implementation Date: February 2024 Responsible Person: Cheri Lewis, Enrollment Management Analyst

View Audit 296491

Finding 383036 (2023-147)

Significant Deficiency 2023

State of Texas C/o Comptroller of Public Accounts

TX

Special Tests & Provisions Student Financial Aid Eligibility § 200.303

Corrective Action Plan: The University has implemented significant enhancements- in its process to grant user access. In addition, to address the specific exceptions noted by the State Auditor’s Office, access for all staff within the SIS has been restricted from disbursing aid. Access is now only g...

Corrective Action Plan: The University has implemented significant enhancements- in its process to grant user access. In addition, to address the specific exceptions noted by the State Auditor’s Office, access for all staff within the SIS has been restricted from disbursing aid. Access is now only granted to the batch user account. Implementation Date: 11/2023 Responsible Person: Scott Lapinski, Assistant Vice President for Enrollment Management/Director of Financial Aid

View Audit 296491

Finding 383032 (2023-135)

Significant Deficiency 2023

State of Texas C/o Comptroller of Public Accounts

TX

Internal Control / Segregation of Duties Special Tests & Provisions Student Financial Aid § 200.303

Corrective Action Plan: In the event that an employee transitions to another University department but needs to retain access for a period of time to facilitate knowledge transfer or to provide backstop support during the transition period, a date will be set for removing that access by setting an e...

Corrective Action Plan: In the event that an employee transitions to another University department but needs to retain access for a period of time to facilitate knowledge transfer or to provide backstop support during the transition period, a date will be set for removing that access by setting an expiration date on the authorization, when feasible. If an automated access expiration date is not available, a calendar meeting will be scheduled for at least 2 people authorized to remove that access to remind them to remove the access. Implementation Date: January 2024 Responsible Person: Diane Todd Sprague, Assistant Vice Provost for Scholarships and Financial Aid Corrective Action Plan: The University is currently in the process of replacing its current custom-developed, mainframe-based financial aid management system with a vendor-provided, cloud-based system. The current issue with the mainframe programming library not being under change control will be resolved with the implementation of the new financial aid management system. Implementation Dates: Rolling implementation starting February 2024 through August 2024 Responsible Person: Graham Chapman, Assistant Vice Provost and Director of Academic Information Systems

View Audit 296491

Finding 383030 (2023-129)

Significant Deficiency 2023

State of Texas C/o Comptroller of Public Accounts

TX

Special Tests & Provisions Student Financial Aid Eligibility § 200.303

Corrective Action Plan: In response to the current finding of temporary access monitoring, the frequency of reviews for people that have temporary Financial Aid role assignments will be increased from an annual review to quarterly, for a period of two years. Staff training for access control and bus...

Corrective Action Plan: In response to the current finding of temporary access monitoring, the frequency of reviews for people that have temporary Financial Aid role assignments will be increased from an annual review to quarterly, for a period of two years. Staff training for access control and business owner training has taken place, to increase awareness that roles need timely removal when maintenance tasks are completed. Implementation Date: 1/29/24 Responsible Persons: Karen Krause, Office of Financial Aid Doug Bergere, Office of Information Technology

View Audit 296491

Finding 383028 (2023-122)

Significant Deficiency 2023

State of Texas C/o Comptroller of Public Accounts

TX

Special Tests & Provisions Student Financial Aid Eligibility § 200.303

Corrective Action Plan: • The University has already implemented significant process enhancements in this area. • The University immediately reviewed all Financial Aid security access and removed any access not deemed immediately necessary to the employee’s job duties. • The University has developed...

Corrective Action Plan: • The University has already implemented significant process enhancements in this area. • The University immediately reviewed all Financial Aid security access and removed any access not deemed immediately necessary to the employee’s job duties. • The University has developed Financial Aid security classes based on employee positions. This will allow us to more easily monitor what access an employee has and ensure that it is appropriate to their job responsibilities. Implementation Date: September 2023 Responsible Persons: Kyle Phillips and Robert Hamilton

View Audit 296491

Finding 383022 (2023-115)

Significant Deficiency 2023

State of Texas C/o Comptroller of Public Accounts

TX

Special Tests & Provisions Student Financial Aid Eligibility § 200.303

Corrective Action Plan: Through analysis of the exceptions identified in the audit, the University has developed a standard operating procedure to assign employee access based on the principle of least privilege as determined by individual roles. The university is engaged with a third-party vendor t...

Corrective Action Plan: Through analysis of the exceptions identified in the audit, the University has developed a standard operating procedure to assign employee access based on the principle of least privilege as determined by individual roles. The university is engaged with a third-party vendor to procure and implement an automated role-based access assignment process, to ensure that the University complies with this audit findings requirements. Implementation Date: June 2024 Responsible Person: Mr. Matthew Steimel, Director of Enterprise Applications

View Audit 296491

Finding 383017 (2023-106)

Significant Deficiency 2023

State of Texas C/o Comptroller of Public Accounts

TX

Special Tests & Provisions Student Financial Aid Eligibility § 200.303

Corrective Action Plan: The user access has been limited to their specific job function. The university will verify user access was appropriately updated/removed. Access review procedures will be reviewed to ensure access is appropriately assigned in the future. To streamline and assure a consistent...

Corrective Action Plan: The user access has been limited to their specific job function. The university will verify user access was appropriately updated/removed. Access review procedures will be reviewed to ensure access is appropriately assigned in the future. To streamline and assure a consistent outcome regarding the approvals for security patches to be introduced to the production environment, the University will convert these normal changes to standard changes. A standard change is “A pre-authorized change that is low risk, relatively common and follows a procedure or work instruction. (ITIL v4 definition.)” Software patching and updates are standard change candidates. Not applying security patches in a timely manner introduces a greater risk to the University than processing these requests as a normal change. A standard change is pre-authorized and will address how IT is testing and/or validating whether the OS patches were successful in an available test environment prior to deployment to production. Test procedures will be documented as a requirement of the Standard Change Model. IT will document that outcome of the testing and/or validating of the OS patch as a Journal entry on the Standard Change prior to implementation. The Change Advisory Board (CAB) will review these changes/procedures on a regular basis to ensure we are in compliance. Policies, Standards and Procedures will be updated to meet any required changes. Implementation Date: January, 2025 Responsible Persons: Michael Dewey, Chief Technology Officer Amy Wilson, Director of Financial Aid and Scholarships

View Audit 296491

Finding 383014 (2023-102)

Significant Deficiency 2023

State of Texas C/o Comptroller of Public Accounts

TX

Student Financial Aid Reporting Significant Deficiency

Corrective Action Plan: When the office of Student Aid began work on the Fiscal Operations Report and Application to Participate (FISAP), a discrepancy in the PELL amount was identified. The SAO team requested the FISAP in October 2023, which notated that the PELL amount would need to be submitted b...

Corrective Action Plan: When the office of Student Aid began work on the Fiscal Operations Report and Application to Participate (FISAP), a discrepancy in the PELL amount was identified. The SAO team requested the FISAP in October 2023, which notated that the PELL amount would need to be submitted by the December 15th deadline. The corrections to PELL were not resolved by the December 15th deadline, so a request for extension was requested on December 15, 2023, and granted on December 20, 2023, with an updated due date of January 3, 2024.  Part II, Section E was completed with the corrected PELL amount on final submission.  FSEOG Expenditures Reporting is being reviewed by Student Aid and Student Business Services to identify the error in reporting discrepancies. Implementation Date: February 2024 Responsible Persons: Megan Begnaud, Director of Student Aid

View Audit 296491

Finding 383009 (2023-029)

Significant Deficiency 2023

State of Texas C/o Comptroller of Public Accounts

TX

Reporting § 200.303

Corrective action plan: TDEM will utilize the federal system APEX reports for financial reports. For FFATA reporting, TDEM will work closely with the software vendor to correct deficiencies in data provided on the automated FFATA report. Additionally, TDEM will utilize the data generated directly fr...

Corrective action plan: TDEM will utilize the federal system APEX reports for financial reports. For FFATA reporting, TDEM will work closely with the software vendor to correct deficiencies in data provided on the automated FFATA report. Additionally, TDEM will utilize the data generated directly from the federal system for monitoring FFATA submissions. Implementation dates: Specific to the financial reporting – October 2023 FFATA – February 2024 Responsible persons: Division Chief – Finance – Vicki Newlin Division Chief – Business Services – Carolyn Record

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Finding 382984 (2023-013)

Significant Deficiency 2023

State of Texas C/o Comptroller of Public Accounts

TX

Subrecipient Monitoring Allowable Costs / Cost Principles Reporting § 200.303 § 200.334

Corrective action plan: The HHSC Federal Funds Office will work with HHSC Accounting, Department of Family and Protective Services (DFPS), and Texas Workforce Commission (TWC) to strengthen oversight of the Social Services Block Grant (SSBG) post-expenditure report. As part of this oversight, HHSC w...

Corrective action plan: The HHSC Federal Funds Office will work with HHSC Accounting, Department of Family and Protective Services (DFPS), and Texas Workforce Commission (TWC) to strengthen oversight of the Social Services Block Grant (SSBG) post-expenditure report. As part of this oversight, HHSC will compile procedure documents, methodologies, data sources, and work documents from DFPS and TWC. The HHSC Federal Funds Office already has this documentation for HHSC. Implementation date: August 31, 2024 Responsible person: Racheal Kane, Director, Federal Funds

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Finding 382968 (2023-010)

Material Weakness 2023

State of Texas C/o Comptroller of Public Accounts

TX

Procurement, Suspension & Debarment Subrecipient Monitoring Material Weakness § 200.303

Corrective action plan: HHSC is currently engaged in long-term planning related to improving FFATA reporting, which may involve the use of CAPPS-Financials, or a different system; with the choice of solution depending on a determination of overall effectiveness. While it may be potentially problemat...

Corrective action plan: HHSC is currently engaged in long-term planning related to improving FFATA reporting, which may involve the use of CAPPS-Financials, or a different system; with the choice of solution depending on a determination of overall effectiveness. While it may be potentially problematic for HHSC to commit to the specific designation of CAPPS-Financials as the improvement solution, actions will be taken to improve compliance. HHSC will implement a quality review of selected programs to assess FFATA compliance on an annual basis. Implementation date: September 1, 2025 Responsible person: Racheal Kane, Director, Federal Funds

View Audit 296491

Finding 382958 (2023-002)

Significant Deficiency 2023

State of Texas C/o Comptroller of Public Accounts

TX

Matching / Level of Effort / Earmarking Special Tests & Provisions Reporting § 200.303

Corrective action plan: An “Adding New Users-CHRS” document was submitted to the auditors in 2022 as an interim measure that remains in place. Immunization program and VHSS program staff are working together with HHSC Information Technology to establish a replacement system to CHRS. The new system i...

Corrective action plan: An “Adding New Users-CHRS” document was submitted to the auditors in 2022 as an interim measure that remains in place. Immunization program and VHSS program staff are working together with HHSC Information Technology to establish a replacement system to CHRS. The new system is expected to address provisioning issues and provide central office staff with reports to be able to analyze data more quickly. This replacement system is expected to be identified and implemented by June 2026. Implementation date: Replacement System implementation anticipated by June 30, 2026 Responsible person: Greg Leos, Assessment and Epidemiology Group Manager

View Audit 296491

Finding 382957 (2023-030)

Significant Deficiency 2023

State of Texas C/o Comptroller of Public Accounts

TX

Matching / Level of Effort / Earmarking Subrecipient Monitoring Period of Performance § 200.303

Corrective action plan: TEA’s Department of Grant Compliance and Administration (GCA) will implement the following actions to ensure accuracy of corrections requested by LEAs in the USDE ESSER Annual Performance Report:  USDE ESSER Reporting Corrections Changelog – In direct response to this audit ...

Corrective action plan: TEA’s Department of Grant Compliance and Administration (GCA) will implement the following actions to ensure accuracy of corrections requested by LEAs in the USDE ESSER Annual Performance Report:  USDE ESSER Reporting Corrections Changelog – In direct response to this audit exception, the GCA Department Chief of Staff and GCA ESSER Reporting Team has begun implementing a changelog to track LEA corrections on the various ESSER Annual Performance Reports. This changelog is intended to: 1. Track changes requested by LEAs; 2. Verify that staff have responded to and confirmed corrections with LEAs; 3. Track that changes have been made on the various reports; and 4. Ensure that the changes are completed on the respective report.  Updated Documentation Procedures – GCA Department Chief of Staff and ESSER Reporting staff will begin to ensure that the various corrected reports (after the first submission, and subsequent correction periods) are properly documented, so that the various versions of the report submitted to USDE are tracked accordingly, this will allow for corrections requested by LEAs can be verified in accordance with the changelog mentioned above.  Quality Control Review – GCA Department Chief of Staff and ESSER Reporting Staff will begin development of additional quality control procedures for the CROSSACT report to verify that the data that is submitted by LEAs via SmartSheet is properly entered into the Excel spreadsheet that is uploaded to USDE. These procedures will verify the following: 1. Verify that the appropriate LEA name and UEI was properly entered into the Excel spreadsheet; and 2. Verify that the FTE counts reported by LEAs upload correctly and within the variance allowed by USDE in their business rules. Implementation date: All of these changes will be implemented starting in Year Four of USDE ESSER Annual Reporting by TEA. Responsible persons: Associate Commissioner and Chief Grants Officer, Cory Green and GCA Department Chief of Staff, Nick Davis

View Audit 296491

Finding 382928 (2023-021)

Significant Deficiency 2023

State of Texas C/o Comptroller of Public Accounts

TX

Subrecipient Monitoring Reporting Significant Deficiency § 200.303

Corrective action plan: The OOG is creating materials for Grantees to clearly define and standardize terms in accordance with SLFRF Compliance and Reporting Guidance Version 5.0. Additionally, the OOG is updating internal processes to enforce Agency reporting of FSRs and Reconcilers on a monthly bas...

Corrective action plan: The OOG is creating materials for Grantees to clearly define and standardize terms in accordance with SLFRF Compliance and Reporting Guidance Version 5.0. Additionally, the OOG is updating internal processes to enforce Agency reporting of FSRs and Reconcilers on a monthly basis for all active grants. The OOG will ensure accuracy of Agency submissions by reconciling data between the eGrants Financial Status Reports (FSRs) and the Reconcilers. Should a variance exist, the OOG will document any changes made, and the reason therefore, with concurrence from the Agency. The OOG will update the reporting processes and institute new internal controls. For each reporting period, the ARPA Reporting Administrator will take the quarterly data provided for each grant and reconcile that information with the eGrants FSR data. The Public Safety Office (PSO) Grants Administration Director will verify the data. The PSO Executive Director will review and Administration Director will approve the reporting information prior to submission in to the ARPA Portal. Prior to final submission, the data will receive a quality assurance check. Implementation date: Full implementation by April 1, 2024 Responsible persons: Suzanne Johnson, Director of Administration and Aimee Snoddy, Executive Director Public Safety Office

View Audit 296491

Finding 382924 (2023-028)

Significant Deficiency 2023

State of Texas C/o Comptroller of Public Accounts

TX

Internal Control / Segregation of Duties Subrecipient Monitoring Reporting § 200.303

Corrective action plan: In response to the recent audit, the Texas Department of Housing and Community Affairs' (TDHCA) Homeowner Assistance Fund (HAF) Data and Reporting Team (DRT) is implementing operational changes to enhance its ability to validate the quarterly reports. Moving forward, DRT will...

Corrective action plan: In response to the recent audit, the Texas Department of Housing and Community Affairs' (TDHCA) Homeowner Assistance Fund (HAF) Data and Reporting Team (DRT) is implementing operational changes to enhance its ability to validate the quarterly reports. Moving forward, DRT will not only receive reports on totals for each budget, obligation, and expenditure field, but will also require the submission of backup documentation from the sending party. This additional step ensures that the team can independently verify the accuracy of reported figures. Furthermore, DRT will check the calculations within the backup documentation to confirm that the aggregate amounts align with the reported figures. These measures are designed to ensure that the HAF program's reporting is both accurate and reflective of activities. Implementation date: February 12, 2024 Responsible persons: David Johnson, HAF/TRR Data and Reporting Manager; Lizet Hinojosa, Director of HAF; Grace Timmons, Assistant Director of HAF; Lanette Johndrow, Director of HAF Subrecipient Activities; and Teri- Ann Parise, HAF Financial Analyst. Corrective action plan: For legal and counseling services, a report has been created that pulls all costs from the Housing Contract System and separates the data by Intake, Housing and Legal to allow for an appropriate report of all costs. This report is to be run weekly and updated by the Director of HAF Subrecipients, and then given to the finance department to verify against paid invoices for validation. Any discrepancies are to be discussed immediately and resolved. Implementation date: July 17, 2023 Responsible persons: Lanette Johndrow, Director of HAF Subrecipient Activities; Teri-Ann Parise, HAF Financial Analyst; and Mariah Tamayo, Financial Analyst

View Audit 296491

Finding 382922 (2023-026)

Significant Deficiency 2023

State of Texas C/o Comptroller of Public Accounts

TX

Internal Control / Segregation of Duties Special Tests & Provisions Allowable Costs / Cost Principles § 200.302 § 200.303

Corrective action plan: TDHCA will enhance internal controls over reporting by implementing a secondary review to compare reported amounts to supporting documentation. Standard Operating Procedures will be updated to include secondary review. The formula that led to this error has already been corre...

Corrective action plan: TDHCA will enhance internal controls over reporting by implementing a secondary review to compare reported amounts to supporting documentation. Standard Operating Procedures will be updated to include secondary review. The formula that led to this error has already been corrected. Implementation date: March 31, 2024 Responsible person: David Johnson, HAF/TRR Data & Reporting Manager

View Audit 296491

Finding 382919 (2023-023)

Significant Deficiency 2023

State of Texas C/o Comptroller of Public Accounts

TX

Subrecipient Monitoring School Nutrition Programs Matching / Level of Effort / Earmarking § 200.303

Corrective action plan: CNC – Food and Nutrition Department revised the internal Federal Funding Accountability and Transparency Act (FFATA) reporting procedures to ensure that all subaward/subaward amendment obligations over $30,000 are identified and submitted in Federal Funding Accountability and...

Corrective action plan: CNC – Food and Nutrition Department revised the internal Federal Funding Accountability and Transparency Act (FFATA) reporting procedures to ensure that all subaward/subaward amendment obligations over $30,000 are identified and submitted in Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS) by the last day of the month following the month in which the subaward/subaward amendment obligation was made or the subcontract award/subcontract modification was made. TDA FND provided correspondence emails and incident reports documentation with screenshots for the FSRS technical issues to CLA:  CNC_NSLP grant: TDA FND informed CLA auditors that agency has been experiencing significant technical difficulties uploading the FFATA data into FSRS. During these attempts, the system shows the following error message: "Sub-awardee Awardee Address - Congressional District could not be validated/matched from the provided address and zip+4." Unfortunately, this occurred on numerous uploads (300-400) every time an attempt was made. As a disclaimer, a single error will prevent an entire report from being uploaded into the system. TDA FND staff has contacted the FSRS helpdesk many times to no avail, resulting in reports not being uploaded and causing TDA FND to be behind on the FFATA reporting.  FFVP grant: TDA allocates FFVP funds to CEs during two periods of operation. If CEs do not spend the funds, then TDA must either (1) reallocate or (2) let the funds lapse and return to USDA. Considering the nature of the grant allocation and USDA requirements of maximizing grant spending to benefit schools during this process, it might cause a discrepancy between what was reported on the FFATA report and what was adjusted after the fact. As of today, the system error continues to occur with TDA FND staff having little to no control over it. TDA would like to emphasize that the help desk process with FSRS is not expedient and would cause the loss of employee productivity if the burden to remedy the systems issues (beyond recording unsuccessful attempts) was delegated to the state. TDA FND staff will continue to prepare the reports and attempt to submit them as required. TDA FND Staff will document instances where the upload is unsuccessful. CDBG – TDA will ensure that all FFATA reports are submitted timely. For CDBG, program staff has implemented procedures to ensure that FFATA reports are prepared, reviewed by the Director of CDBG Programs, and submitted on a monthly basis. Implementation dates: CDBG: January 2024 CNC: March 1, 2024 Responsible persons: CDBG: Suzanne Barnard, Director for CDBG Programs CNC: Anwar Sophy, Administrator, TDA FND Business Management

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Finding 382918 (2023-022)

Significant Deficiency 2023

State of Texas C/o Comptroller of Public Accounts

TX

HUD Housing Programs Reporting Significant Deficiency § 200.303

Corrective action plan: TDA has completed the noted adjustments and submitted a corrected PR-28 for Program Year 2022 to HUD. Implementation date: February 1, 2024 Responsible person: Suzanne Barnard, Director for CDBG Programs

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Finding 382917 (2023-007)

Significant Deficiency 2023

State of Texas C/o Comptroller of Public Accounts

TX

Subrecipient Monitoring Reporting Procurement, Suspension & Debarment § 200.303

Corrective action plan: In this case, the filtering of the data did not pick up these two contracts. When it was determined that they had been overlooked, the reporting was completed. The source information for FFATA reporting was originally coming from the Contracts department. In order to have a m...

Corrective action plan: In this case, the filtering of the data did not pick up these two contracts. When it was determined that they had been overlooked, the reporting was completed. The source information for FFATA reporting was originally coming from the Contracts department. In order to have a more complete dataset, CDR was tasked as identifying the source data as opposed to Contracts as they are more familiar with these contracts. This change was implemented beginning in September 2023. This change should mitigate the chance of any contracts being missed. Implementation date: September 2023 Responsible person: Elizabeth Ozuna - Senior Director of Federal Finance and Grant Management

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Corrective Action Plans

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