Corrective Action Plans

Finding 554790 (2024-002)

None 2024

SC

Student Financial Aid Subrecipient Monitoring Reporting

Finding 2024-002 – Student Financial Aid Cluster, Assistance Listing # 84.063 and 84.268 Limestone University utilizes Jenzabar software to extract and report enrollment data to the National Student Clearinghouse (NSC). However, in some instances, the data reported was incorrect. Since the occurrenc...

Finding 2024-002 – Student Financial Aid Cluster, Assistance Listing # 84.063 and 84.268 Limestone University utilizes Jenzabar software to extract and report enrollment data to the National Student Clearinghouse (NSC). However, in some instances, the data reported was incorrect. Since the occurrence of this issue, the University hired a new Registrar in August 2024. After reviewing the findings, the Registrar implemented the use of the NSC Edit Student Data Records window, in addition to the NSC Edit Registration Transactions window. This change allows a special status on the NSC Edit Student Data Records window to override the status on the Registration Transactions window, providing more precise monitoring of withdrawal dates and ensuring the accuracy and timeliness of the data reported to NSC. To ensure ongoing accuracy, the Registrar now reports enrollment status changes to NSC on a monthly basis. Additionally, the University reviewed the students identified in the findings, along with other students who had the same status (withdrawn) and made adjustments as necessary to ensure that all student data was accurately reported.

View Audit 353372

Finding 554773 (2024-002)

Significant Deficiency 2024

Nevins Manor, Inc.

MA

HUD Housing Programs Internal Control / Segregation of Duties Subrecipient Monitoring

FINDINGS—FEDERAL AWARD PROGRAMS AUDITS U.S. Department of Housing and Urban Development 2024‐002 Section 202 Supportive Housing for the Elderly – Assistance Listing No. 14.157 Recommendation: The Auditors recommend that management implement internal controls to document the monitoring of the financ...

FINDINGS—FEDERAL AWARD PROGRAMS AUDITS U.S. Department of Housing and Urban Development 2024‐002 Section 202 Supportive Housing for the Elderly – Assistance Listing No. 14.157 Recommendation: The Auditors recommend that management implement internal controls to document the monitoring of the financial institution's rating on a quarterly basis to ensure consistency with the minimally acceptable ratings as established by the Government National Mortgage Association (GNMA) and maintain documentation of the ratings for at least three years. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The management company will begin documenting the financial institutions ratings on a quarterly basis to ensure consistency with the minimally acceptable ratings as established by the Government National Mortgage Association (GNMA and maintain this documentation in the administrative record for three years, including the current year Name(s) of the contact person(s) responsible for corrective action: Alexa Ducote Planned completion date for corrective action plan: March 25, 2025. If the U.S. Department of Housing and Urban Development has questions regarding this plan, please call Alexa Ducote at 857‐221‐8753.

View Audit 353354

Finding 554771 (2024-040)

Significant Deficiency 2024

State of Oregon

OR

Subrecipient Monitoring § 200.332 § 200.339 § 200.521

2024-040 Oregon Department of Emergency Management Assign responsibility to ensure review of subrecipient audit reports Management Response: The Oregon Department of Emergency Management (OEM) concurs with the finding and the recommendations as outlined in the letter and above. OEM is undertaking th...

2024-040 Oregon Department of Emergency Management Assign responsibility to ensure review of subrecipient audit reports Management Response: The Oregon Department of Emergency Management (OEM) concurs with the finding and the recommendations as outlined in the letter and above. OEM is undertaking the following corrective actions to address the recommendations made by the Secretary of State’s Audits Division: • OEM will identify sufficient and appropriate grant accounting staff to perform this work on an ongoing basis, ensure that this work is added to their Position Descriptions, provide them with appropriate training, support, and guidance regarding subrecipient audit reviews. • OEM will establish an annual plan to assign this work out, establish and utilize tracking sheets, and follow up for timely completion. • OEM will work to address the past due FY 24 subrecipient reviews noted in the audit finding letter and above, and will then work to address those from FY23 and FY22. Anticipated completion date: December 31, 2026. Contact person: Amy Mettler, Chief Financial Officer.

View Audit 353343

Finding 554770 (2024-039)

Significant Deficiency 2024

State of Oregon

OR

Subrecipient Monitoring Reporting Significant Deficiency § 200.303

2024-039 Oregon Department of Emergency Management Continue FFATA reporting improvements and make inquiries on FSRS functionality Management Response: The Oregon Department of Emergency Management (OEM) concurs with the finding and the recommendations as outlined in the letter and above. OEM has und...

2024-039 Oregon Department of Emergency Management Continue FFATA reporting improvements and make inquiries on FSRS functionality Management Response: The Oregon Department of Emergency Management (OEM) concurs with the finding and the recommendations as outlined in the letter and above. OEM has undertaken and continues the following corrective actions to address the recommendations made by the Secretary of State’s Audits Division: • OEM has developed procedures for capturing necessary information and ensuring FFATA reports are filed in compliance with federal criteria. • OEM has identified all awards since July 1st 2023 and is working to ensure 100% compliance from that date forward. • OEM will conduct timely follow up on all submissions that fail to successfully load into the system, and clearly document that follow up for inclusion in our files. • OEM will continue to review older awards to determine what actions should be taken. Anticipated completion date: June 30, 2025. Contact person: Amy Mettler, Chief Financial Officer.

View Audit 353343

Finding 554745 (2024-009)

Material Weakness 2024

State of Oregon

OR

Subrecipient Monitoring § 200.331

2024-009 Oregon Health Authority Continue to implement and strengthen controls to ensure subrecipients are appropriately identified and monitored. Management Response: The agency agrees with the finding. During state fiscal year 2024, the division was in the process of implementing controls for sub...

2024-009 Oregon Health Authority Continue to implement and strengthen controls to ensure subrecipients are appropriately identified and monitored. Management Response: The agency agrees with the finding. During state fiscal year 2024, the division was in the process of implementing controls for subrecipient determination or contractors, required reporting, risk assessment, and monitoring plan. Since this period, the division has fully implemented the internal controls to ensure compliance with the federal requirements as identified in prior audits. The division recognizes that there are opportunities to strengthen the controls for subrecipient contractor determination, risk assessments and monitoring activities are accurate, complete, and documented and will refine these tools. The division also recognizes the opportunity to continue to improve controls that ensure that corresponding disbursements of federal funds are appropriately reported. The division will collaborate with agency financial services to develop enhanced controls that will ensure prevention, detection, and correction of payment reporting. Contact Person: Mick Kincaid Business Operations Manager Behavioral Health Division

View Audit 353343

Finding 554744 (2024-010)

Significant Deficiency 2024

State of Oregon

OR

Subrecipient Monitoring Reporting Significant Deficiency § 200.303

2024-010 Oregon Health Authority Submit required Federal Funding Accountability and Transparency Act reports Management Response: The agency agrees with the finding. The FFATA Reporting Coordinator position within the Office of Contracts & Procurement (OC&P) has been vacant for eight months but sho...

2024-010 Oregon Health Authority Submit required Federal Funding Accountability and Transparency Act reports Management Response: The agency agrees with the finding. The FFATA Reporting Coordinator position within the Office of Contracts & Procurement (OC&P) has been vacant for eight months but should be filled by April 15, 2025. On March 8, 2025, FSRS.gov was retired, and all subaward reporting data and functionality are now on SAM.gov. The new SAM.gov reporting system will allow for multiple Data Entry roles, allowing each program or division of ODHS/OHA to submit their own reporting, and allowing OC&P to conduct Quality Assurance/Quality Control. Once the FFATA Reporting Coordinator is onboard and trained, we anticipate the FFATA reporting will resume and any missing reports will be submitted by April 15, 2026. Anticipated Completion Date: April 15, 2026 Contact person: Noemi Schlegel, Compliance & Audits Program Manager

View Audit 353343

Finding 554739 (2024-025)

Significant Deficiency 2024

State of Oregon

OR

Special Tests & Provisions Subrecipient Monitoring Significant Deficiency

2024-025 Oregon Department of Human Services Ensure work participation rate calculation uses verified and accurate data Management Response: We agree with this recommendation. Office of Program Integrity’s leadership priorities are to update the risk assessment and to continue to meet weekly with th...

2024-025 Oregon Department of Human Services Ensure work participation rate calculation uses verified and accurate data Management Response: We agree with this recommendation. Office of Program Integrity’s leadership priorities are to update the risk assessment and to continue to meet weekly with the Chief Operating Officer to highlight the risks associated with inadequate staffing levels. Risk mitigation efforts to ensure JOBS reviews are performed in accordance with established procedures include cross training JOBS second level Quality Control beginning in March 2025 and time studies planned to determine adequate staffing levels for additional position requests. ODHS has a current workgroup led by the Project Management Office (PMO) that is tasked with conducting a training and coaching gap analysis for family coaches and making recommendations regarding Oregon’s Work Participation Rate. The workgroup consists of TANF policy analysts and the self- sufficiency training unit. In addition to the gap analysis, the workgroup is currently producing communications regarding documentation of work participation hours. ODHS will implement additional recommendations once they are identified. Anticipated Completion Date: 12/31/2025 Contact Person: Eva Ruiz, TANF program manager

View Audit 353343

Finding 554734 (2024-030)

Significant Deficiency 2024

State of Oregon

OR

Subrecipient Monitoring § 200.332

2024-030 Department of Education Perform regular fiscal monitoring as part of subrecipient monitoring Management Response: ODE agrees with this finding. ODE will ensure subrecipient fiscal monitoring is performed on the schedule set by department policy by: • Updating the internal procedure and time...

2024-030 Department of Education Perform regular fiscal monitoring as part of subrecipient monitoring Management Response: ODE agrees with this finding. ODE will ensure subrecipient fiscal monitoring is performed on the schedule set by department policy by: • Updating the internal procedure and timeline for requesting, reviewing and approving district submissions of claims for IDEA Fiscal Cyclical Monitoring. • Updating current IDEA Subrecipient Fiscal Monitoring manual to clarify updated internal procedure and timeline. The department will develop a procedure to track the completion of cyclical fiscal monitoring by: • Establishing a dedicated digital file to save district claims documentation and email communications for each cyclical monitoring review for each district. • Creating and utilizing a tracking document or system for each Cohort Group that will include the district, date of claim, amount of claim, approval status, date of approval, and location of documentation. • Develop a standard request notification and a standard approval notification for claims documentation. Anticipated Completion Date: June 30, 2025 Contact person: Allyson McNeil, OESO, Director of Resource Management and Operations and Rae Ann Ray, OESO IDEA Fiscal Team, IDEA Part B Grant Manager

View Audit 353343

Finding 554729 (2024-037)

Significant Deficiency 2024

State of Oregon

OR

Subrecipient Monitoring § 200.332 § 200.339 § 200.521

2024-037 Oregon Business Development Department Assign responsibility to ensure review of subrecipient audit reports Management Response: We agree with this recommendation. In January 2025, Business Oregon started the initial work by meeting with DAS SARS team on identifying specific tasks for Busin...

2024-037 Oregon Business Development Department Assign responsibility to ensure review of subrecipient audit reports Management Response: We agree with this recommendation. In January 2025, Business Oregon started the initial work by meeting with DAS SARS team on identifying specific tasks for Business Oregon as the assigned audit agency for the SLFRF award. Business Oregon completed the preliminary reviews and confirmed that 23 out of 24 recipients of the SLFRF award are required for the single audit. Business Oregon contacted the recipients and requested financial reports to proceed with review of subrecipient audits. As of March 2025, the work is still ongoing, and Business Oregon is currently communicating with the recipients. The estimated completion date of this review is 6/30/2025 Anticipated Completion Date: June 30, 2025 Contact person: Imee Anderson, Chief Financial Officer, Mia Seo, Deputy-Chief Financial Officer, Rory Spencer, Accounting Manager

View Audit 353343

Finding 554725 (2024-036)

Significant Deficiency 2024

State of Oregon

OR

Subrecipient Monitoring Reporting Significant Deficiency

2024-036 Oregon Business Development Department Implement controls and submit delinquent FFATA reports Management Response: We partially agree with this recommendation. Business Oregon has prepared and submitted FFATA reports in SAM.gov through 2023, and had done so yearly since 2011. Due to staff t...

2024-036 Oregon Business Development Department Implement controls and submit delinquent FFATA reports Management Response: We partially agree with this recommendation. Business Oregon has prepared and submitted FFATA reports in SAM.gov through 2023, and had done so yearly since 2011. Due to staff turnover, Business Oregon has not completed loading the data for FFATA reporting for 2024. Business Oregon is currently in the process of compiling the data pertaining to CDBG grant awards and other federal grant awards that met the criteria for FFATA reporting. Business Oregon will formally assign this reporting task and create written procedures regarding preparation of the FFATA reports to ensure a complete list of recipients or subawards is reported in SAM.gov in a timely manner. The estimated completion date of this corrective action is 6/30/2025. Anticipated Completion Date: June 30, 2025 Contact person: Imee Anderson, Chief Financial Officer, Mia Seo, Deputy-Chief Financial Officer, Rory Spencer, Accounting Manager, Jon Unger, CDBG Program Manager

View Audit 353343

Finding 554721 (2024-031)

Significant Deficiency 2024

State of Oregon

OR

Subrecipient Monitoring Reporting School Nutrition Programs § 200.303

2024-031 Department of Education Implement controls to ensure FFATA reporting is completed for all required subawards Management Response: ODE agrees with this finding. To strengthen controls and ensure FFATA reporting is completed for all required subawards, ODE plans to implement the following pro...

2024-031 Department of Education Implement controls to ensure FFATA reporting is completed for all required subawards Management Response: ODE agrees with this finding. To strengthen controls and ensure FFATA reporting is completed for all required subawards, ODE plans to implement the following process improvements: • Collaborate with the Child Nutrition program management and Fiscal Grants team to provide full documentation of grant awards including terms, conditions and attachments. • Update ODE’s grant profile request Smartsheet tool to: o Identify FFATA eligibility prior to setting up a new grant award in the accounting system. o Automatically notify the FFATA team of new grant awards that require reporting. Anticipated Completion Date: June 30, 2025 Contact person: Kristie Miller, Accounting Director

View Audit 353343

Finding 554720 (2024-001)

None 2024

City of Cedar Park, Texas

TX

Special Tests & Provisions Subrecipient Monitoring HUD Housing Programs § 200.326

2024-001 Planned Corrective Action Management Comments and Corrective Action: The project manual included in the solicitation issued for construction of the North Brushy Creek Fork Trail Project did contain FHWA Required Contract Provisions that include the wage rate requirements and submission of...

2024-001 Planned Corrective Action Management Comments and Corrective Action: The project manual included in the solicitation issued for construction of the North Brushy Creek Fork Trail Project did contain FHWA Required Contract Provisions that include the wage rate requirements and submission of weekly certiﬁed payrolls to the City. City sta􀀁 was requesting the certiﬁed payrolls from the construction contractor upon request from TXDOT, the federal funding representative. Therefore, not all weekly payrolls were initially obtained. Upon request of the auditor, all weekly payrolls were obtained from the contractor and no issues were identiﬁed. City sta􀀁 has begun implementing a checklist for City sta􀀁 surrounding construction contracts on which Federal funding is involved. In addition, sta􀀁 and third-party representatives will be trained in federal reporting requirements. Proposed Implementation Date of Corrective Action: In process and to be completed by September 30, 2025. Person Responsible for Corrective Action: Chris Brickey, P.E., Capital Projects Manager – Engineering and Capital Projects

View Audit 353340

Finding 554719 (2024-003)

Material Weakness 2024

Tri-County Senior Citizens and Housing, Inc.

CO

Special Tests & Provisions Subrecipient Monitoring HUD Housing Programs

Finding 2024-003: Lower Income Housing Assistance Program - Section 8 New Construction and Substantial Rehabilitation Assistance Listing Number: 14.182 U.S. Department of Housing and Urban Development Compliance Require...

Finding 2024-003: Lower Income Housing Assistance Program - Section 8 New Construction and Substantial Rehabilitation Assistance Listing Number: 14.182 U.S. Department of Housing and Urban Development Compliance Requirements: Special Tests and Provisions Type of finding: Internal Control (material weakness) and Compliance (material noncompliance) Recommendation: The Organization should strengthen its internal controls with adopted policies and procedures to establish a monitoring process to ensure compliance with Mortgage Restructuring Loan terms and conditions. Action Taken: Director should review monthly statements and provide to bookkeeper for documentation. Annually, the bookkeeper and director should review the terms and determine the amount due for electronic payment of the Mortgage Restructuring Loan to be made by the bookkeeper. If there are any questions regarding this plan, please call the responsible party at (719) 852-5778. Sincerely yours, Monica Wolfe Executive Director Tri-County Senior Citizens and Housing, Inc.

View Audit 353337

Finding 554718 (2024-002)

Significant Deficiency 2024

Tri-County Senior Citizens and Housing, Inc.

CO

HUD Housing Programs Internal Control / Segregation of Duties Special Tests & Provisions § 200.303

Finding 2024-002: Lower Income Housing Assistance Program - Section 8 New Construction and Substantial Rehabilitation Assistance Listing Number: 14.182 U.S. Department of Housing and Urban Development ...

Finding 2024-002: Lower Income Housing Assistance Program - Section 8 New Construction and Substantial Rehabilitation Assistance Listing Number: 14.182 U.S. Department of Housing and Urban Development (Repeat of Finding 2023-002 and 2022-002) Compliance Requirements: Cash Management, Eligibility, Reporting, Special Tests and Provisions Type of finding: Internal Control Over Compliance (significant deficiency) Recommendation: The Organization should strengthen its internal controls with adopted policies and procedures to ensure a review process is established through adequate segregation of duties. The Organization should consider assessing and realigning the duties and responsibilities of administrative staff allowing the administrator to act in a more supervisory position. Action Taken: At this time, we do not have an administrative assistant/Activities Coordinator. Administrator works closely with the bookkeeper. Administrator and Executive Director will schedule every third recertification for review. Executive Director does review of the financial statements on a monthly basis when they are emailed over just before Policy Board meetings. During audit last year, we understood that reporting and eligibility did not have to happen at each interval but a review by another party in office every few re-certifications, as well as reviewing cash management. If there are any questions regarding this plan, please call the responsible party at (719) 852-5778. Sincerely yours, Monica Wolfe Executive Director Tri-County Senior Citizens and Housing, Inc.

View Audit 353337

Finding 554694 (2024-001)

Significant Deficiency 2024

Gettysburg Area School District

PA

Student Financial Aid Subrecipient Monitoring Reporting

CORRECTIVE ACTION PLAN YEAR END JUNE 30, 2024 Gettysburg Area School District respectfully submits the following corrective action plan in response to the findings listed in Section II of the Schedule of Findings and Questioned Costs for the year end June 30, 2024. Finding 2024-001: Reporting Requ...

CORRECTIVE ACTION PLAN YEAR END JUNE 30, 2024 Gettysburg Area School District respectfully submits the following corrective action plan in response to the findings listed in Section II of the Schedule of Findings and Questioned Costs for the year end June 30, 2024. Finding 2024-001: Reporting Requirements Condition: The District did not file the Title I, Title II, Title III, Title IV, ARP ESSER, ARP ESSER 7%, ARP ESSER Homeless Children and Youth, and ARP ESSER 2.5% Reconciliation of Cash on Hand Quarterly Reports for September 2023 and March 2024 in an timely manner within the 10-day requirement. The District did not file the Title I, Title II, Title III, Title IV, ARP ESSER, ARP ESSER 7%, ARP ESSER Homeless Children and Youth, and ARP ESSER 2.5% Reconciliation of Cash on Hand Quarterly Reports for December 2023 and June 2024. Additionally, the Final Expenditure Report for the ESSER II was not filed by the required due date. The reports noted here were not related to a single audit requirement and thus were reported as a financial statement internal control finding. Corrective Actions Taken or Planned: Corrective Action has been addressed for the Federal filing requirements for the 2024-2025 fiscal year and thereafter.

View Audit 353324

Finding 554683 (2024-009)

Significant Deficiency 2024

Harris County- 7 Month Audit

TX

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.213

Based on the nature of this finding, it has been determined that this finding has been isolated to the Harris County Purchasing Department who has the oversight of issuing all purchase orders pertaining to Countywide grants. The Harris County Purchasing Department along with each sub-awarded County ...

Based on the nature of this finding, it has been determined that this finding has been isolated to the Harris County Purchasing Department who has the oversight of issuing all purchase orders pertaining to Countywide grants. The Harris County Purchasing Department along with each sub-awarded County department will work to ensure the suspension and debarment requirements will be met as indicated in the Harris County Federal Procurement Policy Manual, adopted by Commissioners Court on March 8, 2022. The County Purchasing Agent shall work to implement the following controls to ensure all federal procurement requirements will be followed: • Obtain funding information from using departments to determine whether the procurement falls under federal funds. • If the procurement does fall under federal funds, a SAM.gov verification requirement will occur prior to processing the request for Commissioners court approval and/or approving a purchase order. • Require the purchase order requestor and/or purchasing agent to capture the date and website information to confirm the SAM.gov verification was performed in a timely manner. The County Purchasing Agent recognizes the importance of having debarment and suspension verifications included in the procurement file. The Harris County Purchasing Department is in the process of revising our internal procedure for Suspension and Debarments (SAMS) for contracts both below and above the $50,000 threshold. The existing internal procedure, last updated in 2018, is no longer adequate. By revising this procedure, we will ensure compliance with federal, state, and local procurement regulations.

View Audit 353302

Finding 554646 (2024-007)

Significant Deficiency 2024

Harris County- 7 Month Audit

TX

Subrecipient Monitoring

Management acknowledges the requirements of the Federal Funding Accountability and Transparency Act (FFATA), which requires direct recipients of grants or cooperative agreements to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Repo...

Management acknowledges the requirements of the Federal Funding Accountability and Transparency Act (FFATA), which requires direct recipients of grants or cooperative agreements to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Management will work with the Harris County Attorney’s Office to ensure these requirements are included in all grant subaward contracts by September 2025; and management will work with County departments and relevant staff to inform them of all parts of the applicable requirements and ensure there is a mechanism in place for reporting subaward data in the FSRS.

View Audit 353302

Finding 554625 (2024-040)

Significant Deficiency 2024

State of Oregon

OR

Subrecipient Monitoring § 200.332 § 200.339 § 200.521

2024-040 Oregon Department of Emergency Management Assign responsibility to ensure review of subrecipient audit reports Management Response: The Oregon Department of Emergency Management (OEM) concurs with the finding and the recommendations as outlined in the letter and above. OEM is undertaking th...

2024-040 Oregon Department of Emergency Management Assign responsibility to ensure review of subrecipient audit reports Management Response: The Oregon Department of Emergency Management (OEM) concurs with the finding and the recommendations as outlined in the letter and above. OEM is undertaking the following corrective actions to address the recommendations made by the Secretary of State’s Audits Division: • OEM will identify sufficient and appropriate grant accounting staff to perform this work on an ongoing basis, ensure that this work is added to their Position Descriptions, provide them with appropriate training, support, and guidance regarding subrecipient audit reviews. • OEM will establish an annual plan to assign this work out, establish and utilize tracking sheets, and follow up for timely completion. • OEM will work to address the past due FY 24 subrecipient reviews noted in the audit finding letter and above, and will then work to address those from FY23 and FY22. Anticipated completion date: December 31, 2026. Contact person: Amy Mettler, Chief Financial Officer.

View Audit 353285

Finding 554624 (2024-039)

Significant Deficiency 2024

State of Oregon

OR

Subrecipient Monitoring Reporting Significant Deficiency § 200.303

2024-039 Oregon Department of Emergency Management Continue FFATA reporting improvements and make inquiries on FSRS functionality Management Response: The Oregon Department of Emergency Management (OEM) concurs with the finding and the recommendations as outlined in the letter and above. OEM has und...

2024-039 Oregon Department of Emergency Management Continue FFATA reporting improvements and make inquiries on FSRS functionality Management Response: The Oregon Department of Emergency Management (OEM) concurs with the finding and the recommendations as outlined in the letter and above. OEM has undertaken and continues the following corrective actions to address the recommendations made by the Secretary of State’s Audits Division: • OEM has developed procedures for capturing necessary information and ensuring FFATA reports are filed in compliance with federal criteria. • OEM has identified all awards since July 1st 2023 and is working to ensure 100% compliance from that date forward. • OEM will conduct timely follow up on all submissions that fail to successfully load into the system, and clearly document that follow up for inclusion in our files. • OEM will continue to review older awards to determine what actions should be taken. Anticipated completion date: June 30, 2025. Contact person: Amy Mettler, Chief Financial Officer.

View Audit 353285

Finding 554599 (2024-009)

Material Weakness 2024

State of Oregon

OR

Subrecipient Monitoring § 200.331

2024-009 Oregon Health Authority Continue to implement and strengthen controls to ensure subrecipients are appropriately identified and monitored. Management Response: The agency agrees with the finding. During state fiscal year 2024, the division was in the process of implementing controls for sub...

2024-009 Oregon Health Authority Continue to implement and strengthen controls to ensure subrecipients are appropriately identified and monitored. Management Response: The agency agrees with the finding. During state fiscal year 2024, the division was in the process of implementing controls for subrecipient determination or contractors, required reporting, risk assessment, and monitoring plan. Since this period, the division has fully implemented the internal controls to ensure compliance with the federal requirements as identified in prior audits. The division recognizes that there are opportunities to strengthen the controls for subrecipient contractor determination, risk assessments and monitoring activities are accurate, complete, and documented and will refine these tools. The division also recognizes the opportunity to continue to improve controls that ensure that corresponding disbursements of federal funds are appropriately reported. The division will collaborate with agency financial services to develop enhanced controls that will ensure prevention, detection, and correction of payment reporting. Contact Person: Mick Kincaid Business Operations Manager Behavioral Health Division

View Audit 353285

Finding 554598 (2024-010)

Significant Deficiency 2024

State of Oregon

OR

Subrecipient Monitoring Reporting Significant Deficiency § 200.303

2024-010 Oregon Health Authority Submit required Federal Funding Accountability and Transparency Act reports Management Response: The agency agrees with the finding. The FFATA Reporting Coordinator position within the Office of Contracts & Procurement (OC&P) has been vacant for eight months but sho...

2024-010 Oregon Health Authority Submit required Federal Funding Accountability and Transparency Act reports Management Response: The agency agrees with the finding. The FFATA Reporting Coordinator position within the Office of Contracts & Procurement (OC&P) has been vacant for eight months but should be filled by April 15, 2025. On March 8, 2025, FSRS.gov was retired, and all subaward reporting data and functionality are now on SAM.gov. The new SAM.gov reporting system will allow for multiple Data Entry roles, allowing each program or division of ODHS/OHA to submit their own reporting, and allowing OC&P to conduct Quality Assurance/Quality Control. Once the FFATA Reporting Coordinator is onboard and trained, we anticipate the FFATA reporting will resume and any missing reports will be submitted by April 15, 2026. Anticipated Completion Date: April 15, 2026 Contact person: Noemi Schlegel, Compliance & Audits Program Manager

View Audit 353285

Finding 554593 (2024-025)

Significant Deficiency 2024

State of Oregon

OR

Special Tests & Provisions Subrecipient Monitoring Significant Deficiency

2024-025 Oregon Department of Human Services Ensure work participation rate calculation uses verified and accurate data Management Response: We agree with this recommendation. Office of Program Integrity’s leadership priorities are to update the risk assessment and to continue to meet weekly with th...

2024-025 Oregon Department of Human Services Ensure work participation rate calculation uses verified and accurate data Management Response: We agree with this recommendation. Office of Program Integrity’s leadership priorities are to update the risk assessment and to continue to meet weekly with the Chief Operating Officer to highlight the risks associated with inadequate staffing levels. Risk mitigation efforts to ensure JOBS reviews are performed in accordance with established procedures include cross training JOBS second level Quality Control beginning in March 2025 and time studies planned to determine adequate staffing levels for additional position requests. ODHS has a current workgroup led by the Project Management Office (PMO) that is tasked with conducting a training and coaching gap analysis for family coaches and making recommendations regarding Oregon’s Work Participation Rate. The workgroup consists of TANF policy analysts and the self- sufficiency training unit. In addition to the gap analysis, the workgroup is currently producing communications regarding documentation of work participation hours. ODHS will implement additional recommendations once they are identified. Anticipated Completion Date: 12/31/2025 Contact Person: Eva Ruiz, TANF program manager

View Audit 353285

Finding 554588 (2024-030)

Significant Deficiency 2024

State of Oregon

OR

Subrecipient Monitoring § 200.332

2024-030 Department of Education Perform regular fiscal monitoring as part of subrecipient monitoring Management Response: ODE agrees with this finding. ODE will ensure subrecipient fiscal monitoring is performed on the schedule set by department policy by: • Updating the internal procedure and time...

2024-030 Department of Education Perform regular fiscal monitoring as part of subrecipient monitoring Management Response: ODE agrees with this finding. ODE will ensure subrecipient fiscal monitoring is performed on the schedule set by department policy by: • Updating the internal procedure and timeline for requesting, reviewing and approving district submissions of claims for IDEA Fiscal Cyclical Monitoring. • Updating current IDEA Subrecipient Fiscal Monitoring manual to clarify updated internal procedure and timeline. The department will develop a procedure to track the completion of cyclical fiscal monitoring by: • Establishing a dedicated digital file to save district claims documentation and email communications for each cyclical monitoring review for each district. • Creating and utilizing a tracking document or system for each Cohort Group that will include the district, date of claim, amount of claim, approval status, date of approval, and location of documentation. • Develop a standard request notification and a standard approval notification for claims documentation. Anticipated Completion Date: June 30, 2025 Contact person: Allyson McNeil, OESO, Director of Resource Management and Operations and Rae Ann Ray, OESO IDEA Fiscal Team, IDEA Part B Grant Manager

View Audit 353285

Finding 554583 (2024-037)

Significant Deficiency 2024

State of Oregon

OR

Subrecipient Monitoring § 200.332 § 200.339 § 200.521

2024-037 Oregon Business Development Department Assign responsibility to ensure review of subrecipient audit reports Management Response: We agree with this recommendation. In January 2025, Business Oregon started the initial work by meeting with DAS SARS team on identifying specific tasks for Busin...

2024-037 Oregon Business Development Department Assign responsibility to ensure review of subrecipient audit reports Management Response: We agree with this recommendation. In January 2025, Business Oregon started the initial work by meeting with DAS SARS team on identifying specific tasks for Business Oregon as the assigned audit agency for the SLFRF award. Business Oregon completed the preliminary reviews and confirmed that 23 out of 24 recipients of the SLFRF award are required for the single audit. Business Oregon contacted the recipients and requested financial reports to proceed with review of subrecipient audits. As of March 2025, the work is still ongoing, and Business Oregon is currently communicating with the recipients. The estimated completion date of this review is 6/30/2025 Anticipated Completion Date: June 30, 2025 Contact person: Imee Anderson, Chief Financial Officer, Mia Seo, Deputy-Chief Financial Officer, Rory Spencer, Accounting Manager

View Audit 353285

Finding 554579 (2024-036)

Significant Deficiency 2024

State of Oregon

OR

Subrecipient Monitoring Reporting Significant Deficiency

2024-036 Oregon Business Development Department Implement controls and submit delinquent FFATA reports Management Response: We partially agree with this recommendation. Business Oregon has prepared and submitted FFATA reports in SAM.gov through 2023, and had done so yearly since 2011. Due to staff t...

2024-036 Oregon Business Development Department Implement controls and submit delinquent FFATA reports Management Response: We partially agree with this recommendation. Business Oregon has prepared and submitted FFATA reports in SAM.gov through 2023, and had done so yearly since 2011. Due to staff turnover, Business Oregon has not completed loading the data for FFATA reporting for 2024. Business Oregon is currently in the process of compiling the data pertaining to CDBG grant awards and other federal grant awards that met the criteria for FFATA reporting. Business Oregon will formally assign this reporting task and create written procedures regarding preparation of the FFATA reports to ensure a complete list of recipients or subawards is reported in SAM.gov in a timely manner. The estimated completion date of this corrective action is 6/30/2025. Anticipated Completion Date: June 30, 2025 Contact person: Imee Anderson, Chief Financial Officer, Mia Seo, Deputy-Chief Financial Officer, Rory Spencer, Accounting Manager, Jon Unger, CDBG Program Manager

View Audit 353285

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