Corrective Action Plans

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DHS will review existing Medical Assistance and income calculation policies, make any necessary changes, and provide refresher training for staff at all levels of eligibility for various types of Medical Assistance. In addition, reminders about the Medical Assistance Policy will be included in month...
DHS will review existing Medical Assistance and income calculation policies, make any necessary changes, and provide refresher training for staff at all levels of eligibility for various types of Medical Assistance. In addition, reminders about the Medical Assistance Policy will be included in monthly unit meetings. DHS will complete targeted Medical Assistance case reviews, and a review of system (Gateway) designs will be conducted to identify any necessary changes, updates, and additional improvements.
Currently, DCH continues to meet with DHS/DFCS to ensure synchronization of the Georgia Gateway and GAMMIS systems. DCH is proposing additional procedures and policies for DHS/DFCS caseworkers to implement that will terminate members who have been determined ineligible in Gateway but remain active i...
Currently, DCH continues to meet with DHS/DFCS to ensure synchronization of the Georgia Gateway and GAMMIS systems. DCH is proposing additional procedures and policies for DHS/DFCS caseworkers to implement that will terminate members who have been determined ineligible in Gateway but remain active in GAMMIS.
DHS will review existing Medical Assistance and income calculation policies, make any necessary changes, and provide refresher training for staff at all levels of eligibility for various types of Medical Assistance. In addition, reminders about the Medical Assistance Policy will be included in month...
DHS will review existing Medical Assistance and income calculation policies, make any necessary changes, and provide refresher training for staff at all levels of eligibility for various types of Medical Assistance. In addition, reminders about the Medical Assistance Policy will be included in monthly unit meetings. DHS will complete targeted Medical Assistance case reviews, and a review of system (Gateway) designs will be conducted to identify any necessary changes, updates, and additional improvements.
To strengthen interagency coordination and ensure continued regulatory clarity, the Agency will revise the existing Memorandum of Understanding (MOU) between DHS and DBHDD. The updated MOU will formally define and document the respective roles and responsibilities of each entity related to Federal F...
To strengthen interagency coordination and ensure continued regulatory clarity, the Agency will revise the existing Memorandum of Understanding (MOU) between DHS and DBHDD. The updated MOU will formally define and document the respective roles and responsibilities of each entity related to Federal Funding Accountability and Transparency Act (FFATA) reporting requirements, consistent with 2 CFR Part 170 and applicable Uniform Guidance provisions. The revised agreement will specifically address the responsibility for FFATA subaward reporting, required data elements and documentation, data transmission timelines, and points of contact and accountability. DBHDD will formally revise Policy 17-102, Federal Funding Accountability and Transparency Act (FFATA) Preparation and Submission, to establish comprehensive procedures for FFATA reporting requirements as a pass-through entity. The revised policy will define standardized protocols, prescribe reporting timelines, specify required subaward data elements, and clearly designate points of contact to ensure the timely and accurate exchange of information necessary to maintain full compliance with FFATA reporting obligations. Also, beginning in November 2025, DBHDD implemented a proactive data-sharing process to support timely FFATA reporting. DBHDD has been providing the DHS Director of Finance with all relevant information pertaining to subawards of $30,000 or more, including the associated subaward data elements for ALN 93.667, within the statutory reporting timeframe. This process was implemented to enhance transparency, promote timely reporting, and eliminate any potential ambiguity regarding data exchange responsibilities. DBHDD believes these actions further strengthen interagency coordination and reinforce compliance with applicable federal reporting requirements. The Agency will revise the existing Memorandum of Understanding (MOU) between DHS and DBHDD upon expiration of the current agreement. The revised MOU will formally incorporate clarified roles and responsibilities related to FFATA reporting requirements, ensuring alignment with 2 CFR Part 170 and applicable Uniform Guidance provisions. At present, formal data transmission protocols are in place between the agencies to support timely and accurate FFATA reporting.
DHS Division of Family and Children Services (DFCS), Temporary Assistance for Needy Families (TANF) program, will review existing TANF and expense statement review policies, and provide refresher training on these policies and applicable forms for staff at all levels of eligibility. TANF management ...
DHS Division of Family and Children Services (DFCS), Temporary Assistance for Needy Families (TANF) program, will review existing TANF and expense statement review policies, and provide refresher training on these policies and applicable forms for staff at all levels of eligibility. TANF management will complete targeted case reviews to ensure that all applicable documentation is included in the file, and peer reviews will be initiated. In addition, a review of the Gateway System will be conducted, and any required form(s) will be updated and included in the case file, if required.
GOHS Management sought guidance from our NHTSA Regional Director, and steps were put in place to report all subawards for FFY2025 and FFY2026. FFATA reporting recently migrated all data entry to SAM. The GOHS Finance Director had Administrator access ONLY to SAM.gov not data entry, the CFO @ DPS had...
GOHS Management sought guidance from our NHTSA Regional Director, and steps were put in place to report all subawards for FFY2025 and FFY2026. FFATA reporting recently migrated all data entry to SAM. The GOHS Finance Director had Administrator access ONLY to SAM.gov not data entry, the CFO @ DPS had to grant data entry access and the GOHS staff began entering all the sub-recipients who were awarded a GOHS Grant of more than $30,000.00 for Federal Fiscal year 2025 and Federal Fiscal year 2026. The GOHS Finance Director noted that previous years FFATA entries were missing in SAM.gov. (no one in the Agency had data entry access). The GOHS Finance Director will ask for data entry access for another employee in the finance division, so the prior year's subawards can be added and GOHS will be in complete compliance with FFATA. To address this finding, GOHS Management will develop and implement formal written FFATA reporting procedures outlining identification of reportable subawards, required data elements, reporting timelines and assigned responsibilities. GOHS will centralize responsibility for FFATA reporting within the GOHS Finance department, with a designated secondary reviewer to ensure appropriate oversight and segregation of duties.
In response, the TCSG Office of Workforce Development has created a “FFATA Subaward Reporting and Tracking Form”. This form will be used to document each subaward that is entered into the SAM.gov federal website, listing each subaward by its FAIN Number, award amount connected to the corresponding F...
In response, the TCSG Office of Workforce Development has created a “FFATA Subaward Reporting and Tracking Form”. This form will be used to document each subaward that is entered into the SAM.gov federal website, listing each subaward by its FAIN Number, award amount connected to the corresponding FAIN number, and the staff member responsible for the subaward submission. This document will be created and provided by the staff member submitting the subawards in SAM.gov. Management within the OWD Grants and Finance Unit will review and confirm and the subawards in SAM.gov as indicated by the FFATA Subaward Reporting and Tracking Form. Upon confirmation by management, the form will be signed and dated. The new FFATA Subaward Reporting and Tracking Form will be emailed directly to DOAA.
GDOL now freezes the overpayment data at the end of every month so we can conduct periodic reconciliation of the overpayment records. This will allow discrepancies to be identified faster and resolved before the deadline to submit the report for the specified period. GDOL consults with USDOL’s natio...
GDOL now freezes the overpayment data at the end of every month so we can conduct periodic reconciliation of the overpayment records. This will allow discrepancies to be identified faster and resolved before the deadline to submit the report for the specified period. GDOL consults with USDOL’s national 227 reporting specialists on an ongoing basis to work towards a reconciliation of previously submitted reports. Federal regulations require an actual person to review and establish fraudulent overpayments. Due to the volume of claims and the number of cross matches to be performed on all state and federal pandemic programs, it requires multiple GDOL staffing levels to manually review all cross matches, requiring increased levels of state and federal funding. The crossmatch process is conducted using a software which runs a systematic check against weeks in a quarter for which benefits are paid, and wages are reported during the same quarter. Although the program may detect weeks paid and wages reported, this alone is not indicative of an overpayment. Therefore, the process involves verification correspondence being sent to both the claimant and the employer, as applicable, to verify the status of employment, the wages earned as well as the weeks in which an individual worked and earned the wages. Based on responses, an assessment is made to determine if an overpayment exists and subsequent actions are taken accordingly. We are prohibited from assuming a match is an overpayment. It is not an overpayment until we have completed a full investigation and provided due process to all parties. The Department has a significant number of pending and potential overpayment investigations that may result in either a non-fraud or fraud determination. We are utilizing merit and time-limited staff to maximize productivity by conducting fact-finding interviews, assessing case details, creating overpayments in the system, and making overpayment determinations. The statutes provide that an overpayment be established up to four years after such occurrence, act, or omission. Additionally, GDOL has procured a vendor to build and implement a modernized UI system slated to be launched in 2026. We will continue to utilize available resources to investigate and establish overpayments in the legacy system as quickly as possible and will continue to do so within the program parameters in the new system. Throughout CY 2025, GDOL participated in quarterly meetings with United States Department of Labor (USDOL) and other regional states to discuss fraud, overpayment issues and best practices used. These meetings will continue in CY2026.
We have documented our procedure for performance reporting so that reports are appropriately reviewed and approved prior to submission.
We have documented our procedure for performance reporting so that reports are appropriately reviewed and approved prior to submission.
GDOL acknowledges that this is a repeat finding from prior years. While the issue has been partially resolved, the Department provides the following response. Claimants who established PUA entitlement with a weekly benefit amount (WBA) greater than the minimum amount, or who were later determined to...
GDOL acknowledges that this is a repeat finding from prior years. While the issue has been partially resolved, the Department provides the following response. Claimants who established PUA entitlement with a weekly benefit amount (WBA) greater than the minimum amount, or who were later determined to be ineligible, did so based on wages self-reported by the claimant and/or wages reported by the employer. Under the CARES Act, claimants were required to submit proof of wages only; however, if proof was not provided, federal guidance permitted payment only at the minimum WBA and did not allow for disqualification of benefits solely due to lack of documentation. For PUA claims initially established at a higher WBA without sufficient proof, the WBA was subsequently reduced to the minimum amount as required. To date, the claimants cited in this finding have not provided the required documentation. The identified PUA claim was adjusted accordingly, and an Overpayment has been established. Disaster Unemployment Assistance (DUA) claims are established under a similar framework as PUA claims, with one key difference: payment requests are currently submitted via paper certification forms. Claimants submit these requests by mail, fax, or email. Because this process is manual, there is an increased risk of misfiling or errors, as occurred in the DUA claim identified. To address these findings and strengthen program integrity, GDOL has implemented and will continue implementing corrective actions and additional safeguards. As system deficiencies were identified, mitigation measures were implemented as quickly as possible to reduce the risk of improper payments. In addition, GDOL’s current UI Information Technology (IT) system was developed in 1982 using mainframe legacy technology. Due to its age and structural limitations, many automated processes and corrective controls cannot be easily implemented. As a result, numerous tasks, including the validation and processing of all PUA and DUA documentation to determine eligibility, must be performed manually by staff. As a long-term measure to strengthen internal controls and improve overall UI program administration, GDOL has partnered with a vendor to implement a modernized UI system. This new system will offer enhanced eligibility determination, improved payment controls, and technological safeguards to support both current and future unemployment programs. Migration to the modernized system is expected in late 2026.
GDOL’s current UI Tax system was developed in 1982 using mainframe legacy technology. Due to its age and structural limitations, many automated financial record-keeping processes and corrective controls cannot be easily implemented. As a long-term solution to strengthen internal controls and enhance...
GDOL’s current UI Tax system was developed in 1982 using mainframe legacy technology. Due to its age and structural limitations, many automated financial record-keeping processes and corrective controls cannot be easily implemented. As a long-term solution to strengthen internal controls and enhance overall UI program administration, GDOL has contracted with a vendor to implement a more efficient method for maintaining documentation of taxes due and received. Migration to the modernized system is anticipated in late 2026. A review of the thirteen accounts identified the source of each payment, the amounts remitted, and the associated tax account allocations. Our records showed all payments, except for one, were submitted electronically via ACH Debit or ACH Credit. These ACH transactions are reflected as components of the total daily ACH Debits or Credits shown on the agency’s bank statement spreadsheets for the dates associated with the payments. The Contribution Tax amount represents only a portion of the total tax due. Therefore, the payment amount and the Contribution Tax amount may differ.
As of August 2025, we transferred all FFATA reporting duties to the Director of Operations and Systems. The Director of Operations and Systems hired a staff member in January 2026 to assist with FFATA reporting. All FFATA reporting moved from USA Spending to SAM.gov during fiscal year 2025. The migr...
As of August 2025, we transferred all FFATA reporting duties to the Director of Operations and Systems. The Director of Operations and Systems hired a staff member in January 2026 to assist with FFATA reporting. All FFATA reporting moved from USA Spending to SAM.gov during fiscal year 2025. The migration to SAM.gov caused delays as a result of the account setup process that were out of our control, but we anticipate being current on all FFATA reporting by June 30, 2026.
Actionable plan: The Organization adopted a written, standalone procurement policy to govern transactions under Federal awards. This policy will be designed to strictly comply with the procurement requirements outlined in the Code of Federal Regulations, specifically 2 CFR 200.318. Responsible indiv...
Actionable plan: The Organization adopted a written, standalone procurement policy to govern transactions under Federal awards. This policy will be designed to strictly comply with the procurement requirements outlined in the Code of Federal Regulations, specifically 2 CFR 200.318. Responsible individual: Madeline Henriquez, Executive Director, and the Board of Directors Completion date: February 17, 2026
Although its already January 28, 2026, and full implementation may not cover the entire fiscal year ending May 31, 2026, the Center will implement mitigating strategies immediately by aligning drawdowns with near-term disbursement needs, enhancing cash forecasting, and using alternative resources to...
Although its already January 28, 2026, and full implementation may not cover the entire fiscal year ending May 31, 2026, the Center will implement mitigating strategies immediately by aligning drawdowns with near-term disbursement needs, enhancing cash forecasting, and using alternative resources to cover payroll/operating costs while awaiting reimbursements. Management will document and review drawdown support to promote ongoing compliance
Finding 1213947 (2025-009)
Material Weakness 2025
It has been brought to our attention that we need an additional policy that covers conflict of interests and govern the performance of its employees engaged in the selection, award, and administration of contracts. We have taken this recommendation and are implementing the proper language, for all e...
It has been brought to our attention that we need an additional policy that covers conflict of interests and govern the performance of its employees engaged in the selection, award, and administration of contracts. We have taken this recommendation and are implementing the proper language, for all employees to acknowledge in our County Handbook. We will strengthen this control and add this be updated yearly, so that all conflict can be disclosed. Creek County prides itself in moving toward complete transparency and holding each employee accountable to disclose all information needed to make a proper selection of purchases. Creek County Clerk’s Office will work with the District Attorney’s Office for proper language.
Finding number 2025-006: Significant deficiency in procurement, suspension, and debarment procedures. The council has enacted a written procurement policy, which management believed met all the standards required under 2 CFR 200.318 through 200.327. However, the policy failed to include some of the ...
Finding number 2025-006: Significant deficiency in procurement, suspension, and debarment procedures. The council has enacted a written procurement policy, which management believed met all the standards required under 2 CFR 200.318 through 200.327. However, the policy failed to include some of the most stringent requirements included in the Uniform Guidance. The organization did not comply with all the documentation requirements laid out in its procurement policy. In addition, the suspension and debarment verification occurred after the contract was entered into, and there was no documentation maintained to demonstrate the monitoring of contract compliance with Build America, Buy America (BABA) Act. Questioned costs: none. Contact Person(s): Brian Barr, Executive Director Explanation and specific reasons for disagreement with audit finding or that corrective action is not required (if applicable): N/A Corrective action planned: Rogue River Watershed Council will review 2 CFR 200.318 through 200.327 and update our Procurement Policy to meet the necessary standards. We will strengthen our policy by setting out procedures related to, when required: (1) suspension/ debarment verification of contractors (including the timing of such verification) and (2) required agreement language related to grantrequired stipulations such as BABA requirements, monitoring, compliance, and documentation. Anticipated completion date: We will develop and approve the updated procurement policy by 7/31/2026.
Finding number 2025-005: Significant deficiency in reporting first-tier subawards of $30,000 or more to the Federal Service and Financial Reporting System in SAM.gov in accordance with Federal Funding Accountability and Transparency Act (FFATA). The council did not submit the required FFATA first-ti...
Finding number 2025-005: Significant deficiency in reporting first-tier subawards of $30,000 or more to the Federal Service and Financial Reporting System in SAM.gov in accordance with Federal Funding Accountability and Transparency Act (FFATA). The council did not submit the required FFATA first-tier subaward report for its federal subaward. The subaward met the reporting threshold, but no report was filed in SAM.gov. Questioned costs: none. US Department of the Interior / National Fish Passage / F24AC01768-00 Contact Person(s): Brian Barr, Executive Director Explanation and specific reasons for disagreement with audit finding or that corrective action is not required (if applicable): N/A Corrective action planned: Rogue River Watershed Council’s sub-recipient award in 2025 represents our first (and only) such award to date. We were not aware of the FFATA first-tier subaward report requirements for federal subawards in excess of $30,000. The Sub-Recipient Award Policy that we will develop to address audit finding 2025-004 will include a procedure (or set of procedures) to ensure the reporting of qualifying first-tier subawards to the Federal Service and Financial Reporting System in SAM.gov in accordance with Federal Funding Accountability and Transparency Act (FFATA). Anticipated completion date: Rogue River Watershed Council will develop and approve a Sub-Recipient Award Policy by 11/30/2026.
Finding number 2025-004: Significant deficiency in subrecipient monitoring. The council did not fully implement the required subrecipient monitoring procedures for its federal subaward. Specifically: • A formal written risk assessment was not performed prior to issuing the subaward. The Council reli...
Finding number 2025-004: Significant deficiency in subrecipient monitoring. The council did not fully implement the required subrecipient monitoring procedures for its federal subaward. Specifically: • A formal written risk assessment was not performed prior to issuing the subaward. The Council relied on its prior working relationship with and knowledge of the subrecipient on non-federally funded projects rather than evaluating federal compliance risk. • Procurement and suspension/debarment verification were performed after the start of the subaward date. • Monitoring procedures performed were not thoroughly documented • The subaward did not include certain necessary language related the audit requirements under 2 CFR 200, Subpart FQuestioned costs: none. Contact Person(s): Brian Barr, Executive Director Explanation and specific reasons for disagreement with audit finding or that corrective action is not required (if applicable): N/A Corrective action planned: Rogue River Watershed Council’s sub-recipient award in 2025 represents our first (and only) such award to date. While we don’t expect any sub-recipient awards in the near future, we will develop a set of procedures guiding such awards including the steps and the required timing for conducting a risk assessment, suspension/ debarment verification, required monitoring procedures, and the required language under 2 CFR 200, Subpart F. These procedures will be contained within a stand-alone policy for sub-recipient awards. Anticipated completion date: Rogue River Watershed Council will develop and approve a Sub-Recipient Award Policy by 11/30/2026.
Finding 2025-003 – Suspension and Debarment Significant Deficiency in Internal Control Over Compliance Corrective Action Plan: The Town will implement procedures to verify contractor eligibility for all applicable procurements by documenting searches performed in the System for Award Management (SAM...
Finding 2025-003 – Suspension and Debarment Significant Deficiency in Internal Control Over Compliance Corrective Action Plan: The Town will implement procedures to verify contractor eligibility for all applicable procurements by documenting searches performed in the System for Award Management (SAM.gov) or obtaining certifications from contractors. Contract templates will be updated to include required suspension and debarment certification language, as applicable. Documentation of verification will be retained in procurement files. Responsible Official: Clerk/Treasurer Planned Completion Date: May 2026
Finding 2025-002 – Cash Management (Reimbursement Request Error) Significant Deficiency in Internal Control Over Compliance and Noncompliance Corrective Action Plan: The Town will strengthen internal controls over reimbursement requests by implementing a reconciliation process between requested amou...
Finding 2025-002 – Cash Management (Reimbursement Request Error) Significant Deficiency in Internal Control Over Compliance and Noncompliance Corrective Action Plan: The Town will strengthen internal controls over reimbursement requests by implementing a reconciliation process between requested amounts and supporting documentation prior to submission. A secondary review and approval will be required for all reimbursement requests. Responsible Official: Clerk/Treasurer Mayor Planned Completion Date: May 2026
Department of Education – Fund for the Improvement of Post Secondary Education Assistance Listing No. 84.116M Recommendation: We recommend the Organization improve controls/processes around reporting to ensure future reports are submitted within the allowable date ranges. Explanation of disagreement...
Department of Education – Fund for the Improvement of Post Secondary Education Assistance Listing No. 84.116M Recommendation: We recommend the Organization improve controls/processes around reporting to ensure future reports are submitted within the allowable date ranges. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management has implemented policies and procedures to ensure reporting is timely completed. These procedures include a monthly review of compliance requirements by both program and fiscal personnel.
The Town will update its finance and procurement procedures to require cost or price analysis for all procurements exceeding the simplified acquisition threshold, including contract modifications. A standard cost or price analysis form will be implemented and required prior to contract approval. Sta...
The Town will update its finance and procurement procedures to require cost or price analysis for all procurements exceeding the simplified acquisition threshold, including contract modifications. A standard cost or price analysis form will be implemented and required prior to contract approval. Staff will be trained on performing and documenting cost and price analyses, including during emergency response situations.
The Town will implement written procedures requiring the development and maintenance of project‑specific budgets for all federal awards, including FEMA emergency response and recovery projects. Project budgets will be prepared in accordance with approved scopes of work and used to monitor expenditur...
The Town will implement written procedures requiring the development and maintenance of project‑specific budgets for all federal awards, including FEMA emergency response and recovery projects. Project budgets will be prepared in accordance with approved scopes of work and used to monitor expenditures throughout the life of the award. The Town will provide training to applicable staff on federal grant budgeting requirements and designate responsibility for budget preparation and monitoring.
FINDING 2025-001: Head Start Program Control Weakness of Filing the Required Semi-Annual and Annual Reports Response: The District Clerk will contact the Head Start Grant Specialist to ensure the SF424 semi and annual reports are reviewed and approved when submitted. The District Clerk has reached o...
FINDING 2025-001: Head Start Program Control Weakness of Filing the Required Semi-Annual and Annual Reports Response: The District Clerk will contact the Head Start Grant Specialist to ensure the SF424 semi and annual reports are reviewed and approved when submitted. The District Clerk has reached out to the office of Head Start for assistance and has not received assistance needed. The District Clerk will go to fiscal training and continue to be proactive with the office of Head Start fiscal reporting team to ensure this finding is closed out. The District will ensure procedures are in place requiring that all Head Start reports be submitted within 30 days of the reporting period end date. The District Clerk will put an internal control in place with the Head Start Director to make sure all SF424's are submitted on time.
The District's management acknowledges and concurs with the finding regarding the maintenance of documentation for students removed from the graduation cohort. We recognize the importance of strictly adhering to the Elementary and Secondary Education Act (ESEA) requirements to ensure the integrity o...
The District's management acknowledges and concurs with the finding regarding the maintenance of documentation for students removed from the graduation cohort. We recognize the importance of strictly adhering to the Elementary and Secondary Education Act (ESEA) requirements to ensure the integrity of the four-year adjusted cohort graduation rate. Following the audit exit conference, District leadership met with staff from the Information Technology (CALPADS team), Educational Services departments and also site staff to discuss the root causes of the missing documentation. The District is committed to strengthening internal controls and ensuring that every student status change is backed by the specific evidentiary standards required by federal and state regulations.
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