Corrective Action Plans

Finding 395360 (2023-020)

Material Weakness 2023

State of Oregon

OR

Subrecipient Monitoring Reporting

2023-020 Oregon Health Authority Implement controls to ensure subrecipients are appropriately identified and monitored MANAGEMENT RESPONSE: We agree with this recommendation. Contracts and program staff have piloted and implemented tools to help administrators determine if the NFP is a contractor...

2023-020 Oregon Health Authority Implement controls to ensure subrecipients are appropriately identified and monitored MANAGEMENT RESPONSE: We agree with this recommendation. Contracts and program staff have piloted and implemented tools to help administrators determine if the NFP is a contractor or sub-recipient using the determination checklist. Department managers have communicated expectations related to the use of this tool and guidance to ensure that contract administrators understand how to determine if an agency is a contractor or sub-recipient. If determination identifies a subrecipient relationship, controls are in place to ensure the Federal Funding Accountability and Transparency Act (FFATA) form, self-assessment, and monitoring plan are completed. Further, mental health block grant planners will assess each new or amended contract for appropriate designation. OHA management plans to establish a single training for all staff to complete before developing a contract. This training will also include necessary messaging to all staff about terminology, location of resources, expectations as an administrator, and compliance/verification processes. OHA will provide this messaging and training through agency-wide emails, newsletters, and all staff meetings. OHA will continue refining its onboarding to incorporate these trainings and messaging. Additionally, the Office of Financial Services reviews each contract to determine the correct coding for each contracted service/deliverable and accurate code, such in State Financial Management Accounting (SFMA) system. Risk assessment survey has been developed that allows for self-assessment and documentation of the process. Administrators are requested to keep a copy of the assessment in their administrative file. Contract administrators create regularly scheduled meetings with the sub-awardee to monitor for compliance, depending on the risk of the sub-awardee. OHA-HSD has created a planning and implementation document to systematically identify the process of self-assessment and monitoring plan. In addition to the 11-module contract administration training required for all administrators. OHA plans to create an accessible folder for download to include the Contract Administration Plan (CAP), RACI Matrix, Monitoring, and closeout activities. Once all of the resources are socialized throughout the Program and Leadership staff, controls are still necessary to get as close to 100% compliance by the administrators. Controls that will be implemented are: • DocuSign CLM- During the automated workflow for approvals, administrators must verify that the determination document and, if applicable, the self-assessment and monitoring plan is attached. If not, the request will be rejected until the proper documentation is provided. • Team audit- The program analyst will perform random audits of grant/contracts administrator folders to confirm documentation is complete for each grant/contract, including monitoring activities, reports, invoices, and grant compliance requirements. Anticipated Completion Date: September 1, 2024 Contact person: Amy Ashton-Williams, Adult Behavioral Health Director

View Audit 305129

Finding 395355 (2023-018)

Significant Deficiency 2023

State of Oregon

OR

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

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

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

View Audit 305129

Finding 395341 (2023-042)

Significant Deficiency 2023

State of Oregon

OR

Procurement, Suspension & Debarment Subrecipient Monitoring Allowable Costs / Cost Principles § 200.303 § 200.439

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

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

View Audit 305129

Finding 395340 (2023-041)

Significant Deficiency 2023

State of Oregon

OR

Subrecipient Monitoring Reporting Significant Deficiency § 200.303

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

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

View Audit 305129

Finding 395332 (2023-045)

None 2023

State of Oregon

OR

Questioned Costs Subrecipient Monitoring § 200.332 § 200.501

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

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

View Audit 305129 Questioned Costs: $1

Finding 395330 (2023-015)

Material Weakness 2023

State of Oregon

OR

Matching / Level of Effort / Earmarking Procurement, Suspension & Debarment Subrecipient Monitoring § 200.303 § 200.311 § 200.313 § 200.317

2023-015 Oregon Housing and Community Services Fully implement controls to ensure subrecipients are in compliance with program requirements MANAGEMENT RESPONSE: We agree with this recommendation. OHCS has hired an outside contractor to complete the requested work. Contractor was not in place in...

2023-015 Oregon Housing and Community Services Fully implement controls to ensure subrecipients are in compliance with program requirements MANAGEMENT RESPONSE: We agree with this recommendation. OHCS has hired an outside contractor to complete the requested work. Contractor was not in place in time to complete action prior to end of audit work, however work will be finalized prior to the end of the current fiscal year. Anticipated Completion Date: June 30, 2024 Contact person: Dean Criscola, Controller

View Audit 305129

Finding 395292 (2023-067)

Significant Deficiency 2023

State of Rhode Island

RI

Allowable Costs / Cost Principles Subrecipient Monitoring Significant Deficiency

Finding 2023-067 – Corrective Action Plan EOHHS amended and updated its guidelines and standard operating procedures leveraging the CMS ‘Delivering Service in School-Based Settings: A Comprehensive Guide to Medicaid Services and Administrative Claiming’ as a source document. In addition to ensurin...

Finding 2023-067 – Corrective Action Plan EOHHS amended and updated its guidelines and standard operating procedures leveraging the CMS ‘Delivering Service in School-Based Settings: A Comprehensive Guide to Medicaid Services and Administrative Claiming’ as a source document. In addition to ensuring alignment with CMS requirements, the updated guidelines include a uniform schedule of quarterly submission dates and details the billing responsibilities of participating LEAs. These responsibilities include meeting all Medicaid documentation requirements; submitting the Certification of Local Funds on a quarterly basis; and signing provider agreements and maintaining all other records used to support claims submitted for Medicaid reimbursement. Upon receipt of these submissions a new audit tool will be utilized to ensure each submissions contains the required documentation. EOHHS Medicaid Program Integrity will also collect the claims data, sort the list, comprise a sample, perform the review, and issue a report for participating LEAs. In the event of missing documentation, incomplete documentation, or an error, the LEA and their billing contractor will be notified. Failure to resubmit the missing file(s) or failure to address any errors identified will result in a withhold of reimbursement for that LEA until the following quarter. A finalized spreadsheet is then sent to finance for reimbursement. EOHHS is also engaged with the school-based services TA Center and will continue leverage this engagement to ensure compliance with CMS guidelines. Anticipated Completion Date: June 1, 2024 Contact Person: Tyler McFeeters, Health Program Administrator, Executive Office of Health & Human Services tyler.mcfeeters@ohhs.ri.gov

View Audit 305097

Finding 395270 (2023-063)

Significant Deficiency 2023

State of Rhode Island

RI

Allowable Costs / Cost Principles Subrecipient Monitoring Eligibility

Finding 2023-063 – Corrective Action Plan Each health plan reports TPL recoveries to EOHHS in its quarterly financial report (FDCR). These recoveries are used as a direct offset to medical expenses. As such, claims paid by the plans on behalf of a member with TPL will remain in the EOHHS encounte...

Finding 2023-063 – Corrective Action Plan Each health plan reports TPL recoveries to EOHHS in its quarterly financial report (FDCR). These recoveries are used as a direct offset to medical expenses. As such, claims paid by the plans on behalf of a member with TPL will remain in the EOHHS encounter data warehouse. Health plans do not void claims that have previously been paid to account for any TPL liability. Rather, they seek to recover from the third party any amount owed and report that amount to the state. In each of the last two fiscal years, this reduced medical expenditures by just under $8 million. EOHHS sent the MCOs a full TPL file in July 2023. EOHHS will start the process for a new file in June 2024. Anticipated Completion Date: Ongoing Contact Person: Jeffrey Schmeltz, Chief of Family Health Systems, Executive Office of Health & Human Services jeffery.schmelts@ohhs.ri.gov

View Audit 305097

Finding 395256 (2023-056)

Material Weakness 2023

State of Rhode Island

RI

Questioned Costs Subrecipient Monitoring Eligibility

Finding 2023-056 – Corrective Action Plan Management agrees with the finding. Regulation 4.5.1, RIW approved families are categorically eligible for CCAP services when they have an acceptable need for services related to fulfilling RIW program requirements. The determination of employment plan com...

Finding 2023-056 – Corrective Action Plan Management agrees with the finding. Regulation 4.5.1, RIW approved families are categorically eligible for CCAP services when they have an acceptable need for services related to fulfilling RIW program requirements. The determination of employment plan components including any combination of education and work-related activities in the approved plan are determined by RIW Regulations, section 2.11. The need for services in an RIW CCAP case is based on the employment plan. In situations where an applicant parent does not comply with the RIW employment plan, CCAP services would not be approved. Once CCAP services are approved based on an employment plan for an RIW recipient, the approval is for a 12-month certification period and would not be terminated, per ACF federal requirements, for a subsequent change in employment plan participation or change in income (unless in excess of 85% SMI). It should be noted that in all cases, the decortications were documented in Bridges. CCAP training has also been enhanced in many ways. CCAP training is delivered along with RIW training on a bi-monthly basis for new hires and/or existing ETs The CCAP training module was revised to include topics specific to improper payments. Office of Child Care also holds monthly CCAP office hours for operations staff to connect with program admins, policy and training specialist to answer/troubleshoot questions from the field. Monthly analysis by error type now includes location and worker ID for analysis of more targeted training. DHS also continues to look at system and process improvements. Weekly CCAP theme meetings are ongoing to identify and solution Bridges related incidents. The CCAP Regulations have been reviewed and were opened Q1 2024 for policy updates to streamline and simplify verification processes where possible. Anticipated Completion Date: July 1, 2024 Contact Person: Nicole Chiello, Assistant Director – Office of Child Care, Department of Human Services nicole.chiello@dhs.ri.gov

View Audit 305097 Questioned Costs: $1

Finding 395252 (2023-055)

Significant Deficiency 2023

State of Rhode Island

RI

Subrecipient Monitoring Eligibility Significant Deficiency

Finding 2023-055 – Corrective Action Plan Management agrees with the finding. 2023-055a – DHS has subsequently reviewed the SOC 2 report and will submit to Accounts & Control. 2023-055b – Passwords have already been changed to meet the ETSS policy. 2023-055c – DHS will review user access every 60 d...

Finding 2023-055 – Corrective Action Plan Management agrees with the finding. 2023-055a – DHS has subsequently reviewed the SOC 2 report and will submit to Accounts & Control. 2023-055b – Passwords have already been changed to meet the ETSS policy. 2023-055c – DHS will review user access every 60 days or 90, respectively and terminate users as necessary. Anticipated Completion Date: June 30, 2024 Contact Persons: Deirdre Weedon, Chief Program Development, Low Income Home Energy Assistance Program (LIHEAP), Department of Human Services deirdre.weedon@dhs.ri.gov Ben Quattrucci, Associate Director, Financial & Contract Management, Department of Human Services benjamin.a.quattrucci@dhs.ri.gov

View Audit 305097

Finding 395247 (2023-054)

Significant Deficiency 2023

State of Rhode Island

RI

Subrecipient Monitoring Internal Control / Segregation of Duties Special Tests & Provisions

Finding 2023-054 – Corrective Action Plan 2023-054a – The State (EOHHS) receives quarterly user access reports from the MMIS fiscal agent. Anyone identified on the reports that have not logged in for a period of 60 days will have their access deleted. Currently, they are locked out and cannot acc...

Finding 2023-054 – Corrective Action Plan 2023-054a – The State (EOHHS) receives quarterly user access reports from the MMIS fiscal agent. Anyone identified on the reports that have not logged in for a period of 60 days will have their access deleted. Currently, they are locked out and cannot access the system without first requesting a password reset, which is reviewed and approved/denied by EOHHS systems group. In addition, when a user leaves state service or moves to another agency, their access is deleted. 2023-054b – The State (EOHHS) collaborates with system vendors (MMIS/Gainwell and Deloitte/RI Bridges) Maintenance & Operations (M&O) and Security teams and to ensure annual risk assessment/vulnerability best practices and lessons learned are integrated into annual planning and scope of work for future FYs. Anticipated Completion Date: Current and Ongoing Contact Persons: Brian Tichenor, RIBridges Medicaid Administrator, Executive Office of Health & Human Services brian.tichenor@ohhs.ri.gov Hector Rivera, Interdepartmental Project Manager, Executive Office of Health & Human Services hector.l.rivera@ohhs.ri.gov

View Audit 305097

Finding 395237 (2023-049)

Significant Deficiency 2023

State of Rhode Island

RI

Subrecipient Monitoring Reporting Significant Deficiency

Finding 2023-049 – Corrective Action Plan RIDOH agrees with the finding and recommendation. The unreported subawards of ELC funds were Memoranda of Understanding (MOU) agreements with Local Education Agencies and other schools in Rhode Island for the ELC COVID Reopening Schools award and were not ...

Finding 2023-049 – Corrective Action Plan RIDOH agrees with the finding and recommendation. The unreported subawards of ELC funds were Memoranda of Understanding (MOU) agreements with Local Education Agencies and other schools in Rhode Island for the ELC COVID Reopening Schools award and were not recognized as being subject to FFATA reporting. RIDOH will review all internal policies and procedures regarding both subawards and interagency agreements with federal funds (IAA-FF), and FFATA reporting thereof, to assure RIDOH is aligned with the statewide DOA policies for FFATA reporting. RIDOH will provide training to all contract managers, program managers for subawards, and staff responsible for reporting in FSRS to assure all subawarded funds are captured and reported appropriately. Anticipated Completion Date: December 31, 2024 Contact Persons: Alisha Colella, Chief Financial Officer, Rhode Island Department of Health alisha.colella@health.ri.gov Carla Lundquist, Deputy CFO / Federal Grants Manager, Rhode Island Department of Health carla.lundquist@health.ri.gov

View Audit 305097

Finding 395228 (2023-048)

Material Weakness 2023

State of Rhode Island

RI

Subrecipient Monitoring Material Weakness Reporting

Finding 2023-048 – Corrective Action Plan RIDE recognizes that CTE Program Monitoring did not reflect US DOE format and therefore developed a monitoring tool that meets USDOE layout and functionality. Using district provided CTE data, RIDE will review written documentation provided by the secondar...

Finding 2023-048 – Corrective Action Plan RIDE recognizes that CTE Program Monitoring did not reflect US DOE format and therefore developed a monitoring tool that meets USDOE layout and functionality. Using district provided CTE data, RIDE will review written documentation provided by the secondary/postsecondary districts being monitored. The monitoring will consist of both a desk audit and an onsite inspection of the subrecipients. After the review process is complete a report for subrecipients will be sent back to the subrecipients that were monitored. This may include next steps and the need (if any) for corrective action. Anticipated Completion Date: On May 1, 2024, and May 3, 2024, RIDE will begin monitoring a secondary and postsecondary Perkins recipient. RIDE will continue with subrecipient monitoring visits in each subsequent fiscal year to satisfy the requirements of the USDOE. Contact Person: Paul McConnell, Career & Technical Education Data Specialist, Department of Elementary & Secondary Education paul.mcconnell@ride.ri.gov

View Audit 305097

Finding 395223 (2023-044)

Significant Deficiency 2023

State of Rhode Island

RI

Internal Control / Segregation of Duties Subrecipient Monitoring Allowable Costs / Cost Principles

Finding 2023-044 – Corrective Action Plan 2023-044a – RIDE has developed written policies and procedures for the maintenance of AcceleGrants user accounts that will have all inactive users removed after 12 months of inactivity. Anticipated Completion Date: October 31, 2024 2023-044b – RIDE financ...

Finding 2023-044 – Corrective Action Plan 2023-044a – RIDE has developed written policies and procedures for the maintenance of AcceleGrants user accounts that will have all inactive users removed after 12 months of inactivity. Anticipated Completion Date: October 31, 2024 2023-044b – RIDE finance and IT offices will review the user complementary controls noted in the vendors most currently available SOC2 report and implement suggested controls that are deemed appropriate, reasonable, and necessary by the joint RIDE team. RIDE will have this finding resolved by December 31,2024. Anticipated Completion Date: December 31, 2024 2023-044c – Finance and IT at RIDE are working together to determine the correct schedule for regular IT risk assessments. The departments are also in the process of reviewing the disaster recovery plans for the vendor, and a vendor management plan. Anticipated Completion Date: December 31, 2024 Contact Person: Mark Dunham, Chief Financial Officer, Department of Elementary & Secondary Education mark.dunham@ride.ri.gov

View Audit 305097

Finding 395222 (2023-043)

Significant Deficiency 2023

State of Rhode Island

RI

Subrecipient Monitoring Internal Control / Segregation of Duties Special Tests & Provisions § 200.332

Finding 2023-043 – Corrective Action Plan Parameters regarding charter management organizations are in the charter school application, but additionally, Charter Management Organizations applicants will be asked to file a plan with the Office of School Opportunities on how they will avoid conflicts ...

Finding 2023-043 – Corrective Action Plan Parameters regarding charter management organizations are in the charter school application, but additionally, Charter Management Organizations applicants will be asked to file a plan with the Office of School Opportunities on how they will avoid conflicts of interest and related party transactions or insufficient segregation of duties between the Charter School and CMO. This request will be made by the Office of School Opportunities to the applicant after the applicant has received an approved completeness check. This answer will be reviewed by RIDE’s legal office before anything proceeds forward with the application". Under current practice, all application teams need to complete an RFP, with a full public comment period and public hearings and approval by the Council on Elementary and Special Education, in order to open a charter. RIDE has included a question in this year's annual subrecipient monitoring survey (which feeds into the annual risk assessment), asking Charters if they have a relationship with a Charter Management Organization (CMO). If they respond 'yes', we ask if they have written internal controls, policies and procedures specific to the CMO relationship and how the Charter School mitigates potential conflicts of interest, related party transactions and/or insufficient segregation of duties. We request that they upload a any written internal control, policies and procedures specific to the CMO relationship (if any). The survey with this revised language was sent out to subrecipients on April 19, 2024. Anticipated Completion Date: September 30, 2024 Contact Person: Mark Dunham, Chief Financial Officer, Department of Elementary & Secondary Education mark.dunham@ride.ri.gov

View Audit 305097

Finding 395209 (2023-040)

Significant Deficiency 2023

State of Rhode Island

RI

Subrecipient Monitoring Special Tests & Provisions Student Financial Aid

Finding 2023-040 – Corrective Action Plan There is no disagreement with the audit finding. The College has designated the Director of Information Security to oversee the information security function. The College has contracted with a firm to function as a virtual Certified Information Security O...

Finding 2023-040 – Corrective Action Plan There is no disagreement with the audit finding. The College has designated the Director of Information Security to oversee the information security function. The College has contracted with a firm to function as a virtual Certified Information Security Officer (vCISO) to support compliance as well as provide training and consulting services. The Assistance Vice President, Chief Information Officer is tasked with ensuring that the Written Information Security Program is updated annually and that compliance is maintained. Anticipated Completion Date: June 2024 Contact Person: Pamela Christman, Assistance Vice President, Chief Information Officer, Rhode Island College pchristman@ric.edu

View Audit 305097

Finding 395204 (2023-038)

Significant Deficiency 2023

State of Rhode Island

RI

Subrecipient Monitoring Reporting Significant Deficiency

Finding 2023-038 – Corrective Action Plan Auditee Views: SFRF reporting utilized physical posted date pulled from PowerBI environment. The issue with physical posted date is that the report can change based on when pulled. PRO project was not detailed in Annual Report. The blank sections of the do...

Finding 2023-038 – Corrective Action Plan Auditee Views: SFRF reporting utilized physical posted date pulled from PowerBI environment. The issue with physical posted date is that the report can change based on when pulled. PRO project was not detailed in Annual Report. The blank sections of the downloaded reports are due to a US Treasury system issue that affects all States, not just Rhode Island. PRO began taking screenshots once it became aware of the problem and will continue to do so. There is a tedious review process that is completed for reporting on this data and information supplied to PRO by the entities. Corrective Actions: Modify the U.S. Treasury reporting process to utilize cash date to align with RIFANS federal transaction register both cumulatively and quarterly. Anticipated Completion Date: May 15, 2024 Add PRO project description to SFRF Annual report to U.S. Treasury. Anticipated Completion Date: July 31, 2024 Collect additional information from component unit agency to support provided reporting data. Anticipated Completion Date: June 30, 2024 Contact Person: Paul L. Dion, Ph.D., Director, Pandemic Recovery Office, Department of Administration paul.l.dion@doa.ri.gov

View Audit 305097

Finding 395203 (2023-037)

Significant Deficiency 2023

State of Rhode Island

RI

Questioned Costs Allowable Costs / Cost Principles Subrecipient Monitoring § 200.403

Finding 2023-037 – Corrective Action Plan Auditee Views: PRO met with the Department of Housing and the legal services vendors. The Department of Housing is collecting backup documentation for the vendors to support payment. This has been shared with PRO via SharePoint. The Department may also...

Finding 2023-037 – Corrective Action Plan Auditee Views: PRO met with the Department of Housing and the legal services vendors. The Department of Housing is collecting backup documentation for the vendors to support payment. This has been shared with PRO via SharePoint. The Department may also request additional backup documentation from the vendors to further support these costs. Corrective Action: Obtain additional documentation from the legal services vendors and maintain SharePoint to ensure PRO has access to supporting documentation. Anticipated Completion Date: Completed and Ongoing Contact Person: Tara Booker, Executive Director of Homelessness and Community Supports, Department of Housing tara.booker@housing.ri.gov

View Audit 305097 Questioned Costs: $1

Finding 395202 (2023-030)

Material Weakness 2023

State of Rhode Island

RI

Subrecipient Monitoring § 200.332

Finding 2023-030 – Corrective Action Plan We agree with the finding and are actively working to address the underlying issues impacting inconsistent subrecipient monitoring activities by state agencies acting as pass-through entities. The Grants Management Office developed and provided a 3-part in ...

Finding 2023-030 – Corrective Action Plan We agree with the finding and are actively working to address the underlying issues impacting inconsistent subrecipient monitoring activities by state agencies acting as pass-through entities. The Grants Management Office developed and provided a 3-part in person (and recorded available on our website) training class on subrecipient monitoring in the fall of 2023. The training classes included monitoring best practice, in-person exercises and scenarios and an in-depth training and demonstration of the subrecipient monitoring module in the eCivis grant management system (GMS). As more subawards are issued through the GMS, we expect the monitoring module to be used to conduct subrecipient monitoring as required by federal rules/regulation. The training and new module in the GMS support the Grant-Making Regulation 220-RICR-20-00-2 which took full effect 7/1/23 and requires state agencies to issue subawards through the GMS. The regulation also specifically outlines the requirement of a risk assessment as part subaward issuance and informs agencies on the relationship between the risk assessment results and subrecipient monitoring. We believe these steps will significantly improve subrecipient monitoring activities conducted by state agencies and address this finding. Anticipated Completion Date: Completed. GMO continues to train and supporting/reinforcing control; expect to see improvements/results in the coming FY. Contact Person: Steve Thompson, Chief of Strategic Planning, Monitoring, and Evaluation, Grants Management Office, Office of Accounts and Control steve.thompson@doa.ri.gov

View Audit 305097

Finding 395194 (2023-032)

Significant Deficiency 2023

State of Rhode Island

RI

Allowable Costs / Cost Principles Subrecipient Monitoring Eligibility

Finding 2023-032 – Corrective Action Plan RIDOH agrees with the finding and recommendation. This finding is centered around some local agency staff being inactive for longer periods of time (60+ days) and the security risk around them not being terminated or made inactive in our Crossroads system....

Finding 2023-032 – Corrective Action Plan RIDOH agrees with the finding and recommendation. This finding is centered around some local agency staff being inactive for longer periods of time (60+ days) and the security risk around them not being terminated or made inactive in our Crossroads system. While RI WIC is routinely notified of terminations and transfers of local agency staff, there are instances of people with varying degrees of access going over 60 days without accessing the system. It is sometimes due to a local agency staff person who is in more of an administrator role and not routinely working in the Crossroads system. RI WIC will review policies and procedures regarding user access to the Crossroads System and will work to strengthen and monitor controls for system access. Policies and procedures will be updated as needed, and internal controls will be implemented and documented. Anticipated Completion Date: December 31, 2024 Contact Persons: Ann Barone, Chief, Office of Women, Infants & Children, Rhode Island Department of Health ann.barone@health.ri.gov Anthony Manzi, WIC Fiscal Manager, Rhode Island Department of Health anthony.manzi@health.ri.gov

View Audit 305097

Finding 395189 (2023-001)

Significant Deficiency 2023

Energy Northwest

WA

Subrecipient Monitoring Special Tests & Provisions

Re: Finding 2023-001 Significant Deficiency and Compliance with Special Tasks and Provisions Energy Northwest Management understands it is our responsibility to have adequate controls to ensure compliance with all provisions of a federal grant contract. To further enhance our internal controls, Ener...

Re: Finding 2023-001 Significant Deficiency and Compliance with Special Tasks and Provisions Energy Northwest Management understands it is our responsibility to have adequate controls to ensure compliance with all provisions of a federal grant contract. To further enhance our internal controls, Energy Northwest will establish the following Corrective Action Plan: Corrective Action Plan to Be Taken – Management will develop a checklist process to be utilized for all federal grants that will outline the specific provisions of each contract, who is responsible for the provision and the due date of each provision. Prior to finalization of the checklist, a review of the checklist will be done to ensure it encompasses all the provisions of the contract. Energy Northwest’s procedures will be updated to include the checklist process. Responsible Parties to Ensure Corrective Action Is Taken – Accounting Manager and Accounting & Budgets Director. The Corrective Action Timeline –  Checklists for existing federal contracts completed – September 30, 2024  Procedure updated with checklist process – September 30, 2024

View Audit 305074

Finding 395180 (2023-005)

Significant Deficiency 2023

The Shaw University, Inc.

NC

Internal Control / Segregation of Duties Subrecipient Monitoring Reporting

Name of Responsible Individual: Vice President of Finance and Administration (David Byrd) Corrective Action: The University concurs with the finding. The University will enhance and strengthen internal controls and procedures. As the university tightens internal controls and procedures, financial s...

Name of Responsible Individual: Vice President of Finance and Administration (David Byrd) Corrective Action: The University concurs with the finding. The University will enhance and strengthen internal controls and procedures. As the university tightens internal controls and procedures, financial statement reporting will be completed in a timely manner. Also, appropriate documentation retention will be maintained. This will result in compliance audits completed before the required deadline. Anticipated Completion Date: June 30, 2024

View Audit 305066

Finding 395114 (2023-001)

None 2023

Town of Westport, Massachusetts

MA

Subrecipient Monitoring Reporting § 200.1

Condition: Obligations were overstated by approximately $800,000 on the March 31, 2023 Project and Expenditure report. Corrective Action Planned: Will adjust on March 31, 2024 Project and Expenditure report. Anticipated Completion Date: April 30, 2024 Contact: Nicole Pearsall, Town Accountant

View Audit 305035

Finding 395111 (2023-001)

Material Weakness 2023

East Liberty Family Health Care Center INC

PA

Subrecipient Monitoring Reporting Internal Control / Segregation of Duties

Since taking over the financial management of ELFHCC in December 2022 we have reorganized the financial reporting process and have been able to ensure meaningful analysis on a regular and continual basis. Policies and procedures have been created, changed, updated and Board approved. All financial r...

Since taking over the financial management of ELFHCC in December 2022 we have reorganized the financial reporting process and have been able to ensure meaningful analysis on a regular and continual basis. Policies and procedures have been created, changed, updated and Board approved. All financial reporting is prepared, analyzed and presented each month without delay.

View Audit 305032

Finding 395033 (2023-007)

Significant Deficiency 2023

Florida Rural Legal Services, Inc.

AL

Subrecipient Monitoring Significant Deficiency Special Tests & Provisions

FRLS shared that as part of the corrective action plan, improved PAI services by changing pro bono coordinators from paralegals to attorneys to better work with private attorneys and respective bar associations throughout our service areas. FRLS has also reestablished connections with our respective...

FRLS shared that as part of the corrective action plan, improved PAI services by changing pro bono coordinators from paralegals to attorneys to better work with private attorneys and respective bar associations throughout our service areas. FRLS has also reestablished connections with our respective service partners throughout the pandemic, rebuilding and providing excellent services through our pro bono partners. PAI remains one of our top priorities in expanding our program services. Our program improvements, including pro bono assistance via virtual and courthouse clinics have resulted in more PAI services to our client communities. We have increased attendance at our annual bench and bar events to raise PAI awareness in our service communities. FRLS is in the process of creating a “low bono” program to expand our network of private attorneys and meet our required 12.5% spending requirement. FRLS will continue to evaluate its policies and procedures surrounding monitoring of PAI compliance to ensure that only allowable pro bono cases are accepted. This will be completed by December 31, 2024.

View Audit 304969

Corrective Action Plans

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