Corrective Action Plans

Finding 382519 (2023-010)

Material Weakness 2023

PA

Questioned Costs Subrecipient Monitoring § 200.332 § 200.425 § 200.521

On March 2, 2021, AMLR program representatives attended a Department of Interior, Office of Surface Mining Reclamation and Enforcement online training covering 2 CFR 200 and contractor or subrecipient determinations. DEP ceased issuing AMLR grants under Management Directive 305.20, Grant Administr...

On March 2, 2021, AMLR program representatives attended a Department of Interior, Office of Surface Mining Reclamation and Enforcement online training covering 2 CFR 200 and contractor or subrecipient determinations. DEP ceased issuing AMLR grants under Management Directive 305.20, Grant Administration. DEP management has determined the recipients with existing agreements are subrecipients and DEP will follow this determination consistently with future agreements and accounting. DEP has developed written policies and procedures for subrecipient monitoring and has notified grantees to implement the policies and procedures immediately to ensure timely subrecipient compliance with federal regulations. On July 28, 2023, an audit resolution letter was issued by the Department of Interior, Office of Surface Mining Reclamation and Enforcement. To further address deficiencies, training for DEP Grant Managers was held on January 24, 2024, and January 31, 2024, to provide details and instruction on reporting requirements and proper documentation to ensure subrecipient compliance with federal regulations and DEP’s role in this compliance. Anticipated Completion Date: Completed Contact Names: Patrick Webb, Director, Bureau of Abandoned Mine Reclamation; Tim Golding, Exec. Assist., Office of Admin. and Management

View Audit 296143 Questioned Costs: $1

Finding 382515 (2023-008)

Significant Deficiency 2023

Commonwealth of Pennsylvania

PA

Questioned Costs Subrecipient Monitoring Internal Control / Segregation of Duties

PDE agrees with the portion of the finding pertaining to the lack of required signature on an expenditure report. To address this error, PDE will retrain staff and update “Tool Tips” in PEARS so that it is clearer for field advisers. PDE disagrees with two of the conditions of the finding, as stat...

PDE agrees with the portion of the finding pertaining to the lack of required signature on an expenditure report. To address this error, PDE will retrain staff and update “Tool Tips” in PEARS so that it is clearer for field advisers. PDE disagrees with two of the conditions of the finding, as stated by the auditors. First, regulation 7 CFR 226.6 (o), cited and summarized by the auditors as requiring PDE to resolve and close reviews within a specific timeline, does not include this requirement in the text. The regulation requires that subrecipients resolve any issues with a timeframe specified in their corrective action. Second, the first bulleted condition, states that “these reviews did not include any complex findings that would have required more time to close.” PDE procedure for closing reviews states that “any exception must be communicated and approved by the Supervisor…” The procedure does not qualify or limit these exceptions to “complex findings.” Accordingly, PDE will continue to follow its procedures as written. Anticipated Completion Date: 06/30/2024 Contact Names: Vonda Ramp, Chief, Div. of Food & Nutr., Bur. of Bdgt. & Fiscal Management; Clayton Carroll, Audit Coord., Bur. of Bdgt. & Fiscal Management

View Audit 296143 Questioned Costs: $1

Finding 382503 (2023-023)

Significant Deficiency 2023

Commonwealth of Pennsylvania

PA

Questioned Costs Subrecipient Monitoring Reporting § 200.1 § 200.332

PDA: For federal programs within the Food Distribution Cluster (ALNs 10.565, 10.568, and 10.569), PDA will put the following steps in place for (1) identifying the federal award information and applicable requirements and (2) evaluating each subrecipient’s risk of noncompliance as Required by the Un...

PDA: For federal programs within the Food Distribution Cluster (ALNs 10.565, 10.568, and 10.569), PDA will put the following steps in place for (1) identifying the federal award information and applicable requirements and (2) evaluating each subrecipient’s risk of noncompliance as Required by the Uniform Grant Guidance. 1) PDA will ensure that FAIN numbers are now included in all new subaward agreements. (For currently existing agreements, PDA will send letters by June 30 to provide the FAIN and reiterate Single Audit requirements.) 2) For those subaward agreements that are permanent and/or cover multiple funding years, PDA will develop procedures to ensure that annual notices are sent to each subrecipient notifying them of the updated FAIN for their agreement and reminding them of the Single Audit requirements that are laid out in the terms of their initial signed agreement. 3) PDA will develop a process to evaluate each subrecipient’s risk of noncompliance with federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring. The evaluation will be based on Key Performance Indicators, such as leadership tenure; prior incidents of food spoilage; or qualitative feedback from clients served. If the evaluation determines that additional monitoring tools beyond the routine performance of on-site reviews of the subrecipient's program operations are necessary, such conditions will be laid out in a separate letter communication to the sub-awardee. Anticipated Completion Date: 06/30/2024 Contact Name: Caryn Long Earl, Director, Bureau of Food Assistance PDOA: PDOA will implement the following steps to evaluate each subrecipient’s risk of noncompliance as required by the uniform grant guidance. 1. Evaluation is ongoing for the impacted Aging Cluster programs. 2. A risk assessment is being developed to evaluate each subrecipient’s risk of noncompliance to proactively address any weaknesses in internal controls over federal programs. - Pointed questions regarding the Organization included to gauge management’s ability to follow all terms and conditions of the contract. - General Policies will be reviewed for adherence to all federal and state regulations and competence of personnel administering the programs. - Since multiple federal funding streams are involved, a fiscal component will also be administered to review internal controls for financial issues. 3. Performance check-ins are launching in April of 2024 as part of a statewide comprehensive monitoring as a new form of regulatory measure. 4. Follow-Up procedures resulting from this finding will be reviewed and adjusted as needed to deliver optimal outcomes. Preliminary procedures will be directed to the agency’s audit review committee for resolution of completeness. 5. In the event the audit review committee determines additional steps beyond the monitoring efforts outlined above are insufficient, additional efforts will be communicated to the AAA network. Anticipated Completion Date: 06/30/2024 Contact Name: Jennifer Cave, Fiscal Management Specialist, PDOA Audit Liaison DOH: DOH plans to develop and implement a robust subrecipient monitoring program which includes establishing a new section within the Budget Office pending enacted budget funds and complement to support the creation of the section. Initiative goals/milestones include: 1. Educate Department: Budget Office is developing a bulletin that will outline the subrecipient monitoring requirements with links to state and federal sources. The bulletin will be shared with all program office staff. The Budget Office will develop the following templates and provide to all program offices: - Determination of vendor status: Subrecipient or Contractor - Risk Assessment Form - Internal Control Self-Assessment for Subrecipient Template - Subrecipient Monitoring Template 2. Implementation of full compliance initiative: Recommendations provided in the assessment will be used to develop and implement comprehensive policies and procedures lead by a new section in the Budget Office. Anticipated Completion Dates: 1 - 03/31/2024; 2 - 03/31/2025 Contact Name: Andrea Race, CFO DHS: Foster Care 1. For the portion of the audit finding that indicates State Agencies Did Not Identify the Federal Award Information and Applicable Requirements at the Time of the Subaward. Beginning state fiscal year 2024-2025, OCYF will begin sending out the required information to the Foster Care non-profit contractor. 2. Separately, OCYF will be developing a risk assessment process for the Foster Care non-profit contractor in state fiscal year 2024-2025. Anticipated Completion Dates: 1 - 06/30/2024; 2 - 06/30/2025 Contact Name: Melissa Erazo, Director, Bureau of Budget and Fiscal Support TANF and SSBG Effective December 31, 2023, DHS’ grant contract with Real Alternatives ended. We have no contract for services with them going forward. Despite repeated attempts and efforts to engage this grantee in ongoing monitoring activities, as well as monitoring after the end of the grant for previous years, they were uncooperative and unresponsive to our requests and therefore regular monitoring was not completed. Due to the Covid-19 global pandemic as well as staff turnover and vacancies in the Office of Policy Development, regular monitoring of SSBG grant recipients was not performed on schedule. However, with the hiring of a full complement of staff for the DHS Policy Office, including a Grant Administrator, we are in the process of creating and implementing a robust monitoring plan for all 19 of our grantees for calendar year 2024, including risk assessments, in person monitoring, desk monitoring, data collection and analysis. Anticipated Completion Date: 12/31/2024 Contact Name: Jessica Schneider, Executive Policy Specialist I, Grants

View Audit 296143 Questioned Costs: $1

Finding 382502 (2023-005)

Significant Deficiency 2023

Commonwealth of Pennsylvania

PA

Questioned Costs Subrecipient Monitoring Eligibility

PDA, Bureau of Food Assistance (BFA) has already or will put the following steps in place to address this deficiency and noncompliance finding. 1. BFA, in coordination with our contractor, Hunger-Free Pennsylvania, has developed a mechanism to track the reviews of all 16 lead subrecipient agencies f...

PDA, Bureau of Food Assistance (BFA) has already or will put the following steps in place to address this deficiency and noncompliance finding. 1. BFA, in coordination with our contractor, Hunger-Free Pennsylvania, has developed a mechanism to track the reviews of all 16 lead subrecipient agencies for the Commodity Supplemental Food Program (CSFP). This tracking mechanism will help to ensure that CSFP monitoring reviews are scheduled and completed in a timely manner, in accordance with federal regulations pertaining to CSFP. 2. BFA has scheduled a comprehensive monitoring review of Food Helpers (formerly known as Greater Washington County Food Bank). The review is scheduled to begin March 2024, and should be completed no later than April 30, 2024. Anticipated Completion Dates: 1 - Completed; 2 - 04/30/2024 Contact Name: Caryn Long Earl, Director, Bureau of Food Assistance

View Audit 296143 Questioned Costs: $1

Finding 382487 (2023-024)

Material Weakness 2023

Commonwealth of Pennsylvania

PA

Questioned Costs Subrecipient Monitoring Reporting § 200.208 § 200.332 § 200.339 § 200.501 § 200.505

PDA: PDA will be hiring a complement position to develop and maintain an audit tracking report to ensure that all single audits are properly logged and processed. In addition, this position will review the financial information in each audit report to determine if all pass-through funding is properl...

PDA: PDA will be hiring a complement position to develop and maintain an audit tracking report to ensure that all single audits are properly logged and processed. In addition, this position will review the financial information in each audit report to determine if all pass-through funding is properly included and subject to audit. This position will coordinate with the bureaus within PDA to ensure all required follow-up is completed in a timely manner. Anticipated Completion Date: 06/30/2024 Contact Name: Tracee Gotwalt, Audit Coordinator PDOA: The PDOA is looking to improve management decision communications in addition to more thorough evaluations as a new Comprehensive Monitoring Process pilot is starting in April 2024 to address the noncompliance of subrecipient monitoring. This has resulted in management designing control activities to achieve timely submissions in the future by initiating the following: 1. An audit tracking log has been established to track report submissions, document when they were received, initiated, findings requiring follow-up, and subsequent steps to finalize the audit. 2. A separate tracking mechanism is in place to ensure the monitoring of subrecipient activities for compliance with federal statutes, regulations, and the terms and conditions of the Agreement for the 52 Area Agency on Aging subrecipients. 3. PDOA is looking to fill a vacant position with a focus of tracking subrecipient expenditures in the aggregate and tracks Single Audit submissions on a Commonwealth wide basis since the Aging Cluster is material and has material sub-granted expenditures. 4. Since receiving the finding, PDOA has reached out to the resource account where Subrecipient Single Audit reports are received by the Federal Audit Clearinghouse (FAC) to verify all outstanding audit items for PDOA, as action is required within six months of receipt. 5. It is PDOAs impression that having increased oversight of the Schedule of Expenditures of Federal Awards (SEFA) will allow for timely dissemination of Management Decision Letters (MDL) in the six-month timeframe for making a management decision for federal award findings. 6. Additionally, PDOA will confirm a closure letter was sent to the Philadelphia Corporation for Aging documenting PDOA’s management decision regarding federal award findings, as included in their FYE 06/30/2021 Single Audit report. 7. Follow-Up procedures resulting from this finding will be reviewed and adjusted as needed to deliver optimal outcomes. Preliminary procedures will be directed to the agency’s audit review committee for resolution of completeness. 8. In the event the audit review committee determines additional steps beyond the monitoring efforts outlined above are insufficient, additional efforts will be communicated to the AAA network. Anticipated Completion Date: 06/30/2024 Contact Name: Jennifer Cave, Fiscal Management Specialist, PDOA Audit Liaison DOH: DOH’s subrecipient single audit tracking report now includes a mechanism to monitor management decision deadlines related to each entity’s FAC submission date. The process for tracking subrecipient audit reports with findings has been updated to include and highlight subrecipients’ audit reports where DOH is the lead agency for finding resolution or the report contains findings that relate to the Department. Anticipated Completion Date: 03/31/2024 Contact Name: Steven Marsden, Chief, Audit Resolution Section PDE: PDE has implemented weekly, monthly and quarterly checks to ensure that all single audits are properly logged and processed. The clerk typist will conduct a weekly review and provide confirmation to the audit coordinator by signature. Bi-weekly, the clerk typist will follow up on any single audits that remain open. Anticipated Completion Date: Completed Contact Names: Clayton Carroll, Audit Coordinator, Bureau of Budget & Fiscal Management; Jessica Sites, Director, Bureau of Budget & Fiscal Management

View Audit 296143 Questioned Costs: $1

Finding 382486 (2023-004)

Significant Deficiency 2023

Commonwealth of Pennsylvania

PA

Reporting School Nutrition Programs Special Tests & Provisions

PDA strives to maintain accurate and complete records with respect to the receipt, distribution, and inventory of USDA donated foods, including end products processed from donated food. To that end, PDA has already or will put the following steps in place to strengthen procedures for future periods ...

PDA strives to maintain accurate and complete records with respect to the receipt, distribution, and inventory of USDA donated foods, including end products processed from donated food. To that end, PDA has already or will put the following steps in place to strengthen procedures for future periods to ensure any errors are identified and corrected when reconciling the Bureau of Food Assistance’s (BFA’s) Commodity Inventory Report: 1. The finding noted in the audit with regards to the Commodity Inventory Report has been corrected and no known issues remain. 2. BFA will cross-train an additional staff member (the NSLP Specialist) on the process of completing the monthly Commodity Inventory Report. This staff member will then serve as a back-up to the Processing Specialist and will be able to complete a monthly review of the completed Commodity Inventory Report to ensure accuracy. 3. In the event that the numbers in BFA’s Monthly Commodity Inventory Report don’t balance, the Processing Specialist will consult with the Technical Specialist managing PA Meals, who can assist with a technical review of the raw numbers. 4. Sent an email communication to select commodity processors and brokers reiterating the process for submitting Monthly Processing Reports (MPRs) to BFA and reminding them of their responsibility to provide prompt responses should questions arise. Anticipated Completion Dates: 1, 3, 4 - Completed; 2 - 06/30/2024 Contact Name: Caryn Long Earl, Director, Bureau of Food Assistance

View Audit 296143

Finding 382482 (2023-012)

Material Weakness 2023

Commonwealth of Pennsylvania

PA

Questioned Costs Special Tests & Provisions Subrecipient Monitoring

Office of Income Maintenance (OIM) Bureau of Operations (BOO) BOO will take the following actions to address the finding: 1. All CAOs and district offices will be reminded of the EBT Coordinators’, alternates’, pinners’, and card makers’ responsibilities. The BOO will ensure users in the EBT Card T...

Office of Income Maintenance (OIM) Bureau of Operations (BOO) BOO will take the following actions to address the finding: 1. All CAOs and district offices will be reminded of the EBT Coordinators’, alternates’, pinners’, and card makers’ responsibilities. The BOO will ensure users in the EBT Card Tracking Database know their responsibilities and segregation of duties and will ensure there is coverage for card pinning until 5:00 pm each business day. Also, reminders to be sent to review the OIM EBT Procedural Manual periodically and when updates occur. This will occur by April 1, 2024. 2. All CAOs and district offices will be reminded to maintain adequate security of the EBT cards, card inventory, pinning devices, and ribbons. The EBT office will ensure all offices have two pinning devices and that they are in working order. This will occur by April 1, 2024. 3. OIM mandates annual training for EBT personnel to be completed at the beginning of each year. The training includes reviewing the procedures that safeguard access to the EBT systems. Area managers and staff assistants monitor completion of the training. Also included are the following: a. Review of roles and responsibilities and who may hold a role b. Card maker and pinner coverage for all business hours c. Proper security for EBT cards and associated items d. Timeframes for submitting changes e. Retention timeframes Anticipated Completion Dates: 1, 2 - 04/01/2024; 3 - Completed Contact Name: Jeanette Coulston, Staff Assistant to Director, Bureau of Operations OIM Bureau of Program Support (BPS)/EBT Project Office BPS will take the following actions to address the finding: 1. The EBT Project Office will make updates to the EBT Procedures Manual (Manual) and OIM EPPIC EBT Systems Application form (application) as needed. Notification of updates will be sent to CAO staff via email. This is expected to occur by April 1, 2024. 2. The EBT Program office will provide guidelines for the CAOs to follow when reviewing/updating their written internal procedures for EBT security of card mailings. This is expected to occur by April 1, 2024. 3. The EBT Project Officer will start retraining parties that are responsible for the completion of the EBT Headquarters Card Destruction log. This is expected to occur by April 1, 2024. Anticipated Completion Date: 04/01/2024 Contact Name: Tonya Holloway, Division Director OIM Bureau of Program Evaluation (BPE)/Division of Corrective Action (DCA) BPE will take the following actions to address the finding: The Bureau of Program Evaluation, Division of Corrective Action conducts EBT Card Security reviews at every CAO and District Office that issues EBT cards. These reviews are completed on a 3-year rotation to ensure compliance in the execution of documented policies and procedures. BPE/DCA will adjust the review criteria to incorporate any procedural changes implemented in the Electronic Benefit Transfer Procedures Manual. The current rotation schedule spans FFY 2022- FFY 2024. The new 3-year schedule will begin October 2024. Anticipated Completion Date: October 2024 Contact Name: Amira S. Milikin, Division Director

View Audit 296143 Questioned Costs: $1

Finding 382478 (2023-002)

Significant Deficiency 2023

County of Bristol, Masaachusetts

MA

Subrecipient Monitoring Internal Control / Segregation of Duties

The County has developed a formalized internal control policy and procedures, including a robust subrecipient monitoring program. The procedures include control environment, risk assessment, control activities and information and communication monitoring. As part of the procedure, the County ensures...

The County has developed a formalized internal control policy and procedures, including a robust subrecipient monitoring program. The procedures include control environment, risk assessment, control activities and information and communication monitoring. As part of the procedure, the County ensures that all documentation associated with subrecipient grants are maintained by the County. The County is monitoring ARPA subrecipients and will continue to do so.

View Audit 296136

Finding 382476 (2023-004)

Material Weakness 2023

North Harrison Community School Corporation

IN

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

Finding 2023-004 – Education Stabilization Fund Wage Rage Requirement Contact Person Responsible for Corrective Action: Administration and Head of Maintenance Contact Phone Number: 812-347-2407 Views of Responsible Official: We concur with the finding Description of Corrective Action Plan: Superin...

Finding 2023-004 – Education Stabilization Fund Wage Rage Requirement Contact Person Responsible for Corrective Action: Administration and Head of Maintenance Contact Phone Number: 812-347-2407 Views of Responsible Official: We concur with the finding Description of Corrective Action Plan: Superintendent will review with Grant Coordinator on any building projects where funds are allocated. Anticipated Completion Date: On going

View Audit 296134

Finding 382464 (2023-062)

None 2023

State of Nebraska

NE

Subrecipient Monitoring Reporting Internal Control / Segregation of Duties

Program: AL 21.027 – COVID-19 – Coronavirus State and Local Fiscal Recovery Funds – Reporting Corrective Action Plan: DAS will continue to request accurate numbers from each agency for quarterly input. DAS is working with the agencies noted to ensure they have and maintain proper documentation re...

Program: AL 21.027 – COVID-19 – Coronavirus State and Local Fiscal Recovery Funds – Reporting Corrective Action Plan: DAS will continue to request accurate numbers from each agency for quarterly input. DAS is working with the agencies noted to ensure they have and maintain proper documentation regarding capital expenditure justification. DHHS has written justification for the $3,967,469 (Improve Infrastructure) of capital expenditures. The Local Health Departments provided budgets which included planned activities/budgeting for capital expenditures. This justification was provided prior to the beginning of the project and was approved by DHHS staff. DHHS will continue to gather documentation from Local Health Departments related to capital expenditures. Contact: Philip Olsen, CPA, State Accounting Administrator; Ryan Daly, DHHS Deputy Director of Finance, Public Health Anticipated Completion Date: January 2024 & June 2025

View Audit 296116

Finding 382463 (2023-061)

Material Weakness 2023

State of Nebraska

NE

Questioned Costs Allowable Costs / Cost Principles Subrecipient Monitoring § 200.303 § 200.332 § 200.403 § 200.430

Program: AL 21.027 – COVID-19 – Coronavirus State and Local Fiscal Recovery Funds – Allowability & Subrecipient Monitoring Corrective Action Plan: Payments to Developmental Disability Providers, Assisted-Living Facilities, and Nursing Facilities for Employee Retention and Recruitment: DHHS is ...

Program: AL 21.027 – COVID-19 – Coronavirus State and Local Fiscal Recovery Funds – Allowability & Subrecipient Monitoring Corrective Action Plan: Payments to Developmental Disability Providers, Assisted-Living Facilities, and Nursing Facilities for Employee Retention and Recruitment: DHHS is in the process of obtaining affidavits from all Developmental Disability Providers, Assisted-Living Facilities, and Nursing Facilities who received payments under LB1014 stating that funds were used for allowable purposes. Premium Pay: We do not believe any corrective action is warranted as our files were corrected with the Auditor’s guidance and assistance in accordance with all CSLFRF eligibility requirements. Assistance to Nonprofits: For Shovel-Ready awards that have already been granted, DED will confirm prior to close-out of the grant that there is sufficient supporting documentation showing the awardee suffered a harm related and reasonably proportional to the award. Sufficient supporting documents must prove that the nonprofits suffered an economic harm, such as a decrease in revenue or an increase in expenses due to COVID-19. The evidence may include but is not limited to: • Profit and loss statements showing a decrease in revenue or an increase in expenses • Audited financial statements showing a decrease in review or an increase in expenses • Change in a line of credit • Increase in costs for projects related to COVID-19, such as construction cost data, • Decrease in written pledges related to COVID-19 • Decrease in donations related to COVID-19 • Historical fundraising comparisons University of Nebraska: The University project is ongoing. In the next six months, Military/NEMA will initiate monitoring activities to include the review and validation of expenditures for allowability as required under 2 C.F.R. part 200. Nursing Scholarships: DHHS’ current internal controls for the Nursing Scholarship program have minimized the risk of fraud as they correctly identified this case of fraud and have identified others prior to any payment being made. DHHS will continue to review payments for the Nursing Scholarship program, which uncovered the $5,000 identified in the finding. Contact: Payments to Developmental Disability Providers, Assisted-Living Facilities, and Nursing Facilities for Employee Retention and Recruitment: Heather Arnold, CPA, CFE DHHS Deputy Director of Financial Services Premium Pay: Nicole Zimmerman, Finance Director Assistance to Nonprofits: Audrey Sautter, DED Compliance Team Manager University of Nebraska: Erv Portis, Assistant Director-Nebraska Emergency Management Agency (NEMA) Nursing Scholarships: Heather Arnold, CPA, CFE DHHS Deputy Director of Financial Services Anticipated Completion Date: Payments to Developmental Disability Providers, Assisted-Living Facilities, and Nursing Facilities for Employee Retention and Recruitment: June 2025 Premium Pay: N/A Assistance to Nonprofits: DED will draft a policy to place the above into effect within the next 7 days. University of Nebraska: July 2024 Nursing Scholarships: June 2025

View Audit 296116 Questioned Costs: $1

Finding 382461 (2023-059)

None 2023

State of Nebraska

NE

Subrecipient Monitoring Procurement, Suspension & Debarment Reporting § 200.1 § 200.331 § 200.511

Program: AL 21.026 – COVID-19 Homeowner Assistance Fund – Subrecipient Monitoring Corrective Action Plan: The Military Department will continue to modify the Memorandum of Understanding between the parties to identify NIFA as a subrecipient and advise of them of any additional requirements. Cont...

Program: AL 21.026 – COVID-19 Homeowner Assistance Fund – Subrecipient Monitoring Corrective Action Plan: The Military Department will continue to modify the Memorandum of Understanding between the parties to identify NIFA as a subrecipient and advise of them of any additional requirements. Contact: Erv Portis Anticipated Completion Date: ongoing

View Audit 296116

Finding 382460 (2023-058)

Material Weakness 2023

State of Nebraska

NE

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles § 200.303 § 200.403 § 200.405

Program: AL 21.023 – COVID-19 Emergency Rental Assistance – Allowability & Eligibility & Period of Performance Corrective Action Plan: Continue process improvement to identify and correct assistance payments that are in accordance with the approved timelines and federal regulations. Contact: Er...

Program: AL 21.023 – COVID-19 Emergency Rental Assistance – Allowability & Eligibility & Period of Performance Corrective Action Plan: Continue process improvement to identify and correct assistance payments that are in accordance with the approved timelines and federal regulations. Contact: Erv Portis Anticipated Completion Date: Ongoing

View Audit 296116 Questioned Costs: $1

Finding 382459 (2023-066)

None 2023

State of Nebraska

NE

Subrecipient Monitoring § 200.1 § 200.332

Program: AL 20.509 – Formula Grants for Rural Areas – Subrecipient Monitoring Corrective Action Plan: NDOT updated the supplemental agreement template to include the Federal Award Identification information, including Federal award date and subaward period of performance start and end dates. A dr...

Program: AL 20.509 – Formula Grants for Rural Areas – Subrecipient Monitoring Corrective Action Plan: NDOT updated the supplemental agreement template to include the Federal Award Identification information, including Federal award date and subaward period of performance start and end dates. A draft template has been provided to the APA. Current 5311 agreements are effective July 1, 2024 to June 30, 2025, when additional supplemental agreements are needed, the updated template which includes FAIN information will be provided to the subrecipients. Contact: Jodi Gibson Anticipated Completion Date: Complete

View Audit 296116

Finding 382458 (2023-065)

Significant Deficiency 2023

State of Nebraska

NE

Questioned Costs Allowable Costs / Cost Principles Subrecipient Monitoring § 200.332 § 200.403 § 200.405 § 200.421 § 200.430

Program: AL 20.509 – Formula Grants for Rural Areas – Allowability & Subrecipient Monitoring Corrective Action Plan: NDOT recently updated the Invoicing Reimbursement Acceptable Documentation Requirement Guidelines. These guidelines offer comprehensive instruction, best practices, and a clearer d...

Program: AL 20.509 – Formula Grants for Rural Areas – Allowability & Subrecipient Monitoring Corrective Action Plan: NDOT recently updated the Invoicing Reimbursement Acceptable Documentation Requirement Guidelines. These guidelines offer comprehensive instruction, best practices, and a clearer definition of allowable expenses for subrecipients. The updated guide was distributed to subrecipients in February 2024. Over the next six months, NDOT plans to conduct additional training sessions through opportunities such as the monthly Transit Manager meetings, on-site visits, or webinars with subrecipients. The objective is to ensure a thorough understanding of required documentation and the identification of eligible federal reimbursement expenses. To assist with transit subrecipient monitoring, NDOT management has designated an internal auditor within the Transit Section. The auditor’s focus will be assessing reimbursement documentation, reviewing time studies, evaluating cost allocation plans, developing risk assessment, and helping to intensify monitoring efforts over all subrecipients. NDOT is also in the process of improving and updating the invoice review process to provide consistency for reviewing and approving invoices to enhance accuracy within the Transit Section. Additionally, NDOT has established a dedicated unit “Financial Oversight” within the Transit Section solely focusing on Subrecipient reimbursements. The four staff members in this unit will report directly to Financial Aid Administrator III, this oversight will enhance the quality checks and consistency among subrecipient reimbursements. The Financial Oversight unit will continue to evaluate and refine the operations to ensure federal regulation and required documentation is in place prior to any subrecipient reimbursement. Contact: Jodi Gibson Anticipated Completion Date: On-going

View Audit 296116 Questioned Costs: $1

Finding 382456 (2023-023)

None 2023

State of Nebraska

NE

Subrecipient Monitoring Reporting Matching / Level of Effort / Earmarking

Program: AL 14.228 – Community Development Block Grants – Reporting Corrective Action Plan: DED has changed its FFATA reporting procedure to ensure that the FFATA information is reported in FSRS within the required timeframe. The FFATA reporting process was previously a special condition to the r...

Program: AL 14.228 – Community Development Block Grants – Reporting Corrective Action Plan: DED has changed its FFATA reporting procedure to ensure that the FFATA information is reported in FSRS within the required timeframe. The FFATA reporting process was previously a special condition to the release of funds. The timeframe for completing special conditions often takes months, which is beyond the deadline for reporting FFATA information to FSRS. DED has changed its procedure to require that the awardee submit the FFATA information to DED at the time the awardee executes the subaward. Nothing can proceed and move forward in the award workflow until DED receives the FFATA information. DED program staff is notified of completion of the FFATA information by the awardee. The FFATA information is now given to the Finance Team when the subaward is executed which gives the Finance Team adequate time to submit the information to FSRS. All DED’s departments, programs, and awards that manage federal grants now use this FFATA procedure. Contact: Audrey Sautter, DED Compliance Team Manager Anticipated Completion Date: DED has already implemented this new FFATA procedure.

View Audit 296116

Finding 382455 (2023-064)

None 2023

State of Nebraska

NE

Subrecipient Monitoring Matching / Level of Effort / Earmarking

Program: AL 97.036 – Disaster Grants - Public Assistance (Presidentially Declared Disasters) – Reporting Corrective Action Plan: The Agency’s top priority is to respond to its vacancy needs by continuing working with department Human Resources to find, hire, and train viable candidates who can pe...

Program: AL 97.036 – Disaster Grants - Public Assistance (Presidentially Declared Disasters) – Reporting Corrective Action Plan: The Agency’s top priority is to respond to its vacancy needs by continuing working with department Human Resources to find, hire, and train viable candidates who can perform these important functions. Contact: Erv Portis Anticipated Completion Date: Ongoing

View Audit 296116

Finding 382454 (2023-063)

Significant Deficiency 2023

State of Nebraska

NE

Subrecipient Monitoring Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking § 200.332 § 200.501 § 200.514 § 200.521

Program: AL 97.036 – Disaster Grants - Public Assistance (Presidentially Declared Disasters) – Subrecipient Monitoring Corrective Action Plan: The Agency’s top priority is to respond to its vacancy needs by continuing working with department Human Resources to find, hire, and train viable candida...

Program: AL 97.036 – Disaster Grants - Public Assistance (Presidentially Declared Disasters) – Subrecipient Monitoring Corrective Action Plan: The Agency’s top priority is to respond to its vacancy needs by continuing working with department Human Resources to find, hire, and train viable candidates who can perform these important functions. Contact: Erv Portis Anticipated Completion Date: Ongoing

View Audit 296116

Finding 382448 (2023-052)

Significant Deficiency 2023

State of Nebraska

NE

Questioned Costs Special Tests & Provisions Procurement, Suspension & Debarment

Program: AL 93.778 – Medical Assistance Program – Special Tests and Provisions Corrective Action Plan: DHHS will update desk audit procedures to ensure the desk audits are completed with a reasonable assurance of accurate cost reporting. Contact: Jerry Vanderbeek; Danny Vanourney Anticipated C...

Program: AL 93.778 – Medical Assistance Program – Special Tests and Provisions Corrective Action Plan: DHHS will update desk audit procedures to ensure the desk audits are completed with a reasonable assurance of accurate cost reporting. Contact: Jerry Vanderbeek; Danny Vanourney Anticipated Completion Date: 12/31/2024

View Audit 296116 Questioned Costs: $1

Finding 382424 (2023-042)

None 2023

State of Nebraska

NE

Subrecipient Monitoring Reporting

Program: AL 93.568 – Low-Income Home Energy Assistance (LIHEAP) - Reporting Corrective Action Plan: The issue regarding the household income levels from the prior year was discussed with the Federal funding agency/Federal funding agency’s data contractor prior to the submission of the Federal Fis...

Program: AL 93.568 – Low-Income Home Energy Assistance (LIHEAP) - Reporting Corrective Action Plan: The issue regarding the household income levels from the prior year was discussed with the Federal funding agency/Federal funding agency’s data contractor prior to the submission of the Federal Fiscal Year (FFY) 2022 Household Report. The Department of Health and Human Services (DHHS) was advised to submit the report with the data that was available and to identify the issue in the comments. DHHS identified the issue in the comments of the Household Report that was submitted to the Federal funding agency, and it was accepted. DHHS will work with technical staff to revise the report to ensure data is accurately reported. As of FFY 2024, the Federal funding agency revised the Household Report to no longer require applicant data. Thus, no further action is necessary regarding the applicant information. Contact: Matt Thomsen Anticipated Completion Date: 12/31/2024

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Finding 382422 (2023-041)

Material Weakness 2023

State of Nebraska

NE

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles

Program: AL 93.566 – Refugee and Entrant Assistance State/Replacement Designee Administered Programs – Allowability & Subrecipient Monitoring Corrective Action Plan: The Refugee Resettlement Program has implemented procedures to ensure invoicing is accurate and appropriate. All subrecipient quart...

Program: AL 93.566 – Refugee and Entrant Assistance State/Replacement Designee Administered Programs – Allowability & Subrecipient Monitoring Corrective Action Plan: The Refugee Resettlement Program has implemented procedures to ensure invoicing is accurate and appropriate. All subrecipient quarterly invoices will be audited with required backup documentation. Contact: Sara Bockelman Anticipated Completion Date: 6/2/2024

View Audit 296116 Questioned Costs: $1

Finding 382417 (2023-039)

None 2023

State of Nebraska

NE

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles

Program: AL 93.558 – Temporary Assistance for Needy Families (TANF) – Allowability & Subrecipient Monitoring Corrective Action Plan: Subrecipient monitoring procedures will be improved by providing guidance to the sub-recipients on the required documentation for documentation of personnel expense...

Program: AL 93.558 – Temporary Assistance for Needy Families (TANF) – Allowability & Subrecipient Monitoring Corrective Action Plan: Subrecipient monitoring procedures will be improved by providing guidance to the sub-recipients on the required documentation for documentation of personnel expenses and operational expenses. In addition, a uniform monitoring tool will be developed for the financial monitoring of all sub-recipients. Contact: Will Varicak Anticipated Completion Date: 3/1/2024

View Audit 296116 Questioned Costs: $1

Finding 382410 (2023-035)

None 2023

State of Nebraska

NE

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles

Program: AL 93.323 – COVID-19 Epidemiology & Laboratory Capacity for Infectious Diseases – Allowability & Subrecipient Monitoring Corrective Action Plan: DHHS will work with the Health Center Association of Nebraska (HCAN) to collect complete source documentation from HCAN's subrecipients and sub...

Program: AL 93.323 – COVID-19 Epidemiology & Laboratory Capacity for Infectious Diseases – Allowability & Subrecipient Monitoring Corrective Action Plan: DHHS will work with the Health Center Association of Nebraska (HCAN) to collect complete source documentation from HCAN's subrecipients and subcontractors. In addition, the ordering process has been updated to ensure adequate documentation is maintained, including delivery receipts. Contact: Ryan Daly, Caryn Vincent, Lucas Atkinson Anticipated Completion Date: 6/30/2024

View Audit 296116 Questioned Costs: $1

Finding 382404 (2023-033)

Significant Deficiency 2023

State of Nebraska

NE

Questioned Costs Allowable Costs / Cost Principles Subrecipient Monitoring

Program: AL 93.069 – Public Health Emergency Preparedness (PHEP); AL 93.889 – National Bioterrorism Hospital Preparedness Program (HPP) – Allowability & Subrecipient Monitoring Corrective Action Plan: The agency will continue to monitor subrecipient expenditures for compliance with applicable fed...

Program: AL 93.069 – Public Health Emergency Preparedness (PHEP); AL 93.889 – National Bioterrorism Hospital Preparedness Program (HPP) – Allowability & Subrecipient Monitoring Corrective Action Plan: The agency will continue to monitor subrecipient expenditures for compliance with applicable federal requirements. Contact: Ryan Daly, Lisa Osborne Anticipated Completion Date: 6/30/2024

View Audit 296116 Questioned Costs: $1

Finding 382403 (2023-028)

Significant Deficiency 2023

State of Nebraska

NE

Reporting Subrecipient Monitoring Matching / Level of Effort / Earmarking

Program: AL 84.425U – COVID-19 Education Stabilization Fund – American Rescue Plan – Elementary and Secondary School Emergency Relief Fund (ARP ESSER) – Reporting Corrective Action Plan: We are constantly reviewing policy and procedures to ensure internal controls are in compliance with federal r...

Program: AL 84.425U – COVID-19 Education Stabilization Fund – American Rescue Plan – Elementary and Secondary School Emergency Relief Fund (ARP ESSER) – Reporting Corrective Action Plan: We are constantly reviewing policy and procedures to ensure internal controls are in compliance with federal regulations. All contracts pass a legal and fiscal review prior to finalizing the agreement. If fiscal reviewer believes the nature of the agreement casts the entity as a subrecipient, then the fiscal reviewer will ask the agreement owner seeking review to further identify if the agreement is a contractor or subrecipient determination based on 2 CFR Chapter I, Chapter II, Part 200 et al. If determined a subrecipient agreement, then further information will be collected from the agreement owner to be incorporated into the agreement and made available for FFATA and fiscal monitoring purposes. Contact: Jen Utemark, Administrator, Office of Budget & Grants Management Anticipated Completion Date: 7/1/2024

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Corrective Action Plans

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