Corrective Action Plans

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FA 2022-001 Improve/Strengthen Controls over Expenditures Compliance Requirement: Activities Allowed or Unallowed Allowable Costs/Cost Principle Procurement and Suspension and Debarment Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding ...
FA 2022-001 Improve/Strengthen Controls over Expenditures Compliance Requirement: Activities Allowed or Unallowed Allowable Costs/Cost Principle Procurement and Suspension and Debarment Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education Assistance Listing Number and Title: COVID-19 - 84.425D - Elementary and Secondary School Emergency Relief Fund COVID-19 - 84.425U - American Rescue Plan Elementary and Secondary School Emergency Relief Fund Federal Award Number: S425D200012 (Year: 2020), S425D210012 (Year: 2021), S425U2120012 (Year: 2021) Questioner Costs: $265,630 Description: The polices and procedures of the School District were insufficient to provide adequate internal controls over expenditures as it relates to the Elementary and Secondary School Emergency Relief Fund program. Corrective Action Plans: We concur with this finding. The process used to pay retention wages to staff has been reviewed and will only be paid to staff employed by the Colquitt County Board of Education. Estimated Completion Date: Contact Person: Jeremy Jones, CFO Telephone: 229-890-6224 Email: jeremy.jones@colquitt.k12.ga.us
View Audit 40794 Questioned Costs: $1
Finding number 2022-002 Reporting - Significant Deficiency and Compliance Finding Assistance Listing 93.600 Head Start Contact Person - Marcy Blender ? Comptroller - 215-400-5435 Anticipated completion date: Four months - July 31, 2023 View of responsible officials and Planned Corrective Action The ...
Finding number 2022-002 Reporting - Significant Deficiency and Compliance Finding Assistance Listing 93.600 Head Start Contact Person - Marcy Blender ? Comptroller - 215-400-5435 Anticipated completion date: Four months - July 31, 2023 View of responsible officials and Planned Corrective Action The District agrees with this finding. The District will ensure that all federal awards are reviewed for FFATA reporting and will codify the method by which that occurs in a formal procedure.
Corrective Action Plan for Current Year Findings and Questioned Costs For the Year Ended June 30, 2022 Reference # and title: 2022-001 Reporting Federal program and specific federal award identification: AL Number Award Year FEDERAL GRANTER/ PASS THROUGH GRANTOR/PROGRAM NAME United States Depar...
Corrective Action Plan for Current Year Findings and Questioned Costs For the Year Ended June 30, 2022 Reference # and title: 2022-001 Reporting Federal program and specific federal award identification: AL Number Award Year FEDERAL GRANTER/ PASS THROUGH GRANTOR/PROGRAM NAME United States Department of Education; passed through Louisiana Department of Education Education Stabilization Funds (ESSER II and III) 84.425D and 84.425U 2021 Condition: Louisiana Department of Education (LDOE) requires the School Board to complete periodic expense reports (PER) each quarter to ensure the amounts expended to date are being properly reported. Good internal controls over the reports require that they are reviewed and approved before submission to ensure amounts being submitted are complete and accurate. In testing a sample of five PER reports, it was noted that two of the five reports did not agree to the School Board?s general ledger. In both cases, the amounts being reported to LDOE were understated. Corrective action planned: A reconciliation of total program expenditures claimed for reimbursement across the entire award period to the total accumulated on the Period Expense Report will be made for each ESF grant award. The total expenditures on the Periodic Expense Report will also be reconciled to School Board?s general ledger transactions for the entire grant award period. Before each PER submission, the Accounting Manager will prepare and submit the reconciliations to the Grant Supervisor who will review and approve the information presented on the PER prior to submission to the LDOE. The Grant Supervisor will review to ensure all expenditures incurred are being reported and accurately presented. The Chief Financial Officer will monitor to ensure these procedures are implemented and are effective. Person responsible for corrective action: Mrs. Juanita Duke, Chief Financial Officer Phone: (318) 255-1430 Lincoln Parish School Board Fax: (318) 255-3203 410 South Farmerville Street Ruston, LA 71270 Anticipated completion date: June 30, 2023 Respectfully,
CORRECTIVE ACTION PLAN Oversight Agency for Audit: U.S. Department of Education The City of Haverhill, Massachusetts respectfully submits the following corrective action plan for the year ended June 30, 2022. Name and address of independent public accounting firm: Powers & Sullivan, LLC 100...
CORRECTIVE ACTION PLAN Oversight Agency for Audit: U.S. Department of Education The City of Haverhill, Massachusetts respectfully submits the following corrective action plan for the year ended June 30, 2022. Name and address of independent public accounting firm: Powers & Sullivan, LLC 100 Quannapowitt Parkway, Suite 101 Wakefield, MA 01880 Audit period: July 1, 2021 through June 30, 2022 The finding from the June 30, 2022, schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. FINDINGS?FEDERAL AWARD PROGRAMS AUDITS U.S. DEPARTMENT OF EDUCATION Passed through the Massachusetts Department of Elementary and Secondary Education Education Stabilization Fund Education Stabilization Fund Federal Assistance Listing No. 84.425C, 84.425D, and 84.425W 2022-003: Controls for the Purchasing of Capital Equipment Compliance Requirement: Equipment/Real Property Management Type of Finding: Compliance and Internal Control over Compliance ? Other Matter Criteria or Specific Requirement: Grantees must obtain prior approval from the pass-through entity for capital expenditures related to general and special purpose equipment purchases. Condition: The City did not have an adequate process to ensure that personnel responsible for grant compliance were aware of the need to obtain prior approval from the pass-through entity for capital expenditures related to the acquisition of general or special purpose equipment. As a result of our audit procedures, we noted the acquisition of a boiler that was charged to the grant where prior approval was not obtained from the pass-through entity. Questioned Costs: The City expended a total of $8.6 million in Education Stabilization Funds in 2022, of which $2.0 million was charged to a building maintenance and repairs account. Of the total charged to building maintenance and repairs, $100,000 was selected for testing and $45,825 was spent on the purchase of a new school boiler without prior approval from the pass-through entity. Context: The City used grant funds to purchase capital equipment without prior approval from the pass-through entity as required by federal and state guidelines. Effect: The City is not in compliance with grant requirements for the acquisition of capital equipment. Cause: Lack of appropriate controls over charging expenditures to the grant, maintaining documentation for costs charged, and lack of knowledge over grant compliance requirements. The internal control process should include the education of personnel on grant compliance requirements and procedures to ensure that grant activity is spent in accordance with federal and state requirements. Recommendation: Management should implement internal controls to ensure that administrators are aware of all grant compliance requirements including the need to obtain prior written approval from the pass-through entity for capital expenditures paid from the Education Stabilization Fund grants. Views of Responsible Officials and Planned Corrective Actions: Management will implement internal controls to ensure that administrators are aware of all grant compliance requirements including the need to obtain prior written approval from the pass-through entity for capital expenditures paid from the Education Stabilization Fund grants. Management plans to implement these procedures in fiscal 2023. If the Oversight Agency has questions regarding this plan, please call Michael Pfifferling, Assistant Superintendent of Finance and Operations at 978-374-3400. Sincerely yours, Michael Pfifferling Assistant Superintendent of Finance and Operations City of Haverhill
View Audit 52314 Questioned Costs: $1
Item 2022-001 ? Suspension & Debarment Contact person: Chellye Stump, Dean of Administrative Services Finding ? Adequate controls were not in place to provide for proper review of covered transactions for suspension and debarment. Covered transactions, over $25,000 paid with grant funding were not r...
Item 2022-001 ? Suspension & Debarment Contact person: Chellye Stump, Dean of Administrative Services Finding ? Adequate controls were not in place to provide for proper review of covered transactions for suspension and debarment. Covered transactions, over $25,000 paid with grant funding were not reviewed for suspension and debarment. Management Response ? The College will implement additional controls to ensure there is evidence of review of covered transactions over $25,000 for suspension and debarment prior to payment. Dean of Administrative Services will be responsible for the corrective action and anticipates completion of corrective action will be taken before 9/30/23. Effective date of completion: within the fiscal ending September 30, 2023
CORRECTIVE ACTION PLAN U.S. Department of Labor Employment and Training Administration: Missouri Chamber Foundation respectfully submits the following corrective action plan for the year ended September 30, 2022. Name and Address of independent accounting firm: Evers & Company, CPA?s, L.L.C., ...
CORRECTIVE ACTION PLAN U.S. Department of Labor Employment and Training Administration: Missouri Chamber Foundation respectfully submits the following corrective action plan for the year ended September 30, 2022. Name and Address of independent accounting firm: Evers & Company, CPA?s, L.L.C., 520 Dix Road, Jefferson City, Missouri, 65109 Audit Period: Fiscal Year Ended September 30, 2022 The findings from the September 30, 2022 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS ? FEDERAL AWARDS AUDIT Significant Deficiencies: 2022-003 Federal Funding Accountability and Transparency Act Reporting Recommendation: Missouri Chamber Foundation should register in the FFATA Subaward Reporting System and enter first-tier subawards to date greater than $25,000. Missouri Chamber Foundation should continue reporting subawards going forward each time a payment is made to remain in compliance. Response: Management concurs with the above recommendation and has registered in the FSRS System and entered all subaward payments to date and will make this a part of their process each time a payment is made. If the U.S. Department of Labor Employment and Training Administration has questions regarding this plan, please telephone Becky Wekenborg at 573-634-3511. Sincerely yours Becky Wekenborg Chief Financial Officer
MATERIAL WEAKNESS 2022-002 Action Taken: We concur with the recommendation, and we are currently taking action to negotiate the contract with our primary vendor, which provides curriculum, instruction, technology, and other services, Pearson Virtual Schools (Connections Education LLC). The new c...
MATERIAL WEAKNESS 2022-002 Action Taken: We concur with the recommendation, and we are currently taking action to negotiate the contract with our primary vendor, which provides curriculum, instruction, technology, and other services, Pearson Virtual Schools (Connections Education LLC). The new contract will be effective July 2023. TECCA administration and Board representatives have consulted with and continue to engage with legal counsel to ensure that the new contract details expenses aligned with agreed-upon terms. For the current year (FY23), we are continuing to request appropriate detail information from the vendor, Pearson Virtual Schools.
View Audit 45571 Questioned Costs: $1
FINDINGS - FINANCIAL STATEMENT AUDIT MATERIAL WEAKNESS 2022-001 - Internal control over financial reporting ? contract monitoring/compliance Action Taken: We concur with the recommendation, and we are currently taking action to negotiate the contract with our primary vendor, which provides curric...
FINDINGS - FINANCIAL STATEMENT AUDIT MATERIAL WEAKNESS 2022-001 - Internal control over financial reporting ? contract monitoring/compliance Action Taken: We concur with the recommendation, and we are currently taking action to negotiate the contract with our primary vendor, which provides curriculum, instruction, technology, and other services, Pearson Virtual Schools (Connections Education LLC). The new contract will be effective July 2023. TECCA administration and Board representatives have consulted with and continue to engage with legal counsel to ensure that the new contract details expenses aligned with agreed-upon terms. For the current year (FY23), we are continuing to request appropriate detail information from the vendor, Pearson Virtual Schools.
View Audit 45571 Questioned Costs: $1
Finding Number: 2022-002 Condition: The University initiated certain returns of Title IV funds after the required timing and, for other students, did not initiate certain returns. The University performed certain return calculations using inappropriate inputs. There were three errors that attributed...
Finding Number: 2022-002 Condition: The University initiated certain returns of Title IV funds after the required timing and, for other students, did not initiate certain returns. The University performed certain return calculations using inappropriate inputs. There were three errors that attributed to this finding: 1.Of the 60 students tested, there were 29 students with discrepancies between the date utilized in return to Title IV calculations and the date required to be utilized based on Federal regulations resulting in $5,990 in questioned costs. 2.Of the 60 students tested there were 18 students identified where the University had returned the funds untimely (45 days if student attended, 30 days if never attended). 3.Of the 60 students tested, there were 4 identified where no return to Title IV calculation was performed and therefore no return of funds until students were selected for testing for the audit resulting in $1,715 in questioned costs. Views of Responsible Officials and Corrective Action Plan - The University agrees with the finding. Planned Corrective Action: The procedures used to monitor, calculate, report, and return Title IV funds are being updated in the following ways to address the errors found and the cause of the errors: ?All procedures will be tied to FSA Handbook and regulatory guidance with references linked as appropriate. This will clarify the procedures being used for the return to Title IV process. ?Procedures will include updated regulations related to module courses. This will address the errors that were caused in misinterpreting these new regulations. ?Methodology for dates being used for end of semester and date of determination will be clearly documented for each semester along with the actual dates used. For non- modular courses, the end of semester date will be the Friday of final exam week. (This will be verified via guidance received from the ask regs function of NASFAA.) This will clarify the required deadlines for each semester. ?A new report generated from our Data Warehouse system will be used to reconcile all required returns for a given semester have occurred. This will address students who were also missed in the prior year process. Contact person responsible for corrective action: Brian Bell, Director Student Account Services Anticipated Completion Date: 10/31/2022
View Audit 53360 Questioned Costs: $1
Corrective Action Plan and Status of Prior Year Findings Management?s Corrective Action Plan: Individual(s) Responsible for Corrective Action Plan Tysha Dixon Director, Financial Reporting (215) 496-8168 Anticipated Completion Date Completed March 2023 Management?s Corrective Action Plan Manage...
Corrective Action Plan and Status of Prior Year Findings Management?s Corrective Action Plan: Individual(s) Responsible for Corrective Action Plan Tysha Dixon Director, Financial Reporting (215) 496-8168 Anticipated Completion Date Completed March 2023 Management?s Corrective Action Plan Management will continue to rely on its existing controls in place; however, noting that Management will closely monitor loans and loan disbursements where the funding source has changed closely to ensure that disbursements are in accordance with funding terms and approval limits. Management will continue to rely on its existing controls that are in place, including the ongoing communication with the City for any changes in transactions that require their approval. In the circumstances where management is pending a contract amendment from the City for loans requiring additional funding, management will determine if there are unrestricted funding sources to support the change in the approved amount of the loan until the amended contract is finalized. Questioned Program: CFDA #14.218 Community Development Block Grants (CDBG)
View Audit 52296 Questioned Costs: $1
Finding 2022-001 Lack of Internal Controls over Reporting Federal Agency: U.S. Department of Agriculture (passed through the State of Alaska) Federal Program: Child Nutrition Cluster Assistance Listing Number: 10.553/10.555/10.582 Award Year: 2022 Type of Finding Material weakness in internal co...
Finding 2022-001 Lack of Internal Controls over Reporting Federal Agency: U.S. Department of Agriculture (passed through the State of Alaska) Federal Program: Child Nutrition Cluster Assistance Listing Number: 10.553/10.555/10.582 Award Year: 2022 Type of Finding Material weakness in internal control over compliance and noncompliance. Name of Contact Person: Dennis Niedermeyer Corrective Action Plan: The District will make changes in personnel to provide for the accurate entry and reporting of meal counts into the state?s reporting and claims system. The NSBSD will hired an experienced and qualified food service administrator who will review, monitor and verify compliance with accurate reporting of meal counts. Proposed Completion Date: October 28, 2022.
The District is currently compliant with ESSA LEA MOE. The Texas Education Agency (TEA) will issue FY 2022 ESSA LEA MOE compliance determinations in Spring 2023. If it is determined that the District will not meet ESSA LEA MOE compliance, then the District understands that it has two potential av...
The District is currently compliant with ESSA LEA MOE. The Texas Education Agency (TEA) will issue FY 2022 ESSA LEA MOE compliance determinations in Spring 2023. If it is determined that the District will not meet ESSA LEA MOE compliance, then the District understands that it has two potential avenues of relief: 1. 5-year flexibility: If a District is non-compliant with FY 2022 ESSA LEA MOE (determinations that FFCR will issue in Spring 2023) but was compliant in FYs 2017, 2018, 2019, 2020, and 2021 then the District would not have its FY 2024 (the school year 2023?2024) ESSA allocations reduced. However, the District would still be considered non-compliant, and FY 2023 expenditures would be compared to FY 2021. 2. USDE waiver: A non-compliant District can submit a waiver request to the U.S. Department of Education (USDE), as TEA does not have the authority to waive ESSA LEA MOE. USDE considers each request on a case-by-case basis and has not shared the criteria they use to evaluate requests. If a District is non-compliant, even if they are eligible for the 5-year flexibility, FFCR staff contact the impacted Districts to advise them on the steps to submit a waiver request to USDE. The District met ESSA LEA MOE in fiscal years 2017, 2018, 2019, 2020, and 2021. Therefore, the District will utilize the allowable 5-year flexibility and submit the USDE waiver. The District will continue to run the state aid template every six weeks to monitor student enrollment and attendance to project revenue. The District will facilitate meetings with the program directors, Human Resources, and Payroll department. In addition, the District will monitor actual expenditures compared to the budget every six weeks to ensure that MOE tests are met by year-end. Contact person: Joel Garcia, Assistant Superintendent for Finance Proposed Completion Date: November 15. 2022 "See full CAP in report"
Finding: 2022-005 Name of Contact Person: Matt Farup, Superintendent Corrective Action: The District relies on the auditor to propose adjustments necessary to prepare the schedule of expenditures of federal awards including the related note disclosures. The District reviews the schedule of expe...
Finding: 2022-005 Name of Contact Person: Matt Farup, Superintendent Corrective Action: The District relies on the auditor to propose adjustments necessary to prepare the schedule of expenditures of federal awards including the related note disclosures. The District reviews the schedule of expenditures of federal awards and approves all adjustments. Proposed Completion Date: Immediately
CORRECTIVE ACTION PLAN 2 CFR ? 200.511(c) JUNE 30, 2022 Finding Number: 2022-001 Planned Corrective Action: In the summer of 2022, during a Monitoring Review performed by ODE of ESSER II funds, the District became aware of the specific requirements/documentation necessary for contracts let with fed...
CORRECTIVE ACTION PLAN 2 CFR ? 200.511(c) JUNE 30, 2022 Finding Number: 2022-001 Planned Corrective Action: In the summer of 2022, during a Monitoring Review performed by ODE of ESSER II funds, the District became aware of the specific requirements/documentation necessary for contracts let with federal ESSER funds. School Districts are usually not required to pay prevailing wages (state/local funds). The District had not used federal funds for construction in the past and was unaware of the requirement. Due to using an architect firm for the HVAC and window projects that were familiar with the requirements, the District had paid prevailing wage and had the required Davis-Bacon documentation for two of the three projects spent out of ESSER funds. The remaining project was in the amount of $46,870 for Locker Room Floor Renovations at the High School. The District was not aware of the Davis-Bacon requirements when the Business Manager originally contacted Kiefer in 2020 about the rubber flooring (no guidance was available). Due to COVID and delays in materials, the project was pushed back and this requirement was not reconsidered. District Administration has been made aware of the requirements using Federal ESSER funds going forward. In addition, the District policy (DJF) regarding purchasing procedures, that did not specifically include Davis-Bacon language, was updated to include Davis-Bacon requirements (Board approved 9/27/22). Further, the District intends to closely follow internal controls pertaining to federal grant management in order to prevent future issues as described in Finding 2022-001. Anticipated Completion Date: 09/27/22 Responsible Contact Person: Julie Taylor, Treasurer
2022-043 Oregon Health Authority Implement controls to ensure subrecipients are appropriately identified and monitored Federal Awarding Agency: U.S. Department of Health and Human Services Assistance Listing Number and Name: 93.958 Block Grants for Community Mental Health Services; 93.959 Block G...
2022-043 Oregon Health Authority Implement controls to ensure subrecipients are appropriately identified and monitored Federal Awarding Agency: U.S. Department of Health and Human Services Assistance Listing Number and Name: 93.958 Block Grants for Community Mental Health Services; 93.959 Block Grants for Prevention and Treatment of Substance Abuse Federal Award Numbers and Years: 93.958: 1B09SM082625, 2020; 1B09SM083823, 2021; 1B09SM086032, 2022; 93.959: 1B08TI083068, 2020; 6B08TI083472, 2021; 6B08TI084667, 2022 Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness; Material Noncompliance Prior Year Finding: N/A Questioned Costs: N/A Criteria: 2 CFR 200.331; 45 CFR 75.352(b); 45 CFR 75.352(d) Federal regulations require pass-through entities to determine if the recipients of disbursements of federal funds are subrecipients or contractors. The subrecipient and contractor determination will impact which federal compliance requirements recipients are subject to and how program expenditures are reported on the Schedule of Expenditures of Federal Awards (SEFA). For recipients meeting the definition of a subrecipient, federal regulations require pass-through entities to evaluate each subrecipient?s risk of noncompliance with federal statutes, regulations, and the terms and conditions of the subaward for the purpose of determining appropriate subrecipient monitoring activities. Monitoring activities should be completed based on the results of the subrecipient?s determined risk to ensure subawards are used appropriately. We reviewed the department?s classification of a sample of eight of 40 Mental Health Block Grant (MHBG) and 11 of 76 Substance Abuse Block Grant (SABG) recipients of federal funds. We judgmentally selected an additional 11 MHBG and 30 SABG recipients for review after our review of the initial sample of recipients identified inconsistencies in the classification of recipients. Based on the following inconsistencies identified in our review, it is unclear if the department correctly classified recipients as subrecipients or contractors and the related expenditures are reported accordingly. As a result, the SEFA may incorrectly report pass-through or direct expenditures. One recipient of MHBG funds and 13 recipients of SABG funds were classified as contractors by the department; however, other recipients providing the same services were classified as subrecipients. As they were identified as contractors, a SEFA correction of $1.4 million was made to report as direct expenditures rather than pass-through expenditures. Three recipients of MHBG funds and one recipient of SABG funds were classified as subrecipients by the department, but it was unclear if each met the definition of a subrecipient. One recipient of MHBG funds was classified as a contractor and appeared to meet the definition of a contractor; however, payments made to this recipient were recorded as pass-through expenditures. A SEFA correction of $329 thousand was made to report as direct expenditures rather than pass-through expenditures. One recipient of SABG funds was classified as neither contractor nor subrecipient. A SEFA correction of $215 thousand was made to report as direct expenditures rather than pass-through expenditures. We also inquired of the department?s risk assessment and monitoring activities for subrecipients. Based on our inquiries, the department does not have a formal implemented process for performing risk assessments to determine appropriate monitoring activities. Moreover, the department has not implemented a formal process to ensure subrecipients comply with federal regulations, terms and conditions of the subaward, and that subaward performance goals are achieved. If subrecipient monitoring is not performed and documented, subawards could be used for unauthorized purposes and performance goals not met. We recommend department management ensure recipients of federal funds are appropriately identified as subrecipients or contractors and the corresponding disbursement of federal funds are appropriately reported as direct or pass-through expenditures. We further recommend department management comply with subrecipient monitoring requirements, develop and implement internal controls to ensure risk assessments are performed and documented for each subrecipient, and monitoring activities are completed and documented according to risk assessment results. MANAGEMENT RESPONSE: We agree with this recommendation. HSD Contracts team has already implemented additional checklists to ensure subrecipients and vendors are identified and coded properly. We will be making the checklist automated through our grant management process and fully implemented by this fall. Anticipated Completion Date: November 30, 2023 Contact: Sarah Adelhart, Interim Manager
2022-042 Oregon Health Authority Ensure expenditures of federal funds are for allowed activities Federal Awarding Agency: U.S. Department of Health and Human Services Assistance Listing Number and Name: 93.958 Block Grants for Community Mental Health Services Federal Award Numbers and Years: ...
2022-042 Oregon Health Authority Ensure expenditures of federal funds are for allowed activities Federal Awarding Agency: U.S. Department of Health and Human Services Assistance Listing Number and Name: 93.958 Block Grants for Community Mental Health Services Federal Award Numbers and Years: 1B09SM083823, 2021 Compliance Requirement: Activities Allowed or Unallowed Type of Finding: Material Weakness; Material Noncompliance Prior Year Finding: N/A Questioned Costs: $525,272 (known) Criteria: 42 USC 300x-5(a)(3) Mental Health Block Grant (MHBG) funds may not be expended on the purchase, construction, or permanent improvement of any building or other facility other than minor remodeling. Substance Abuse and Mental Health Services Administration?s (SAMHSA) standard funding restriction guidance defines minor alterations and renovations as the lesser of 25% of the budget period or $150 thousand. Additionally, all minor alterations and renovations must be approved by SAMHSA. During our testing of MHBG subrecipient contracts entered into during state fiscal year 2022, we noted one contract included payment for the remodeling of an existing building owned by the subrecipient. A payment of $525,272 was processed in December 2021 for the remodeling expenses as specified in the contract's payment provisions. However, this amount exceeds SAMHSA's threshold for minor alterations and renovations and is not allowed under the MHBG. We recommend department management ensure controls are properly designed and implemented to record only allowable expenditures to the MHBG. We further recommend department management seek SAMHSA approval for minor alterations and renovations. MANAGEMENT RESPONSE: We agree with this recommendation. OHA intended to have an interagency agreement with ODHS to co-fund an improvement to a much-needed treatment facility for children. OHA submitted the payment per our agreement with the vendor with the expectation that ODHS would fund the non-SAMHSA allowable expenses. The vendor used the funds for minor safety related renovations as one would expect them to prioritize before programmatic costs. But unfortunately, the ODHS payment was never made to OHA which prevented any additional funds from being sent to the vendor. Then, pandemic constraints along with a lack of funding prevented the vendor from being able to finalize their plan in the initial time frame. OHA sought a legal review, and the recommendation was made to cleave the contract from ODHS and allow the vendor additional time to finish their work. Upon cleaving the contract, the elements that OHA knows to be unallowable for SAMHSA funding were left in the contract because the contractor had already performed the work. OHA is awaiting a final review of expenditure reports and will request SAMHSA approval if warranted or adjust funding codes as needed to align with SAMHSA allowable charges. Anticipated Completion Date: September 30, 2023 Contact: Sarah Adelhart, Interim Manager
View Audit 45093 Questioned Costs: $1
Finding 47807 (2022-048)
Significant Deficiency 2022
2022-048 Oregon Health Authority Improve review of federal performance progress reports Federal Awarding Agency: U.S. Department of Health and Human Services Assistance Listing Number and Name: 93.788 Opioid STR (Non-major program) Federal Award Numbers and Years: H79TI081716, 2020; H79TI083316, 2...
2022-048 Oregon Health Authority Improve review of federal performance progress reports Federal Awarding Agency: U.S. Department of Health and Human Services Assistance Listing Number and Name: 93.788 Opioid STR (Non-major program) Federal Award Numbers and Years: H79TI081716, 2020; H79TI083316, 2021 Compliance Requirement: Reporting Type of Finding: Significant Deficiency Prior Year Finding: 2019-020 Questioned Costs: N/A Criteria: 45 CFR 75.303(a); 45 CFR 75.342(b); Opioid STR Notice of Awards Federal regulations require performance progress reports (reports) be submitted semi-annually and include an overview of the goals and objectives accomplished during the funding period as stated in the grants? funding opportunity announcements. In addition, federal regulations require award grantees to establish and maintain effective internal control that provides reasonable assurance the award is managed in compliance with regulations and terms and conditions of the award. Effective controls may include review and approval of reports for completeness and accuracy. The Health Systems Division of the Oregon Health Authority (department) developed a tool to document post award monitoring in March of 2020, and for three years, the department has pointed to this tool as an action taken to ensure reports are complete and accurate. Although the department has yet to implement this tool, we found evidence of other internal controls that were partially implemented. Program now utilizes collaborative online software called Smartsheet which allows a contracted evaluator to compile subrecipient performance data the department can monitor and edit in real time. The department uses the Smartsheet as support for progress report data. We found some key data elements in the SOR2 year 2 progress report did not agree to support in Smartsheet. Program stated they reviewed a different spreadsheet supplied by the evaluator, not Smartsheet, which had totals agreeing to the submitted report. However, the department did not retain this additional spreadsheet. Without retaining the underlying support used for review, we are unable to assess the effectiveness of the department?s review of the report prior to submission. Program now requires manager review of reports prior to submission. We found evidence of manager review of the SOR2 year 2 progress report, however it was dated two days after the report was submitted. Ineffective controls could result in a misrepresentation of the grant?s performance. We recommend department management implement internal controls to ensure performance progress reports are complete and accurate prior to report submission. MANAGEMENT RESPONSE: We agree with this recommendation. To ensure performance progress reports are complete and accurate prior to report submission, the department will review current internal controls and plans to implement revised or new controls. The current process steps we are reviewing include: ? Sending the completed report via email to the program manager requesting they review the report for completeness and accuracy. ? Documenting approval via email confirmation that the report is complete and accurate prior to submission to federal funders. There is a need to revisit the internal control of having only managers designated to review the federal performance progress reports; we plan to discuss having the following individuals designated to conduct this review: principal investigator, grant coordinator, active partner, or manager. Anticipated Completion Date: December 31, 2023 Contact: Kelsey Smith-Payne, Opioid SOR Grants Project Director and Sarah Adelhart, Interim Manager
Finding 47806 (2022-047)
Significant Deficiency 2022
2022-047 Oregon Health Authority Implement controls to comply with subrecipient monitoring requirements Federal Awarding Agency: U.S. Department of Health and Human Services Assistance Listing Number and Name: 93.788 Opioid STR (Non-major program) Federal Award Numbers and Years: H79TI081716, 2020...
2022-047 Oregon Health Authority Implement controls to comply with subrecipient monitoring requirements Federal Awarding Agency: U.S. Department of Health and Human Services Assistance Listing Number and Name: 93.788 Opioid STR (Non-major program) Federal Award Numbers and Years: H79TI081716, 2020; H79TI083316, 2021 Compliance Requirement: Subrecipient Monitoring Type of Finding: Significant Deficiency; Noncompliance Prior Year Finding: 2019-019 Questioned Costs: N/A Criteria: 45 CFR 75.303(d); 45 CFR 75.351; 45 CFR 75.352(b) and (d) Federal regulations require that pass-through entities evaluate each subrecipient?s risk of noncompliance with federal statutes, regulations, and the terms and conditions of the subaward for the purpose of determining appropriate subrecipient monitoring activities. Monitoring activities should be completed based on the results of the subrecipient?s determined risk. Federal regulations also require grantees take prompt action when instances of noncompliance are identified in audit findings. The Health Systems Division of the Oregon Health Authority (department) developed a formal process for performing risk assessments to determine appropriate monitoring activities and developed a tool to document post award monitoring in March of 2020, and for three years, the department has pointed to these procedures as actions taken to partially correct the original 2019 finding. However, the department has yet to implement these or other procedures, and the Opioid program has no documented monitoring plan in place. Federal regulations require the department, as a pass-through entity, to determine if the recipients of disbursements of federal funds are subrecipients or contractors. The subrecipient and contractor determination will impact how program expenditures are reported on the Schedule of Expenditures of Federal Awards (SEFA). Out of 75 contracts with 59 subrecipients, we reviewed 15 contracts with 10 subrecipients and based on the contracts? listed deliverables, we determined five of them did not appear to meet the definition of a subrecipient. Department management could not support its subrecipient determinations and could not identify who made the decisions. As a result, the SEFA may incorrectly report $751,911 as pass-through funds instead of direct expenditures. We recommend department management comply with subrecipient monitoring requirements by implementing and documenting a procedure that evaluates each subrecipient?s risk of noncompliance for the purpose of determining and performing the appropriate monitoring for each subrecipient. We also recommend department management implement procedures to ensure federal subrecipient versus contractor determinations result in accurate reporting on the SEFA. MANAGEMENT RESPONSE: We agree with this recommendation. To comply with subrecipient monitoring requirements, the authority will implement our documented procedures. We will evaluate subrecipient?s risk of noncompliance for the purpose of determining and performing the appropriate monitoring for each subrecipient. We will ensure each subrecipient completes the grantee self-risk assessment survey we?ve created; once completed and submitted this survey will generate a monitoring guidance document based on if the grantee was determined low, moderate, or high risk. This risk assessment survey and guidance document will help inform appropriate subrecipient monitoring. The auto-generated word document is emailed to the identified OHA staff, stored in the software?s report, and can be accessed by staff on an OHA intranet page (OWL site). Additionally, the authority will ensure accurate federal subrecipient versus contractor determinations. We will evaluate and improve current determination procedures, develop a comprehensive checklist or guidance document based on improvement recommendations, determine who has the primary responsibility for subrecipient determinations, and provide training as needed. Anticipated Completion Date: December 31, 2023 Contact: Kelsey Smith-Payne, Opioid SOR Grants Project Director and Sarah Adelhart, Interim Manager
2022-032 Oregon Housing and Community Services Ensure subrecipient risk assessments and fiscal monitoring are performed and required grant information is communicated timely to subrecipients Federal Awarding Agency: U.S. Department of Health and Human Services, Administration for Children and Fami...
2022-032 Oregon Housing and Community Services Ensure subrecipient risk assessments and fiscal monitoring are performed and required grant information is communicated timely to subrecipients Federal Awarding Agency: U.S. Department of Health and Human Services, Administration for Children and Families Assistance Listing Number and Name: 93.568 Low-Income Home Energy Assistance Program 93.568 Low-Income Home Energy Assistance Program (COVID-19) Federal Award Numbers and Years: 2001ORE5C3, 2020 (COVID-19); 2102ORLIEA, 2021; 2102ORE5C6 , 2021 (COVID-19); 2202ORLIEA, 2022 Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness; Material Noncompliance Prior Year Finding: N/A Questioned Costs: N/A Criteria: 2 CFR ? 200.332(a) ? (h) Federal regulations require that pass-through entities evaluate each subrecipient?s risk of noncompliance with federal statutes, regulations, and the terms and conditions of the subaward to determine the extent and scope of subrecipient monitoring activities. Monitoring activities should be based on the results of a given subrecipient?s determined risk. Pass-through entities must also communicate certain award information to subrecipients as the time of the subaward. The department, as the pass-through entity, has long-established subrecipient monitoring procedures broken into two categories: program and fiscal monitoring. Program monitoring is performed by program-specific staff and focuses on requirements related to certain aspects of Activities Allowed and Client Eligibility. During FY2022, the department performed program monitoring activities as planned. Fiscal monitoring reviews compliance requirements related to Allowable Costs, Activities Allowed, and Earmarking. However, fiscal monitoring activities were limited due to staff turnover. As a result, limited fiscal monitoring procedures were performed for 5 of 17 subrecipients, and fiscal monitoring risk assessments were not performed for any of the 17 subrecipients. Without the performance of subrecipient risk assessments and adequate fiscal monitoring, the department risks distributing program funds to subrecipients out of compliance with federal program requirements. Additionally, we reviewed 5 randomly selected subrecipients to determine whether all required grant award information was communicated at the time of the subaward. For all of the 5 subrecipients reviewed, only some of the required information was communicated at the time of the award. The required information missing in the original grant agreements was communicated via agreement amendments several months later. Without timely communication of required grant information, subrecipients may not have all the information they need for the subaward they received. We recommend department management ensure subrecipient risk assessments are performed for all subrecipients and ensure required fiscal monitoring activities are performed based on the results of the risk assessments. We also recommend department management ensure all required award information is communicated to subrecipients at the time of the subawards. MANAGEMENT RESPONSE: We agree with this recommendation. OHCS lost critical fiscal monitoring staff and was unable to complete all risk assessments and fiscal monitoring due to this. OHCS is on track to complete fiscal monitoring and risk assessments for all subrecipients of LIHEAP in FY23. Additionally, OHCS has established vendor relationships to perform fiscal monitoring as a backup for when staff vacancies exist. Anticipated Completion Date: June 30, 2023 Contact: Dean Criscola, Controller or Michelle Cole, Assistant Director of Energy Services
2022-038 Department of Human Services Ensure work participation rate calculation uses verified and accurate data Federal Awarding Agency: U.S. Department of Health and Human Services Assistance Listing Number and Name: 93.558 Temporary Assistance for Needy Families Federal Award Numbers and Yea...
2022-038 Department of Human Services Ensure work participation rate calculation uses verified and accurate data Federal Awarding Agency: U.S. Department of Health and Human Services Assistance Listing Number and Name: 93.558 Temporary Assistance for Needy Families Federal Award Numbers and Years: 2021G996115, 2021; 2022G996115, 2022 Compliance Requirement: Special Test and Provisions Type of Finding: Material Weakness; Material Noncompliance Prior Year Finding: 2021-010, 2020-014, 2019-009 Questioned Costs: N/A Criteria: 45 CFR 261.61-62, 65 Federal regulations require each state maintain adequate documentation, verification, and internal control procedures to ensure the accuracy of data used in calculating work participation rates. Each state must have procedures to count and verify reported hours of work and must comply with its Work Verification Plan as approved by the U.S. Department of Health and Human Services (DHHS). Oregon?s Work Verification Plan outlines a system of controls for how reported hours will be verified and documented, and for reviews and monitoring procedures to identify errors. Work participation hours are reported via the quarterly Temporary Assistance for Needy Families (TANF) ACF-199 data reports and for benefits paid with designated state funds called maintenance of effort (MOE), the ACF-209 reports. As stated in a separate finding, titled `Ensure performance data reports are complete and accurate,? we determined the data reports are not complete or accurate. However, we found the department did correct a previous issue in which work participation hours on the ACF-199 report were left blank. Although reports were known to be incomplete, we reviewed the reporting periods October 1, 2021, through June 30, 2022, to test for compliance of the Work Verification Plan. We reviewed 20 randomly selected ACF-199 cases from a population of 16,249, and 20 randomly selected ACF-209 cases from a population of 146,324 of participating clients for verification of work activity participation. We found: Five of 20 ACF-199 cases with reported participation hours did not agree with hours in the system of record TRACS. 14 of 20 ACF-199 cases lacked support for the reported hours. 9 of 20 ACF-209 cases lacked support for the reported hours. These inaccurate or unverified hours were reported to DHHS for use in calculating the work participation rate. If the state fails to follow the approved Work Verification Plan, DHHS may penalize the state. We recommend TANF program management ensure the work participation rate is calculated appropriately using verified and accurate participation data in adherence to the department?s Work Verification Plan. We also recommend program management review the system of controls and identify where improvements are needed to ensure compliance with the work verification plan. MANAGEMENT RESPONSE: We agree with this recommendation. The Department will develop training specific to error trends based on Quality Control audits of the JOBS program, skill enhancement/best practices on collecting and documenting accurate attendance, and technical training on the Department?s attendance documentation system, TRACS. The training will be instructor led and offered at minimum on a quarterly basis. The Department will review and edit tools, resources, and attendance logs to ensure compliance with the work verification plan. Updates made will be communicated to staff working with families receiving TANF. The Department will also form a workgroup to review the attendance documentation and case management system known as the Transition Referral and Client Self-Sufficiency (TRACS) system. The workgroup will make recommendations to developer, which will include system enhancements and edits to improve the process for staff. Anticipated Completion Date: April 30, 2024 Contact: Annette Palmer, TANF Program Manager
Finding 47787 (2022-045)
Significant Deficiency 2022
2022-045 Oregon Health Authority Submit required FFATA reports Federal Awarding Agency: U.S. Department of Health and Human Services Assistance Listing Number and Name: 93.268 Immunization Cooperative Agreements; 93.323 Epidemiology and Laboratory Capacity for Infectious Diseases; 93.958 Bloc...
2022-045 Oregon Health Authority Submit required FFATA reports Federal Awarding Agency: U.S. Department of Health and Human Services Assistance Listing Number and Name: 93.268 Immunization Cooperative Agreements; 93.323 Epidemiology and Laboratory Capacity for Infectious Diseases; 93.958 Block Grants for Community Mental Health Services; 93.959 Block Grants for Prevention and Treatment of Substance Abuse Federal Award Numbers and Years: 93.268: 5 NH23IP922626; 6 NH23IP922626; 93.323: 6 NU50CK000541; 93.958: 1B09SM083823, 2021; 93.959: 6B08TI083472, 2021; 6B08TI084667, 2022 Compliance Requirement: Reporting Type of Finding: Significant Deficiency; Noncompliance Prior Year Finding: N/A Questioned Costs: N/A Criteria: 2 CFR 170 Appendix A; 2 CFR 200.303 Federal regulations require recipients of federal awards to report certain subaward information in the FFATA Subaward Reporting System (FSRS) for subawards meeting the criteria for reporting. Reports must be submitted no later than the end of the month following the month in which the subawards were made. Federal regulations also require recipients of federal awards establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. We identified and reviewed the reporting status of all the department?s subawards subject to FFATA reporting during the audit period. We determined: Five of 30 Mental Health Block Grant (MHBG) subawards were not reported, totaling $4.2 million in obligations. 12 of 65 Substance Abuse Block Grant (SABG) subawards were not reported, totaling $6.2 million in obligations. Four of 37 Epidemiology and Laboratory Capacity (ELC) subawards were not reported, totaling almost $55.5 million in obligations. Five of 39 Immunization Cooperative Agreements subawards were not reported, totaling $6.3 million in obligations. Of the total not reported, one SABG, one ELC, and two Immunization subawards were not reported in the FSRS due to oversights in the department?s reporting process. The remaining unreported subawards resulted from the department?s suspension of FFATA reporting stemming from the federal replacement of the DUNS number with the Unique Entity Identifier (UEI) in May 2022. The department did not have UEI numbers for all subrecipients at the time of the replacement which prevented the department from submitting accurate reports. FFATA reporting was suspended through the end of state fiscal year 2022 and into the following state fiscal year. Although the department suspended FFATA reporting in the FSRS, a tracking spreadsheet was maintained that included all subaward award information needed for reporting once reporting is resumed. We recommend department management resume FFATA reporting as soon as feasible and ensure all necessary subawards are reported. We further recommend department management implement controls to ensure all subawards are appropriately tracked and reported. MANAGEMENT RESPONSE: We agree with this recommendation. On April 4, 2022, the federal government made a switch in the identifying information required for a subrecipient, changing from the previously used DUNS to a newly assigned Unique Entity Identifier (UEI). ODHS/OHA was not made aware of the upcoming federal switch until late March 2022. OHA?s Office of Contracts & Procurement (OC&P) is working directly with Program Contract Administrator?s to request the missing UEIs. As the data comes in from Program it is being validated for accuracy and updated in the appropriate systems, so when all missing UEIs from a given FAIN?s report month are collected, all NTE changes can be made immediately. OC&P is confident all FFATA reporting related to this audit will be submitted by July 31, 2023. Anticipated Completion Date: July 31, 2023 Contact: Brenda Brown, Procurement Manager
Finding 2022 - 101 ? Improve Home Inspection Process (Significant Deficiency) FAL Number: 14.239 Program Title: HOME Investment Partnership Program Condition and Context: LCSA did not properly document the procedures taken to inspect the homes maintained through their HOME program. Recommendati...
Finding 2022 - 101 ? Improve Home Inspection Process (Significant Deficiency) FAL Number: 14.239 Program Title: HOME Investment Partnership Program Condition and Context: LCSA did not properly document the procedures taken to inspect the homes maintained through their HOME program. Recommendation: The auditors recommend maintaining a list or memoranda including the items inspected at each home during routine inspections for documentation purposes. Contact Name: Rebekah Friend, Executive Director Corrective Action Planned: Management is creating a procedure and form to document the tracking of homes maintained. Anticipated Completion Date: Immediately
FA 2022-002 Improve Controls over Equipment Compliance Requirement: Equipment and Real Property Management Internal Control Impact: Material Weakness Compliance Impact: Material Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education...
FA 2022-002 Improve Controls over Equipment Compliance Requirement: Equipment and Real Property Management Internal Control Impact: Material Weakness Compliance Impact: Material Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education Assistance Listing Number and Title: COVID-19 - 84.425D - Elementary and Secondary School Emergency Relief Fund COVID-19 - 84.425U - American Rescue Plan Elementary and Secondary School Emergency Relief Fund COVID-19 - 84.425W - American Rescue Plan Elementary and Secondary School Emergency Relief Fund - Homeless Children and Youth Federal Award Number: S425D210012 (Year: 2021), S425U2120012 (Year: 2021) S425W210011 (Year: 2021) Questioned Costs: None identified Description: The policies and procedures of the School District were insufficient to provide adequate internal controls over equipment and real property management as it relates to the Elementary and Secondary School Emergency Relief Fund program. Corrective Action Plans: We concur with this finding. A new Federal Programs Director began work during the period of the audit. The change in personnel coupled with the influx of new grants, large awards of grant dollars and new regulations and requirements contributed to the finding. To correct, staff meet and attend training on all federal grant funds received to ensure compliance on all reporting requirements. A federal inventory sheet has been developed that includes all applicable components for current assets and will be used for physical inventory purposes. Tattnall County School District has received an ESSER III- ARP-REI Technology Grant; an approved purchase in this grant is an inventory system. Systems are currently being evaluated and reviewed for purchase. It is anticipated that this system will be fully implemented during fiscal year 2024. Estimated Completion Date: June 30, 2023 for federal inventory asset sheet and June 30, 2024 for new inventory software system. Contact Person: Debbie Driggers Powell Telephone: (912) 557-3327 Email: dpowell@tattnall.k12.ga.us
FA 2022-001 Strengthen Controls over Expenditures Compliance Requirement: Activities Allowed or Unallowed Allowable Costs/Cost Principle Period of Performance Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of ...
FA 2022-001 Strengthen Controls over Expenditures Compliance Requirement: Activities Allowed or Unallowed Allowable Costs/Cost Principle Period of Performance Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education Assistance Listing Number and Title: COVID-19 - 84.425D - Elementary and Secondary School Emergency Relief Fund COVID-19 - 84.425U - American Rescue Plan Elementary and Secondary School Emergency Relief Fund COVID-19 - 84.425W - American Rescue Plan Elementary and Secondary School Emergency Relief Fund - Homeless Children and Youth Federal Award Number: S425D210012 (Year: 2021), S425U2120012 (Year: 2021) S425W210011 (Year: 2021) Questioned Costs: $108,220 Description: A review of expenditures charged to the Elementary and Secondary School Emergency Relief Fund program revealed that the School District's internal control procedures were not operating appropriately to ensure that expenditures were allowable for the program. Corrective Action Plans: We concur with this finding. A new Federal Programs Director began work during the period of the audit. The change in personnel coupled with the influx of new grants, large awards of grant dollars and new regulations and requirements contributed to the finding. To correct, staff meet and attend training on all federal grant funds received to ensure compliance on all reporting requirements. The federal programs director enters and monitors all grant budgets into the consolidated application and supplies all prior approval forms for those items for which it is required. The federal programs director also approves all purchase requisitions using federal funds before items can be purchased; she also reviews and approves request for reimbursement of federal funds before those funds are drawn down. (Superintendent approves as well.) Estimated Completion Date: June 30, 2023 Contact Person: Debbie Driggers Powell Telephone: (912) 557-3327 Email: dpowell@tattnall.k12.ga.us
View Audit 40842 Questioned Costs: $1
FINDING:2022-004 Contact Person Responsible for Corrective Action: Brenda Layne, Food Service Director Contact Phone Number: 765-289-7323 Views of Responsible Official: We concur with the findings Description of Corrective Action Plan: The Corporation Treasure and I discussed this matter and we will...
FINDING:2022-004 Contact Person Responsible for Corrective Action: Brenda Layne, Food Service Director Contact Phone Number: 765-289-7323 Views of Responsible Official: We concur with the findings Description of Corrective Action Plan: The Corporation Treasure and I discussed this matter and we will be more mindful in the future to get the reimbursement claims receipted in a timely manner. Anticipated Completion Date: February 2023
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