Corrective Action Plans

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Recommendation: We recommend that when the District decides to utilize cooperative purchasing programs and use federal funds for those purchases that a review of compliance with the procurement policy occurs. The District should then document its process and how it complies with the procurement stan...
Recommendation: We recommend that when the District decides to utilize cooperative purchasing programs and use federal funds for those purchases that a review of compliance with the procurement policy occurs. The District should then document its process and how it complies with the procurement standards. View of Responsible Officials: The District has reviewed the applicable Uniform Guidance from the Federal Office of Management and Budget and has developed administrative procedures to aid with ensuring that all procurements financed with federal funding fully comply with Uniform Grant Guidance Federal acquisition thresholds and requirements. Effective the 22-23 fiscal year forward the District will fully deploy the referenced administrative procedures to all applicable District stakeholders and monitor all such procurements for compliance purposes.
Finding Number: 2022-001 Planned Corrective Action: The School District has already implemented policies and procedures to ensure timely updating and has documented the remedies taken for the items noted as noncompliant in the audit. Anticipated Completion Date: January 31, 2023 Responsible Contact...
Finding Number: 2022-001 Planned Corrective Action: The School District has already implemented policies and procedures to ensure timely updating and has documented the remedies taken for the items noted as noncompliant in the audit. Anticipated Completion Date: January 31, 2023 Responsible Contact Person: Donna Solano, Financial Aid Coordinator
FINDING 2022-009: Prevailing Wage Rate Internal Control and Compliance Response: Going forward all construction using federal funds in excess of $2000 will have a contract stating the prevailing wage rate clause and submission of weekly certified payrolls.
FINDING 2022-009: Prevailing Wage Rate Internal Control and Compliance Response: Going forward all construction using federal funds in excess of $2000 will have a contract stating the prevailing wage rate clause and submission of weekly certified payrolls.
Condition: The City did not submit the necessary FFATA reports for two of its subrecipients. Corrective Action Plan: Due to recent HUD monitoring, one subaward agreement (Bloomington Housing Authority) will begin to be awarded directly to the subrecipient in future years. The City now has a fully...
Condition: The City did not submit the necessary FFATA reports for two of its subrecipients. Corrective Action Plan: Due to recent HUD monitoring, one subaward agreement (Bloomington Housing Authority) will begin to be awarded directly to the subrecipient in future years. The City now has a fully-staffed Community Development department with positions supporting the CDBG grant. The City has added FFATA reporting as a part of its subaward process. The City will also seek out technical assistance and training to ensure successful reporting going forward. Anticipated Date of Completion: November 2022 Contact Person: Patti-Lynn Silva, Finance Director
Finding 45178 (2022-007)
Significant Deficiency 2022
2022-007 Gramm-Leach-Bliley Act Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance; Other Matters Recommendation: We recommend that the College engage a third party or perform the risk assessment for the three areas required by the...
2022-007 Gramm-Leach-Bliley Act Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance; Other Matters Recommendation: We recommend that the College engage a third party or perform the risk assessment for the three areas required by the Gramm-Leach-Bliley Act and ensure that there are documented safeguards for identified risks. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Tabor College is currently meeting with companies who provide services to assist with meeting the requirements of the Gramm-Leach-Bliley Act. Name(s) of the contact person(s) responsible for corrective action: Cathy Castle, Vice President for Business and Finance Planned completion date for corrective action plan: April 2023 and ongoing. If the Department of Education has questions regarding this plan, please call Cathy Castle at 620-947-3121 x 1056.
FINDING 2022-004 Contact Person Responsible for Corrective Action: Shawn Spindler, Business Manager/Treasurer Contact Phone Number: 812.926.2090 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: We will ensure that any future private school expenses ar...
FINDING 2022-004 Contact Person Responsible for Corrective Action: Shawn Spindler, Business Manager/Treasurer Contact Phone Number: 812.926.2090 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: We will ensure that any future private school expenses are incurred and paid by the district instead of reimbursing the private schools their expenses. This will be reviewed by the Director of Curriculum to ensure compliance. Anticipated Completion Date: March 2023
The District will enforce, not only that the contract includes prevailing wages are to be paid, but that certified payroll reports from contractors are provided to the District. These payroll reports will be reviewed, and retained before payment will be made to the contractor. The control and proc...
The District will enforce, not only that the contract includes prevailing wages are to be paid, but that certified payroll reports from contractors are provided to the District. These payroll reports will be reviewed, and retained before payment will be made to the contractor. The control and procedure will be implemented immediately by completing a check list. To comply with the prevailing wage law this checklist will be completed before payment is issued to the contractor.
U.S. Department of Health and Human Services 2022-002 Provider Relief Fund ? Assistance Listing No. 93.498 Recommendation: Management should implement procedures to ensure the lost revenue is calculated and reported using an option that is appropriate for any future periods and revise the lost reven...
U.S. Department of Health and Human Services 2022-002 Provider Relief Fund ? Assistance Listing No. 93.498 Recommendation: Management should implement procedures to ensure the lost revenue is calculated and reported using an option that is appropriate for any future periods and revise the lost revenue amounts on any subsequent filings, if applicable. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management will design and implement procedures of review ensuring the appropriate option is selected for how lost revenue is reported for any future reporting periods and on any subsequent filings. Name(s) of the contact person(s) responsible for corrective action: Beau Brown, CFO Planned completion date for corrective action plan: September 30, 2023.
Views of Responsible Officials ChesPenn Health Services, Inc. will continue to monitor the process of maintaining paper copies of all sliding fee scale patient files in each office as a back-up to potential electronic system failures for scanning patient's records. In addition, ChesPenn Health Servi...
Views of Responsible Officials ChesPenn Health Services, Inc. will continue to monitor the process of maintaining paper copies of all sliding fee scale patient files in each office as a back-up to potential electronic system failures for scanning patient's records. In addition, ChesPenn Health Services, Inc.'s Compliance Officer and Chief Operating Officer will conduct random monthly audits of sliding fee applications at all three locations. Results from the audits will be presented to the site Office Manager who will then conduct staff training sessions with the Patient Service Representatives. The audit and subsequent training will include a review of the following parameters for proper documentation and sliding fee scale determination: Identification: o State issued driver's license o State issued or state recognized identification card o School identification o Government issued passport o If married, a copy of spouse's identification as well Social Security Cards: o For the applicant o For the spouse, if married o For all dependents 18 years of age or younger o For a college student, up to 23 years of age with college documentation o If a social security card is not available for a child, a birth certificate will be accepted Paystubs: o One recent pay stub, if married a copy from spouse as well o Benefits statement from social security, if married from husband and wife o Awards letter for unemployment, if married from husband and wife o Self-employed - Last year's income tax statement o If paid in cash, a letter from the employer, on company letter head that states the hourly rate and hours worked o If the letter is handwritten, the letter must be notarized o When an individual has no source of income and has no insurance, they are required to fill out the information on the front and the back of the sliding fee scale form. Photo identification and social security cards are required Responsible Party: Susan Harris-McGovern, President/CEO Susan.harris@chespenn.org, 610-485-3800 Estimated Time of Completion: March 31, 2023
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 Federal Awarding Agency: U.S. Department of Education Pass-Thr...
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 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 - Homless Children and Youth Federal Award Number: S425D200012 (Year: 2020), S425U2120012 (Year: 2021) S425W210011 (Year: 2021) Questioner Costs: $30,180 Prior Year Finding: None Description: The polices and procedures of the School District were insufficient to provide and adequate internal controls over expenditures as it relates to the Elementary and Secondary School Emergency Relief Fund program. Corrective Action Plans: Revise Federal Programs Handbook to enhance internal controls in the area of contracts. Provide addendums to contracted services to provide for retention bonuses to contracted staff. Estimated Completion Date: June 30, 2023 Contact Person: Seth Taylor, Chief Financial Officer Telephone: 229-723-4337 Email: staylor@early.k12.ga.us
View Audit 39876 Questioned Costs: $1
CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Elma School District No. 68 September 1, 2021 through August 31, 2022 This schedule presents the corrective action the District is planning to take for findings included in this report in accordance with Title 2 U.S. Code of Federa...
CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Elma School District No. 68 September 1, 2021 through August 31, 2022 This schedule presents the corrective action the District is planning to take for findings included in this report in accordance with Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Finding ref number: 2022-001 Finding caption: The District did not have adequate internal controls for ensuring compliance with allowable activities and costs, procurement, and restricted purpose requirements Name, address, and telephone of District contact person: Lisa Arnold 1235 Montesano Elma Road Elma, WA, 98541 (360) 482-2822 Corrective action the auditee plans to take in response to the finding: The district concurs with the auditor. The district will ensure that processes are followed by all purchases going through the district office for approval before purchase. Purchases are now through an online system InformedK12 to help ensure procedures are followed. The district would like to note that this finding is because the district did not go out to bid for the student Chromebooks. The bid step was overlooked due to the quick turnaround to purchase devices to make sure all students had Chromebooks for the pandemic. Anticipated date to complete the corrective action: 01/2023
View Audit 46960 Questioned Costs: $1
Finding 44952 (2022-002)
Significant Deficiency 2022
CORRECTIVE ACTION PLAN Finding 2022-002: Subrecipient Monitoring ...
CORRECTIVE ACTION PLAN Finding 2022-002: Subrecipient Monitoring Public Allies has developed a Risk Assessment tool that will be implemented with subgrantees ("local sites") for Program Year '23. The tool?s development was driven by noted best practices and guidance shared with AmeriCorps grantees and Public Allies? prior monitoring findings. The tool includes a self-assessment by local sites and the results will drive the level of monitoring and training and assistance each site receives. Public Allies will also be piloting a new Progress Report, that will provide an at-a-glance assessment of site performance based upon metrics determined in collaboration with subgrantees. The programmatic monitoring process will be led by a dedicated monitoring team that is supported by staff that provide direct programmatic training and technical assistance to sites. For fiscal monitoring, Public Allies has shifted from outsourcing all accounting and financial management to bringing all accounting in-house. As described above, this staff now includes a Finance Director, a Staff Accountant and Senior Accountant. This shift was the result of an evaluation of internal operations and financial management systems. The addition of multiple full-time accounting staff has improved our capacity to monitor and manage subgrantees, effectively track and manage process improvements, ensure fiscal-related grants compliance, and efficiently manage our federal grant funding requests and reports. A fiscal Grants Manager was hired to review subgrantee financial reporting, provide technical assistance, and implement financial monitoring of subrecipients. Finally, a desk audit will be implemented in FY23. The number of files to be reviewed for each site will be determined based upon risk factors assessed, including: AmeriCorps Monitoring Common Findings, staff retention data, prevalence of turnover in AmeriCorps members, and length of time since the site underwent an audit. Requested programmatic and fiscal documents will include: ? Ally/Member Leadership Journal Position Descriptions ? Time Logs ? Ally/Member Evaluations ? Exit Documentation ? Ally/Member Payroll Register, and ? Operating Partner Due Diligence ? Annual Financial Statement ? Separation of Duties Survey ? Internal Controls Questionnaire The Public Allies Network will be notified of the Desk-Based Audit by May 26th and the desk audit will conclude by fiscal year end. Findings of the audit, in the form of a Monitoring Report will be shared with subrecipients, including required follow-up necessary to remediate compliance findings. Results of the desk audit will be used to determine future training needs, policy recommendations, and future monitoring Person Responsible: Najah Woods, Apprenticeship Program Grants Manager Implementation Date: August 31, 2023
Finding 44948 (2022-002)
Significant Deficiency 2022
Finding 2022-002 Condition The College did not accurately report the amount of institutional HEERF II and III and SIP spent in their quarterly reports ending June 30, 2021, December 31, 2021 and March 31, 2022. The College did ultimately correct these reports to reflect accurate information. Corr...
Finding 2022-002 Condition The College did not accurately report the amount of institutional HEERF II and III and SIP spent in their quarterly reports ending June 30, 2021, December 31, 2021 and March 31, 2022. The College did ultimately correct these reports to reflect accurate information. Corrective Action Plan The College has corrected the misstated reports. To help ensure this does not occur again, the College will appropriately assign all necessary data collection responsibilities and ensure that corresponding submission deadline are clearly communicated. The Assistant Controller will be assigned the responsibility to coordinate the collection of necessary data and the compilation of the report. The Controller will then review the draft report and make timely submission. Name(s) of Contact Person(s) Responsible for Corrective Action: Jeffrey Strader ? Vice President, Finance and Strategic Partnerships Anticipated Completion Date: Reports have been corrected as of February 2023 and secondary review will be performed in quarters going forward. Procedures will be incorporated into the College?s work processes during Fiscal Year 2022-2023
Finding 2022-001: Enrollment Reporting Federal Program - Federal Direct Student Loans Federal Agency - U.S. Department of Education Pass-Through Entity - Not Applicable CFDA Number - 84.268 Federal Award Year -...
Finding 2022-001: Enrollment Reporting Federal Program - Federal Direct Student Loans Federal Agency - U.S. Department of Education Pass-Through Entity - Not Applicable CFDA Number - 84.268 Federal Award Year - June 30, 2022 Condition/Context: The change in student status for 1 out of 25 students tested was not reported to the National Student Loan Data System (NSLDS) within 30 days or included in a response to a roster file within 60 days. The student withdrew in September 2021 but was not reported until December 2021. Views of Responsible Officials and Planned Corrective Actions: The College agrees with the finding. The Office of Academic Success now notifies all pertinent offices of any student withdrawals in a timely manner. In addition, if a student withdraws with more than a week between their withdrawal and the last day of attendance, their change in status notification is processed immediately in NSLDS by the Registrar?s office. The Registrar also performs a monthly review of all status changes to verify all enrollment status changes are updated accurately and reported to NSLDS within the required timeframe. Names of Contact Persons Responsible for Corrective Action: Barbara Schmitt, Director of Financial Aid and Dan Cebrick, Registrar Anticipated Completion Date: Changes were effective for Fall 2022 semester.
Finding 44881 (2022-001)
Significant Deficiency 2022
Alight
MN
Views of Responsible Officials and Planned Corrective Actions: Executive leadership at Alight determined that the investigation uncovered an extensive breakdown in values and culture within the Alight Uganda program. At this time, Alight has taken the following actions: ? Immediate action was taken ...
Views of Responsible Officials and Planned Corrective Actions: Executive leadership at Alight determined that the investigation uncovered an extensive breakdown in values and culture within the Alight Uganda program. At this time, Alight has taken the following actions: ? Immediate action was taken to terminate employment with all staff involved in the malfeasance. ? The Uganda leadership team is in the process of being rebuilt. An interim Country Director was appointed and vacancies recruited and hired. ? Fraud training was provided and attended by almost 60 staff across Alight including Ugandan staff. ? Alight?s anonymous global reporting portal was upgraded with communication and training provided to all Alight country programs. ? Alight?s executive leaders conducted policy, procedures and fraud notification training with the Uganda staff including how to report suspected incidence of fraud. ? Executive leaders and Uganda leaders are routinely traveling to field offices to review operations and provide staff the opportunity to report issues. Executive leadership at Alight believes these actions have re-established appropriate values, culture and processes within Uganda and reinforced their importance across Alight countries. Additional fraud training and reporting will be scheduled in fiscal year 2023.
Finding 2022-001: For the year ended December 31, 2021, the Corporation did not submit the Data Collection Form to the Federal Audit Clearinghouse in the time period required by Uniform Guidance. Comments on the Finding and Each Recommendation: The Corporation should submit the Data Collection Form...
Finding 2022-001: For the year ended December 31, 2021, the Corporation did not submit the Data Collection Form to the Federal Audit Clearinghouse in the time period required by Uniform Guidance. Comments on the Finding and Each Recommendation: The Corporation should submit the Data Collection Form to the Federal Audit Clearinghouse within the required time period. Management agrees to the finding and recommendation. Action(s) Taken or Planned on the Finding: The Data Collection Form was submitted to the Federal Audit Clearinghouse on October 11, 2022, no further action is required.
Finding 44823 (2022-001)
Significant Deficiency 2022
Finding Reference Number: SA2022-001 Failure to Maintain Proper Documentation (Significant Deficiency) Assistance Listing Number: 97.036 Assistance Listing Title: Disaster Grants ? Public Assistance Named of Federal Agency: U.S. Department of Homeland Security Federal Award Identification Number: F...
Finding Reference Number: SA2022-001 Failure to Maintain Proper Documentation (Significant Deficiency) Assistance Listing Number: 97.036 Assistance Listing Title: Disaster Grants ? Public Assistance Named of Federal Agency: U.S. Department of Homeland Security Federal Award Identification Number: FEMA-4308-DR-CA Name of pass-through Entity: California Office of Emergency Services Name(s) of the contact person: Nickie Mastay, Daniel Chavarria Corrective Action Plan: Since noting the deficiencies, the Public Works Department has successfully hired a new Public Works Director, a new Deputy Public Works Director, project managers, and support staff to improve and adhere to necessary grant reporting and reimbursement with proper supporting documentation. Management has assigned a team to review and track all grants monthly, including the Via Verdi project. All team members will be trained on grant reporting and drawdown, and reminders set in their calendars to ensure these tasks are completed in a timely manner. Anticipated Completion Date: Fiscal Year 23-24
Finding 44789 (2022-066)
Significant Deficiency 2022
2022-066 Oregon Department of Education Improve subrecipient monitoring procedures Federal Awarding Agency: U.S. Department of Education Assistance Listing Number and Name: 84.425C, 84.425D, 84.425U & 84.425W Education Stabilization Fund (COVID-19) Federal Award Numbers and Years: S425C200048; 20...
2022-066 Oregon Department of Education Improve subrecipient monitoring procedures Federal Awarding Agency: U.S. Department of Education Assistance Listing Number and Name: 84.425C, 84.425D, 84.425U & 84.425W Education Stabilization Fund (COVID-19) Federal Award Numbers and Years: S425C200048; 2020 (COVID-19), S425D200049; 2020 (COVID-19), S425C210048; 2021 (COVID-19), S425D210049; 2021 (COVID-19), S425U210049; 2021 (COVID-19), S425W210038; 2021 (COVID-19) Compliance Requirement: Subrecipient Monitoring Type of Finding: Significant Deficiency; Noncompliance Prior Year Finding: N/A Questioned Costs: N/A Criteria: 2 CFR 200.332 Federal regulations require the department to evaluate each subrecipients risk of noncompliance with Federal statues, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate monitoring to perform. In addition, the department should monitor the activities of the subrecipients receiving funds to ensure the subaward is used for authorized purposes, is in compliance with Federal statutes, regulations, and the terms and condition of the subaward; and the subaward performance goals are achieved. Depending on the department risk assessment, which was not performed, the department could perform various monitoring tools to ensure accountability and compliance. As of June 30, 2022, the department was still in the process of drafting and implementing a plan to monitor the funds. The department had not completed a risk assessment process of the local educational agencies (LEA) for these funds and stated it planned to begin some desk or on-site monitoring in Spring 2023. $522 million in funds have been passed through to subrecipients as of June 30, 2022. The department required LEA?s to submit applications to receive funds and sign agreements that outlined all federal requirements. In addition, the department also required the LEA?s to complete a reimbursement request form that contains general ledger detail but no additional support is provided. According to the department, it follows-up with a LEA if funds appear to be ineligible or other questions are raised. Finally, although LEAs programs may have had a single audit the department could not provide a list of which LEAs had audits and whether there were findings or not. In fiscal year 2021, the department was also working to finalize its risk assessment and monitoring plans. However, the department experienced staff turnover which delayed its plans. Insufficient subrecipient monitoring increases the risk of not timely identifying subrecipients that are not administering federal awards in compliance with federal requirements. We recommend department management complete its risk assessment, consider the results of LEAs single audits and perform desk or on-site monitoring as necessary. MANAGEMENT RESPONSE: We agree with this recommendation. ODE acknowledges that it did not implement pandemic funding related desk audit and site monitoring procedures in FY 21. FY 21 saw the COVID-19 Delta and Omicron variants continue to infect school staff and students so on-site visits were not feasible. The pandemic also forced districts to dedicate administrator time and attention to student health and safety and adjusting to the ever-changing health environment, guidance and requirements. In anticipation of such challenges during the pandemic, ODE set up the ESSER reimbursements to districts allows for much more detailed reporting when requesting reimbursement to allow ODE to track how districts were spending their funds. While not traditional monitoring, it was an effective, efficient, and creative way to ensure ODE spending oversight in unprecedented times. As discussed with Secretary of State auditors, ODE finalized and implemented a risk assessment tool in the spring of 2023 and has completed an initial set of ten monitoring desk reviews with districts. Anticipated Completion Date: June 30, 2024 Contact: Cynthia Stinson, Senior Manager of Federal Investments & Pandemic, Renewal Effort, OTLA
2022-031 Oregon Housing and Community Services Comply with subrecipient monitoring requirements Federal Awarding Agency: U.S. Department of the Treasury Assistance Listing Number and Name: 21.027 Coronavirus State and Local Fiscal Recovery Fund (COVID-19) Federal Award Numbers and Years: OMB Appro...
2022-031 Oregon Housing and Community Services Comply with subrecipient monitoring requirements Federal Awarding Agency: U.S. Department of the Treasury Assistance Listing Number and Name: 21.027 Coronavirus State and Local Fiscal Recovery Fund (COVID-19) Federal Award Numbers and Years: OMB Approved No. 1505-0271, 2022 (COVID-19) Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness, Material Noncompliance Prior Year Finding: N/A Questioned Costs: N/A Criteria: 45 CFR 75.351; 45 CFR 75.352(b); 45 CFR 75.352(d) When recipients of Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) provide award funds to an entity to carry out objectives of program on behalf of the CSLFRF recipient, the entities receiving such funding are subrecipients. The recipient has the responsibility to monitor expenditures and activities subrecipients. Nearly all the department?s CSLFRF expenditures are comprised of payments to a private organization. Per the contract, the organization was hired to conduct eligibility assessments for the Emergency Rental Assistance program and be responsible to ensure only eligible applicants receive rental and utility assistance payments. CLSFRF funds were used for emergency rental assistance; therefore, the organization is carrying out a program on behalf of the department. The department then has the responsibility to monitor the expenditures and activities of the organization. The department incorrectly identified the organization as a vendor rather than a subrecipient during the contracting process. Per the guidance above, this was not an appropriate determination because the organization carries out eligibility determinations of the program. Management acknowledged no monitoring of the organization was performed during the audit period; therefore, there are no related key controls for the fiscal year ended June 30, 2022. Although program staff maintain a close working relationship with the organization, these interactions are not formalized and documented for the purpose of subrecipient monitoring. If subrecipient monitoring is not performed and documented, subawards could be used for unauthorized purposes and performance goals not met. We recommend department management reassess the department?s contracting process to appropriately identify whether an organization is a vendor or a subrecipient. If a subrecipient, we recommend the department comply with subrecipient monitoring requirements, including developing related internal controls and processes to monitor the expenditures and activities of the organization. MANAGEMENT RESPONSE: We agree with this recommendation. OHCS performed appropriate due diligence in determining whether organization was a subrecipient or vendor. Internally OHCS identified the issue of how to classify the organization and used all resources available to make the determination. The result of the due diligence and discussion was that OHCS determined the organization should be classified as a vendor, not a subrecipient. OHCS will review and strengthen the current process for determination. Anticipated Completion Date: December 31, 2023 Contact: Sandra Flickinger, Procurement Manager
2022-030 Oregon Housing and Community Services Ensure controls over administrative expenditure limits are properly designed and sufficiently detailed to ensure compliance Federal Awarding Agency: U.S. Department of the Treasury Assistance Listing Number and Name: 21.023 Emergency Rental Assistance...
2022-030 Oregon Housing and Community Services Ensure controls over administrative expenditure limits are properly designed and sufficiently detailed to ensure compliance Federal Awarding Agency: U.S. Department of the Treasury Assistance Listing Number and Name: 21.023 Emergency Rental Assistance Program (COVID-19) Federal Award Numbers and Years: ERA 1, 2021; ERA 2, 2021 (COVID-19) Compliance Requirement: Allowable Costs/Cost Principles Type of Finding: Material Weakness Prior Year Finding: N/A Questioned Costs: N/A Criteria: 2 CFR 200.303(a), (c)-(d); 15 U.S.C. 9058a(c)(5)(A); 15 U.S.C. 9058c(d)(1)(C) Department management is responsible for establishing and maintaining effective internal control that provides reasonable assurance the department is managing, evaluating, and monitoring the federal award in compliance with the terms and conditions of the award and taking prompt action when instances of noncompliance are identified. Federal regulations limit the amount of federal funds that can be used for administrative expenditures. The department periodically prepared tracking spreadsheets during the fiscal year to monitor spending and ensure administrative expenditure limitations were not exceeded. We reviewed four randomly selected tracking spreadsheets and noted two tracking spreadsheets where there was insufficient detail to determine what category expenditures were associated with (administrative versus programmatic); and three tracking spreadsheets where there was no indication that the expenditures were within administrative expenditures limitations due to the periodic nature of the tracking. Without sufficiently designed and implemented controls, the department is at risk for exceeding their allowable administrative cost limits. We recommend department management ensure tracking spreadsheets are properly designed and sufficiently detailed to ensure compliance with administrative expenditures limitations. MANAGEMENT RESPONSE: We agree with this recommendation. This was a very fast-paced, complex award with multiple layers of funding. OHCS did have and continues to have a pulse on administrative costs from the various admin funding sources and has not exceeded those allowable limits. Reporting was routinely compiled to show the various allocations and expenditures to date, which included administrative costs. Reporting was not provided in a consistent manner as information from multiple systems was needed, however program and fiscal staff met regularly to review. OHCS is taking careful steps to design a system that will consistently track awards while ensuring spending is in alignment with requirements and is distributed in a timely fashion. In doing so we will create a more consistent framework for tracking new awards to ensure limits and expenditures are consistently documented. Anticipated Completion Date: December 31, 2023 Contact: Jill Smith, Director of Housing Stabilization Division or Beth Brown, Accounting Manager
2022-029 Oregon Housing and Community Services Ensure accessible documentation to evidence compliance with program requirements Federal Awarding Agency: U.S. Department of the Treasury Assistance Listing Number and Name: 21.023 Emergency Rental Assistance Program (COVID-19) Federal Award Numbers a...
2022-029 Oregon Housing and Community Services Ensure accessible documentation to evidence compliance with program requirements Federal Awarding Agency: U.S. Department of the Treasury Assistance Listing Number and Name: 21.023 Emergency Rental Assistance Program (COVID-19) Federal Award Numbers and Years: ERA 1, 2021 (COVID-19) Compliance Requirement: Activities Allowed or Unallowed; Allowable Costs/Cost Principles; Eligibility Type of Finding: Material Weakness Prior Year Finding: N/A Questioned Costs: N/A Criteria: 2 CFR 200.302(a); 2 CFR 200.332(a)(5) Department management is responsible for communicating to subrecipients that they are required to permit the department and auditors access to their records as necessary to ensure the department is compliant with program requirements. To ensure compliance with program requirements, subrecipient records must also be sufficiently detailed. The department passed through $140 million phase one program funds to community action agencies (subrecipients) to provide program delivery. The department performed limited fiscal monitoring during the audit period which included procedures to address compliance with activities allowed and allowable cost requirements for administrative costs. The department did not perform any program monitoring during the audit period which primarily addresses compliance with eligibility requirements. To determine whether the department complied with program requirements for the fiscal year, auditors attempted to reconcile detailed subrecipient ledgers with the intent of selecting and testing sample items at each individual subrecipient organization. We noted issues with two individual subrecipients, resulting in an inability to perform testing procedures over a total of $21,438,521 in program expenditures. For the first subrecipient we were able to reconcile their detailed ledgers to the department?s financial records, however their detailed ledger included pass-through payments to a third organization for program delivery. As a result of the combination of direct and pass-through payments, we were unable to obtain sufficiently detailed data that also reconciled to the department?s financial records to select individual transactions for testing. This subrecipient represents $19,877,962 of the unaudited expenditures. For the second subrecipient we were able to reconcile their detailed ledgers to the department?s financial records and select administrative and program transactions for testing. However, the subrecipient was unresponsive to documentation requests to substantiate expenditures. This subrecipient accounted for $1,560,559 of the unaudited expenditures. We recommend department management obtain and reconcile sufficiently detailed subrecipient ledgers and support to substantiate expenditures to allow for fiscal and program monitoring to ensure subrecipients are administering program funds in accordance with program requirements. MANAGEMENT RESPONSE: We agree with this recommendation. To effectively deliver much needed funds to maintain the housing stability of tens of thousands of Oregonians on the brink of experiencing homelessness during the pandemic, agency staff raced to stand up a first-of-its-kind ?single entry point? program for Oregonians to apply for assistance regardless of zip code. In our efforts to focus on speed we acknowledge that there was insufficient planning and capacity to stand up a large-scale emergency program including sufficient assurances our subrecipients could generate evidence of compliance with program requirements including transaction level details to assist with reconciliation. Oregon?s experience is in line with national findings. According to the January 2021 research brief conducted by the National Low Income Housing Coalition around key program challenges with administering emergency rental assistance programs. Survey respondents listed the two most common limitations to be staff capacity and the completeness of applications. Many agencies leaned on whatever local capacity was available to develop programs, review, and process applications, make payments and conduct outreach. Corrective action plan: OHCS had significant compliance monitoring staff turnover in FY22 leading to incomplete subrecipient monitoring reviews. OHCS completing these reviews would?ve ensured subrecipients had adequate time to produce necessary documentation to evaluate compliance, or if not, subrecipients would?ve been required to take corrective actions. For fiscal compliance, OHCS hired a contractor to perform fiscal monitoring of federal funded Grantees. OHCS also hired fiscal staff to pre-FY22 levels, fully trained them, conducted coordinated working sessions, and reached out to the CAA network for discussions on improving processes. OHCS continues to work with the contractor for much needed assistance in monitoring of back log while internal staff move forward to allow for all monitoring to be back on schedule and coordinating both fiscal and program compliance during future fiscal years. Program compliance employees have been hired and compliance efforts are underway. All providers will have internal compliance visits at regular intervals to ensure they have necessary documents and eligibility is being determined in compliance with program requirements. Additionally regular and ongoing check ins and trainings are being offered by program staff. Finally, program compliance teams are working with the Finance compliance team as well as a contracted expert to develop systems and processes in alignment with the Finance compliance team. As a result of program compliance efforts, a risk evaluation is being developed and incorporated into future contracting decisions. Efforts in hiring and systemic investments in infrastructure, processes, and procedures in addition to partner communications have taken place to ensure agency readiness in the event another emergency occurs. As part of our commitment to continual learning, our OHCS research team is collaborating closely with university and national partners to analyze our ERA program data and findings to see what themes emerge for improvement both nationally and in Oregon. Anticipated Completion Date: December 31, 2023 Contact: Jill Smith, Director of Housing Stabilization Division and Dean Criscola, Controller
2022-028 Oregon Housing and Community Services Ensure Federal Funding Accountability and Transparency Act reporting is completed Federal Awarding Agency: U.S. Department of the Treasury Assistance Listing Number and Name: 21.023 Emergency Rental Assistance Program (COVID-19) Federal Award Numbers...
2022-028 Oregon Housing and Community Services Ensure Federal Funding Accountability and Transparency Act reporting is completed Federal Awarding Agency: U.S. Department of the Treasury Assistance Listing Number and Name: 21.023 Emergency Rental Assistance Program (COVID-19) Federal Award Numbers and Years: ERA 1, 2021 (COVID-19); ERA 2, 2021 (COVID-19) Compliance Requirement: Reporting Type of Finding: Material Weakness, Material Noncompliance Prior Year Finding: N/A Questioned Costs: N/A Criteria: 2 CFR 200.303(a), (c)-(d); 2 CFR 170, Appendix A I(a) Department management is responsible for establishing and maintaining effective internal control that provides reasonable assurance the department is managing, evaluating, and monitoring the federal award in compliance with the terms and conditions of the award and taking prompt action when instances of noncompliance are identified. The Federal Funding Accountability and Transparency Act (FFATA) requires the department to submit information for any subaward action that equals or exceeds $30,000. Program guidance required the department to report detailed subaward information directly to the federal awarding agency. This detailed subaward information encompassed all requirements related to FFATA, and the federal awarding agency gave the department the option of filing required FFATA reports on their behalf. The department stated they did not provide the detailed subaward information to the federal awarding agency to complete FFATA reporting on their behalf, and they did not complete any alternate FFATA submissions during the fiscal year due to grant award information not being available on the federal website to file their reports. As a result, the department is not in compliance with FFATA reporting requirements. We recommend department management ensure FFATA reporting is completed. MANAGEMENT RESPONSE: We agree with this recommendation. Oregon was not unique. Many states experienced frustration with the lack of clarity in the reporting process. For example, the National Coalition for State Housing Agencies sent a Feb 8, 2022 letter to urge Treasury to fix technology problems with its reporting portal, streamline reporting requirements and provide technical assistance to ERA grantees. Oregon also experienced challenges getting responses from Treasury about around reporting questions, but we understand that our federal partners were also operating under emergency circumstances and were also strained to capacity. Corrective action plan: OHCS has attempted multiple times to submit the FFATA, however the award was never made available to report on within the system. OHCS has also reached out to US Treasury multiple times to confirm that we were not required to report but have yet to hear directly from US Treasury. OHCS was able to confirm and received a response from US Treasury that went to another state that grantees were not required to complete the FFATA on the federal reporting website as US Treasury was doing that on behalf of the recipient, and OHCS did share that correspondence with SOS. Although US Treasury has been nonresponsive, OHCS will continue to attempt to obtain a direct response from US Treasury for our own records. Anticipated Completion Date: December 31, 2023 Contact: Beth Brown, Accounting Manager
2022-027 Oregon Housing and Community Services Ensure Monthly and Quarterly reports are accurate and adequately supported Federal Awarding Agency: U.S. Department of the Treasury Assistance Listing Number and Name: 21.023 Emergency Rental Assistance Program (COVID-19) Federal Award Numbers and Ye...
2022-027 Oregon Housing and Community Services Ensure Monthly and Quarterly reports are accurate and adequately supported Federal Awarding Agency: U.S. Department of the Treasury Assistance Listing Number and Name: 21.023 Emergency Rental Assistance Program (COVID-19) Federal Award Numbers and Years: ERA 1, 2021; ERA 2, 2021 (COVID-19) Compliance Requirement: Reporting Type of Finding: Material Weakness; Material Noncompliance Prior Year Finding: N/A Questioned Costs: N/A Criteria: 2 CFR 200.302(a) and (b)(3); 2 CFR 200.303(a), (c)-(d) Department management is responsible for establishing and maintaining effective internal control that provides reasonable assurance the department is managing, evaluating, and monitoring the federal award in compliance with the terms and conditions of the award and taking prompt action when instances of noncompliance are identified. Additionally, the department is responsible for maintaining records to allow for submission of reports that are accurate and adequately supported. We tested four randomly selected monthly reports and found one report did not accurately report the number of unique households assisted and the amount of the assistance based on the supporting documentation. The department stated the differences were likely due to a transition in subsystem reporting formats and delays in report processing. We tested four quarterly reports, two of which were randomly selected and two of which were judgmentally selected. We found one report where the cumulative obligation amount did not agree to supporting documentation and were not accurate, and one report where the cumulative obligation and cumulative expenditures amounts did not agree to supporting documentation and were not accurate. The department stated these errors were due to erroneously entered information in the federal awarding agency?s reporting portal. Information included in these reports is used by the federal awarding agency to determine whether the department qualifies for receiving reallocation payments, as well as how much of a reallocation would be awarded to the department. Errors in these reports could result in errors in the federal awarding agency?s determination of eligibility for funding, and/or the reallocation formula. We recommend department management update and correct erroneous reports and establish controls to ensure reported amounts are accurate and adequately supported. MANAGEMENT RESPONSE: We agree with this recommendation. Numerous Community Action Agencies (CAAs), after months of exponential growth in program resources without time to strategize and scale operations, reported major capacity issues a chronic backup of applications at the local level. OHCS took the unprecedented step to augment CAA staff to contract with a third-party vendor to clear the backlog. This approach rapidly increased production and moved the federal program closer in line with the state?s then 60-day safe harbor period but came with additional monitoring and reporting challenges. OHCS did meet the reporting timelines and requirements of US Treasury. OHCS relied on information within the applicant tracking system that does have some discrepancies when compared to our accounting records. These discrepancies are due to various factors such as dates within the system causing application activity to be pulled into the reporting detail more than once, or the application tracking system not being updated with the most current payment record information by some grantees disbursing payments. These variances were overcome by relying on our accounting system and records as a control source of actual disbursements. During the audit, it was brought to our attention that the compilation of the application tracking system data at a point in time was not stored to demonstrate the reconciliation with the accounting information. SOS was then not able to verify the application tracking system data figures in one monthly reporting instance that were used to support the numbers reported to US Treasury as the file had likely been overridden. Similarly in one instance, the quarterly cumulative report was also impacted, however future cumulative figures were reported correctly. Corrective action plan: While OHCS submitted monthly and quarterly reports since program inception that include program and fiscal information, we acknowledge that there were some discrepancies between systems when one file was overridden with new information and one other file contained an error. We have taken steps to ensure data integrity and records retention moving forward and future compilations of the application tracking system data will be stored to support the point in time reconciliations and figures reported to US Treasury. One quarterly report will also be refiled if allowable by US Treasury to ensure quarterly figures reported are accurate. Data integrity is of the utmost importance to the agency, and we appreciate the thorough review by the auditing team. Anticipated Completion Date: June 30, 2023 Contact: Beth Brown, Accounting Manager
2022-026 Oregon Housing and Community Services Department Implement program monitoring over client assistance payments to ensure compliance Federal Awarding Agency: U.S. Department of the Treasury Assistance Listing Number and Name: 21.023 Emergency Rental Assistance Program (COVID-19) Federal Aw...
2022-026 Oregon Housing and Community Services Department Implement program monitoring over client assistance payments to ensure compliance Federal Awarding Agency: U.S. Department of the Treasury Assistance Listing Number and Name: 21.023 Emergency Rental Assistance Program (COVID-19) Federal Award Numbers and Years: ERA 1, 2021; ERA 2, 2021 (COVID-19) Compliance Requirement: Activities Allowed or Unallowed; Eligibility Type of Finding: Material Weakness; Material Noncompliance Prior Year Finding: N/A Questioned Costs: $21,624 (known); $11,067,350 (likely) (COVID-19) Criteria: 2 CFR 200.332(d); 2 CFR 200.501(g) Department management is responsible for monitoring the activities of subrecipients to ensure subawards are used for authorized purposes and are compliant with federal requirements. Additionally, department management is responsible for ensuring compliance when a contractor is responsible for program compliance or the contractor?s records must be reviewed to determine program compliance. The department provided $140 million and $46 million of phase one program funds to community action agencies (subrecipients) and a third-party vendor (contractor) to provide program delivery, respectively; and $132 million phase two program funds to only the contractor. Program delivery included determining client eligibility and making payments for direct client assistance for rent, utilities, internet, and other housing related costs. During implementation of the program, the department provided program manuals to the subrecipients and contractor. Due to the department?s limited staff, they focused on updating policies and procedures to address systemic issues identified; however, if a particularly challenging application required the department?s review, they were available to provide direct assistance. The department did not implement any predefined, systemic program monitoring of the subrecipients or contractor to ensure direct client assistance payments were paid to only eligible clients for only allowable and supported amounts. Therefore, auditors performed additional procedures at the subrecipient and contractor level to determine whether direct client assistance payments were paid to eligible clients for allowable activities. We tested a total of 62 randomly selected direct client assistance payments at 16 subrecipients totaling $183,515, and found the following: One subrecipient did not respond to audit requests for documentation, resulting in an inability to test one transaction in the amount of $360. One subrecipient did not obtain documentation to support that there was a lease agreement in place, resulting in questioned costs of $5,775. When extrapolated to the total population, these errors result in over $2.3 million in likely questioned costs. We tested 61 randomly selected contractor direct client assistance payments totaling $374,274, and found the following: One payment where an incorrect landlord was paid in the amount of $2,700. Attempts to recover the funds have been unsuccessful as of the date of the finding. Two payments where the rental amount was doubled, resulting in overpayments totaling $5,910. Seven payments where amounts already paid were not accurately reflected in the calculation of assistance provided, resulting in overpayments totaling $4,191. Three payments where amounts did not agree to supporting documentation, resulting in overpayments of $2,181. Three payments where there was insufficient documentation for amounts paid, resulting in overpayments of $432. One payment where costs were paid for the same household on alternate applications, resulting in an overpayment of $73. When extrapolated to the total population, these errors result in over $8.7 million in likely questioned costs. We recommend department management implement predefined, systemic program monitoring to ensure the subrecipients and contractor are administering program funds in accordance with program requirements. MANAGEMENT RESPONSE: We agree with this recommendation. OHCS agrees and had we not been operating during a global health pandemic and had we had adequate time and staffing, we would have addressed this issue more carefully as we have in previous years. However, given that this was a new program that lacked sufficient time and resources to design, launch and operate to meet the pressing needs of Oregonians facing eviction and homelessness, the work required unprecedented action that sometimes fell short of our usual standards for client assistance payment compliance. OHCS will use these lessons moving forward should we operate future emergency programs to move towards best practices. Corrective action plan: Lack of staff significantly limited our ability to perform the necessary monitoring. An additional contractor was brought on to monitor the work of our vendor in February of 2022. The contractor continued to provide program compliance support to OHCS through the end of January 2023. This contractor was also engaged in other projects and activities as needed during their contract term. The largest workload was investigating payments or cases that were identified as potentially non-compliant. All these cases were researched extensively, and findings were identified, and corrective action and collection activities were started if needed. Out of concern for the lack of administrative dollars associated with ERA staff knew an internal compliance effort would also be required. Since the summer of 2022 OHCS staff have been conducting internal random samples of applications and payments in addition to the work of our hired contractor. Additionally, this spring the program compliance team has engaged in a formalized review process focused on specific agencies administering ERA funds. Anticipated Completion Date: December 31, 2023 Contact: Jill Smith, Director of Housing Stabilization Division
View Audit 45093 Questioned Costs: $1
2022-025 Oregon Housing and Community Services Perform fiscal monitoring for subrecipients administrative expenditures to ensure compliance Federal Awarding Agency: U.S. Department of the Treasury Assistance Listing Number and Name: 21.023 Emergency Rental Assistance Program (COVID-19) Federal Aw...
2022-025 Oregon Housing and Community Services Perform fiscal monitoring for subrecipients administrative expenditures to ensure compliance Federal Awarding Agency: U.S. Department of the Treasury Assistance Listing Number and Name: 21.023 Emergency Rental Assistance Program (COVID-19) Federal Award Numbers and Years: ERA 1, 2021 (COVID-19) Compliance Requirement: Activities Allowed or Unallowed; Allowable Costs/Cost Principles Type of Finding: Material Weakness; Material Noncompliance Prior Year Finding: N/A Questioned Costs: $121,463 (known) (COVID-19) Criteria: 2 CFR 200.332(a)(5) and (d) Department management is responsible for monitoring the activities of subrecipients to ensure subawards are used for authorized purposes and in compliance with federal requirements. Additionally, department management is responsible for communicating to subrecipients that they are required to permit the department and auditors access to their records as necessary to ensure the department is in compliance with program requirements. The department passed through program funds to community action agencies (subrecipients) to provide program delivery, including administrative costs. The department performed fiscal monitoring for only five of their 18 subrecipients during the audit period due to staff turnover. Fiscal monitoring includes procedures to address compliance with activities allowed and allowable cost requirements for administrative costs. Due to the limited fiscal monitoring performed, auditors performed additional procedures at the subrecipient level to determine whether the department was compliant with program requirements. We tested a total of 82 transactions, 70 randomly selected and 12 judgmentally selected from the 13 subrecipients that did not receive subrecipient monitoring during the fiscal year. We noted the following: One subrecipient did not respond to audit requests for documentation, resulting in an inability to test four transactions totaling $4,114. One subrecipient did not provide sufficiently detailed documentation to determine whether 7 transactions were for accurate amounts totaling $117,349. Of those seven transactions, we were unable to determine whether two transactions were for allowable activities or appropriately categorized as administrative expenditures. Without adequate monitoring of subrecipients, the department?s ability to ensure compliance with program requirements is diminished. We recommend department management perform fiscal monitoring to ensure subrecipients are expending administrative funds in accordance with program requirements. MANAGEMENT RESPONSE: We agree with this recommendation. Corrective action plan: OHCS had significant compliance monitoring staff turnover in FY22 which led to a lack of monitoring. OHCS has subsequently hired a contractor to perform fiscal monitoring of all ESG funded grantees. OHCS also hired staff to pre-FY22 levels, fully trained all staff and began developing internal working relationships with program staff to assure operational efficiencies. This includes an annual workshop with all grantees, internal training, and standardizations of monitoring processes. Anticipated Completion Date: June 30, 2023 Contact: Dean Criscola, Controller
View Audit 45093 Questioned Costs: $1
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