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Finding 433354 (2022-024)
Significant Deficiency 2022
Dear Mr. Waguespack:The Louisiana Department of Health (LDH) acknowledges receipt of correspondence from the Louisiana Legislative Auditor (LLA) dated February 27, 2023, regarding a reportable audit finding related to Inadequate Controls Over and Noncompliance with National Correct Coding Initiative...
Dear Mr. Waguespack:The Louisiana Department of Health (LDH) acknowledges receipt of correspondence from the Louisiana Legislative Auditor (LLA) dated February 27, 2023, regarding a reportable audit finding related to Inadequate Controls Over and Noncompliance with National Correct Coding Initiative Requirements. LDH appreciates the opportunity to provide this response to your office?s findings.Finding: Inadequate Controls Over and Noncompliance with National Correct Coding Initiative RequirementsRecommendation: Management should ensure all required NCCI edits are properly applied to FFS claims.LDH Response: LDH partially concurs with this finding.LDH disagrees with the premise that a data pull compared with NCCI quarterly files represents an accurate and final adjudication of claims in a claims processing system. LDH disagrees that such a data pull could be used as the basis of a determination of inappropriate adjudication.The data pull does not consider the final adjudication of claims. Our review identified examples outside of the processing dates utilized by LLA where the NCCI edits applied and claims denied correctly in subsequent processing dates. A single data pull by the LLA may not dependably reflect the accurate final outcome of the applied edits.Fee-for-service (FFS) NCCI editing occurs within the integrated ClaimsXten Portfolio (CXT P) (formerly Change Healthcare) `ClaimCheck? product. System constraints of both the fiscal intermediary and ClaimCheck preclude applying Medically Unlikely Edits (MUE) to outpatient hospital and durable medical equipment (DME) claims.The LLA has been previously informed that Medicaid FFS is working with the fiscal intermediary (FI) and CXT P to implement and integrate the newest version of the clinical editing product, `ClaimsXten? which houses all of the Medicaid NCCI methodologies. This product replaces ClaimCheck and will not have the same constraints in applying NCCI edits. LDH is currently in the process of converting to `ClaimsXten?. The estimated completion date is March 24, 2023.The LLA is also aware that FFS Medicaid applies the Medicaid NCCI `procedure to procedure? (PTP) edits for practitioner, outpatient hospital (OPH), and durable medical equipment (DME) as well as the medically unlikely edits for practitioners. DME and OPH MUE are not currently applied due to previously mentioned system constraints. CMS is aware of the methodologies applied to Louisiana Medicaid FFS claims.LDH concurs that not all of the Medicaid NCCI edit methodologies are in place due to the limitations of the fiscal intermediary and the current integrated editing product.Corrective Action Plan:As ongoing corrective action, LDH is working with both the FI and CXT P to integrate and implement the updated clinical editing product `ClaimsXten? that will allow full compliance with all of the NCCI edit methodologies.LDH will continue to perform biweekly reviews that include examples of FFS NCCI edits to assure correct functionality. Once `ClaimsXten? is implemented, all methodologies will be able to be monitored. The estimated completion date is March 24, 2023.You may contact Tara A. Leblanc, Medicaid Director at (225) 219-7810 or via e-mail at Tara.LeBlanc@la.gov or Brandon Bueche, Medicaid Section Chief at (225) 384-0460 or via email at Brandon.Bueche@la.gov with any questions about this matter.
View Audit 312391 Questioned Costs: $1
Finding 433315 (2022-033)
Significant Deficiency 2022
Dear Mr. Waguespack,We appreciate the opportunity afforded to review and respond to the revised audit finding regarding the "Weakness in Controls over Research and Development Project Closeouts and Accounting Records".Finding: Weakness in Controls over Research and Development Project Closeouts and ...
Dear Mr. Waguespack,We appreciate the opportunity afforded to review and respond to the revised audit finding regarding the "Weakness in Controls over Research and Development Project Closeouts and Accounting Records".Finding: Weakness in Controls over Research and Development Project Closeouts and Accounting RecordsManagement concurs with the finding listed in the report.Response to Finding and Corrective Actions:We agree with the finding that the audit identified ledger transactions incurred outside of 120 days from project end dates. Although LSUHSC-NO has made considerable progress in rectifying the weakness by implementing corrective plans identified in prior findings, significant turnover in departmental business managers and difficulty in recruiting personnel have impacted the complete resolution of the issue.Despite the considerable progress made, your office identified three (3) projects as being non-compliant. Of these projects, the FFR/final invoice was submitted within federal guidelines of 120 days. Thereafter, a credit was applied resulting in a revised FFR/final invoice and refund to the sponsor.It should be further noted that of the remaining seven (7) projects with control issues, none had questioned costs and are summarized below:? Four (4) projects had no effect on the Federal Financial Report (FFR) submitted or drawdown of funds. The expenditures included on the FFR and the requested funds were reasonable, allocable, allowable, and within the project closeout timeline.? One (1) project had transactions due to the month end indirect cost allocation process which was within the posting guidelines for the institution and within the period included in the 120 days .? Two (2) projects were authorized for an extension as supported by the documents provided to the auditor.LSUHSC-NO is committed to continued fiscal responsibility, partnership and training as evidenced by the following corrective actions:1) Sponsored Projects Accounting ("SPA") will initiate training for Departmental Business Managers and School Fiscal Deans to review single audit compliance requirements, project management, and SPA related reports and expectations.Responsible Personnel for #1: Sponsored Projects AccountingAnticipated Completion Date: June 30, 20232) Accounting Services will investigate the feasibility of implementing automated system controls in PeopleSoft to prevent costs from being charged to projects beyond close out periods or the feasibility of providing SPA with the authority to close out projects not addressed by the Schools in a timely manner.Responsible Personnel for #2: Executive Director of Accounting ServicesAnticipated Completion Date: December 31, 20233) In recognition of the significant turnover in Business Managers, LSUHSC-NO has increased the salaries of the departmental business managers to attract and retain effective team members. SPA has recently hired two new positions in response to the previous years' finding. Additionally, LSUHSC-NO will commit to hiring a third new position in SPA.The Director for Financial Reporting , Asset Management & Sponsored Projects Accounting position was recently created to provide a higher level oversight in the department. The director is reassessing the roles and responsibilities of the existing staff in the department and has identified opportunities for better utilization of the employees.Responsible Personnel for #3: Executive Director of Accounting ServicesAnticipated Completion Date: December 31, 2023Furthermore, LSUHSC -NO will continue the following ongoing corrective actions previously implemented:4) The Fiscal Dean of each School or his/her designee will continue to review and monitor departmental compliance with Chancellor Memorandum ("CM-21"), which includes the responsibilities of the required financial management of an individual project or group of projects.5) The Fiscal Dean of each School or his/her designee will ensure their Business Managers are properly trained on the following: monitoring budgets and timely collections of overruns, project closeout procedures, and account reconciliation in compliance with CM-21.Responsible Personnel for #4 and #5: School Fiscal DeansAnticipated Completion Date for #4 and #5: June 30, 20216) SPA will continue to provide PeopleSoft Financials error reports to applicable Business Managers and Fiscal Deans for immediate action with errors such as: projects with an end date that has passed, projects in deficit, or projects not setup to accept personnel expenses.Responsible Personnel for #6:Departmental Business Managers School Fiscal Deans Sponsored Projects AccountingAnticipated Completion Date for #6: February 20227) SPA will continue to escalate and follow-up on requests to correct projects with expenditures posting beyond 90 days that are not addressed in a timely manner to the Principal Investigator, Department Head, Dean, and Chancellor as necessary.Responsible Personnel for #7: Sponsored Projects AccountingAnticipated Completion Date for #7: January 5, 2023If you have any additional questions or concerns, please do not hesitate contacting me.
Finding 433303 (2022-027)
Significant Deficiency 2022
Dear Mr. Waguespack:The Louisiana Department of Health (LDH) acknowledges receipt of correspondence from the Louisiana Legislative Auditor (LLA) dated January 20, 2023, regarding a reportable audit finding related to Inadequate Controls over Monitoring of Abortion Claims. LDH appreciates the opportu...
Dear Mr. Waguespack:The Louisiana Department of Health (LDH) acknowledges receipt of correspondence from the Louisiana Legislative Auditor (LLA) dated January 20, 2023, regarding a reportable audit finding related to Inadequate Controls over Monitoring of Abortion Claims. LDH appreciates the opportunity to provide this response to your office's findings.Finding: Inadequate Controls over Monitoring of Abortion ClaimsRecommendation: LDH should continue its process to validate self-reported information from the health plans and ensure its process is operating effectively to ensure compliance with federal regulations regarding funding of prohibited abortions claims.LDH Response:LDH concurs with the finding that it did not compare or validate the monthly Managed Care Organization (MCO) self-reported information to ensure the reporting was accurate and complete for the entire fiscal year.LDH developed and proposed an additional review procedure in March 2022 that would validate encounter data to the MCOs self-reported monthly report, but the procedure was not in place prior to the end of state fiscal year 2022. Analysis of encounter data has very significant limitations because the same procedure codes used for an elective abortion are the same procedure codes used for treatments of a fetal death that has already occurred (miscarriage). Therefore, oversight had to be clinically-oriented, which added complexity to the process.The additional review procedure was implemented in July 2022 and reviewed data retrospectively for January 2022 through June 2022.LDH will continue its process to validate the self-reported information from the Managed Care Organizations against encounter data on an ongoing basis and this will be completed for all of Fiscal Year 2023.LDH partially concurs with the finding that the instructions provided to the MCOs concerning how to complete the reports are not detailed and could potentially lead to all five health plans reporting different information. The monthly report includes a definitions tab that includes information on what and how data should be reported. By reviewing reports submitted and encounter data, LDH is able to make determinations on how each MCO is reporting data. However, LDH will review and revise the reporting instructions to include more detail for the MCOs in order to mitigate the potential for misunderstanding by the MCOs.You may contact Tara A. Leblanc, Medicaid Director at (225) 219-7810 or via e-mail at Tara.LeBlanc@la.gov or Brandon Bueche, Medicaid Section Chief at (225) 384-0460 or via email at Brandon.Bueche@la.gov with any questions about this matter.
Finding 433298 (2022-019)
Significant Deficiency 2022
Dear Mr. Waguespack:The Department of Children and Family Services (DCFS) has reviewed the finding ?Control Weakness Relating to Foster Care Subrecipient Monitoring.? The finding states DCFS did not adequately review subrecipient Foster Care Invoices submitted by the Office of Juvenile Justice (OJJ)...
Dear Mr. Waguespack:The Department of Children and Family Services (DCFS) has reviewed the finding ?Control Weakness Relating to Foster Care Subrecipient Monitoring.? The finding states DCFS did not adequately review subrecipient Foster Care Invoices submitted by the Office of Juvenile Justice (OJJ) for reimbursement of administrative expenditures to ensure billings were accurately calculated. DCFS concurs with the finding.DCFS will establish a secondary level of review to ensure accuracy of OJJ administrative invoices prior to reimbursement. The Child Welfare Consultant will review OJJ?s IVE Administrative Expenditure Invoice for accuracy. Upon verification of an accurate OJJ invoice, the Federal Programs Manager will conduct a secondary level review to confirm accurate calculation of administrative expenditures.If discrepancies are noted, the Consultant will contact OJJ for clarification and request corrections, if necessary. OJJ will be required to submit a corrected invoice. Upon receipt of the corrected invoice, the Consultant will conduct a review of the invoice to ensure accuracy. The Consultant will submit the invoice to the Federal Programs Manager for a secondary level review. This secondary level reviewer will ensure no additional issues exist and will confirm the accuracy of the calculations for administrative expenditures.Secondary level reviews of OJJ administrative expenditure invoices will begin immediately and DCFS is working with OJJ to recover the overpayment through deduction from the next FY22 Quarterly invoice submitted by OJJ.If you have any additional questions, please reach out Sharla Thomas, Child Welfare Manager 2, at Sharla.Thomas.DCFS@la.gov.
View Audit 312391 Questioned Costs: $1
Finding 433294 (2022-021)
Significant Deficiency 2022
Dear Mr. Waguespack:The Department of Children and Family Services (DCFS) has received the finding titled ?Noncompliance with Reporting Requirements for the Federal Funding Accountability and Transparency Act.?The finding noted that DCFS did not report subawards in compliance with the Federal Fundin...
Dear Mr. Waguespack:The Department of Children and Family Services (DCFS) has received the finding titled ?Noncompliance with Reporting Requirements for the Federal Funding Accountability and Transparency Act.?The finding noted that DCFS did not report subawards in compliance with the Federal Funding Accountability and Transparency Act (FFATA) in the FFATA Subaward Reporting System (FSRS) during fiscal year 2022 for the Foster Care Title IV-E and the Temporary Assistance for Needy Families programs. We concur with the finding.DCFS is presently developing policies and procedures to ensure accurate and timely reporting of data required by the FFATA in FSRS and is working to collect the required information from subrecipients to begin reporting. We will implement and train staff on policies and procedures regarding FFATA reporting requirements and begin reporting required data in FSRS on an ongoing basis in accordance with FFATA required timeframes by March 31, 2023.The contact person for Foster Care Title IV-E reporting is Tina Joseph, Program Manager, who may be reached at 225-342-4152 or tina.josheph.dcfs@la.gov. The contact persons for TANF reporting are Julie Starns, Program Manager, who may be reached at 225-342-0495 or julie.starns.dcfs@la.gov, and Robert Williams, Program Manager, who may be reached at 225-342- 4791 or robert.williams.dcfs@la.gov.
Finding 433289 (2022-018)
Significant Deficiency 2022
Mr. Waguespack,Please accept this response to the audit conducted by your office on the Acadiana Area Human Services District (AAHSD). There were two findings listed: 1) Inadequate Controls over Sub - Recipient Agreements; 2) Untimely Billing of Patient Services.Please find the response for each und...
Mr. Waguespack,Please accept this response to the audit conducted by your office on the Acadiana Area Human Services District (AAHSD). There were two findings listed: 1) Inadequate Controls over Sub - Recipient Agreements; 2) Untimely Billing of Patient Services.Please find the response for each under separate letter attached.We appreciate the feedback and comments from your team and will use this information to improve our systems and processes.Finding:Inadequate Controls over Subrecipient AgreementsComment:We concur with this finding. AAHSD works closely with the Louisiana Department of Health (LDH) regarding interagency transfers (IAT) and other grant funding, including TANF and Block Grant funds. Much of the information required to demonstrate compliance with this element is maintained by LDH and was not always accessible to us in a timely manner. Additionally, we have worked with LDH to revise the documentation regarding risk assessment for the subrecipients.Corrective Action:? AAHSD will develop and implement an appropriate checklist of required information regarding:o identification of Federal award informationo a risk assessment of the subrecipients' non-compliance? AAHSD has revised our contract template to include the necessary information regarding audits of subrecipient organizations? AAHSD will request all necessary information from subrecipient organizations at the initiation of the contracting process rather than waiting on notification from LDHPerson(s) Responsible:The Executive Director is ultimately responsible for ensuring all corrective action. Specific duties may be delegated to other senior managers, specifically: the Chief Financial Officer; the Director of Behavioral Health; and the Corporate Compliance/Accreditation Officer.Timeframe:All action points implemented within 90 calendar days of receiving the final audit report.
Finding 433276 (2022-014)
Significant Deficiency 2022
Dear Mr. Waguespack,Please accept this letter as the official response from the Louisiana Department of Education (LDOE) to the audit finding entitled Non-Compliance with Reporting Requirements for the Federal Funding Accountability and Transparency Act (FFATA) for the fiscal year ending June 30, 20...
Dear Mr. Waguespack,Please accept this letter as the official response from the Louisiana Department of Education (LDOE) to the audit finding entitled Non-Compliance with Reporting Requirements for the Federal Funding Accountability and Transparency Act (FFATA) for the fiscal year ending June 30, 2022.Recommendation:DOE should continue to strengthen internal controls to ensure that appropriate personnel are aware of the federal programs that are subject to FFATA reporting and assign appropriate personnel to complete the FFATA reporting in accordance with federal requirements.LDOE Response:In order to strengthen internal controls over FFATA reporting to address the recommendation, the LDOE has implemented procedures to identify appropriate personnel as responsible for the preparation and submission of FFATA reporting in addition to providing training to the responsible personnel on federal regulations regarding required reporting. The agency?s third-party electronic grants management system vendor has provided the reports for FFATA Reporting that ensures accurate data submission in accordance with the federal requirements, therefore the LDOE concurs with the finding. The LDOE plans to have these corrective actions in place no later than September 30, 2023.Contributing Factor:As part of the formal response, LDOE would like to identify the Federal Subaward Reporting System (FSRS) as a contributing factor in the resolution process for FFATA reporting. While LDOE is and will continue to work through the process of submission/correction to FFATA reporting, please note that timely/accurate submission is to some extent dependent on the submission process as designed by the FSRS. LDOE has and continues to encounter technical issues with the FSRS site where these reports are uploaded. To resolve the issues, the staff must submit FSRS Helpdesk tickets whereas the timely resolution of the tickets are a vital component of the corrective action protocols. Upon request, LDOE provides our program contact at the US Department of Education (ED) information regarding its outstanding helpdesk tickets and their status for resolution. The agency?s team is maintaining a record regarding the ticket submissions and their resolution status to ensure all FFATA reports are submitted accurately and timely.The Department takes seriously the reporting requirements for FFATA and is dedicated to ensuring the reporting is accurate and timely. Further questions concerning this response may be directed to Mr. Bernell Cook, by telephone at 225-342-1050 or via email at bernell.cook@la.gov.
Dear Mr. Waguespack,The Louisiana Workforce Commission (LWC) respectfully submits its response to the Single Audit Report finding of Inadequate Controls Over and Noncompliance with Subrecipient Monitoring Requirements.First and foremost, it is important to note that the Compliance and Monitoring Uni...
Dear Mr. Waguespack,The Louisiana Workforce Commission (LWC) respectfully submits its response to the Single Audit Report finding of Inadequate Controls Over and Noncompliance with Subrecipient Monitoring Requirements.First and foremost, it is important to note that the Compliance and Monitoring Unit of LWC has been working very diligently to comply with the requirements of the Workforce Innovation and Opportunity Act (WIOA) of annual monitoring reviews of subrecipients. LWC recognizes the importance of monitoring our subrecipients and in doing so performs their due diligence to ensure that compliance with all legal requirements within WIOA are met. Enormous strides are being made towards improving and sustaining the great work that has already been done. We will continue our efforts to ensure that we remain on track in accomplishing full compliance with subrecipient monitoring at the close of the current fiscal year.Should you have any questions or need additional information, please feel free to contact my office at (225) 342-3001.? Two monitoring reports were not issued timely by LWC. The monitoring reports were issued 74 and 75 days after the completion of the monitoring review. LWC?s policy requires monitoring review reports to be issued 60 days after the completion of the monitoring review.? LWC concurs with this portion of the finding that 2 out of the 15 monitoring reports were issued more than 60 days after the conclusion of the monitoring review. We find it important to note that the late issuance of the 2 monitoring reports is a direct result of the many challenges LWC faced during the monitoring cycle. As a result of these challenges, LWC undertook a review of its internal policy and has made revisions to the policy with regard to, among other things, the timeliness of the issuance of monitoring reports.? For four monitoring reports, close out letters were issued 145 to 191 days after monitoring report issuance. For six monitoring reports, close out letters were not issued as of January 2023 while the monitoring reports for these reviews were issued over 200 days prior. The monitoring reports include findings with possible questioned cost totaling $3.1 million. LWC policy does not specifically address timeliness requirements for closeout letters.? LWC concurs in part with this finding concluding that four close out letters were issued 145 to 191 days after monitoring report issuance and that six close out letters were not issued as of January 2023 while the monitoring reports for these reviews were issued over 200 days prior. However, LWC does not concur with the overarching conclusion that its policy does not specifically address timeliness requirements for closeout letters.A closeout letter is not generated to a subrecipient unless all findings identified in the monitoring report have been resolved. When findings are identified in the monitoring report, subrecipients are given the opportunity to clear those findings by submitting a Corrective Action Plan (CAP). A CAP is the subrecipient?s opportunity to address the cause of the findings and provide LWC with a well thought-out plan not only address the cause of the finding but to implement steps to prevent findings of that nature in the future. Until the CAP is submitted, all steps executed, and a determination that the finding has been resolved, a closeout letter will not be issued.If a subrecipient submits a CAP, LWC periodically reviews the CAP with the subrecipient to determine whether sufficient steps are being taken toward resolution of the finding(s). If at some point, it is determined that resolution is not attainable, an initial determination is then issued.For the time period covering the Single Audit, LWC?s policy provided for the following:? Within 45 days of issuance of the monitoring report, the subrecipient must submit a corrective action plan for all findings listed in the monitoring report.? Within 30 days of receiving the corrective action plan from the subrecipient, LWC would notify the subrecipient of acceptance or rejection of the corrective action plan.The next step in the process, as articulated in LWC?s policy is the initial determination.? Three subrecipients had findings on the monitoring reports stemming from a lack of documentation supporting the subrecipients? drawdowns of WIOA funds and drawdowns of federal funds could not be reconciled by LWC to the subrecipients accounting records. The monitoring reports noted potential questioned cost associated with these drawdowns. These reviews are included in the six monitoring reports not issued as of January 2023, noted in the bullet above. Timely resolution would allow LWC to quickly address any compliance issues at the subrecipients? level. According to LWC, it is working with the subrecipients to reconcile the federal funds drawdowns and close out the reports.? LWC received unorganized data from the subrecipients. In response to LWC?s request for financial documentation such as general ledgers, balance sheets, expenditure reporting, invoices, etc., subrecipients basically did a data dump. There was no legend or other identifying information associated with the data that was submitted and opening each unidentified file, reviewing it and trying to identify it with thousands of transaction for 15 subrecipients proved tedious, time-consuming and confusing. In an effort to stick as closely as possible to very tight timelines, LWC issued a finding within the monitoring report anticipating that the finding would compel the subrecipients to work with LWC to resolve the differences. As a result of issuing these findings the subrecipients developed corrective action plans to resolve the differences in the drawdown reconciliations. LWC created internal control documents to assist in the organization of material received from the subrecipients. The documents will be utilized when performing the review of the financial portions of the monitoring.Documents that were created include:REQUEST FOR DOCUMENTS - The ?Request for Documents? is a document that details for the subrecipient how documents are to be submitted and labeled. Attached is a copy of the Request for Documents and a detail of the new layout of how the documents are to be uploaded. Portions of the corrective action plan were omitted due to character limitations; See Corrective Action Plan for attachment.INTERNAL CONTROL QUESTIONNAIRE - The ?Internal Control Questionnaire? is a series of queries that helps LWC understand the structure and workflow of the subrecipient. Attached is a copy of the Internal Control Questionnaire. Portions of the corrective action plan were omitted due to character limitations; See Corrective Action Plan for attachment.The new format has significantly reduced the amount of time to complete the financial monitoring of the subrecipient.
Dear Mr. Waguespack:The Division of Administration, Louisiana Office of Community Development (LOCD) is submitting the following in response to the audit finding titled "Restore Louisiana Homeowner Assistance Program Awards Identified for Grant Recovery."LOCD acknowledges the LLA finding of "Restore...
Dear Mr. Waguespack:The Division of Administration, Louisiana Office of Community Development (LOCD) is submitting the following in response to the audit finding titled "Restore Louisiana Homeowner Assistance Program Awards Identified for Grant Recovery."LOCD acknowledges the LLA finding of "Restore Homeowner awards identified for Grant Recovery. " In response to the 2016 Floods, the LOCD created the Restore Louisiana Homeowner Assistance Program (HAP). Grant recapture procedures were established from the beginning of the program and have been implemented timely. It is impossible to administer a disaster recovery program that will not have certain files requiring grant recapture during the life of the program. The Restore Program requires a duplication of benefits check on all files prior to grant execution. For example, it is always possible an applicant may receive additional funding, e.g., insurance proceeds that are deemed duplicative by law. The Restore Program has controls in place to capture these amounts in the grants management system, subrogation agreements executed with each applicant, and recapture procedures to recover the funds. From the very beginning, the Restore Program was created to minimize the potential of applicants' ending up in recapture. As a result, the state has issued over $670 million to 17,262 homeowners of which 80, or 0.46% have been placed in recapture. As the Restore Homeowner Program comes to a close, LOCD does not anticipate further files requiring recapture of funds.LOCD agrees with the observation of 8 files with a potential grant recapture as a necessary ongoing activity for the Program. LOCD will continue to follow the established recapture procedures for these grant awards to ensure ultimate compliance, however, this is not a corrective action, but rather the continued implementation of program protocols.The contact person responsible for these ongoing compliance activities is Ginger Moses, OCD Chief Operating Officer. The anticipated completion date for activities addressing this finding will coincide with the closing of the Restore Louisiana program.If you have questions or require additional information, please feel free to contact me.
View Audit 312391 Questioned Costs: $1
Dear Mr. Waguespack:The Division of Administration, Louisiana Office of Community Development (OCD) submits the following in response to the audit finding titled "Inadequate Recovery of Small Rental Property Program Loans."The Small Rental Property Program (SRPP) has two tiers of compliance obligati...
Dear Mr. Waguespack:The Division of Administration, Louisiana Office of Community Development (OCD) submits the following in response to the audit finding titled "Inadequate Recovery of Small Rental Property Program Loans."The Small Rental Property Program (SRPP) has two tiers of compliance obligations. The federal compliance requirements are for the CDBG funds issued to a borrower to meet a National Objective and be expended on an Eligible Activity. On top of the federal requirements, the State has its own program requirements. Upon the initial placement of an eligible tenant in a habitable unit at a restricted rent amount, the U.S. Department of Housing and Urban Development (HUD) requirements have been satisfied. Most of the matters made the subject of your report deal with the borrower's non-compliance with the State's program rules, not the HUD requirements.OCD has allocated approximately $649 million to the SRPP program to fund approximately 4,500 applicants and we maintain an ongoing monitoring process to promote compliance and continued availability of affordable housing. Consistent with the program's mission of preserving and expanding much needed affordable housing, OCD's primary focus for the SRPP is to assist property owners in achieving and maintaining compliance, i.e., creating and continuing affordable housing opportunities, as opposed to foreclosure and/or recapture of funds, and are, therefore, not subject to recapture by HUD.In summary, as of June 30, 2022, the LLA reports that 1,156 applicant files have been identified as noncompliant. Of these, 163 files have been determined to be uncollectible, leaving 993 files that are actively being addressed. OCD's compliance and repayment efforts relating to the state imposed continuing requirements of the program are ongoing. See corrective action plan for footnote. The optimal outcome of these efforts is the continued availability of affordable housing through compliance.In June 2016, OCD, working with the Louisiana Housing Corporation (LHC) and HUD, identified 397 SRPP borrowers that did not meet a National Objective. Immediately thereafter, OCD's Legal Section and LHC program staff began communicating with non-compliant borrowers and evaluating proposed workouts. OCD sent default letters to and initiated recapture efforts on all borrowers. Each file is processed with a goal of either achieving compliance, securing repayment, or identifying another viable workout plan. As of June 30, 2022, of the 397 files identified, 76 borrowers have become compliant, 14 have either partially or fully repaid their loans, 18 borrowers have transferred their housing obligations to other compliant properties and 28 have been determined uncollectable for various reasons. As noted in the audit, OCD continues to seek technical assistance regarding the enforcement of mortgages through the judicial foreclosure/public auction process.In conclusion, OCD will continue the efforts to recover those loans determined to be ineligible in accordance with policies and procedures that are acceptable to HUD. Concurrently, OCD will also continue to assist rental property owners to become compliant and to resolve any program compliance issues, thus increasing available affordable rental housing and reducing or eliminating the need to recapture funds from rental property owners, where appropriate.The contact person responsible for the corrective action is Ginger Moses, OCD Chief Operating Officer. Once approved by HUD, the anticipated completion date for this corrective action plan will coincide with the closing of the SRPP program.If you have questions or require additional information, please feel free to contact me.
View Audit 312391 Questioned Costs: $1
Dear Mr. Waguespack,Please find below our management response to the audit finding "Noncompliance with Subrecipient Monitoring Requirements".The University does not concur that this is a second consecutive year finding, but in fact the same one from FY2021.The completion of FY2021 audit and the star...
Dear Mr. Waguespack,Please find below our management response to the audit finding "Noncompliance with Subrecipient Monitoring Requirements".The University does not concur that this is a second consecutive year finding, but in fact the same one from FY2021.The completion of FY2021 audit and the start of FY2022 audit did not allow the University time in between to correct the FY2021 finding.The following is timeline for the FY2021 finding.? Notification of potential finding was issued on 5/26/22.? Preliminary response request was issued on 5/26/2022.? Preliminary finding response was submitted on 6/2/2022.? Audit response request letter was submitted on 6/6/22.? Audit response was submitted on 6/13/22.Sponsored Programs Finance Administration and Compliance (SPFAC) will continue the following corrective action provided in FY2021 and it will be overseen by Director of SPFAC.1. Continue with our procedures to adequately monitor subrecipients.2. Implement a risk assessment questionnaire and have Senior SPFAC staff complete one for every sub recipient per 2 CFR 200.332 (f).
Management has stressed the criticality of prompt submission through comprehensive globalcommunications from the corporate headquarters. This directive will emphasize coordinating withvarious departmental heads to reinforce the requirement across different levels of the organization.Management is im...
Management has stressed the criticality of prompt submission through comprehensive globalcommunications from the corporate headquarters. This directive will emphasize coordinating withvarious departmental heads to reinforce the requirement across different levels of the organization.Management is implementing a worldwide procurement system to structure the current reportingframework.
Finding 425605 (2022-016)
Significant Deficiency 2022
REFERENCE: 2022-016 ? Subrecipient MonitoringResearch and Development Cluster (12.420, 93.279, 93.853, and 93.866)Federal Grantor: U.S. Department of Defense and U.S. Department of Health and Human ServicesFacility: St. Joseph?s Hospital and Medical CenterFinding: St. Joseph?s Hospital and Medical C...
REFERENCE: 2022-016 ? Subrecipient MonitoringResearch and Development Cluster (12.420, 93.279, 93.853, and 93.866)Federal Grantor: U.S. Department of Defense and U.S. Department of Health and Human ServicesFacility: St. Joseph?s Hospital and Medical CenterFinding: St. Joseph?s Hospital and Medical Center?s subrecipient monitoring tracking document, while designed appropriately, is not being maintained effectively and includes errors, since line items on the tracking document for several subrecipients appear to be incorrect with regards to audit findings. Findings appear to have been left off of the tracking document or added incorrectly for a particular subrecipient or may not apply to the subrecipient but to a different subrecipient.Corrective Action Plan: To check for completeness and accuracy, additional review of the subrecipient monitoring tracking document will completed by the Division Director Research Administration and System Director Grant Accounting.Person Responsible: Sheri Sanders, Division Director Research Administration and Jenny Lewis-Whelan, System Director Grant AccountingExpected Completion: June 2023
REFERENCE: 2022-011 ? Special Tests and Provisions ? Key PersonnelResearch and Development Cluster (Multiple)Federal Grantor: U.S. Department of DefenseU.S. Department of Health and Human ServicesFacility: St. Joseph?s Hospital and Medical CenterFinding: St. Joseph?s Hospital and Medical Center?s in...
REFERENCE: 2022-011 ? Special Tests and Provisions ? Key PersonnelResearch and Development Cluster (Multiple)Federal Grantor: U.S. Department of DefenseU.S. Department of Health and Human ServicesFacility: St. Joseph?s Hospital and Medical CenterFinding: St. Joseph?s Hospital and Medical Center?s internal controls over key personnel were not designed and operating effectively since level of effort certifications were not completed and signed timely by key personnel on grants.Corrective Action Plan: On a quarterly basis, program managers and grant managers meet with the principal investigator on all of their federal grants. During the meeting, level of effort is reviewed and certified by PI?s.Person Responsible: Research Ops Managers; Tomas Cortez, Grant Accounting ManagerCompletion: September 2022
Finding Number 2022-204: $196,247,971 was not properly identified as covid-19 funds on the statewide Schedule of Expenditures of Federal Awards (SEFA).Federal Programs:10.551 - Supplemental Nutrition Assistance Program (SNAP)10.557 - WIC Special Supplemental Nutrition Program for Women, Infants, and...
Finding Number 2022-204: $196,247,971 was not properly identified as covid-19 funds on the statewide Schedule of Expenditures of Federal Awards (SEFA).Federal Programs:10.551 - Supplemental Nutrition Assistance Program (SNAP)10.557 - WIC Special Supplemental Nutrition Program for Women, Infants, and Children10.561 - State Administrative Matching Grants for the Supplemental Nutrition Assistance Program64.005- Grants to States for Construction of State Home Facilities84.181 - Special Education - Grants for Infants and Families84.425R - Education Stabilization Fund - Emergency Assistance for Non-Public Schools93.391 - Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises93.497 - Family Violence Prevention and Services/ Sexual Assault/Rape Crisis Services and Supports93.590 - Community-Based Child Abuse Prevention Grants93.958- Block Grants for Community Mental Health Services93.977 - Sexually Transmitted Diseases (STD) Prevention and Control Grants97.036 - Disaster Grants - Public Assistance (Presidentially Declared Disasters)Related to Prior Finding: N/AAgency?s view: The Office agrees with this finding.Corrective Action: Since the State began receiving COVID-19 funding, we diligently provided training and resources to the agencies regarding the funding and how it should be reported on the SEFA closing package. This includes a discussion in our annual closing package training, online resources regarding COVID-19 funds, an FAQ document, and being available to discuss questions and concerns. In addition to the steps we are currently taking, we will reiterate the importance of designating COVID-19 related expenditures on the SEFA closing package during our annual closing package training. We will review STARS activity in the COVID-19 related funds and compare to the agency submitted closing packages for reasonableness. Recognizing that not all agencies utilize these specific funds, we will also review COVID-19 related expenditures on an external online source that reports federal grant expenditures. We will then use this information to compare to what is reported on agency closing packages for reasonableness.Anticipated Corrective Action Date: Errors identified were corrected prior to issuance of the Single Audit report. We will work with agencies to ensure all COVID-19 funds are identified for FY23 reporting.Responsible for Corrective Action: Ethan Draves, Reporting and Review Bureau ChiefEdraves@sco.idaho.gov 208-334-3100
Finding Number 2022-202: The Commission did not complete required reports for the Federal Funding Accountability and Transparency Act (FFATA).Federal Programs: 93.044, 93.045, 93.053 ? Aging ClusterRelated to Prior Finding: N/AAgency?s view: The Commission agrees with this finding.Corrective Action:...
Finding Number 2022-202: The Commission did not complete required reports for the Federal Funding Accountability and Transparency Act (FFATA).Federal Programs: 93.044, 93.045, 93.053 ? Aging ClusterRelated to Prior Finding: N/AAgency?s view: The Commission agrees with this finding.Corrective Action: Federal Funding Accountability and Transparency Act (FFATA) reporting for federal fiscal years 2021, and 2022 have been completed as of March 27, 2023. The agency will complete FFATA reporting as awards are administered to sub-awardees going forward.Anticipated Corrective Action Date: March 27, 2023Responsible for Corrective Action: Joe Zaher, Senior Financial SpecialistJoe.zaher@aging.idaho.gov 208-577-2864
Finding 424941 (2022-205)
Significant Deficiency 2022
Finding Number 2022-205: An expenditure was made by the Department for unallowable activities from the Elementary and Secondary School Emergency Relief (ESSER) program.Federal Program: 84.425U - Education Stabilization Fund - ARPA ESSER IIIRelated to Prior Finding: N/AAgency?s view: The Department a...
Finding Number 2022-205: An expenditure was made by the Department for unallowable activities from the Elementary and Secondary School Emergency Relief (ESSER) program.Federal Program: 84.425U - Education Stabilization Fund - ARPA ESSER IIIRelated to Prior Finding: N/AAgency?s view: The Department agrees with this finding.Corrective Action: When the Elementary and Secondary School Emergency Relief Funds {ESSER) were first awarded, it was not required that districts attach any documentation to their Grant Reimbursement Application {GRA) requests. Federal Programs will start requiring that all requests coming in through the GRA system have supporting documentation attached as of July 1, 2023, which is the beginning of our next fiscal cycle.Anticipated Corrective Action Date: We will announce this new procedure through emails and during our state-wide Consolidated Federal and State Grant Application training in April and May2023.Responsible for Corrective Action: Gideon Tolman, Chief Financial Officergtolman@sde.idaho.gov 208-332-6874
View Audit 312368 Questioned Costs: $1
Finding Number 2022-206: The Department did not complete required subrecipient monitoring of the Elementary and Secondary School Emergency Relief (ESSER) Fund of the Education Stabilization Fund.Federal Programs:84.425U - Education Stabilization Fund ? ARPA ESSER III84.425D - Education Stabilization...
Finding Number 2022-206: The Department did not complete required subrecipient monitoring of the Elementary and Secondary School Emergency Relief (ESSER) Fund of the Education Stabilization Fund.Federal Programs:84.425U - Education Stabilization Fund ? ARPA ESSER III84.425D - Education Stabilization Fund - Elementary and Secondary School Emergency Relief Fund84.425W - Education Stabilization Fund - ARPA ESSER - Homeless Children and Youth84.425R - Education Stabilization Fund - Emergency Assistance for Non-Public SchoolsRelated to Prior Finding: 2021-204Agency?s view: The Department agrees with this finding.Corrective Action: It was not until the end of the 2022 legislative session that spending authority was given to the State Department of Education to use ARP ESSER Sincerely, administrative funds to hire additional staff to meet the robust requirements identified by the U.S. Department of Education. Up to that point, only one full-time person was handling all of the needs associated with ESSER funds. Since then, two positions have been hired. The ESSER Data and Reporting Coordinator began in April 2022, and the ESSER Monitoring Coordinator began in June 2022. While developing the monitoring procedures began in July 2022, it was after the audit timeframe. The Department now has in place all ESSER monitoring policies and procedures and will complete year one monitoring before May 5, 2023.Anticipated Corrective Action Date: May 2023Responsible for Corrective Action: Gideon Tolman, Chief Financial Officergtolman@sde.idaho.gov 208-332-6874
Finding 424935 (2022-210)
Significant Deficiency 2022
Finding Number 2022-210: The Department did not review subrecipient application information for Coronavirus State and Local Fiscal Recovery Funds at a sufficient level to identify missing information from required documentation.Federal Program: 21.027 - Coronavirus State and Local Fiscal Recovery Fu...
Finding Number 2022-210: The Department did not review subrecipient application information for Coronavirus State and Local Fiscal Recovery Funds at a sufficient level to identify missing information from required documentation.Federal Program: 21.027 - Coronavirus State and Local Fiscal Recovery FundsRelated to Prior Finding: N/AAgency?s view: The Department agrees with this finding.In the rush to respond to emergency needs during the pandemic and the non-traditional format these funds were distributed, the Department neglected to properly review and hold incomplete attestation applications. The attestation application process was specifically developed under the pandemic, was a new process for staff, and was during the time period of transitioning from DUNS to Unique Identifier. Additionally, staff not typically involved in the subrecipient process approved the applications for payment and did not know to hold payments if the unique identifier field was blank. Finally, attestation documents did not route through the traditional internal processes where controls would have identified the gap. After funds were distributed and the misstep was realized, the Department verified Unique Identifiers through SAMS registration or by reaching out directly to the hospitals for documented proof. At the time of the audit, we did not have documentation of a unique identifier for two (2) hospitals out of the forty-three (43) awarded, but that information has subsequently been obtained.The attestation process has since been discontinued. Internal controls are in place as the Department procurement policy; staff are trained to check SAM.gov on all subrecipients. Additionally, internal forms needed to execute a subrecipient agreement require documentation of the Unique Identifier. If the Unique Identifier field is left blank, the Department Contracts and Procurement Unit will not process the agreement request. This finding was a result of a new process and untrained staff pulled into the rapid dispersal of COVID funds.Corrective Action: Corrective action is complete. Internal controls are in place as the Department procurement policy; staff are trained to check SAM.gov on all subrecipients. Additionally, internal forms needed to execute a subrecipient agreement require documentation of the Unique Identifier. If the Unique Identifier field is left blank, the Department Contracts and Procurement Unit will not process the agreement request. This finding was a result of a new process and untrained staff pulled into the rapid dispersal of COVID funds.Anticipated Corrective Action Date: Corrective action has been taken as of April 2023Responsible for Corrective Action: Kelly Combs, Bureau Chief, Compliancekelly.combs@dhw.idaho.gov 208-334-5814
Finding 424932 (2022-203)
Significant Deficiency 2022
Office of the State ControllerFinding Number 2022-203: Errors in the elimination process between state agencies resulted in misstatements to the Schedule of Expenditures of Federal Awards (SEFA) totaling $14,656,928 for direct awards and $14,278,362 for expenditures provided to subrecipients.Federal...
Office of the State ControllerFinding Number 2022-203: Errors in the elimination process between state agencies resulted in misstatements to the Schedule of Expenditures of Federal Awards (SEFA) totaling $14,656,928 for direct awards and $14,278,362 for expenditures provided to subrecipients.Federal Programs:21.027 - State and Local Fiscal Recovery Fund84.334S - Gaining Early Awareness and Readiness for Undergraduate ProgramsRelated to Prior Finding: N/AAgency?s view: The Office agrees with this finding.Corrective Action: We will improve our elimination and reporting process by adding the following steps:? We will add an additional tab to our SEFA Master file to cross check all COVID-19 related funding to ensure agencies are not double reporting expenditures.? We will add additional steps to our SEFA preparation and review checklist outlining specific steps for completing the subrecipient elimination process, and identify higher risk areas that require the most scrutiny.? We will also improve our current elimination tab (awards received from other state agencies) and reconciliation procedures for subrecipients.Anticipated Corrective Action Date: Errors identified were corrected prior to issuance of the Single Audit report. Changes to the subrecipient reporting process will occur for FY23 reporting.Responsible for Corrective Action: Ethan Draves, Reporting and Review Bureau ChiefEdraves@sco.idaho.gov 208-334-3100
Finding 424930 (2022-207)
Significant Deficiency 2022
Finding Number 2022-207: The amount reported as passed through to subrecipients on the Schedule of Expenditures of Federal Awards (SEFA) closing package was overstated by $331,500.Federal Programs:15.605 - Sport Fish Restoration15.611 - Wildlife Restoration and Basic Hunter EducationRelated to Prior...
Finding Number 2022-207: The amount reported as passed through to subrecipients on the Schedule of Expenditures of Federal Awards (SEFA) closing package was overstated by $331,500.Federal Programs:15.605 - Sport Fish Restoration15.611 - Wildlife Restoration and Basic Hunter EducationRelated to Prior Finding: N/AAgency?s view: The Department agrees with this finding.Corrective Action: The Department will provide additional training and update its procedural documentation to ensure that expenses are thoroughly vetted before they are reported as subrecipient expenditures on the SEFA. Each expenditure identified as a subrecipient expense will be tied back to a specific subaward, further limiting the possibility of non-subaward expenses being reported in the subrecipient portion of the SEFA.Anticipated Corrective Action Date: This corrective action plan will be implemented by the end of August 2023.Responsible for Corrective Action: Michael Pearson, Chief, Bureau of Administrationmichael.pearson@idfg.idaho.gov(208) 287-2800Jon Oswald, Financial Managerjonathan.oswald@idfg.idaho.gov(208) 287-2820
Finding Number 2022-209: An annual physical inventory was not completed for all storage facilities used by sub-distributing agencies for the Emergency Food Assistance Program as required by federal guidance.Federal Program: 10.568 - Emergency Food Assistance ProgramRelated to Prior Finding: N/AAgenc...
Finding Number 2022-209: An annual physical inventory was not completed for all storage facilities used by sub-distributing agencies for the Emergency Food Assistance Program as required by federal guidance.Federal Program: 10.568 - Emergency Food Assistance ProgramRelated to Prior Finding: N/AAgency?s view: The Department agrees with this finding.Corrective Action: The Department questioned and relied upon an opinion from the National Office of USDA Food and Nutrition Service (FNS), which administers TEFAP, affirming the Department?s interpretation of the regulations for this program. Dixon, R. (2023) Email to Cho Heide, March 23. In that opinion the Department asserted and FNS agreed that the requirements for an annual physical review of food inventories only applies to storage facilities used by the state distributing agency or sub-distributing agencies (as defined in 7 CFR 250.2). The Department has always considered the organizations with which we have subgrant agreements for TEFAP to be eligible recipient agencies (as defined in 7 CFR 251.3), not sub-distributing agencies. The Department provided this information to LSO auditors but on review with them as relates to the compliance supplement for this program, it became clear that the guidance from FNS was not authoritative and therefore, did not supersede the compliance supplement. With this knowledge, the Department will work with FNS to clarify requirements within the compliance supplement, revising our control process in this program accordingly.Anticipated Corrective Action Date: July 2023Responsible for Corrective Action: Kelly Combs, Bureau Chief, Compliancekelly.combs@dhw.idaho.gov 208-334-5814
Finding Number 2022-212: The Department did not maintain consistent operation of controls and compliance with Electronic Benefit Transfer (EBT) Card Security procedures for the Supplemental Nutrition Assistance Program (SNAP).Federal Programs:10.551 - Supplemental Nutrition Assistance Program (SNAP)...
Finding Number 2022-212: The Department did not maintain consistent operation of controls and compliance with Electronic Benefit Transfer (EBT) Card Security procedures for the Supplemental Nutrition Assistance Program (SNAP).Federal Programs:10.551 - Supplemental Nutrition Assistance Program (SNAP)10.561 - State Administrative Matching Grants for the Supplemental Nutrition Assistance ProgramRelated to Prior Finding: 2021-210Agency?s view: The Department agrees with this finding.Corrective Action: Immediately upon receiving the audit finding in March 2022, staffreviewed and revised procedures and fully implemented a corrective action plan by June 30, 2022. The entire EBT team was trained on the bulk card ordering and issuing process and modified security procedures to mitigate the risk of non-compliance in the future. The bulk card managers in the field offices review and reconcile card issuances monthly. Also, the EBT Supervisor documents the review of the previous quarter?s electronic card audits for accuracy and completeness.Anticipated Corrective Action Date: See corrective action above.Responsible for Corrective Action: Kelly Combs, Bureau Chief, Compliancekelly.combs@dhw.idaho.gov 208-334-5814
Finding: 2022-026 - FY 22 Federal Funding Accountability and Transparency Act subaward reporting for Elementary and Secondary School Emergency Relief Fund (ESSER) and American Rescue Plan ? Elementary and Secondary School Emergency Relief Fund (ARP ESSER) did not occur for 72 subawards.Questioned Co...
Finding: 2022-026 - FY 22 Federal Funding Accountability and Transparency Act subaward reporting for Elementary and Secondary School Emergency Relief Fund (ESSER) and American Rescue Plan ? Elementary and Secondary School Emergency Relief Fund (ARP ESSER) did not occur for 72 subawards.Questioned Costs: NoneAssistance Listing Number: 84.425D; 84.425UAssistance Listing Title: ESSER ? COVID-19; ARP ESSER ? COVID-19Views of Responsible Officials (state whether your agency agrees or disagrees with the finding; if you disagree, briefly explain why): The department partially agrees with Finding 2022-026. The department agrees with the count of 72 separate awards not being reported, however the department disagrees with the specific dollar amount listed as ESSER II subawards were not reported. The amount listed is missing $5,483. This amount was awarded to a school district that also received ESSER II SEA Reserve funding under the same grant award and the FFATA reporting system has no mechanism to differentiate between mandatory funding and SEA Reserve funding. Per 2 CFR ? 170.220(b) and FFATA guidance documents, if an award increases to greater than the $30,000 reporting threshold, the full amount of the award must be reported, not just the portion that exceeded the threshold.Corrective Action (corrective action planned): Both the procedures and the financial report used to populate the FFATA reporting have been updated. Department staff have been working with the FFATA help desk for approximately two years, through multiple help desk tickets, and have not been able to make the corrections despite repeated, ongoing follow-up, and intervention by the U.S. Department of Education. The department has not submitted FFATA reporting since April 2022 as most activity for the noted assistance listings is only relevant to reports the department could not access. The FFATA help desk did successfully make those reports accessible again as of February 21, 2023, and the department has since completed the ESSER I (ALN 84.425D) FFATA reporting corrections as of March 3, 2023. The department will make the necessary ESSER II (ALN 84.425D) and ESSER III (ALN 84.425U) corrections and resume normal FFATA reporting as soon as reasonably possible.Completion Date (list anticipated completion date): October 1, 2023Agency Contact (name of person responsible for corrective action): Stephanie Allison, Division Operations Manager, Division of Administrative Services
Finding 422844 (2022-027)
Significant Deficiency 2022
Finding: 2022-027 ? Department of Education and Early Development staff did not document risk assessments for non-Local Educational Agency (LEA) subrecipients.Questioned Costs: NoneAssistance Listing Number: 84.425D; 84.425UAssistance Listing Title: ESSER ? COVID-19; ARP ESSER Fund ? COVID-19Views o...
Finding: 2022-027 ? Department of Education and Early Development staff did not document risk assessments for non-Local Educational Agency (LEA) subrecipients.Questioned Costs: NoneAssistance Listing Number: 84.425D; 84.425UAssistance Listing Title: ESSER ? COVID-19; ARP ESSER Fund ? COVID-19Views of Responsible Officials (state whether your agency agrees or disagrees with the finding; if you disagree, briefly explain why): The department agrees with Finding 2022-027.Corrective Action (corrective action planned): Risk assessments for the FY2023 grant year are being done prior to grant payments for all grantees. Program staff have also implemented formal subrecipient monitoring in FY2023.Completion Date (list anticipated completion date): July 30, 2023Agency Contact (name of person responsible for corrective action): Deb Riddle, Division Operations Manager, Division of Innovation and Education Excellence
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