Corrective Action Plans

Finding 35099 (2022-001)

Significant Deficiency 2022

AK

Subrecipient Monitoring Reporting Significant Deficiency

Federal Award Finding Finding 2022-001 Lack of Internal Controls and Noncompliance over Subrecipient Monitoring Name of Contact Person: Dora Cross, Finance Director Corrective Action Plan: The Borough Manager will either assign grant-related monitoring staff in the finance department or ensure th...

Federal Award Finding Finding 2022-001 Lack of Internal Controls and Noncompliance over Subrecipient Monitoring Name of Contact Person: Dora Cross, Finance Director Corrective Action Plan: The Borough Manager will either assign grant-related monitoring staff in the finance department or ensure that non-finance department staff assigned to a grant participate in grant training to ensure they are fully aware of subrecipient monitoring requirements. Proposed Completion Date: December 31, 2022

View Audit 31987

Finding 34987 (2022-001)

Significant Deficiency 2022

New Mexico Aging and Long-Term Services Department

NM

Subrecipient Monitoring Significant Deficiency

Corrective Action: Programmatic monitoring is included in the Department?s State Unit on Aging ACL State Plan and in the contracts for the Area Agencies on Aging. The Department will develop an internal policy and procedures to address program monitoring by December 31, 2022. The Department also ...

Corrective Action: Programmatic monitoring is included in the Department?s State Unit on Aging ACL State Plan and in the contracts for the Area Agencies on Aging. The Department will develop an internal policy and procedures to address program monitoring by December 31, 2022. The Department also has in the AAA contracts the annual submission of audits and reviews the AAA monthly invoices and back-up documentation for reimbursement verification. Timeline of Corrective Actions: December 31, 2022 Responsible Party(ies): Aging Network Division Director

View Audit 34757

Finding 34947 (2022-001)

None 2022

Pacific School of Religion

CA

Student Financial Aid Matching / Level of Effort / Earmarking Subrecipient Monitoring

December 1, 2022 U.S. Department of Education 400 Maryland Avenue SW Washington, DC 20202 Re: Corrective Action Plan Pacific School of Religion (PSR) respectfully submits the following corrective action plan for the year ended June 30, 2022. Audit period: July 01, 2021 through June 30, 2022 The find...

December 1, 2022 U.S. Department of Education 400 Maryland Avenue SW Washington, DC 20202 Re: Corrective Action Plan Pacific School of Religion (PSR) respectfully submits the following corrective action plan for the year ended June 30, 2022. Audit period: July 01, 2021 through June 30, 2022 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Finding 2022-001 Enrollment Reporting Criteria: Title IV regulations (34 CFR 685.309(b)) require that upon receipt of an enrollment report from the Secretary, institutions must update all information included in the report and return the report to the Secretary: (i) in the manner and format prescribed by the Secretary: and (ii) within the timeframe prescribed by the Secretary. Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, an institution must notify the Secretary within 30 days after the date the institution discovers that: (i) a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the institution, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least half-time basis for the period for which the loan was intended; or (ii) a student who is enrolled at the institution and who received a loan under Title IV of the Act has changed his or her permanent address. Recommendation: The School should revise its procedures to ensure accurate enrollment information is sent to NSLDS with the required timeframe for all students. Corrective Action Plan: Procedural changes implemented by the school during the Spring 2022 semester that allow for more frequent and timely enrollment reporting will correct this type of enrollment reporting error going forward. In addition, school administration will update procedures to verify status start dates for any enrollment changes specifically match the student?s enrollment in the student information system. Sincerely, Natasha Lee Vice President for Finance and Administration

View Audit 34647

Finding 34936 (2022-001)

Material Weakness 2022

Lebanon Community School Corporation

IN

Questioned Costs Internal Control / Segregation of Duties Cash Management § 200.303

Finding 2022-001 Subject: Medicaid ? Eligibility, Other Matters Audit Findings: Material Weakness Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the eligibility compliance...

Finding 2022-001 Subject: Medicaid ? Eligibility, Other Matters Audit Findings: Material Weakness Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the eligibility compliance requirements that are performed by the Special Education Cooperative on behalf of the School Corporation. Context: The School Corporation participates in a Special Education Co-op. In 2015, the Co-op provided an avenue through a third-party company, for the member school districts to obtain reimbursement for Medicaid services. It was discovered in 2021 that the yearly parental disclosure statements had not been completed for Medicaid eligibility compliance. Due to this oversight, each member school has had to voi transactions through the third-party company and pay back the amount of these transactions from August 9, 2015 through April 23, 2021. The School Corporation?s amount owed was $481,276 for the period identified during 2015-2021. The School Corporation completed a Voluntary Self-Disclosure of Provider of Overpayments Packet through the Indiana Family & Social Services Administration?s Office of Medicaid Policy and Planning Office to reimburse the amounts owed. The amount related to this period July 1, 2020 through June 30, 2022 was indeterminable. The full amount was paid back prior to June 30, 2021. Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Parental disclosure statements are completed annually for Medicaid eligibility compliance. This has already been implemented. Responsible Party and Timeline for Completion: Madeline Sandberg, Director of BCNWH Joint Services, 7/1/2021

View Audit 32733 Questioned Costs: $1

Finding 34910 (2022-005)

Material Weakness 2022

Lebanon Community School Corporation

IN

Subrecipient Monitoring Allowable Costs / Cost Principles Material Weakness § 200.303 § 200.309 § 200.343 § 200.461

FINDING 2022-005 Subject: Special Education Cluster ? Period of Performance Audit Findings: Material Weakness Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the equipment ...

FINDING 2022-005 Subject: Special Education Cluster ? Period of Performance Audit Findings: Material Weakness Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the equipment requirements of the Period of Performance compliance requirement. Context: The School Corporation was a member of a joint service cooperative (Cooperative). The Cooperative operated the special education programs on behalf of the School Corporation and managed the special education grant funds. Because the grant agreements were between the Indiana Department of Education and the School Corporation, the School Corporation was ultimately responsible for compliance with the grant agreement and the Period of Performance compliance requirement. During fiscal year 2021, the School Corporation paid membership fees to the Cooperative out of federal Special Education funds. These membership fees made up approximately 48% of the total federal expenditures reimbursed during fiscal year 2021. The Cooperative accounted for state, local, and federal funds in a single fund. The fund did not separately account for each of the funding sources. This made it difficult to identify which expenditures were from federal funds, or to identify expenditures by federal program, award number, or years. Therefore, we could not test compliance with the period of performance requirements for approximately 48% of the expenditures. The School Corporation did not have adequate procedures in place to ensure that the Cooperative complied with the period of performance requirements. The Cooperative did not have adequate procedures in place to ensure that costs were charged to the programs only during the period of performance, or that all obligations were liquidated within 90 days of the end of the period of performance. The lack of internal controls and noncompliance were systemic issues, which occurred specifically during fiscal year 2021. No reportable findings were noted for fiscal year 2022. Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Members of the cooperative are no longer paying their cooperative member fees with federal funds. This was resolved effective 7/1/2021. Responsible Party and Timeline for Completion: Zach Dennis, CFO, 7/1/2021

View Audit 32733

Finding 34902 (2022-003)

Material Weakness 2022

Garrett-Keyser-Butler Community School District

IN

Internal Control / Segregation of Duties Allowable Costs / Cost Principles Material Weakness § 200.303

Finding 2022-003 ? Head Start - Activities Allowed or Unallowed, Allowable Costs- Cost Principles Contact Person Responsible for Corrective Action: Brittany Treesh Contact Phone Number: 260-357-3185 Views of Responsible Official: The school corporation concurs with the finding. Description ...

Finding 2022-003 ? Head Start - Activities Allowed or Unallowed, Allowable Costs- Cost Principles Contact Person Responsible for Corrective Action: Brittany Treesh Contact Phone Number: 260-357-3185 Views of Responsible Official: The school corporation concurs with the finding. Description of Corrective Action Plan: The school corporation will implement additional internal controls to make sure all timesheets have been received and signed by supervisors prior to payroll being completed. Anticipated Completion Date: Garrett-Keyser-Butler Community School District is no longer the LEA for the Head Start Program. However, this will be implemented immediately at the corporation.

View Audit 32731

Finding 34867 (2022-002)

None 2022

Universidad Interamericana De Puerto Rico, Inc.

PR

Student Financial Aid Subrecipient Monitoring Reporting

Enrollment Reporting Student - Rodriguez Peria, Joan; ID #M00601823; Term 2022-13 Cause The student's Graduated (G) status was not reported to the NSLDS. The student's graduation application was dated December 2, 2021, but was not paid and submitted until February 12, 2022. The student's degree ...

Enrollment Reporting Student - Rodriguez Peria, Joan; ID #M00601823; Term 2022-13 Cause The student's Graduated (G) status was not reported to the NSLDS. The student's graduation application was dated December 2, 2021, but was not paid and submitted until February 12, 2022. The student's degree was certified in our Banner system on February 23, 2022. By the certification date, the "Graduate-Only" file transmissions to the Clearinghouse (NSCH) for the 2022-13 term had ceased. Once the file transmission for a term ceases, any cases has to be manually reported at NSLDS. Unfortunately, this case was not reported to NSLDS. Action Once the circumstances of this case were identified, the student's status update to a (G) Graduate in NSLDS has been intended several instances over the past few weeks and is still in process due to problems with the NSLDS modernized website. The Electronic Announcement ID: GENERAL-22-76 reports open issues with the NSLDS modernized website. Corrective Action Plan According to the Graduation Certification Calendar submitted to the registrars, we will develop a monitoring process to identify students certified as graduate past the certification deadline. These students will be referred to the registrars for immediate certification at the NSLDS and to the Management Compliance Office for verification at the NSLDS. Contact persons: Mrs. Patricia Alvarez, Ph. D. Associate Vice President of Academic Affairs Prof. Evelyn Aviles Institutional Director for Academic Affairs and Student Services

View Audit 31533

Finding 34810 (2022-002)

Material Weakness 2022

Triad Local School District

OH

Subrecipient Monitoring Cash Management School Nutrition Programs § 200.208 § 200.305

Finding Number: 2022-002 Planned Corrective Action: The District has initiated an internal audit reconciliation system to confirm each month that all reimbursable breakfast and lunch reports agree. Anticipated Completion Date: 07/01/2022 Responsible Contact Person: Neil Laughbaum, Director of Oper...

Finding Number: 2022-002 Planned Corrective Action: The District has initiated an internal audit reconciliation system to confirm each month that all reimbursable breakfast and lunch reports agree. Anticipated Completion Date: 07/01/2022 Responsible Contact Person: Neil Laughbaum, Director of Operations

View Audit 32571

Finding 34788 (2022-005)

Significant Deficiency 2022

Panthera Corporation

NY

Subrecipient Monitoring § 200.332

Panthera has now adopted the implementation of the Federal Assistance Listing Numbers on each agreement with subrecipients, and will ensure a formal approval is issued on all expenditure reports.

View Audit 34492

Finding 34760 (2022-003)

Material Weakness 2022

Snohomish County

WA

Matching / Level of Effort / Earmarking Subrecipient Monitoring

See Corrective Action Plan for chart/table

View Audit 34269

Finding 34753 (2022-001)

Significant Deficiency 2022

Jobpath, Inc.

AZ

Subrecipient Monitoring Reporting

To ensure the timely submission of the monthly participant report to the pass-through entity, JobPath has modified its current process, submitting the report by the required deadline, separately from the invoice, which is due later in the month. By the next reporting date of April 5th, reports will ...

To ensure the timely submission of the monthly participant report to the pass-through entity, JobPath has modified its current process, submitting the report by the required deadline, separately from the invoice, which is due later in the month. By the next reporting date of April 5th, reports will be reviewed internally by supervisory personnel who did not prepare the report. The CEO will ensure these actions are taken. To ensure reporting accuracy, JobPath will create and maintain an electronic journal documenting individual participant funding assignments and any changes made to the funding sources, including the date, the person making the change, and the reason for the change. Only individuals with the appropriate roles and authority will have editing access. The CEO will ensure this action is implemented by the next reporting date of April 5th. Additionally, JP will work with the platform developer to add the necessary features so that changes are automatically documented and maintained and historical data/reports can be generated for control purposes. The Director of Operations will ensure this action is taken by June 30th.

View Audit 37765

Finding 34744 (2022-002)

Significant Deficiency 2022

West Central Wisconsin Workforce Development Board, Inc.

WI

Matching / Level of Effort / Earmarking Subrecipient Monitoring Significant Deficiency

Earmarking Requirements Recommendation: We recommend West Central Wisconsin Workforce Development Board, Inc.?s implement systems, procedures and training to ensure that earmarking requirements are met. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. ...

Earmarking Requirements Recommendation: We recommend West Central Wisconsin Workforce Development Board, Inc.?s implement systems, procedures and training to ensure that earmarking requirements are met. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: The entity has addressed this in the current year by providing additional training and expectations set forth to the subrecipient (WRI). Additionally, the Board has worked with DWD to ensure the requirement will be met in the current year. Name of the contact person responsible for corrective action: Jon Menz Planned completion date for corrective action plan: June 30, 2023 If involved agencies have any questions regarding this plan, please call Jon Menz at 715-235-8393

View Audit 36864

Finding 34743 (2022-001)

Significant Deficiency 2022

Stepping Out Housing, Inc.

CA

Subrecipient Monitoring HUD Housing Programs

Corrective Action Plan For the Year Ended June 30, 2022 Finding 2022-001 Corrective Action Plan: The Organization is in the process of establishing monthly closing procedures to ensure timely monthly deposits to the replacement reserve account. In addition, the additional monthly deposits were depo...

Corrective Action Plan For the Year Ended June 30, 2022 Finding 2022-001 Corrective Action Plan: The Organization is in the process of establishing monthly closing procedures to ensure timely monthly deposits to the replacement reserve account. In addition, the additional monthly deposits were deposited into the reserve fund subsequent to year-end. Name of Responsible Person: Kim Morrison, CFO Anticipated Completion Date: December 31, 2022 Signed by Kim Morrison on October 12, 2022.

View Audit 35075

Finding 34720 (2022-003)

Significant Deficiency 2022

Alternatives, Inc.

IL

Cash Management Subrecipient Monitoring Reporting

Finding 2022-003 Adherence and Application of Financial Policies and Procedures for Vouchering Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: Illinois Department of Human Services Program Name: Social Services Block Grant Assistance Listing #: 93.667 Que...

Finding 2022-003 Adherence and Application of Financial Policies and Procedures for Vouchering Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: Illinois Department of Human Services Program Name: Social Services Block Grant Assistance Listing #: 93.667 Questioned Costs: None Corrective Action: We agree with the auditor?s comments and actions stated in the recommendation. The Organization is rewriting its accounting policies and procedures to ensure adherence to the proper procedures for vouchering, which will be completed in fiscal year 2024. In August 2022, the building at 4730 N. Sheridan was sold. During the move some documents were misfiled or otherwise missed place. This made it difficult to find vouchers for the audit. The new accounting system allows Alternatives to save a copy of the vouchers and necessary support within the software. The electronic filing of the backup documentation will prevent misplacement of vouchers in the future. Contact Person: Sonya Cook, Finance Director Anticipated Completion Date: December 15, 2023

View Audit 33247

Finding 34716 (2022-001)

Significant Deficiency 2022

Coos County Family Health Services, Inc.

ME

Subrecipient Monitoring Significant Deficiency Internal Control / Segregation of Duties

Finding Number: 2022-001 Condition Found: The Organization has not applied sliding fee discounts to patient charges consistent with its sliding fee discount program. Individual(s) Responsible for Corrective Action: Brenda Ladd-Front Office Manager Brandon Gilbert-Compliance Officer Corrective Ac...

Finding Number: 2022-001 Condition Found: The Organization has not applied sliding fee discounts to patient charges consistent with its sliding fee discount program. Individual(s) Responsible for Corrective Action: Brenda Ladd-Front Office Manager Brandon Gilbert-Compliance Officer Corrective Action Planned: 1. The Front Office Manager will provide additional training to the Front Desk/Reception Staff. 2. Assign the Compliance Officer the task of performing monthly audits on 25 random sliding fee charges to verify patient eligibility and discount. The results of the monthly audits will be reported to the Chief Executive Officer, Chief Financial Officer, and the Revenue Cycle Manager. Anticipated Completion Date: 1. Retraining of Front Desk/Reception will begin immediately. 2. Monthly audits of 25 random sliding fee charges will begin immediately.

View Audit 32420

Finding 34711 (2022-002)

Material Weakness 2022

Fresno Pacific University and Subsidiaries

CA

Student Financial Aid Subrecipient Monitoring Material Weakness

Untimely Returns to Title IV (R2T4) Planned Corrective Action: We have trained and implemented processes to correctly determine period lengths and the earned and unearned percentages. We have increased the number of reports used to identify potential withdrawals. To correctly and timely process ...

Untimely Returns to Title IV (R2T4) Planned Corrective Action: We have trained and implemented processes to correctly determine period lengths and the earned and unearned percentages. We have increased the number of reports used to identify potential withdrawals. To correctly and timely process R2T4s, we outsourced the determination and calculation processes to a third-party vendor in November 2022 (this took longer than we anticipated). In March 2023, we were granted additional staffing resources and are in the process of hiring for those positions. To reduce the number of R2T4 calculations required, we also plan to switch from being an institution required to take attendance to a non-attendance taking institution for the 2023-2024 aid year. Person Responsible for Corrective Action Plan: Bryan Taylor, Associate Director of Student Financial Services Anticipated Date of Completion: May 2023

View Audit 37763

Finding 34707 (2022-006)

None 2022

City of South San Francisco

CA

Subrecipient Monitoring § 200.332 § 200.501

Finding Reference Number: SA2022-006 - Subrecipient Monitoring Assistance Listing Number: 21.027 Assistance Listing Title: COVID-19 ? Coronavirus State and Local Fiscal Recovery Funds Name of Federal Agency: Department of the Treasury Federal Award Identification Number: EES4XJFTXC28...

Finding Reference Number: SA2022-006 - Subrecipient Monitoring Assistance Listing Number: 21.027 Assistance Listing Title: COVID-19 ? Coronavirus State and Local Fiscal Recovery Funds Name of Federal Agency: Department of the Treasury Federal Award Identification Number: EES4XJFTXC28 ? Name(s) of the contact person: Karen Chang, Finance Director ? Corrective Action Plan: City will incorporate this information in our grant policy to ensure the program staff is aware of this requirement. ? Anticipated Completion Date: July 1, 2023

View Audit 36521

Finding 34704 (2022-005)

Material Weakness 2022

City of South San Francisco

CA

Questioned Costs Cash Management Subrecipient Monitoring § 200.305

Finding Reference Number: SA2022-005 - Cash Management ? Draw Down of Community Development Block Grant Funds in Advance of Expenditures Assistance Listing Number: 14.218 Assistance Listing Title: Community Development Block Grant ? Entitlement Grant COVID-19 - Community Development Bloc...

Finding Reference Number: SA2022-005 - Cash Management ? Draw Down of Community Development Block Grant Funds in Advance of Expenditures Assistance Listing Number: 14.218 Assistance Listing Title: Community Development Block Grant ? Entitlement Grant COVID-19 - Community Development Block Grants/ Entitlement Grants-CV Name of Federal Agency: Department of Housing and Urban Development Federal Award Identification Number: B-21-MC-06-0042 COVID-19 ? B-20-MW-06-0042 CDBG Daly City Pass Through #Not Available Name of Pass-through Entity: City of Daly City ? Name(s) of the contact person: Karen Chang, Finance Director ? Corrective Action Plan: The CDBG grant seldom involves a contract that has included a retention payable. Going forward, staff will double check contracts that have retention clauses and ensure the reimbursement submission does not include an unpaid retention. Staff will also check with the grantor to see if the City needs to reimburse the interest earned on the grant funds advanced. ? Anticipated Completion Date: December 31, 2023

View Audit 36521 Questioned Costs: $1

Finding 34698 (2022-003)

Material Weakness 2022

City of South San Francisco

CA

Subrecipient Monitoring Procurement, Suspension & Debarment Eligibility

Finding Reference Number: SA2022-003 - Monitoring of CDBG Program Activities For Compliance with Program Rules and Regulations Assistance Listing Number: 14.218 Assistance Listing Title: Community Development Block Grant ? Entitlement Grant COVID-19 - Community Development Block Grants/ ...

Finding Reference Number: SA2022-003 - Monitoring of CDBG Program Activities For Compliance with Program Rules and Regulations Assistance Listing Number: 14.218 Assistance Listing Title: Community Development Block Grant ? Entitlement Grant COVID-19 - Community Development Block Grants/ Entitlement Grants-CV Name of Federal Agency: Department of Housing and Urban Development Federal Award Identification Number: B-21-MC-06-0042 COVID-19 ? B-20-MW-06-0042 CDBG Daly City Pass Through #Not Available Name of Pass-through Entity: City of Daly City ? Name(s) of the contact person: Nell Selander, ECD Director/ Karen Chang, Finance Director ? Corrective Action Plan: It should be noted that the City does not agree with all of the findings made by HUD and is actively evaluating whether findings will be disputed or corrective action taken. For example, Finding 2023-01-B may be disputed, as the City?s CDBG Committee and City Council meet to evaluate requests for funding. These meetings are captured in audio (and in some cases video) recordings, minutes produced, and recommendations summarized in staff reports. Additionally, staff do not agree with Finding 2023-02-A, that a grant-based accounting system must be used to manage CDBG. There is currently a system in place to track and report revenue and expenditures for CDBG. Finance will bolster this system by using the project accounting module in Eden to manage future CDBG projects to increase efficiency and promote transparency. Given the extensiveness of the findings made in the HUD monitoring letter and the need to coordinate with multiple subgrantees and internal departments, the City has requested an extension to respond, which was granted by HUD to extend the response date to June 8, 2023. To address any corrective action needed as a result of HUD?s findings, ECD is in the process of updating the CDBG grant management manual, in coordination with Finance. During the past several years, both ECD and Finance have experienced staff turnover. Both departments are working closely to ensure staff are familiar with the latest CDBG program procedural manual, purchasing guidelines, and financial management policy to ensure record keeping is done properly and transparently. ? Anticipated Completion Date: July 1, 2023

View Audit 36521

Finding 34695 (2022-002)

Material Weakness 2022

City of South San Francisco

CA

Subrecipient Monitoring Reporting

Finding Reference Number: SA2022-002 - Federal Funding Accountability and Transparency Act (FFATA) Reporting Assistance Listing Number: 14.218 Assistance Listing Title: Community Development Block Grant ? Entitlement Grant COVID-19 - Community Development Block Grants/ Entitlement Grants...

Finding Reference Number: SA2022-002 - Federal Funding Accountability and Transparency Act (FFATA) Reporting Assistance Listing Number: 14.218 Assistance Listing Title: Community Development Block Grant ? Entitlement Grant COVID-19 - Community Development Block Grants/ Entitlement Grants-CV Name of Federal Agency: Department of Housing and Urban Development Federal Award Identification Number: B-21-MC-06-0042 COVID-19 ? B-20-MW-06-0042 CDBG Daly City Pass Through #Not Available Name of Pass-through Entity: City of Daly City ? Name(s) of the contact person: Karen Chang, Finance Director ? Corrective Action Plan: Staff were not aware of this requirement. The city is going to incorporate this requirement in the grant procedural manual to ensure the grant program manager understands the reporting requirements under the FFATA. ? Anticipated Completion Date: July 1, 2023

View Audit 36521

Finding 34693 (2022-002)

Material Weakness 2022

Josephine County, Oregon

OR

Subrecipient Monitoring § 200.331

Management of Josephine County has acknowledged that evidence of subrecipient monitoring and risk assessments were not retained in the file. While vetting was done on subrecipients a risk assessment form was not formally written. We have addressed it by providing training to central staff as well as...

Management of Josephine County has acknowledged that evidence of subrecipient monitoring and risk assessments were not retained in the file. While vetting was done on subrecipients a risk assessment form was not formally written. We have addressed it by providing training to central staff as well as department staff who have responsibility over grants. Further, a dedicated staff member will be responsible for monitoring grant compliance and completing risk assessments that were not done based on the vetting process that did occur. Anticipated Completion date is June 30, 3023. The responsible contact person is Sandy Novak, Finance Director.

View Audit 36520

Finding 34682 (2022-003)

Significant Deficiency 2022

Suffolk County, New York

NY

Questioned Costs Eligibility Student Financial Aid

REFERENCE # 2022-003 ELIGIBILITY FOR INDIVIDUALS ? NONCOMPLIANCE Program ADOPTION ASSISTANCE TITLE IV-E (Assistance Listing # 93.659) Identification Number(s) 18000 Finding New York State has enacted legislation which allows payments to be made for the care and maintenance of children when they are ...

REFERENCE # 2022-003 ELIGIBILITY FOR INDIVIDUALS ? NONCOMPLIANCE Program ADOPTION ASSISTANCE TITLE IV-E (Assistance Listing # 93.659) Identification Number(s) 18000 Finding New York State has enacted legislation which allows payments to be made for the care and maintenance of children when they are adopted. Suffolk County Department of Social Services (the ?Department?) provides a monthly adoption subsidy payment mandated by law for the care, maintenance, and/or medical needs of a child who fits the definition of handicapped or hard-to-place as defined by New York State law and regulations. Subsidy payments are available to all eligible children until the age of 21 regardless of the adoptive parent?s income. These payments are discontinued only when it is determined by a social service official that the adoptive parent(s) is no longer legally responsible for the support of the child or that the child is no longer receiving any support from the parent(s). Of the sixty (60) files selected for testing: ? Five (5) case file did not include the Home Studies narrative; and one (1) case file did not include the Criminal check form. Therefore, we were not able to determine if the eligible participants met all the eligibility criteria. Questioned Costs Cannot be determined. Recommendation We recommend the Department strengthen its monitoring controls over the adoption assistance case files to ensure the timely and accurate determination of eligibility. Corrective Action Plan With regards to the Criminal check form: Corrective Action Plan: It was found that one (1) case file did not include the criminal check form. The criminal check forms for this case was conducted when the children were in Foster Care and the results were included in the Foster Home record. Foster Home records are purged after eight (8) years of the home closing and no longer available. Currently: The criminal record check is included in the Adoption Subsidy file upon adoption as well as maintained in our Adoption vendor files. With regards to the Home Study narrative: Corrective Action Plan: It was found that five (5) cases did not include the Home Study narrative. The Home Study narratives for these case files were conducted when the homes were first certified as Foster Homes and were included in the Foster Home case record. Foster Home records are purged after eight (8) years of the home closing and no longer available. Currently: The Home Study narrative is included in the Adoption Subsidy file upon adoption as well as maintained in our Adoption vendor files. Action Date Record Check ? 2018 Home Study ? 2021 Final Implementation Date Record Check ? 2039 Home Study ? 2042 Name And Phone # Of Person Responsible For Implementation Carleen Newlands, Division Administrator 631-854-9626

View Audit 31089 Questioned Costs: $1

Finding 34680 (2022-004)

Significant Deficiency 2022

Suffolk County, New York

NY

Questioned Costs Eligibility Subrecipient Monitoring

REFERENCE # 2022-004 ELIGIBILITY FOR INDIVIDUALS ? NONCOMPLIANCE Program LOW-INCOME HOME ENERGY ASSISTANCE (ALN # 93.568) Identification Number(s) 21-LCM-15, 21-LCM-23, 22-LCM-06, and 23-LCM-01 Finding The New York State Office of Temporary and Disability Assistance is responsible for Low-Income Ene...

REFERENCE # 2022-004 ELIGIBILITY FOR INDIVIDUALS ? NONCOMPLIANCE Program LOW-INCOME HOME ENERGY ASSISTANCE (ALN # 93.568) Identification Number(s) 21-LCM-15, 21-LCM-23, 22-LCM-06, and 23-LCM-01 Finding The New York State Office of Temporary and Disability Assistance is responsible for Low-Income Energy assistance programs that provide assistance and support to eligible families and individuals. The Home Energy Assistance Program (HEAP) helps eligible New Yorkers heat and cool their homes. An eligibility family may receive one regular HEAP benefit per program year and could also be eligible for emergency HEAP benefits if you are in danger of running out of fuel or having utility service shut off. Of the sixty (60) files selected for testing: ? One (1) case file did not include the required documentation to support eligibility for HEAP. Therefore, we were not able to determine if the eligible participants met all the eligibility criteria. Questioned Costs Cannot be determined. Recommendation We recommend the Department strengthen its monitoring controls over the Low-Income Home Energy case files to ensure the timely and accurate determination of eligibility. Corrective Action Plan Staff will be reminded of the importance of scanning all applications and required documentation into the Imaging and Enterprise Document Repository to ensure that a complete and accurate case file is kept electronically for all cases. Action Date 9/20/2023 Final Implementation Date 2024 Name And Phone # Of Person Responsible For Implementation Loreta Keller 631-854-9920

View Audit 31089 Questioned Costs: $1

Finding 34669 (2022-003)

None 2022

Boys & Girls Clubs in Tennessee

TN

Reporting Subrecipient Monitoring Internal Control / Segregation of Duties § 200.414 § 200.502

Name of Responsible Individual(s): Jason Penegar, BGCA Vice President ? Controller Shelby Mahoney, Accounting Manager - State Alliances Corrective Action: Management will review grant agreements to confirm whether funding received from private entities are federal funds that should be reported on th...

Name of Responsible Individual(s): Jason Penegar, BGCA Vice President ? Controller Shelby Mahoney, Accounting Manager - State Alliances Corrective Action: Management will review grant agreements to confirm whether funding received from private entities are federal funds that should be reported on the SEFA. Anticipated Completion Date: December 31, 2023

View Audit 34598

Finding 34667 (2022-002)

Significant Deficiency 2022

Boys & Girls Clubs in Tennessee

TN

Subrecipient Monitoring Cash Management Reporting

Individual Responsible for Corrective Action Plan: Whitney Holliday, Director of Club Financial Services Corrective Action: Previous Process: The previous process was created prior to the current admin becoming the dedicated Financial Services leader on the Boys & Girls Clubs in TN/TN Alliance admi...

Individual Responsible for Corrective Action Plan: Whitney Holliday, Director of Club Financial Services Corrective Action: Previous Process: The previous process was created prior to the current admin becoming the dedicated Financial Services leader on the Boys & Girls Clubs in TN/TN Alliance admin team. All changes took place over the 2022/2023 grant cycles. Current Process: The previous process was overhauled to our current process in Q1 of 2022. Training and updates to the process were performed with 20 organizations throughout the year. We also implemented better direct communication with admin/staff 1:1s and a quarterly financial update call to continue training and best practice sharing. Process Update: A process update will be implemented beginning with July 2023 reimbursement requests/submissions to funders. These updates will be shared with individual Clubs with an expectation of full implementation by the end of Q3 2023. The admin will enhance its policies and procedures over sub-recipient monitoring to ensure accurate invoicing. -All reimbursement requests due from the Clubs by the 15th of each month o Previous Process: ? Requests were either loaded in the shared drive or emailed directly to the admin. Requests were consistently late and admin would communicate with each Club to see if they submitted something but it was missed. o Current Process: ? Calendar reminders are disbursed to all financial contacts with the deadlines clearly defined ? All submissions must be made in the shared drive. No email reimbursement requests are allowed. ? Admin no longer reached out to Clubs if nothing is loaded in the shared drive to process by the deadline ? Direct communication opened and established between Club financial leaders and admin financial leader to ensure all deadlines are met o Process Update: ? No update is needed ? Reimbursement Request/Cover Sheet o Previous Process: ? Submissions were processed based on a spreadsheet that the Clubs tracked in the shared drive. ? Manual verification of lines requested o Current Process: ? A cover sheet detailing the calculations of each line in the reimbursement request is required with each submission. Acknowledgment by Clubs that they have included/not included (timesheets signed in 3 places, receipts with no sales tax or other unallowable expenses, request submitted by the 15th of each month) via check boxes prior to authorized signature and date. ? All salary and benefit calculations must be completely detailed in the supporting documentation. This has remained difficult with all 20 organizations having different pay structures, paycheck layouts, benefit providers, etc. ? All supporting documentation must be present at the time of processing or line item requests are removed from overall submission. ? All submissions are compiled and sent to funders by their deadline on a monthly basis o Process Update: ? Additional calculation details will now be required for all submissions. We will add a separate box for the percentage breakdown to be charged to each grant to match supporting documentation exactly. ? All communication of errors will be in writing and detailed notes will be kept. No more phone conversations about corrections unless also documented in writing. ? If there are any unclear calculations in the request, it will be sent back to the Club to submit the following month. This will take the liability for the error off the admin and place it back with the Club. ? We will no longer allow miscellaneous benefits (other than payroll taxes) as an allowable expense for reimbursement as they are difficult to verify. ? 1:1 training will be conducted with each Club prior to their first reimbursement request for new grant cycles. With turnover and task sharing in our organization, this will ensure direct training and increase compliance. ? Quarterly financial update calls will be longer/more specific. ? We will no longer allow Clubs to combine requests over multiple months. This inconsistency tends to lead to errors. ? Additional admin support has been added to decrease the number of requests being processed by one individual per month. We have hired an additional staff member. ? Status of Funds o Previous Process: ? Clubs kept up with their budgets/available balances themselves o Current Process: ? Admin updates a running spreadsheet in the shared drive after each month's submission to ensure Clubs are aware of their available balances for each grant o Process Update: No update is needed Anticipated Completion Date: September 30, 2023

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