Corrective Action Plans

Finding 21963 (2022-018)

Material Weakness 2022

MS

Subrecipient Monitoring Material Weakness Reporting § 200.331 § 200.501 § 200.512

SUBRECIPIENT MONITORING ALN Number 93.568 Low Income Home Energy Assistance (LIHEAP) 2022-018 The Mississippi Department of Human Services Should Strengthen Controls Over Onsite Monitoring for the Low-Income Home Energy Assistance Program (LIHEAP). Response: MDHS Concurs that controls should be s...

SUBRECIPIENT MONITORING ALN Number 93.568 Low Income Home Energy Assistance (LIHEAP) 2022-018 The Mississippi Department of Human Services Should Strengthen Controls Over Onsite Monitoring for the Low-Income Home Energy Assistance Program (LIHEAP). Response: MDHS Concurs that controls should be strengthened over On-Site monitoring for the LIHEAP Program. MDHS also concurs with the following specific recommendations of the OSA and incorporates those recommendations as the foundation for the MDHS Corrective Action Plan (CAP) related to this finding. Corrective Action Plan: 1. Strengthen controls over the subrecipient monitoring process: A. The Office of Compliance, Division of Monitoring has made significant strides in strengthening controls over the subrecipient monitoring process. The Division continues to review and update the processes and procedures as necessary to ensure processes are adequate and effective. Staff are constantly notified/trained on updates to policies, procedures, and regulations to ensure continued compliance with monitoring the agency's subgrant agreements. B. Responsible Party: Kameron Harris, Chief Compliance Officer, Director of Monitoring, Laketha Gilmore C. Completion Date: This corrective action has been implemented and is ongoing. 2. Ensure subgrants are monitored timely and the Report of Findings is issued in a timely manner: A. The Office of Compliance, Division of Monitoring continues to improve upon the monitoring review process. The Division has implemented timeliness requirements to ensure the Agency's compliance with the monitoring process. B. Responsible Parties: Kameron Harris, Chief Compliance Officer, Director of Monitoring, Laketha Gilmore C. Anticipated Completion Date: This corrective action has been implemented. 3. Maintain all supporting monitoring tools, reports, and correspondence in the monitoring file: A. The Division of Monitoring has implemented a quality control measures to ensure all required documentation is included in the monitoring file. B. Responsible Parties: Kameron Harris, Chief Compliance Officer, Director of Monitoring, Laketha Gilmore C. Anticipated Completion Date: This corrective action has been implemented.

View Audit 18740

Finding 21952 (2022-030)

Significant Deficiency 2022

State of Mississippi

MS

Internal Control / Segregation of Duties Special Tests & Provisions Subrecipient Monitoring

84.425 Education Stabilization Fund (ESSER) Special Test & Provisions - Participation of Private School Children 2022-030 Strengthen Controls to Ensure Compliance with Equitable Participation of Private School Children Requirements Response The MDE does not see the finding as a systemic problem wi...

84.425 Education Stabilization Fund (ESSER) Special Test & Provisions - Participation of Private School Children 2022-030 Strengthen Controls to Ensure Compliance with Equitable Participation of Private School Children Requirements Response The MDE does not see the finding as a systemic problem with the program. The two non-public schools initially participated in the ESSER I Equitable Services, and the LEA provided services. However, when USDE revoked the Interim Final Rule, the two non-public schools decided to no longer participate. Services were offered before the non-public school's decision not to participate. Corrective Action Plan A. The MDE will continue to work with and provide trainings to subrecipients to follow the established procedures and update monitoring procedures, as necessary, to ensure efficiency and effectiveness.

View Audit 18740

Finding 21947 (2022-029)

Significant Deficiency 2022

State of Mississippi

MS

Subrecipient Monitoring § 200.331 § 200.332

84.027 Special Education - Grants to States (IDEA, Part B) 84.173 Special Education - Preschool Grants (IDEA, Preschool) Subrecipient Monitoring 2022-029 Strengthen Controls to Ensure Compliance with On-Site Subrecipient Monitoring Requirements for Special Education Cluster Programs. Response Th...

84.027 Special Education - Grants to States (IDEA, Part B) 84.173 Special Education - Preschool Grants (IDEA, Preschool) Subrecipient Monitoring 2022-029 Strengthen Controls to Ensure Compliance with On-Site Subrecipient Monitoring Requirements for Special Education Cluster Programs. Response The MDE Office of Special Education (OSE) acknowledges the findings identified by the Office of the State Auditor's as described above. MDE OSE has maintained the review of the Single Audits and provided follow-up on corrections needed by LEAs with funding under IDEA programs. In addition, MDE OSE provides technical assistance to LEAs regarding such. Further, MDE OSE utilizes the District Determinations (SPP/APR) data to provide proactive technical assistance to LEAs. During the 2020-2021 school year, MDE OSE conducted cyclical monitoring to the best of its ability given school closures related to the COVID-19 pandemic. During SY 20-21, the existing procedure required onsite visits for every monitoring activity. However, during that time, and under the guidance of the National Center for Systemic Improvement (NCSI) , MDE OSE monitored LEAs via Special Education Determination Reports, Mississippi Comprehensive Automated Performance-based System (MCAPS) funding application review, and Formal State Complaints using previous procedures while MDE OSE developed new procedures and risk assessments. Additionally, with the onset of COVID-19, the districts and state agencies faced challenges in meeting monitoring requirements and timelines during the first six months of the 2020-2021 school year due to health and safety restrictions. In its implementation of new procedures and risk assessments, MDE OSE has incorporated broad revisions to the agency's subrecipient monitoring procedures and made a significant investment in building the capacity of new OSE management team members to monitor subrecipient compliance and ensure that subawards are used for authorized purposes. Those newly developed procedures were piloted during the 2021-2022 school year, finalized in May 2022, and fully implemented for school year 2022-2023. It should be noted that in June 2023, the MDE OSE received a program determination letter (PDL) from the U.S. Department of Education (US DOE), Office of Special Education and Rehabilitative Services (OSERS) that resolved a similar finding 2021-037 from Audit 04-21-39984 conducted by the State of Mississippi, Office of the State Auditor. The corrective actions included in finding 2021-037 are the same as those seen below. The PDL indicated that the MDE OSE produced evidence of revised systems to ensure compliance with the agency?s requirements for subrecipient monitoring. Corrective Action Plan: A. The MDE OSE will continue the programmatic and cyclical monitoring of LEAs that began as a pilot in the spring of 2020. The newly implemented procedures will be utilized fully in the 2022-2023 school year. B. The MDE OSE will continue to complete the risk-based assessment, that includes the SPP/APR data, each year as universal monitoring of all LEAs to identify those in need of intensive intervention and support. C. The MDE OSE will continue to review, approve and monitor budgets and expenditures through the Mississippi Comprehensive Automated Performance-based System (MCAPS) to oversee the use of IDEA grant funds to subrecipients. D. The MDE OSE has established a procedure of virtual self-assessment via desk audits if the process is once again interrupted due to health and safety concerns.

View Audit 18740

Finding 21946 (2022-028)

Material Weakness 2022

State of Mississippi

MS

Subrecipient Monitoring Material Weakness Reporting

84.010 Title I-Grants to Local Education Agencies 84.367 Title II - Supporting Effective Instruction 84.425 Education Stabilization Fund Reporting 2028-028 Strengthen Controls to Ensure Compliance with Federal Funding Accountability and Transparency Act (FFATA) requirements Response: The MDE doe...

84.010 Title I-Grants to Local Education Agencies 84.367 Title II - Supporting Effective Instruction 84.425 Education Stabilization Fund Reporting 2028-028 Strengthen Controls to Ensure Compliance with Federal Funding Accountability and Transparency Act (FFATA) requirements Response: The MDE does not concur with this finding. The MDE maintains a process to repo1i FFATA information timely. The MDE is hampered in its reporting, however, by known issues to the FFATA reporting system. For example, if the MDE needs to revise a report it must submit a request to the FSRS Helpdesk to delete the previously-uploaded report before it can upload a revised repo1i. This revised report is required when entities DUNS/UEI became valid and/or when allocations were revised. In these instances, the repo1iing date will be the date of the revised repo1i, rather than the original report. The MDE made good faith effo1is to upload this information in a timely manner. Unfortunately, the FSRS system cannot provide the transactions on each federal award to show when an original file was uploaded into the system or provide a report on the end-user activity in the system. In addition, the FSRS system experiences frequent system errors that prevent the MOE from uploading its repo1is in a timely fashion. Thus, the MDE is unable to demonstrate exactly when the file was initially submitted to the FSRS system or upload files that are timely prepared. These common reporting and system issues are known by and affect all users. Until these issues are corrected, the MDE may continue to experience difficulty in uploading reports. All current reports have been uploaded and are visible within the FSRS system. Corrective Action Plan: A. The MDE will maintain a copy of the PDF file of the upload for the initial submission and will electronically provide a date stamp on the document indicating its upload. This process was implemented on June 30, 2023, and is monitored by Elisha Campbell, Executive Director.

View Audit 18740

Finding 21945 (2022-033)

Material Weakness 2022

State of Mississippi

MS

Reporting Internal Control / Segregation of Duties Subrecipient Monitoring § 200.502 § 200.510

2022-033 Veterans State Nursing Home Care - Assistance Listing No. 64.015 Recommendation: We recommend that The Department review and enhance procedures over accounting for and reporting federal program expenditure activity. The Department's enhancement to the procedures should strengthen internal...

2022-033 Veterans State Nursing Home Care - Assistance Listing No. 64.015 Recommendation: We recommend that The Department review and enhance procedures over accounting for and reporting federal program expenditure activity. The Department's enhancement to the procedures should strengthen internal controls over the preparation and review of the SEFA to ensure that all grant award information and related expenditures are complete and accurate. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Mississippi Veterans Affairs will submit all financial data for the GAAP reporting packets and ensure necessary adjustments and corrections are accurately reported. The preparation of reviewing and recording federal awards expenditures will be maintained and tracked accordingly. The Mississippi Veterans Affairs Internal Auditor will monitor the Finance Department internal processes and procedures to implement corrective actions for compliance requirements. Name(s) of the contact person(s) responsible for corrective action: Demetrice Watts Planned completion date for corrective action plan: December 31, 2023

View Audit 18740

Finding 21943 (2022-032)

Material Weakness 2022

State of Mississippi

MS

Subrecipient Monitoring Allowable Costs / Cost Principles § 200.303 § 200.400

21.023 COVID-19 Emergency Rental Assistance (ERA) 21.026 COVID-19 Homeowners Assistance Fund (HAF) Monitoring 2022-032 Strengthen Controls to Ensure Compliance with Federal Monitoring Requirements Response: DFA was simply a pass-through agency of the funds and was required to draw down the funds...

21.023 COVID-19 Emergency Rental Assistance (ERA) 21.026 COVID-19 Homeowners Assistance Fund (HAF) Monitoring 2022-032 Strengthen Controls to Ensure Compliance with Federal Monitoring Requirements Response: DFA was simply a pass-through agency of the funds and was required to draw down the funds in light of an impending federal deadline. It is not possible for DFA to conduct monitoring as it has not been appropriated any funds nor does it have the personnel or other resources to do so. Corrective Action Plan: A. Mississippi Home Corporation should hire a 3rd party monitor. B. Mississippi Home Corporation Director Scott Spivey C. N/A D. N/A

View Audit 18740

Finding 21942 (2022-031)

Material Weakness 2022

State of Mississippi

MS

Subrecipient Monitoring Internal Control / Segregation of Duties Eligibility § 200.303

21.023 COVID-19 Emergency Rental Assistance (ERA) Eligibility 2022-031 Strengthen Controls to Ensure Compliance with Eligibility Requirements for the Emergency Rental Assistance Program Response: DFA was simply a pass-through agency of the funds and was required to draw down the funds in light of...

21.023 COVID-19 Emergency Rental Assistance (ERA) Eligibility 2022-031 Strengthen Controls to Ensure Compliance with Eligibility Requirements for the Emergency Rental Assistance Program Response: DFA was simply a pass-through agency of the funds and was required to draw down the funds in light of an impending federal deadline. It is not possible for DFA to assess and conduct eligibility determinations as it has not been appropriated any funds nor does it have the personnel or other resources to do so. Corrective Action Plan: A. Mississippi Home Corporation has eligibility and fraud prevention policies in place; however, this grant program is no longer accepting applications. B. N/A C. N/A

View Audit 18740

Finding 21939 (2022-023)

Material Weakness 2022

State of Mississippi

MS

Subrecipient Monitoring § 200.332 § 200.425 § 200.501

ALN Number 17.258, 17.259, 17.278 ? Workforce Innovation and Opportunity Act 2022-023 ? Strengthen Controls to Ensure Compliance with Subrecipient Monitoring Requirements. Cat ? M, Finding Type, A, C1 (MW, MNC) MDES Response: The Mississippi Department of Employment Security concurs in principle wi...

ALN Number 17.258, 17.259, 17.278 ? Workforce Innovation and Opportunity Act 2022-023 ? Strengthen Controls to Ensure Compliance with Subrecipient Monitoring Requirements. Cat ? M, Finding Type, A, C1 (MW, MNC) MDES Response: The Mississippi Department of Employment Security concurs in principle with the three conditions noted in the finding. During and prior to this audit, MDES enacted new procedures to address the concerns noted in this finding. MDES renewed its commitment to ensuring that subrecipients are qualified to receive funds. MDES contracted with Booth Management Consultants and more recently Trace Advisory Group to ensure compliance with all DOL monitoring requirements, including on-site monitoring and through other modes. Also, we started implementing a risk-based assessment tool to ensure the performance of a thorough qualification assessment on all grantees. Corrective Action Plan: A. The Offices of Grant Management and Business Management will develop a plan to document our assessment of the subrecipients? awareness of audit requirements at 2 CFR 200.332(f). MDES will start implementing the plan detailed below on or before October 31, 2023. This plan involves the following: 1) Perform a pre-award risk assessment to determine risk for awarding grant and the level of monitoring required during program; 2) Issue a standardized audit requirement letter or agreed upon procedures to all subgrantees to remind them of grant requirements; 3) Receipt of required federal single audit from subgrantees expending more than $750,000 in federal funds from all sources OR receipt of a statement that the entity did not meet this threshold; 4) Document the review and assessment of the audits received for findings or questioned costs using tools, such as the templates found in the DOL Core Monitoring Guide; and 5) Document all required agency action necessary to mitigate the risks identified in the audits. B. COVID-19 caused extensive travel and in-person meeting restrictions nationwide. MDES did not restrict travel or virtual meetings. As contact guidelines fluctuated, the on-site monitoring team had discretion regarding the method to conduct this process. Also during this time, DOL staff observed similar contact restrictions, which limited federal monitoring of MDES. Such challenges and restrictions no longer exist. MDES will perform on-site and remote monitoring, as required. Where possible, MDES intends to conduct future monitoring on-site. MDES management will also hold regular meetings with the subrecipients to monitor progress and to ensure questions related to grant expenditures receive timely responses. C. Although the agency did not perform a risk-based assessment in the year reviewed by the auditors (PY21), MDES did incorporate the Risk Assessment Tool, Tool S from the U. S. Department of Labor?s Core Monitoring Guide, into its review of subgrantees for PY 2022. MDES will continue to ensure the performance of a thorough risk-based assessment on all grantees.

View Audit 18740

Finding 21934 (2022-024)

Significant Deficiency 2022

State of Mississippi

MS

Internal Control / Segregation of Duties Subrecipient Monitoring Significant Deficiency

ALN Number 17.225 ? Unemployment Insurance 2022-024 ? Strengthen Controls to Ensure Compliance with Special Tests ? Benefit Payments Requirements for Unemployment Insurance. Cat ? N, Finding Type B (SD) MDES Response: MDES appreciates the value of ensuring that appropriate staff review reports and ...

ALN Number 17.225 ? Unemployment Insurance 2022-024 ? Strengthen Controls to Ensure Compliance with Special Tests ? Benefit Payments Requirements for Unemployment Insurance. Cat ? N, Finding Type B (SD) MDES Response: MDES appreciates the value of ensuring that appropriate staff review reports and of maintaining appropriate documentation of supervisor/investigator signatures after examination of each report. This finding identified isolated and non- reoccurring incidents. Moreover, MDES has procedures in place to ensure the review of all reports and documentation of such activities Corrective Action Plan: MDES has adopted the corrective procedures listed below for the activities relevant to this finding. MDES staff have the option to use the Docusign for this process. We shall evaluate the efficiency and effectiveness of these procedures and modify them as necessary. A. The reviewer in the department prepares the draft report and sends it to the appropriate manager/supervisor for review, editing, and approval. B. The appropriate manager/supervisor receives the report, reviews it, makes changes as necessary, and approves it. C. The appropriate manager/supervisor or designated records custodian receives the approval, prints it, and stores the report with the record of the review.

View Audit 18740

Finding 21933 (2022-022)

Material Weakness 2022

State of Mississippi

MS

Internal Control / Segregation of Duties Subrecipient Monitoring Material Weakness § 200.302

ALN Number 17.225 ? Unemployment Insurance 2022-022 ? Strengthen Controls to Ensure Compliance with Reporting Requirements for Unemployment Insurance. Cat ? L, Finding Type, A, C2 (MW, IMNC) MDES Response: During the pandemic emergency, MDES relied upon the procedures encoded in ReEmployMS to gener...

ALN Number 17.225 ? Unemployment Insurance 2022-022 ? Strengthen Controls to Ensure Compliance with Reporting Requirements for Unemployment Insurance. Cat ? L, Finding Type, A, C2 (MW, IMNC) MDES Response: During the pandemic emergency, MDES relied upon the procedures encoded in ReEmployMS to generate the non-emergency tasks. Currently, the Policy and Compliance staff conduct random reviews and tests of both files and reports for accuracy validation using samples identified by the US DOL. The ReEmployMS system generates and stores flat files containing the specific individual records to create the ETA reports. When an error occurs in the generated reports, the staff receive alerts to review the data and reconcile the report. If the system does not generate an error, the information passes as accurate and verification occurs later upon the generation of test samples. Corrective Action Plan: After the relative subsidence of the COVID-19 crisis and review of our activities, MDES better appreciates the value of ensuring that appropriate staff review reports and of maintaining documentation for each examination. Moreover, MDES currently has procedures in place to ensure the review of all reports and to document such activities.

View Audit 18740

Finding 21931 (2022-020)

Material Weakness 2022

State of Mississippi

MS

Questioned Costs Internal Control / Segregation of Duties Subrecipient Monitoring

ALN Number 17.225 ? Unemployment Insurance 2022-020 ? Strengthen Controls to Ensure Compliance with Special Tests ? Program Integrity ? Overpayments Requirements for Unemployment Insurance. Cat ? N, Finding Type, A, C1 (MW, MNC) MDES Response: MDES respectfully disagrees with this finding because t...

ALN Number 17.225 ? Unemployment Insurance 2022-020 ? Strengthen Controls to Ensure Compliance with Special Tests ? Program Integrity ? Overpayments Requirements for Unemployment Insurance. Cat ? N, Finding Type, A, C1 (MW, MNC) MDES Response: MDES respectfully disagrees with this finding because the flexibility to present its interpretations of federal guidance as impacted by state law to DOL for approval remains a cornerstone of the federal-state dynamic of the unemployment insurance system. In addition, the federal pandemic programs that Congress required MDES to institute involved broad, complex, and overlapping processes. MDES worked tirelessly to ensure that we followed all federal guidelines to the best of our ability while promptly enacting the pandemic program. In addition, DOL issued many updates to the federal guidelines including program changes via UIPLs. These UIPLs also referenced prior UIPLs and guidelines creating a high level of complexity when the pandemic demanded swift decisions and rapid implementation of program changes to provide vital assistance to Mississippi?s citizens suddenly thrust into unemployment. MDES will continue to work with DOL regarding its interpretations of federal program guidance as affected by state law. MDES maintains an on-going review of these programs to determine proper and timely payments and offsets under each program and will make necessary programmatic changes to ensure we properly issue payments and make offsets in compliance with federal and state guidelines. On June 19, 2023, MDES implemented an updated process to adjust the offset percentages for these programs.

View Audit 18740 Questioned Costs: $1

Finding 21929 (2022-027)

Significant Deficiency 2022

State of Mississippi

MS

Questioned Costs Allowable Costs / Cost Principles School Nutrition Programs

10.558 Child and Adult Care Food Program Allowable Cost 2022-027 Strengthen Controls to Ensure Compliance with Allowable Costs Requirements of the Child and Adult Care Food Program (CACFP). Response: The MDE does not concur with this finding. The OSA did not identify weaknesses in the MDE subrec...

10.558 Child and Adult Care Food Program Allowable Cost 2022-027 Strengthen Controls to Ensure Compliance with Allowable Costs Requirements of the Child and Adult Care Food Program (CACFP). Response: The MDE does not concur with this finding. The OSA did not identify weaknesses in the MDE subrecipient monitoring process, such as in the selection of organizations, the monitoring cycle, or monitoring procedures. Instead, OSA identified potential errors made by individual participating organizations. The MDE has a robust system of internal controls and subrecipient monitoring system for the CACFP. In addition to meeting USDA requirements for monitoring, the MDE Office of Child Nutrition (OCN) also employs a risk -based process to select CACFP subrecipients for review and to determine the scope of monitoring. The MDE routinely exceeds the USDA requirement to monitor 33.3% of participating organizations annually. For Program Year (PY) 2021-2022, 60.3% of participating organizations were reviewed to provide additional oversight of subrecipients. When the MDE identifies instances of noncompliance, it requires participating organizations to take appropriate corrective action. For organizations that are very high-risk, the MDE employs the USDA Serious Deficiency process in accordance with 7 C.F.R. 226.6. The MDE already has a process to recover funds from an organization if an error is discovered during subrecipient monitoring. In PY 2022, the MDE assessed $132,207 in repayments of USDA funds and required an additional $40,577 in unallowable costs to be returned to local CACFP accounts. Finally, MDE staff was not included in the reviews of subrecipients by OSA, so the MDE was unable to verify the accuracy of the proposed unallowable costs before publication of the report from OSA. MDE staff will need to review documentation from OSA, and source documentation retained at CACFP sites before it can make a final determination regarding the potential unallowable cost determinations against sponsors. Corrective Action Plan: A. The MDE will review documentation provided by OSA of potential questioned costs and review source documentation held by the subrecipients to determine the amount of unallowable costs. If confirmed, the MDE will recover any unallowable costs in accordance with USDA policies. This review will be completed by January 22, 2024. Susie Evans, CACFP Director for the MDE OCN, will oversee the review. B. The MDE will continue to assess its CACFP monitoring and continue to strengthen the process while remaining in compliance with USDA regulations.

View Audit 18740 Questioned Costs: $1

Finding 21928 (2022-019)

Material Weakness 2022

State of Mississippi

MS

Procurement, Suspension & Debarment Subrecipient Monitoring Internal Control / Segregation of Duties

REPORTING ALN Number 93.558 Temporary Assistance for Needy Families (TANF) 93.667 Social Services Block Grant (SSBG) 93.568 Low Income Home Energy Assistance (LIHEAP) 10.542 and 10.649 Pandemic EBT Benefits 93.596 and 93.575 Child Care Development Fund (CCDF) 2022-019 The Mississippi Department of...

REPORTING ALN Number 93.558 Temporary Assistance for Needy Families (TANF) 93.667 Social Services Block Grant (SSBG) 93.568 Low Income Home Energy Assistance (LIHEAP) 10.542 and 10.649 Pandemic EBT Benefits 93.596 and 93.575 Child Care Development Fund (CCDF) 2022-019 The Mississippi Department of Human Services Should Strengthen Controls to Ensure Compliance with the Federal Funding and Accountability and Transparency Act (FFATA) Reporting Requirements. Response : MDHS concurs that controls should be strengthened over FFATA reporting requirements. Corrective Action Plan: 1. Strengthen controls to ensure compliance with FFATA reporting requirements. A. MDHS implemented a process as of January 1, 2023, to ensure that FFATA reporting is being done and verified on a periodic basis. Standard Operating Procedures are under revision as we master this federal system. B. Responsible Parties: Wayne Carpenter, Deputy of Finance and Samuel Cole, Director of Procurement Services C. Anticipated Completion Date: Initial implementation was executed January 1, 2023, with newly issued subgrants. We are in the process of entering subgrants awarded between July 1, 2022, and December 31, 2022, in an attempt to become current on this fiscal year's reporting requirements.

View Audit 18740

Finding 21895 (2022-002)

Significant Deficiency 2022

Arts Midwest, Incorporated

MN

Procurement, Suspension & Debarment Subrecipient Monitoring

Finding 2022-002 Federal Agency Name: National Endowment for the Arts Program Name: Promotion of the Arts Partnership Agreement CFDA # 45.025 Finding Summary: Controls were not adequately designed to ensure compliance with all requirements for procurement, suspension, and debarment under Uniform Gui...

Finding 2022-002 Federal Agency Name: National Endowment for the Arts Program Name: Promotion of the Arts Partnership Agreement CFDA # 45.025 Finding Summary: Controls were not adequately designed to ensure compliance with all requirements for procurement, suspension, and debarment under Uniform Guidance. Responsible Individuals: Anne Romens, Vice President and Joshua Feist, Director of Grantmaking Corrective Action Plan: In the future, starting with the next round of subgrant awards, the grants team will verify through the SAM.gov website that potential subgrantees are not suspended or debarred before issuing subgrant agreements. This verification will be documented on the subgrantee file. Estimated Completion Date: March 31, 2023

View Audit 23778

Finding 21873 (2022-004)

Significant Deficiency 2022

Brillare Beauty Institute, INC

TN

Questioned Costs Student Financial Aid Special Tests & Provisions

FINDING 2022-004: Untimely Paid Credit Balance A. Comments on Findings and Recommendations: In response to the untimely paid credit balance, Brillare Beauty Institute agrees with the Single Audit Finding 2022-003. B. Actions Taken or Planned: Brillare Beauty Institute had resolved the student accoun...

FINDING 2022-004: Untimely Paid Credit Balance A. Comments on Findings and Recommendations: In response to the untimely paid credit balance, Brillare Beauty Institute agrees with the Single Audit Finding 2022-003. B. Actions Taken or Planned: Brillare Beauty Institute had resolved the student account credit balance issue but not in the required time. Brillare Beauty Institute hired an additional Financial Aid Officer in February 2022 to help with administering the Title IV program. The new position gave the institute the ability to have an additional set of eyes reviewing many of our processes to ensure compliance. At the time of this error, training of the new employee was still in process.

View Audit 20936 Questioned Costs: $1

Finding 21865 (2022-001)

Significant Deficiency 2022

National Disability Institute

DC

Subrecipient Monitoring § 200.331

Views of Responsible Officials: The National Disability Institute will adopt a formal risk assessment pre-award policy that outlines detailed and specific levels of monitoring for subrecipients based on the assessed level of risk. The National Disability Institute will document the pre-award risk as...

Views of Responsible Officials: The National Disability Institute will adopt a formal risk assessment pre-award policy that outlines detailed and specific levels of monitoring for subrecipients based on the assessed level of risk. The National Disability Institute will document the pre-award risk assessment process and resulting linked level of monitoring on its subrecipients as part of the pre-award process.

View Audit 19946

Finding 21864 (2022-001)

Material Weakness 2022

Knox County

IN

Procurement, Suspension & Debarment Subrecipient Monitoring

Auditor shall review that a certification from the vendor is enclosed with expenditures. The Auditor had a discussion with Jason Booth and going forward that the certification will be completed by the vendors for transactions over $25,000 using ARPA funds.

View Audit 19471

Finding 21857 (2022-004)

Significant Deficiency 2022

Turtle Mountain Public Utilities Commission

ND

Procurement, Suspension & Debarment Subrecipient Monitoring

Contact Person ? Kenneth Azure, Executive Director Corrective Action Plan ? Management will review its policies and procedures for monitoring suspended and debarred parties. Completion Date ? 12/31/2022

View Audit 19216

Finding 21855 (2022-001)

Material Weakness 2022

Mississippi Valley Fair Inc.

IA

Subrecipient Monitoring Material Weakness Internal Control / Segregation of Duties

Mississippi Valley Fair respectfully submits the following corrective action plan for the year ended August 31, 2022. Name and address of the public accounting firm: Olsen Thielen & Co., Ltd. 300 Prairie Center Drive, Suite 300 Eden Prairie, MN 55344 Current Findings on the Schedule of Findings, ...

Mississippi Valley Fair respectfully submits the following corrective action plan for the year ended August 31, 2022. Name and address of the public accounting firm: Olsen Thielen & Co., Ltd. 300 Prairie Center Drive, Suite 300 Eden Prairie, MN 55344 Current Findings on the Schedule of Findings, Questioned Costs, and Recommendations Finding No. 2022 -001 COVID-19 Shuttered Venue Operators Grant Program Recommendation ? The Organization should continue to monitor expenditures to ensure they are recorded in the correct period and incorporate monitoring for unusual transactions, in addition they should monitor and incorporate procedures to ensure controls are in place and operating effectively. Comments on the Recommendation - Management acknowledges the material weakness and is in the process of creating written control policy and procedures that will be in place if they ever receive federal awards in the future. Action Taken ? Management is in the process of creating written internal control policies and procedures and expects to have this process completed by April 1st 2023. Corrective Action Plan prepared by: Name: Shawn Loter Position: General Manager Telephone Number: 563-326-5338

View Audit 19027

Finding 21853 (2022-002)

Significant Deficiency 2022

Allegheny County Industrial Development Authority

PA

Allowable Costs / Cost Principles Reporting Matching / Level of Effort / Earmarking § 200.303

Finding 2022-001: Segregation of Duties / Internal Control Industrial Development Authority Corrective Action Plan: The following procedures have been implemented to improve controls and segregation of duties. 1. Each Accountant has been assigned an authority for monitoring and invoicing. Invoices...

Finding 2022-001: Segregation of Duties / Internal Control Industrial Development Authority Corrective Action Plan: The following procedures have been implemented to improve controls and segregation of duties. 1. Each Accountant has been assigned an authority for monitoring and invoicing. Invoices are sent on the first of the month. The Auditor or Sr. Finance Manger will monitor Quickbooks to ensure invoices are prepared timely and efforts are made for collection. 2. Loan receivable detail including amortization schedules and payment schedules will be maintained monthly and reconciled to Quickbooks each month. 3. Interfund activity will be recorded timely and reconciled monthly. The Sr. Manger or Auditor will review monthly. 4. Only the Auditor or Sr. Finance Manger will make journal entries. Finding 2022-002: Allowable Costs/Cost Principles and Reporting Industrial Development Authority Corrective Action Plan: 1. To prevent incorrect interest rates in the future, a loan process flow document [Exhibit C] has been created. The project and division manager will use this tool prior to drafting an offer letter, which serves as the first official offering of a fixed rate. Rates will be checked again prior to closing. If at this time, the rate is different then what was provided in the offer letter, the division manager will seek approval from EDA. Please see table included in the corrective action plan. 2. Business Development, Finance, and the Deputy Director have set up monthly loan monitoring meetings. Additionally, Business Development staff will send out annual specific requests for loan monitoring materials for all active loans, on top of the monthly reminders already sent with invoices. 3. ACED Business Development will work with ACED Finance to perform a monthly reconciliation to ensure cash balances are reported accurately and timely in all systems. 4. Federal reports are now being prepared by the Manager of Business Development and reviewed by the Sr. Finance Manager, the Assistant Director, and the Deputy Director before submission with an approval memo tracking their review. Reports are now current and were submitted on time for June 30, 2023. Please contact me with questions or concerns regarding the corrective action plans. Sincerely, Simone McMeans Authorized Designate

View Audit 18644

Finding 21852 (2022-001)

Material Weakness 2022

King County

WA

Subrecipient Monitoring

Finding ref number: 2022-001 Finding caption: The County?s internal controls within the Department of Public Health were inadequate for ensuring compliance with federal reporting requirements. Name, address, and telephone of County contact person: Eben Sutton, Chief Accountant Financial Manageme...

Finding ref number: 2022-001 Finding caption: The County?s internal controls within the Department of Public Health were inadequate for ensuring compliance with federal reporting requirements. Name, address, and telephone of County contact person: Eben Sutton, Chief Accountant Financial Management Section Finance and Business Operations Division 201 S. Jackson Street, Suite 0714 Seattle, WA 98104 (206) 477-4540 Corrective action the auditee plans to take in response to the finding: King County Public Health Finance will provide consistent training to personnel regarding FFATA reporting and will conduct management reviews through quarterly monitoring to ensure reporting requirements and deadlines are met. Anticipated date to complete the corrective action: March 2024.

View Audit 19945

Finding 21851 (2022-004)

Significant Deficiency 2022

Archdiocese of St. Louis

MO

Subrecipient Monitoring Reporting Significant Deficiency

Finding No. 2022-004 Significant Deficiency Personnel Responsible for Corrective Action: Teri Gregory, CFO of Child Center~Marygrove Anticipated Completion Date: March 31, 2023 Corrective Action Plan: Marygrove CFO will create electronic folders on our system that include subfolders for eac...

Finding No. 2022-004 Significant Deficiency Personnel Responsible for Corrective Action: Teri Gregory, CFO of Child Center~Marygrove Anticipated Completion Date: March 31, 2023 Corrective Action Plan: Marygrove CFO will create electronic folders on our system that include subfolders for each report filed. The subfolder will contain all reports and correspondences used to create the required filing. Once the filing is created it will be forwarded to the CEO or the CFOO of Catholic Charities (CFOO) for review prior to submission. Once the CEO or CFOO approves the report, the filing will be finalized in the PRF Reporting Portal. A copy of the final report and copies of all emails related to the review will be retained in the corresponding subfolder.

View Audit 27933

Finding 21850 (2022-002)

Material Weakness 2022

Archdiocese of St. Louis

MO

Subrecipient Monitoring Reporting Material Weakness § 200.510

Finding No. 2022-002 Material Weakness Personnel Responsible for Corrective Action: Archdiocesan Finance Office, Marilisa Heiderscheid (Controller) Anticipated Completion Date: March 31, 2023 Corrective Action Plan: Management will implement procedures to assure that all costs charged to the...

Finding No. 2022-002 Material Weakness Personnel Responsible for Corrective Action: Archdiocesan Finance Office, Marilisa Heiderscheid (Controller) Anticipated Completion Date: March 31, 2023 Corrective Action Plan: Management will implement procedures to assure that all costs charged to the Provider Relief Fund are reviewed by a competent individual, and those reviews will be documented.

View Audit 27933

Finding 21839 (2022-003)

Material Weakness 2022

El Monte Union High School District

CA

Subrecipient Monitoring Material Weakness Reporting

The Auditor discovered that two weekly reports for September 2021 lacked documentation. Compared to the number of tests reported overall in 2021-2022, the number of unverified tests constitute a finding for non-compliance and indicative of issues surrounding record keeping. It has since come to ligh...

The Auditor discovered that two weekly reports for September 2021 lacked documentation. Compared to the number of tests reported overall in 2021-2022, the number of unverified tests constitute a finding for non-compliance and indicative of issues surrounding record keeping. It has since come to light that some tests were inconclusive but were not identified as such leading to a higher test count versus negative/positive counts. No program specific corrective action steps shall be instituted as this is not an on-going program. However, it will be important to laboriously work out the details prior to an agreement and specify the need for clerical support in future agreements. In addition, the district will review its records and verify alignment with reports submitted to the Los Angeles COE.

View Audit 18007

Finding 21761 (2022-002)

Material Weakness 2022

Clayton Ridge Community School District

IA

School Nutrition Programs Subrecipient Monitoring Reporting

2022-002 The District has insufficient procedures in place to ensure all long term liability and related expense transactions were properly recorded. Material adjustments were needed for the District's financial statements. See response and corrective action plan at 2022-002.

View Audit 27497

Corrective Action Plans

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