Corrective Action Plans

Finding 32489 (2022-013)

Significant Deficiency 2022

PA

Questioned Costs Subrecipient Monitoring Reporting § 200.1 § 200.332

DHS: The Office of Children, Youth, and Families (OCYF) is sending out a Restrictions and Requirements document with each tentative and final allocation letter. This document lists all OCYF?s grants, the federal agency granting the fund and where to find the rules and regulations guiding the usage o...

DHS: The Office of Children, Youth, and Families (OCYF) is sending out a Restrictions and Requirements document with each tentative and final allocation letter. This document lists all OCYF?s grants, the federal agency granting the fund and where to find the rules and regulations guiding the usage of the funds. For the State fiscal year 2021-2022, Tentative Allocation Letters were sent out on April 1, 2021, with Federal Award Identification Numbers (FAIN) and funding amounts. Final Allocation Letters were sent out August 12, 2021, with the Amount, FAIN and Name. OCYF has a risk assessment process in place for Title IV-E and TANF awards. During the Quality Assurance reviews, which occur twice a year at a minimum, OCYF reviews a sample of Title IV-E eligible foster care cases, Title IV-E ineligible foster care cases, Title IV-E eligible adoption assistance cases, and TANF eligible cases. Depending on the number of eligibility and claiming errors identified during the review, OCYF schedules more frequent visits as the risk of repeated and continued errors in these County Children and Youth Agencies (CCYAs) is higher. Inaccurate eligibility determinations lead to inaccurate federal claiming, so basing the review schedule on a CCYA?s eligibility review outcome allows OCYF to target those CCYAs where inaccurate claiming is a higher risk. However, to further address this finding, the risk assessment now includes documentation. Anticipated Completion Date: Completed Contact Person and Title: TinaMarie Petrovitz, Director of County Support DOH: The Department plans to develop and implement a robust subrecipient monitoring program which includes establishing a new section within the Budget Office pending enacted budget funds and complement to support the creation of the section. Initiative goals/milestones include: - Assessment: Comprehensive assessment of all current federal grants and subawards and their processes. This assessment will document best practices and identify gaps within the agency?s processes. It will also provide an evaluation of current operational and technological resources that can be leveraged to facilitate compliance. Target start date: February 27, 2023. Target completion date: June 30, 2023. - Educate Department: Budget Office is developing a bulletin that will outline the subrecipient monitoring requirements with links to State and Federal Sources. The bulletin will be shared with all program office staff. The Budget Office will develop the following templates and provide to all program offices: - Determination of vendor status: Subrecipient or Contractor - Risk Assessment Form - Internal Control Self-Assessment for Subrecipient Template - Subrecipient Monitoring Template All materials will be updated with any additional information gained during the assessment. Start date: February 3, 2023. Target Completion Date: June 30, 2023 - Implementation of full compliance initiative: Recommendations provided in the assessment will be used to develop and implement comprehensive policies and procedures led by a new section in the Budget Office. Target start date July 1, 2023. Target fully operational date: June 30, 2024. Anticipated Completion Date: 06/30/2024 Contact Person and Title: Andrea Race, CFO

View Audit 27724 Questioned Costs: $1

Finding 32472 (2022-012)

Material Weakness 2022

Commonwealth of Pennsylvania

PA

Subrecipient Monitoring Matching / Level of Effort / Earmarking

The following steps were taken to address this material weakness: ? FFATA procedures will be updated to populate the award date in the grant internal order (IO) when the grant is set up in SAP instead of when the grant is in FSRS. ? General Accounting will review their IOs to ensure the award da...

The following steps were taken to address this material weakness: ? FFATA procedures will be updated to populate the award date in the grant internal order (IO) when the grant is set up in SAP instead of when the grant is in FSRS. ? General Accounting will review their IOs to ensure the award date is populated. ? A procedure workgroup will be established to ensure a consistent FFATA review in General Accounting. Anticipated Completion Date: 05/31/2023 Contact Person and Title: Sandra Bruno, Integrated Financial Service Manager; Jamie Jerosky, Assistant Director

View Audit 27724

Finding 32463 (2022-004)

Significant Deficiency 2022

Commonwealth of Pennsylvania

PA

Subrecipient Monitoring Questioned Costs Reporting § 200.303

PDE uses its eGrants system to collect all LEA required records under ESSER I and ESSER II. The eGrants system is designed to allow licensed educational agencies and certain community-based programs within the Commonwealth, access to PDE grants. Through this system, the LEA can submit applications f...

PDE uses its eGrants system to collect all LEA required records under ESSER I and ESSER II. The eGrants system is designed to allow licensed educational agencies and certain community-based programs within the Commonwealth, access to PDE grants. Through this system, the LEA can submit applications for funding, e-sign contracting documents, upload back-up documentation, submit program quarterly reports, and file final expenditure reports. PDE Division of Federal Programs also utilizes Pennsylvania's Information Management System (PIMS) to collect and verify LEA data. PIMS has business rules built in to ensure valid data collection. The eGrants system makes it possible for records pertaining to the ESSER awards to be retained separately from other grant funds, including funds that an SEA or LEA receives under the CARES Act and CRRSA. This follows the requirements under 2 C.F.R. ? 200.334 and 34 C.F.R. ? 76.730, including financial records related to the use of grant funds. Through quarterly financial reporting, LEAs are required to report the amount of cash received, expended, and on hand. If the amount of cash-on-hand reported is determined to be too high, or the quarterly report is not submitted, monthly payments will be suspended until the next quarterly report is due. Current monitoring to verify data and ensure compliance with existing federal guidelines, typically occurs from January through May. LEAs receive a unique username and password to access Fedmonitor and complete an online self-assessment. Beginning in October 2022, all LEAs were placed on a four-year monitoring cycle and were monitored in the 2021?22 fiscal year and will be monitored again in the 2024?25 fiscal year. Data collected in eGrants, PIMS and Fedmonitor is verified during these monitoring visits. Anticipated Completion Date: Completed Contact Person and Title: Susan McCrone, Division Manager, Federal Programs; Brian Campbell, Director, Bureau of Curriculum, Assessment, and Instruction

View Audit 27724 Questioned Costs: $1

Finding 32457 (2022-011)

Significant Deficiency 2022

Commonwealth of Pennsylvania

PA

Subrecipient Monitoring Reporting Significant Deficiency

While the Governor?s Budget Office agrees with the fact cited in finding, it is not possible to correct the situation and the error had no impact on the implementation of the federal program. No corrective action is necessary, nor would it have any discernable impact. The Interim Report was a one-...

While the Governor?s Budget Office agrees with the fact cited in finding, it is not possible to correct the situation and the error had no impact on the implementation of the federal program. No corrective action is necessary, nor would it have any discernable impact. The Interim Report was a one-time progress report required by U.S. Treasury to document our state?s progress in spending State and Local Fiscal Recovery Funds and distributing, on the behalf of the U.S. Treasury, payments from the Treasury to Non-Entitlement Units (NEU) of local government as of July 31, 2021. The Interim Report also required states to provide revenue replacement calculations for calendar year 2020. This report was due on August 31, 2021. There were no follow up reports using the same format as the Interim Report. The figures reported as transfers to NEUs in the Interim Report accurately reflected the total dollars that had been electronically transferred to local governments as of July 31, 2021, as that was how we interpreted the federal guidance at the time. It was our interpretation that U.S. Treasury wanted information on how much had been distributed and received by NEUs as of July 31, 2021, rather than how many payments we had approved in our accounting system and were in the process of being paid. After filing the Interim Report, the Office of the Budget continued to report updates of distributions to NEUs both using a U.S. Treasury portal, and ultimately by exchanging spreadsheets of NEU data with the US Treasury to painstakingly ensure the data the U.S. Treasury had was correct. The Office of the Budget will continue to file compliance reports in accordance with U.S. Treasury?s guidance. At no time did the U.S. Treasury indicate there were issues with the composition or acceptability of our filed Interim Report. At this time, all NEU funds received from the federal government have been either distributed to NEUs or have been returned to the U.S. Treasury and this program is complete. Therefore, we are currently not required to, nor do we have plans to report on the progress of NEU distributions to the federal government in the future. Anticipated Completion Date: N/A Contact Person and Title: Mike Wood, Bureau Director, Bureau of Performance, Revenue, and Program Analysis; Colleen Kling, Division Manager, Division of Program Analysis and Performance Improvement

View Audit 27724

Finding 32455 (2022-007)

Significant Deficiency 2022

Commonwealth of Pennsylvania

PA

Subrecipient Monitoring Reporting Matching / Level of Effort / Earmarking § 200.303

Similar to other DHS programs, DHS has implemented an after-action review of information submitted, using a contracted vendor. DHS faced challenges implementing a program with 67 counties and no central eligibility determination system. DHS has learned that implementing the supportive services and m...

Similar to other DHS programs, DHS has implemented an after-action review of information submitted, using a contracted vendor. DHS faced challenges implementing a program with 67 counties and no central eligibility determination system. DHS has learned that implementing the supportive services and multi-sector partnerships was challenging in the context of the global pandemic and workforce shortages. This made DHS dependent on local county reports to maintain program oversight and compile statewide data for submission to US Treasury. DHS plans to strengthen this control as we plan for future emergency or pandemic programs related to rental assistance. Anticipated Completion Date: 06/30/2023 Contact Person and Title: Joel O?Donnell, Director, Bureau of Program Support, OIM

View Audit 27724 Questioned Costs: $1

Finding 32453 (2022-005)

Material Weakness 2022

Commonwealth of Pennsylvania

PA

Questioned Costs Subrecipient Monitoring § 200.332 § 200.425 § 200.521

AMLR program representatives attended Department of Interior, Office of Surface Mining Reclamation and Enforcement online training covering 2 CFR 200 and contractor or subrecipient determinations. DEP ceased issuing AMLR grants under Management Directive 305.20, Grant Administration. DEP managem...

AMLR program representatives attended Department of Interior, Office of Surface Mining Reclamation and Enforcement online training covering 2 CFR 200 and contractor or subrecipient determinations. DEP ceased issuing AMLR grants under Management Directive 305.20, Grant Administration. DEP management has determined the recipients with existing agreements are subrecipients and DEP will follow this determination consistently with future agreements and accounting. DEP has developed written policies and procedures for subrecipient monitoring and has notified grantees to implement the policies and procedures immediately to ensure timely subrecipient compliance with federal regulations. Anticipated Completion Date: Completed Contact Person and Title: Patrick Webb, Acting Dir., Bureau of AMLR; Tim Golding, Executive Assistant, Office of Admin. and Management

View Audit 27724 Questioned Costs: $1

Finding 32431 (2022-014)

Material Weakness 2022

Commonwealth of Pennsylvania

PA

Questioned Costs Subrecipient Monitoring Reporting § 200.208 § 200.332 § 200.339 § 200.501 § 200.505

PDE: Audits retrieved from the Federal Audit Clearinghouse are now reviewed after entry into PDE?s SharePoint website, to ensure PDE remains compliant with federal guidelines to respond to any and all findings pertaining to federal dollars it passes to subrecipients. Likewise, PDE Audit Section cont...

PDE: Audits retrieved from the Federal Audit Clearinghouse are now reviewed after entry into PDE?s SharePoint website, to ensure PDE remains compliant with federal guidelines to respond to any and all findings pertaining to federal dollars it passes to subrecipients. Likewise, PDE Audit Section continues to improve upon its processes for timely determinations of those single audits with findings by multiple means, including periodic SharePoint enhancements designed to aid in timely review of single audit packages, working closely with PDE program areas to assist in timely responses and quickly addressing SharePoint access issues as they arise. Anticipated Completion Date: 06/30/2023 Contact Person and Title: Clayton P. Carroll, II, Audit Coordinator; Jessica Sites, Director, Bur. of Budget and Fiscal Mgmt DEP: BAFM now provides agencies with single audit reporting packages that have findings each week that have been accepted by the Federal Audit Clearinghouse (FAC). This allows for us to start our management decision process in a timelier manner and meet the six-month deadline for issuing our decision. This information first appeared in our notifications starting April 30, 2021. In addition, the DEP program that had been previously identifying agreements as contracts rather than subrecipient agreements has corrected this issue and all subrecipients have been notified in writing of this correction and provided the information for submitting their single audits (if necessary). The letters were sent to subrecipients on approximately May 31, 2022. DEP Fiscal Management staff will continue to monitor the BAFM SharePoint site and FAC for additional filings to attempt to avoid this issue in the future. DEP is also hiring additional staff for the oversight and monitoring of the subrecipient single audits to ensure compliance with all requirements. These positions are currently in the filing process, and we are hopeful that they will be filled, and staff trained by September 30, 2023. Anticipated Completion Date: 09/30/2023 Contact Person and Title: Jennifer L. Brandt, Senior Fiscal Management Specialist, Federal Grants and Audits DOH: NORTH Inc.?s Single Audit report for the period ending 9/30/2020 was officially submitted and showing on the FAC on 2/9/2023. Bureau of WIC staff reached out to the Director and CFO of NORTH Inc. by phone and email. Emails were sent with instructions on how to submit the report as well as the importance of submitting the report timely per their grant agreement. Each follow-up phone call included discussion on the importance of submitting their single audit as soon as possible. Moving forward the Bureau of WIC will implement the following procedure: 1 .Three months after the end of the audit period (Federal Fiscal Year), Project Officers will send an email that outlines the process for submitting a single audit reporting package to the FAC to their respective WIC local agencies. This email will provide a date that the single audit is due to be submitted to the FAC in order to stay in compliance with their current WIC grant agreement. 2. Six months after the end of the audit period (three months from the due date of the single audit reporting package) an official letter from the Bureau Director will go out to the WIC local agencies that are due to submit a single audit. The letters will include instructions on how to submit the single audit in FAC and the Audit Requirements link referenced in their grant agreement. 3. If the WIC local agency notifies the Bureau of WIC that their auditor will not be able to submit their agency?s single audit by the due date, then the Project Officer will work with the local agency to get a projected date of completion and a timeline on when the local agency?s auditor is able to finalize the audit and submit it to the FAC. The Bureau of WIC will then notify DOH?s Audit Coordinator and OB-BAFM of this information, so they are able to track it. 4. If the WIC local agency does not submit the report by the due date and fails to notify their project officer; a notice to cure letter will be sent to the agency. Concerning NORTH Inc.?s Single Audit report for the period ending September 30, 2021: 1. The Bureau of WIC will contact NORTH Inc. and request a meeting with their auditor. 2. Following the meeting with NORTH Inc.?s auditor, the Bureau Director will send an official letter to NORTH Inc. The letter will include the instructions on how to submit the single audit in the FAC and the Audit Requirements link referenced in their grant agreement. They will also be made aware of the actions that could result from them not submitting this audit by the agreed upon date. 3. If the single audit is not received by the agreed upon date, then the Bureau of WIC will send a notice to cure letter. Anticipated Completion Date: 03/24/2023 Contact Person and Title: Sally Zubairu-Cofield, Director, Bureau of WIC DHS: Regarding the timeliness of finding resolution and procedures related to the SEFA reviews, the Audit Resolution Section (ARS) hired an additional staff member in August 2021 and hired two additional staff members in February 2022, and an additional staff member in January 2023. Finally, the ARS worked with Office of the Budget, Bureau of Accounting and Financial Management to develop a risk-based approach for single audit reviews, which will greatly streamline the process of single audit reviews to gain substantial efficiencies. Regarding late audit report submissions, we will continue to follow the requirements of 2 CFR ?200.339 and Commonwealth Management Directive 325.8. We will continue to work with counties and their independent auditors to obtain any late Single Audit reports. Anticipated Completion Date: 06/30/2023 Contact Person and Title: David Bryan, Manager, ARS; Alexander Matolyak, Director, Division of Audit & Review

View Audit 27724 Questioned Costs: $1

Finding 32426 (2022-006)

Material Weakness 2022

Commonwealth of Pennsylvania

PA

Questioned Costs Special Tests & Provisions Subrecipient Monitoring

Bureau of Operations (BOO): BOO will take the following actions to address the finding: 1. All CAOs and district offices will be reminded of the EBT Coordinators?, alternates?, pinners?, and card makers? responsibilities. The BOO will ensure users in the EBT Card Tracking Database know their respo...

Bureau of Operations (BOO): BOO will take the following actions to address the finding: 1. All CAOs and district offices will be reminded of the EBT Coordinators?, alternates?, pinners?, and card makers? responsibilities. The BOO will ensure users in the EBT Card Tracking Database know their responsibilities and segregation of duties and will ensure there is coverage for card pinning until 5:00 pm each business day. Also, reminders to be sent to review the OIM EBT Procedural Manual periodically and when updates occur. This has already taken place on October 7, 2022. 2. All CAOs and district offices will be reminded to maintain adequate security of the EBT cards, card inventory, pinning devices, and ribbons. The EBT office will ensure all offices have two pinning devices and that they are in working order. This has already taken place on October 7, 2022. 3. OIM mandates annual training for EBT personnel to be completed at the beginning of each year. The training includes reviewing the procedures that safeguard access to the EBT systems. Also included are the following: a. Review of roles and responsibilities and who may hold a role b. Card maker and pinner coverage for all business hours c. Proper security for EBT cards and associated items d. Timeframes for submitting changes e. Retention timeframes Training was completed in January 2023. Area managers and staff assistants monitor completion of the training. Bureau of Program Support (BPS)/EBT Project Office: BPS will take the following actions to address the finding: 1. The EBT Project Office will make updates to the EBT Procedures Manual (Manual) and OIM EPPIC EBT Systems Application form (application) as needed. Notification of updates will be sent to CAO staff via email. This is expected to occur by April 30, 2023. 2. The EBT Program office will provide guidelines for the CAOs to follow when reviewing/updating their written internal procedures for EBT security of card mailings. This is expected to occur by April 30, 2023. 3. The EBT Project Officer will start retraining parties that are responsible for the completion of the EBT Headquarters Card Destruction log. This is expected to occur by May 1, 2023. Bureau of Program Evaluation (BPE), Division of Corrective Action (DCA) will take the following actions to address the finding: BPE, DCA conducts EBT Card Security reviews at every CAO and District Office that issues EBT cards. These reviews are completed on a consistent basis, and in the future will be completed annually on a 3-year rotation basis, to ensure the improvement of the execution of documented policies and procedures. BPE/DCA will adjust the review criteria to incorporate any procedural changes implemented in the Electronic Benefit Transfer Handbook. Current rotation schedule spans FFY 2022- FFY 2024. The annual reviews for this cycle started October 2022. Anticipated Completion Date: BOO 1,2, 3- Completed; BPS 1, 2- 04/30/2023; BPS 3- 05/01/2023; BPE- Completed Contact Person and Title: BOO- Jeanette Coulston, Staff Assistant to Director of Bureau of Operations; BPS- Tonya Holloway, Division Director; BPE- Amira S. Milikin, Division Director

View Audit 27724 Questioned Costs: $1

Finding 32425 (2022-001)

Significant Deficiency 2022

Area Xv Multi-County Housing Agency

IA

HUD Housing Programs Special Tests & Provisions Subrecipient Monitoring

The Authority recognizes that the utility schedule was not updated in the most recent fiscal year. There has been staff turnover in the Authority in the roles that have oversight over these policies and in the transition, numerous things were not communicated as to whose responsibility it now is. Th...

The Authority recognizes that the utility schedule was not updated in the most recent fiscal year. There has been staff turnover in the Authority in the roles that have oversight over these policies and in the transition, numerous things were not communicated as to whose responsibility it now is. The Executive Director will be contacting HUD to determine the next course of action as the utility allowance schedule has been updated for 2023.

View Audit 27901

Finding 32418 (2022-003)

Significant Deficiency 2022

Crawford County Community School Corporation

IN

Subrecipient Monitoring Reporting Significant Deficiency § 200.302 § 200.303 § 200.328

Finding 2022-003 Information on the federal program: Subject: Education Stabilization Fund ? Internal Controls Federal Agency: Department of Education Federal Program: COVID-19 ? Education Stabilization Fund Assistance Listing Number: 84.425C, 84.425D, 84.425U Pass-Through Entity: Indiana Departmen...

Finding 2022-003 Information on the federal program: Subject: Education Stabilization Fund ? Internal Controls Federal Agency: Department of Education Federal Program: COVID-19 ? Education Stabilization Fund Assistance Listing Number: 84.425C, 84.425D, 84.425U Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Significant Deficiency 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 Reporting compliance requirements. Context: The School Corporation was required to submit two Annual Data Reports to the Indiana Department of Education (IDOE) to meet federal reporting requirements for ESSER grant awards and the GEER grant award. The first report was for the period of March 13, 2020 to September 30, 2020 and was due by January 21, 2021. The second report was for the period of October 1, 2020 to June 30, 2021 and was due by May 13, 2022. We noted for both reports that were submitted, there was no documented review by someone other than the preparer of the report to ensure the information submitted was complete and accurate. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding. Crawford County Community School Corporation will continue submission of required data to the IDOE on federal spending with at least two people completing the curation. However, final drafts will be reviewed and then final reports will be signed by the at least two people who reviewed the final draft. This signed copy, if not required to be submitting to the IDOE, will be kept locally. Responsible party and timeline for completion: 1) Amy Belcher, Program Administrator, will ensure all final reports have been reviewed and signed by at least two people before submission to the IDOE immediately.

View Audit 27913

Finding 32417 (2022-002)

Material Weakness 2022

Crawford County Community School Corporation

IN

Matching / Level of Effort / Earmarking Special Tests & Provisions Subrecipient Monitoring § 200.303

Finding 2022-002 Information on the federal program: Subject: Education Stabilization Fund ? Special Tests and Provisions - Wage Rate Requirements Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listing Number: 84.425C, 84.425D, 84.425U P...

Finding 2022-002 Information on the federal program: Subject: Education Stabilization Fund ? Special Tests and Provisions - Wage Rate Requirements Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listing Number: 84.425C, 84.425D, 84.425U Pass-Through Entity: Indiana Department of Education Compliance Requirement: Special Tests and Provisions - Wage Rate Requirements Audit Findings: Material Weakness, Material Noncompliance 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 Special Tests and Provisions ? Wage Rate Requirements compliance requirements. The School Corporation did not obtain the weekly payroll reports certifications from a construction company and its subcontractors for a building project. Context: The School Corporation did not have an internal control designed to collect the weekly payroll reports certifications from a construction company and its subcontractors for a building project. The construction payments represented 45% of the Education Stabilization Fund disbursements for the audit period. Therefore, no review was performed to ensure that pay rates complied with the federal wage rate requirements. The construction contracts did not include a clause for federal wage rate requirements. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding. In the future, when Crawford County Community School Corporation utilizes federal funding to supplement construction costs, the construction manager will ensure awarded contracts include Davis Bacon language and be assigned the task of collecting weekly pay rate data on all contractors and subcontractors. A school employee will then review. Responsible party and timeline for completion: Brandon Johnson, Superintendent, will collect weekly pay rate data from the construction manager and review.

View Audit 27913

Finding 32402 (2022-001)

Material Weakness 2022

Enumclaw School District No. 216

WA

Internal Control / Segregation of Duties Subrecipient Monitoring Allowable Costs / Cost Principles

SUMMARY SCHEDULE OF PRIOR AUDIT FINDINGS Enumclaw School District No. 216 September 1, 2021 through August 31, 2022 This schedule presents the status of findings reported in prior audit periods. Audit Period: September 1, 2020 ? August 31, 2021 Report Ref. No.: 1030921 Finding Ref. No.: 2021-001 Ass...

SUMMARY SCHEDULE OF PRIOR AUDIT FINDINGS Enumclaw School District No. 216 September 1, 2021 through August 31, 2022 This schedule presents the status of findings reported in prior audit periods. Audit Period: September 1, 2020 ? August 31, 2021 Report Ref. No.: 1030921 Finding Ref. No.: 2021-001 Assistance Listing Number(s): 84.425 Federal Program Name and Granting Agency: COVID-19 Education Stabilization Fund, U.S. Department of Education Pass-Through Agency Name: Office of Superintendent of Public Instruction Finding Caption: The District did not have adequate internal controls for ensuring compliance with Davis-Bacon Act (prevailing wage rate) requirements. Background: During the 2020-2021 school year, the District paid $658,502 from its ESSER II award to 11 contractors to repair and replace the roof at two schools, update HVAC controls in seven schools, and replace wet and rotting insulation to improve air quality and circulation to prevent the spread of COVID-19. Additionally, the District used its ESSER II award to replace faulty and broken bathroom sinks to allow for safe and consistent use of sinks for hand washing. Our audit found the District did not have adequate internal controls for ensuring compliance with federal prevailing wage rate requirements. Specifically, the District did not collect weekly certified payroll reports from the contractors to confirm they paid laborers proper prevailing wages. We consider this deficiency in internal controls to be a material weakness, which led to material noncompliance. The issue was not reported as a finding in the prior audit.

View Audit 27599

Finding 32390 (2022-002)

Material Weakness 2022

Christian Housing of St. Joseph, INC Chilton Place Apts.

MO

HUD Housing Programs Internal Control / Segregation of Duties Subrecipient Monitoring

CORRECTIVE ACTION PLAN FOR THE YEAR ENDED MARCH 31, 2022 Name of Audit: Christian Housing of St. Joseph, Inc. HUD Project Number: 084-11148 Name of Audit Firm: Welch & Associates, LLC Period Covered by Audit: Year Ended March 31, 2022 Corrective Action Plan Prepared by: Name: Tamara Wallace Position...

CORRECTIVE ACTION PLAN FOR THE YEAR ENDED MARCH 31, 2022 Name of Audit: Christian Housing of St. Joseph, Inc. HUD Project Number: 084-11148 Name of Audit Firm: Welch & Associates, LLC Period Covered by Audit: Year Ended March 31, 2022 Corrective Action Plan Prepared by: Name: Tamara Wallace Position: Executive Director ? Management Agent Telephone Number: 816-233-4250 Finding 2022-002 Comments on Findings and Each Recommendation: The Organization agrees with the auditors? finding. Action(s) Taken or Planned on the Finding: The Organization is in the process of selling its assets pending HUD approval and expects to dissolve within the next 12 months (see Note 11).

View Audit 27889

Finding 32372 (2022-001)

Material Weakness 2022

School District of Haveford Township

PA

School Nutrition Programs Internal Control / Segregation of Duties Subrecipient Monitoring

Management?s Response: Management will implement safeguards to ensure responsible business office employees are held accountable for following procedures to ensure timely and complete monthly and annual financial reporting.

View Audit 28232

Finding 32371 (2022-002)

Material Weakness 2022

Inova Health System

VA

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles

Recommendation: Inova Juniper Program?s (IJP) existing policies and procedures are in line with the requirements of the pass-through agreement with the Department; however, IJP should continue to evaluate whether appropriate oversight is performed to ensure that these policies and procedures are bei...

Recommendation: Inova Juniper Program?s (IJP) existing policies and procedures are in line with the requirements of the pass-through agreement with the Department; however, IJP should continue to evaluate whether appropriate oversight is performed to ensure that these policies and procedures are being followed with regard to eligibility verification for all clients. View of Responsible Officials: Management concurs with the finding and has implemented, during 2021 and 2022, procedures to ensure the appropriate oversight is performed regarding eligibility. inova.org Inova Health Care Services Name(s) of the Contact Person(s) Responsible for Corrective Action: Christopher T. Smith, Vice President of Finance and Corporate Controller, 571-472-8122. Christopher Trump, Senior Director of Financial Reporting, 571-373-2868. Michael H. Lowen, Director, Grant Accounting, 571-472-8108. Mara Carter, Senior Director Community Health, Inova Juniper Program, 703-321-2687 Planned Completion Date for Corrective Action Planned: Corrective action plan has been implemented.

View Audit 27876 Questioned Costs: $1

Finding 32370 (2022-003)

Significant Deficiency 2022

Inova Health System

VA

Reporting Questioned Costs Subrecipient Monitoring

Recommendation: The System?s policy and procedures should be designed to ensure accurate reporting as required by the Uniform Guidance. View of Responsible Officials: There is no disagreement with the audit finding. Corrective Action Planned: Management will design and ensure written policies and pr...

Recommendation: The System?s policy and procedures should be designed to ensure accurate reporting as required by the Uniform Guidance. View of Responsible Officials: There is no disagreement with the audit finding. Corrective Action Planned: Management will design and ensure written policies and procedures will be created outlining processes and control activities to ensure reporting to federal awarding agencies and pass-through entities are complete and accurate. During the current fiscal year, Inova began implementing enhancements to Oracle?s Grants Accounting module. Once completed, this will assist management to automate certain processes and procedures that were not available after the initial implementation. The enhanced reporting capabilities will include automated reporting that will identify grants that expended federal awards. Grants Accounting will schedule quarterly meetings with Finance and GMO leadership present. The purpose of these meetings will be to review federal funding received that will ultimately be used in the preparation of financial reports submitted to the appropriate governing agencies. The Director of Grants Accounting will guide the meetings and obtain approvals from department leaders confirming amounts to be reported for federal grant awards. In preparation of the meetings, the Director of Grants Accounting will prepare an agenda to guide discussions of grant terms and conditions and applicable FAQs, more explicitly for awards received outside of Inova?s normal course of business (i.e., COVID-19). These meetings will also provide an opportunity for Finance, GMO, and Grants Accounting leaders to review the unique characteristics of the federal grant award programs on at least a quarterly basis. Meeting minutes will be maintained to document discussions and actions to be taken. The minutes will also serve as support for accounting memos related to special awards received that document Inova?s understanding of the award and related reporting requirements. All accounting memos will be prepared by the Director of Grants Accounting and reviewed by the Senior Director of Financial Reporting. Name(s) of the Contact Person(s) Responsible for Corrective Action: Christopher T. Smith, Vice President of Finance and Corporate Controller, 571-472-8122. Christopher Trump, Senior Director of Financial Reporting, 571-373-2868. Michael H. Lowen, Director, Grant Accounting, 571-472-8108. Planned completion Date for Corrective Action Planned: Ongoing with completion date of December 31, 2023.

View Audit 27876

Finding 32338 (2022-003)

None 2022

Thurston County Chamber of Commerce

WA

Internal Control / Segregation of Duties Questioned Costs Subrecipient Monitoring

CORRECTIVE ACTION PLAN Finding 2022-001 Internal Control over Bank Reconciliation and Vendor Invoice Management Response: Management agrees with this recommendation and have taken steps to implement proper review and documentation for bank reconciliations and vendor invoice approvals. Person Resp...

CORRECTIVE ACTION PLAN Finding 2022-001 Internal Control over Bank Reconciliation and Vendor Invoice Management Response: Management agrees with this recommendation and have taken steps to implement proper review and documentation for bank reconciliations and vendor invoice approvals. Person Responsible: President/CEO, Finance Officer, and Program Managers Finding 2022-02 Debarred and Suspended Vendors Management Response: Management agrees with this recommendation and have taken steps to develop and implement proper internal controls. Person Responsible: Finance Officer and Program Managers Finding 2022-03 Monitoring Subcontractor Performance Management response: Management agrees with the recommendation and have scheduled training for key personnel. Person Responsible: Program Managers Finding 2022-04 Written Approval of Subcontractors Management Response: Management agrees with this recommendation and have scheduled training for key personnel. Person Responsible: President/CEO and Program Managers Finding 2022-005 Indirect Cost Allocation ? Questioned Costs Management Response: Management agrees with the need for additional grant training, especially as it applies to calculating and allocating indirect costs. However, we do have issues with the classification of expenses within the original contract and hope we can reconcile those prior to the finalization of the grant award. Person Responsible: President/CEO Finance Officer

View Audit 27061

Finding 32335 (2022-001)

Significant Deficiency 2022

Hopeworks of Howard County, Inc.

MD

Internal Control / Segregation of Duties Questioned Costs Subrecipient Monitoring

Finding: Thirteen reports within three quarters were submitted after the required deadline. We recommend reviewing the controls in place to ensure that all future reports are submitted on time and in accordance with grant requirements. If the Organization expects that there will be a delay in the su...

Finding: Thirteen reports within three quarters were submitted after the required deadline. We recommend reviewing the controls in place to ensure that all future reports are submitted on time and in accordance with grant requirements. If the Organization expects that there will be a delay in the submission of the reports, they should obtain permission to extend the submission date from the awarding agency. Statement of Concurrence or Non-Concurrence Statement of Concurrence: HopeWorks concurs with the finding and recommendation listed above. Corrective Action HopeWorks has implemented a number of streamlined processes in which to expedite the availablity of information needed to file the funder reports more timely. These processes are not limited to electronic import of payroll and benefit entries, implementation and consistent use of Bill.com for expenditures, and prioritization of recording credit card activity. Fifteen days is a strict deadline and if for some reason reporting will be late, HopeWorks will communicate to the funder and document that communication. In FY23, we are also working to streamline the technology and our internal and departmental grant reporting processes to ensure that we are being as efficient as possible with our existing resources, both technological and human.

View Audit 27429

Finding 32303 (2022-004)

Significant Deficiency 2022

City of Nashwauk

MN

Internal Control / Segregation of Duties Significant Deficiency Subrecipient Monitoring

REPRESENTATION OF CITY OF NASHWAUK CORRECTIVE ACTION PLAN Year Ended December 31, 2022 Finding Number: 2022-004 Finding Title: SEGREGATION OF DUTIES Name of Contact Person Responsible for Correcti...

REPRESENTATION OF CITY OF NASHWAUK CORRECTIVE ACTION PLAN Year Ended December 31, 2022 Finding Number: 2022-004 Finding Title: SEGREGATION OF DUTIES Name of Contact Person Responsible for Corrective Action April Kurtock, Clerk/Treasurer Corrective Action Planned The City Council will attempt to monitor transactions and structure the duties of office personnel to help ensure as much segregation of duties as possible within the City's staffing limitations and funding constraints Anticipated Completion Date Ongoing.

View Audit 31098

Finding 32302 (2022-001)

Significant Deficiency 2022

City of Chicopee, Massachusetts

MA

Questioned Costs Subrecipient Monitoring Reporting

Finding 2022-001 Significant Deficiency in Internal Control Over Compliance ? U.S. Department of Treasury ? Coronavirus Relief Fund City Municipal Assistance ? (CFDA No. 21.019) ? Reporting (continued) Passed Through Commonwealth of Massachusetts Executive Office of Administration and Finance Nam...

Finding 2022-001 Significant Deficiency in Internal Control Over Compliance ? U.S. Department of Treasury ? Coronavirus Relief Fund City Municipal Assistance ? (CFDA No. 21.019) ? Reporting (continued) Passed Through Commonwealth of Massachusetts Executive Office of Administration and Finance Name of Person Responsible: Marie T. Laflamme, Treasurer Sharyn Riley, Auditor John Miarecki, School Director of Budget & Finance Corrective Action Planned: The City will immediately review all expenses related to the Coronavirus Relief Funds. The City will take steps to reconcile the Coronavirus Report to our General Ledger. Anticipated Completion Date: May 30, 2023

View Audit 31097

Finding 32258 (2022-013)

Significant Deficiency 2022

State of North Dakota

ND

Questioned Costs Subrecipient Monitoring Matching / Level of Effort / Earmarking

Finding: 2022-013 Department of Human Services Response/Corrective Action Plan: The Department agrees with the recommendation. The Child Care Licensing System (CCL) went live Dec. 2022, CCL will add upcoming unannounced visits to Licensing Specialist?s work que. Licensing Supervisors and the L...

Finding: 2022-013 Department of Human Services Response/Corrective Action Plan: The Department agrees with the recommendation. The Child Care Licensing System (CCL) went live Dec. 2022, CCL will add upcoming unannounced visits to Licensing Specialist?s work que. Licensing Supervisors and the Licensing Administrator will run a monthly report to assure unannounced visits are being completed by the Licensing Specialists. Contact Person: Carmen Traeholt, Child Care Licensing Administrator Anticipated Completion Date: Completed January 2023

View Audit 36677

Finding 32257 (2022-012)

Significant Deficiency 2022

State of North Dakota

ND

Questioned Costs Subrecipient Monitoring Matching / Level of Effort / Earmarking

Finding: 2022-012 Department of Human Services Response/Corrective Action Plan: The Department of Health and Human Service agrees with this recommendation. The Department has been working with a developer to create a Child Care Licensing Data System to replace a paper process and multiple sprea...

Finding: 2022-012 Department of Human Services Response/Corrective Action Plan: The Department of Health and Human Service agrees with this recommendation. The Department has been working with a developer to create a Child Care Licensing Data System to replace a paper process and multiple spreadsheets. The system allows each licensing specialist to see their workflow when they log into the system. It also notifies when a reinspection is needed and will escalate the notice if the reinspection is not done timely. Contact Person: Carmen Traeholt, Child Care Licensing Administrator Anticipated Completion Date: The data system launched in December 2022.

View Audit 36677

Finding 32252 (2022-002)

Material Weakness 2022

Metropolitan Boston Housing Partnership, Inc.

MA

Questioned Costs Subrecipient Monitoring Eligibility

2022-002 Recertifications 14.881 Moving to Work Demonstration Program ? Award No. OCD26401344019MTW 14.871 Housing Choice Voucher Program (Housing Voucher Cluster) ? Award No. OCD26401344019HCV Responsible Official John Hillis Director of Inspections & Property Owner Services, Systems, and Com...

2022-002 Recertifications 14.881 Moving to Work Demonstration Program ? Award No. OCD26401344019MTW 14.871 Housing Choice Voucher Program (Housing Voucher Cluster) ? Award No. OCD26401344019HCV Responsible Official John Hillis Director of Inspections & Property Owner Services, Systems, and Compliance Plan Detail After a detailed RFP process, Metro Housing has selected an outside vendor (Nan McKay) to assist with completing a backlog of regular reexaminations amassed during calendar years 2020 and 2021. The contract was signed on September 27, 2022. By clearing up this backlog of work, Metro Housing staff working on the completion of regular re-exams for the Section 8 HCVP and MTW programs will be able to renew their focus on completing current work timely and accurately. Metro Housing is also making changes to decrease caseload sizes for Program Specialists while also streamlining workflows to better internal and external communication needed to complete our tasks. The roll-out of this new setup should be complete before the end of the current calendar year. Anticipated Completion Date June 30, 2023 ? All reexaminations will be current, and past due percentages will be lowered to acceptable levels.

View Audit 32287

Finding 32251 (2022-001)

Material Weakness 2022

Metropolitan Boston Housing Partnership, Inc.

MA

HUD Housing Programs Subrecipient Monitoring Internal Control / Segregation of Duties

2022-001 Unit Inspections 14.881 Moving to Work Demonstration Program ? Award No. OCD26401344019MTW 14.871 Housing Choice Voucher Program (Housing Voucher Cluster) ? Award No. OCD26401344019HCV Responsible Official John Hillis Director of Inspections & Property Owner Services, Systems, and Com...

2022-001 Unit Inspections 14.881 Moving to Work Demonstration Program ? Award No. OCD26401344019MTW 14.871 Housing Choice Voucher Program (Housing Voucher Cluster) ? Award No. OCD26401344019HCV Responsible Official John Hillis Director of Inspections & Property Owner Services, Systems, and Compliance Plan Detail Metro Housing is converting all eligible inspections from an annual to a biennial cycle as allowed by the program. Due to the constraints of the pandemic waivers, Metro Housing was required to perform an inspection of every unit on its portfolio over a 12-month period instead of a 24-month period, which resulted in numerous delays. This shift should allow for all our inspections to be completed timely. Metro Housing also faced problems in implementing the COVID-waiver issued by HUD to allow for self-certifications of units?namely, if the owner did not provide said waiver, our only recourse would have been to terminate the HAP Contract and force the tenant to move, which was not a course of action deemed appropriate by Metro Housing leadership given the circumstances. We do not anticipate that self-certifications will be implemented again, and so this process should not be a factor moving forward with our ability to meet program requirements. Anticipated Completion Date July 1, 2023 ? All inspections will be in compliance and on a biennial schedule.

View Audit 32287

Finding 32248 (2022-001)

None 2022

West House Corporation

RI

Subrecipient Monitoring HUD Housing Programs Internal Control / Segregation of Duties

August 5, 2022 Re: West House Corporation Project No. 016-EE-010 YE June 30, 2022 Finding 2022-001: Federal Program- Section 811: Criteria- HUD regulations require all bank accounts be fully insured up to the FDIC limit or that management monitor the bank ratings if an excess of the FDIC limit exist...

August 5, 2022 Re: West House Corporation Project No. 016-EE-010 YE June 30, 2022 Finding 2022-001: Federal Program- Section 811: Criteria- HUD regulations require all bank accounts be fully insured up to the FDIC limit or that management monitor the bank ratings if an excess of the FDIC limit exists. Corrective Action Plan: Management has transferred the excess to another bank account. Finding 2002-002: Federal program ? PRAC: Criteria ? the HUD Occupancy handbook specifies the nature and content of tenant income re/certifications. Corrective Action Plan: Management has reviewed all files, obtained required information, and corrected calculations. Site staff will be trained in correct procedures. Please let me know if you have any questions. Sincerely, Jennifer Y. Huynh Vice President

View Audit 32171

Corrective Action Plans

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