Corrective Action Plans

Finding 15987 (2022-040)

Material Weakness 2022

State of Washington C/o Office of Financial Management

WA

Subrecipient Monitoring Reporting Allowable Costs / Cost Principles § 200.208 § 200.332 § 200.339 § 200.501 § 200.513

Finding: The Department of Commerce did not have adequate internal controls over and did not comply with requirements to issue management decisions for audit findings to subrecipients of the Low-Income Home Energy Assistance Program. Questioned Costs: Assistance Listing # 93.568 93.568 COVID-...

Finding: The Department of Commerce did not have adequate internal controls over and did not comply with requirements to issue management decisions for audit findings to subrecipients of the Low-Income Home Energy Assistance Program. Questioned Costs: Assistance Listing # 93.568 93.568 COVID-19 Status: Corrective action complete Corrective Action: The Department?s internal control officer is responsible for completing the monitoring of federal reporting and issuing management decisions for subrecipients who receive federal audit findings for programs funded with the Department?s federal pass-through funding. Beginning in December 2021, the internal control officer documented all findings, corrective action plans, and communication with subrecipients in a monitoring spreadsheet. This enabled the Department to ensure all efforts in monitoring subrecipients were taken. In May 2022, all management decisions were added to the monitoring spreadsheet which documented the Department?s management decisions. To ensure compliance with federal requirements for subrecipient monitoring, the Department has implemented the following process: ? Review all audit findings issued to Department subrecipients. ? Review each subrecipient?s corrective action plan. ? Review and discuss all findings and corrective action plans with subrecipients to identify and understand the basis for the deficiency and planned corrections. ? Create a management decision for each subrecipient finding, receive leadership approval, and formally communicate the decision to our subrecipient. ? All management decisions will be formally communicated to our pass-through subrecipients within the six-month federal deadline. Completion Date: September 2022 Agency Contact: Gena Allen Internal Control Officer PO Box 42525 Olympia, WA 98504-2525 (360) 480-5149 Gena.Allen@Commerce.wa.gov

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Finding 15986 (2022-039)

Material Weakness 2022

State of Washington C/o Office of Financial Management

WA

Subrecipient Monitoring

Finding: The Department of Commerce did not have adequate internal controls over and did not comply with reporting requirements for the Low-Income Home Energy Assistance Program. Questioned Costs: Assistance Listing # 93.568 93.568 COVID-19 Amount $0 Status: Corrective action complete Co...

Finding: The Department of Commerce did not have adequate internal controls over and did not comply with reporting requirements for the Low-Income Home Energy Assistance Program. Questioned Costs: Assistance Listing # 93.568 93.568 COVID-19 Amount $0 Status: Corrective action complete Corrective Action: The Low-Income Home Energy Assistance Program (LIHEAP) receives awards from one funding source in a typical program year. During fiscal year 2022, the Department received additional COVID Pandemic funds from additional sources. The Department was instructed to keep and track all funds separately. The U.S. Department of Health and Human Services (HHS) issued the Action Transmittal LIHEAP-AT-2022-02 Performance Data Form for Fiscal Year 2021 on March 14, 2022. The Action Transmittal states that the first page of the federal report was to include all Coronavirus Aid, Relief, and Economic Security Act and the American Rescue Plan Act funds as combined and separated out in subsequent pages of the report. To meet reporting requirements, the Department tracked and reported all funds separately for regular LIHEAP funding and additional LIHEAP funding. The reports were reviewed and accepted by HHS and APPRISE, a contractor of HHS. The Department follows the reporting process outlined below: ? Program manager pulls the necessary reports. ? Managing director (MD) reviews reports before submittal. ? Program manager submits reports once MD approval is received. ? Program manager receives notice that the report has been accepted by the funder. ? Program manager saves a copy of the report, documentation, and acceptance. The program manager is working with the HHS contractor, APPRISE, to revise the reporting submission. The conditions noted in this finding were previously reported in finding 2021-032. Completion Date: March 2023 Agency Contact: Gena Allen Internal Control Officer PO Box 42525 Olympia, WA 98504-2525 (360) 480-5149 Gena.Allen@Commerce.wa.gov

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Finding 15985 (2022-038)

Material Weakness 2022

State of Washington C/o Office of Financial Management

WA

Subrecipient Monitoring Matching / Level of Effort / Earmarking

Finding: The Department of Commerce did not have adequate internal controls over and did not comply with requirements to ensure it filed reports required by the Federal Funding Accountability and Transparency Act. Questioned Costs: Assistance Listing # 93.568 93.568 COVID-19 Amount $0 Stat...

Finding: The Department of Commerce did not have adequate internal controls over and did not comply with requirements to ensure it filed reports required by the Federal Funding Accountability and Transparency Act. Questioned Costs: Assistance Listing # 93.568 93.568 COVID-19 Amount $0 Status: Corrective action complete Corrective Action: The Department has two programs that administer the two different program funding activities. Corrective actions are listed separately for each program to reflect slightly different implementation timelines. Low-Income Home Energy Assistance Program (LIHEAP) The program added all current awards to the Federal Funding Accountability and Transparency Act (FFATA) Subaward Reporting System and data entry for the sub-awardees was completed as of April 15, 2022. In April 2022, the program implemented the following procedures to strengthen internal controls and to ensure compliance with the reporting requirements: ? Designated the LIHEAP program manager to be responsible for performing the FFATA reporting duties. ? Established a procedure to monitor subawards upon receiving an award letter from the federal grantor, including reviewing incoming amendments and determining if the threshold for FFATA reporting has been reached. ? Stipulated the due date of report submission to be 30 days after the assistant director signs the obligation memo to ensure that the program meets FFATA reporting deadlines. ? Required each award and amendment to be entered separately into the FFATA Subaward Reporting System. The program provided and will continue to provide training to program staff before the annual technical assistance and training conference for sub- grantees. The training consists of the FFATA requirement overview and walkthrough of the Department?s internal FFATA reporting procedures. The program will continue to review the FFATA procedures on an annual basis to ensure compliance with current federal requirements. Corrective action was completed for the Low-Income Home Energy Assistance Program in April 2022. Low-Income Weatherization Program The Low-Income Weatherization Program added all current awards to the FFATA Subaward Reporting System and data entry of the awards was completed as of January 15, 2023. In response to the finding, the program implemented the following procedures to strengthen internal controls and to ensure compliance with the reporting requirements: ? Award letters and funding allocations will be reviewed by the budget team and assistant director before issuing subawards to the weatherization network. ? Added FFATA reporting requirements to the obligation process for contracting funds, which includes an obligation memo that outlines the amounts the program intends to pass through to subrecipients and contractors. ? Designated the Weatherization Program coordinator to be responsible for performing the FFATA reporting duties. ? Established a procedure to monitor subawards upon receiving an award letter from the federal grantor, including reviewing incoming amendments and determining if the threshold for FFATA reporting has been reached. ? Stipulated the due date of report submission to be 30 days after the assistant director signs the obligation memo to ensure that the program meets FFATA reporting deadlines. The program will provide training to all relevant current staff and future staff at the time of onboarding, including supervisors, program managers, and program coordinators. The training will consist of a FFATA requirement overview and walkthrough of the Department?s internal FFATA reporting procedures. The Department will review the FFATA procedures on an annual basis to ensure compliance with current federal requirements. Corrective action was completed for the Low-Income Weatherization Program in January 2023. The conditions noted in this finding were previously reported in finding 2021-031. Completion Date: January 2023 Agency Contact: Gena Allen Internal Control Officer PO Box 42525 Olympia, WA 98504-2525 (360) 480-5149 Gena.Allen@Commerce.wa.gov

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Finding 15981 (2022-037)

Material Weakness 2022

State of Washington C/o Office of Financial Management

WA

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

Finding: The Department of Social and Health Services did not have adequate internal controls over and did not comply with requirements to ensure staff properly considered the income information obtained from data matching when determining client eligibility and benefits for the Temporary Assistanc...

Finding: The Department of Social and Health Services did not have adequate internal controls over and did not comply with requirements to ensure staff properly considered the income information obtained from data matching when determining client eligibility and benefits for the Temporary Assistance for Needy Families program. Questioned Costs: Assistance Listing # 93.558 Amount $0 Status: Corrective action not taken Corrective Action: The Department does not concur with the finding. The Department has established processes in place to ensure income information is properly considered during client eligibility and benefits determination for the Temporary Assistance for Needy Families (TANF) Program. During eligibility determination at application intake, the eligibility worker: ? Interviews the client to determine income. ? Compares client reported information and cross matches against the Income Eligibility and Verification System (IEVS) per the Code of Federal Regulations (CFR). ? Resolves discrepancies for all new or previously unverified information received. ? Uses the information to determine if the client income is below the maximum earned income limits for TANF per WAC 388-478-0035. ? Verifies all circumstances as required in WAC 388-490-0005 and follows requirements when discrepancies exist, which include taking appropriate actions if the information is questionable, confusing, or outdated. The Department utilizes Spider, which is a tool that combines several different data matches including IEVS. In addition, the Department uses templates to appropriately and comprehensively document the eligibility determination to ensure consistency, accuracy, and that lean processes are followed. ? The Earned Income Template o Addresses income received within 30 days of the application date and any discrepancies found between the case record, online verification systems, previously projected income, and income type. o Does not require documentation if there is no income reported and when no discrepancy is found in cross matches. ? The Final Narrative Template o Includes completing check boxes to document types of cross matches reviewed during application intake and a summary of the transactions that occurred. In all seven exceptions identified by the auditors, the client?s situation did not require the eligibility workers to use the Earned Income Templates due to: ? No income reported. ? No income found in IEVS and other cross matches. ? No discrepancies. ? No changes within 30 days. The eligibility workers did create documentation using the Final Narrative Template for all seven cases with notation stating: ?Reviewed the following system(s): Spider.? All these actions were consistent and aligned with the Department?s "Standard Remarks and Narrative Documentation? procedures. Alerts are not generated for all income fluctuations but as appropriate when a review and potential action is required. This is to minimize creating unnecessary alerts which would take staff time away from other required and mission-critical actions. The Department asserts that the system is working as designed, which is evidenced by the fact that the Department accurately determined eligibility in all seven cases identified as exceptions by the auditors. The Department will continue to: ? Review IEVS information at application intake and verify and document any discrepancies between what is reported by the household and what is shown in the cross matches. ? Use templates to ensure documentation supports the eligibility decisions. ? Generate alerts when an applicant is budgeted with zero income, but the IEVS data match shows income. ? Use the final narrative documentation template, that includes check boxes, to notate cross matches reviewed during application intake. Completion Date: Not applicable Agency Contact: Rick Meyer External Audit Compliance Manager PO Box 45804 Olympia, WA 98504-5804 (360) 664-6027 Richard.Meyer@dshs.wa.gov

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Finding 15980 (2022-036)

Material Weakness 2022

State of Washington C/o Office of Financial Management

WA

Allowable Costs / Cost Principles Questioned Costs Subrecipient Monitoring § 200.1 § 200.410 § 200.516

Finding: The Department of Children, Youth, and Families did not have adequate internal controls over and did not comply with client eligibility requirements for child care services paid with the Child Care and Development Fund and Temporary Assistance for Needy Families funds. Questioned Costs:...

Finding: The Department of Children, Youth, and Families did not have adequate internal controls over and did not comply with client eligibility requirements for child care services paid with the Child Care and Development Fund and Temporary Assistance for Needy Families funds. Questioned Costs: Assistance Listing # 93.558 93.575 93.575 COVID-19 93.596 Amount $5,689 $5,078 Status: Corrective action in progress Corrective Action: The Child Care and Development Fund (CCDF) program was previously managed by the Department of Social and Health Services and the Department of Early Learning. Since the program transitioned in 2019, the Department has been making efforts to strengthen internal controls over payments to child care providers and other CCDF grant requirements. In response to the finding, the Department established overpayments and referred them to the Office of Financial Recovery for collection. As part of process and internal control improvements, the Department implemented the Fair Start for Kids Act (FSKA) on October 1, 2021, to simplify rules and expand eligibility. The FSKA: ? Raises the State Median Income threshold, increasing the number of eligible two-parent households. ? Caps copayments at $115 for applicants and $215 for reapplicants, reducing the copay amounts for two-parent households. ? Acts as disincentives for fraud as families are less likely to report the non-custodial parent who is not a household member. The Department continues to review cases for accuracy following these new rules and policies. In September 2022, the Office of Child Care (OCC) released a document to help CCDF lead agencies simplify the format and content of child care assistance applications, which includes guidance on defining, collecting, and verifying eligibility information. The Department continues to follow guidance from OCC to update policies and procedures within the authority under the Revised Code of Washington and Washington Administrative Code. This includes: ? Updating policies and procedures for cases with simplified eligibility such as families experiencing homelessness or families with children receiving protective services. Public Benefit Specialist (PBS) staff received training in the winter of 2022, which included the use of systems data to establish household composition. ? Developing a guide for staff to more effectively use the Employment Security Department (ESD) quarterly reported data for eligibility determinations. The ESD data is directly reported by the employer, secured, and reduces delays in benefits by eliminating the wait for employment verification. It is also simple to use for the PBS staff and the auditors, thereby reducing income calculation errors and removing the need for consumers to provide documentation to support the eligibility determination. This procedural change and training are expected to be completed by the summer of 2023. The conditions noted in this finding were previously reported in findings 2021-035, 2020-039, 2019-032, 2018-030, 2017-026, 2016-023, 2015-026, 2014-026, 2013-017 and 2012-30. Completion Date: Estimated October 2023 Agency Contact: Stefanie Niemela Audit Liaison PO Box 40970 Olympia, WA 98504-0970 (360) 725-4402 stefanie.niemela@dcyf.wa.gov

View Audit 23129 Questioned Costs: $1

Finding 15979 (2022-035)

Material Weakness 2022

State of Washington C/o Office of Financial Management

WA

Allowable Costs / Cost Principles Subrecipient Monitoring Questioned Costs § 200.1 § 200.403 § 200.410 § 200.53

Finding: The Department of Children, Youth, and Families did not have adequate internal controls over and did not comply with requirements to ensure payments to child care providers paid with Temporary Assistance for Needy Families funds were allowable and properly supported. Questioned Costs: A...

Finding: The Department of Children, Youth, and Families did not have adequate internal controls over and did not comply with requirements to ensure payments to child care providers paid with Temporary Assistance for Needy Families funds were allowable and properly supported. Questioned Costs: Assistance Listing # 93.558 Amount $67,699,429 Status: Corrective action in progress Corrective Action: The Working Connections Child Care (WCCC) program was previously managed by the Department of Social and Health Services (DSHS) and the Department of Early Learning. Since the program transitioned in 2019, the Department has been making efforts to strengthen internal controls over payments to child care providers and other grant requirements. The Department implemented grant-level management of all federal funds, including the Temporary Assistance for Needy Families (TANF) grant. The Department allocated the TANF grant to eligible clients and allowable activities in compliance with 45 CFR 98.67. For the fiscal year 2021 program audit, the State Auditor?s Office (SAO) issued a finding with $32 questioned costs for non-compliance with the CCDF eligibility requirement. No other findings, management letters, or exit items were reported in this compliance area or the cost allocation of funds based on eligibility for the CCDF or TANF grants. Given that eligibility or cost allocation has not been an area of concern, and transfers were processed between TANF and CCDF source of funds with the same eligibility criteria, the Department is assured that TANF funding was spent appropriately within federal regulations. The Department is committed to improving internal controls. The Department does not currently have the resources to develop and maintain the business process redesign, as well as the information technology initiatives necessary to meet the level of assurance recommended by SAO. In response to prior year?s audit recommendations, the Department has submitted a budget request to the Legislature in the 2023-2025 biennial budget for additional resources to process adjustments to include transaction-level data. As part of the audit resolution process, the Department of Health and Human Services (HHS), which oversees the CCDF program at the federal level, reviews all SAO findings and issues management decision letters. The letters will reflect the grantor?s determination of whether an audit finding is sustained, the reasons for the decision, and the required actions by the auditee. When a management decision is issued for the fiscal year 2021 finding, the Department will work with HHS and follow the audit resolution process. Completion Date: Agency Contact: The conditions noted in this finding were previously reported in finding 2021-028. Estimated December 2024 Stefanie Niemela Audit Liaison PO Box 40970 Olympia, WA 98504-0970 (360) 725-4402 stefanie.niemela@dcyf.wa.gov

View Audit 23129 Questioned Costs: $1

Finding 15976 (2022-034)

Material Weakness 2022

State of Washington C/o Office of Financial Management

WA

Subrecipient Monitoring Reporting Equipment & Real Property Management

Finding: The Department of Health did not have adequate internal controls over and did not comply with reporting requirements for the Epidemiology and Laboratory Capacity for Infectious Diseases program. Questioned Costs: Assistance Listing # 93.323 93.323 COVID-19 Status: Corrective action...

Finding: The Department of Health did not have adequate internal controls over and did not comply with reporting requirements for the Epidemiology and Laboratory Capacity for Infectious Diseases program. Questioned Costs: Assistance Listing # 93.323 93.323 COVID-19 Status: Corrective action in progress Corrective Action: The Department partially agrees with the finding. For the two reports on which the auditors took exceptions, the Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) program did discover the errors after the original reports were submitted. The Department notified the Centers for Disease Control and Prevention (CDC) about the reporting errors in February 2022, which was within the reporting period. However, due to a technical issue, the federal reporting system would not allow ELC program staff to input edits to the reports for the months of July through October 2021. After a discussion with CDC, program staff were advised to submit the corrected data of the previous reports via email, which was subsequently accepted by the grantor and the issue was resolved. The Department agrees there needs to be evidence of documented reviews of reports and is implementing steps to ensure review and approval of reports are well documented and retained before final submission to the federal grantor. Completion Date: Estimated December 2023 Agency Contact: Jeff Arbuckle External Audit Manager PO Box 47890 Olympia, WA 98504-7890 (360) 701-0798 Jeff.Arbuckle@doh.wa.gov

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Finding 15975 (2022-033)

Material Weakness 2022

State of Washington C/o Office of Financial Management

WA

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles § 200.00 § 200.516

Finding: The Department of Health did not have adequate internal controls over and did not comply with fiscal monitoring requirements to ensure subrecipients of the Epidemiology and Laboratory Capacity for Infectious Diseases program only used funds for allowable activities and met cost principles....

Finding: The Department of Health did not have adequate internal controls over and did not comply with fiscal monitoring requirements to ensure subrecipients of the Epidemiology and Laboratory Capacity for Infectious Diseases program only used funds for allowable activities and met cost principles. Questioned Costs: Assistance Listing # 93.323 93.323 COVID-19 Amount $1,644,873 Status: Corrective action in progress Corrective Action: The Department partially concurs with the finding. The Department agrees with the auditors? recommendation over subrecipient monitoring to require transactions that were previously coded as ?COVID? to be recorded with the specific revenue source and will do so in future monitoring visits. The Department does not agree with the auditors? assessment of a material weakness in internal controls over subrecipient monitoring. When staff conduct fiscal monitoring site visits, key control systems including payroll and disbursements are reviewed and documented. These monitoring activities ensure internal controls are operating effectively and providing assurance that reimbursements are allowable and accurate. The Department acknowledges that internal controls can be strengthened over provider payments and will take the following actions: ? Require payments to providers be adequately supported by the appropriate backup documentation and subrecipient risk assessments. ? Update the documentation requirements to align with the identified risk levels and federal guidance. ? Develop tracking sheets, which enable staff to record details from backup documentation reviews and payment approvals. ? Provide additional training to staff in the Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) program responsible for reviewing invoices. The Department disagrees with the SAO?s assessment of a material weakness in internal controls over the consolidated contract provider payment process for the ELC program. The Department has established processes in place to ensure payments are allowable and meet cost principles for the program. These include: ? Perform annual review and approval of detailed subrecipient budgets. ? Compare invoice amounts to budgeted amounts for reasonableness before payment approval. ? Provide subrecipients regular technical assistance and training on applicable policies related to fiscal and programmatic processes. ? Conduct biennial program and fiscal monitoring visits to subrecipients as part of the Department?s monitoring procedures. In addition, the ELC program has monitoring controls in place and evidence of review at the program level. Program staff maintain a detailed spreadsheet that documents review and approval and includes any amounts that need to be withheld until issues with invoice support are resolved. These reviews are to be completed within the 10-day period before payment is released. The Department is planning on meeting with federal grantors to work through the exceptions and questioned costs identified in the finding. Completion Date: Estimated March 2024 Agency Contact: Jeff Arbuckle External Audit Manager PO Box 47890 Olympia, WA 98504-7890 (360) 701-0798 Jeff.Arbuckle@doh.wa.gov

View Audit 23129 Questioned Costs: $1

Finding 15970 (2022-032)

Material Weakness 2022

State of Washington C/o Office of Financial Management

WA

Subrecipient Monitoring Internal Control / Segregation of Duties Matching / Level of Effort / Earmarking

Finding: The Department of Health did not have adequate internal controls to ensure it filed accurate and timely reports required by the Federal Funding Accountability and Transparency Act for the Immunization Cooperative Agreements program. Questioned Costs: Assistance Listing # 93.268 93.26...

Finding: The Department of Health did not have adequate internal controls to ensure it filed accurate and timely reports required by the Federal Funding Accountability and Transparency Act for the Immunization Cooperative Agreements program. Questioned Costs: Assistance Listing # 93.268 93.268 COVID-19 Amount $0 Status: Corrective action in progress Corrective Action: The Department agrees with the finding. The Department will review internal processes and determine when a review is most effective to ensure accuracy and completeness of the Federal Funding Accountability and Transparency Act reporting submissions. Management has already addressed the obligation dates to ensure the execution date of the award or amendment is reported. Completion Date: Estimated July 2024 Agency Contact: Jeff Arbuckle External Audit Manager PO Box 47890 Olympia, WA 98504-7890 (360) 701-0798 Jeff.Arbuckle@doh.wa.gov

View Audit 23129

Finding 15969 (2022-031)

Material Weakness 2022

State of Washington C/o Office of Financial Management

WA

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles § 200.00 § 200.1 § 200.410 § 200.516

Finding: The Department of Health did not have adequate internal controls over and did not comply with requirements to ensure payments to providers were allowable, met cost principles, and were within the period of performance for the Immunization Cooperative Agreements program. Questioned Costs:...

Finding: The Department of Health did not have adequate internal controls over and did not comply with requirements to ensure payments to providers were allowable, met cost principles, and were within the period of performance for the Immunization Cooperative Agreements program. Questioned Costs: Assistance Listing # 93.268 93.268 COVID-19 Status: Corrective action in progress Corrective Action: The Department partially agrees with the finding. The Department agrees that internal controls can be strengthened over provider payments to ensure funds are allowable and spent within the period of performance. The following actions were taken: ? Required payments to providers contain adequate support in line with the A19 matrix and subrecipients? risk assessments. ? Provided additional training to staff in the immunization unit responsible for reviewing invoices. ? Developed tracking sheets which enable staff to record details from backup documentation reviews and payment approvals. The Department will review the control weaknesses identified in the audit related to the consolidated contract payment process and will determine if changes need to be made. The Department disagrees with the audit exceptions and questioned costs identified in the finding. The Department will work with the federal grantor to resolve any questioned costs. Completion Date: Estimated December 2023 Agency Contact: Jeff Arbuckle External Audit Manager PO Box 47890 Olympia, WA 98504-7890 (360) 701-0798 Jeff.Arbuckle@doh.wa.gov

View Audit 23129 Questioned Costs: $1

Finding 15901 (2022-002)

Material Weakness 2022

Woodland School District No. 404

WA

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

Finding ref number: 2022-002 Finding caption: The District did not have adequate internal controls for ensuring compliance with wage rate requirements. Name, address, and telephone of District contact person: Stacy Brown, Director of Business Services 800 Second St Woodland, WA 98674-8467 (360) 8...

Finding ref number: 2022-002 Finding caption: The District did not have adequate internal controls for ensuring compliance with wage rate requirements. Name, address, and telephone of District contact person: Stacy Brown, Director of Business Services 800 Second St Woodland, WA 98674-8467 (360) 841-2715 Corrective action the auditee plans to take in response to the finding: (If the auditee does not concur with the finding, the auditee must list the reasons for disagreement). The current vendor invoices do not break out when we are getting equipment and when there are staff onsite working. The work has been sporadic, so in the Business Office, we do not know when they are onsite and therefore not sure when payrolls are required. We are working with the maintenance department to keep us apprised when we have contractors onsite working on the HVAC (ESSER) projects. We originally thought we could get the weekly payrolls from the L&I website, but are finding that they are not posted timely and sometimes not at all. We are working directly with the vendors to provide weekly payrolls when they are working. The district has implemented a review log for all Federal projects requiring review of weekly payrolls. The Purchasing and Benefits Coordinator will document the vendor, week and certify that she has received and reviewed the payrolls received. Payment will be withheld if we do not receive the payrolls in a timely manner. Anticipated date to complete the corrective action: 6/12/23

View Audit 19549

Finding 15899 (2022-001)

Material Weakness 2022

Woodland School District No. 404

WA

Questioned Costs Procurement, Suspension & Debarment Subrecipient Monitoring

Finding ref number: 2022-001 Finding caption: The District did not have adequate internal controls for ensuring compliance with allowable activities and costs, equipment, procurement, and restricted purpose requirements. Name, address, and telephone of District contact person: Stacy Brown, Director...

Finding ref number: 2022-001 Finding caption: The District did not have adequate internal controls for ensuring compliance with allowable activities and costs, equipment, procurement, and restricted purpose requirements. Name, address, and telephone of District contact person: Stacy Brown, Director of Business Services 800 Second St Woodland, WA 98674-8467 (360) 841-2715 Corrective action the auditee plans to take in response to the finding: (If the auditee does not concur with the finding, the auditee must list the reasons for disagreement). The district disagrees with some portions of the finding. The district originally was not going to participate in the ECF program as we did not believe we had an unmet need, per the original requirements. We then received notification from our contractor that the FCC had clarified the rules and if we have a policy that shows we only allow district owned and managed devices on our network and we can estimate how many devices (staff and student) would be needed if the school or some schools went back to remote learning, we would qualify for funding. Based on this information and a review of our policies, we decided to apply for the funds. The finding states that we do not have internal controls in place to ensure we have all required elements for our inventories. We were not able to get serial numbers from the vendor but we were able to back into the dates the Chromebooks were entered into inventory and accounted for all 600 student devices and the students to which they were assigned. This also showed that we met the restricted purpose of one device per student or staff member. In response to the finding, the district will make the following corrective actions: 1. The Business Manager will be more diligent in ensuring that all Federal program funds are properly included on the Schedule of Expenditures of Federal Assistance (SEFA). 2. The district will ensure that they are aware of compliance requirements new or unfamiliar Federal grants. 3. The district will ensure that devices or equipment purchased with Federal funds are identified as such and accounted for as such in the district inventory. 4. The district will ensure that Federal and District procurement policies are followed, including sealed bids for purchases greater than $75.000. 5. Once accounting for ECF purchases as federal devices, the district will be able to show that only one device has been issued to each student and staff member. Anticipated date to complete the corrective action: 6/12/23

View Audit 19549 Questioned Costs: $1

Finding 15893 (2022-001)

Material Weakness 2022

Home Share 092-Hd017

MN

Internal Control / Segregation of Duties Eligibility HUD Housing Programs § 200.303

March 27, 2023 HOME SHARE HUD PROJECT NO. 092-HD017 Corrective Action Plan Finding: 2022-001 ? Compliance and Controls over Compliance ? Eligibility Supportive Housing for Persons with Disabilities (Section 811), CFDA No. 14.181 Material Weakness & Noncompliance In 2022, Home Share did not have cont...

March 27, 2023 HOME SHARE HUD PROJECT NO. 092-HD017 Corrective Action Plan Finding: 2022-001 ? Compliance and Controls over Compliance ? Eligibility Supportive Housing for Persons with Disabilities (Section 811), CFDA No. 14.181 Material Weakness & Noncompliance In 2022, Home Share did not have controls in place to ensure that eligibility criteria and rent calculations were being reviewed and/or approved by someone other than the individual making the initial determination or annual recertification. Actions Taken or Planned: Management agrees with this finding. Beginning in January 2022, management has contracted out the eligibility determination process to a third-party contractor with significant experience in affordable housing and similar processes. Management is working with the contractor to include a second individual in this process so that there will be a review performed by someone other than the individual making the initial determination or annual recertification. Contact Persons: Ernest Johnson, Housing Associate Director Robert Pickering, Chief Financial Officer

View Audit 19545

Finding 15889 (2022-004)

Material Weakness 2022

Memorial Health and Subsidiaries

IL

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles § 200.303

? Finding 2022-004 ? In October 2022, Management enhanced its maintained supporting documentation to provide evidence of review and approval of FEMA expenditures and financial reporting for future FEMA submissions. o Responsible Party: Amanda Zentefis

View Audit 19521

Finding 15884 (2022-003)

Significant Deficiency 2022

Memorial Health and Subsidiaries

IL

Subrecipient Monitoring Questioned Costs Reporting § 200.303

? Finding 2022-003 ? On or before September 30, 2023, Management will re-review its subrecipient monitoring policy and ensure it has fully complied during its fiscal year 2023. o Responsible Party: Peggy Wisher

View Audit 19521

Finding 15882 (2022-001)

Material Weakness 2022

Memorial Health and Subsidiaries

IL

Subrecipient Monitoring Reporting Questioned Costs § 200.303

? Finding 2022-001 ? In June 2023, Management re-educated itself on the terms & conditions of the Hospital Rate Agreement and has adjusted its subaward calculation forms to ensure direct costs included in the base is limited to $25,000 per subaward per grant year for purposes of calculating indirect...

? Finding 2022-001 ? In June 2023, Management re-educated itself on the terms & conditions of the Hospital Rate Agreement and has adjusted its subaward calculation forms to ensure direct costs included in the base is limited to $25,000 per subaward per grant year for purposes of calculating indirect costs. On or before September 30, 2023, Management will review all indirect cost rate calculations covering its fiscal year 2023 and ensure the correct indirect cost rate used was based on the applicable Hospital Rate Agreement. In addition, effective June 2023, Management has changed its process to ensure updates to the indirect cost rate used is applied in the month the updated Hospital Rate Agreement is received from the Federal agency, and no later. o Responsible Party: Peggy Wisher

View Audit 19521 Questioned Costs: $1

Finding 15880 (2022-001)

Significant Deficiency 2022

Mar Vista Eldorado, INC

IN

Subrecipient Monitoring Cash Management HUD Housing Programs

Name of auditee: Mar Vista Eldorado, Inc. HUD auditee identification number: 122-EH528-WAH-NP Name of audit firm: Dauby O'Connor & Zaleski, LLC Period covered by the audit: Year ended June 30, 2022 CAP prepared by Name: Dwight Hargett Position: President/CEO - Management Agent Tele...

Name of auditee: Mar Vista Eldorado, Inc. HUD auditee identification number: 122-EH528-WAH-NP Name of audit firm: Dauby O'Connor & Zaleski, LLC Period covered by the audit: Year ended June 30, 2022 CAP prepared by Name: Dwight Hargett Position: President/CEO - Management Agent Telephone number: 812-987-8344 Current Findings on the Summary of Auditors Results Statement of Condition 2022-001 (Assistance Listing Number 14.157): The required residual receipts deposit in the amount of $9,607 per the June 30, 2021 Computation of Surplus Cash, Distributions and Residual Receipts was not deposited into the residual receipts account within 90 days after the fiscal year end. Recommendation: Management should make a deposit of $9,607 to the residual receipts account for the underfunded amount. Additionally, management should make deposits, as required by the Regulatory Agreement, on an annual basis. Actions taken or planned on the finding: Management made a deposit of $9,607 on August 4, 2022 to fully fund the residual receipts account for the year ended June 30, 2022.

View Audit 19417 Questioned Costs: $1

Finding 15875 (2022-007)

Material Weakness 2022

School District of Marathon City

WI

Internal Control / Segregation of Duties Questioned Costs Subrecipient Monitoring

Child Nutrition Cluster Reporting Child Nutrition Cluster - Assistance Listing No. 10.553, 10.555 Recommendation: We recommend the District implement a review procedure over reimbursement requests where someone other than the preparer reviews the claim to ensure accounts agree back to supporting doc...

Child Nutrition Cluster Reporting Child Nutrition Cluster - Assistance Listing No. 10.553, 10.555 Recommendation: We recommend the District implement a review procedure over reimbursement requests where someone other than the preparer reviews the claim to ensure accounts agree back to supporting documentation prior to the reimbursement request being filed with the grating agency. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action Planned/Taken: Food service reports are now reviewed and initialed monthly. Food service director would initially run the report and it would be reconciled by the Business Manager. Final claims are reconciled before the report is submitted and initialed by the Superintendent. Name(s) of the contact person(s) responsible for corrective action: Nimisha Patel, Business Manager Planned completion date for corrective action plan: January 1, 2023

View Audit 19352

Finding 15833 (2022-030)

Material Weakness 2022

State of Washington C/o Office of Financial Management

WA

Subrecipient Monitoring Procurement, Suspension & Debarment Allowable Costs / Cost Principles § 200.208 § 200.332 § 200.339 § 200.501 § 200.513

Finding: The University of Washington did not have adequate internal controls over and did not comply with federal requirements to ensure subrecipients of the Global AIDS program received required single or program-specific audits, and that it followed up on findings and issued management decisions...

Finding: The University of Washington did not have adequate internal controls over and did not comply with federal requirements to ensure subrecipients of the Global AIDS program received required single or program-specific audits, and that it followed up on findings and issued management decisions. Questioned Costs: Assistance Listing # 93.067 93.067 COVID-19 Amount $0 Status: Corrective action in progress Corrective Action: The University maintains that there are adequate internal controls to ensure the Global AIDS program complies with the requirements for pass-through entities as outlined in Uniform Guidance 2 CFR ? 200.332 and the university policy incorporated in Grants Information Memorandum 8. As noted in the finding, the University uses a certification process to obtain information and documentation needed, such as audited financial statements, from each subrecipient and perform a risk assessment using standard risk criteria. For the one exception identified by the auditors, the University misinterpreted the response provided by the subrecipient regarding whether it expended $750,000 or more in federal awards during the fiscal year. Although the single or program specific audit report was not obtained and reviewed, a risk assessment was performed on the subrecipient. With a medium risk rating, the subrecipient was subject to monitoring at the program level throughout the project during the period in question, in accordance with University policy. The University will: ? Update the certification process with all subrecipients to confirm if federal expenditures during a fiscal year exceed the $750,000 threshold to require a single or program-specific audit. ? Issue written management decisions for all applicable audit findings. ? Ensure subrecipients develop and perform acceptable corrective actions to address all audit recommendations, if applicable. Completion Date: Estimated September 2023 Agency Contact: Erick Winger Controller 4300 Roosevelt Way NE Seattle, WA 98195 (206) 543-5322 erickw@uw.edu

View Audit 23129

Finding 15832 (2022-029)

Material Weakness 2022

State of Washington C/o Office of Financial Management

WA

Subrecipient Monitoring

Finding: The University of Washington did not have adequate internal controls over and did not comply with requirements to ensure it filed reports required by the Federal Funding Accountability and Transparency Act. Questioned Costs: Assistance Listing # 93.067 93.067 COVID-19 Amount $0 St...

Finding: The University of Washington did not have adequate internal controls over and did not comply with requirements to ensure it filed reports required by the Federal Funding Accountability and Transparency Act. Questioned Costs: Assistance Listing # 93.067 93.067 COVID-19 Amount $0 Status: Corrective action in progress Corrective Action: The University acknowledges that one report related to the Global AIDS program subaward modification was not submitted during the audit period in accordance with Federal Funding Accountability and Transparency Act (FFATA) requirements. The University: ? Submitted the required report as of May 2023. ? Reviewed all subaward actions (new subawards and modifications) for the program active during fiscal year 2022 and verified that no additional reports were missed. The University maintains that solid and effective controls are already in place related to FFATA reporting, but acknowledges that the current process can be enhanced through better use of the data in the Sponsored Projects Administration and Electronic Research Compliance (SPAERC) system. The University will: ? Strengthen management monitoring process to ensure compliance with FFATA reporting requirements. ? Design a report to assist in the identification and review of FFATA-reportable actions. Implementation of this process is expected to occur in fiscal year 2024. Completion Date: Estimated December 2023 Agency Contact: Erick Winger Controller 4300 Roosevelt Way NE Seattle, WA 98195 (206) 543-5322 erickw@uw.edu

View Audit 23129

Finding 15831 (2022-028)

Material Weakness 2022

State of Washington C/o Office of Financial Management

WA

Subrecipient Monitoring Allowable Costs / Cost Principles § 200.516

Finding: The University of Washington did not establish adequate internal controls to ensure payments to contractors and subrecipients for the Global AIDS program were allowable, properly supported and within the period of performance. Questioned Costs: Assistance Listing # 93.067 93.067 COV...

Finding: The University of Washington did not establish adequate internal controls to ensure payments to contractors and subrecipients for the Global AIDS program were allowable, properly supported and within the period of performance. Questioned Costs: Assistance Listing # 93.067 93.067 COVID-19 Amount $0 Status: Corrective action complete Corrective Action: The University partially concurs with the finding. The University disagrees with the auditors? assertion that internal controls were inadequate to ensure payments to contractors and subrecipients of the Global AIDS program were allowable, properly supported, and within the period of performance. Payments to country offices The University administers the program through its International Training and Education Center for Health (I-TECH), a center in the University?s Department of Global Health, with staff in various locations worldwide. I-TECH country offices are not contractors but are an extension of the University. The audit identified one of 58 payments in the test sample (1.7 percent) that did not meet the approval requirements set forth in I-TECH?s standard operating procedures. Based on the error percentage, the University disagrees with this part of the finding. Payments to contractors The University?s current payment process to contractors has multiple approval requirements. Upon receipt, program/budget manager reviews and approves individual invoices prior to input into the University?s procurement system by the I-TECH accounts payable administrator. The system requires compliance approval from the account payable supervisor or other manager, as well as funding approval from the budget manager prior to payment. Approvals of Budget Activity Reports (BARS) are not part of the approval process for contractor payments, but are post-payment reviews by budget managers of monthly expenses posted to the budget to ensure they are within expectations. The University disagrees with the exceptions identified in the finding related to payments to contractors. The exceptions noted were payments made to country offices instead of contractors, the supporting approvals of which were provided to the auditors on April 26, 2023, prior to the completion of fieldwork. Subrecipient reimbursements Contract managers review each subrecipient invoice for reasonableness, allowability and allocability, and require approval by both budget managers and principal investigators (PI) prior to payment in the University?s procurement system. The auditors reviewed and verified PI approvals for each selected subrecipient with no exception identified. It should be noted that approvals of BARS are also not part of the approval process for payments to subrecipients. The University acknowledges that documentation related to BARS reviews by budget managers was not available for 52 of the transactions tested and agrees that improvement is needed for retaining documentation of monthly reviews. In response to the finding, the University has started saving BARS review documentation on the server to ensure the documents are readily available. Completion Date: April 2023 Agency Contact: Erick Winger Controller 4300 Roosevelt Way NE Seattle, WA 98195 (206) 543-5322 erickw@uw.edu

View Audit 23129

Finding 15816 (2022-027)

Material Weakness 2022

State of Washington C/o Office of Financial Management

WA

Subrecipient Monitoring Internal Control / Segregation of Duties Matching / Level of Effort / Earmarking

Finding: The Office of Financial Management did not have adequate internal controls over and did not comply with federal level of effort requirements for the Education Stabilization Fund program. Questioned Costs: Assistance Listing # 84.425D COVID-19 84.425R COVID-19 94.425U COVID-19 84.425...

Finding: The Office of Financial Management did not have adequate internal controls over and did not comply with federal level of effort requirements for the Education Stabilization Fund program. Questioned Costs: Assistance Listing # 84.425D COVID-19 84.425R COVID-19 94.425U COVID-19 84.425V COVID-19 Amount $0 Status: Corrective action not taken Corrective Action: The Office does not concur with the finding. The Office performed the maintenance of effort (MOE) calculations in accordance with the guidance provided by the U.S. Department of Education (ED). Based on appropriations and past funding, it was determined that the fiscal year 2022 expenditure level did not meet the MOE requirement. The Office followed the federal guidance and directions from a legislative proviso in the enacted state budget (Chapter 334, Laws of 2021, Sec. 954) and submitted a waiver request for fiscal years 2022 and 2023. The waiver was submitted before ED?s stipulated deadline of December 31, 2021. ED?s website confirmed an MOE waiver request was received from Washington state and the status of the request is currently listed as ?under review.? The Office maintains adequate internal controls and has followed all federal and state requirements with due diligence in requesting the MOE waiver. The approval process rests with the federal grantor, and the waiver has not been disapproved. In addition, the Office has been meeting with ED on a monthly basis and is already consulting with the grantor regarding the pending waiver request. The Office will also continue to work with the Legislature, which is the state-level authority for state appropriations, to monitor any updates to federal requirements. Completion Date: Not applicable Agency Contact: Brian Tinney Statewide Accounting Director PO Box 43127 Olympia, WA 98504-3127 (564) 999-1781 brian.tinney@ofm.wa.gov

View Audit 23129

Finding 15799 (2022-001)

Significant Deficiency 2022

The International Center for Journalists, Inc.

DC

Subrecipient Monitoring Reporting

Views of Responsible Officials and Planned Corrective Actions: All applicable subawards (including any cost-related modifications) are now registered in the FFATA Subaward Reporting System (FSRS.gov). ICFJ?s Budget & Compliance Officer carefully reviews all new Federal awards received by ICFJ to ens...

Views of Responsible Officials and Planned Corrective Actions: All applicable subawards (including any cost-related modifications) are now registered in the FFATA Subaward Reporting System (FSRS.gov). ICFJ?s Budget & Compliance Officer carefully reviews all new Federal awards received by ICFJ to ensure all applicable subawards are registered at FSR.gov in compliance with FFATA requirement. Periodic trainings on FFATA compliance for all staff who work on federally-funded awards have been conducted and are scheduled at least annually. FFATA requirement is a checklist item during onboarding of new awards.

View Audit 22274

Finding 15797 (2022-001)

Significant Deficiency 2022

Lake Erie Preparatory School

OH

Special Tests & Provisions Questioned Costs Subrecipient Monitoring

Finding Number: 2022-001: ESSER ? Wage Rate Requirements Planned Corrective Action: Summary of corrective action to be taken Anticipated Completion Date: December 31, 2022 Responsible Contact Person: Dave Massa, Treasurer As recommended, the School will perform existing controls and establish new c...

Finding Number: 2022-001: ESSER ? Wage Rate Requirements Planned Corrective Action: Summary of corrective action to be taken Anticipated Completion Date: December 31, 2022 Responsible Contact Person: Dave Massa, Treasurer As recommended, the School will perform existing controls and establish new controls to ensure that contractors and subcontractors are in compliance with all labor standards by conducting on-site inspections and collecting the required certified payroll documentation in a timely manner. Specifically, the School will add an Affidavit of Compliance Form to the contracts that will be required to be submitted by the grantee before closing. A project will not be considered closed until the School has received an executed copy of the form. Upon notification of construction commencement, the School will immediately begin monitoring for Wage Rate Requirements in the form of both on-site inspections and review and approval of certified payroll reports.

View Audit 21372

Finding 15786 (2022-002)

Significant Deficiency 2022

United Way of Thurston County

WA

Subrecipient Monitoring

Auditor?s Recommendations: The Organization should communicate the compliance requirements for staff involved in the distribution of funds to sub-recipients. The staff should conduct the required procedures to monitor the use of funds, check status of programs and obtain regular updates sufficient...

Auditor?s Recommendations: The Organization should communicate the compliance requirements for staff involved in the distribution of funds to sub-recipients. The staff should conduct the required procedures to monitor the use of funds, check status of programs and obtain regular updates sufficient to satisfy themselves regarding the appropriate use of funds in accordance with the requirements of the federal award and any related contracts. Response: Finance Director, Richele Center, will update the finance policies with the procurement policy including a section concerning Federal Awards. This new section will include guidance for Budget Managers requiring them to create a system of monitoring the appropriate use of funds for each project or sub recipient based on specific federal award. Budget Managers will be responsible for creating and implementing a timeline, and procedures sufficient to ensure their confidence that the funds are being used appropriately based on the contract. Budget Managers will provide documentation of monitoring to Finance Director, Richele Center, for auditing purposes. Timing of Remediation: This updated policy will be completed by the Finance Director, Richele Center by March 23, 2023.

View Audit 18901

Corrective Action Plans

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