Corrective Action Plans

Finding 1207081 (2024-038)

Material Weakness 2024

State of Illinois

IL

Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties Special Tests & Provisions § 200.303

Finding Number: 2024-038 Finding Name: Failure to Follow Established Control Procedures for Approving Certified Payrolls for the Airport Improvement Program, COVID-19 Airports Programs, and Infrastructure Investment and Jobs Act Programs (AIP) Finding Condition(s): The Illinois Department of Transpo...

Finding Number: 2024-038 Finding Name: Failure to Follow Established Control Procedures for Approving Certified Payrolls for the Airport Improvement Program, COVID-19 Airports Programs, and Infrastructure Investment and Jobs Act Programs (AIP) Finding Condition(s): The Illinois Department of Transportation (IDOT) did not document approval of certified payrolls in accordance with its established internal control procedures for the Airport Improvement Program (AIP) program. Name of Contact Person(s): Joe Segobiano, Bureau Chief of Administrative Services – Illinois Department of Transportation, Division of Aeronautics Corrective Action(s): IDOT’s Construction Section within the Bureau of Airport Engineering of the Division of Aeronautics will verify that payrolls are attached to pay estimates and that they are signed and dated by the resident engineer prior to submittal to the Bureau of Administrative Services at the Division for ultimate financial review/fulfillment. Proposed Completion Date: June 30, 2026

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Finding 1207079 (2024-037)

Material Weakness 2024

State of Illinois

IL

Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties Subrecipient Monitoring § 200.303

Finding Number: 2024-037 Finding Name: Inaccurate Special Report Finding Condition(s): The Illinois Department of Commerce and Economic Opportunity (DCEO) did not maintain supporting documentation for key line items or prepare accurate special reports for the Low-Income Home Energy Assistance Progra...

Finding Number: 2024-037 Finding Name: Inaccurate Special Report Finding Condition(s): The Illinois Department of Commerce and Economic Opportunity (DCEO) did not maintain supporting documentation for key line items or prepare accurate special reports for the Low-Income Home Energy Assistance Program (LIHEAP). Additionally, the DCEO has not established appropriate internal controls to ensure its quarterly reports submitted to the United States Department of Health and Human Services (DSDHHS) are properly supported in accordance with federal requirements. Finally, the DCEO’s supervisory review procedures have not been designed to operate at a level of precision to identify errors of the size and nature noted above. Name of Contact Person(s): • Lisa Clement, Audit Liaison – Illinois Department of Commerce and Economic Opportunity, Office of Accountability • Jared Ebel, Chief Accountability Officer – Illinois Department of Commerce and Economic Opportunity, Office of Accountability • Ben Moore, Fiscal Operations Manager – Illinois Department of Commerce and Economic Opportunity, Office of Community Assistance • David Wortman, Deputy Director - Illinois Department of Commerce and Economic Opportunity, Office of Community Assistance Corrective Action(s): The DCEO’s Office of Community Assistance (OCA) has implemented a process for an independent verification by a second OCA staff member of the correct data entry prior to submission of obligated funds for all future LIHEAP quarterly reports. Additionally, the OCA receives the obligated amounts to be included in LIHEAP quarterly reports from the DCEO’s Office of Financial Management (OFM) to help ensure accuracy and consistency of reported costs with data contained in the DCEO’s accounting system. Proposed Completion Date: February 25, 2025 – Completed

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Finding 1207078 (2024-036)

Material Weakness 2024

State of Illinois

IL

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.303

Finding Number: 2024-036 Finding Name: Failure to Maintain Updated Procedures to File Subaward Information Required by FFATA Finding Condition(s): The Illinois Department of Commerce and Economic Opportunity (DCEO) failed to maintain updated procedures which resulted in filing inaccurate Federal Fun...

Finding Number: 2024-036 Finding Name: Failure to Maintain Updated Procedures to File Subaward Information Required by FFATA Finding Condition(s): The Illinois Department of Commerce and Economic Opportunity (DCEO) failed to maintain updated procedures which resulted in filing inaccurate Federal Funding Accountability and Transparency Act (FFATA) reports. Name of Contact Person(s): • Lisa Clement, Audit Liaison – Illinois Department of Commerce and Economic Opportunity, Office of Accountability • Jared Ebel, Chief Accountability Officer – Illinois Department of Commerce and Economic Opportunity, Office of Accountability • Phil Keshen, Deputy Director – Illinois Department of Commerce and Economic Opportunity, Office of Financial Management Corrective Action(s): The DCEO’s Office of Financial Management (OFM) will update the FFATA reporting procedures so reports are filed based on the award dates and to reflect that if grants’ values are equal or exceed $30,000 and are modified by any amount, they must be reported on again. Proposed Completion Date: April 30, 2025 - Completed

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Finding 1207074 (2024-035)

Material Weakness 2024

State of Illinois

IL

Subrecipient Monitoring Cash Management Matching / Level of Effort / Earmarking § 200.303

Finding Number: 2024-035 Finding Name: Failure to Perform Cash Draws in Accordance with the Treasury-State Agreement Finding Condition(s): The Illinois Department of Commerce and Economic Opportunity (DCEO) did not perform its cash draws in accordance with the funding technique prescribed in the Tre...

Finding Number: 2024-035 Finding Name: Failure to Perform Cash Draws in Accordance with the Treasury-State Agreement Finding Condition(s): The Illinois Department of Commerce and Economic Opportunity (DCEO) did not perform its cash draws in accordance with the funding technique prescribed in the Treasury-State Agreement (TSA). Additionally, the auditors noted that internal controls have not been established to ensure cash draws are calculated and recertified in accordance with Treasury regulations and the funding technique prescribed by the Treasury-State agreement. Name of Contact Person(s): • Lisa Clement, Audit Liaison – Illinois Department of Commerce and Economic Opportunity, Office of Accountability • Jared Ebel, Chief Accountability Officer – Illinois Department of Commerce and Economic Opportunity, Office of Accountability • Phil Keshen, Deputy Director – Illinois Department of Commerce and Economic Opportunity, Office of Financial Management Corrective Action(s): The DCEO’s Office of Financial Management (OFM) has requested that the Governor’s Office of Management & Budget (GOMB) change the funding technique for the Low-Income Home Energy Assistance Program within the Treasury-State Agreement to Pre-Issuance. This corrective action was implemented during State fiscal year 2025. Proposed Completion Date: July 1, 2025 – Completed

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Finding 1207070 (2024-032)

Material Weakness 2024

State of Illinois

IL

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

Finding Number: 2024-032 Finding Name: Inadequate Process for Preparing ETA 2208A Special Report Finding Condition(s): The Illinois Department of Employment Security (IDES) does not have an adequate process in place to ensure the ETA 2208A special reports prepared for the Unemployment Insurance (UI)...

Finding Number: 2024-032 Finding Name: Inadequate Process for Preparing ETA 2208A Special Report Finding Condition(s): The Illinois Department of Employment Security (IDES) does not have an adequate process in place to ensure the ETA 2208A special reports prepared for the Unemployment Insurance (UI) program are complete and accurate. Name of Contact Person(s): Linette Hughes, Budget Director – Illinois Department of Employment Security, Office of the Budget Corrective Action(s): The IDES hired additional budget staff to aid in compiling and checking the reports to ensure complete and accurate reporting. Additionally, the IDES created and approved written procedures for the completion of the reports, including a second-level review of reports prior to submission. Finally, the IDES implemented procedures for the preparation, the review, and the approval of the reports. Proposed Completion Date: April 30, 2025 - Completed

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Finding 1207068 (2024-031)

Material Weakness 2024

State of Illinois

IL

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

Finding Number: 2024-031 Finding Name: Inadequate Process for Preparing ETA 9130 Financial Reports Finding Condition(s): The Illinois Department of Employment Security (IDES) does not have an adequate process in place to ensure that the ETA 9130 financial reports prepared for the Unemployment Insura...

Finding Number: 2024-031 Finding Name: Inadequate Process for Preparing ETA 9130 Financial Reports Finding Condition(s): The Illinois Department of Employment Security (IDES) does not have an adequate process in place to ensure that the ETA 9130 financial reports prepared for the Unemployment Insurance (UI) program are complete and accurate. The auditors also noted that the IDES does not perform analytical or other procedures over previously reported information or expectations relative to current program activities. Additionally, supervisory review procedures are not designed to operate at a level of precision to identify errors of this nature. Name of Contact Person(s): Kelly McGrath, Manager of Accounting and Reporting – Illinois Department of Employment Security, Accounting and Reporting Corrective Action(s): The IDES hired a Grant Accountant Supervisor and has a new Senior Accountant starting in February 2026. Accounting has been training the new Grant Accountant Supervisor and will be training the new Senior Accountant on how to review and complete 9130 reports. Accounting will review current procedures to determine ways to improve controls over preparation, reviews, and approvals. The IDES, as a whole, will be looking for ways to strengthen internal controls over its multiple divisions to ensure data is complete and accurate. Proposed Completion Date: June 30, 2026

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Finding 1207064 (2024-029)

Material Weakness 2024

State of Illinois

IL

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.303

Finding Number: 2024-029 Finding Name: Failure to Report Subaward Information Required by FFATA Finding Condition(s): The Illinois Community College Board (ICCB) failed to report information required by the Federal Funding Accountability and Transparency Act (FFATA) for awards granted to subrecipien...

Finding Number: 2024-029 Finding Name: Failure to Report Subaward Information Required by FFATA Finding Condition(s): The Illinois Community College Board (ICCB) failed to report information required by the Federal Funding Accountability and Transparency Act (FFATA) for awards granted to subrecipients of the Child Care and Development Fund (CCDF) Cluster. Name of Contact Person(s): Jennifer Franklin, Deputy Director for Finance and Operations - Illinois Community College Board Corrective Action(s): The ICCB will implement corrective actions to ensure full compliance with FFATA reporting requirements for applicable federal subawards. The ICCB will develop and formalize a written FFATA reporting procedure that defines applicability thresholds, required data elements, reporting timelines, and assigned responsibilities. Additionally, the ICCB will assign FFATA reporting responsibilities to a fiscal staff person and integrate FFATA determination and certification steps into the subaward and amendment workflow. Finally, the ICCB will provide targeted training to fiscal and program staff on FFATA requirements. Proposed Completion Date: July 1, 2026

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Finding 1207058 (2024-027)

Material Weakness 2024

State of Illinois

IL

Procurement, Suspension & Debarment Subrecipient Monitoring Matching / Level of Effort / Earmarking § 200.303

Finding Number: 2024-027 Finding Name: Failure to Report Subaward Information Required by Federally Funded Accountability and Transparency Act (FFATA) Finding Condition(s): The Illinois State Board of Education (ISBE) failed to report subaward information required by the Federal Funding Accountabili...

Finding Number: 2024-027 Finding Name: Failure to Report Subaward Information Required by Federally Funded Accountability and Transparency Act (FFATA) Finding Condition(s): The Illinois State Board of Education (ISBE) failed to report subaward information required by the Federal Funding Accountability and Transparency Act (FFATA) for awards granted to subrecipients of the Education Stabilization Fund (ESF) program. Additionally, the auditors noted that ISBE did not have adequate internal controls in place over FFATA reporting to ensure all subawards were reported as required. Name of Contact Person(s): Andy Krupin, Director – Illinois State Board of Education, Department of Funding and Disbursements Corrective Action(s): When a grant runs longer than its financial systems are accustomed to (two state fiscal years), management in the Department of Funding and Disbursements will maintain and present a list of grants previously approved and reported to FFATA to the principal consultant responsible for FFATA reporting, ensuring the principal consultant has the necessary tools to properly reconcile grants that have previously been reported and those that have not. Then, management will review the list of subrecipient projects prepared by the principal consultant for submission to ensure accuracy prior to the data being reported. Proposed Completion Date: January 1, 2026 – Completed

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Finding 1207051 (2024-026)

Material Weakness 2024

State of Illinois

IL

Subrecipient Monitoring Reporting § 200.303

Finding Number: 2024-026 Finding Name: Untimely Review of Subrecipient Performance Reports Finding Condition(s): The Illinois State Board of Education (ISBE) did not review subrecipient performance reports in a timely manner according to its program monitoring policies and procedures for subrecipien...

Finding Number: 2024-026 Finding Name: Untimely Review of Subrecipient Performance Reports Finding Condition(s): The Illinois State Board of Education (ISBE) did not review subrecipient performance reports in a timely manner according to its program monitoring policies and procedures for subrecipients of the Education and Stabilization Fund - Elementary and Secondary Education (ESF) program for fiscal year 2024. Name of Contact Person(s): • Denise Blaney, Director – Illinois State Board of Education, Title Grant Administration Department • Lazell Logan, Supervisor – Illinois State Board of Education, Title Grant Administration Department • Annie Brooks, Executive Director – Illinois State Board of Education, Regulatory Services Corrective Action(s): To ensure proper review procedures are performed in a timely manner in accordance with its program monitoring policies and procedures, ISBE’s Title Grant Administration Department started to send bi-weekly lists of submitted, past due, and disapproved Grant Periodic Reports (GPRS) to each applicable ISBE department. The Title Grant Administration Department analyzes the GPRS reports and prioritizes reviews based on submission dates. The Title Grant Administration Department also trained team members to assist with the review process. Proposed Completion Date: November 15, 2025 – Completed

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Finding 1207044 (2024-025)

Material Weakness 2024

State of Illinois

IL

Subrecipient Monitoring § 200.303 § 200.332

Finding Number: 2024-025 Finding Name: Inadequate Monitoring of 21st Century Subrecipients Finding Condition(s): The Illinois State Board of Education (ISBE) did not adequately monitor and document program monitoring procedures performed over subrecipients of the 21st Century Community Learning Cent...

Finding Number: 2024-025 Finding Name: Inadequate Monitoring of 21st Century Subrecipients Finding Condition(s): The Illinois State Board of Education (ISBE) did not adequately monitor and document program monitoring procedures performed over subrecipients of the 21st Century Community Learning Centers (21st Century) program. Additionally, ISBE’s internal controls over subrecipient on-site monitoring are not designed at an appropriate level of precision to ensure monitoring of subrecipients is completed, documented, and retained as required by ISBE’s policies and procedures. Name of Contact Person(s): • Jeffrey Judge, Director – Illinois State Board of Education, Wellness and Student Care Management Department • Nehemiah Ankoor, Supervisor; 21st Century Community Learning Centers (CCLC) State Education Agency Coordinator – Illinois State Board of Education, Wellness and Student Care Management Department Corrective Action(s): To ensure that 21st Century Community Learning Centers (21st CCLC) subgrantees’ progress and performance are monitored in accordance with 2 CFR 200.331(d), 2 CFR 200.331(b), and 2 CFR 200.303, Wellness and Student Care Management and the 21st CCLC team developed processes and structures to facilitate the procedures, protocols, and efficacy of subgrantee monitoring. Components of this work included, but were not limited to: • Evaluating and revising the program’s subgrantee risk analysis procedures and tools to ensure that they are relevant and accurately reflect the items/actions that suggest higher levels of subgrantee risk (2 CFR 200.331(b)). Complete. After careful examination, we have revised the risk analysis procedures and tools and have begun using them to inform our fiscal year 2026 monitoring. • Reviewing and revising the procedures and/or documentation that is collected for all three tiers of subgrantee monitoring to ensure that all processes are relevant; are not simply perfunctory; ensure compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that the subaward performance goals are achieved (2 CFR 200.331(d)). Complete. We have determined which of the documents we have historically collected meet those requirements, and we have evaluated all remaining documents (extraneous to ED requirements) to determine which we feel are most necessary to keep and what we are able to discontinue requiring. • Establishing and implementing specific processes and protocols to ensure that all components of subgrantee monitoring are timely, that management reviews and provides approval for key components of the process, and that accurate and complete documentation is produced and maintained (2 CFR 200.303). Complete. The expectations herein have been communicated to staff and have begun to be implemented (i.e. management approval, maintaining documentation, etc.). We still need to ensure that we precisely document these expectations and protocols, but through meetings and less formal communications, the required changes to our practices have been implemented. Proposed Completion Date: December 31, 2025 - Completed

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Finding 1207043 (2024-024)

Material Weakness 2024

State of Illinois

IL

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.303

Finding Number: 2024-024 Finding Name: Failure to Maintain Documentation to Evidence Timely Reporting of Subaward Information Required by Federally Funded Accountability and Transparency Act (FFATA) Finding Condition(s): The Illinois Department of Public Health (IDPH) did not maintain documentation ...

Finding Number: 2024-024 Finding Name: Failure to Maintain Documentation to Evidence Timely Reporting of Subaward Information Required by Federally Funded Accountability and Transparency Act (FFATA) Finding Condition(s): The Illinois Department of Public Health (IDPH) did not maintain documentation to evidence information required to be reported by the Federal Funding Accountability and Transparency Act (FFATA) was submitted within required timeframes for awards granted to subrecipients of the Immunization Cooperative Agreements (ICA) and Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) programs. Name of Contact Person(s): • Jacob Cisco, Chief Financial Officer/Bureau Chief, Finance – Illinois Department of Public Health, Office of Administrative Affairs • Sheila Jefferson, Chief Accountability Officer – Illinois Department of Public Health, Office of Performance Management • Timothy Stevens, Grant Management Auditor – Illinois Department of Public Health, Office of Performance Management Corrective Action(s): The IDPH revised its policy on the FFATA report submission to capture the change from a FSRS.gov batch upload to a manual entry in SAM.gov. Additionally, the IDPH documented its process to provide evidence of the original submission dates in SAM.gov. Proposed Completion Date: March 23, 2026

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Finding 1207033 (2024-021)

Material Weakness 2024

State of Illinois

IL

Special Tests & Provisions Procurement, Suspension & Debarment Subrecipient Monitoring

Finding Number: 2024-021 Finding Name: Failure to Perform Reviews over Home and Community Based Waiver Services (HCBS) Finding Condition(s): The Illinois Department of Healthcare and Family Services (DHFS) failed to conduct utilization reviews over home and community-based services for five of the n...

Finding Number: 2024-021 Finding Name: Failure to Perform Reviews over Home and Community Based Waiver Services (HCBS) Finding Condition(s): The Illinois Department of Healthcare and Family Services (DHFS) failed to conduct utilization reviews over home and community-based services for five of the nine waivers contracted out to its vendor during fiscal year 2024. Name of Contact Person(s): • Pamela Winsel, Bureau Chief, Waiver Operations Management - Illinois Department of Healthcare and Family Services, Division of Medical Programs • Tracy Anderson, Public Service Administrator, Waiver Operations Management - Illinois Department of Healthcare and Family Services, Division of Medical Programs • Sarah Myerschough-Mueller, Deputy Administrator - Illinois Department of Healthcare and Family Services, Division of Medical Programs Corrective Action(s): The DHFS will procure a new vendor to complete record reviews. An Invitation for Bid was been posted to procure a contractor to resume record reviews. The opening of bids occurred in January 2026. The new vendor will begin record reviews in fiscal year 2027. Proposed Completion Date: July 1, 2026

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Finding 1207009 (2024-017)

Material Weakness 2024

State of Illinois

IL

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

Finding Number: 2024-017 Finding Name: Inadequate Procedures to Determine and Document Beneficiary Eligibility Finding Condition(s): The Illinois Department of Healthcare and Family Services (DHFS) does not have adequate procedures to determine and document eligibility for beneficiaries of the Child...

Finding Number: 2024-017 Finding Name: Inadequate Procedures to Determine and Document Beneficiary Eligibility Finding Condition(s): The Illinois Department of Healthcare and Family Services (DHFS) does not have adequate procedures to determine and document eligibility for beneficiaries of the Children’s Health Insurance Program (CHIP) and the Medicaid Cluster programs. Additionally, the auditors noted that the DHFS does not have adequate resources to perform and document eligibility determinations. Finally, the auditors noted that the DHFS has not established appropriate monitoring procedures to ensure eligibility determinations are properly documented in accordance with program requirements. Name of Contact Person(s): • Jacqueline Myers, Interim Deputy Administrator - Illinois Department of Healthcare and Family Services, Eligibility Data and Systems • Pam Winsel, Bureau Chief, Waiver Operations Management - Illinois Department of Healthcare and Family Services, Division of Medical Programs • Jeremy Thomas, Impact Technical Lead - Illinois Department of Healthcare and Family Services, Bureau of Technical Support Corrective Action(s): A report will be created to identify those enrolled in the waiver program, but not receiving full Medicaid that makes them ineligible for payment. This report will be run monthly and worked on manually until a system edit is implemented to reject claims when there is no match on full Medicaid coverage coding. Program staff at the waiver operating agencies will also be trained to assist them in identifying certain criteria that would exclude a waiver program enrollee from being eligible for payment. Rules have been modified (PIR #53483) to make sure eligibility in the RDB (Medicaid Management Information System (MMIS)) gets closed. In addition, a monthly report has been developed and is run monthly to identify any case with the eligibility closed in the IES, yet open in the Recipient Database (RDB). Cases shown on this report are worked to ensure both the Integrated Eligibility System (IES) and the RDB (MMIS) match. Proposed Completion Date: September 1, 2026

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Finding 1206977 (2024-013)

Material Weakness 2024

State of Illinois

IL

Procurement, Suspension & Debarment Subrecipient Monitoring Reporting § 200.303

Finding Number: 2024-013 Finding Name: Failure to Report Subaward Information Required by FFATA Finding Condition(s): The Illinois Department of Human Services (IDHS) failed to report information required by the Federal Funding Accountability and Transparency Act (FFATA) for awards granted to subrec...

Finding Number: 2024-013 Finding Name: Failure to Report Subaward Information Required by FFATA Finding Condition(s): The Illinois Department of Human Services (IDHS) failed to report information required by the Federal Funding Accountability and Transparency Act (FFATA) for awards granted to subrecipients of the Temporary Assistance for Needy Families (TANF), Child Care and Development Fund (CCDF) Cluster, Social Services Block Grant (SSBG), and Block Grants for Prevention and Treatment of Substance Abuse (SAPT) programs. Name of Contact Person(s): • Kyle Thomas, Bureau Chief of Planning and Evaluation – Illinois Department of Human Services, Division of Family and Community Services • Christina Miller, Fund Disbursement Manager, Illinois Department of Human Services, Behavioral Health and Recovery - SAPT Program Corrective Action(s): The IDHS will (1) revise its FFATA reporting procedures to address the timely reporting of contracts with new federal awards, (2) revise its contract procedures to require that the contract signature date be recorded in its financial management system (FMS) on the same day the contract is signed., (3) revise its contract procedures to include the verification of contract signature dates in its FMS, (4) develop a checklist for its contract staff, (5) hire a manager in its IDHS-SAPT Program to develop revised procedures and complete FFATA reporting, and (6) identify interim controls and milestones in its IDHS-SAPT Program that will operate prior to full automation. Proposed Completion Date: April 1, 2026

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Finding 1206960 (2024-009)

Material Weakness 2024

State of Illinois

IL

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

Finding Number: 2024-009 Finding Name: Missing Documentation in Beneficiary Files Finding Condition(s): The Illinois Department of Human Services (IDHS) could not locate case file documentation supporting certain eligibility and special test requirements for beneficiaries of the Temporary Assistance...

Finding Number: 2024-009 Finding Name: Missing Documentation in Beneficiary Files Finding Condition(s): The Illinois Department of Human Services (IDHS) could not locate case file documentation supporting certain eligibility and special test requirements for beneficiaries of the Temporary Assistance for Needy Families (TANF) program. Also, the auditors noted that the IDHS does not have adequate resources to perform and document eligibility determinations. Additionally, the auditors noted that the IDHS has not established appropriate monitoring procedures to ensure eligibility determinations are properly documented in accordance with program requirements. Name of Contact Person(s): Kasey Reagan, Interim Director – Illinois Department of Human Services, Division of Family and Community Services (FCS) Corrective Action(s): The IDHS’ TANF Managers will conduct a monthly review of TANF cases to include all components of the TANF cases. Additionally, an Integrated Eligibility System (IES) enhancement will be implemented to allow telephonic signatures for TANF Responsibility and Service Plans. This will eliminate the need to use a paper process. Proposed Completion Date: March 21, 2027

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Finding 1206947 (2024-007)

Material Weakness 2024

State of Illinois

IL

Subrecipient Monitoring Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking § 200.303 § 200.332

Finding Number: 2024-007 Finding Name: Failure to Follow Established Program Subrecipient Monitoring Procedures Finding Condition(s): The Illinois Department of Human Services (IDHS) did not follow its established program monitoring policies and procedures for subrecipients of the Temporary Assistan...

Finding Number: 2024-007 Finding Name: Failure to Follow Established Program Subrecipient Monitoring Procedures Finding Condition(s): The Illinois Department of Human Services (IDHS) did not follow its established program monitoring policies and procedures for subrecipients of the Temporary Assistance for Needy Families (TANF), Child Care Development Fund Cluster (CCDF), Social Services Block Grant (SSBG), and Block Grants for Prevention and Treatment of Substance Abuse (SAPT) programs. Further, the auditors noted that the IDHS did not have adequate policies or procedures to ensure fiscal and administrative reviews were completed timely to detect potential non-compliance. Name of Contact Person(s): • Kasey Reagan, Interim Director – Illinois Department of Human Services, Division of Family and Community Services (FCS) • Christina Miller, Fund Disbursement Manager – Illinois Department of Human Services, Division of Behavioral Health and Recovery (IDHS-SAPT-Program) • Maureen Bilek, Audit Compliance and Programmatic Monitoring Administrator – Illinois Department of Human Services, Division of Early Childhood (DEC) • Brian Bond, Director – Illinois Department of Human Services, Office of Contract Administration (OCA) Corrective Action(s): The IDHS has completed or will take the following actions within four of its divisions/offices: Division of Family and Community Services (FCS) The FCS (1) has worked to identify the late subrecipient monitoring reviews and created a plan to address the backlog, (2) will utilize the plan to eliminate the back log of subrecipient monitoring reviews, (3) will meet with staff to reinforce the importance of adhering to the agreed upon monitoring processes and timeframes, (4) will update and circulate to staff the revised monitoring standard operating procedure, and (5) will review staff adherence to monitoring SOP timeframes during weekly meetings with staff who conduct monitoring. Division of Behavioral Health and Recovery (IDHS-SAPT PROGRAM) The IDHS-SAPT PROGRAM will (1) hire an administrative assistant to assist with compliance monitoring tracking activities to maintain communication about important deadlines, (2) hire compliance monitors to engage in conducting compliance reviews, (3) meet weekly to track monitoring activities to ensure deadlines are met, (4) review policy and procedures to assess timelines associated with the monitoring process, and (5) train all monitors to use the updated tool, templates and updated policies and procedures and the new electronic system. Division of Early Childhood (DEC) The DEC will (1) develop and implement a standardized deadline tracking tool to monitor review completion dates and required subrecipient notifications, including documented supervisory review and management oversight to ensure timeliness, (2) establish and implement internal Corrective Action Plan (CAP) procedures that outline standardized processes for CAP tracking, documentation, and escalation efforts and define protocols when subrecipients fail to submit required CAPs within established timeframes, (3) initiate and implement a CAP tracking tool to monitor review dates, findings issuance, subrecipient notification dates, CAP receipt, and implementation follow-up activities, with documented management oversight and approval to ensure timeliness, accountability, and consistent monitoring, and (4) conduct formal staff training on procedures for accurately completing and maintaining the CAP tracking tool, including documentation standards, required data elements, and supervisory review expectations to ensure consistent and compliant use. Office of Contract Administration (OCA) The OCA (1) has formally briefed leadership and management the issues noted in the finding and initiated a cross-division review of current subrecipient monitoring execution to identify gaps, inconsistencies, and needed revisions, (2) will complete a structured validation of monitoring expectations to ensure programmatic on-site reviews and expenditure/performance report reviews are occurring at the required frequency and depth, consistent with pass-through monitoring responsibilities, (3) will review minimum documentation standards and supervisory quality control checkpoints for review workpapers, expenditure/performance report review evidence, and monitoring report issuance, to strengthen internal controls over compliance, (4) will standardize and revise the data tracking definitions to ensure program findings from subrecipient monitoring are issued, tracked, and followed through to corrective action completion, including defined escalation steps when responses are delinquent or incomplete, (5) will align enforcement actions with the Statewide Grantee Compliance Enforcement System (GCES) framework (e.g., stop-payment status triggers, notices, objection windows, and resolution and closure steps), and ensure staff understand how and when to apply GCES in response to unresolved monitoring deficiencies, (6) finalize recommendations to streamline Fiscal Administrative Review (FAR) production triggers (pre-draft and post-draft), clarify program engagement in special condition processing post-FAR, and reduce reliance on informal technical assistance in CAP in favor of documented compliance correction and closure, (7) revised procedures and controls will be implemented for FARs scheduled on/after August 1, 2026 (target), with interim guidance applied as feasible to active cases prior to that date, and (8) will conduct structured database integrity review and update process aligned with official guidance and source documentation to ensure accuracy, completeness, consistency, and reliability of all FAR database records. Proposed Completion Date: December 31, 2026

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Finding 1206939 (2024-006)

Material Weakness 2024

State of Illinois

IL

Subrecipient Monitoring Allowable Costs / Cost Principles Reporting § 200.303 § 200.502 § 200.510

Finding Number: 2024-006 Finding Name: Inadequate Process for Monitoring Interagency Program Expenditures Finding Condition(s): The Illinois Department of Human Services (IDHS) does not have an adequate process for monitoring interagency expenditures claimed under or used to meet maintenance of effo...

Finding Number: 2024-006 Finding Name: Inadequate Process for Monitoring Interagency Program Expenditures Finding Condition(s): The Illinois Department of Human Services (IDHS) does not have an adequate process for monitoring interagency expenditures claimed under or used to meet maintenance of effort (MOE) requirements of the Temporary Assistance for Needy Families (TANF) and Child Care Development Fund (CCDF) Cluster programs. Name of Contact Person(s): Sarah Eves, Deputy Chief Financial Officer – Illinois Department of Human Services Corrective Action(s): The IDHS will request quarterly certifications, control assessments, and program expenditure questionnaires for those agencies receiving funds from federal awards. Additionally, the IDHS will sample interagency expenditures and request that the agency provide supporting documentation for the expenses. This documentation will be reviewed by the IDHS to ensure that the expenditures meet federal program requirements. Proposed Completion Date: October 1, 2026

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Finding 1206934 (2024-005)

Material Weakness 2024

State of Illinois

IL

Equipment & Real Property Management Matching / Level of Effort / Earmarking Special Tests & Provisions § 200.303

Finding Number: 2024-005 Finding Name: Inadequate Review of Recipient Agencies of the Food Distribution Cluster Finding Condition(s): The Illinois Department of Human Services (IDHS) did not adequately review the recipient agencies of the Food Distribution Cluster (FDC) program. Name of Contact Pers...

Finding Number: 2024-005 Finding Name: Inadequate Review of Recipient Agencies of the Food Distribution Cluster Finding Condition(s): The Illinois Department of Human Services (IDHS) did not adequately review the recipient agencies of the Food Distribution Cluster (FDC) program. Name of Contact Person(s): • Liz Lusk, Audit Liaison, Deputy Chief Financial Officer – Illinois Department of Human Services, Division of Family and Community Services (FCS) • Kasey Reagan, Interim Director – Illinois Department of Human Services, Division of Family and Community Services (FCS) Corrective Action(s): The IDHS will update the Procedure Manual for The Emergency Food Assistance Program (TEFAP) to include the requirement that an annual inventory count and reconciliation of inventory records be submitted for all recipient agencies at the end of each State fiscal year. Additionally, the IDHS will collect annual inventory count and reconciliation from all food banks at the end of each State fiscal year. Finally, the IDHS will reconcile the annual inventory counts within 60 days of receipt. Proposed Completion Date: September 30, 2026

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Finding 1206930 (2024-004)

Material Weakness 2024

State of Illinois

IL

Subrecipient Monitoring § 200.303 § 200.332

Finding Number: 2024-004 Finding Name: Inadequate Monitoring of Subrecipients of the CSLFRF Program Finding Condition(s): The Illinois Department of Human Services (IDHS) did not obtain and review periodic performance reports for subrecipients of the COVID-19 – Coronavirus State and Local Fiscal Rec...

Finding Number: 2024-004 Finding Name: Inadequate Monitoring of Subrecipients of the CSLFRF Program Finding Condition(s): The Illinois Department of Human Services (IDHS) did not obtain and review periodic performance reports for subrecipients of the COVID-19 – Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) program during the year ended June 30, 2024 Name of Contact Person(s): • Liz Lusk, Audit Liaison, Deputy Chief Financial Officer – Illinois Department of Human Services, Division of Family and Community Services (FCS) • Kasey Reagan, Interim Director – Illinois Department of Human Services, Division of Family and Community Services (FCS) Corrective Action(s): The IDHS will work to develop a process for the review of Periodic Performance Reports (PPR) that will include grantee certification of accuracy and staff certification of review and approval. Additionally, the IDHS will train staff in the importance of maintaining PPRs obtained from subrecipients and related documentation, including maintaining evidence of PPR reviews and appropriate reviewer signatures. Finally, the IDHS is exploring creating a centralized repository for each program area in the FCS (Division of Family & Community Services) to allow for PPR document files to be easily maintained, searched, and located to avoid any issues related to staffing changes. Proposed Completion Date: December 30, 2026

View Audit 398893

Finding 1206928 (2024-003)

Material Weakness 2024

State of Illinois

IL

Subrecipient Monitoring Reporting Matching / Level of Effort / Earmarking § 200.303 § 200.328

Finding Number: 2024-003 Finding Name: Failure to Accurately Prepare Performance Reports for the COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Program Finding Condition(s): The Illinois Governor’s Office of Management and Budget (GOMB) did not prepare accurate federal project and expe...

Finding Number: 2024-003 Finding Name: Failure to Accurately Prepare Performance Reports for the COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Program Finding Condition(s): The Illinois Governor’s Office of Management and Budget (GOMB) did not prepare accurate federal project and expenditure reports (Paperwork Reduction Act (PRA) 1505-0271) for the COVID-19 – Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) program. Name of Contact Person(s): Lesley Winbush, Accountant – Illinois Governor’s Office of Management and Budget Corrective Action(s): GOMB will improve the reporting process by implementing checks to ensure that all expenditures are reported by State agencies. The checks will include comparing reported data against agency financial reports to ensure that the data is complete. Proposed Completion Date: June 30, 2026

View Audit 398893

Finding 1206926 (2024-002)

Material Weakness 2024

State of Illinois

IL

Subrecipient Monitoring Matching / Level of Effort / Earmarking § 200.303 § 200.332 § 200.521

Finding Number: 2024-002 Finding Name: Inadequate Monitoring of Subrecipient Single Audit Reviews Finding Condition(s): The State of Illinois did not establish adequate controls to monitor the completion and documentation of the review of single audit reports for its subrecipients of the Special Sup...

Finding Number: 2024-002 Finding Name: Inadequate Monitoring of Subrecipient Single Audit Reviews Finding Condition(s): The State of Illinois did not establish adequate controls to monitor the completion and documentation of the review of single audit reports for its subrecipients of the Special Supplemental Nutrition Program for Women, Infants, and Children (WIC), the Child and Adult Care Food Program (CACFP), the Crime Victims Assistance Program (CVA), the Workforce Innovation and Opportunity Act (WIOA) Cluster, the Highway and Planning Construction (Highway), the Coronavirus State and Local Fiscal Recovery Funds (SLFRF), the Title I Grants to Local Education Agencies (Title I), the Special Education Cluster (IDEA), the Twenty-First Century Community Learning Centers (Twenty-First Century), the Supporting Effective Instruction State Grants (SEISG), the Education Stabilization Funds (ESF), the Aging Cluster (Aging), the Epidemiology and Laboratory Capacity for Infectious Diseases (ELC), the Temporary Assistance for Needy Families (TANF), the Child Support Services (CSS), the Low-Income Home Energy Assistance Program (LIHEAP), the Child Care and Development Fund (CCDF) Cluster, the Social Services Block Grant (SSBG), the Block Grants for Prevention and Treatment of Substance Abuse (SAPT), and the Homeland Security Grant Program (Homeland Security) programs in the State's Grant Accountability and Transparency Act (GATA) Audit Report Review Management System (ARRMS). Name of Contact Person(s): Keyria Rodgers, Grant Accountability and Transparency Unit Director – Illinois Governor’s Office of Management and Budget Corrective Action(s): The Grant Accountability and Transparency Unit (GATU) provides a centralized, uniform process and a system to which State grant-making agencies are required to adhere throughout the lifecycle of the grant. Beginning November 2025, the Illinois Governor’s Office of Management and Budget (GOMB) sends a monthly analysis to agency Chief Accountability Officers (CAOs) detailing incomplete documentation of reviews within ARRMS. GOMB also provides monthly reminders of the importance of documenting the completeness of the reviews within our regular occurring CAO meetings and Subject Matter Expert (SME) meetings. Lastly, GOMB increased direct technical support by contacting CAOs to address questions, offered individualized live assistance, and provided a live demonstration during the February 2026 ARRMS meeting on how to generate and upload Management Decision Letters (MDLs) to ensure the system is updated by agencies and accurate as to the completeness of the agencies’ report reviews, letter issuances, and desk reviews. Proposed Completion Date: April 30, 2026

View Audit 398893

Finding 1206764 (2024-001)

Material Weakness 2024

SACRAMENTO ASIAN PACIFIC CHAMBER OF COMMERCE

CA

Reporting Subrecipient Monitoring Material Weakness

Finding: 2024-001: Material Weakness - Untimely Audit Submission in Accordance with 0MB Uniform Guidance Description of Finding: The Chamber did not electronically submit their December 31, 2024 Single Audit reporting package (Single Audit Report, Data Collection Form, Status of Prior Year Findings,...

Finding: 2024-001: Material Weakness - Untimely Audit Submission in Accordance with 0MB Uniform Guidance Description of Finding: The Chamber did not electronically submit their December 31, 2024 Single Audit reporting package (Single Audit Report, Data Collection Form, Status of Prior Year Findings, and a Corrective Action Plan) within the required time period. Cause: The submission was delayed because the Single Audit could not be completed on time due to change in audit firm and staffing shortages. Statement of Concurrence or Nonconcurrence: SacAsian agrees with the finding. Corrective Action: SacAsian understands the seriousness of this deficiency and the need for strict adherence to timely audit submissions per the OMB Uniform Guidance. Additional staff have been hired to assist in accounting processes, including a Controller to review all accounting processes and procedures with the Director of Finance and implement best practice recommendations and stronger month-end closing procedures and schedule. The delay in performing the 2024 audit was caused by a change in auditors. Our previous auditor did not have the capacity to continue our audit engagement due to staff shortages related to COVID. A new audit firm identified and engaged. However, there were delays in beginning the audit, and staffing challenges internally with completing the audit such that deadlines were not met. Additionally, an external finance and accounting firm was hired in September 2025 to provide additional capacity and high-level support to bring our audits current by March 2026. The additional staffing, external expertise, and improved procedures will prevent untimely submissions in future years. Responsible Party: Ryan Fong, Director of Finance, 916-446-7883, rfong@sacasiancc.org Pat Fong Kushida, President & CEO, 916-446-7883, patfk@sacasiancc.org Karen Wood, Not-for-Profit CFO (Creating Answers LLC), 916-930-0777, kwood@creatinganswers.com Projected Completion Date: March 2026 If the Office of Policy and Management and/or Oversight Agency has questions regarding this Plan, please call Ryan Fong at (916) 446-7883.

View Audit 398841

Finding 1206574 (2024-003)

Material Weakness 2024

Town of Natick, Massachusetts

MA

Subrecipient Monitoring Allowable Costs / Cost Principles Procurement, Suspension & Debarment

2024-003 Document Policies and Procedures Over Federal Awards Cluster/Program: All federal programs Type of Finding Compliance – Other Matters Internal Control over Compliance – Significant Deficiency Condition: The Town has not formalized written policies and procedures related to federal awards re...

2024-003 Document Policies and Procedures Over Federal Awards Cluster/Program: All federal programs Type of Finding Compliance – Other Matters Internal Control over Compliance – Significant Deficiency Condition: The Town has not formalized written policies and procedures related to federal awards required under the Uniform Guidance. Criteria: OMB’s Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requirements stipulate that federal award recipients must document their policies and procedures over certain aspects of financial and program management. Specifically, written policies are required for the following: • Cash management • Determination of allowable costs • Employee travel • Procurement • Conflicts of interest • Subrecipient monitoring and management Cause: The Town has not developed written formal documentation of internal controls to encompass all required areas per the Uniform Guidance. Effect: The Town is not in compliance with the requirements of the Uniform Guidance as it relates to the requirement to have documented policies and procedures pertaining to the management of federal awards. No questioned costs are reported as this requirement is procedural in nature. Recommendation: Written policies and procedures should be implemented in accordance with the Uniform Guidance. Views of Responsible Official: The reconciliations of retirement board accounts were handled through a third party prior to January 2024. There have been delays in obtaining the files from the third party. With the hiring of the new director in January 2024, the reconciliations are now performed in the Retirement office, by the retirement staff. We anticipate that the records will be available upon request in the future.

View Audit 398631

Finding 1206470 (2024-001)

Material Weakness 2024

Regional Youth Adult Social Action Partnership, Inc.

CT

Subrecipient Monitoring Reporting Significant Deficiency

Effective January 2025, Catalyst CT, Inc. transferred all accounting and finance functions in-house after terminating a contract with a third-party accounting firm. The in-house transition process was completed in phases, commencing in October 2023 with the hiring of a VP of Finance (CFO equivalent)...

Effective January 2025, Catalyst CT, Inc. transferred all accounting and finance functions in-house after terminating a contract with a third-party accounting firm. The in-house transition process was completed in phases, commencing in October 2023 with the hiring of a VP of Finance (CFO equivalent) who reviewed the in-place accounting/finance model. Based on the review, an in-house Controller was hired in March 2024, and a Staff Accountant was hired in December 2024. Transitioning of financial report preparation in-house began in the March 31, 2024 reporting period with a goal of having all reporting transferred in-house by year-end. As a result of this transition, reporting is handled by a central group of finance/accounting associates with consistent processes as well as improved internal notifications, including a Grant Cover Sheet, a Grant Cover Sheet Budgets spreadsheet and regular spend rate meetings with relevant senior program directors. Regarding this particular finding, until the end of year 2024, many past reports were a few days to a few weeks overdue because monthly/quarterly books weren’t typically closed by the third-party accountants until at least the third week of the following month. This is not atypical, a monthly closing date within 15 days is usually an exception rather than a rule. Furthermore, most of our grantors were not flummoxed by this. Those who had issues with reporting past the 15th would usually communicate this to us and we would arrange to provide estimated figures by the 15th. Given the nature of our grants, the newly formed in-house accounting group, as of January 1, 2025 has expedited the closing process to occur before the 15th of each month, allowing Catalyst CT, Inc. to meet reporting deadlines with that deadline to be more easily met.

View Audit 398478

Finding 1206452 (2024-004)

Material Weakness 2024

Regional School Unit #54 - Msad #54

ME

Procurement, Suspension & Debarment Subrecipient Monitoring Matching / Level of Effort / Earmarking

Management’s response/corrective action plan: Management will implement a formal, documented process for annually verifying the status of all active vendors and contractors. This process will include checking the federal System for Award Management (SAM.gov) to confirm that entities are not suspende...

Management’s response/corrective action plan: Management will implement a formal, documented process for annually verifying the status of all active vendors and contractors. This process will include checking the federal System for Award Management (SAM.gov) to confirm that entities are not suspended or debarred from receiving federal funds. The results of these checks will be documented and retained in each vendor’s file. For new vendors, the verification will occur prior to contract execution or payment. For existing vendors, the verification will be conducted at least annually and prior to the renewal or continuation of any federally funded work. Management will assign responsibility to a designated individual or department to oversee ongoing compliance with the vendor verification process.

View Audit 398467

Corrective Action Plans

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