Corrective Action Plans

VIEWS OF RESPONSIBLE OFFICIALS The PRDE does not agree with the Recommendation to establish an allocation method for TPFA invoices because TPFA services are overhead costs paid from administrative funds and are not tied to any specific federal grant. In addition, the PRDE does not agree that contract terms should be revised before the contract expiration to require a reconciliation of total hours and rates because again, payments to the TPFA are overhead costs not directly tied to any specific program. Finally, the PRDE does not agree with the recommendation that the TPFA submit supporting evidence for the reimbursement of expenses because (i) the TPFA contract is a fixed fee that is inclusive of all professional service fees and expenses and (ii) the TPFA provides an explanation of major expenses incurred within each monthly invoice. Auditor Comment on Management Response for Finding No. 2024-004 As stated in CONDITION 2., “…on invoice 830311-2023-32 the amount of $1,978,791 (85% of total invoice amount) was charged to several programs of ALN 84.425, although the services described in the invoice were not related only to these programs; therefore, the cost objective is not chargeable in accordance with the relative benefit received.” Further, the 2 CFR 200.1, establishes that: “Indirect [facilities & administrative (F&A)] costs mean those costs incurred for a common or joint purpose benefitting more than one cost objective, and not readily assignable to the cost objectives specifically benefitted, without effort disproportionate to the results achieved. To facilitate equitable distribution of indirect expenses to the cost objectives served, it may be necessary to establish a number of pools of indirect (F&A) costs. Indirect (F&A) cost pools must be distributed to benefitted cost objectives on bases that will produce an equitable result in consideration of relative benefits derived.” This information was not provided for our evaluation. Also, we made reference to the Program Determination Email for ALNs. 84.938 and 84.425 dated September 18, 2024 (Audit Control Number 02-21-39634), received from Ms. Catherine Miers of the Office of Elementary and Secondary Education of the US Department of Education (USDE), in which they required that the PRDE provide documentation for the following corrective actions: “revised the contract terms to include a reconciliation of total hours and rates to adjust the payments made to the vendor before the contract expiration; requested that adequate supporting evidence from the vendors be presented for any expenses to be reimbursed by the PRDE; and develop an adequate review of the vendors invoice to properly identify the actual hours of services that benefited the Federal programs so a correct allocation of the costs incurred can be made within Federal programs and state funds”. IMPLEMENTATION DATE None RESPONSIBLE PERSON Jullymar Octtaviani Vega Sub-Secretary of Administration María de los Angeles Lizardi Valdés Office of Federal Affairs Director

Finding: According to the Uniform Guidance, 2 CFR 200.303(a), non-Federal entities receiving Federal awards must establish and maintain effective internal controls over these awards. These controls must provide reasonable assurance that the entity manages the Federal award in compliance with applicable Federal statutes, regulations, and the terms and conditions of the award. The Uniform Guidance, 2 CFR Part 200, Appendix XI Compliance Supplement, May 2023, requires the Alabama Department of Labor to operate a Worker Profiling and Reemployment Services (WPRS) or Reemployment Services and Eligibility Assessments (RESEA) program. The Alabama Department of Labor operates a RESEA program. Under the RESEA program, Alabama Department of Labor staff must be promptly and appropriately notified of any eligibility issues identified during any review of a claimant’s information. Claimants are also required to attend appointments for reemployment to maintain their eligibility status. The Alabama Department of Labor has controls in place to provide notification of claimants who failed to report to scheduled RESEA appointments, however those controls were not operating as designed. While reviewing 25 claimant’s information, we noted that 8 claimants failed to report to their scheduled appointments for reemployment. These failures to appear are reported to staff at the Alabama Department of Labor and should prompt a stop of benefit payments; however, the Alabama Department of Labor did not stop payment on these 8 claimants which resulted in overpayments totaling $8,884.00. There was also one instance where Alabama Department of Labor could not provide documentation to support staff was appropriately notified of the eligibility status for a claimant. The Alabama Department of Labor’s policies and procedures did not operate as designed to prevent payments to ineligible claimants. Because the Alabama Department of Labor’s internal controls were not operating as designed, this caused benefits to be paid to ineligible claimants. Recommendation: The Alabama Department of Labor should ensure internal controls are operating as designed to help ensure payments are not made to ineligible claimants. Response/Views: ADOL does not agree with this finding as explained in the Request for Views CAP letter. Corrective Action Planned: Issues reported were beyond ADOL control due to another system shared by multiple state agencies being brought down due to cyberattack. The shared system is not the system of record for UI benefit payments. UI claim records were manually reviewed by UI staff and noted accordingly upon review. Additional measures and procedures have already been implemented in case of future occurrences. Anticipated Completion Date: Already corrected. System processes implemented in October 2023 Contact Person(s): Thomas Daniel, ADOL Unemployment Compensation Division Director

Corrective Action Plan As a corrective measure, the following will be carried out: 1. A procedure will be documented with instructions for making and completing transfers. 2. Students' transactions that require transfer between academic terms must be handled by the designated Collections staff, completing the entire transaction in the University system. 3. Once the transfer transaction is completed, it must be verified by the Enrollment Manager, ensuring that the debt collection process has been completed in compliance with the provisions of Title IV. 4. At the Central Office, a report with all transfers made during the academic year will be produced to review and monitor the correctness of the transactions.

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

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