Corrective Action Plans

Dear Mr. Waguespack,Thank you for the opportunity to respond to your office's finding related to cash management for Research & Development Cluster (R&D) programs. LSU Health Sciences Center in Shreveport (LSUHSC-S) has reviewed the concerns identified by your staff and concurs with the finding.Recommendation:LSUHSC -S should ensure that a review and approval is performed on the final amounts requested for reimbursement and evidence is maintained. LSUHSC-S should also ensure that established controls are followed to ensure the review and approval is performed by someone other than the preparer.Response and Corrective Action Plan:LSUHSC-S' s monthly NIH drawdown process document is being updated to include the detailed efforts of the grants department accounting staff. The preparer's monthly reconciliation of federal award expenditures will continue to be reviewed by the grants manager before final drawdown and the clear evidence of this review and approval consistently noted on the documentation.LSUHSC-S will improve the drawdown schedule to be more consistent with the reconciliation process. In addition, any variances between the reconciliation and actual drawdown amount will be documented by the approver.Name of Contact(s) Responsible for Action PlanWilliam Haacker, Assistant Director of Grants AccountingCurtis Lawrence, Staff Accountant of Grants AccountingSheila Faour, Chief Financial Officer, Business and ReimbursementsAnticipated Completion Date: June 30, 2023If you have questions or need additional information, please contact me at (318) 675-5230 or via email at cindy.rives@lsuhs.edu.Attachment: LSUHSC-S Monthly NIH Drawdown Process Document at March 26, 2023 for completion by June 30, 2023 (See Corrective Action Plan for attachment)

Dear Mr. Waguespack:Please allow this letter to serve as the official response for both the Management Letter and the Single Audit Report in reference to the finding concerning Control Weakness Relating to Foster Care Billings.The Office of Juvenile Justice (OJJ) does concur with the finding. The agency and LA Department of Public Safety (DPS), Office of Management and Finance, Financial Services, which is responsible for performing the back office functions for OJJ, has a responsibility for ensuring that the Foster Care administrative invoices are properly reviewed prior to submission to the Department of Children and Family Services (DCFS) for reimbursement. Inadequate review of the invoice submission for quarter ending December 2021 resulted in an overpayment of $128,236.00 from DCFS made to OJJ.Effectively immediately, an additional level of review and approval of the Foster Care administrative invoices will be added to the process. Samantha Dunbar, DPS Staff Accountant, will continue to prepare the invoices, and submit the invoice and supporting documentation to Wanda Armwood, DPS lead Staff Accountant for the first level review and approval. Once the Lead Accountant approves, the invoices and documentation will be forwarded to A'shli Oliver, DPS Accounting Manager, for the second level review and approval. Once the second level approval has been completed, the DPS Accounting Manager will submit the invoices and documentation to OJJ staff for final review and approval. Undersecretary, Jason Starnes will provide the final approval of the invoices after Karli Pullard, Program Manager at OJJ, and Cassandra Washington, Deputy Undersecretary at OJJ, have reviewed and approved the invoices submitted by DPS.

Dear Mr. Waguespack:The Louisiana Workforce Commission (LWC) respectfully submits its response to the finding Inadequate Controls and Noncompliance with Unemployment Insurance Benefits Requirements, included in the Single Audit Report.The LWC vehemently disagrees with the LLA?s interpretation of federal ?wage documentation? and identity verification requirements. Assuming arguendo the LLA actually meant ?proof of employment? rather than ?wage documentation?, any determination or finding of a failure to provide proof of employment is premature absent a request to provide such proof and absent USDOL disposition of the State?s blanket waiver request. As stated in the report, LWC issued more than $681 million in benefit payments to more than 260,000 claimants during Fiscal Year 2022. The questioned costs of $30,704, however, account for less than 0.005 percent of total benefits paid.It should be noted that all of the purported ?errors? identified in the report occurred under the hastily assembled Pandemic Unemployment Assistance (PUA) program. The implementing legislation (CARES ACT) and initial USDOL guidance for implementation of the PUA program expressly prohibited states from verifying employment and wages, establishing PUA as a self- attestation program. States were inundated with claims that, when taken at face value, appeared to qualify for benefits. It was only after widespread fraudulent activity and rampant abuse of the self-attestation legal requirement that Congress later implemented identification, employment, and wage verification requirements to be completed either during the application process or retroactively. The program requirements were ever-evolving and amended to address situations and deficiencies that all states encountered. Many states are still working to implement this retroactive guidance provided by USDOL.Although our State ended pandemic programs in July 2021, we continue to work through a substantial backlog of pandemic cases, a backlog that is a direct result of the PUA program?s initial lax requirements. What is more, in August of 2021, less than one month after the pandemic programs ended, the state faced its sixth declared disaster in a two-year period, and the LWC was immediately tasked with administering Disaster Unemployment Assistance for yet another major disaster. The LWC responded to the Pandemic and the multiple disasters that impacted the state as effectively as possible. Our Agency will continue to work diligently to resolve the issues noted in the report and to investigate claims to determine proper eligibility.Should you have any questions or need additional information, please feel free to contact my office at 225-342-3001.Inadequate Internal Controls and Noncompliance with Unemployment Insurance Benefit RequirementsThe Louisiana Workforce Commission (LWC) concurs in part. As stated in our response to the same finding last year, it was nearly impossible to implement adequate internal controls and ensure full compliance with the pandemic programs given little time, insufficient guidance, and inadequate resources to implement not only the initial requirements, but later burdensome retroactive requirements all while managing a record-breaking surge in claims volume.Wage Documentation RequirementsIn all cases cited in this report, the ?wage documentation? the auditor was expecting to see is what is referred to as ?proof of employment.? This finding refers to a retroactive requirement that was put in place with the Continued Assistance Act (CAA) and requires the Agency to provide notice to individuals, who filed for PUA before enactment of this requirement, to provide proof of employment within 90 days ?all after previously notifying them that proof of employment was not a requirement of the program. Failure on the part of the individual to provide proof of employment would result in a retroactive disqualification back to December 27, 2020, thus causing a substantial overpayment. The 90-day timeframe does not commence until an official request is transmitted to the individual.The documentation was not on file for the cases in question because the LWC has not yet requested this information from individuals subject to the 90-day proof of employment requirement. Not only was there a ?unique confluence of circumstances? that prevented the LWC from sending out these notices in a timely fashion, but we strongly believe that any overpayments resulting from a claimant?s non-compliance with this requirement is through no fault of their own. To that end, last year, the LWC requested a blanket waiver of overpayments resulting from implementation of this requirement. USDOL ETA?s response to this request will dictate how we proceed with implementation of this requirement. The blanket waiver allowance would only slightly minimize the burden and confusion that implementation of this retroactive requirement causes.Missing IdentificationThe LWC agreed to disagree with the LLA?s interpretation of the identity verification requirements set forth in the CAA. Unemployment Insurance Program Letter 16-20, change 4 provided the following guidance:Requirement to Verify Identity. Section 242 of the Continued Assistance Act requires that states must include procedures for identity verification or validation for timely payment, to the extent reasonable and practicable, by January 26, 2021 (30 days after the enactment of the Continued Assistance Act) to ensure that they have an adequate system for administering the PUA program. Refer to section C.3. of Attachment I to this UIPL for additional details. [Emphasis supplied.]Section C.3:Verification of Identity (Section 242(a) of the Continued Assistance Act) (new). Section 242(a) of Continued Assistance Act modifies Section 2102(f)(1) of the CARES Act. For states to have an adequate system for administering the PUA program, states must include procedures for ?identity verification or validation and for timely payment, to the extent reasonable and practicable? by January 26, 2021, which is 30 days after December 27, 2020 (enactment of the Continued Assistance Act). States that previously verified an individual?s identity on a UC, EB, or PEUC claim within the last 12 months are not required to re-verify identity on the PUA claim, though the Department encourages the state to take additional measures if the identity is questioned. Individuals filing new PUA initial claims that have not been through the state?s identity verification process must have their identities verified to be eligible. The Department strongly encourages states to use the Identity Verification (IDV) solution offered by the UI Integrity Center as part of its Integrity Data Hub (IDH) as one method to meet this requirement. This IDV solution offers states advanced fraud risk scoring to I-13 maximize front-end ID verification, aiding states in assessing whether an individual is using a false, stolen, or synthetic ID. It is available to states at no cost and is a secure, robust, centralized, multi-state data system that allows participating state UI agencies to submit claims for cross matching and analysis to support the prevention and detection of improper payments, fraud, and ID theft. There is also a range of other tools on the market that states may consider to satisfy this requirement for identity verification. States are also strongly encouraged to explore implementation of complementary and rigorous forms of identity verification solutions. The Department will provide states with additional administrative funding to support state costs to implement PUA identity verification processes and solutions and to continue work to address fraud in both the PUA and PEUC programs.[Emphasis supplied.]In the above guidance, we see two requirements (i.e., ?states must?) for our system to be considered ?adequate? for the purpose of administering the PUA program. First, we must have identity verification or validation procedures in place, to the extent reasonable and practicable, by January 26, 2021. In order to thwart the surge of fraudulent claim activity, the LWC implemented identity verification procedures in November 2020 and going forward for all new claims filed, including all new PUA claims. Additionally, we implemented identity verification procedures for anyone whose claim was flagged for suspicious indicators that called into question the individual?s identity. These procedural safeguards were in place even before November 2020. Second, we must verify identities for all individuals filing new PUA initial claims.In the four cases cited in this report, all were PUA initial claims filed long before the CAA identity verification requirements were enacted, and none had been flagged for staff?s review based on suspicious indicators that called the claimant?s identity into question. It would not have been ?reasonable or practicable? for us to verify identities on every single PUA claim filed since the beginning of the Pandemic. The workload the new identity verification requirement created was already more than existing staff and system resources could timely handle.Child Support DeductionsThe child support payments were not properly withheld in the case cited on the report due to a one-off staff training issue. Staff closed the child support work item with no action taken in error, believing the claim was monetarily ineligible. The staff person overlooked that there was an existing PUA claim on file.Contact Person: Margaret MabileCorrective Action Plan: The LWC will continue to work through the pandemic backlog and address issues as they arise.Anticipate Completion Date: Ongoing

Dear Mr. Waguespack,Thank you for the opportunity to respond to your office's finding related to federal research and development expenses. LSU Health Sciences Center in Shreveport (LSUHSC-S) has reviewed the issues identified by your staff. LSUHSC-S concurs with the recommendations to address the finding and provides the following response and corrective action plan.Recommendation:Management should monitor time and effort certifications completed by the departments and investigate and obtain justification from department personnel for untimely certifications as well as untimely adjustments and lack of supporting documentation for the adjustments to enforce established policies.Response and Corrective Action Plan:LSUHSC-S will continue to offer training classes and educational meetings to address the Federal requirements and ensure compliance. The training classes include one-on-one departmental meetings held by the Office of Sponsored Programs on new awards, Department Business Manager and Administrative Staff monthly meetings, and research personnel time and effort educational sessions. Emphasis will be placed on grant management organizational podcasts and classes for seasoned and new business staff, principal investigators, and institutional grant and contract support staff.LSUHSC-S will again review the procedures to address improvements for processing adjustments through PERs with sufficient justification and timely approvals and entry in Peoplesoft.Name of Contact(s) Responsible for Action PlanSheila Faour, CFO, Business and ReimbursementsJen Katzman, Assistant Vice Chancellor for Administration and Finance (with Departmental Business Managers)Bill Haacker, Assistant Director of Grants AccountingSteven McAlister, Associate Director of General AccountingAnnella Nelson, Assistant Vice Chancellor for Research DevelopmentAnticipated Completion Date: ContinuousRecommendation:Management should ensure adequate design and operating effectiveness of controls over expenses, including P-Card expenses, charged to federal awards to verify allowability of costs in accordance with federal requirements and grant terms and conditions prior to requesting reimbursement.Response and Corrective Action Plan:The transaction exceptions identified totaled approximately $1,200 with one transaction exceeding the allocated budget and two transactions being coded to an incorrect award number.To address the exceptions, LSUHSC-S is exploring implementation of additional Peoplesoft module vendor transaction utility, such as adding more approvers and requiring additional description of the purchase to assist the applicable departments in fulfilling their responsibilities in the transactional review area.LSUHSC-S will also add this responsibility role training as part of our continuing one on one meetings and educational classes.Name of Contact(s) Responsible for Action PlanSheila Faour, CFO, Business and ReimbursementsJen Katzman, Assistant Vice Chancellor for Administration and Finance (with Departmental Business Managers)Steven McAlister, Associate Director of General AccountingBill Haacker, Assistant Director of Grants AccountingAnnella Nelson, Assistant Vice Chancellor for Research DevelopmentAnticipated Completion Date: ContinuousRecommendation:Management should also consider implementing other complementary controls such as preventing costs from being charged to projects in the accounting system beyond the approved budget or period of performance.Response and Corrective Action Plan:LSUHSC-S has implemented a setting in Peoplesoft that prevents personnel expenditures on accounts over budget or beyond the performance period. The personnel expenditures are captured in a suspense account for review by departmental business staff to identify the appropriate funding. This setting will be expanded for more projects and non-personnel expenditures.Name of Contact(s) Responsible for Action PlanSheila Faour, CFO, Business and ReimbursementsJen Katzman, Assistant Vice Chancellor for Administration and Finance (with Departmental Business Managers)Steven McAlister, Associate Director of General AccountingBill Haacker, Assistant Director of Grants AccountingAnticipated Completion Date: June 30, 2023If you have questions or require additional information, please contact me at (318) 675-5230 or via email at cindy.rives@lsuhs.edu.

REFERENCE: 2022-006 ? EligibilityHIV Emergency Relief Project Grants (Assistance listing No. 93.914)Federal Grantor: Health Resources and Services AdministrationFacility: St. Mary?s Medical Center ? San FranciscoSt. Mary Medical Center ? Long BeachFinding: St. Mary Medical Center ? Long Beach and St. Mary?s Medical Center ? San Francisco did notconsistently retain evidence of their internal controls over the requirement to review eligibility requirements prior toadministering services in accordance with the grant agreements.Corrective Action Plan: This finding has been corrected. The 6 month eligibility check is no longer required. Forthe annual eligibility checks at St. Mary?s Medical Center ? San Francisco, all HIV patients are listed on an Excelspreadsheet that is on a shared drive. Both the Social Worker and Case Manager are responsible for monitoring andupdating patient information contained on the spreadsheet. The spreadsheet is monitored and updated daily. Hardcopies of eligibility documents are kept in a locked file cabinet located in the Social Worker?s office. Along with thehard copies, a face sheet listing eligibility documents, patient name and medical record number and name of personwho received the documents is documented. Electronic copies of eligibility documents are kept on the CaseManager?s password protected computer hard drive. The disposition and status of each patient is documented on thespreadsheet. The date documents were last collected is listed in the first column on the eligibility spreadsheet.Patients not participating on the ADAP program are contacted at least 15 days prior to the expiration of eligibilitydocuments on file. Patient contact attempts are documented in the patient?s medical record. In the event the patientdoes not respond to phone calls the patient is sent a certified letter. Patients may be contacted via secure email withthe address on file. The spreadsheet is reviewed weekly. Outreach attempts are documented in the patient?smedical chart. Corrective action was implemented in July 2022.At St. Mary Medical Center ? Long Beach, In April 2022 management implemented a more robust and electronicfile for each client to make it easy to ensure appropriate tracking of eligibility requirements validation. Files arereviewed monthly to ensure compliance.Person Responsible: Toni Luckett, Manager of Nursing, St. Mary?s San FranciscoSharon McNealy, CFO ? St. Mary Long BeachCompletion: April 30, 2022

REFERENCE: 2022-007 ? Allowable Costs/Cost PrinciplesHIV Emergency Relief Project Grants (Assistance listing No. 93.914)Federal Grantor: Health Resources and Services AdministrationFacility: St. Mary?s Medical Center ? San FranciscoVirginia MasonFinding: At St. Mary?s Medical Center ? San Francisco and Virginia Mason, controls over the requiredallowability criteria with regard to payroll expense were not performed and/or documented throughout the year.Corrective Action Plan: This finding has been corrected. At St. Mary?s Medical Center ? San Francisco, as of July2021 invoices were prepared using actual payroll as opposed to budget. At Virginia Mason, beginning in April 2022,managers receive notification from the payroll department of unapproved time cards that are waiting for approval.A reminder email is sent to managers and employees to approve and submit their time cards on time. Trainingsessions were implemented to instruct all employees and the managers of this requirement. Once the training hasbeen completed and employees or managers miss approving the timecard then disciplinary actions will be taken.Payroll sends out messages of outstanding timecards awaiting approval.Person Responsible: Doug Amarelo ? St. Mary?s Medical Center, San FranciscoRebecca Kiser ? Virginia MasonCompletion: April 2022

REFERENCE: 2022-015 ? Allowable Costs/Cost PrinciplesMedical Assistance Program (Medicaid Cluster) (93.778)Federal Grantor: U.S. Department of Health and Human ServicesFacility: Dignity Health Connected LivingFinding: At Dignity Health Connected Living, internal controls over the required allowability criteria with regard to payroll expense were not performed for 1 of 25 employees selected for testing.Corrective Action Plan: In addition to timecard approval by supervisors, Dignity Health Connected Living finance will review a TEAMs salary report to review that time charged to the grant is accurate and appropriate. Review will be completed on a payperiod basis.Person Responsible: Marcela Ashinhurst, Senior Financial AnalystExpected Completion: April 2023

REFERENCE: 2022-012 ? EligibilityMedicaid Cluster (93.778)Federal Grantor: U.S. Department of Health and Human ServicesFacility: Dignity Health Medical FoundationDignity Health Connected LivingFinding: The Dignity Health Medical Foundation and Dignity Health Connected Living did not retain evidence of Medicaid eligibility being reviewed prior to patient services being provided.Corrective Action Plan: For the Medical Assistance Program eligibility is validated through a Medi-Cal system website. Dignity Health Medical Foundation personnel have implemented procedures to ensure documentation of eligibility checks are retained. The Clinic Operations manager has instructed staff and supervisors to save proof of eligibility for all months. The Clinic Operations manager checks for retention of eligibility documentation on a random basis and an internal audit will be performed to check for compliance with the documentation retention.At Connected Living the staff will identify participants who may be ineligible for continued services at the beginning of each service month. The Medi-Cal eligibility report is produced on the first business day of each month. The list includes all eligible and ineligible participants. This report will be saved each month for tracking purposes. The report will be reviewed each month for ineligible participants or factors that may impact eligibility for the coming month. Steps will be taken to obtain proof of eligibility or being termination proceedings.Person Responsible: Nicole Hill, Clinic Operations Manager, Dignity Health Medical Foundation.Kristina Devan, Dignity Health Connected LivingCompletion: July 1, 2022

REFERENCE: 2022-017 ? Special Tests and Provisions ? Disbursements to or on Behalf of StudentsSFA Cluster (84.268)Federal Grantor: U.S. Department of EducationFacility: Good Samaritan College of Nursing and Health ScienceFinding: Good Samaritan College of Nursing & Health Science did not send loan notifications to 2 of 28 students selected for disbursement testing for direct loans.Corrective Action Plan: Compliance will be verified through internal audit of student disbursements. A sample of disbursements will be checked for proper notifications on periodic basis throughout the semester.Person Responsible: James Younger, Dean of Financial Services and DevelopmentExpected Completion: April 2023

REFERENCE: 2022-001 ? Special Tests and Provisions ? Disbursements to or on Behalf of StudentsStudent Financial Assistance Cluster (Assistance listing No. 84.268)Federal Grantor: U.S. Department of EducationFacility: Good Samaritan College of Nursing and Health ScienceFinding: Good Samaritan College of Nursing & Health Science did not have evidence of whether the quality assurance system was operating effectively during the fiscal year ended June 30, 2022.Corrective Action Plan: This finding was corrected by June 30, 2022. In January 2021 the institution updated the Financial Aid Department Policy and Procedure Manual to include a section that address quality assurance oversight. The Quality Assurance Plan developed includes the following: reports loan records, disbursements, and adjustments to disbursements correctly to the Common Origination Disbursement system; disburses and returns loan funds in accordance with regulatory requirements; disburses the correct loan amount to the correct student; completes monthly reconciliation and Program Year Closeout. Program will be reviewed annually and updated accordingly by FAS and GSC Management. Compliance with the quality assurance policy is monitored through the reconciliation process which was implemented in June 2022.Person Responsible: Judy Kronenberger ? President Good Samaritan College of Nursing and Health ScienceCompletion: June 2022

REFERENCE: 2022-002 ? Special Tests and Provisions ? Borrower Data and Reconciliation (Direct Loan)Student Financial Assistance Cluster (Assistance Listing No. 84.268)Federal Grantor: U.S. Department of EducationFacility: Good Samaritan College of Nursing and Health ScienceFinding: Good Samaritan College of Nursing & Health Science did not perform the direct loan monthlyreconciliations for FY22.Corrective Action Plan: Good Samaritan implemented a formal monthly reconciliation process, includingcomparison of all systems for the period, a final review of G5 funds prior to draw down, a cover sheet noting anyexplaining any differences, proper sign off for preparation and review and the date by Good Samaritan management.A year end reconciliation will also be performed following the same process.Person Responsible: Judy Kronenberger ? President Good Samaritan College of Nursing and Health Scienceand Financial Aid Services (FAS)Completion: June 2022

REFERENCE: 2022-003 ? Reporting ? Common Origination and Disbursement (COD) SystemStudent Financial Assistance Cluster (Assistance listing No. 84.063)Federal Grantor: U.S. Department of EducationFacility: Good Samaritan College of Nursing and Health ScienceFinding: Good Samaritan College of Nursing & Health Science did not perform its internal control over therequirement to submit Pell payment data to the Department of Education through the COD system, which consists ofmonthly Pell COD reconciliations.Corrective Action Plan: Good Samaritan will implement a formal monthly reconciliation process, includingcomparison of all systems for the period, a final review of G5 funds prior to draw down, a cover sheet noting anyexplaining any differences, proper sign off for preparation and review and the date by Good Samaritan management.A year end reconciliation will also be performed following the same process.Person Responsible: Judy Kronenberger ? President Good Samaritan College of Nursing and Health Scienceand Financial Aid Services (FAS)Completion: June 2022

REFERENCE: 2022-005 ? Special Tests and Provision ? Enrollment ReportingStudent Financial Assistance Cluster (Assistance listing No. 84.007, 84.063, 84.268)Federal Grantor: U.S. Department of EducationFacility: Good Samaritan College of Nursing and Health ScienceFinding: Good Samaritan College of Nursing & Health Science did not have internal controls over enrollmentreporting.Corrective Action Plan: Monthly reconciliations are conducted by the Bursar and Financial Aid departments.Monthly reconciliation reports are presented to the Dean of Enrollment Management at all monthly reconciliationupdate meetings.Person Responsible: Judy Kronenberger ? President Good Samaritan College of Nursing and Health ScienceCompletion: June 2022

REFERENCE: 2022-004 ? Cash ManagementStudent Financial Assistance Cluster (Assistance listing No. 84.007, 84.063, 84.268)Federal Grantor: U.S. Department of EducationFacility: Good Samaritan College of Nursing and Health ScienceFinding: Per discussion with management, Good Samaritan College of Nursing & Health Science has processes andinternal controls in place to ensure requests for funding are allowable under the terms of the grant agreement. Theseinternal controls included validating the draw agreed between the G5 system, COD, and Good Samaritan College ofNursing & Health Science?s internal records for student financial need. However, management did not consistentlyretain documentation evidencing the performance of these internal controls.Corrective Action Plan: Good Samaritan will implement a formal monthly reconciliation process, includingcomparison of all systems for the period, a final review of G5 funds prior to draw down, a cover sheet noting anyexplaining any differences, proper sign off for preparation and review and the date by GSC management and FASmanagement. A year end reconciliation will also be performed following the same process.Person Responsible: Judy Kronenberger ? President Good Samaritan College of Nursing and Health ScienceCompletion: June 2022

REFERENCE: 2022-014 ? Allowable Costs/Cost PrinciplesCoronavirus Relief Fund (21.019)Federal Grantor: U.S. Department of TreasuryFacility: CHI MemorialFinding: At CHI Memorial, controls over the required allowability criteria and period of performance with regard to payroll expense were not performed and/or documented.Corrective Action Plan: Hospital staff will be provided training to refresh the requirement to approve timecards for supervisees. Accounting/finance will review payroll reports to ensure only time properly approved is charged to grant for reimbursement.Person Responsible: Craig Nielsen, Market Director Operational FinanceExpected Completion: April 2023

REFERENCE: 2022-018 ? Procurement and Suspension and DebarmentResearch and Development Cluster (12.420, 93.103 and 93.853)Federal Grantor: U.S. Department of Defense and U.S. Department of Health and Human ServicesFacility: St. Joseph?s Hospital and Medical CenterFinding: St. Joseph?s Hospital and Medical Center did not prepare and retain documentation of sole source justification for three procurements over the micro-purchase threshold made without competition.Corrective Action Plan: Training was provided to program and operations managers to add additional documentation to requisitions. An updated work instruction will be developed by the research administration department outlining the necessary documentation for non-competitive purchases.Person Responsible: Sheri Sanders, Division Director Research AdministrationExpected Completion: April 2023

REFERENCE: 2022-016 ? Subrecipient MonitoringResearch and Development Cluster (12.420, 93.279, 93.853, and 93.866)Federal Grantor: U.S. Department of Defense and U.S. Department of Health and Human ServicesFacility: St. Joseph?s Hospital and Medical CenterFinding: St. Joseph?s Hospital and Medical Center?s subrecipient monitoring tracking document, while designed appropriately, is not being maintained effectively and includes errors, since line items on the tracking document for several subrecipients appear to be incorrect with regards to audit findings. Findings appear to have been left off of the tracking document or added incorrectly for a particular subrecipient or may not apply to the subrecipient but to a different subrecipient.Corrective Action Plan: To check for completeness and accuracy, additional review of the subrecipient monitoring tracking document will completed by the Division Director Research Administration and System Director Grant Accounting.Person Responsible: Sheri Sanders, Division Director Research Administration and Jenny Lewis-Whelan, System Director Grant AccountingExpected Completion: June 2023

REFERENCE: 2022-011 ? Special Tests and Provisions ? Key PersonnelResearch and Development Cluster (Multiple)Federal Grantor: U.S. Department of DefenseU.S. Department of Health and Human ServicesFacility: St. Joseph?s Hospital and Medical CenterFinding: St. Joseph?s Hospital and Medical Center?s internal controls over key personnel were not designed and operating effectively since level of effort certifications were not completed and signed timely by key personnel on grants.Corrective Action Plan: On a quarterly basis, program managers and grant managers meet with the principal investigator on all of their federal grants. During the meeting, level of effort is reviewed and certified by PI?s.Person Responsible: Research Ops Managers; Tomas Cortez, Grant Accounting ManagerCompletion: September 2022

REFERENCE: 2022-010 ? Allowable Costs/Cost Principles (Salary Cap)Research and Development Cluster (Multiple)Federal Grantor: U.S. Department of DefenseU.S. Department of Health and Human ServicesFacility: St. Joseph?s Hospital and Medical CenterFinding: St. Joseph?s Hospital and Medical Center did not retain evidence of review of the NIH salary cap requirement.Corrective Action Plan: On a quarterly basis, program managers and grant managers meet with the principal investigator on all of their federal grants. During the meeting, the actual hours for all individuals are reviewed. Additionally, a reconciliation of actual to budget is performed. Documentation of the quarterly reviews is maintained on a google shared drive. Quarterly meetings include evaluation of salary charged to grant in comparison to NIH salary cap.Person Responsible: Research Ops Managers; Tomas Cortez, Grant Accounting ManagerCompletion: September 2022

REFERENCE: 2022-008 ? Activities Allowed or UnallowedResearch and Development Cluster (Multiple)Federal Grantor: U.S. Department of DefenseU.S. Department of Health and Human ServicesFacility: St. Joseph?s Hospital and Medical CenterFinding: St. Joseph?s Hospital and Medical Center used budgeted costs to determine the amount of expenses allocated to the grant and failed to reconcile these amounts to actual payroll costs at year-end. Additionally, certain payroll expenditures were not reviewed and approved.Corrective Action Plan: On a quarterly basis, program managers and grant managers meet with the principal investigator on all of their federal grants. During the meeting, the actual hours for all individuals are reviewed. Additionally, a reconciliation of actual to budget is performed. Documentation of the quarterly reviews is maintained on a google shared drive. Clinical time for federal grants will be supported by a completed timesheet signed by a supervisor or PI. Timesheets will be completed monthly.Person Responsible: Research Ops Managers; Tomas Cortez, Grant Accounting ManagerExpected Completion: September 2022

REFERENCE: 2022-009 ? Activities Allowed or UnallowedResearch and Development Cluster (Multiple)Federal Grantor: U.S. Department of DefenseU.S. Department of Health and Human ServicesFacility: St. Joseph?s Hospital and Medical CenterFinding: At St. Joseph?s Hospital and Medical center, internal controls over allowability criteria with regard to indirect expenditures were not performed throughout the entire period.Corrective Action Plan: Indirect expense calculation is reviewed and compared to grant agreement by Grant Accounting Manager prior to month end close.Person Responsible: Tomas Cortez, Grant Accounting ManagerCompletion: January 2022

Finding Number 2022-208: State Opioid Response program performance progress reports did not have documentation to support completion of a review for accuracy and compliance prior to submission.Federal Program: 93.788 - Opioid STRRelated to Prior Finding: N/AAgency?s view: The Department agrees with this finding.The contract manager attests that she did, in fact, review, edit, re-review and ultimately approve the 5 program performance reports to the grantor. The reports were either emailed to the Program Manager or uploaded in Teams for her review/approval. The auditor was provided documentation of these reviewed documents, including editing notes by that manager. Additionally, one-on-one supervision notes between the person submitting the reports and the contract manager validate that these reports were, in fact, reviewed and approved prior to submission to the grantor. The federal funder does not require this type of documentation of review/approval and the program was not aware of this CFR requirement. The program does, however, agree, that review and approval of these reports was not documented and that a corrective action plan is warranted.Corrective Action: Beginning April 1, 2023, all required federal reports will include thefollowing statement, which will be signed and dated electronically by the approving reviewerbefore the report is submitted:? I, _______________________, have reviewed and approved this report prior tosubmission.Name, titleA copy of the approved and signed report will be retained in DBH?s electronic grant fundingrecords.Anticipated Corrective Action Date: April 1, 2023Responsible for Corrective Action: Kelly Combs, Bureau Chief, Compliancekelly.combs@dhw.idaho.gov 208-334-5814

Finding Number 2022-211: The Schedule of Expenditures of Federal Awards (SEFA) closing package originally submitted to the Office of the State Controller did not properly identify COVID-19 Emergency Acts expenditures for multiple programs.Federal Programs:93.391 - Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises10.551 - Supplemental Nutrition Assistance Program (Snap)84.181 - Special Education - Grants for Infants and Families93.497 - Family Violence Prevention and Services/ Sexual Assault/Rape Crisis Services and Supports93.590 - Community-Based Child Abuse Prevention Grants93.958 - Block Grants for Community Mental Health Services93.977 - Sexually Transmitted Diseases (STD) Prevention and Control Grants10.557 - WIC Special Supplemental Nutrition Program for Women, Infants, And Children10.561 - State Administrative Matching Grants for The Supplemental Nutrition Assistance ProgramRelated to Prior Finding: 2021-206Agency?s view: The Department agrees with this finding.The Department agrees with this finding but it is important to highlight that our internal controls and review processes are designed to detect and correct material inaccuracies or omissions of required information within the annual SEFA. As this does not constitute a material error, but rather a significant deficiency, the Department?s controls for this process worked as intended.This was a new requirement and Department personnel failed to identify a significant risk related to it and enhance the review procedures accordingly. This requirement will be monitored while we spend down the remaining COVID-19 emergency funding we have already been awarded.Corrective Action: This corrective action plan is complete. Effective immediately, we willmonitor awards for any new COVID-19 funding, but we don?t believe that there will be any newCOVID-19 awards. All existing awards have been confirmed as being reported as COVID-19funding.Anticipated Corrective Action Date: Corrective action has been taken as of April 2023Responsible for Corrective Action: Kelly Combs, Bureau Chief, Compliancekelly.combs@dhw.idaho.gov 208-334-5814

Finding Number 2022-202: The Commission did not complete required reports for the Federal Funding Accountability and Transparency Act (FFATA).Federal Programs: 93.044, 93.045, 93.053 ? Aging ClusterRelated to Prior Finding: N/AAgency?s view: The Commission agrees with this finding.Corrective Action: Federal Funding Accountability and Transparency Act (FFATA) reporting for federal fiscal years 2021, and 2022 have been completed as of March 27, 2023. The agency will complete FFATA reporting as awards are administered to sub-awardees going forward.Anticipated Corrective Action Date: March 27, 2023Responsible for Corrective Action: Joe Zaher, Senior Financial SpecialistJoe.zaher@aging.idaho.gov 208-577-2864

Finding Number 2022-201: The Commission did not complete the required Federal Financial SF-425 Report for the Aging Cluster Grant program in a timely manner.Federal Programs: 93.044, 93.045, 93.053 ? Aging ClusterRelated to Prior Finding: N/AAgency?s view: The Commission agrees with this finding.Corrective Action: Actions have been taken to complete SF-425 reports as they come due for each grant. A reporting workbook has been created to track awards and reporting dates. Reporting period end dates and due dates will be added to fiscal staff calendars. We will continue to keep our federal partners appraised of our progress through completion.Anticipated Corrective Action Date: 'A soft target date for completion of all past due reports is set for September 30, 2023, and a hard target date of December 31, 2023.Responsible for Corrective Action: Joe Zaher, Senior Financial SpecialistJoe.zaher@aging.idaho.gov 208-577-2864