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Finding 59797 (2022-023)
Significant Deficiency 2022
Program: Various, including AL 10.561 ? State Administrative Matching Grants for the Supplemental Nutrition Assistance Program; AL 93.558 ? Temporary Assistance for Needy Families; AL 93.566 ? Refugee and Entrant Assistance State/Replacement Designee Administered Programs; AL 93.575 ? Child Care and...
Program: Various, including AL 10.561 ? State Administrative Matching Grants for the Supplemental Nutrition Assistance Program; AL 93.558 ? Temporary Assistance for Needy Families; AL 93.566 ? Refugee and Entrant Assistance State/Replacement Designee Administered Programs; AL 93.575 ? Child Care and Development Block Grant ? Allowable Costs/Cost Principles Corrective Action Plan: Several areas within DHHS are currently working to improve upon the process of determining how staff are paid during the hiring process and when turnover occurs. Contact: Patrick Werner Anticipated Completion Date: 02/01/2024
View Audit 55212 Questioned Costs: $1
Finding Number: 2022-004 Program: 14.218 ? Community Development Block Grant Compliance Requirement: Special Tests and Provisions ? Wage Rate Requirements Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Condition: Prince George?s County (County) did not ens...
Finding Number: 2022-004 Program: 14.218 ? Community Development Block Grant Compliance Requirement: Special Tests and Provisions ? Wage Rate Requirements Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Condition: Prince George?s County (County) did not ensure a construction project complied with wage rate requirements. Cause: The County?s policies and procedures were not sufficient to ensure that all contracts complied with wage rate requirements. Internal controls did not prevent or detect the error. Resolution: DHCD established Policies and Procedures governing all entitlement programs, including the Community Development Block Grant Program. All projects subject to the Davis Bacon Wage Rate requirement must have a preconstruction conference where wage rates and submission of certified payrolls are discussed. They must also submit certified payroll before a reimbursement is processed. This particular subrecipient became unresponsive and extensive technical assistance was provided for over a year. Responsible Party: Aspasia Xypolia, Director, DHCD Anticipated corrective action plan completion date: The Department will continue to follow the established procedures going forward to ensure that all projects subject to the Davis Bacon Wage Rate requirement will be reviewed and approved for compliance prior to the approval of reimbursement. For the one project out of compliance, extensive technical assistance was provided for over a year. A letter (attached) was sent to the subrecipient outlining the technical assistance and documentation needed. The Department is in the process of recovering the funds previously awarded to this subrecipient. Any questions concerning the findings or corrective action plan can be directed to Aspasia Xypolia, Director, DHCD at (301) 883-5501.
Finding Number: 2022-003 Program: 14.218 ? Community Development Block Grant Compliance Requirement: Reporting ? Performance Reporting Type of Finding: Material Weakness in Internal Control Over Compliance, Material Noncompliance Condition: Prince George?s County (County) did not submit a report of ...
Finding Number: 2022-003 Program: 14.218 ? Community Development Block Grant Compliance Requirement: Reporting ? Performance Reporting Type of Finding: Material Weakness in Internal Control Over Compliance, Material Noncompliance Condition: Prince George?s County (County) did not submit a report of Section 3 activities for a specific project to IDIS as required. Cause: The County?s policies and procedures were not sufficient to ensure that Section 3 reports were completed and submitted to IDIS as required by program regulations. Internal controls did not prevent or detect the error. Resolution: DHCD established Policies and Procedures governing all entitlement programs, including the Community Development Block Grant Program. All projects subject to Section 3 must have a preconstruction conference where Section 3 is discussed, among other required regulations. They must also submit Section 3 documentation before the project is closed- out and reimbursement is processed. Responsible Party: Aspasia Xypolia, Director, DHCD Anticipated corrective action plan completion date: The Department will continue to follow the established procedures going forward to ensure that all projects subject to the Section 3 requirement will be reviewed and approved for compliance prior to the approval of close-out and reimbursement. The department does have the Section 3 report for all project including this specific project, however it was not processed through the Integrated Disbursement and Information System (IDIS), which was effective July 2021. This particular report (attached) will be submitted through the FHEO Section 3 Performance Evaluation and Registry System (SPEARS). Any questions concerning the findings or corrective action plan can be directed to Aspasia Xypolia, Director, DHCD at (301) 883-5501.
Finding Number: 2022-002 Program: 14.218 ? Community Development Block Grant Compliance Requirement: Reporting ? Federal Funding Accountability and Transparency Act (FFATA) Type of Finding: Material Weakness in Internal Control Over Compliance, Material Noncompliance Condition: Prince George?s Count...
Finding Number: 2022-002 Program: 14.218 ? Community Development Block Grant Compliance Requirement: Reporting ? Federal Funding Accountability and Transparency Act (FFATA) Type of Finding: Material Weakness in Internal Control Over Compliance, Material Noncompliance Condition: Prince George?s County (County) did not report required subaward information to FSRS for first-tier subawards of $30,000 or more. Cause: The County?s policies and procedures were not sufficient to ensure that required subaward information was reported to FSRS. Internal controls did not prevent or detect the errors. Resolution: DHCD established Policies and Procedures governing all entitlement programs, including the Community Development Block Grant Program. DHCD will provide the Office of Management of Budget (OMB) with all subawards of $30,000 or more monthly to upload into the FSRS system. Responsible Party: Aspasia Xypolia, Director, DHCD Anticipated corrective action plan completion date: The Department will coordinate with OMB to upload the required data of the sub awardees receiving $30,000 or more in entitlement funds. DHCD has the necessary sub-awardee data for current and prior years to begin updating the required data. Any questions concerning the findings or corrective action plan can be directed to Aspasia Xypolia, Director, DHCD at 301-883- 6511.
Finding 2022-002 Federal Agency Name: Department of Treasury, State of South Dakota Governor?s Office of Economic Development Program Name: Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing: 21.027 Finding Summary: The Company has not documented their internal c...
Finding 2022-002 Federal Agency Name: Department of Treasury, State of South Dakota Governor?s Office of Economic Development Program Name: Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing: 21.027 Finding Summary: The Company has not documented their internal controls for compliance with the procurement, suspension and debarment compliance requirement of Uniform Guidance as outlined above. The Company does not have a written policy related to procurement or written standards of conduct for employees involved in contracting, awarding contracts only to responsible contractors, and maintaining records to document history of procurement, as well as, established procedures in place related to suspension and debarment. The Company did not follow the procurement method required based on the dollar amount and conditions specified in 2 CFR 200.320. For contracted vendors with expenditures in excess of $25,000, the Company did not verify vendors were not suspended or debarred prior to entering into transaction with the vendor. Responsible Individuals: James Groft, CEO Corrective Action Plan: The Company will draft and adopt policies that implement internal controls consistent with the compliance requirements for procurement, suspension and debarment. The Company will follow the new documented policies and retain documentation to support compliance with the requirements. Anticipated Completion Date: June 1st, 2023
FINDING 2022-002 Contact Person Responsible for Corrective Action: Yvonne Hoffmaster Contact Phone Number: 219 873-1404 Ext. 2004 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: To bring the City into compliance with effective internal controls to en...
FINDING 2022-002 Contact Person Responsible for Corrective Action: Yvonne Hoffmaster Contact Phone Number: 219 873-1404 Ext. 2004 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: To bring the City into compliance with effective internal controls to ensure requirements related to the grant agreement and the reporting compliance requirements are satisfied, the City Controller will prepare the project and expenditure reports and the Assistant Controller, or the 2nd Assistant Controller will review the project and expenditure reports before they are submitted. Anticipated Completion Date: The process will begin with the reports due April 30, 2023.
FINDING 2022-001 Contact Person Responsible for Corrective Action: Yvonne Hoffmaster Contact Phone Number: 219 873-1404 Ext. 2004 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: To bring the City into compliance with effective internal controls to en...
FINDING 2022-001 Contact Person Responsible for Corrective Action: Yvonne Hoffmaster Contact Phone Number: 219 873-1404 Ext. 2004 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: To bring the City into compliance with effective internal controls to ensure requirements related to the grant agreement and the Suspension and Debarment are satisfied, the City has created a checklist, Exhibit A, that contain a sign off by the Department Head and Board of Works as necessary. Anticipated Completion Date: The checklist will begin to be utilized on May 1, 2023.
FINDING 2022-001 Contact Person Responsible for Corrective Action: Adam C. Minth, Assistant Superintendent Contact Phone Number: 219-374-3504 Views of Responsible Official: The school corporation concurs with the finding and will be implementing corrective procedures by the end of this fiscal year. ...
FINDING 2022-001 Contact Person Responsible for Corrective Action: Adam C. Minth, Assistant Superintendent Contact Phone Number: 219-374-3504 Views of Responsible Official: The school corporation concurs with the finding and will be implementing corrective procedures by the end of this fiscal year. Description of Corrective Action Plan: The Corporation Treasurer and the Assistant Superintendent of Business and Operations are going to perform an analysis on the identified employee who is currently splitting her duties between the Child Nutrition Cluster and other non-federal duties. The analysis will be used to determine what percentage of her workload is directly related to the Child Nutrition Cluster, and what percentage is directly related to non-federal duties. Once the analysis has been completed, the Assistant Superintendent of Business and Operations will direct the Payroll Specialist in regard to what percentage of her pay should go to the Child Nutrition Cluster, and what percentage should go to the Operations Fund. Anticipated Completion Date: 4/30/2023
View Audit 50200 Questioned Costs: $1
2022-001 ? Significant deficiency in documentation supporting Provider Relief Fund expenditures Cluster: Not applicable Federal Granting Agency: Health Resources and Services Administration (HRSA) Assistance Listing #: 93.498 Assistance Listing Title: COVID-19 Provider Relief Fund and American Resc...
2022-001 ? Significant deficiency in documentation supporting Provider Relief Fund expenditures Cluster: Not applicable Federal Granting Agency: Health Resources and Services Administration (HRSA) Assistance Listing #: 93.498 Assistance Listing Title: COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Award Year: 1/1/20 - 6/30/22 Pass-through entity: Not applicable Management has reassessed its internal controls over the review and approval of allowable expenditures under this program. HRSA reporting periods 4 and 5 are supported by lost revenues and will not include any expenditures. Management has updated its documentation for this program and is in the process of updating other documentation related to period 4 and 5 for the FY23 audit. Leadership Responsible: Steve Warren, Network Grants Management Manager; Melissa Laurie, Network VP/Corporate Controller Anticipated Completion Date: 9/30/2023
2022-002 ? Material weakness over amounts reported on the Schedule of Expenditures of Federal Awards (SEFA) Cluster: Not applicable Federal Granting Agency: Health Resources and Services Administration (HRSA) Award Year: 10/1/21 ? 9/30/22 Assistance Listing #: 93.461 Assistance Listing Title: HRSA ...
2022-002 ? Material weakness over amounts reported on the Schedule of Expenditures of Federal Awards (SEFA) Cluster: Not applicable Federal Granting Agency: Health Resources and Services Administration (HRSA) Award Year: 10/1/21 ? 9/30/22 Assistance Listing #: 93.461 Assistance Listing Title: HRSA COVID-19 Claims Reimbursement for the Uninsured Program and the COVID-19 Coverage Assistance Fund Pass-through entity: Not applicable Management notes that this program is complete, and expenditures will not be incurred or present on the Schedule of Expenditures of Federal Awards (SEFA) in future years. Management is working toward a centralized process for grant tracking. Blackbaud?s Financial Edge NXT software was implemented at UVM Medical Center, CVMC, PMC, and AHMC in 2021, ECH in 2022 and is scheduled to complete for CVPH on October 1, 2023. The system still needs to be implemented at HHH with a goal date of sometime in FY24. The system has the capability to track all grant related expenses and income by organization but currently only being used for grant tracking at UVMMC. This change in process is in its later stages. The intent of this work is to ensure that all grants are tracked centrally, with consistent oversight and monitoring. This will allow for centralized compilation of the SEFA for the Uniform Guidance audit. Currently the process is disparate across several entities with not a single point of contact. Management has added an additional FTE within the Network Grants Management Finance team beginning at the end of July 2023 to engage in this work to centralize grant tracking, which will continue to enhance our controls to ensure completeness and accuracy of the consolidated Network SEFA. Leadership Responsible: Steve Warren, Network Grants Management Manager; Melissa Laurie, Network VP/Corporate Controller Anticipated Completion Date: 12/31/2023
Finding 2022-001 Activities Allowed or Unallowed and Allowable Costs/Cost Principles A material weakness in internal control over compliance was issued related to activities allowed or unallowed and allowable costs/cost principles for the R&D Cluster grant agreements of Advocate Aurora Health (the ...
Finding 2022-001 Activities Allowed or Unallowed and Allowable Costs/Cost Principles A material weakness in internal control over compliance was issued related to activities allowed or unallowed and allowable costs/cost principles for the R&D Cluster grant agreements of Advocate Aurora Health (the Organization). Charges of salaries and wages to the R&D Cluster were not consistently reviewed by a knowledgeable individual or not certified timely. In addition, certain individuals? effort certification did not account for 100% of their effort (R&D and institutional). This is a repeat finding (2021-002). The Office of Sponsored Research (OSR) committed in the 2020 Corrective Action Plan to implement a paper format effort certification process beginning March 2022. This process was fully implemented by the end of fiscal 2022. Also in 2022, Advocate Aurora Research Institute employees were transferred and integrated under one financial system. The integration of this system supports the monitoring of 100% of total effort. The OSR will also continue to utilize a paper effort certification process. The OSR team will generate effort certification form, distribute the effort certification form to the appropriate team member for manual or electronic signature and obtain a secondary approval signature from an individual who has first-hand knowledge of the team member's activities. All completed effort certification forms will be verified and initialed by a third individual. Effort certification logs will be maintained to ensure that all effort certifications are completed within 30 days. Completed effort certification forms will be maintained within OSR. Sarah Long, Director Sponsored Research, is responsible for this Corrective Action Plan.
Finding 59624 (2022-002)
Significant Deficiency 2022
Condition: Internal controls over the payroll transaction cycle were not operating effectively in that payroll was being processed without proper review and approval of employee timecards being performed by supervisors. Management is responsible for compliance with the requirements referred to abov...
Condition: Internal controls over the payroll transaction cycle were not operating effectively in that payroll was being processed without proper review and approval of employee timecards being performed by supervisors. Management is responsible for compliance with the requirements referred to above and for the design, implementation, and maintenance of effective internal control over compliance with the requirements of laws, statutes, regulations, rules and provisions of contracts or grant agreements applicable to the Organization?s federal programs. In testing payroll transactions for compliance, we identified instances of employees? timecards lacking approval from supervisors prior to their hours being charged to the federal program. Planned Corrective Action: Management has now developed a ?Timecards Not Approved? query report within ADP, which the Controller will run two days prior to payroll submission. This query will be provided to the Operations Director and Fiscal Services Director. If the query reflects instances of non-timecard approval, the applicable supervisor(s) will be contacted to ensure the timecard is approved before payroll is submitted. Contact Person: Mark Swanson, Fiscal Services Director Anticipated Completion Date: July 31, 2023
Financial Statement Finding: 2022-001 ? Significant Deficiency in Internal Control over Financial Reporting and Compliance ? Payroll Allocations Name and Contact Person: Shanette Wik, Chief Executive Officer 907-283-2682 swik@bgckp.com Corrective Action: The Organization has taken steps to...
Financial Statement Finding: 2022-001 ? Significant Deficiency in Internal Control over Financial Reporting and Compliance ? Payroll Allocations Name and Contact Person: Shanette Wik, Chief Executive Officer 907-283-2682 swik@bgckp.com Corrective Action: The Organization has taken steps to utilize a new payroll system to help address issues and reduce issues with the allocation of employee wages and the processing of payroll. Proposed Completion Date: March 1, 2023
Federal Agency Name: Department of Health and Human Services Program Name: Block Grants for Community Mental Health Services CFDA # 93.958 Finding Summary: There was no formal documentation of review of wage rates for eight employees selected for testing. There was no formal documented review for t...
Federal Agency Name: Department of Health and Human Services Program Name: Block Grants for Community Mental Health Services CFDA # 93.958 Finding Summary: There was no formal documentation of review of wage rates for eight employees selected for testing. There was no formal documented review for the calculation of indirect costs submitted for reimbursement for four months selected for testing. There was no formal documented review for seven reimbursements requests selected for testing. Washburn Center has designed internal controls over these areas; however, the controls were not formally documented. Responsible Individuals: Mohamed Omar, MBA, MS, Chief Administrative Officer Corrective Action Plan: Management will review the current active review process and implement a formal documentation of the review including the appropriate level of management sign off and date of review on the supporting documentation. Anticipated Completion Date: December 2023
FINDING 2022-003 Finding Subject: Water and Waste Disposal Systems for Rural Communities - Internal Controls Summary of Finding: Material weaknesses found involving Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and Procurement and Suspension and Debarment for the Water and Waste ...
FINDING 2022-003 Finding Subject: Water and Waste Disposal Systems for Rural Communities - Internal Controls Summary of Finding: Material weaknesses found involving Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and Procurement and Suspension and Debarment for the Water and Waste Disposal Systems for Rural Communities major federal program. Contact Person Responsible for Corrective Action: John Paulin, Clerk-Treasurer and Ralph Terry, Mayor Contact Phone Number and Email Address: 812-547-8994, canneltoncct@gmail.com (Clerk- Treasurer) cnneltonmayorusa@gmail.com (Mayor) Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Activities Allowed or Unallowed and Allowable Costs/Cost Principles The City Council will review program disbursements to ensure that program disbursements were in compliance with Activities Allowed or Unallowed, Allowable Costs/Cost Principles requirements. Procurement and Suspension and Debarment The City plans to review existing policies and procedures and make any needed changes to ensure that they are in compliance with the federal compliance requirements for procurement as well as suspension and debarment. Furthermore, controls will be established to ensure that the City?s policies related to compliance with the federal compliance requirements for procurement as well as suspension and debarment are followed. Anticipated Completion Date: January 2024
View of Responsible Officials DLS has implemented a procedure across all ESF and ESEA programs to ensure timely and accurate reporting. DLS has also partnered with GSA to resolve issues within the FSRS (FFATA) system, however, there seems to be many technical issues on their end that their develope...
View of Responsible Officials DLS has implemented a procedure across all ESF and ESEA programs to ensure timely and accurate reporting. DLS has also partnered with GSA to resolve issues within the FSRS (FFATA) system, however, there seems to be many technical issues on their end that their developers are currently working through. At the time of this finding, the technical issue on GSA?s side hasn?t been resolved. The procedure includes a flow chart, PowerPoint presentation, FAQ document, and process. Additionally, there have been numerous training opportunities both in person and online across the Division to train as many stakeholders as possible in the reporting and monitoring of FFATA to ensure timeliness and accuracy. In-person and online trainings were held on 01/04/23, 01/26/23, and 02/06/23. The United States Department of Education also recently held a FFATA webinar on 01/18/2023, which all ESF and ESEA program personnel involved in FFATA reporting where required to attend. Anticipated Completion Date: 02/06/2023 Contact Person: Jessica Lescarbeau, Bureau Administrator and Lindsey Labonville, Compliance Administrator
View of Responsible Officials The Department does not concur. The Department notes extensions are in place related to COVID-19 and the Tydings Amendment through the Department of Education mitigating the condition noted. The Department will confer with the US DE to clarify the extensions in place ...
View of Responsible Officials The Department does not concur. The Department notes extensions are in place related to COVID-19 and the Tydings Amendment through the Department of Education mitigating the condition noted. The Department will confer with the US DE to clarify the extensions in place and resolve any disparities identified within the finding. Anticipated Completion Date: Completed as of the date of this report Contact Person: Lindsey Labonville, Melissa White Rejoinder Based on the supporting documentation provided by the Department, it did not appear that the expenses identified within the condition found were charged to the correct period of performance during the liquidation period. Subsequently management adjusted the CAN the expenses related to which would correct the condition found.
View Audit 49723 Questioned Costs: $1
View of Responsible Officials NHED concurs with the finding identified in section A. This was an oversight on the part of NHED, and a process has been implemented to ensure that when the GAN template is generated, there is a review by 2 separate staff members to ensure all required elements on the G...
View of Responsible Officials NHED concurs with the finding identified in section A. This was an oversight on the part of NHED, and a process has been implemented to ensure that when the GAN template is generated, there is a review by 2 separate staff members to ensure all required elements on the GAN are complete. NHED concurs with the finding identified in Section B. The previous Division Director of Learner Support, without understanding the unintended consequences, required that the IDEA allocations be uploaded in separate installments instead of including the full year award amount. This led to a GAN generation that included only the first installment. This procedure has since been corrected and NHED is now uploading the full year allocation amount in GMS, this will then generate a GAN that reflects the full year grant amount. If a reallocation does occur, there is a review by 2 separate staff members to ensure that the amount is verified and that a new GAN is manually generated to include that verified amount, and then the GAN is reissued to the recipient. Anticipated Completion Date: Already completed Contact Person: Lindsey Labonville
View of Responsible Officials DLS has implemented a procedure across all ESF and ESEA programs to ensure timely and accurate reporting. DLS has also partnered with GSA to resolve issues within the FSRS (FFATA) system, however, there seems to be many technical issues on their end that their develope...
View of Responsible Officials DLS has implemented a procedure across all ESF and ESEA programs to ensure timely and accurate reporting. DLS has also partnered with GSA to resolve issues within the FSRS (FFATA) system, however, there seems to be many technical issues on their end that their developers are currently working through. At the time of this finding, the technical issue on GSA?s side hasn?t been resolved. The procedure includes a flow chart, PowerPoint presentation, FAQ document, and process. Additionally, there have been numerous training opportunities both in person and online across the Division to train as many stakeholders as possible in the reporting and monitoring of FFATA to ensure timeliness and accuracy. In-person and online trainings were held on 01/04/23, 01/26/23, and 02/06/23. The United States Department of Education also recently held a FFATA webinar on 01/18/2023, which all ESF and ESEA program personnel involved in FFATA reporting where required to attend. Anticipated Completion Date: 02/06/2023 Contact Person: Jessica Lescarbeau, Bureau Administrator and Lindsey Labonville, Compliance Administrator
View of Responsible Officials The Department acknowledges the misinterpretation of the agreement as a subaward has led to a failure to comply with 2 CFR section 200.332(a). Underlying this misinterpretation was the Department?s failure to differentiate between entering into agreements with other st...
View of Responsible Officials The Department acknowledges the misinterpretation of the agreement as a subaward has led to a failure to comply with 2 CFR section 200.332(a). Underlying this misinterpretation was the Department?s failure to differentiate between entering into agreements with other state agencies and entities recognized as component units of state government such as the NH Business Finance Authority; noting agreements between state agencies would not require such compliance. Accordingly, the Department will review existing policies and procedures related to subawarding and subrecipient monitoring to ensure agreements with component units of state government are properly considered. Additionally, the Department will amend the existing agreement to ensure required award information is communicated and ensure all other subrecipient monitoring protocols are applied to the subaward. Anticipated Completion Date: June 30, 2023 Contact Person: Taylor Caswell
View of Responsible Officials The Department acknowledges the misinterpretation of the agreement as a subaward has led to a failure to comply with 2 CFR 170. Underlying this misinterpretation was the Department?s failure to differentiate between entering into agreements with other state agencies an...
View of Responsible Officials The Department acknowledges the misinterpretation of the agreement as a subaward has led to a failure to comply with 2 CFR 170. Underlying this misinterpretation was the Department?s failure to differentiate between entering into agreements with other state agencies and entities recognized as component units of state government such as the NH Business Finance Authority; noting FFATA reporting would not apply to agreements between state agencies. Accordingly, the Department will review existing policies and procedures related to FFATA reporting to ensure agreements with component units of state government are properly considered and reported. Anticipated Completion Date: June 30, 2023 Contact Person: Taylor Caswell
View of Responsible Officials The Department acknowledges the misinterpretation of the agreement as a subaward has led to a failure to comply with 2 CFR section 180. Underlying this misinterpretation was the Department?s failure to differentiate between entering into agreements with other state ag...
View of Responsible Officials The Department acknowledges the misinterpretation of the agreement as a subaward has led to a failure to comply with 2 CFR section 180. Underlying this misinterpretation was the Department?s failure to differentiate between entering into agreements with other state agencies and entities recognized as component units of state government such as the NH Business Finance Authority; noting suspension and debarment policies and procedures do not apply to agreements between state agencies. Accordingly, the Department will review existing policies and procedures related to suspension and debarment certifications to ensure agreements with component units of state government are properly considered. Anticipated Completion Date: June 30, 2023 Contact Person: Taylor Caswell
View of Responsible Officials The State concurs. The State will review and strengthen existing policies and procedures related to suspension and debarment to improve compliance. Anticipated Completion Date: December 2023 Contact Person: Chase Hagaman and Steven Giovinelli
View of Responsible Officials The State concurs. The State will review and strengthen existing policies and procedures related to suspension and debarment to improve compliance. Anticipated Completion Date: December 2023 Contact Person: Chase Hagaman and Steven Giovinelli
Finding 59409 (2022-008)
Significant Deficiency 2022
View of Responsible Officials The State largely concurs with the findings and recommendations and has either implemented procedures to address the identified conditions already or will do so. With regard to condition A(a) and (b), although the State illustrated that it includes clauses related to al...
View of Responsible Officials The State largely concurs with the findings and recommendations and has either implemented procedures to address the identified conditions already or will do so. With regard to condition A(a) and (b), although the State illustrated that it includes clauses related to allowed costs in its subawards, including direct and indirect costs, it will work to ensure that agencies entering into such agreements clearly indicate the terms required by Uniform Guidance, including permitted indirect cost rates and whether the award is for R&D. With regard to condition B, the State agrees that risk assessments should have been completed and has since implemented a framework to help ensure that agencies are more consistently conducting and documenting subrecipient risk assessments. With regard to condition C, the State concurs and has already implemented an agency-wide framework to help ensure procedures and policies are in place concerning Uniform Guidance Report review and the issuance of any necessary management decision letters, to the extent required. It is worth noting that the State in most cases has timely conducted risk assessments of subrecipients and reviewed relevant Uniform Guidance Reports, but its corrective actions will result in better documentation and more consistent and timelier follow through. Anticipated Completion Date: The corrective actions indicated above relative to conditions B and C have already been implemented as of the date of this response. The State will work to address Condition A before the end of the current Fiscal Year. Contact Person: Chase Hagaman and Steve Giovinelli
View of Responsible Officials The State concurs in part with the findings and recommended action. The State?s HAF program fully launched in March 2022 of the Fiscal Year under review, which ended June 30, 2022. On the whole, a more robust subrecipient monitoring framework and process is being implem...
View of Responsible Officials The State concurs in part with the findings and recommended action. The State?s HAF program fully launched in March 2022 of the Fiscal Year under review, which ended June 30, 2022. On the whole, a more robust subrecipient monitoring framework and process is being implemented during the current Fiscal Year for this program. However, the State has engaged in thorough monitoring of its subrecipient, receiving and reviewing recurring biweekly and quarterly reports. As noted, discussion of those reports takes place during weekly conversations with the subrecipient. However, the State has acknowledged that it needs to more formally memorialize the substance of such conversations to demonstrate such review. This change in protocol and procedure has already been implemented during this Fiscal Year. The State has also engaged in a subrecipient risk assessment and review of audited financials for the purposes of uniform guidance report review. However, its process and protocols will be revised to better demonstrate when such reviews/assessments take place moving forward. Moreover, the State relies on its subrecipient to facilitate the State?s HAF program, which includes collecting and processing data, as outlined in the program?s policy guide manual. A key feature of that process is a detailed quality control protocol. Additionally, during this Fiscal Year, the State engaged in a robust, on-site review of the subrecipient?s quality control protocols and methods, including applicant file review, and found them satisfactory and reliable. The State also works closely with its subrecipient during the quarterly and annual U.S. Treasury reporting processes, which involves reviewing and analyzing data provided by the subrecipient for reporting purposes. This review and the resulting communications can result in corrections to data prior to submission to U.S. Treasury. Corrective Action and Anticipated Completion Date: As of this response, the State has already implemented several corrective actions that align with the recommendations above, including documentation of report review during weekly calls with the subrecipient, timestamping procedures for uniform guidance report review, and on site, detailed review of quality control protocols that involved applicant file review. The State will further ensure that such updated protocols and procedures are memorialized in the Programs? transaction processing memo during its Q1 2023 update, including any protocols necessary to ensure timely issuance of any required management decisions relative to the subrecipient. Contact Person: Chase Hagaman, Lisa Cota-Robles, and Michele Zangri-Crean
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