Corrective Action Plans

Finding 13081 (2022-007)

Significant Deficiency 2022

CO

Subrecipient Monitoring § 200.303 § 200.332

2022-007 Finding: Subrecipient Monitoring - ALN 93.391 ? Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises / Department of Health and Human Services / Award Number: ENVHL-202159027 / Award Year: 2021 Status: Corrective ...

2022-007 Finding: Subrecipient Monitoring - ALN 93.391 ? Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises / Department of Health and Human Services / Award Number: ENVHL-202159027 / Award Year: 2021 Status: Corrective action in progress Corrective Action: The City agrees with the finding. DDPHE will consult with the City?s Federal Grants Manager, other agencies that typically have subrecipients for federal awards, and the City Attorney?s Office to review the current standard contract provisions to ensure they cover all required provisions and will modify those provisions accordingly. Person(s) Responsible for Implementing: DDPHE ? Paige Cheney Implementation Date: October 2023

View Audit 17407

Finding 13073 (2022-012)

Material Weakness 2022

City and County of Denver

CO

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.303

2022-012 Finding: Procurement and Suspension and Debarment - ALN 21.027 - Coronavirus State and Local Fiscal Recovery Funds / Department of the Treasury / Award Number: N/A / Award Year: 2020 ALN 93.391 - Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to...

2022-012 Finding: Procurement and Suspension and Debarment - ALN 21.027 - Coronavirus State and Local Fiscal Recovery Funds / Department of the Treasury / Award Number: N/A / Award Year: 2020 ALN 93.391 - Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises / Department of Health and Human Services / Award Number: ENVHL-202159027 / Award Year: 2021 Status: Corrective action in progress Corrective Action: 21.027 - The City agrees with the finding and will continue to make the necessary improvements to ensure that all vendors are appropriately verified on SAM.gov and documented in our system of record. The City will also continue to provides periodic training to ensure that the agencies are aware of all grant administration standards required by the City. 93.391 - DDPHE completed SAM.gov searches initially for the vendors however did not document the search. SAM.gov verification been documented in prior audits and as of January 1, 2023 we have implemented this step into our policies and procedures moving forward. Person(s) Responsible for Implementing: 21.027 DOF ? Dan Fetcher, 93.391 DDPHE - Paige Cheney Implementation Date: 21.027 - August 2023, 93.391 - August 2023

View Audit 17407

Finding 13071 (2022-013)

Significant Deficiency 2022

City and County of Denver

CO

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

2022-013 Finding: Activities Allowed and Unallowed, Allowable Costs - ALN 21.023 ? Emergency Rental Assistance Program / Department of the Treasury / Award Number: ERAE0437; ERAE0436 / Award Year: 2021 Status: Corrective action complete Corrective Action: The City agrees with the finding and have im...

2022-013 Finding: Activities Allowed and Unallowed, Allowable Costs - ALN 21.023 ? Emergency Rental Assistance Program / Department of the Treasury / Award Number: ERAE0437; ERAE0436 / Award Year: 2021 Status: Corrective action complete Corrective Action: The City agrees with the finding and have implemented procedures ensure that all timecards for individuals charging time and effort to the program be subjected to review prior to payroll being processed. Due to mitigating circumstances beyond HOST?s control, the City was not able to utilize the electronic timekeeping system due to a global Kronos ransomware attack. During the outage the City was limited to a web-based timesheet that unfortunately did not ensure supervisor approval. The City was eventually able to begin the process of restoring Kronos in June/July 2022. We have now transitioned to tracking time and effort in Workday beginning August 1, 2023 that requires allocations for employees charging to grants, and supervisor review and approval. Person(s) Responsible for Implementing: HOST ? Melissa Thate Implementation Date: Complete

View Audit 17407

Finding 13070 (2022-011)

Significant Deficiency 2022

City and County of Denver

CO

Subrecipient Monitoring Allowable Costs / Cost Principles Reporting § 200.303

2022-011 Finding: Reporting - ALN 21.023 ? Emergency Rental Assistance Program / Department of the Treasury / Award Number: ERAE0436, ERAE0437/Award Year: 2021 Status: Corrective action in progress Corrective Action: The City agrees with the finding and has established a reporting checklist. The che...

2022-011 Finding: Reporting - ALN 21.023 ? Emergency Rental Assistance Program / Department of the Treasury / Award Number: ERAE0436, ERAE0437/Award Year: 2021 Status: Corrective action in progress Corrective Action: The City agrees with the finding and has established a reporting checklist. The checklist includes saving supporting documentation for all numbers submitted on reports, a final supervisor review of supporting documentation and report numbers, and an email approval with evidence of the review of documentation supporting the numbers being submitted in reports. Likewise, the Grant Administrator Policies & Procedures outlines the internal controls outlined in 2 CFR Section 200.303 that supports a continuous built-in component of operations and a system of fiscal reviews. Grant Administrator Policies & Procedures, Reporting Purpose Statement: Grants awarded to HOST may require that progress, programmatic and financial reports be submitted to the grantor. Accurate and timely reporting is critical to maintaining a good relationship with the grantor. Late or inaccurate reports may negatively impact current or future funding. Grant Reporting Policy: ** HOST will prepare timely and accurate financial or programmatic reports as required by grantor. ** The Financial Services Unit shall submit all financial reports, grant budget adjustments, and reimbursement requests to the grantor. ** All copies of submitted reports will be maintained in a master file. ** For internal control purposes, all reports shall be prepared by the appropriate staff, then submitted for approval after review from a manager or supervisor for content, accuracy, and revise as appropriate. ** Copies of all financial status and final reports prepared for submission to the grantor shall be provided, along with the associated grant name and year to the Office of Grant Administration at the time of submission to the grantor. Person(s) Responsible for Implementing: HOST - Housing Stability and Homelessness Resolution Division Directors Implementation Date: August 31, 2023

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Finding 13060 (2022-014)

Significant Deficiency 2022

City and County of Denver

CO

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

2022-014 Finding: Reporting - ALN 14.241 ? Housing Opportunities for Persons with AIDS / Department of Housing and Urban Development / Award Number: COH20-FHW001; COH21-F001; COH20-F001 / Award Year: 2020; 2021 Status: Corrective action in progress Corrective Action: The City agrees with the finding...

2022-014 Finding: Reporting - ALN 14.241 ? Housing Opportunities for Persons with AIDS / Department of Housing and Urban Development / Award Number: COH20-FHW001; COH21-F001; COH20-F001 / Award Year: 2020; 2021 Status: Corrective action in progress Corrective Action: The City agrees with the finding, and we have implemented procedures to ensure submissions of FFATA reports are reviewed. Due to mitigating circumstances beyond HOST?s control, the issuance of a federal Unique Entity Identifier (UEI) was significantly delayed. HOST was able to obtain its Unique Entity Identifier (UEI) on September 14, 2022. Reports are current through FY2022, and proof of the submissions were provided to BDO on July 29, 2023 in response to this finding. This matter has been remediated going forward, however, per the assessment, this issue is a carryover into 2022 sub-awards based on the contract timeframes. Person(s) Responsible for Implementing: HOST Operations Division Directors Implementation Date: July 2023

View Audit 17407

Finding 13058 (2022-016)

Significant Deficiency 2022

City and County of Denver

CO

Matching / Level of Effort / Earmarking HUD Housing Programs Reporting § 200.302 § 200.303

2022-016 Finding: Program Income - ALN 14.239 ? Home Investment Partnerships Program / Department of Housing and Urban Development / Award Number: M22-MC080204 / Award Year: 2022 Status: Corrective action in progress Corrective Action: The City agrees with the finding as this was a simple oversight ...

2022-016 Finding: Program Income - ALN 14.239 ? Home Investment Partnerships Program / Department of Housing and Urban Development / Award Number: M22-MC080204 / Award Year: 2022 Status: Corrective action in progress Corrective Action: The City agrees with the finding as this was a simple oversight for the finance team due to the extreme staff shortages we?ve encountered over the last year. HOST has a process of reviewing and approving program income in Workday and associated grantor entries. We are filling vacancies to support the general ledger transactions and currently onboarding a new staff accountant to support this effort. Del Norte Loan # 34-36-01 had cash flow in 2021, and a subsequent payment due in 2022. An interest payment of $48,500 was completed credited correctly. The interest was booked in the General Ledger (GL) under HOME/GR2437 instead of NSP2/GR98, causing the NR to be inaccurately overstated in HOME/GR2437 and understated NSP2/GR98. This has been remediated going forward by practicing a process of reconciling each fund with each revenue category. Person(s) Responsible for Implementing: HOST ? Ami Webb Implementation Date: August 2023

View Audit 17407

Finding 13053 (2022-015)

Significant Deficiency 2022

City and County of Denver

CO

Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.303

2022-015 Finding: Activities Allowed or Unallowed, Allowable Costs - ALN 93.778 ? Medicaid Cluster / ALN 93.659 ? Adoption Assistance Program / ALN 93.563 ? Child Support Enforcement / ALN 93.090 ? Guardianship Assistance (Non-Major) / ALN 93.658 ? Foster Care Title IV-E / ALN 10.551/10.561 ? Supple...

2022-015 Finding: Activities Allowed or Unallowed, Allowable Costs - ALN 93.778 ? Medicaid Cluster / ALN 93.659 ? Adoption Assistance Program / ALN 93.563 ? Child Support Enforcement / ALN 93.090 ? Guardianship Assistance (Non-Major) / ALN 93.658 ? Foster Care Title IV-E / ALN 10.551/10.561 ? Supplemental Nutrition Assistance Program (SNAP Cluster) / Department of Health and Human Services and Department of Agriculture / Award Number: N/A / Award Year: 2022 Status: Corrective action in progress Corrective Action: The City agrees with the finding. After a lot of back and forth and research we have determined that the City?s Central Services Cost Allocation Plan should be submitted to the FAA. This was submitted to the Airport for submission to the FAA on June 16, 2023. We have been unable to obtain acknowledgement of receipt. The FY22 City?s Central Services Cost Allocation Plan was submitted to the FAA on September 1, 2023. Person(s) Responsible for Implementing: Jessica Chandler, Rachel Bardin - Department of Finance Implementation Date: September 2023

View Audit 17407

Finding 13052 (2022-010)

Significant Deficiency 2022

City and County of Denver

CO

Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.303

2022-010 Finding: Activities Allowed and Unallowed, Allowable Costs - / ALN 93.778 ? Medicaid Cluster, ALN 93.659 ? Adoption Assistance Program, ALN 93.563 ? Child Support Enforcement, ALN 93.558 ? Temporary Assistance for Needy Families, ALN 93.658 ? Foster Care Title IV-E, ALN 93.667 ? Social Serv...

2022-010 Finding: Activities Allowed and Unallowed, Allowable Costs - / ALN 93.778 ? Medicaid Cluster, ALN 93.659 ? Adoption Assistance Program, ALN 93.563 ? Child Support Enforcement, ALN 93.558 ? Temporary Assistance for Needy Families, ALN 93.658 ? Foster Care Title IV-E, ALN 93.667 ? Social Services Block Grant, ALN 10.551/10.561 ? Supplemental Nutrition Assistance Program (SNAP) Cluster / Department of Health and Human Services and Department of Agriculture / Award Number: N/A / Award Year: 2022 Status: Corrective action in progress Corrective Action: The City agrees with the finding. The City and County of Denver is in the process of switching from Kronos to Workday to track employee time and attendance. As part of this change, DHS will provide updated guidance to department employees who split their time between programs and those employees? supervisors, including reminding them of the requirement that timecards be approved by supervisors each pay period. DHS will conduct internal audits to verify compliance with this requirement. Person(s) Responsible for Implementing: DHS ? Robert Baker Implementation Date: October 31, 2023

View Audit 17407

Finding 13047 (2022-008)

Significant Deficiency 2022

City and County of Denver

CO

Procurement, Suspension & Debarment § 200.303

2022-008 Finding: Procurement, Suspension and Debarment ? ALN 14.231 ? Emergency Solutions Grant Program / Department of Housing and Urban Development / Award Number: E-21-MC-08-005, E-20-MC-08-0005/E-20-MW-08-0005 / Award Years: 2020, 2021 Status: Corrective action in progress Corrective Action: Th...

2022-008 Finding: Procurement, Suspension and Debarment ? ALN 14.231 ? Emergency Solutions Grant Program / Department of Housing and Urban Development / Award Number: E-21-MC-08-005, E-20-MC-08-0005/E-20-MW-08-0005 / Award Years: 2020, 2021 Status: Corrective action in progress Corrective Action: The City agrees with the finding. However, based on when the finding was identified, there was insufficient time to address the finding prior to December 31, 2022.To remediate prior finding 2021-011, HOST updated the agency?s Contract & Performance Management Policies under Section VII. Procedure Process Map, Step 1 to include the requirement to verify Suspension and Debarment for all subgrantees utilizing federal funding. This policy was modified and completed in July 2023, and a copy of this was provided to BDO on August 16, 2023, in response to the finding. Per the assessment this issue is a carryover into 2022 sub-awards based on the contract timeframes. Person(s) Responsible for Implementing: HOST ? Jon Luper Implementation Date: July 2023

View Audit 17407

Finding 13046 (2022-009)

Material Weakness 2022

City and County of Denver

CO

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

2022-009 Finding: Matching - ALN 14.231 ? Emergency Solutions Grant Program / Department of Housing and Urban Development / Award Number: E-20-MC-08-0005 / Award Year: 2020 Status: Corrective action complete Corrective Action: The City disagrees with the finding. To remediate prior finding 2021-009,...

2022-009 Finding: Matching - ALN 14.231 ? Emergency Solutions Grant Program / Department of Housing and Urban Development / Award Number: E-20-MC-08-0005 / Award Year: 2020 Status: Corrective action complete Corrective Action: The City disagrees with the finding. To remediate prior finding 2021-009, HOST and HUD Technical Assistance provider, HomeBase, created an ESG Match Guide and Reporting template and training for sub-grantees utilizing ESG funds that incorporate regulations contained within 24 CFR 576.201. HomeBase and HOST conducted a match training on July 22, 2022 with subrecipients that received funding under E-20-MC-08-0005. Documentation of the July 2022 training and copies of the ESG Match Guide were provided to BDO on August 25, 2023 as requested. The ESG Match Guide outlines the ESG Match Documentation and Timing Requirements for Cash and In-Kind Match (this includes non-cash, i.e., Property, Goods, and Equipment). HOST is executing Commitment Letters and/or Memorandums of Understanding (MOU) as required prior to executing grant contracts with subrecipients. Commitment Letters for cash match must contain: ** Amount of cash to be provided to the recipient for the project ** Specific date the cash will be made available ** The actual grant and fiscal year to which the cash match will be contributed ** Time period during which funding will be available ** Allowable activities to be funded by the cash match MOU?s for in-kind match must contain: 1. Value of donated goods to be provided to the recipient for the project 2. Specific date the goods will be made available 3. The actual grant and fiscal year to which the match will be contributed 4. Time period during which the donation will be available 5. Allowable activities to be provided by the donation 6. Value of commitments of land, buildings, and equipment ? the value of these items is one-time only and cannot be claimed by more than one project or by the same project in another year The ESG Match Report includes pertinent project information (i.e., project, HOST contract number, grant amount, the project term date, match required for the grant, match being reported and reported to date (prior cumulative). The cash match documentation required with each report submission is: ** Documentation of cash source ** Expenditure documentation that demonstrates: ** Timing of expenditure ** Shows that expenses were incurred for eligible activities This may include general ledger and other similar documentation. The in-kind match documentation required with each report submission is: ** Documentation of contribution (including time and description) ** Documentation of the valuation of the contribution ** Documentation that contribution supported eligible activities ** Documentation of service hours provided (this should be a detailed record that shows dates, hours, activities, etc.) This may include copies of employee timesheets/paychecks and other similar documentation. The report must be certified via signature with the authorized signatory. The documentation and certification requirements contained in HOST?s ESG Match Guide and ESG Match Report meet all requirements necessary including those outlined in CPD Monitoring Exhibits 28-7 (Guide for Review of ESG Match Requirements), and as applicable 28-8 (Guide for Review of ESG Financial Management and Cost Allowability), 34-1 (Guide for Review of Financial Management and Audits), and 34-2 (Guide for Review of Cost Allowability). Likewise, match requirements are reflected in HOST contractual agreements as standard language. The agreement language outlines match report submissions, and documentation and records maintenance requirements. Program Officers in HOST?s Division of Housing Stability and Homelessness Resolution (HSHR) now ensures that contractor?s submit match reports with supporting documentation and certifications as outlined in the executed agreements and per the policy guide. Person(s) Responsible for Implementing: HOST - Housing Stability and Homelessness Resolution Division Directors Implementation Date: Complete

View Audit 17407

Finding 13045 (2022-006)

Material Weakness 2022

City and County of Denver

CO

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

2022-006 Finding: Special Tests and Provisions ? Obligation, Expenditure and Payment Requirements - ALN 14.231 ? Emergency Solutions Grant Program / Department of Housing and Urban Development / Award Number: E-21-MC-08-0005, E-20-MC-08-0005/E-20-MW-08-0005 / Award Years: 2020, 2021 Status: Correcti...

2022-006 Finding: Special Tests and Provisions ? Obligation, Expenditure and Payment Requirements - ALN 14.231 ? Emergency Solutions Grant Program / Department of Housing and Urban Development / Award Number: E-21-MC-08-0005, E-20-MC-08-0005/E-20-MW-08-0005 / Award Years: 2020, 2021 Status: Corrective action in progress Corrective Action: The City agrees with the finding. HOST makes every effort to comply with not only federal requirements but also City Charter requirements for timely payment. Occasionally there are exceptional circumstances where there is a need to update the City financial system Workday, for budget modifications or the like that could result in a delay of payment. In an effort to determine these items ahead of time we?ve updated our internal policies to require finance budget review prior to contract execution. Likewise, HOST is engaged in an application upgrade with Salesforce which is in the final User Acceptance Testing (UAT) phase to incorporate changes that now include status tracking for vendor invoice submissions and reimbursement payments. This will support a more comprehensive and accurate accounting of any legitimate postponed payments due to waiting on more required information from vendors, budget modifications, contract amendments, etc. Person(s) Responsible for Implementing: HOST Operations Division Directors Implementation Date: Q1-2024

View Audit 17407

Finding 13044 (2022-005)

Material Weakness 2022

City and County of Denver

CO

Procurement, Suspension & Debarment Subrecipient Monitoring Allowable Costs / Cost Principles § 200.303

2022-005 Finding: Special Tests and Provisions ? Obligation, Expenditure and Payment Requirements - ALN 14.231 ? Emergency Solutions Grant Program / Department of Housing and Urban Development / Award Number: E-21-MC-08-0005 / Award Year: 2021 Status: Corrective action in progress Corrective Action:...

2022-005 Finding: Special Tests and Provisions ? Obligation, Expenditure and Payment Requirements - ALN 14.231 ? Emergency Solutions Grant Program / Department of Housing and Urban Development / Award Number: E-21-MC-08-0005 / Award Year: 2021 Status: Corrective action in progress Corrective Action: The City agrees with the finding. However, based on when the finding was identified, there was insufficient time to address the finding prior to December 31, 2022. To remediate prior finding 2021-010, HOST updated the agency?s Grant Administrator Policies & Procedures, and our Contract & Performance Management Policies that now include language to ensure obligation of funding within the required deadlines. These policies were modified complete in June 2022 and July 2023. HOST?s current Notice of Funding Availability (NOFA) cycle for ESG funding will apply to subrecipient programs awarded beginning 01/01/2024, with anticipated contract executions in Q4 2023. Copies of both policies were provided to BDO on August 16, 2023, in response to the finding. This matter has been remediated, however, per the assessment this issue is a carryover into 2022 sub-awards based on the contract timeframes. Person(s) Responsible for Implementing: HOST Operations Division Directors Implementation Date: July 2023

View Audit 17407

Finding 13032 (2022-002)

Material Weakness 2022

City of Columbus

IN

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.303

FINDING 2022-002 Contact Person Responsible for Corrective Action: Luann Welmer Contact Phone Number: 812-376-2510 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Prior to entering into subawards and covered transactions with SLFRF award funds the Ci...

FINDING 2022-002 Contact Person Responsible for Corrective Action: Luann Welmer Contact Phone Number: 812-376-2510 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Prior to entering into subawards and covered transactions with SLFRF award funds the City will verify contractors and subrecipients are not suspended, debarred or otherwise excluded. Anticipated Completion Date: The action plan will take place immediately.

View Audit 17100

Finding 13021 (2022-001)

Material Weakness 2022

Ripley County

IN

Procurement, Suspension & Debarment Subrecipient Monitoring Matching / Level of Effort / Earmarking § 200.214 § 200.303 § 200.317 § 200.318 § 200.327

FINDING 2022-001 Contact Person Responsible for Corrective Action: Amy Copeland Contact Phone Number: (812) 689-6311 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The Ripley County Auditor, Amy Copeland, has already been in contact with the Auditor...

FINDING 2022-001 Contact Person Responsible for Corrective Action: Amy Copeland Contact Phone Number: (812) 689-6311 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The Ripley County Auditor, Amy Copeland, has already been in contact with the Auditors in the State of Indiana to help with a Procurement Policy they already have in place. This is so the Ripley County Attorney and I can work on getting Ripley County a Procurement Policy in place as soon as possible. Ripley County will also be writing a Suspension and Debarment Policy for any checks written over $25,000.00 to any subrecipient or contracts. The new polices will address procedures for procurement and suspension and debarment to ensure there is a review and approval process in place to ensure compliance. Anticipated Completion Date: 8/30/2023

View Audit 17665

Finding 12897 (2022-003)

Significant Deficiency 2022

Bartholomew Consolidated School Corporation

IN

Procurement, Suspension & Debarment § 200.303

2022-003 Child Nutrition Cluster ? Assistance Listing No. 10.553/10.555/10.559 Recommendation: Adhere to internal control procedures over the review of invoices for micro- purchases. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in ...

2022-003 Child Nutrition Cluster ? Assistance Listing No. 10.553/10.555/10.559 Recommendation: Adhere to internal control procedures over the review of invoices for micro- purchases. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: Cafe managers will initial or sign invoices upon receipt. Food Service Financial Specialist (Andrew Millspaugh) will sign off on invoices once they have been reconciled to the company statements. Food Service Personnel Coordinator (Vicki Fields) will review the invoices before sending to the business office for payment. Food Service Director (Nancy Millspaugh) will approve entries before they are sent to the business office. A form similar to the one being used for bank reconciliation will be used to verify the invoices were reconciled, reviewed and entered with approval. Name(s) of the contact person(s) responsible for corrective action: Nancy Millspaugh Planned completion date for corrective action plan: April 30, 2023

View Audit 17687

Finding 12895 (2022-002)

Material Weakness 2022

City of East Chicago

IN

Internal Control / Segregation of Duties Allowable Costs / Cost Principles Material Weakness § 200.1 § 200.303

FINDING 2022-002 Contact Person Responsible for Corrective Action: Valeriano F. Gomez / City Controller Contact Phone Number: 219-391-8300 Views of Responsible Official: We concur with the finding Description of Corrective Action Plan: Additional Internal controls to address Finding 2022-002: A.- 1....

FINDING 2022-002 Contact Person Responsible for Corrective Action: Valeriano F. Gomez / City Controller Contact Phone Number: 219-391-8300 Views of Responsible Official: We concur with the finding Description of Corrective Action Plan: Additional Internal controls to address Finding 2022-002: A.- 1. East Chicago SLFRF reporting personnel, will be expanded to include a review of Quarterly Project and Expenditure Reports by a city senior accountant. 2. All personnel will jointly review Quarterly Project & Expenditure Report when completed, before proceeding to submission in portal. 3. Review by city personnel of previous Quarterly Reports to include the initial Interim Report (SLT-4798, 8-31-21) to address issues. 4. To address possible error in reporting tier will e-mail Treasury (SLFRF@treasury.qov.) for guidance and direction. Per Project and Expenditure Report User Guide April 1, 2023. B.- 2. East Chicago SLFRF reporting personnel will include the project ledger to future SLFRF Compliance Quarter Reports to ensure accurate reporting within the proper timeline / period. Note: In addition, with further discussion, we will continue to work on finding other proposals to improve internal controls issues related to Finding 2022-002. Anticipated Completion Date: Corrective actions should be in place for next SLFRF Quarterly Report (2nd Qtr. 2023).

View Audit 17648

Finding 12894 (2022-001)

Material Weakness 2022

City of East Chicago

IN

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.303

FINDING 2022-001 Contact Person Responsible for Corrective Action: Valeriano F. Gomez / City Controller Contact Phone Number: 219-391-8300 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Internal controls to ensure compliance of the following 1 Docum...

FINDING 2022-001 Contact Person Responsible for Corrective Action: Valeriano F. Gomez / City Controller Contact Phone Number: 219-391-8300 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Internal controls to ensure compliance of the following 1 Documentation of procurement, suspension, and debarment clause compliance requirements. 2. Collection of certification from vendors and retention of documentation to show Excluded Parties List System (EPLS) was checked prior to entering into transaction. City Departments will provide in all bid packages requirements for the documentation pertaining to items l & 2 listed above; to include a required check list with items listed, The City Board of Public Works (and all awarding Boards) before awarding bids and approving contracts shall ensure all items on check list have been provided, and the discussed documentation has been entered into meeting minutes. All actions shall proceed before entering into a covered transaction. Board Attorneys shall also review city bid packages to ensure compliance of these controls. Required Documentation to be included in all check lists: 1. U.S. Gov. System for Award Management (SAM) exclusions 2. Certification from Person / Firm / Vendor pertaining to Excluded Parties List System (EPLS) or adding of clause or condition to transaction or contract. Note: In addition, with further discussion, we will continue to work on finding other proposals to improve internal controls issues related to the Finding 2022-001 Anticipated Completion Date: All Boards and Departments will be informed to include all information listed above on their June/July agendas for discussion and to carry out the requirements.

View Audit 17648

Finding 12879 (2022-005)

Material Weakness 2022

Brown County

IN

Internal Control / Segregation of Duties Allowable Costs / Cost Principles Material Weakness § 200.303

FINDING 2022-005 Julia Reeves Auditor Contact Person 812-988-5485 Contact Phone Number: Views of Responsible Official: I agree with the findings as they are listed. Description of Corrective Action Plan: The Auditors office will have a member of the subrecipient review and sign off and date that the...

FINDING 2022-005 Julia Reeves Auditor Contact Person 812-988-5485 Contact Phone Number: Views of Responsible Official: I agree with the findings as they are listed. Description of Corrective Action Plan: The Auditors office will have a member of the subrecipient review and sign off and date that the invoice was approved with allowable service, prior to coming to the auditor?s office for payment. Anticipated Completion Date: December 31, 2023

View Audit 17582

Finding 12878 (2022-004)

Material Weakness 2022

Brown County

IN

Internal Control / Segregation of Duties Allowable Costs / Cost Principles Material Weakness § 200.1 § 200.303

FINDING 2022-004 Julia Reeves Auditor Contact Person 812-988-5485 Contact Phone Number: Views of Responsible Official: I agree with the findings as they are listed. Description of Corrective Action Plan: Auditor?s office will Generate a report with a date range and keep the report on file for verifi...

FINDING 2022-004 Julia Reeves Auditor Contact Person 812-988-5485 Contact Phone Number: Views of Responsible Official: I agree with the findings as they are listed. Description of Corrective Action Plan: Auditor?s office will Generate a report with a date range and keep the report on file for verification to confirm report. The Auditor?s office will verify report before submission. Anticipated Completion Date: December 31, 2023

View Audit 17582

Finding 12877 (2022-003)

Material Weakness 2022

Brown County

IN

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.303

FINDING 2022-003 Julia Reeves Auditor Contact Person 812-988-5485 Contact Phone Number: Views of Responsible Official: I agree with the findings as they are listed. Description of Corrective Action Plan: The Auditor?s office will verify that the Contractors and Subrecipients have not been debarred o...

FINDING 2022-003 Julia Reeves Auditor Contact Person 812-988-5485 Contact Phone Number: Views of Responsible Official: I agree with the findings as they are listed. Description of Corrective Action Plan: The Auditor?s office will verify that the Contractors and Subrecipients have not been debarred on the Sam's website. Anticipated Completion Date: December 31, 2023

View Audit 17582

Finding 12873 (2022-001)

Significant Deficiency 2022

Hall County Board of Education

GA

Questioned Costs Allowable Costs / Cost Principles Procurement, Suspension & Debarment § 200.303 § 200.318 § 200.403

FA 2022-001 Improve Controls over Federal Expenditures Compliance Requirement: Activities Allowed or Unallowed Allowable Costs/Cost Principles Procurement and Suspension and Debarment Internal Control Impact: Significant Deficiency Compliance Im...

FA 2022-001 Improve Controls over Federal Expenditures Compliance Requirement: Activities Allowed or Unallowed Allowable Costs/Cost Principles Procurement and Suspension and Debarment Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education Assistance Listing Number and Title: COVID-19 - 84.4250 - Elementary and Secondary School Emergency Relief Fund COVID-19 - 84.425U - American Rescue Plan Elementary And Secondary School Emergency Relief Fund Federal Award Number: S425D210012 (Year: 2021) S45U210012 (Year: 2021) Questioned Costs: $116,610 Repeat of Prior Year Finding: None Description: The policies and procedures of the School District were insufficient to provide adequate internal controls over expenditures as it relates to the Elementary and Secondary School Emergency Relief Fund program. Corrective Action Plans: We concur with the auditor?s reasoning that the contract terms for services should have been modified to reflect the one-time retention payments for contracted custodial personnel. Retention of contracted custodial staff members was deemed by the District to be an essential part of its effort to ensure clean, sanitary facilities in response to COVID-19 pandemic. ? The District has several internal controls in place to determine and verify the allowability of ESSER expenditures, which include: ? Authorization by the Hall County Board of Education. ? Authorization by the Georgia Department of Education through the ESSER program?s consolidated application. ? Approval of all ESSER payments and purchase orders by relevant personnel familiar with the allowability requirements of the ESSER program. ? Approval of all ESSER contract agreements by relevant personnel familiar with the allowability requirement of the ESER program. ? Documented protocols for determining District personnel eligible to be paid through ESSER funds. The District will conduct a review of its contract with third party service providers to ensure compliance with Uniform Grant Guidance. The District currently has no further plans for the provision of additional retention payments to contracted personnel using ESSER funds, and no additional corrective action is anticipated to be required for the isolated instance. Estimated Completion Date: March 31, 2023 Contact Person: Jonathan C. Boykin Telephone: 770-534-1080 Email: jonathan.boykin@hallco.org

View Audit 17388 Questioned Costs: $1

Finding 12867 (2022-004)

Material Weakness 2022

Wagner Community Memorial Hospital

SD

Special Tests & Provisions Subrecipient Monitoring Cash Management § 200.303

Finding 2022-004 Federal Agency Name: Department of Health and Human Services Federal Financial Assistance Listing/CFDA #10.766 Program Name: Communities Facilities Loans and Grants Cluster Compliance Requirement: Special Tests - Set aside of a reserve amount backed by the full faith and credit of t...

Finding 2022-004 Federal Agency Name: Department of Health and Human Services Federal Financial Assistance Listing/CFDA #10.766 Program Name: Communities Facilities Loans and Grants Cluster Compliance Requirement: Special Tests - Set aside of a reserve amount backed by the full faith and credit of the United States Finding Summary: Management maintained a reserve account in a pooled investment fund which includes marketable securities backed by the full faith and credit of the United States, but based on the portfolio mix of the investment pool, was not adequate to cover the entire reserve requirement. In addition, we had not established a separate bookkeeping account and/or a separate bank account. Responsible Individuals: Bryan Slaba, Chief Executive Officer Corrective Action Plan: A separate savings account backed by the full faith and credit of the United States and bookkeeping account will be established. Anticipated Completion Date: 12/31/2022

View Audit 17145

Finding 12771 (2022-004)

Significant Deficiency 2022

Charles County Public Schools

MD

Allowable Costs / Cost Principles Subrecipient Monitoring Period of Performance § 200.303 § 200.308 § 200.309 § 200.403

U.S. Department of Education 2022-004 Special Education Cluster ? Assistance Listing No. 84.027 and 84.173 Recommendation: The Board should review and enhance internal controls and procedures to ensure that it charges expenditures to the program that are incurred within an award?s allowable period o...

U.S. Department of Education 2022-004 Special Education Cluster ? Assistance Listing No. 84.027 and 84.173 Recommendation: The Board should review and enhance internal controls and procedures to ensure that it charges expenditures to the program that are incurred within an award?s allowable period of performance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Office of Fiscal Services will improve internal controls over the procedures that ensure expenditures to a program are incurred within an award?s allowable period of performance. During the year-end close out process, the Lead Restricted Funds Accountant will review the close out of all restricted funds against the grant periods. If expenditures are inadvertently incurred outside of the grant period, the expenditures will be reclassified to an existing like grant if allowable or to the operating budget. If the Lead Restricted Funds Accountant is unavailable or has closed out grants themselves, this review will be done by the Budget Manager. The school district will implement a new financial system in July 2023. The implementation of this new system will allow for more automated internal controls. Name(s) of the contact person(s) responsible for corrective action: Rosa Aquino and/or Sherri Fisher-Davis Planned completion date for corrective action plan: December 31, 2022

View Audit 17731

Finding 12728 (2022-002)

Significant Deficiency 2022

Hot Springs County

WY

Reporting Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.302 § 200.303

Audit Finding 2022-002 Finding Lack of Written Policies and Procedures over Federal Awards ALN Number 21.027 ALN Name Coronavirus State & Local Fiscal Recovery Funds Questioned Costs $0 County Response Concur Status Corrective action plan in progress Corrective Action Plan In response to the finding...

Audit Finding 2022-002 Finding Lack of Written Policies and Procedures over Federal Awards ALN Number 21.027 ALN Name Coronavirus State & Local Fiscal Recovery Funds Questioned Costs $0 County Response Concur Status Corrective action plan in progress Corrective Action Plan In response to the finding, the County is in the process of developing written policies and procedures relative to internal controls over federal awards, to help achieve: - County wide consistency over compliance regulations and standards - Decrease the risk of grant agreement noncompliance - Reduce the risk of undetected errors in processing of financial transactions relative to federal awards. Steps taken include: - Familiarization of requirements in 2 CFR 200.303 - Obtain draft examples of policies and procedures adopted by other Counties - Discussion with governance and county attorney regarding development and adoption of policies and procedures In addition, the County is continuing to suggest departments implement effective internal control structures to - Protect assets against theft and waste - Ensure accurate and reliable operating and accounting data The conditions noted in this finding were previously reported in finding 2021-002 Completion Date Estimated June 2023 - policy written, approved by Commissioners, and disseminated ot departments Training - ongoing County Contact Becky Kersten, County Clerk

View Audit 17708

Finding 12722 (2022-001)

Material Weakness 2022

Legacy Health

OR

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

Finding 2022-001 Federal program: Provider Relief Fund Assistance Listing Number 93.498 Statement of Condition For 2 of 40 samples of expenditures, the expenditure claimed represented an amount that was claimed twice by the Company in their expenditures reporting in the Provider Relief Fund porta...

Finding 2022-001 Federal program: Provider Relief Fund Assistance Listing Number 93.498 Statement of Condition For 2 of 40 samples of expenditures, the expenditure claimed represented an amount that was claimed twice by the Company in their expenditures reporting in the Provider Relief Fund portal. Additionally, Legacy claimed expenses that were duplicated within the reporting portal. The general distribution report for Legacy Health for Period 1 shows $35,760,843 in expenses applied against the PRF funds in the PRF portal report for Legacy as a consolidated entity. Separately, the stand-alone reports for targeted funds received by Emanuel Hospital & Health Center for Period 1, Legacy Silverton Medical Center for Period 1, Legacy Clinics, LLC for Period 1, and Legacy Meridian Park Hospital for Period 2 also include expenses totaling $12,291,293 that are included in the $35,760,843 listed in the consolidated report above. This results in duplicate reporting of the same expenditures. During testing over reporting and allowability it was observed that the lost revenues attributable to Coronavirus were reported in both the parent entity?s PRF reports on the general distribution payments and the subsidiary entities? PRF reports on the targeted distribution payments (i.e., lost revenues were duplicated). Lost revenues shown on the subsidiary reports as available to be applied against PRF that related to lost revenues also reported in the parent entity?s report were related to Emanuel Hospital & Health Center for Period 1 in the amount of $27,106,110 and Legacy Silverton Medical Center for Period 1 in the amount of $10,269,349. Actions Taken and Status As noted within the portal filing summary, for reporting period 1, Legacy consolidated COVID-19 expenses ($35,760,843) plus lost revenue ($150,037,450) totaled $185,798,293. Payments from the PRF totaled $89,818,954. As a result, there were sufficient qualifying lost revenues to receive and earn all PRF funds received, regardless of the questioned costs above. Therefore, management believes no repayment of PRF funds received would be required. Further, management considered the finding. Reporting for the Legacy parent reporting entity was based on the ?Post-Payment Notice of Reporting Requirements (6/11/21)?, which includes the following requirement: ?Reporting entities will submit consolidated reports.? Neither the methodology utilized by Legacy or application of the methodology advocated by KPMG result in repayment of any of the funds received from the PRF. Management is implementing a process to identify and resolve situations in which reporting requirements are inconclusive, in conflict, or ambiguous. Outside subject matter expertise will be accessed as needed. Person responsible for the implementation of the corrective action plan: Tom Haywood Legacy Health 1919 NW Lovejoy St Portland OR 97219 503-415-5793 thaywood@lhs.org

View Audit 17558 Questioned Costs: $1

Corrective Action Plans

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