Corrective Action Plans

Finding 559045 (2024-006)

Material Weakness 2024

Knox College

IL

Student Financial Aid Subrecipient Monitoring Equipment & Real Property Management § 200.303

Identifying Number: 2024-006 Finding: Graham Leach Bliley Act – Student Information Security The College’s written information security program did not include the following elements required by regulation as agreed to in the PPA.  The College has performed a risk assessment utilizing internal reso...

Identifying Number: 2024-006 Finding: Graham Leach Bliley Act – Student Information Security The College’s written information security program did not include the following elements required by regulation as agreed to in the PPA.  The College has performed a risk assessment utilizing internal resources but has not based the information security program on the results of this assessment, nor has the College included all required elements of internal and external risks to the security, confidentiality or integrity of customer information. The College’s risk assessment is missing an inventory of IT systems that process and store customer information and the compliance with information security elements related to multifactor authentication, access control, change management, logging and alerting and encryption.  The College has not identified, designed or implemented safeguards for all of the risks identified in the risk assessment. The safeguards do not include the identification of security events or detection and response capabilities to support incident response.  The College has not been able to test safeguards because safeguards have not been designed or implemented in response to the risk assessment.  The College has not developed written policies and procedures to ensure that personnel are able to enact the information security program. There is a lack of evidence of leadership being required to report to the board or an appropriate supervisory council to ensure those charged with governance are informed on the current state of the information security program. The College has not developed policies and procedures to oversee information service providers Corrective Actions Taken or Planned: For the past 2 years, the College has been systematically addressing its IT and IT Security needs. These practices were updated in January 2023 and the policies have been formalized in November 2024. Person Responsible: James Stevens, jstevens@knox.edu Anticipated completion date: November 2024

View Audit 355305

Finding 559025 (2024-004)

Material Weakness 2024

Marble Valley Regional Transit District

VT

Procurement, Suspension & Debarment § 200.303 § 200.319 § 200.320

Although procurement will be handled through several manager, MVRTD will implement a procedure that All procurements will be finalized and filed with the procurement manager. MVRTD will update it procurement policy to restate the timetable for operational procurements and define the filing of the do...

Although procurement will be handled through several manager, MVRTD will implement a procedure that All procurements will be finalized and filed with the procurement manager. MVRTD will update it procurement policy to restate the timetable for operational procurements and define the filing of the documentation of each operational procurement above a specific dollar value ( to be defined).

View Audit 355288

Finding 559024 (2024-003)

Significant Deficiency 2024

Marble Valley Regional Transit District

VT

Allowable Costs / Cost Principles § 200.303 § 200.430

MVRTD is in the process of procuring and implementing software that will be managed regularly to ensure that the general ledger reflects the allocation and disbursements that will assist in reconciling the payroll costs with the grant budget. MVRTD will assign different individuals to handle payrol...

MVRTD is in the process of procuring and implementing software that will be managed regularly to ensure that the general ledger reflects the allocation and disbursements that will assist in reconciling the payroll costs with the grant budget. MVRTD will assign different individuals to handle payroll preparation, approval, and reconciliation.

View Audit 355288

Finding 559014 (2024-001)

Significant Deficiency 2024

Community Action Agency of St. Louis County, Inc.

MO

Eligibility Significant Deficiency Internal Control / Segregation of Duties § 200.303

CAASTLC acknowledges the timing discrepancy in the documentation of staff review and signature during the drive-through food pantry operations in early 2024. Although eligibility was appropriately determined prior to the distribution of food, we recognize the importance of ensuring that all related ...

CAASTLC acknowledges the timing discrepancy in the documentation of staff review and signature during the drive-through food pantry operations in early 2024. Although eligibility was appropriately determined prior to the distribution of food, we recognize the importance of ensuring that all related documentation is contemporaneously completed and appropriately approved to maintain a strong internal control environment. The current intake and eligibility verification procedures was revised to include explicit language requiring staff signatures and approval of eligibility documentation on the date of service. These updated procedures will reflect both in-office and drive-through (if resumed) operations. All relevant staff members will receive updated training on intake documentation requirements, including the importance of contemporaneous staff review and approval. Training materials will be revised to emphasize compliance with federal requirements related to eligibility documentation. While data entry into MIS may still occur post-service, staff will be required to document and date eligibility approvals on the intake fonns at the time of service. Intake forms will now include a section for immediate staff verification with date stamps to reflect real-time approval. Name of Responsible Person: Linda Huntspon, Chief Executive Officer Anticipated Completion Date: Implemented in January 31, 2025

View Audit 355262

Finding 559003 (2024-001)

Significant Deficiency 2024

Indiana Health Centers, Inc.

IN

Eligibility Subrecipient Monitoring Significant Deficiency § 200.303

SIGNIFICANT DEFICIENCIES WIC Special Supplemental Nutrition Program for Women, Infants and Children Federal Assistance Listing Numbers: 10.557 2024.001 Recommendation We recommend that management provide training for those responsible for verifying eligibility to ensure that documentation and inter...

SIGNIFICANT DEFICIENCIES WIC Special Supplemental Nutrition Program for Women, Infants and Children Federal Assistance Listing Numbers: 10.557 2024.001 Recommendation We recommend that management provide training for those responsible for verifying eligibility to ensure that documentation and internal control over eligibility is maintained. Action Taken The agency Coordinator will have a training session with each clerk in the agency on the importance of documentation and completion of assessing WIC eligibility. This re-training will include step-by-step instructions. Clerks will be instructed to add notes when needed to explain a client's eligibility, (ex. immigrants and eligibility). Demonstration will be required by each clerk to their supervisor. The re-education will be completed by the end of June 2025 and reported on a log with attendees. Ongoing monitoring will be performed by agency supervisors. They will audit five charts twice a month for each clerk/certifier. In the event, there are deficiencies identified, the supervisor will re-train the clerk/certifier at that time. 1. A folder for each clerk will be kept in a locked cabinet by the agency supervisor. It will contain a log that will consist of the clerk's name, household audited and an analysis of the eligibility that was completed at the certification. 2. Ongoing corrections if needed will be addressed by the agency supervisor or coordinator. Retraining may be requested by clerical staff at any time. If the Cognizant or Oversight Agency for Audit has questions regarding this plan, please call: Mr. Tracy Nagel, CFO at (317) 576-1335 or email to tnagel@ihcinc.org.

View Audit 355246

Finding 559000 (2024-001)

Material Weakness 2024

Allegheny County Industrial Development Authority

PA

Matching / Level of Effort / Earmarking Reporting § 200.303

Finding 2024-001: Reporting Management Response: The system to record IDA’s loan portfolio has an incorrect cash balance that has been carried forward from prior years. The cash balance is self populated within the reporting system which the Authority can’t correct. The Authority has...

Finding 2024-001: Reporting Management Response: The system to record IDA’s loan portfolio has an incorrect cash balance that has been carried forward from prior years. The cash balance is self populated within the reporting system which the Authority can’t correct. The Authority has reached out to our RLF portfolio manager at the EDA for guidance and resolution. Once corrected, we will have a separate finance team member review the reported cash balance agrees to IDA’s general ledger. Anticipated Completion Date: Immediate

View Audit 355242

Finding 558995 (2024-002)

Significant Deficiency 2024

Almost Home, Inc.

CO

Eligibility Subrecipient Monitoring Allowable Costs / Cost Principles § 200.303

After FY2024, Almost Home ceased using Temporary Assistance for Needy Families (TANF) to cover the cost of Severe Weather Activation Vouchers (SWAP) for TANF-eligible families. From this point forward, TANF will only be used for clients meeting all TANF eligibility requirements.

View Audit 355240

Finding 558965 (2024-004)

Significant Deficiency 2024

Polytechnic University of Puerto Rico, Inc.

PR

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

Monitor compliance through regular internal reviews and sample audits of personnel records.

View Audit 355176

Finding 558956 (2024-003)

Significant Deficiency 2024

Polytechnic University of Puerto Rico, Inc.

PR

Cash Management Internal Control / Segregation of Duties Procurement, Suspension & Debarment § 200.303

Add a new staff member to the Federal Funds Office to strengthen segregation of duties. Update and document internal procedures to ensure proper role separation in the drawdown process. Leverage the upcoming implementation of a new ERP system to support workflow automation and enforce segregation. C...

Add a new staff member to the Federal Funds Office to strengthen segregation of duties. Update and document internal procedures to ensure proper role separation in the drawdown process. Leverage the upcoming implementation of a new ERP system to support workflow automation and enforce segregation. Conduct training to clarify and reinforce individual roles and responsibilities. Introduce periodic internal reviews to verify compliance with segregation protocols.

View Audit 355176

Finding 558746 (2024-059)

Material Weakness 2024

State of Washington C/o Office of Financial Management

WA

Matching / Level of Effort / Earmarking Subrecipient Monitoring Allowable Costs / Cost Principles § 200.303 § 200.403 § 200.410 § 200.53

Finding: The Department of Children, Youth, and Families did not have adequate internal controls over and did not comply with financial reporting requirements for the Child Care and Development Fund Cluster. Questioned Costs: Assistance Listing # 93.575 93.575 COVID-19 93.596 Amount $0 Sta...

Finding: The Department of Children, Youth, and Families did not have adequate internal controls over and did not comply with financial reporting requirements for the Child Care and Development Fund Cluster. Questioned Costs: Assistance Listing # 93.575 93.575 COVID-19 93.596 Amount $0 Status: Corrective action in progress Corrective Action: The Child Care and Development Fund (CCDF) program was previously managed by the Department of Social and Health Services and the Department of Early Learning. Since the program transitioned in 2019, the Department has been making efforts to strengthen internal controls over payments to child care providers and other CCDF grant requirements. The Department implemented grant-level management of all federal funds, including the CCDF grant. The Department allocated the CCDF grant to eligible clients and allowable activities in compliance with 45 CFR 98.67. As part of the audit resolution process, the Department of Health and Human Services (HHS), Administration for Children & Families (ACF), which oversees the CCDF program at the federal level, reviews all the State Auditor’s Office (SAO) findings and issues management decision letters. The Department received a management decision letter dated October 3, 2023, from HHS for finding 2021-033 (2020-038) where ACF did not sustain the disallowance of questioned costs for prior findings and stated: “Although the Department’s internal controls were lacking, the ACF has not identified any funds that were expended on ineligible activities.” The ACF recommended: “…that the Department work with the auditors to determine an appropriate methodology that can be tested to ensure child care payments comply with Federal regulations.” The SAO has taken issue in the past several audits and maintained that the program is not auditable without child-level data. The Department is committed to collaborating with SAO to determine an appropriate methodology that identifies a sampling unit for accurately testing compliance. During the audit period, the Department did not have the staff and resources to develop and maintain the business process redesign, as well as the information technology initiatives necessary to meet the level of assurance as recommended by the SAO. In response to the auditor’s recommendations, the Department submitted a budget request for the 2024 supplemental budget. The enacted budget included funding to implement the Department’s budget request beginning in state fiscal year 2025, specifically: “Funding in this subsection must be expended with internal controls that provide child-level detail for all transactions, beginning July 1, 2024.” The Department is working with a developer to assist with building out the required databases between the Social Service Payment System and the Agency Financial Reporting System to allow transfers between funding sources to include child-level data related to the expenditures. The Department looks forward to working with SAO to resolve the child-level data concerns in the audit of the CCDF grant programs. The conditions noted in this finding were previously reported in findings 2023-062, 2022-044, and 2021-038. Completion Date: Estimated December 2025 Agency Contact: Stefanie Niemela Audit Liaison PO Box 40970 Olympia, WA 98504-0970 (360) 725-4402 stefanie.niemela@dcyf.wa.gov

View Audit 355165

Finding 558745 (2024-058)

Material Weakness 2024

State of Washington C/o Office of Financial Management

WA

Matching / Level of Effort / Earmarking Subrecipient Monitoring § 200.303 § 200.403 § 200.410 § 200.53

Finding: The Department of Children, Youth, and Families did not have adequate internal controls over and did not comply with period of performance requirements for the Child Care and Development Fund Cluster. Questioned Costs: Assistance Listing # 93.575 93.575 COVID-19 93.596 Amount $0 S...

Finding: The Department of Children, Youth, and Families did not have adequate internal controls over and did not comply with period of performance requirements for the Child Care and Development Fund Cluster. Questioned Costs: Assistance Listing # 93.575 93.575 COVID-19 93.596 Amount $0 Status: Corrective action in progress Corrective Action: The Child Care and Development Fund (CCDF) program was previously managed by the Department of Social and Health Services and the Department of Early Learning. Since the program transitioned in 2019, the Department has been making efforts to strengthen internal controls over payments to child care providers and other CCDF grant requirements. The Department implemented grant-level management of all federal funds, including the CCDF grant. The Department allocated the CCDF grant to eligible clients and allowable activities in compliance with 45 CFR 98.67. As part of the audit resolution process, the Department of Health and Human Services (HHS), Administration for Children & Families (ACF), which oversees the CCDF program at the federal level, reviews all the State Auditor’s Office (SAO) findings and issues management decision letters. The Department received a management decision letter dated October 3, 2023, from HHS for finding 2021-033 (2020-038) where ACF did not sustain the disallowance of questioned costs for prior findings and stated: “Although the Department’s internal controls were lacking, the ACF has not identified any funds that were expended on ineligible activities.” The ACF recommended: “…that the Department work with the auditors to determine an appropriate methodology that can be tested to ensure child care payments comply with Federal regulations.” The SAO has taken issue in the past several audits and maintained that the program is not auditable without child-level data. The Department is committed to collaborating with SAO to determine an appropriate methodology that identifies a sampling unit for accurately testing compliance. During the audit period, the Department did not have the staff and resources to develop and maintain the business process redesign, as well as the information technology initiatives necessary to meet the level of assurance as recommended by the SAO. In response to the auditor’s recommendations, the Department submitted a budget request for the 2024 supplemental budget. The enacted budget included funding to implement the Department’s budget request beginning in state fiscal year 2025, specifically: “Funding in this subsection must be expended with internal controls that provide child-level detail for all transactions, beginning July 1, 2024.” The Department is working with a developer to assist with building out the required databases between the Social Service Payment System and the Agency Financial Reporting System to allow transfers between funding sources to include child-level data related to the expenditures. The Department looks forward to working with SAO to resolve the child-level data concerns in the audit of the CCDF grant programs. The conditions noted in this finding were previously reported in findings 2023-061, 2022-043, 2021-037, and 2020-041. Completion Date: Estimated December 2025 Agency Contact: Stefanie Niemela Audit Liaison PO Box 40970 Olympia, WA 98504-0970 (360) 725-4402 stefanie.niemela@dcyf.wa.gov

View Audit 355165

Finding 558744 (2024-057)

Material Weakness 2024

State of Washington C/o Office of Financial Management

WA

Matching / Level of Effort / Earmarking Subrecipient Monitoring Allowable Costs / Cost Principles § 200.303 § 200.403 § 200.410 § 200.53

Finding: The Department of Children, Youth, and Families did not have adequate internal controls over and did not comply with matching, level of effort and earmarking requirements for the Child Care and Development Fund Cluster. Questioned Costs: Assistance Listing # 93.575 93.575 COVID-19 9...

Finding: The Department of Children, Youth, and Families did not have adequate internal controls over and did not comply with matching, level of effort and earmarking requirements for the Child Care and Development Fund Cluster. Questioned Costs: Assistance Listing # 93.575 93.575 COVID-19 93.596 Amount $0 Status: Corrective action in progress Corrective Action: The Child Care and Development Fund (CCDF) program was previously managed by the Department of Social and Health Services and the Department of Early Learning. Since the program transitioned in 2019, the Department has been making efforts to strengthen internal controls over payments to child care providers and other CCDF grant requirements. The Department implemented grant-level management of all federal funds, including the CCDF grant. The Department allocated the CCDF grant to eligible clients and allowable activities in compliance with 45 CFR 98.67. As part of the audit resolution process, the Department of Health and Human Services (HHS), Administration for Children & Families (ACF), which oversees the CCDF program at the federal level, reviews all the State Auditor’s Office (SAO) findings and issues management decision letters. The Department received a management decision letter dated October 3, 2023, from HHS for finding 2021-033 (2020-038) where ACF did not sustain the disallowance of questioned costs for prior findings and stated: “Although the Department’s internal controls were lacking, the ACF has not identified any funds that were expended on ineligible activities.” The ACF recommended: “…that the Department work with the auditors to determine an appropriate methodology that can be tested to ensure child care payments comply with Federal regulations.” The SAO has taken issue in the past several audits and maintained that the program is not auditable without child-level data. The Department is committed to collaborating with SAO to determine an appropriate methodology that identifies a sampling unit for accurately testing compliance. During the audit period, the Department did not have the staff and resources to develop and maintain the business process redesign, as well as the information technology initiatives necessary to meet the level of assurance as recommended by the SAO. In response to the auditor’s recommendations, the Department submitted a budget request for the 2024 supplemental budget. The enacted budget included funding to implement the Department’s budget request beginning in state fiscal year 2025, specifically: “Funding in this subsection must be expended with internal controls that provide child-level detail for all transactions, beginning July 1, 2024.” The Department is working with a developer to assist with building out the required databases between the Social Service Payment System and the Agency Financial Reporting System to allow transfers between funding sources to include child-level data related to the expenditures. The Department looks forward to working with SAO to resolve the child-level data concerns in the audit of the CCDF grant programs. The conditions noted in this finding were previously reported in findings 2023-060, 2022-042, 2021-036, and 2020-040. Completion Date: Estimated December 2025 Agency Contact: Stefanie Niemela Audit Liaison PO Box 40970 Olympia, WA 98504-0970 (360) 725-4402 stefanie.niemela@dcyf.wa.gov

View Audit 355165

Finding 558743 (2024-056)

Material Weakness 2024

State of Washington C/o Office of Financial Management

WA

Questioned Costs Matching / Level of Effort / Earmarking Allowable Costs / Cost Principles § 200.303 § 200.403 § 200.410 § 200.53

Finding: The Department of Children, Youth, and Families did not have adequate internal controls over and did not comply with requirements to ensure payments to child care providers for the Child Care and Development Fund Cluster programs were allowable and properly supported. Questioned Costs: ...

Finding: The Department of Children, Youth, and Families did not have adequate internal controls over and did not comply with requirements to ensure payments to child care providers for the Child Care and Development Fund Cluster programs were allowable and properly supported. Questioned Costs: Assistance Listing # 93.575 93.575 COVID-19 93.596 Amount $415,579,473 Status: Corrective action in progress Corrective Action: The Child Care and Development Fund (CCDF) program was previously managed by the Department of Social and Health Services and the Department of Early Learning. Since the program transitioned in 2019, the Department has been making efforts to strengthen internal controls over payments to child care providers and other CCDF grant requirements. The Department implemented grant-level management of all federal funds, including the CCDF grant. The Department allocated the CCDF grant to eligible clients and allowable activities in compliance with 45 CFR 98.67. As part of the audit resolution process, the Department of Health and Human Services (HHS), Administration for Children & Families (ACF), which oversees the CCDF program at the federal level, reviews all the State Auditor’s Office (SAO) findings and issues management decision letters. The Department received a management decision letter dated October 3, 2023, from HHS for finding 2021-033 (2020-038) where ACF did not sustain the disallowance of questioned costs for prior findings and stated: “Although the Department’s internal controls were lacking, the ACF has not identified any funds that were expended on ineligible activities.” The ACF recommended: “…that the Department work with the auditors to determine an appropriate methodology that can be tested to ensure child care payments comply with Federal regulations.” The SAO has taken issue in the past several audits and maintained that the program is not auditable without child-level data. The Department is committed to collaborating with SAO to determine an appropriate methodology that identifies a sampling unit for accurately testing compliance. During the audit period, the Department did not have the staff and resources to develop and maintain the business process redesign, as well as the information technology initiatives necessary to meet the level of assurance as recommended by the SAO. In response to the auditor’s recommendations, the Department submitted a budget request for the 2024 supplemental budget. The enacted budget included funding to implement the Department’s budget request beginning in state fiscal year 2025, specifically: “Funding in this subsection must be expended with internal controls that provide child-level detail for all transactions, beginning July 1, 2024.” The Department is working with a developer to assist with building out the required databases between the Social Service Payment System and the Agency Financial Reporting System to allow transfers between funding sources to include child-level data related to the expenditures. The Department looks forward to working with SAO to resolve the child-level data concerns in the audit of the CCDF grant programs. The conditions noted in this finding were previously reported in findings 2023-058, 2022-041, 2021-033, 2020-038, 2019-035, 2018-034, 2017-024, 2016-021, 2015-023, 2014-023, 2013-016, 12-28, 11-23, 10-31, 9-12, and 8-13. Completion Date: Estimated December 2025 Agency Contact: Stefanie Niemela Audit Liaison PO Box 40970 Olympia, WA 98504-0970 (360) 725-4402 stefanie.niemela@dcyf.wa.gov

View Audit 355165 Questioned Costs: $1

Finding 558481 (2024-022)

Material Weakness 2024

State of Washington C/o Office of Financial Management

WA

Subrecipient Monitoring Reporting § 200.303

Finding: The Department of Commerce did not have adequate internal controls over and did not comply with requirements to perform risk assessments for subrecipients of the Coronavirus State and Local Fiscal Recovery Funds. Questioned Costs: Assistance Listing # 21.027 COVID-19 Amount $0 Sta...

Finding: The Department of Commerce did not have adequate internal controls over and did not comply with requirements to perform risk assessments for subrecipients of the Coronavirus State and Local Fiscal Recovery Funds. Questioned Costs: Assistance Listing # 21.027 COVID-19 Amount $0 Status: Corrective action in progress Corrective Action: The Department maintains that there are effective internal controls over programs that are funded by the Coronavirus State and Local Fiscal Recovery Funds. The federal programs included in this audit had completed risk assessment procedures in compliance with federal requirements. Due to delayed audit planning and scoping, the auditors were unable to perform procedures to ascertain whether the Department established and followed internal controls to ensure compliance with program requirements. The Department plans to ensure sufficient time and resources are available for all future audits by performing the following steps: • Performing outreach to all federal programs to document internal controls for all applicable compliance requirements before the start of the next single audit cycle. • Working with the State Auditor’s Office earlier in the audit cycle to identify the audit scope for selected programs. • Providing support and guidance to programs selected for audit to ensure compliance with all internal controls and compliance requirements. To strengthen controls over performing risk assessments for subrecipients, the Department will review procedures with program staff and verify processes are followed when required. The conditions noted in this finding were previously reported in findings 2023-031 and 2022-021. Completion Date: Estimated August 2025 Agency Contact: Gena Allen, CFE Internal Control Officer PO Box 42525 Olympia, WA 98504-2525 (360) 480-5149 Gena.Allen@Commerce.wa.gov

View Audit 355165

Finding 558479 (2024-020)

Material Weakness 2024

State of Washington C/o Office of Financial Management

WA

Procurement, Suspension & Debarment Subrecipient Monitoring Reporting § 200.303

Finding: The Department of Commerce did not have adequate internal controls to ensure compliance with suspension and debarment requirements for the Coronavirus State and Local Fiscal Recovery Funds. Questioned Costs: Assistance Listing # 21.027 COVID-19 Status: Corrective action in progress...

Finding: The Department of Commerce did not have adequate internal controls to ensure compliance with suspension and debarment requirements for the Coronavirus State and Local Fiscal Recovery Funds. Questioned Costs: Assistance Listing # 21.027 COVID-19 Status: Corrective action in progress Corrective Action: The Department maintains that there are effective internal controls over programs that are funded by the Coronavirus State and Local Fiscal Recovery Funds. The Department’s contract templates include the required suspension and debarment language, which is in compliance with the federal regulations. Due to delayed audit planning and scoping, the auditors were unable to perform procedures to ascertain whether the Department established and followed internal controls to ensure compliance with program requirements. To address the internal control concerns reported, the Department plans to ensure sufficient time and resources are available for all future audits by performing the following steps: • Performing outreach to all federal programs to document internal controls for all applicable compliance requirements before the start of the next single audit cycle. • Working with the State Auditor’s Office earlier in the audit cycle to identify the audit scope for selected programs. • Providing support and guidance to programs selected for audit to ensure compliance with all internal controls and compliance requirements. Completion Date: Estimated August 2025 Agency Contact: Gena Allen, CFE Internal Control Officer PO Box 42525 Olympia, WA 98504-2525 (360) 480-5149 Gena.Allen@Commerce.wa.gov

View Audit 355165

Finding 558478 (2024-019)

Material Weakness 2024

State of Washington C/o Office of Financial Management

WA

Subrecipient Monitoring Allowable Costs / Cost Principles Reporting § 200.303

Finding: The Department of Commerce did not have adequate internal controls to ensure payments to subrecipients were allowable, properly supported and met period of performance requirements for the Coronavirus State and Local Fiscal Recovery Funds. Questioned Costs: Assistance Listing # 21.0...

Finding: The Department of Commerce did not have adequate internal controls to ensure payments to subrecipients were allowable, properly supported and met period of performance requirements for the Coronavirus State and Local Fiscal Recovery Funds. Questioned Costs: Assistance Listing # 21.027 COVID-19 Amount $0 Status: Corrective action in progress Corrective Action: The Department maintains that there are effective internal controls over programs that are funded by the Coronavirus State and Local Fiscal Recovery Funds. Due to delayed audit planning and scoping, the auditors were unable to perform procedures to ascertain whether the Department established and followed internal controls to ensure compliance with program requirements. The Department plans to ensure sufficient time and resources are available for all future audits by performing the following steps: • Performing outreach to all federal programs to document internal controls for all applicable compliance requirements before the start of the next single audit cycle. • Working with the State Auditor’s Office earlier in the audit cycle to identify the audit scope for selected programs. • Providing support and guidance to programs selected for audit to ensure compliance with all internal controls and compliance requirements. The conditions noted in this finding were previously reported in findings 2023-027, 2023-028, and 2022-019. Completion Date: Estimated August 2025 Agency Contact: Gena Allen, CFE Internal Control Officer PO Box 42525 Olympia, WA 98504-2525 (360) 480-5149 Gena.Allen@Commerce.wa.gov

View Audit 355165

Finding 558315 (2024-063)

Significant Deficiency 2024

State of Rhode Island

RI

Allowable Costs / Cost Principles Internal Control / Segregation of Duties Subrecipient Monitoring § 200.303

EOHHS amended and updated its guidelines and standard operating procedures leveraging the CMS ‘Delivering Service in School-Based Settings: A Comprehensive Guide to Medicaid Services and Administrative Claiming’ as a source document. In addition to ensuring alignment with CMS requirements, the upda...

EOHHS amended and updated its guidelines and standard operating procedures leveraging the CMS ‘Delivering Service in School-Based Settings: A Comprehensive Guide to Medicaid Services and Administrative Claiming’ as a source document. In addition to ensuring alignment with CMS requirements, the updated guidelines include a uniform schedule of quarterly submission dates and details the billing responsibilities of participating LEAs. These responsibilities include meeting all Medicaid documentation requirements; submitting the Certification of Local Funds on a quarterly basis; and signing provider agreements and maintaining all other records used to support claims submitted for Medicaid reimbursement. Upon receipt of these submissions a new audit tool will be utilized to ensure each submissions contains the required documentation. Beginning June 2025, EOHHS will initiate on-site reviews of twenty (20) LEAs using a tiered, randomized sample of claims from State Fiscal Year 2023 (SFY23). The sample will include claims with at least 20 claims per LEA, selected to ensure wide geographic representation. If documentation is missing, incomplete, or found to be in error, the LEA and their billing contractor will be notified and corrective action will be implemented. Lastly, EOHHS is also working in partnership with the CMS School-Based Services Technical Assistance Center to ensure continued alignment with federal expectations and the implementation of national best practices in school-based Medicaid claiming and update guidance. Anticipated Completion Date: Administrative Claiming Materials – June 1, 2024; On-site Audit – June 30, 2025 Contact Persons: Tyler McFeeters, Health Program Administrator, Executive Office of Health and Human Services tyler.mcfeeters@ohhs.ri.gov Mark Kraics, Deputy Medicaid Director, Executive Office of Health and Human Services mark.kraics@ohhs.ri.gov

View Audit 355126

Finding 558259 (2024-050)

Material Weakness 2024

State of Rhode Island

RI

Questioned Costs Special Tests & Provisions Subrecipient Monitoring § 200.303

System changes to modify the time schedule that RIBridges interfaces with SWICA for processing tasks has already been submitted (RIB-141767). Currently, the interface occurs twice yearly. This will increase the frequency to quarterly. Anticipated Completion Date: October 31, 2025 Contact Person:...

System changes to modify the time schedule that RIBridges interfaces with SWICA for processing tasks has already been submitted (RIB-141767). Currently, the interface occurs twice yearly. This will increase the frequency to quarterly. Anticipated Completion Date: October 31, 2025 Contact Person: Donna Rook, Administrator, Family and Adult Services, Department of Human Services donna.m.rook@dhs.ri.gov

View Audit 355126 Questioned Costs: $1

Finding 558245 (2024-045)

Material Weakness 2024

State of Rhode Island

RI

Questioned Costs Allowable Costs / Cost Principles Subrecipient Monitoring § 200.303

RIDOH agrees with the finding and recommendations and will develop and implement enhanced internal controls over Uniform Grant Spreadsheets (UGSs) to assure that all indirect cost billings and drawdowns of federal funds are appropriate and accurate. The UGS internal controls will include (but are n...

RIDOH agrees with the finding and recommendations and will develop and implement enhanced internal controls over Uniform Grant Spreadsheets (UGSs) to assure that all indirect cost billings and drawdowns of federal funds are appropriate and accurate. The UGS internal controls will include (but are not limited to): • Mandatory refresher training for all staff that complete and/or review UGSs, with focus on areas of potential errors and correct entry of UGS data in the Monthly Federal Grants Tracking spreadsheet used for drawdowns and indirect billing. • Providing a crosswalk of expenditure categories and natural accounts to grants management staff to assure appropriate and consistent assignment of transactions to categories subject to/not subject to indirect costs. • A rotating schedule of monthly in-depth reviews of UGSs to assure that data entry aligns with RIFANS transaction reports, transactions are recorded so natural accounts align with correct expenditure categories, the appropriate indirect cost rate is entered, and formulas for computation of indirect costs are not corrupted. Reviews will be conducted by supervisors of staff completing UGSs, and results will be reported to the Deputy CFO/Federal Grants Manager. • Review of the Monthly Federal Grants Tracking spreadsheets each month before indirect cost billing and federal drawdowns are completed, to assure that expenditures reported align with RIFANS reports and indirect billings and drawdown requests are appropriate. RIDOH credited the ELC Enhancing Detection federal award for the unallowable indirect costs on 3/14/2025 (J25075GMC530). The credit was calculated using RIFANS transaction data from 7/1/2020 through 3/13/2025, not from the UGSs. The UGSs for this award and others are being re-built from the start of the award using RIFANS data in new, less complicated templates to assure correct charging and reporting going forward. Anticipated Completion Date: July 31, 2025 Contact Persons: Alisha Colella, Chief Financial Officer, Department of Health alisha.colella@health.ri.gov Carla Lundquist, Deputy CFO / Federal Grants Manager, Department of Health carla.lundquist@health.ri.gov

View Audit 355126 Questioned Costs: $1

Finding 558243 (2024-043)

Significant Deficiency 2024

State of Rhode Island

RI

Subrecipient Monitoring Reporting § 200.303

2024-043a: Office of Performance Management will develop internal policies to explain how Grant reporting requirements are met and will adjust accordingly to comply with the FHWA guidance, as it becomes available. 2024-043b: Office of Performance Management will adopt a standard approval form to si...

2024-043a: Office of Performance Management will develop internal policies to explain how Grant reporting requirements are met and will adjust accordingly to comply with the FHWA guidance, as it becomes available. 2024-043b: Office of Performance Management will adopt a standard approval form to sign off on the required grant submissions. Anticipated Completion Date: December 31, 2025 Contact Person: Anastasia Wachter, Principal Economic and Policy Analyst, Department of Transportation anastasia.wachter@dot.ri.gov

View Audit 355126

Finding 558189 (2024-001)

Significant Deficiency 2024

City of Providence, Rhode Island

RI

Procurement, Suspension & Debarment § 200.303

Internal Controls over Compliance Description of Finding While the School Department has policies and procedures to ensure vendors are not suspended or debarred, the procedures were not retrospectively applied to contracts entered into before these policies were implemented. Statement of Concurre...

Internal Controls over Compliance Description of Finding While the School Department has policies and procedures to ensure vendors are not suspended or debarred, the procedures were not retrospectively applied to contracts entered into before these policies were implemented. Statement of Concurrence or Nonconcurrence Management concurs with the finding. Corrective Action The School Department will retrospectively review vendors to ensure they are not suspended or debarred, in accordance with the updated policies. Name of Contact Person John Welch Projected Completion Date 6/30/2025

View Audit 355099

Finding 558140 (2024-001)

Significant Deficiency 2024

Champaign-Urbana Mass Transit District

IL

Reporting Matching / Level of Effort / Earmarking § 200.303

We have reviewed the control procedures around preparation and review of the schedule of expenditures of federal awards (SEFA) and implemented an independent review of the assistance listing numbers (ALN) per the grant agreements in the initial review of the SEFA. The improved procedures will provid...

We have reviewed the control procedures around preparation and review of the schedule of expenditures of federal awards (SEFA) and implemented an independent review of the assistance listing numbers (ALN) per the grant agreements in the initial review of the SEFA. The improved procedures will provide the needed structure to fulfill management's responsibility to accurately report the grantor agency / pass-through grantor, assistance listing number, federal program name and number, and expenditures. Identification of major programs, utilizing the guidelines in the Office of Management and Budget's (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) are the responsibility of the auditor.

View Audit 355000

Finding 558102 (2024-005)

Significant Deficiency 2024

Florida Rural Legal Services, Inc.

AL

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

This finding is related to activities on our VOCA grants. This finding is related to Finding 2024-001. 4 invoices were not approved by management. FRLS’s AP policy that was adopted in September 2024 allowed us to skip separate management approval in cases of recurring invoices such as utilities and ...

This finding is related to activities on our VOCA grants. This finding is related to Finding 2024-001. 4 invoices were not approved by management. FRLS’s AP policy that was adopted in September 2024 allowed us to skip separate management approval in cases of recurring invoices such as utilities and in cases where we have approved contracts such as rent payments, software subscriptions etc. This was our policy before September 2024, but it was not formalized before that date. As in the case of 2024-001. FRLS will modify its AP Policy and Procedures to remove this recurring payment exception and will now require all invoices be approved by management by routing invoices to management for approvals through the Teams automated system. Invoices over $5,000 will also be required to be approved by the Executive Director or their temporary designee. Such designation must be made in writing. This change will be made within the next 60 days.

View Audit 354985

Finding 558066 (2024-001)

Significant Deficiency 2024

Smithsonian Institution

DC

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

The Smithsonian agrees with the finding. The Smithsonian would like to add that the reports were delivered to the sponsor and that the sponsor was satisfied with them. Furthermore, the sponsor has provided written acknowledgment that they were “verbally kept up to date” by the National Postal Museum...

The Smithsonian agrees with the finding. The Smithsonian would like to add that the reports were delivered to the sponsor and that the sponsor was satisfied with them. Furthermore, the sponsor has provided written acknowledgment that they were “verbally kept up to date” by the National Postal Museum (NPM) regarding this potential delay. Moving forward, NPM will strengthen senior management oversight of report delivery, review due dates more rigorously, and enhance internal controls to ensure timely submission. Any potential delays will be confirmed in writing to the sponsor ahead of the due date, and compliance updates will be provided by NPM senior management to the sponsor on a regular basis. Additionally, NPM will establish procedures to cross train staff to perform required responsibilities applicable to the NPM Project.

View Audit 354905

Finding 558043 (2024-029)

Significant Deficiency 2024

State of Georgia/state Accounting Office-Ein Noted

GA

Questioned Costs Allowable Costs / Cost Principles Period of Performance § 200.303 § 200.403 § 200.77

Federal Fund Source liquidation is monitored monthly via the Fund Source Reconciliation Report and the Provider Utilization Report. Requests to close purchase orders associated with expiring federal fund sources are submitted to OPC accordingly. The Federal Financial Reporting Group will now have th...

Federal Fund Source liquidation is monitored monthly via the Fund Source Reconciliation Report and the Provider Utilization Report. Requests to close purchase orders associated with expiring federal fund sources are submitted to OPC accordingly. The Federal Financial Reporting Group will now have the right to close purchase orders with federal fund sources to expedite this process. Also, the Provider Utilization Report has been updated with Key Performance Indicators (KPIs), Contract End Date Exceeds Period of Performance and Payments Exceed Period of Performance, that specifically address the period of performance as of December 2024.

View Audit 354902 Questioned Costs: $1

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