Corrective Action Plans

ALN Number 17.258, 17.259, 17.278 ? Workforce Innovation and Opportunity Act 2022-023 ? Strengthen Controls to Ensure Compliance with Subrecipient Monitoring Requirements. Cat ? M, Finding Type, A, C1 (MW, MNC) MDES Response: The Mississippi Department of Employment Security concurs in principle with the three conditions noted in the finding. During and prior to this audit, MDES enacted new procedures to address the concerns noted in this finding. MDES renewed its commitment to ensuring that subrecipients are qualified to receive funds. MDES contracted with Booth Management Consultants and more recently Trace Advisory Group to ensure compliance with all DOL monitoring requirements, including on-site monitoring and through other modes. Also, we started implementing a risk-based assessment tool to ensure the performance of a thorough qualification assessment on all grantees. Corrective Action Plan: A. The Offices of Grant Management and Business Management will develop a plan to document our assessment of the subrecipients? awareness of audit requirements at 2 CFR 200.332(f). MDES will start implementing the plan detailed below on or before October 31, 2023. This plan involves the following: 1) Perform a pre-award risk assessment to determine risk for awarding grant and the level of monitoring required during program; 2) Issue a standardized audit requirement letter or agreed upon procedures to all subgrantees to remind them of grant requirements; 3) Receipt of required federal single audit from subgrantees expending more than $750,000 in federal funds from all sources OR receipt of a statement that the entity did not meet this threshold; 4) Document the review and assessment of the audits received for findings or questioned costs using tools, such as the templates found in the DOL Core Monitoring Guide; and 5) Document all required agency action necessary to mitigate the risks identified in the audits. B. COVID-19 caused extensive travel and in-person meeting restrictions nationwide. MDES did not restrict travel or virtual meetings. As contact guidelines fluctuated, the on-site monitoring team had discretion regarding the method to conduct this process. Also during this time, DOL staff observed similar contact restrictions, which limited federal monitoring of MDES. Such challenges and restrictions no longer exist. MDES will perform on-site and remote monitoring, as required. Where possible, MDES intends to conduct future monitoring on-site. MDES management will also hold regular meetings with the subrecipients to monitor progress and to ensure questions related to grant expenditures receive timely responses. C. Although the agency did not perform a risk-based assessment in the year reviewed by the auditors (PY21), MDES did incorporate the Risk Assessment Tool, Tool S from the U. S. Department of Labor?s Core Monitoring Guide, into its review of subgrantees for PY 2022. MDES will continue to ensure the performance of a thorough risk-based assessment on all grantees.

Contact person(s) responsible: Executive Director Vanessa Timmons; Associate Director Keri Moran Kuhn; Accounting Manager Linda Koonce. Corrective action planned: OCADSV added an Administrative Cost Center to its General Ledger effective 10-01-22, the beginning of FY23, and began costing administrative payroll costs to that cost center. Additionally, the organization re-trained administrative staff on direct cost-allowable activities vs. administrative activities relative to timekeeping and timesheet preparation and the necessity of daily work descriptions supporting the hourly allocation. The Payroll policy that requires supervisors to review and sign off on timesheets and hourly allocations to cost centers was also reviewed. Audit Costs for FY22 will be allocated in accordance with 2 CFR 200.405 requirements. Beginning with FY23, all accounting and other admin payroll-related costs will be costed to the administration cost center with the exception of time spent in activities related to a specific grant or other cost centers. FY22 Grants expenditures were reviewed post year-end, and a line-by-line review was conducted to bring the direct and indirect expense cumulative total into compliance with audit findings. Any outstanding reports were adjusted to reflect the adjusted Life of Grant to the current date reporting. Executive, Financial, and Grant Management staff will, during FY24, complete the Online Grants Financial Management Training available at onlinegfmt.training.ojp.gov to improve knowledge and compliance with 2 CFR 200 guidance and requirements. The said training will be incorporated into onboarding processes for any newly hired employees who have direct responsibilities related to Grant management and/or reporting. Said training requirements will be added to hire letters and work plans. Anticipated completion date: Effective 6/21/2023 and ongoing