Corrective Action Plans

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Finding 2026-001 – Management’s Corrective Action Plan | To whom it may concern: | U.S. Department of Education | Award Year 2025-2026 | Student Financial Assistance Cluster (ALN: 84.268) | Management concurs with the finding. The student's required withdrawal for academic performance was a Universi...
Finding 2026-001 – Management’s Corrective Action Plan | To whom it may concern: | U.S. Department of Education | Award Year 2025-2026 | Student Financial Assistance Cluster (ALN: 84.268) | Management concurs with the finding. The student's required withdrawal for academic performance was a University-initiated decision that fell outside the standard withdrawal process managed by the Registrar's Office. Because the decision letter was not forwarded to the Registrar's Office at the time the student was notified, the withdrawal was not recorded in Banner or reported to NSLDS within the required 60 days. The student's status has since been corrected in NSLDS. | To prevent this from recurring, the University will require that any office issuing a student status decision, including required withdrawals for academic performance, send a copy of the decision to the Registrar's Office on the same day the student is notified. Steps are being taken to automate the notification process. The Registrar's Office will record the change in Banner so that it is included in the next Enrollment Reporting Roster submission. In addition, the Registrar's Office will compare academic standing decisions against enrollment status before each roster certification to confirm that all University-initiated withdrawals have been reported. | The anticipated completion date of June 1, 2027, reflects the implementation of the automated notification process and the completion of roster certifications under the new review procedure. | Leadership Responsible: Andy Marx, Ph.D., University Registrar, Clark University, 508-793-7426 | Anticipated Completion Date: June 1, 2027
Authority's Response and Planned Corrective Action Plan: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Public Housing Capital Fund Program to ensure that established internal control policies are being followed on a timely basis. Kinteh Darboe,...
Authority's Response and Planned Corrective Action Plan: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Public Housing Capital Fund Program to ensure that established internal control policies are being followed on a timely basis. Kinteh Darboe, Chief of Financial Operations & Management, is responsible for ensuring the deficiencies have been rectified by March 31, 2026.
Authority's Response and Planned Corrective Action Plan: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Public Housing Capital Fund Program to ensure that established internal control policies are being followed on a timely basis. Kinteh Darboe,...
Authority's Response and Planned Corrective Action Plan: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Public Housing Capital Fund Program to ensure that established internal control policies are being followed on a timely basis. Kinteh Darboe, Chief of Financial Operations & Management, is responsible for ensuring the deficiencies have been rectified by March 31, 2026.
Management agrees and will implement our recommendations.
Management agrees and will implement our recommendations.
Management will implement the corrective actions described in Findings 2025-003 and 2025-004 across all federal awards, including strengthened procedures for documenting, reviewing, and reconciling federal expenditures and reimbursement requests. Management will coordinate with the USDA Forest Servi...
Management will implement the corrective actions described in Findings 2025-003 and 2025-004 across all federal awards, including strengthened procedures for documenting, reviewing, and reconciling federal expenditures and reimbursement requests. Management will coordinate with the USDA Forest Service regarding the $62,404 in questioned costs and will follow the awarding agency's direction.
Management will implement written procedures for federal grant administration applicable to all federal awards. Reimbursement requests will be limited to costs incurred and supported by documentation at the time of the request. The reimbursement request, expenditure listing, supporting documentation...
Management will implement written procedures for federal grant administration applicable to all federal awards. Reimbursement requests will be limited to costs incurred and supported by documentation at the time of the request. The reimbursement request, expenditure listing, supporting documentation, and documented allowability review will be maintained together in a referenced file and will include preparer and reviewer sign-off. For advance payments, management will document the program's immediate cash requirements supporting the amount and timing of each advance and monitor the period between receipt and disbursement of federal funds. The reimbursement log reconciliation and Schedule of Expenditures of Federal Awards will be subject to documented review by an individual who was not involved in their preparation. Management will also coordinate with the USDA Forest Service regarding the $64,969 in questioned costs and follow the awarding agency's direction.
Golden West Humanitarian Foundation agrees with the finding and will implement written cash management procedures designed to ensure compliance with the requirements applicable to interest earned on Federal advance payments. The Foundation will establish procedures to identify Federal advance balanc...
Golden West Humanitarian Foundation agrees with the finding and will implement written cash management procedures designed to ensure compliance with the requirements applicable to interest earned on Federal advance payments. The Foundation will establish procedures to identify Federal advance balances by Federal award and applicable bank or investment account and to calculate the amount of interest earned on those balances. The calculation will be performed at least annually and more frequently when Federal advance balances are significant. As part of this process, the Foundation will determine the amount of interest earned on Federal funds that is subject to remittance after consideration of the annual amount permitted to be retained for administrative expenses. Any amount required to be remitted will be recorded as a payable at year-end and remitted to the Federal government through the applicable Federal payment system in accordance with Federal requirements. The Foundation has evaluated the interest earned on Federal advance balances during the year ended December 31, 2025 and determined the amount, required to be remitted to the Federal government. Any required liability will be recorded and amounts due will be remitted in accordance with applicable Federal requirements. Responsibility for preparing the interest calculation and related reconciliation will be assigned to Asia Johnson, Chief Compliance Officer. The calculation, related accounting entries, and evidence of any required remittance will be reviewed by and approved by an individual (or individuals) independent of the preparer.
Finding 2025-004: Noncompliance Over Activities Allowed or Unallowed/Allowable Costs/Cost Principles Name of Contact: Eileen Zaiser, Controller Corrective Action: Management will set-forth in writing its long-standing implicit policy that charges to federal awards will be disallowed without adequate...
Finding 2025-004: Noncompliance Over Activities Allowed or Unallowed/Allowable Costs/Cost Principles Name of Contact: Eileen Zaiser, Controller Corrective Action: Management will set-forth in writing its long-standing implicit policy that charges to federal awards will be disallowed without adequate documentation to support compliance with grant and regulatory requirements. Proposed Completion Date: October 1, 2026.
State of Missouri Single Audit Corrective Action Plan Year Ended June 30, 2025 State Agency: Department of Economic Development Audit Finding Number: 2025-016 – DED FFATA Reporting Name of the contact person responsible for corrective action: Christopher McCormick Anticipated completion date for cor...
State of Missouri Single Audit Corrective Action Plan Year Ended June 30, 2025 State Agency: Department of Economic Development Audit Finding Number: 2025-016 – DED FFATA Reporting Name of the contact person responsible for corrective action: Christopher McCormick Anticipated completion date for corrective action: June 30, 2026 The Department partially agrees with the auditor's findings. The Departments Corrective Action Plan below includes an explanation and specific reasons for our disagreement and any planned actions to address the finding. The Department agrees that we need to strengthen internal controls to ensure information is timely and accurately reported for the CDBG program and complete FFATA reporting in accordance with the applicable requirements. The one (1) award that was not reported as required was a clerical error and was not repeated. The Department disagrees with the findings that exceed the scope of the current audit period (July 1, 2024 – June 30, 2025). The correct audit population comprises new subawards, and amendments executed during the audit period, rather than all active subawards. The reported items were submitted before June 30, 2024, and correspond to prior award periods that are now closed. Furthermore, the Department's internal control mechanisms identified the FFATA reporting discrepancy in September 2024. The Department subsequently conducted a retrospective review and reported all outstanding amendments. Because the Department discovered and corrected the breakdown through its own internal controls, we believe the finding is inconsistent with the regulatory intent regarding systemic non-compliance. The Department maintains that FFATA does not require the reporting of deobligations or a reconciliation with USASpending.gov. Per 2 CFR §170 Appendix A, the regulatory requirement is as follows: “…the recipient must report each subaward that equals or exceeds $30,000 in Federal funds... The recipient must also report a subaward if a modification increases the Federal funding to an amount that equals or exceeds $30,000. All reported subawards should reflect the total amount of the subaward.” The Department adheres to the literal language of this regulation. The requirement specifies reporting the total amount of the subaward, rather than a "net" amount or a "remaining balance." In accounting and auditing standards, "Total," "Balance," and "Net" are distinct terms with specific applications; had the regulation intended for deobligations to be factored into the reported figure, it would have specified a "net", “balance”, or "liquidated" balance. The Department disagrees with the finding that subawards were reported in the incorrect year. For annual federal funds, the Department operates on a First-In, First-Out (FIFO) basis. In the standard course of business, subaward invoices are typically paid from the specific pool of funds from which they were awarded. However, as older funding streams approach expiration, an invoice for a subaward originally awarded and properly reported to FFATA in FY2022 may be relieved using FY2019 funds. Since the subawards were reported accurately at the time of the award action, they remain in compliance with FFATA regulations. Corrective Plan of Action: The CDBG program will implement the following measures to ensure ongoing compliance and strengthen oversight: • Training and Regulatory Review: The Department will conduct comprehensive FFATA training for the reporting team, specifically focusing on the requirements set forth in 2 CFR Part 170. This review will ensure that all staff are aligned with federal reporting standards and the literal requirements of the regulation. • Internal Control Enhancement: A thorough evaluation of existing internal controls related to FFATA reporting is underway. The Department will identify and implement any necessary improvements to provide reasonable assurance that all reporting remains accurate and compliant. • Best Practice Research and Benchmarking: The Department will engage with peer agencies in other states to determine if a reconciliation process with USAspending.gov is utilized as a best practice. • Process Implementation: If an effective reconciliation model is identified through this benchmarking, the Department will evaluate its feasibility and integrate a similar reconciliation process into the State of Missouri’s standard operating procedures to further bolster reporting integrity.
Finding 2025-002: Eligibility – Temporary Assistance for Needy Families Name of Contact Person: Bobbie Crooker, Director of Energy and Housing Services Management’s Views and Corrective Action Plan: The Department of Energy and Housing Services (EHS) at MaineHousing agrees with the finding. The elig...
Finding 2025-002: Eligibility – Temporary Assistance for Needy Families Name of Contact Person: Bobbie Crooker, Director of Energy and Housing Services Management’s Views and Corrective Action Plan: The Department of Energy and Housing Services (EHS) at MaineHousing agrees with the finding. The eligibility determination error occurred because the applicant initially presented a qualifying dependent child that met program requirements. However, the applicant subsequently failed to provide the required verification documentation. Although the applicant should have been deemed ineligible due to noncompliance, the system did not update accordingly to adjust the benefit level. The system has since been corrected to address this issue. Application intake and approval are performed by Community Action Agencies (CAAs) on behalf of MaineHousing. To provide greater assurance that CAAs accurately determine and document participant eligibility, MaineHousing has strengthened its oversight and monitoring procedures. As part of this corrective action, MaineHousing enhanced its monitoring procedures to include additional supervisory review of CAA applications and eligibility determinations. These procedures supplement the annual required risk monitoring performed for each CAA and better enable MaineHousing to identify and address determination errors or related control weaknesses in a timely manner. EHS has reviewed the circumstances surrounding the specific case identified and has determined that it appears that the known questioned costs did not exceed reportable federal thresholds and no further recovery action is necessary. This program was administered as part of a subrecipient agreement with the Maine Department of Health and Human Services (DHHS). Due to structural and fiscal changes at DHHS, MaineHousing concluded its administration of these TANF funds effective July 1, 2026. Proposed Completion Date: Completed
– Management acknowledges the lapse in internal controls and the lack of documented procedures regarding MOE preparation, review, and retention of MOE calculation support in FY 2025. Corrective Action: This issue was addressed and corrected during FY2026. Specifically, we have implemented the follow...
– Management acknowledges the lapse in internal controls and the lack of documented procedures regarding MOE preparation, review, and retention of MOE calculation support in FY 2025. Corrective Action: This issue was addressed and corrected during FY2026. Specifically, we have implemented the following: 1. A formal written procedure on the MOE calculation describing the methodology, data sources, document retention, review and approvals. 2. UCOA training has been provided to secretarial staff and school administrators involved in related processes to ensure proper coding of expenses. 3. Implementation of new approval chains to review and approve the UCOA coding to ensure proper coding of expenses. 4. Monthly transaction reconciliations. Expected Completion: The corrective actions have been substantially competed as of this writing. Final completion expected by June 30, 2026.
The EPI Center conducted a comprehensive review of all contractors subject to testing and verified, through alternative procedures, that none were suspended or debarred (e.g., verification through SAM.gov and documented vendor validation processes). As a result, all costs associated with these contr...
The EPI Center conducted a comprehensive review of all contractors subject to testing and verified, through alternative procedures, that none were suspended or debarred (e.g., verification through SAM.gov and documented vendor validation processes). As a result, all costs associated with these contracts were determined to be allowable, reasonable, and allocable to the federal award. Accordingly, management concluded that the finding relates to procurement policy implementation, documentation, and compliance processes rather than the allowability, allocability, or eligibility of the expenditures tested.
The Authority will strengthen its annual payment standard review procedures to ensure payment standards are supported by current FMRs and any required HUD approval or notification is obtained and retained before implementation. HUD approval of 120% payment standards has been obtained for the 2026 pr...
The Authority will strengthen its annual payment standard review procedures to ensure payment standards are supported by current FMRs and any required HUD approval or notification is obtained and retained before implementation. HUD approval of 120% payment standards has been obtained for the 2026 program year. Anticipated completion date: December 31, 2026. Responsible contact person: Ola Stepp, Executive Director.
The Authority will strengthen its Housing Choice Voucher file review procedures to ensure executed leases, rent reasonableness determinations, gross income calculations, and utility allowances are properly documented and reviewed. Anticipated completion date: December 31, 2026. Responsible contact p...
The Authority will strengthen its Housing Choice Voucher file review procedures to ensure executed leases, rent reasonableness determinations, gross income calculations, and utility allowances are properly documented and reviewed. Anticipated completion date: December 31, 2026. Responsible contact person: Ola Stepp, Executive Director.
Response and Views of Responsible Officials Management acknowledges the finding related to the design and operating effectiveness of internal controls over compliance for the MIECHV program. While key review processes were generally in place, the organization recognizes that controls were not consis...
Response and Views of Responsible Officials Management acknowledges the finding related to the design and operating effectiveness of internal controls over compliance for the MIECHV program. While key review processes were generally in place, the organization recognizes that controls were not consistently documented or demonstrated during the audit period. In addition, documentation supporting expenditure approvals, grant coding, reimbursement preparation, supervisory review, and retention of supporting records was not consistently maintained. As a result, the auditors were unable to rely on the organization's internal controls to reduce the risk of noncompliance. The organization has taken the following corrective actions: • Adopted comprehensive Financial Policies and Procedures and Accounting Policies that clearly define internal controls over purchasing, cash disbursements, payroll, grant management, documentation retention, segregation of duties, supervisory review, and financial reporting. • Implemented written procedures outlining the authorization, coding, allocation, reimbursement, and documentation requirements for grant-funded expenditures. • Adopted a formal Cost Allocation Plan that documents the methodology for allocating shared costs and grant expenditures. • Assigned responsibility for independent review of reimbursement requests prior to submission. Reimbursement requests are now prepared by program management and reviewed by the internal bookkeeper before submission whenever practicable. • Established standardized documentation requirements to retain supporting invoices, approvals, allocation documentation, reimbursement support, and evidence of supervisory review within organized grant files. • Established procedures requiring documentation of management review through signatures, initials, electronic approvals, or other evidence demonstrating that required reviews were completed. To further strengthen internal controls and ensure continued compliance, the organization will: • Develop standardized internal review checklists for reimbursement requests and other key grant compliance activities to document preparation, supervisory review, and approval. • Conduct periodic internal monitoring to verify that established procedures are operating consistently and that supporting documentation is complete. • Provide training to staff responsible for grant administration and financial management regarding internal control responsibilities, documentation expectations, and federal compliance requirements. • Incorporate periodic management review of grant files to verify that expenditures, approvals, reimbursement documentation, and supporting records are complete and retained in accordance with organizational policies. Responsible Official: Josie Brittain Anticipated Completion Date: September 30, 2026
Finding 2025-003 — Questioned Costs Related to Expenditures Exceeding Approved Grant Budget Corrective Action Plan Management acknowledges that expenditures under the OASH HEALS award exceeded the approved grant budget by $8,158.59. To prevent similar instances in the future and strengthen complianc...
Finding 2025-003 — Questioned Costs Related to Expenditures Exceeding Approved Grant Budget Corrective Action Plan Management acknowledges that expenditures under the OASH HEALS award exceeded the approved grant budget by $8,158.59. To prevent similar instances in the future and strengthen compliance with Uniform Guidance, management will implement the following corrective actions:  Implement monthly budget-to-actual reviews for each federal award to monitor expenditures against approved budget categories and award ceilings.  Establish a monitoring process with alerts when expenditures approach approved budget limits, allowing management to take timely corrective action.  Require prior written approval from the grantor before incurring expenditures that would exceed approved budget limits or require budget revisions.  Assign responsibility to the Accounting Manager to review grant expenditures monthly and report any potential budget overruns to the Executive Director before additional costs are incurred.  Work with OASH to resolve the current over-award of $8,158.59 and retain documentation of the agency's allowability determination and any required corrective actions. Responsible Party Executive Director; Accounting Manager; Program Directors/Managers. Completion Date Budget monitoring procedures implemented immediately; resolution with OASH targeted by August 31, 2026. Questioned Costs $8,158.59
Communications with the Police Jury and Parish Engineers along with all Police Jury Department Head have taken place reinforcing to them the requirements of purchasing, contracting, bidding, and following all Police Jury establised policies and procedures for the proper procurement of goods and serv...
Communications with the Police Jury and Parish Engineers along with all Police Jury Department Head have taken place reinforcing to them the requirements of purchasing, contracting, bidding, and following all Police Jury establised policies and procedures for the proper procurement of goods and services. The reinforcement of the Police Jury Personnel Manual was made advising them all to strictly follow it immediately.
Finding 2025-003 Eligibility Project Based Cluster Corrective Action: • JHA will continue to monitor deficiencies to effectively streamline internal process controls including but not limited to the hiring of quality control analysts, data integrity analysts and monthly file auditing • JHA will crea...
Finding 2025-003 Eligibility Project Based Cluster Corrective Action: • JHA will continue to monitor deficiencies to effectively streamline internal process controls including but not limited to the hiring of quality control analysts, data integrity analysts and monthly file auditing • JHA will create a sample file to ensure standardization. • JHA will provide training to all new employees within 60 days and refresher course training for all existing employees. • JHA performs monthly audits of 10% of files and maintains a quality control system to track error trends, identify deficiencies
Finding 2025-002 Eligibility Low Rent Public Housing Corrective Action: • JHA has created sample files to ensure standardization. • JHA has delivered internal Public Housing training to all employees. In addition, JHA conducted Rent Calculation training on September 11, 2025. All participating emplo...
Finding 2025-002 Eligibility Low Rent Public Housing Corrective Action: • JHA has created sample files to ensure standardization. • JHA has delivered internal Public Housing training to all employees. In addition, JHA conducted Rent Calculation training on September 11, 2025. All participating employees successfully achieved a passing score on the required certification assessment. • JHA will provide training to all new employees within 60 days and refresher course training for all existing employees. JHA performs monthly audits of 10% of files and maintains a quality control system to track error trends, identify deficiencies and correct deficiencies. • JHA will continue to monitor deficiencies to effectively streamline internal process controls including but not limited to the hiring of quality control analysts and data integrity analyst and monthly file auditing.
Cash Management Moving to Work Demonstration Program AL No. 14.881 Other matter required to be reported in accordance with 2 CFR 200.516(a) Condition: Out of the 66 grant drawdowns during the year, 19 drawdowns were tested and it was noted that 1 of the drawdowns was made in advance of the supportin...
Cash Management Moving to Work Demonstration Program AL No. 14.881 Other matter required to be reported in accordance with 2 CFR 200.516(a) Condition: Out of the 66 grant drawdowns during the year, 19 drawdowns were tested and it was noted that 1 of the drawdowns was made in advance of the supporting invoices being paid to the vendors and subsequently the invoices were not paid within three business days, as required. Auditor’s Recommendations: The Agency should continue to develop and implement internal controls over grant management to coordinate capital fund draws with the timing of invoice payments. Action Taken: Action Due Date Responsible Person This finding occurred prior to the staff receiving the results of the previous audit. There have been no additional invoice payments outside of the 3-day allowable time. Staff developed and implemented an internal tracking document to ensure payments are made within three days of the draw. Complete – May 2025 Accounting Technician, Kary Smith, Lauren Hodgens and Ryan Bates
Eligibility Moving to Work Demonstration Program AL. No. 14.881 Other matter required to be reported in accordance with 2 CFR 200.516(a) Reported from 2024 audit (see prior year finding 2024-002) Condition: Out of an approximate population of approximately 4,800 tenants, 40 tenant files were tested ...
Eligibility Moving to Work Demonstration Program AL. No. 14.881 Other matter required to be reported in accordance with 2 CFR 200.516(a) Reported from 2024 audit (see prior year finding 2024-002) Condition: Out of an approximate population of approximately 4,800 tenants, 40 tenant files were tested and the following deficiencies were noted: ▪ Two files did not have 214 documentation available for a member of the household, ▪ One file had the incorrect income calculated, which impacted the HAP received, ▪ One file had the incorrect income calculated, which did not impact the HAP received, ▪ One file received the incorrect HAP for which no subsequent correction was made, ▪ One file did not have a required rent reasonableness performed during the year, and ▪ One file did not have a quality control checklist maintained in the file. Auditor Recommendations: The Authority should re-evaluate their established procedures and controls in place to ensure full compliance in regards to eligibility. The Authority needs to correct the deficiencies noted in the tested files and consider the impact to the rest of the population of tenant files that were not selected as part of the auditor’s sample. Action Due Date Responsible Person Conduct a review of cases with identified audit findings to confirm the accuracy of the determinations and implement corrections as needed. Eligibility checklists were implemented on July 31, 2024, in response to the FY23 audit findings. An additional checklist specific to annual and recertification processes was implemented in October 2025 to further strengthen compliance and quality control. Some households are on a triannual recertification cycle and have not undergone a recertification since the prior audit; these cases will be reviewed as applicable. The accuracy and effectiveness of all checklists will be reviewed and updated as needed by August 31, 2026. September 30, 2026 Program Manager, Christi Champ To address findings related to incorrect income calculations, the agency conducts monthly quality assurance reviews through random case sampling, consistent with HUD-recommended practices. Additionally, beginning in March 2026, the agency initiated comprehensive refresher trainings for all Housing Specialist (HS) staff, covering core program functions and requirements. These trainings are scheduled for completion by the end of July 2026. September 30, 2026 Program Manager, Christi Champ The file identified as missing required rent reasonableness documentation will be reviewed, and any deficiencies will be corrected as appropriate. Based on internal review, this case may be associated with a Project-Based Voucher (PBV) unit, where prior rent increases were appropriately completed but not consistently retained within the tenant file. In Spring 2026, the agency identified this documentation gap and implemented process improvements, including updates to internal policies to ensure that all rent reasonableness determinations are consistently documented and maintained September 30, 2026 Program Manager, Christi Champ in the tenant file. These updates will be effective July 2026. All required rent reasonableness documentation will be added to the applicable tenant file
Eligibility Housing Voucher Cluster Other matter required to be reported in accordance with 2 CFR 200.516(a) Condition: Out of an approximate population of approximately 600 tenants, 40 tenant files were tested and the following deficiencies were noted: ▪ Four files did not have an inspection perfor...
Eligibility Housing Voucher Cluster Other matter required to be reported in accordance with 2 CFR 200.516(a) Condition: Out of an approximate population of approximately 600 tenants, 40 tenant files were tested and the following deficiencies were noted: ▪ Four files did not have an inspection performed during the required period, ▪ Two files did not have an up to date 9886 form on file ▪ One file did not have ID for an adult tenant in the household, and ▪ One file had the incorrect income calculated, which did not impact the HAP received. Auditor Recommendations: The Authority should re-evaluate their established procedures and controls in place to ensure full compliance in regards to eligibility. The Authority needs to correct the deficiencies noted in the tested files and consider the impact to the rest of the population of tenant files that were not selected as part of the auditor’s sample. Action Taken: Action Due Date Responsible Person Conduct a review of cases associated with inspectionrelated findings to verify the accuracy of the determinations and implement corrections as necessary. In certain cases, inspections may align with approved biennial inspection schedules, or delays may have occurred due to inability to access the unit or tenant non-compliance. In such instances, cases may currently be progressing through the ineligibility process, which requires additional time to resolve in accordance with program requirements. Additionally, the agency identified system-related reporting issues within Yardi that may have impacted the September 30, 2026 Program Manager, Nat Dybens accuracy of inspection tracking reports. The agency has been actively collaborating with system coordinators to address and resolve these issues. Files identified as lacking an upto-date Form HUD-9886 will be reviewed to confirm the accuracy of the finding, and all required documentation will be obtained and maintained in the tenant file to ensure compliance. Form HUD-9886-A [24 CFR 5.230(b)(1), b(2), (c)(4), and (c)(5)]; Notice PIH 2023-27 All adult applicants and participants sign form HUD-9886- A, Authorization for Release of Information. All adult family members (and the head and spouse/cohead, regardless of age) are required to sign the Form HUD9886-A at admission. Participants, prior to January 1, 2024, signed and submitted Form HUD9886 at each annual reexamination. HOTMA eliminated this requirement and instead required that the Form HUD-9886-A be signed only once. On or after January 1, 2024 (regardless of the PHA’s HOTMA compliance date), current program participants must sign and submit a new Form HUD-9886-A at their next interim or annual reexamination. This form will only be signed once. Another Form HUD-9886-A will not be submitted to the PHA except under the following circumstances: • When any person 18 years or older becomes a member of the family; • When a current member of the family turns 18; or • As required by HUD or the PHA in administrative instructions. September 30, 2026 Program Manager, Christi Champ The PHA has the discretion to establish policies around when family members must sign consent forms when they turn 18. PHAs must establish these policies stating when family members will be required to sign consent forms at intervals other than at reexamination. PHA To address areas of identified findings, the agency will reinforce expectations through staff reminders and provide additional training as needed. Additionally, beginning in March 2026, the agency initiated comprehensive refresher trainings for all Housing Specialist (HS) staff, covering core program functions and requirements. These trainings are scheduled for completion by the end of July 2026. Continued throughout the year. Program Manager, Christi Champ and Program Manager, Nat Dybens The file identified as missing required identification documentation for an adult household member will be reviewed to verify the accuracy of the finding, and all necessary documentation will be obtained and updated as appropriate. The agency recognizes that there are multiple acceptable methods for verifying adult identity and will ensure that documentation on file meets HUD requirements and is properly maintained. Additionally, a recertification checklist was implemented in October 2025 to support staff in verifying the presence of all required permanent documentation, including identification, during case file reviews. This control strengthens ongoing compliance and reduces September 30, 2026 Program Manager, Christi Champ the likelihood of similar deficiencies.
Finding 2025-014 Medicaid Cluster, ALN 93.775, 93.777, and 93.778 and Children's Health Insurance Program, ALN 93.767 - Expenditure Processing for Medical Payments Management Views MDHHS agrees with the finding. Planned Corrective Action MDHHS implemented a system update in Bridges to ensure new cas...
Finding 2025-014 Medicaid Cluster, ALN 93.775, 93.777, and 93.778 and Children's Health Insurance Program, ALN 93.767 - Expenditure Processing for Medical Payments Management Views MDHHS agrees with the finding. Planned Corrective Action MDHHS implemented a system update in Bridges to ensure new cases are correctly assigned to either CHIP or Medicaid, and all remaining existing cases were updated during fiscal year 2025, eliminating the need for the quarterly manual reclassification. MDHHS discontinued the manual reclassification process during fiscal year 2026 and transferred the expenditures back to Medicaid for the individuals identified in the finding. Anticipated Completion Date Completed Responsible Individual(s) Brant Cole, MDHHS Crystal Kline, MDHHS
Finding 2025-013 Medicaid Cluster, ALN 93.775, 93.777 and 93.778 and Children’s Health Insurance Program, ALN 93.767 - Beneficiary Eligibility Management Views MDHHS agrees with the identified exceptions for parts a. and c. However, MDHHS disagrees that 2 Medicaid cases and 11 CHIP cases with MAGI d...
Finding 2025-013 Medicaid Cluster, ALN 93.775, 93.777 and 93.778 and Children’s Health Insurance Program, ALN 93.767 - Beneficiary Eligibility Management Views MDHHS agrees with the identified exceptions for parts a. and c. However, MDHHS disagrees that 2 Medicaid cases and 11 CHIP cases with MAGI determinations cited in part b. lacked documentation supporting the eligibility determination. CMS has determined that a reasonable compatibility indicator can be used for CMS audit purposes to determine if the attested income information was electronically verified for MAGI cases. For this reason, MDHHS disagrees that documentation was not maintained. The State of Michigan (SOM) MiIntegrate system communicates with various electronic State and federal trusted data sources and sends information from these sources, along with the beneficiaries’ attested income, to the SOM MAGI Rules Engine where the MAGI eligibility determination is made. As part of the MAGI eligibility determination, a reasonable compatibility test is completed to determine if beneficiary/applicant attested income is within a specified percentage of the trusted data sources or if the attested and verified income are below the threshold for the applicable program. The results of the MAGI eligibility determination are sent back to MiIntegrate using an Account Transfer (AT) packet that contains the results. MiIntegrate then communicates the results to the SOM MAGI Viewer and Bridges using an AT packet and Bridges stores the AT packet number only that can be used to view the details of the AT packet within the SOM MAGI Viewer. The version of the AT packet within the MAGI Viewer also contains a reasonable compatibility indicator that documents the outcome of the reasonable compatibility test and supports the SOM MAGI Rules Engine eligibility decision. MDHHS stores the AT packet information, including facts essential to the eligibility determination, within MiIntegrate and the MAGI viewer instead of Bridges to help protect and secure the federal income tax data and unemployment data used for the determination. The AT packet for each individual determination can be retrieved from the MAGI Viewer using the AT packet number stored in each beneficiary’s case file within Bridges. MDHHS is not aware of any federal regulations that preclude MDHHS from storing this information in a separate, secure system to ensure appropriate data protection and access controls required by federal and State laws. Planned Corrective Action To address the exceptions identified that are not related to MAGI-based income verification results, MDHHS developed mandatory training protocols for eligibility specialists, and the first Medicaid audit-focused mandatory training was implemented in June 2025. MDHHS will continue to determine where additional training or enhancements to training are needed to ensure eligibility is accurately determined and documentation is properly maintained within the electronic case file. For the exception that did not contain the appropriate coverage termination date, MDHHS reviewed the case and determined that the beneficiary remained eligible to transition to another aid category, and therefore no improper payments occurred. MDHHS will identify the system issue that produced the incorrect termination date and will implement a system fix if necessary. Should such an improvement be identified, it will be submitted through the Departmental Work Intake Process for prioritization and implementation by the Bridges technical team. MDHHS maintains that documentation supporting MAGI eligibility determinations is retained within MiIntegrate and the MAGI Viewer and therefore disagrees that case file documentation was not maintained. As such, no further corrective action is planned. Anticipated Completion Date June 30, 2027 Responsible Individual(s) Logan Dreasky, MDHHS Brant Cole, MDHHS Mariah Schaefer, MDHHS
Finding 2025-051 Low-Income Home Energy Assistance, ALN 93.568 - Eligibility Determinations Management Views MDHHS agrees with the finding. Planned Corrective Action In May 2025, MDHHS issued memo 2025-20, which implemented mandatory training requirements for all eligibility staff and their managers...
Finding 2025-051 Low-Income Home Energy Assistance, ALN 93.568 - Eligibility Determinations Management Views MDHHS agrees with the finding. Planned Corrective Action In May 2025, MDHHS issued memo 2025-20, which implemented mandatory training requirements for all eligibility staff and their managers to address audit-related findings. The State Emergency Relief (SER) training courses occur biannually, in March and August, and cover verification of client income, client contribution payments, and proof of energy crisis. To ensure accuracy of payment processing, in October 2025, MDHHS issued memo 2025-48 which implemented the mandatory SER Reconciliation Report requirement. As part of this updated process, each county office must run the SER Energy Reconciliation Report weekly and review all energy-related payments to ensure accuracy and confirm that required documentation is maintained. In addition, MDHHS will continue to communicate with BSCs and local offices regarding the requirements to maintain sufficient documentation to support SER processing through formal internal communication channels. MDHHS will also continue to provide direct SER guidance and clarification through the SER mailbox. Further, MDHHS will explore a potential system enhancement that will provide automated solutions for an added layer of efficiency and compliance. Should such an improvement be identified, it will be submitted through the Departmental Work Intake Process for prioritization and implementation by the Bridges technical team. Anticipated Completion Date MDHHS has not yet determined an anticipated completion date because the completion date is dependent on the priority assigned to system enhancements as determined by the Departmental Work Intake Process. Responsible Individual(s) Bethany Cabanaw, MDHHS Kent Schulze, MDHHS Julie McLaughlin, MDHHS
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