Corrective Action Plans

Finding 402751 (2023-052)

Material Weakness 2023

State of Michigan

MI

Questioned Costs Allowable Costs / Cost Principles Eligibility

Finding 2023-052 Refugee and Entrant Assistance State/Replacement Designee Administered Programs, ALN 93.566 - Assistance to Ineligible Refugees Management Views LEO and MDHHS agree with the finding. Planned Corrective Action For part a., MDHHS will issue a memo to BSCs and local offices and provi...

Finding 2023-052 Refugee and Entrant Assistance State/Replacement Designee Administered Programs, ALN 93.566 - Assistance to Ineligible Refugees Management Views LEO and MDHHS agree with the finding. Planned Corrective Action For part a., MDHHS will issue a memo to BSCs and local offices and provide training to local office staff regarding the requirements to maintain sufficient documentation to support Refugee and Entrant Assistance State/Replacement Designee Administered Programs eligibility. For part b., MDHHS corrected the reporting defect and properly adjusted the accounting records. MDHHS already had a process in place to identify the reporting defect and make necessary accounting adjustments. MDHHS will ensure that accounting adjustments are prioritized for any future reporting defects. Anticipated Completion Date a. September 30, 2024 b. Completed Responsible Individual(s) a. Mariah Schaefer, MDHHS b. Trish Bouck, MDHHS

View Audit 309982 Questioned Costs: $1

Finding 402750 (2023-051)

Significant Deficiency 2023

State of Michigan

MI

Subrecipient Monitoring Allowable Costs / Cost Principles Period of Performance

Finding 2023-051 Refugee and Entrant Assistance State/Replacement Designee Administered Programs, ALN 93.566 - Salesforce Security Management and Access Controls Management Views LEO agrees with the finding. Planned Corrective Action The LEO Office of Global Michigan will update established proced...

Finding 2023-051 Refugee and Entrant Assistance State/Replacement Designee Administered Programs, ALN 93.566 - Salesforce Security Management and Access Controls Management Views LEO agrees with the finding. Planned Corrective Action The LEO Office of Global Michigan will update established procedures and tracking logs to ensure compliance with SOM Technical Standard 1340.00.020.01. The LEO Internal Controls unit is in the process of establishing a grants compliance team that will perform validation of the ongoing reviews. Anticipated Completion Date December 31, 2024 Responsible Individual(s) Ben Cabinaw, LEO Allen Williams, LEO

View Audit 309982

Finding 402743 (2023-009)

Significant Deficiency 2023

State of Michigan

MI

Cash Management

Finding 2023-009 Treasury - Recertification of Clearance Patterns Management Views Treasury agrees with the finding. When the Cash Management Improvement Act (CMIA) program transferred to Treasury FSD in early 2022, there was a lack of well-documented procedures on how to complete program clearance...

Finding 2023-009 Treasury - Recertification of Clearance Patterns Management Views Treasury agrees with the finding. When the Cash Management Improvement Act (CMIA) program transferred to Treasury FSD in early 2022, there was a lack of well-documented procedures on how to complete program clearance pattern reviews. FSD created a procedure for the review process, but it is not complete. Planned Corrective Action Treasury FSD will continue to gain a better understanding of the clearance pattern review process and thoroughly document the procedures for future fiscal years to ensure compliance with federal regulations. FSD will research how the clearance patterns are determined for each program, identify which programs require clearance pattern review each year, ensure that the SIGMA BI queries are functioning properly for each program under review, and clarify how to interpret the BI query results. Anticipated Completion Date September 2024 Responsible Individual(s) Melanie Alvord, Treasury Lauren Markwart, Treasury

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Finding 402741 (2023-050)

Significant Deficiency 2023

State of Michigan

MI

Eligibility Special Tests & Provisions Reporting

Finding 2023-050 Temporary Assistance for Needy Families, ALN 93.558 - Child Support Non-Cooperation Management Views MDHHS disagrees with 4 of 5 exceptions identified. The MDHHS Bridges technical team reviewed each cited case and determined that Bridges was functioning as intended for four cases i...

Finding 2023-050 Temporary Assistance for Needy Families, ALN 93.558 - Child Support Non-Cooperation Management Views MDHHS disagrees with 4 of 5 exceptions identified. The MDHHS Bridges technical team reviewed each cited case and determined that Bridges was functioning as intended for four cases identified because each case was in a non-ongoing mode at the time the automated interface occurred. A case is placed into this status if the client circumstances have changed for any MDHHS program within Bridges and the case requires a redetermination. TANF policy cannot mandate Bridges to change the non-ongoing mode because each impacted program is required to be certified prior to changing the status. MDHHS policy does not mandate a specific length of time that a case can be in a non-ongoing status. The results of the redetermination can impact the client’s non-cooperation status and therefore the client should not be sanctioned until the certification by all programs is complete. For two of the cases, the client was appropriately sanctioned after the case review was complete and for the other two cases, the client was determined to be in compliance once the case was removed from the non-going status mode. Planned Corrective Action The MDHHS Bridges technical team will follow the Departmental Work Intake Process to prioritize the identification of potential system modifications that may be needed to help ensure that Bridges is appropriately applying the one-month sanction period for child support non-cooperation. After identifying potential solutions, the MDHHS Bridges technical team will report their findings to MDHHS ESA policy staff and determine the best solution for remediation. Anticipated Completion Date August 31, 2024 Responsible Individual(s) Kenton Schulze, MDHHS Brian Sanborn, MDHHS

View Audit 309982

Finding 402740 (2023-049)

Significant Deficiency 2023

State of Michigan

MI

Subrecipient Monitoring

Finding 2023-049 Temporary Assistance for Needy Families, ALN 93.558 - Risk Assessment and During-the-Award Monitoring Management Views MDHHS agrees with the finding. Planned Corrective Action MDHHS monitors financial and programmatic reports submitted by the grantee and communicates with the gran...

Finding 2023-049 Temporary Assistance for Needy Families, ALN 93.558 - Risk Assessment and During-the-Award Monitoring Management Views MDHHS agrees with the finding. Planned Corrective Action MDHHS monitors financial and programmatic reports submitted by the grantee and communicates with the grantee on a consistent basis. MDHHS will evaluate the risk assessment results to determine if additional monitoring is needed. MDHHS will also develop a program template to document monitoring activities, including follow-up action related to deficiencies noted during monitoring. Anticipated Completion Date July 31, 2024 Responsible Individual(s) Jessica Altenbernt, MDHHS Amber Troupe, MDHHS

View Audit 309982

Finding 402739 (2023-048)

Significant Deficiency 2023

State of Michigan

MI

Allowable Costs / Cost Principles Eligibility

Finding 2023-048 Temporary Assistance for Needy Families, ALN 93.558 - Inappropriate TANF-Funded Adoption Subsidy Rate Management Views MDHHS disagrees with the finding. Although the appropriate negotiated rate was not used to calculate the initial payment, MDHHS disagrees that a deficiency exists....

Finding 2023-048 Temporary Assistance for Needy Families, ALN 93.558 - Inappropriate TANF-Funded Adoption Subsidy Rate Management Views MDHHS disagrees with the finding. Although the appropriate negotiated rate was not used to calculate the initial payment, MDHHS disagrees that a deficiency exists. MDHHS ensures that the appropriate negotiated rate is used during an annual review process that occurs each year and is based on the child’s birth month. The annual report process includes a thorough payment history review for each adoption assistance case to ensure payments are issued accurately. This involves verifying cases are paid at the correct rate and identifying any overpayments that occurred for adoption assistance agreements that were entered into between January 21, 2014 through June 18, 2015, prior to the MiSACWIS system update to automate the clothing allowance offset. The overpayment noted in the finding was identified by the auditor during the month prior to MDHHS’s annual review process, which was scheduled for April 2024, and the negotiated rate for the month the child turned 13 was manually corrected and recouped by MDHHS in March 2024. MDHHS believes this is a timing issue and disagrees that a deficiency exists. Planned Corrective Action MDHHS disagrees with the finding and does not intend to take further action. Anticipated Completion Date Not applicable Responsible Individual(s) Kathonya Rice, MDHHS

View Audit 309982

Finding 402738 (2023-047)

Significant Deficiency 2023

State of Michigan

MI

Questioned Costs Allowable Costs / Cost Principles Eligibility § 200.516

Finding 2023-047 Temporary Assistance for Needy Families, ALN 93.558 - Non-Financial Eligibility Documentation Management Views MDHHS agrees with the finding. Planned Corrective Action MDHHS’s ESA will continue to emphasize the importance of maintaining eligibility documentation through ongoing st...

Finding 2023-047 Temporary Assistance for Needy Families, ALN 93.558 - Non-Financial Eligibility Documentation Management Views MDHHS agrees with the finding. Planned Corrective Action MDHHS’s ESA will continue to emphasize the importance of maintaining eligibility documentation through ongoing staff training and a memorandum sent to local offices and Eligibility Specialists. ESA leadership will reach out to managers of individual Eligibility Specialists regarding issues identified with the Family Automated Screening Tool and Family Self-Sufficiency Plan completion and verification of school enrollment and provide additional guidance as needed. Anticipated Completion Date August 31, 2024 Responsible Individual(s) Brian Sanborn, MDHHS Kenton Schulze, MDHHS

View Audit 309982 Questioned Costs: $1

Finding 402737 (2023-046)

Significant Deficiency 2023

State of Michigan

MI

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

Finding 2023-046 Temporary Assistance for Needy Families, ALN 93.558 - MARS User Access Management Views The Department of Labor and Economic Opportunity (LEO) agrees with the finding. The Management of Awards to Recipients System (MARS) is an older legacy system that does not automatically deactiv...

Finding 2023-046 Temporary Assistance for Needy Families, ALN 93.558 - MARS User Access Management Views The Department of Labor and Economic Opportunity (LEO) agrees with the finding. The Management of Awards to Recipients System (MARS) is an older legacy system that does not automatically deactivate user accounts after 60 days of inactivity. The LEO Finance unit continues to experience challenges related to staffing shortages and competing priorities. Accordingly, the LEO Internal Controls unit will assist the LEO Finance unit in the interim with implementing corrective action until this legacy application is replaced, and new procedures are implemented. Planned Corrective Action LEO has received a Technical Review Board exception from SOM Technical Standard 1340.00.020.01 (Access Control Standard). The exception allows MARS inactive accounts to remain open for up to 90 days - an interval at which Michigan Works! Agency administrators make quarterly approvals (sometimes their only activity on the system). The exception was granted on April 12, 2024, and is valid through October 9, 2024, but may be extended. LEO staff has begun manually pulling an inactive users report monthly and manually deactivating accounts that were not accessed during the previous 90-day period. LEO is currently working on a request for proposal to replace MARS and anticipates that the new system will be able to automatically deactivate user accounts in accordance with the SOM Technical Standard. The LEO Finance unit has updated its procedures to reflect its interim process and will further revise them once the MARS replacement system goes live. Anticipated Completion Date September 30, 2026 Responsible Individual(s) Lora MacKay, LEO Allen Williams, LEO

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Finding 402736 (2023-045)

Significant Deficiency 2023

State of Michigan

MI

Internal Control / Segregation of Duties Allowable Costs / Cost Principles Eligibility

Finding 2023-045 Temporary Assistance for Needy Families, ALN 93.558 - MiSACWIS Security Management and Access Controls Management Views MDHHS agrees with the finding. Planned Corrective Action For parts a. and c., MDHHS will continue to provide training for local office security coordinators (LOS...

Finding 2023-045 Temporary Assistance for Needy Families, ALN 93.558 - MiSACWIS Security Management and Access Controls Management Views MDHHS agrees with the finding. Planned Corrective Action For parts a. and c., MDHHS will continue to provide training for local office security coordinators (LOSCs) via quarterly webinars to emphasize the appropriate procedures for granting access, reviewing, and comparing access. All new information related to security access is presented to the LOSCs during the webinars and one-on-one assistance is available as needed for additional support. For part b., MDHHS currently has a process in place to review the user narrative describing the incompatible role exceptions within the DSA Michigan Statewide Automated Child Welfare Information System (MiSACWIS) request as part of the approval process. MDHHS will continue to work on adding an incompatible role form in the DSA MiSACWIS request with automated routing for appropriate approval. Anticipated Completion Date a. and c. Corrective action is ongoing. b. MDHHS has not yet determined an anticipated completion date because implementation is dependent on funding, approval, and prioritization of other proposed system changes. Responsible Individual(s) Alana Lowe, MDHHS Deon Nelson, MDHHS

View Audit 309982

Finding 402722 (2023-044)

Significant Deficiency 2023

State of Michigan

MI

Special Tests & Provisions Procurement, Suspension & Debarment Eligibility

Finding 2023-044 Immunization Cooperative Agreements, ALN 93.268 - Control, Accountability, and Safeguarding of Vaccine and Record of Immunization Management Views MDHHS disagrees with the finding. Site visits did not resume for all Vaccines for Children (VFC) providers until the July 1, 2022 throu...

Finding 2023-044 Immunization Cooperative Agreements, ALN 93.268 - Control, Accountability, and Safeguarding of Vaccine and Record of Immunization Management Views MDHHS disagrees with the finding. Site visits did not resume for all Vaccines for Children (VFC) providers until the July 1, 2022 through June 30, 2023 review cycle because the Centers for Disease Control and Prevention (CDC) allowed jurisdictions to temporarily suspend these visits during the COVID-19 pandemic that ended during May 2023. MDHHS previously reached out to the CDC for clarification on conducting site visits and was informed that site visit activities could be suspended based on COVID-19 activity in MDHHS’s jurisdiction and capacity within MDHHS’s organization. The site visits identified in the finding were included in the backlog of suspended site visits that MDHHS continued to work through during the audit period. Planned Corrective Action MDHHS sent reminders of the VFC program requirements and program guidelines to MDHHS field representatives and local health department (LHD) site reviewers, including those overseeing VFC providers in need of compliance site visits. In order to remain compliant with program requirements, the MDHHS VFC team issued expectation dates for completing site visits and monitored site visit progress. MDHHS communicated this information via monthly Vaccine Management Calls, training sessions, and email notifications. MDHHS sent each LHD a letter which contained a list of VFC providers that remained non-compliant after June 30, 2023, with a short extension to complete needed site visits by August 24, 2023. All overdue site visits were completed as of December 31, 2023. Anticipated Completion Date Completed Responsible Individual(s) Heather Barnes, MDHHS Heidi Loynes, MDHHS Ryan Malosh, MDHHS

View Audit 309982

Finding 402721 (2023-043)

Significant Deficiency 2023

State of Michigan

MI

Special Tests & Provisions Subrecipient Monitoring Equipment & Real Property Management

Finding 2023-043 Immunization Cooperative Agreements, ALN 93.268 - MCIR User Access Controls Management Views MDHHS agrees with the finding. Planned Corrective Action MDHHS received approval for an exception allowing them to disable inactive accounts after 120 days instead of 60 days, which was i...

Finding 2023-043 Immunization Cooperative Agreements, ALN 93.268 - MCIR User Access Controls Management Views MDHHS agrees with the finding. Planned Corrective Action MDHHS received approval for an exception allowing them to disable inactive accounts after 120 days instead of 60 days, which was implemented May 8, 2024. The exception was requested and granted because the Michigan Care Improvement Registry (MCIR) users include non-SOM users that do not log in as frequently. MDHHS will develop and implement a manual process to deactivate users from the MDHHS sites in MCIR that have not been accessed in 120 days. Anticipated Completion Date September 30, 2024 Responsible Individual(s) Abigail Cheney, MDHHS Ryan Malosh, MDHHS Beatrice Salada, MDHHS

View Audit 309982

Finding 402719 (2023-042)

Significant Deficiency 2023

State of Michigan

MI

Subrecipient Monitoring

Finding 2023-042 Public Health Emergency Preparedness, ALN 93.069 - Risk Assessment and During-the-Award Monitoring Management Views MDHHS agrees with the finding. Planned Corrective Action MDHHS hired a financial analyst during May 2024 to assist with subrecipient monitoring. MDHHS evaluated the...

Finding 2023-042 Public Health Emergency Preparedness, ALN 93.069 - Risk Assessment and During-the-Award Monitoring Management Views MDHHS agrees with the finding. Planned Corrective Action MDHHS hired a financial analyst during May 2024 to assist with subrecipient monitoring. MDHHS evaluated the subrecipient monitoring plan and revised as needed. Although MDHHS conducts quarterly reviews of Financial Status Reports and requests supporting documentation based on reviews, MDHHS will annually consider if any additional monitoring activities are necessary based on the annual risk assessment results. Anticipated Completion Date Completed Responsible Individual(s) Jay Fiedler, MDHHS Brianna Briggs, MDHHS

View Audit 309982

Finding 402645 (2023-041)

Significant Deficiency 2023

State of Michigan

MI

Matching / Level of Effort / Earmarking Allowable Costs / Cost Principles Special Tests & Provisions

Finding 2023-041 Medicaid Cluster, ALN 93.775, 93.777, and 93.778 - ADP Security Program Management Views MDHHS agrees with part a. of the finding. MDHHS and DTMB disagree with part b. of the finding. For part b., although MDHHS agrees that system security plans were not updated timely for the sys...

Finding 2023-041 Medicaid Cluster, ALN 93.775, 93.777, and 93.778 - ADP Security Program Management Views MDHHS agrees with part a. of the finding. MDHHS and DTMB disagree with part b. of the finding. For part b., although MDHHS agrees that system security plans were not updated timely for the systems cited and the authority to operate expired for both systems, MDHHS disagrees that effective controls were not implemented to ensure confidentiality, integrity, and availability of its automated data processing (ADP) information systems. MDHHS also disagrees that the security of critical systems was at risk by failing to mitigate potential vulnerabilities as described above. MDHHS has compensating controls in place to ensure confidentiality, integrity, and availability of its ADP information systems in addition to mitigating potential vulnerabilities. MDHHS monitors remediation of Plans of Actions and Milestones for all information systems even after expiration of the authority to operate. The ADP systems cited for not having an updated risk assessment are reviewed biennially through the Internal Control Evaluation process where control evidence is updated to demonstrate effectiveness of controls. For one system cited, MDHHS is required to audit the system as part of the responsibilities related to the Affordable Care Act and the Medicaid Expansion marketplace. Those audits are conducted to show compliance with federal information security and privacy requirements related to data stored in those systems. The other system cited did not have any significant changes and implemented controls are still working as expected. Planned Corrective Action For part a., MDHHS will perform annual reviewing and testing of the business continuity plan (BCP). MDHHS has completed annual review and testing of the BCP as of April 22, 2024. For part b., MDHHS and DTMB will complete the necessary updates to the system security plans, including updating the risk assessments, and anticipate completion for both systems by December 31, 2024. MDHHS and DTMB anticipate that authority to operate renewals will be attained for both systems by December 31, 2024. Anticipated Completion Date December 31, 2024 Responsible Individual(s) Jim Bowen, MDHHS Nathan Buckwalter, DTMB Heather Frick, DTMB Karen Scott, MDHHS Keelie Honsowitz, MDHHS

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Finding 402644 (2023-040)

Significant Deficiency 2023

State of Michigan

MI

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

Finding 2023-040 Medicaid Cluster, ALN 93.775, 93.777, and 93.778 - Practitioner Reimbursement Management Views MDHHS agrees with the finding. Planned Corrective Action MDHHS has determined the primary remaining source for overlaps between fee-for-service and capitation payments is due to retroact...

Finding 2023-040 Medicaid Cluster, ALN 93.775, 93.777, and 93.778 - Practitioner Reimbursement Management Views MDHHS agrees with the finding. Planned Corrective Action MDHHS has determined the primary remaining source for overlaps between fee-for-service and capitation payments is due to retroactive removal of Medicaid eligibility within Bridges. An upgraded interface fix is being implemented that will address several issues. This upgraded interface will remove the existing limitations to mitigate the occurrence of retroactive disenrollment. The interface fix is scheduled for March 2025 implementation. Anticipated Completion Date March 31, 2025 Responsible Individual(s) Latina McCausey, MDHHS Alexis Bond, MDHHS

View Audit 309982 Questioned Costs: $1

Finding 402643 (2023-039)

Significant Deficiency 2023

State of Michigan

MI

Questioned Costs Matching / Level of Effort / Earmarking Allowable Costs / Cost Principles § 200.516

Finding 2023-039 Medicaid Cluster, ALN 93.775, 93.777, and 93.778 - Ineligible HHP Payments Management Views MDHHS agrees with the finding. Planned Corrective Action MDHHS presented the audit findings and planned corrective action to local office workers, managers, and staff at an Adult Services ...

Finding 2023-039 Medicaid Cluster, ALN 93.775, 93.777, and 93.778 - Ineligible HHP Payments Management Views MDHHS agrees with the finding. Planned Corrective Action MDHHS presented the audit findings and planned corrective action to local office workers, managers, and staff at an Adult Services statewide meeting during March 2024. During the meeting, MDHHS reviewed recoupment policies and procedures and the importance of reviewing work for accuracy. MDHHS issued an Adult Services Notification to managers and directors during April 2024 informing them of the recent recoupment audit findings and reminding local office management of the expectation to review hospitalization reports to ensure timely and accurate action is taken. Anticipated Completion Date Completed Responsible Individual(s) Elaina Brown-Mingo, MDHHS Michelle Martin, MDHHS

View Audit 309982 Questioned Costs: $1

Finding 402642 (2023-038)

Significant Deficiency 2023

State of Michigan

MI

Questioned Costs Matching / Level of Effort / Earmarking Allowable Costs / Cost Principles § 200.516

Finding 2023-038 Medicaid Cluster, ALN 93.775, 93.777, and 93.778 - Payments on Behalf of Ineligible Beneficiaries Management Views MDHHS agrees with the finding. Planned Corrective Action MDHHS developed a prior report review process to ensure impacted records that do not get corrected with the C...

Finding 2023-038 Medicaid Cluster, ALN 93.775, 93.777, and 93.778 - Payments on Behalf of Ineligible Beneficiaries Management Views MDHHS agrees with the finding. Planned Corrective Action MDHHS developed a prior report review process to ensure impacted records that do not get corrected with the CHAMPS retrigger are addressed. MDHHS continues to work with DTMB on the underlying issues in Bridges causing synchronization problems between Bridges and CHAMPS, as well as developing mitigation strategies to temporarily address the overpayment concerns while the more permanent system solutions are developed. MDHHS expects all remaining synchronization issues to be resolved once the remaining larger system changes are implemented in March 2025. Anticipated Completion Date March 31, 2025 Responsible Individual(s) Jamy Hengesbach, MDHHS

View Audit 309982 Questioned Costs: $1

Finding 402641 (2023-019)

Significant Deficiency 2023

State of Michigan

MI

Finding 2023-019 Medicaid Cluster, ALN 93.775, 93.777, and 93.778 and Children's Health Insurance Program, ALN 93.767 - Managed Care Periodic Audits Management Views MDHHS agrees with the finding. Planned Corrective Action MDHHS formally added the Encounter Data Validation (EDV) protocol to its Ex...

Finding 2023-019 Medicaid Cluster, ALN 93.775, 93.777, and 93.778 and Children's Health Insurance Program, ALN 93.767 - Managed Care Periodic Audits Management Views MDHHS agrees with the finding. Planned Corrective Action MDHHS formally added the Encounter Data Validation (EDV) protocol to its External Quality Review Organization contracts as of October 1, 2022. EDV activities have been completed and final reports outlining the results of the reviews were posted to the website during February and March 2024. Anticipated Completion Date Completed Responsible Individual(s) Brad Barron, MDHHS Jackie Sproat, MDHHS Matthew Seager, MDHHS

View Audit 309982

Finding 402640 (2023-018)

Significant Deficiency 2023

State of Michigan

MI

Finding 2023-018 Medicaid Cluster, ALN 93.775, 93.777, and 93.778 and Children's Health Insurance Program, ALN 93.767 - Medical Loss Ratio Management Views MDHHS agrees with the finding. Planned Corrective Action For the Prepaid Inpatient Health Plan (PIHP), MI Choice, and Dental Health Plan medic...

Finding 2023-018 Medicaid Cluster, ALN 93.775, 93.777, and 93.778 and Children's Health Insurance Program, ALN 93.767 - Medical Loss Ratio Management Views MDHHS agrees with the finding. Planned Corrective Action For the Prepaid Inpatient Health Plan (PIHP), MI Choice, and Dental Health Plan medical loss ratio (MLR) reporting, MDHHS will revise the instructions and the template; as well as instruct the contracted actuary to include this managed care entity required reporting as part of their MLR review. The MLR instructions for the Medicaid Health Plan Comprehensive Health Care Plan (CHCP) were updated during June 2023 and comparisons were required to be submitted to MDHHS as part of the MLR reporting process. MDHHS will work with the CHCPs, PIHPs, MI Choice, and Dental Health Plans to obtain the comparisons as part of the MLR reporting process. Anticipated Completion Date September 30, 2024 Responsible Individual(s) Keith White, MDHHS

View Audit 309982

Finding 402639 (2023-017)

Significant Deficiency 2023

State of Michigan

MI

Reporting

Finding 2023-017 Medicaid Cluster, ALN 93.775, 93.777, and 93.778 and Children's Health Insurance Program, ALN 93.767 - Refunding of Federal Share of Overpayments Management Views MDHHS agrees with the finding. Planned Corrective Action MDHHS worked with the Adult Services Authorized Payments (ASA...

Finding 2023-017 Medicaid Cluster, ALN 93.775, 93.777, and 93.778 and Children's Health Insurance Program, ALN 93.767 - Refunding of Federal Share of Overpayments Management Views MDHHS agrees with the finding. Planned Corrective Action MDHHS worked with the Adult Services Authorized Payments (ASAP) system vendor to correct the reports used for the preparation of the quarterly statement of expenditures report (CMS-64 report) and updates were deployed to production on September 27, 2023. MDHHS finalized updates in CHAMPS on October 1, 2023, to properly report overpayments. MDHHS will work with the ASAP vendor to implement a system enhancement that identifies overpayments returned late and calculates the corresponding interest due to CMS. Anticipated Completion Date September 30, 2024 Responsible Individual(s) Gina Fleury, MDHHS Carol O’Callaghan, MDHHS Darryl Walker, MDHHS

View Audit 309982

Finding 402638 (2023-016)

Significant Deficiency 2023

State of Michigan

MI

Eligibility HUD Housing Programs Reporting

Finding 2023-016 Medicaid Cluster, ALN 93.775, 93.777, and 93.778 and Children's Health Insurance Program, ALN 93.767 - Provider Eligibility Management Views MDHHS agrees with the finding. Planned Corrective Action MDHHS will amend the managed care contracts to require that signatures are obtained...

Finding 2023-016 Medicaid Cluster, ALN 93.775, 93.777, and 93.778 and Children's Health Insurance Program, ALN 93.767 - Provider Eligibility Management Views MDHHS agrees with the finding. Planned Corrective Action MDHHS will amend the managed care contracts to require that signatures are obtained on the Provider Screening Information Collection Tool (PSICT) forms and returned timely when contracts and waivers are renewed and extended. MDHHS expects that signatures will be obtained on the PSICT forms effective September 2024 for the fiscal year 2025 contract cycle. MDHHS continues to send an annual reminder to the managed care entities to report any change in ownership to MDHHS within 35 days. In addition, MDHHS incorporated a review of provider agreements as part of their monitoring process conducted for all MI Choice Waiver Program (MI Choice) entities. MDHHS’s review of fiscal year 2023 provider agreements for MI Choice entities will be completed by September 30, 2024, and will be ongoing. MDHHS also added language to MI Choice contracts that requires PSICT forms to be returned by September 1 each year and reminders will be sent during August 2024 to complete the tools and submit to MDHHS by this deadline. Anticipated Completion Date September 30, 2024 Responsible Individual(s) Elizabeth Gallagher, MDHHS Latina McCausey, MDHHS

View Audit 309982

Finding 402637 (2023-015)

Significant Deficiency 2023

State of Michigan

MI

Eligibility Internal Control / Segregation of Duties

Finding 2023-015 CHAMPS Eligibility Interface Errors Management Views MDHHS agrees with the finding. Planned Corrective Action Bridges is the system of record for eligibility and produces reports with potential duplicate records for local office staff to review. In addition, CHAMPS is currently de...

Finding 2023-015 CHAMPS Eligibility Interface Errors Management Views MDHHS agrees with the finding. Planned Corrective Action Bridges is the system of record for eligibility and produces reports with potential duplicate records for local office staff to review. In addition, CHAMPS is currently designed to reject potential duplicate records to prevent duplicate payments for the same individuals that already exist in CHAMPS and places these records on a CHAMPS report for review. These two reports could potentially contain the same duplicate records identified by both CHAMPS and Bridges. MDHHS central office will develop a process to reconcile the rejected records identified on the CHAMPS and Bridges reports and ensure that MDHHS is appropriately reviewing those records and making any necessary corrections. Anticipated Completion Date December 2024 Responsible Individual(s) Jamy Hengesbach, MDHHS Mariah Schaefer, MDHHS

View Audit 309982

Finding 402635 (2023-013)

Material Weakness 2023

State of Michigan

MI

Questioned Costs Eligibility Material Weakness § 200.516

Finding 2023-013 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 finding. Planned Corrective Action MDHHS continues to pursue other data sources for income verification and other s...

Finding 2023-013 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 finding. Planned Corrective Action MDHHS continues to pursue other data sources for income verification and other system enhancements so that all case data is available to all reviewers. In addition, 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 and loaded to the electronic case file. Once this is completed, MDHHS will develop mandatory training protocols for eligibility workers. Lastly, MDHHS has been working since 2018 to ensure correct eligibility classifications in Bridges at the time of payment and a system change was implemented in April 2021 to correct the issue. All new cases are being correctly routed. MDHHS originally expected to have all cases corrected at the end of the public health emergency (PHE) unwind (July 2024), however, due to some of the mitigation strategies that the Centers for Medicare and Medicaid Services (CMS) developed to ensure children did not lose eligibility, not all cases had their coding updated when they were renewed. MDHHS expects that all existing cases will be updated by May 2025. Anticipated Completion Date May 2025 Responsible Individual(s) Logan Dreasky, MDHHS Brant Cole, MDHHS Mariah Schaefer, MDHHS

View Audit 309982 Questioned Costs: $1

Finding 402634 (2023-011)

Significant Deficiency 2023

State of Michigan

MI

Reporting

Finding 2023-011 MDHHS - FFATA Reporting Management Views MDHHS agrees with the finding. Planned Corrective Action MDHHS updated the grantee profile in the Electronic Grants Administration and Management System (EGrAMS) with information that is obtained from the grantee and was missing or incorrec...

Finding 2023-011 MDHHS - FFATA Reporting Management Views MDHHS agrees with the finding. Planned Corrective Action MDHHS updated the grantee profile in the Electronic Grants Administration and Management System (EGrAMS) with information that is obtained from the grantee and was missing or incorrect at the time of required reporting. To ensure the query properly retrieved all required FFATA data elements, MDHHS corrected the accounting template that populates the funding source table for one of the subawards. The MDHHS Federal Reporting Section will ensure all federal grant awards are recorded in SIGMA and included on the department’s Grants Received Report. The Grants Received Report will be maintained on the department’s SharePoint site for use by those within the department. All data elements required to comply with federal funding requirements, such as FFATA, will be included on the Grants Received Report. In the event data elements are missing from the report, the MDHHS Federal Reporting Section will follow up with the awarding agency, program area, or others to update the missing data elements within 30 days of receipt of the award. The Bureau of Grants and Purchasing will use the information from the Grants Received Report to report the information in the FFATA Subaward Reporting System in accordance with FFATA requirements. Anticipated Completion Date September 30, 2024 Responsible Individual(s) Jeanette Hensler, MDHHS Steve Bendele, MDHHS

View Audit 309982

Finding 402632 (2023-005)

Significant Deficiency 2023

State of Michigan

MI

Eligibility Internal Control / Segregation of Duties

Finding 2023-005 CHAMPS General Controls Management Views Although MDHHS and DTMB delayed the implementation of the State of Michigan (SOM) tailored configurations, DTMB disagrees that during the audit period the system contained potentially vulnerable database configurations and disagrees that DTM...

Finding 2023-005 CHAMPS General Controls Management Views Although MDHHS and DTMB delayed the implementation of the State of Michigan (SOM) tailored configurations, DTMB disagrees that during the audit period the system contained potentially vulnerable database configurations and disagrees that DTMB cannot ensure the security of the data. DTMB has implemented and continues to implement the manufacturer’s recommendations regarding security configurations and performs regular database and operating system patching. Additionally, the databases reside in restricted trusted internal security zones, protected by firewalls, which are specific to each application and database, in conjunction with intrusion protection, antivirus software, and SOM standard security safeguards. Planned Corrective Action DTMB will implement the SOM tailored configurations by July 31, 2024. Anticipated Completion Date July 31, 2024 Responsible Individual(s) Nathan Buckwalter, DTMB

View Audit 309982

Finding 402594 (2023-037)

Significant Deficiency 2023

State of Michigan

MI

Subrecipient Monitoring

Finding 2023-037 CCDF Cluster, ALN 93.575 and 93.596 - Subaward Information Management Views MiLEAP agrees with the finding. Planned Corrective Action MiLEAP will develop procedures for reviewing award documents, which will include verifying a unique entity identifier and federal award project d...

Finding 2023-037 CCDF Cluster, ALN 93.575 and 93.596 - Subaward Information Management Views MiLEAP agrees with the finding. Planned Corrective Action MiLEAP will develop procedures for reviewing award documents, which will include verifying a unique entity identifier and federal award project description are included on each award. Anticipated Completion Date October 1, 2024 Responsible Individual(s) Lisa Brewer Walraven, MiLEAP

View Audit 309982

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