Corrective Action Plans

Finding 397208 (2023-022)

Material Weakness 2023

State of Washington C/o Office of Financial Management

WA

Subrecipient Monitoring Eligibility Internal Control / Segregation of Duties

Finding: The Housing Finance Commission did not have adequate internal controls over eligibility requirements for the Homeowner Assistance Fund program. Questioned Costs: Assistance Listing # 21.026 COVID-19 Amount $0 Status: Corrective action in progress Corrective Action: The Commissi...

Finding: The Housing Finance Commission did not have adequate internal controls over eligibility requirements for the Homeowner Assistance Fund program. Questioned Costs: Assistance Listing # 21.026 COVID-19 Amount $0 Status: Corrective action in progress Corrective Action: The Commission will take the following corrective actions to strengthen controls over eligibility requirements for the Homeowner Assistance Fund (HAF) program: • Select an increased percentage of approved, denied, and withdrawn HAF applications that have previously been reviewed by the contractor, as part of the Quality Control process, for a secondary review by program staff. • Review a selection of HAF applications independent of the Quality Control process performed by the contractor. • Review a selection of approved HAF applications prior to disbursing funds to confirm eligibility determinations are proper. Completion Date: Estimated June 2024 Agency Contact: Lucas Loranger Senior Finance Director 1000 Second Ave, Suite 2700 Seattle, WA 98104-3601 (206) 464-7139 Lucas.Loranger@wshfc.org

View Audit 306534

Finding 397207 (2023-021)

Material Weakness 2023

State of Washington C/o Office of Financial Management

WA

Subrecipient Monitoring Internal Control / Segregation of Duties

Finding: The Department of Commerce did not have adequate internal controls over federal requirements to ensure subawards for the Emergency Rental Assistance program contained the correct federal award identification elements. Questioned Costs: Assistance Listing # 21.023 COVID-19 Amount $0 St...

Finding: The Department of Commerce did not have adequate internal controls over federal requirements to ensure subawards for the Emergency Rental Assistance program contained the correct federal award identification elements. Questioned Costs: Assistance Listing # 21.023 COVID-19 Amount $0 Status: Corrective action complete Corrective Action: During 2022, the Department identified the need to determine subrecipient and contractor classifications on the face sheet of all contracts. The Department implemented the following actions: • Added a check box to all federal contract template face sheets to designate whether a contract is issued to a subrecipient or contractor. • Added all federal subaward required data elements to the face sheet. The Department followed these updated procedures until the program ended June 30, 2023. Completion Date: October 2022 Agency Contact: Gena Allen, CFE Internal Control Officer PO Box 42525-2525 Olympia, WA 98504 (360) 480-5149 Gena.Allen@Commerce.wa.gov

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Finding 397206 (2023-020)

Material Weakness 2023

State of Washington C/o Office of Financial Management

WA

Subrecipient Monitoring

Finding: The Department of Commerce did not have adequate internal controls over and did not comply with subrecipient monitoring requirements for the Emergency Rental Assistance program. Questioned Costs: Assistance Listing # 21.023 COVID-19 Amount $0 Status: Corrective action complete C...

Finding: The Department of Commerce did not have adequate internal controls over and did not comply with subrecipient monitoring requirements for the Emergency Rental Assistance program. Questioned Costs: Assistance Listing # 21.023 COVID-19 Amount $0 Status: Corrective action complete Corrective Action: The U.S. Department of Treasury funding for this federal program ended June 30, 2023. As a result of a similar finding issued in fiscal year 2022, the Department has implemented procedures to strengthen internal controls to ensure compliance with the subrecipient fiscal monitoring requirements and confirm expenditures are allowable and properly supported. In fiscal year 2023, the program hired a new employee to assist with program monitoring duties. As of January 2024, the Department implemented the following procedures: • Increased the number of client files reviewed during program monitoring from five to ten for each grantee. • Expanded monthly monitoring to include the collection and review of specific back-up documentation to accompany all payment requests to ensure payments are allowable and properly supported. Completion Date: January 2024 Agency Contact: Gena Allen, CFE Internal Control Officer PO Box 42525 Olympia, WA 98504-2525 (360) 480-5149 Gena.Allen@Commerce.wa.gov

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Finding 397205 (2023-019)

Material Weakness 2023

State of Washington C/o Office of Financial Management

WA

Reporting Subrecipient Monitoring Internal Control / Segregation of Duties

Finding: The Department of Commerce did not have adequate internal controls over reporting requirements for the Emergency Rental Assistance program. Questioned Costs: Assistance Listing # 21.023 COVID-19 Amount $0 Status: Corrective action complete Corrective Action: The Department has imple...

Finding: The Department of Commerce did not have adequate internal controls over reporting requirements for the Emergency Rental Assistance program. Questioned Costs: Assistance Listing # 21.023 COVID-19 Amount $0 Status: Corrective action complete Corrective Action: The Department has implemented procedures to strengthen internal controls and eliminate possible errors to ensure required approval of quarterly financial reports (SF-425) is documented within the Contracts Management System (CMS). The Accounting Department is responsible for the completion of the SF-425. Accounting management staff, or their delegate, utilize a newly created tracking log to document the date approval is submitted within CMS. The documentation of approval confirms the completion of management review prior to submission of the report. Funding for this program ended June 30, 2023. The Department will follow these updated procedures for other federal programs with similar reporting requirements. The conditions noted in this finding were previously reported in finding 2022-017. Completion Date: October 2023 Agency Contact: Gena Allen, CFE Internal Control Officer PO Box 42525 Olympia, WA 98504-2525 (360) 480-5149 Gena.Allen@Commerce.wa.gov

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Finding 397204 (2023-018)

Material Weakness 2023

State of Washington C/o Office of Financial Management

WA

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

Finding: The Department of Commerce did not have adequate internal controls over and did not comply with reporting requirements for the Emergency Rental Assistance program. Questioned Costs: Assistance Listing # 21.023 COVID-19 Amount $0 Status: Corrective action complete Corrective Actio...

Finding: The Department of Commerce did not have adequate internal controls over and did not comply with reporting requirements for the Emergency Rental Assistance program. Questioned Costs: Assistance Listing # 21.023 COVID-19 Amount $0 Status: Corrective action complete Corrective Action: In November 2023, the Homelessness Assistance Unit implemented the following procedures to strengthen internal controls and ensure compliance with reporting requirements for federal programs: • Monthly expenditures are reviewed and approved by the program coordinator and federal team manager before being submitted into the federal reporting system. The expenditure approval is documented via email. • Annual report data is reviewed and approved by the federal team manager and documented via email. • Annual federal reports are submitted to the required federal department and are saved and posted to the Commerce webpage. Funding for this program ended June 30, 2023. The Department will follow these updated procedures for other federal programs with similar reporting requirements. The conditions noted in this finding were previously reported in finding 2022-017. Completion Date: November 2023 Agency Contact: Gena Allen, CFE Internal Control Officer PO Box 42525 Olympia, WA 98504-2525 (360) 480-5149 Gena.Allen@Commerce.wa.gov

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Finding 397203 (2023-017)

Material Weakness 2023

State of Washington C/o Office of Financial Management

WA

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles § 200.1 § 200.403 § 200.410 § 200.516

Finding: The Department of Commerce did not have adequate internal controls over and did not comply with requirements to ensure payments to subrecipients of the Emergency Rental Assistance program were allowable and properly supported. Questioned Costs: Assistance Listing # 21.023 COVID-19 A...

Finding: The Department of Commerce did not have adequate internal controls over and did not comply with requirements to ensure payments to subrecipients of the Emergency Rental Assistance program were allowable and properly supported. Questioned Costs: Assistance Listing # 21.023 COVID-19 Amount $4,123,486 Status: Corrective action complete Corrective Action: The funding for the Emergency Rental Assistance program ended on June 30, 2023. The Department is no longer funding this program. To address the control deficiencies reported in the prior year’s finding, the Department improved internal control processes, resulting in improved compliance. The Department strives to meet all federal requirements and any repayment of questioned costs will be determined through the normal audit resolution process with the U.S. Treasury. The conditions noted in this finding were previously reported in finding 2022-016. Completion Date: July 2023 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 306534 Questioned Costs: $1

Finding 397202 (2023-016)

Material Weakness 2023

State of Washington C/o Office of Financial Management

WA

Subrecipient Monitoring § 200.332

Finding: The Washington State Department of Transportation did not have adequate internal controls over and did not comply with subrecipient monitoring requirements for the Formula Grants for Rural Areas program. Questioned Costs: Assistance Listing # 20.509 Amount $0 Status: Corrective action...

Finding: The Washington State Department of Transportation did not have adequate internal controls over and did not comply with subrecipient monitoring requirements for the Formula Grants for Rural Areas program. Questioned Costs: Assistance Listing # 20.509 Amount $0 Status: Corrective action in progress Corrective Action: The Washington State Department of Transportation concurs with the finding. As of October 2023, the Public Transportation Division (PTD) had conducted all five site visits identified in the condition of this finding. The PTD is also planning on implementing the auditor’s recommendations, specifically to: • Update the PTD policies and procedures to document the risk-based site visit approach more accurately. This update will clarify how an organization’s risk assessment score impacts the timing and number of administrative and financial site visits. This update will not impact capital reviews and drug and alcohol site visits because PTD staff conduct them every two years regardless of risk assessment scores. • Evaluate new ways for management, supervisors, and staff to monitor site visit completion and established due dates more effectively. Once a new process is developed, management will ensure policies and/or procedures are updated and communicate the new process to impacted staff. Completion Date: Estimated June 2024 Agency Contact: Jesse Daniels External Audit Liaison PO Box 47320 Olympia, WA 98504-7320 (360) 705-7035 danielje@wsdot.wa.gov

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Finding 397201 (2023-015)

Material Weakness 2023

State of Washington C/o Office of Financial Management

WA

Questioned Costs Subrecipient Monitoring Cash Management § 200.1 § 200.410 § 200.516

Finding: The Washington State Department of Transportation did not have adequate internal controls over and did not comply with cash management requirements for the Formula Grants for Rural Areas program. Questioned Costs: Assistance Listing # 20.509 Amount $41,555 Status: Corrective action com...

Finding: The Washington State Department of Transportation did not have adequate internal controls over and did not comply with cash management requirements for the Formula Grants for Rural Areas program. Questioned Costs: Assistance Listing # 20.509 Amount $41,555 Status: Corrective action complete Corrective Action: The audit identified a payment that was entered into the Electronic Clearing House Operation (ECHO) system with incorrect project information. The Department has since implemented additional controls to help ensure the draws of program funds are timely and accurate and are drawn for the correct program. To address the audit recommendations, the Department: • Assigned Project Support and Receivable (PS&R) staff to submit Public Transportation ECHO draws. Two additional staff have been identified as backup in this process to ensure draws are processed timely. • Rescheduled the entry of draw information into the ECHO system to the morning to allow for timely corrections as needed. • Updated the ECHO system to allow automatic confirmation email for payments entered into the system. Additionally, • The PS&R Manager will automatically receive draw confirmation emails and conduct a review and check as the draws are being submitted. • Additional checks and balances will be performed by the person entering information into the ECHO system. • The Public Transportation division has a validation process in place for staff to check the amounts with the project. The Department will continue to review procedures regularly and update as required to ensure compliance. The questioned costs identified in the audit have been reimbursed to the incorrectly charged federal program. Completion Date: October 2023 Agency Contact: Jesse Daniels External Audit Liaison PO Box 47320 Olympia, WA 98504-7320 (360) 705-7035 danielje@wsdot.wa.gov

View Audit 306534 Questioned Costs: $1

Finding 397197 (2023-014)

Material Weakness 2023

State of Washington C/o Office of Financial Management

WA

Subrecipient Monitoring Internal Control / Segregation of Duties Special Tests & Provisions

Finding: The Washington State Department of Transportation did not have adequate internal controls over and did not comply with quality assurance program requirements to ensure materials conformed to approved plans and specifications, and that only qualified personnel performed testing for projects...

Finding: The Washington State Department of Transportation did not have adequate internal controls over and did not comply with quality assurance program requirements to ensure materials conformed to approved plans and specifications, and that only qualified personnel performed testing for projects funded by the Highway Planning and Construction Cluster. Questioned Costs: Assistance Listing # 20.205 Amount $0 Status: Corrective action in progress Corrective Action: The Department is committed to ensuring that our grant programs comply with federal regulations related to quality assurance (QA) requirements and safeguarding that materials and workmanship conform to approved plans and specifications through testing, inspections, or certifications. The Department has worked closely with the Federal Highway Administration (FHWA) on our QA program and continues to receive feedback on the strength of our program. The Department has been working towards replacement of the Record of Materials (ROM) legacy system; therefore, it was not practical to modify the system to help correct issues previously reported in the fiscal year 2022 audit. During fiscal year 2023, the Department eliminated the practice requiring updates to the ROM within 30 days of payment and instead relied on the required documentation as evidence of proper materials acceptance. Due to the timing of implementation, these changes were not fully reflected in the current year’s audit. In January 2023, as a result of recommendations from the fiscal year 2022 audit, the Department modified its practice related to how tester data is reviewed and entered into the tester certification tracking system. All offices now funnel tester data to the Headquarters Quality Assurance Program for review and entry. These procedure changes were communicated to appropriate staff and are reflected in the Construction Manual, which was reviewed and approved by FHWA. The Department is also assessing replacement of additional software legacy programs associated with the QA program. The Department will continue to improve the QA program while waiting for the new software programs to be fully developed. To address the audit recommendations, the Department’s Construction Division will examine current policies and procedures/practices related to the audit issues. The Department will: • Update policies and procedures, including the Department’s Construction Manual (M46-01), as needed to ensure staff practices meet federal regulations. Updates will also include other clarifications to address documentation and evidence of compliance, and a reasonable level of controls regarding materials testing, inspections, certification, acceptance, and tester certifications. Completion Date: Agency Contact: • Obtain approval of updates to the Construction Manual from the FHWA. • Communicate changes in policies and procedures to division staff and stakeholders. • Provide training to Project Engineering Office staff to emphasize QA program requirements. The conditions noted in this finding were previously reported in findings 2022-011, 2021-011, 2020-017 and 2019-019. Completion Date: Estimated June 2024 Agency Contact: Jesse Daniels External Audit Liaison PO Box 47320 Olympia, WA 98504 (360) 705-7035 danielje@wsdot.wa.gov

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Finding 397196 (2023-013)

Material Weakness 2023

State of Washington C/o Office of Financial Management

WA

Subrecipient Monitoring Internal Control / Segregation of Duties Special Tests & Provisions

Finding: The Washington State Department of Transportation did not have adequate internal controls over and did not comply with requirements to collect certified payrolls from contractors on projects funded by the Highway Planning and Construction program. Questioned Costs: Assistance Listing # ...

Finding: The Washington State Department of Transportation did not have adequate internal controls over and did not comply with requirements to collect certified payrolls from contractors on projects funded by the Highway Planning and Construction program. Questioned Costs: Assistance Listing # 20.205 Amount $0 Status: Corrective action in progress Corrective Action: In April 2019 and July 2020, the Department received management decision letters from the Federal Highway Administration (FHWA) in response to similar findings for the fiscal years 2018 and 2019, respectively, which stated: • FHWA approved the Department’s Construction Manual and Standard Specifications and confirmed that documented procedures contain the necessary controls to ensure reasonable compliance with 29 CFR 5.5 and the Davis-Bacon and Related Acts. • FHWA agreed that current processes in place are reasonable and satisfy the intent of the Department of Labor’s certified payroll requirements. • FHWA considers this finding to be resolved. The Department continues to strive for improvements in this area. To further address the audit recommendations, the Department is planning on taking the following actions by December 2024: • Update the Construction Manual to include language for certified payroll collection requirements when no work is performed on federal projects. • Review and update the Construction Manual, as needed, to clarify the authority to withhold payments regarding federal wage administration. • Standardize the required frequency of checking for certified payroll collection and the methods to document tracking. • Define “timely,” given the circumstances surrounding weekly collection of certified payrolls and sanctions on a monthly pay estimate, including: o Defining the timeline when the Department must communicate overdue certified payroll to the contractor and the allowable methods of that communication. o Defining the timeline for determining when the Department must consider imposing sanctions on the contractor after a certified payroll is overdue. o Defining the minimum required documentation that sanctions (e.g., partial deferral of payment) were considered against the contractor regarding an overdue certified payroll. • Communicate any changes to the Construction Manual to appropriate construction staff and partners. • Continue to work with our federal grantor, FHWA, for any further actions needed to resolve this finding. Completion Date: Agency Contact: Estimated December 2024 Jesse Daniels External Audit Liaison PO Box 47320 Olympia, WA 98504-7320 (360) 705-7035 danielje@wsdot.wa.gov

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Finding 397195 (2023-012)

Material Weakness 2023

State of Washington C/o Office of Financial Management

WA

Subrecipient Monitoring Internal Control / Segregation of Duties

Finding: The Washington State Department of Transportation did not have adequate internal controls over and did not comply with requirements to perform risk assessments for subrecipients of the Highway Planning and Construction program. Questioned Costs: Assistance Listing # 20.205 Amount $0 St...

Finding: The Washington State Department of Transportation did not have adequate internal controls over and did not comply with requirements to perform risk assessments for subrecipients of the Highway Planning and Construction program. Questioned Costs: Assistance Listing # 20.205 Amount $0 Status: Corrective action in progress Corrective Action: The Washington State Department of Transportation (WSDOT) is committed to ensuring our grant programs comply with federal regulations regarding required risk assessments. Risk assessments for subrecipients under the Federal Highway Administration grant programs are the responsibility of WSDOT’s Regional Local Programs Engineers, located in the six WSDOT regions. The Department has attempted to complete a risk assessment at each phase of a project, however, staff turnover contributed to the lack of consistency and timeliness in completing these assessments. To help ensure consistency, the Department has updated position descriptions for Local Programs Engineers to reflect this requirement. The Department will: • Continue to communicate with Regional Local Programs Engineers to ensure risk assessments are performed and properly documented in accordance with the risk assessment program guidelines. • Continue to communicate with regional management to ensure required monitoring activities by staff are tracked, and the status of these activities are reported as part of annual performance evaluations. Completion Date: Estimated June 2024 Agency Contact: Jesse Daniels External Audit Liaison PO Box 47320 Olympia, WA 98504-7320 (360) 705-7035 danielje@wsdot.wa.gov

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Finding 397189 (2023-010)

Material Weakness 2023

State of Washington C/o Office of Financial Management

WA

Subrecipient Monitoring Internal Control / Segregation of Duties Special Tests & Provisions

Finding: The Employment Security Department did not have adequate internal controls over and did not comply with requirements to ensure it profiled all claimants under the Unemployment Insurance program to identify people likely to need reemployment services and ensure staff providing those service...

Finding: The Employment Security Department did not have adequate internal controls over and did not comply with requirements to ensure it profiled all claimants under the Unemployment Insurance program to identify people likely to need reemployment services and ensure staff providing those services received required training. Questioned Costs: Assistance Listing # 17.225 17.225 COVID-19 Amount $0 Status: Corrective action in progress Corrective Action: The Department concurs with the recommendation to review the calculation of the profile score within the Unemployment Tax and Benefit (UTAB) system. The Department will explore a plan and review resource allocations to more effectively validate the profile score to ensure that coefficient values are correctly determined and assigned by the UTAB system. The Department partially concurs with the recommendation to reconcile the UTAB and Reemployment Appointment Scheduler (RAS) interface. There is currently a process in place to notify the RAS team if a record fails at the time of data transmission between UTAB and RAS. The Department will review its processes to verify the complete UTAB exit file was successfully received by RAS. The Department does not concur with the recommendation to implement additional internal controls over the claimant profiling process. The Department has coordinated closely with the U.S. Department of Labor (USDOL) to conduct the randomized control trial (RCT) to evaluate the Reemployment Services and Eligibility Assessments (RESEA). The Department has written approval from USDOL to utilize this method concurrently with the program’s established process. All program-eligible applicants are scored and provided a risk profile score based on both established standards and a random score for the purposes of carrying out the RCT. The Department does not concur with the recommendation to ensure all employees receive the required RESEA training before providing reemployment screening services to claimants. The Department has internal controls in place to ensure training requirements are met and staff are not granted access to schedule appointments for RESEA services without first receiving the required training. The exceptions noted by the auditors relate to the annual refresher training. In the fall of 2022, the Department implemented procedures to formally track the refresher training completed by RESEA staff. The audit exceptions identified were for two staff not currently providing RESEA services to clients. These individuals will receive the refresher training prior to providing RESEA services going forward. Completion Date: Estimated April 2025 Agency Contact: Jay Summers External Audit Manager PO Box 9046 Olympia, WA 98507-9046 (360) 529-6718 Joshua.Summers@esd.wa.gov

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Finding 397188 (2023-009)

Material Weakness 2023

State of Washington C/o Office of Financial Management

WA

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

Finding: The Employment Security Department did not have adequate internal controls over and did not comply with federal requirements to conduct case reviews for the Benefit Accuracy Measurement program of the Unemployment Insurance program in a timely manner. Questioned Costs: Assistance Listin...

Finding: The Employment Security Department did not have adequate internal controls over and did not comply with federal requirements to conduct case reviews for the Benefit Accuracy Measurement program of the Unemployment Insurance program in a timely manner. Questioned Costs: Assistance Listing # 17.225 17.225 COVID-19 Amount $0 Status: Corrective action in progress Corrective Action: Historically, the Benefit Accuracy Measurement (BAM) unit has been challenged to maintain full levels of staffing. Staff turnover, long training requirements, and unique skill sets make these positions difficult to maintain. During the prior audit period, the Department was in a hiring freeze for Unemployment Insurance administrative funding, furthering the challenge to fully staff the unit and meet program requirements. The hiring freeze was lifted in April 2023 and the unit began filling vacant positions in May 2023. Due to the lengthy training timelines for new positions, the Department anticipated the unit would not meet federally mandated performance measures for case reviews for state fiscal year 2023. The Department continues to partner and frequently communicate with the U.S. Department of Labor (USDOL) Regional Offices to discuss staffing and training models. The Quality Assurance Manager and the Case Review Supervisor are committed to routinely monitor caseload, workload, and the overall assurance of meeting the BAM operations performance goals and measures as set forth by USDOL. The conditions noted in this finding were previously reported in findings 2022-006, 2021-005, and 2020-011. Completion Date: Estimated March 2025 Agency Contact: Jay Summers External Audit Manager PO Box 9046 Olympia, WA 98507-9046 (360) 529-6718 Joshua.Summers@esd.wa.gov

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Finding 397187 (2023-008)

Significant Deficiency 2023

State of Washington C/o Office of Financial Management

WA

Subrecipient Monitoring Internal Control / Segregation of Duties Equipment & Real Property Management

Finding: The Employment Security Department did not have adequate internal controls to ensure it submitted accurate monthly reports for the Unemployment Insurance program. Questioned Costs: Assistance Listing # 17.225 17.225 COVID-19 Amount $0 Status: Corrective action complete Correctiv...

Finding: The Employment Security Department did not have adequate internal controls to ensure it submitted accurate monthly reports for the Unemployment Insurance program. Questioned Costs: Assistance Listing # 17.225 17.225 COVID-19 Amount $0 Status: Corrective action complete Corrective Action: In response to the prior year’s finding, the Department immediately implemented the secondary review of the monthly ETA 9055 performance reports. However, the auditor’s recommendation and the Department’s implementation occurred after state fiscal year 2023 had begun. The Department expects adequate internal controls to be in place and functioning for fiscal year 2024 and onward. The conditions noted in this finding were previously reported in finding 2022-005. Completion Date: May 2023 Agency Contact: Jay Summers External Audit Manager PO Box 9046 Olympia, WA 98507-9046 (360) 529-6718 Joshua.Summers@esd.wa.gov

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Finding 397186 (2023-007)

Material Weakness 2023

State of Washington C/o Office of Financial Management

WA

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

Finding: The Employment Security Department did not have adequate internal controls to ensure it submitted accurate financial reports for the Unemployment Insurance program. Questioned Costs: Assistance Listing # 17.225 17.225 COVID-19 Amount $0 Status: Corrective action complete Correct...

Finding: The Employment Security Department did not have adequate internal controls to ensure it submitted accurate financial reports for the Unemployment Insurance program. Questioned Costs: Assistance Listing # 17.225 17.225 COVID-19 Amount $0 Status: Corrective action complete Corrective Action: The Department has implemented procedures to ensure the ETA 9130 and ETA 2112 reports have a secondary review by management prior to submission to the federal grantor. Additionally, documentation of the review and submission will be maintained. Completion Date: February 2024 Agency Contact: Jay Summers External Audit Manager PO Box 9046 Olympia, WA 98507-9046 (360) 529-6718 Joshua.Summers@esd.wa.gov

View Audit 306534

Finding 397185 (2023-006)

None 2023

State of Washington C/o Office of Financial Management

WA

Questioned Costs Allowable Costs / Cost Principles Eligibility § 200.1 § 200.410 § 200.516

Finding: The Employment Security Department made improper payments to ineligible beneficiaries of the Unemployment Insurance program. Questioned Costs: Assistance Listing # 17.225 17.225 COVID-19 Amount $603 Status: Corrective action not taken Corrective Action: The Department does not ...

Finding: The Employment Security Department made improper payments to ineligible beneficiaries of the Unemployment Insurance program. Questioned Costs: Assistance Listing # 17.225 17.225 COVID-19 Amount $603 Status: Corrective action not taken Corrective Action: The Department does not concur with the finding. The State Auditor’s Office (SAO) made the assertion that the Department incorrectly interpreted guidance in the Unemployment Insurance Program Letter (UIPL) No. 16-20 requiring claimants to provide proof of employment to receive Pandemic Unemployment Assistance (PUA) payments. However, the section cited by SAO was paragraph b(ii) which only lays out the requirements for establishing the respond-by dates for providing documentation for review. The deadline for responses is different depending on whether the PUA claim was filed before January 31, 2021, or on/after that date. This paragraph does not establish the requirements for payment or non-payment of PUA weeks. In our finding response, the Department cited section C.2 of the UIPL, which states: If, in that timeframe, the individual fails to provide documentation or fails to show good cause to have the deadline extended, an overpayment must be established for all of the weeks paid beginning with the week ending January 2, 2021. This is because the individual cannot be deemed ineligible for a week of unemployment ending before the date of enactment solely for failure to submit documentation. Therefore, the three cases identified by SAO should not be exceptions under this guidance. Further, the Department received guidance from the U.S. Department of Labor on January 11, 2021, which confirmed the proper methodology used by the Department. Completion Date: Not Applicable Agency Contact: Jay Summers External Audit Manager PO Box 9046 Olympia, WA 98507-9046 (360) 529-6718 Joshua.Summers@esd.wa.gov

View Audit 306534 Questioned Costs: $1

Finding 397184 (2023-005)

Material Weakness 2023

State of Washington C/o Office of Financial Management

WA

Subrecipient Monitoring

Finding: The Office of Superintendent of Public Instruction did not have adequate internal controls over and was not compliant with requirements to perform risk assessments for subrecipients of the Child and Adult Care Food Program. Questioned Costs: Assistance Listing # 10.558 Amount $0 S...

Finding: The Office of Superintendent of Public Instruction did not have adequate internal controls over and was not compliant with requirements to perform risk assessments for subrecipients of the Child and Adult Care Food Program. Questioned Costs: Assistance Listing # 10.558 Amount $0 Status: Corrective action complete Corrective Action: The Office has established and implemented the following internal controls to ensure subrecipients are monitored according to program requirements: • Conduct a risk assessment annually on approved subrecipients during each renewal cycle. • Utilize the risk assessment results, Washington Integrated Nutrition System data, and USDA program specific guidance to determine how subrecipients will be monitored in the coming year. • Follow a risk assessment process to identify and track the monitoring status of each subrecipient. Completion Date: November 2023 Agency Contact: Chaundi Barbosa CACFP Director PO Box 47200 Olympia, WA 98504-7200 (360) 764-0411 Chaundi.Barbosa@k12.wa.us

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Finding 397183 (2023-004)

Material Weakness 2023

State of Washington C/o Office of Financial Management

WA

Subrecipient Monitoring Allowable Costs / Cost Principles Material Weakness

Finding: The Office of Superintendent of Public Instruction did not have internal controls over and did not comply with requirements to verify single audits were completed for all subrecipients of the Child and Adult Care Food Program. Questioned Costs: Assistance Listing # 10.558 Amount $0 ...

Finding: The Office of Superintendent of Public Instruction did not have internal controls over and did not comply with requirements to verify single audits were completed for all subrecipients of the Child and Adult Care Food Program. Questioned Costs: Assistance Listing # 10.558 Amount $0 Status: Corrective action in progress Corrective Action: The Office will implement internal controls to ensure all subrecipients requiring a single audit are identified and follow up on any program-related findings that require a management decision. Internal controls will include: • Updating procedures on maintaining the subrecipient audit tracking log. • Implementing a training plan for the Child Nutrition Services fiscal team, which includes cross training and completing the State Auditor’s Office subrecipient monitoring training. The Office will follow up with the subrecipient identified in the audit to ensure it obtains its required single audit. Completion Date: Estimated August 2024 Agency Contact: Debbie Libra Fiscal & Claims Supervisor PO Box 47200 Olympia, WA 98504-7200 (564) 233-8620 Debbie.libra@k12.wa.us

View Audit 306534

Finding 397182 (2023-003)

Material Weakness 2023

State of Washington C/o Office of Financial Management

WA

Subrecipient Monitoring Internal Control / Segregation of Duties

Finding: The Office of Superintendent of Public Instruction did not have adequate internal controls over and did not comply with requirements to ensure it communicated federal award identification elements to subrecipients of the Child and Adult Care Food Program. Questioned Costs: Assistance Li...

Finding: The Office of Superintendent of Public Instruction did not have adequate internal controls over and did not comply with requirements to ensure it communicated federal award identification elements to subrecipients of the Child and Adult Care Food Program. Questioned Costs: Assistance Listing # 10.558 Amount $0 Status: Corrective action in progress Corrective Action: In response to the audit finding, the Office: • Will establish policies and procedures and internal controls to communicate federal award information and requirements to all subrecipients. • Is consulting with the U.S. Department of Agriculture for additional guidance on communicating subaward information for programs that are reimbursement based. Completion Date: Estimated August 2024 Agency Contact: Leanne Eko Chief Nutrition Officer PO Box 47200 Olympia, WA 98504-7200 (360) 725-0410 Leanne.eko@k12.wa.us

View Audit 306534

Finding 397181 (2023-002)

Material Weakness 2023

State of Washington C/o Office of Financial Management

WA

Subrecipient Monitoring

Finding: The Office of Superintendent of Public Instruction did not have adequate internal controls over and did not comply with required monitoring of subrecipients of the Child and Adult Care Food Program. Questioned Costs: Assistance Listing # 10.558 Amount $0 Status: Corrective action ...

Finding: The Office of Superintendent of Public Instruction did not have adequate internal controls over and did not comply with required monitoring of subrecipients of the Child and Adult Care Food Program. Questioned Costs: Assistance Listing # 10.558 Amount $0 Status: Corrective action complete Corrective Action: The Office has established and implemented the following internal controls to ensure subrecipients are monitored according to program requirements: • A procedure where the program supervisor and program director assign and track the monitoring activities that have been assigned to staff. • A procedure utilizing a data dashboard to track subrecipient review progress and completion. Completion Date: November 2023 Agency Contact: Chaundi Barbosa CACFP Director PO Box 47200 Olympia, WA 98504-7200 (360) 764-0411 Chaundi.Barbosa@k12.wa.us

View Audit 306534

Finding 397179 (2023-001)

None 2023

Chinatown Manpower Project, INC

NY

Reporting

CMP continues to make every effort towards recruitment of appropriate staff to fill vacant positions while temporarily hiring consultants to handle day-to-day processes.

View Audit 306529

Finding 397176 (2023-003)

Significant Deficiency 2023

Niobrara County School District No. 1

WY

December 28, 2023 To Whom It May Concern: This letter is in response to the audit findings identified in the annual district financial report for fiscal year ended June 30, 2023 issued by Leo Riley & Co. This letter addresses the following compliance findings: 2023-001 Separation of Duties The Di...

December 28, 2023 To Whom It May Concern: This letter is in response to the audit findings identified in the annual district financial report for fiscal year ended June 30, 2023 issued by Leo Riley & Co. This letter addresses the following compliance findings: 2023-001 Separation of Duties The District is unable to assign a different person to each stage of the transaction cycle due to lack of personnel. The District will brief new Trustees on their role in internal control and stress the importance of their oversight responsibilities. In addition, District will consider providing training on detecting abuse and fraud as well as ordering printed materials for distributions to Trustees. 2023-002 Budget Noncompliance The District is aware that the budget was exceeded and has implemented procedures to monitor and amend the budget in accordance with Wyoming State Statute. 2023-003 Separation of Duties The District is unable to assign a different person to each stage of the transaction cycle due to lack of personnel. The District will brief new Trustees on their role in internal control and stress the importance of their oversight responsibilities. In addition, District will consider providing training on detecting abuse and fraud as well as ordering printed materials for distributions to Trustees. Sincerely, Katie Caffee Business Manager

View Audit 306527

Finding 397174 (2023-005)

Material Weakness 2023

Dakota Plains Legal Services, Inc.

SD

Special Tests & Provisions Subrecipient Monitoring Material Weakness

Legal Services Corporation CFDA #09-742018 Legal Services Corporation - Basic Field - General CFDA #09-742018 Legal Services Corporation - Basic Field - Native American Special Tests & Provisions -Accounting Requirements Material Weakness in Internal Control over Compliance Condition: DPLS has not...

Legal Services Corporation CFDA #09-742018 Legal Services Corporation - Basic Field - General CFDA #09-742018 Legal Services Corporation - Basic Field - Native American Special Tests & Provisions -Accounting Requirements Material Weakness in Internal Control over Compliance Condition: DPLS has not performed an annual risk assessment since 2021, nor tested an emergency disaster prevention and recovery plan. Management Response: DPLS is going to seek outside assistance to have a complete risk assessment and review of our emergency disaster and recovery plans completed. After the assessment is finished, management will review the findings, and make every effort to enact the recommendations made to the program. Responsible Individuals: Lori Stanford, Deputy Director, Tom Mortland, Executive Director. Anticipated Completion Date: December 31, 2024.

View Audit 306525

Finding 397172 (2023-004)

Material Weakness 2023

Dakota Plains Legal Services, Inc.

SD

Procurement, Suspension & Debarment

Legal Services Corporation CFDA #09-742018 Legal Services Corporation - Basic Field - General CFDA #09-742018 Legal Services Corporation - Basic Field - Native American Procurement Material Weakness in Internal Control over Compliance Condition: Auditor testing detected three instances in which th...

Legal Services Corporation CFDA #09-742018 Legal Services Corporation - Basic Field - General CFDA #09-742018 Legal Services Corporation - Basic Field - Native American Procurement Material Weakness in Internal Control over Compliance Condition: Auditor testing detected three instances in which the transaction exceeded the DPLS' small purchase threshold, requiring rate quotes and a written evaluation why the vendor was chose, however, this was not completed. Management's Response: Management will work to ensure that all qualified transactions exceeding the small purchase threshold will contain the proper documentation with regards to quotes, evaluations, and other factors which determine the selection of a particular service, product, or vendor. DPLS is working with David de la Tour on the development of a new Procurement Policy that will simplify and improve the current policy and procedures. Management will work to have this new Procurement Policy completed and presented for consideration to the DPLS Board of Directors, at the next board meeting in July 2024. Responsible Individuals: Michelle Lovejoy, Program Administrator, and Tom Mortland, Executive Director. Anticipated Completion Date: July 31, 2024.

View Audit 306525

Finding 397170 (2023-003)

Significant Deficiency 2023

Dakota Plains Legal Services, Inc.

SD

Internal Control / Segregation of Duties Cash Management Eligibility

Legal Services Corporation FFAL #09-742018 Legal Services Corporation - Basic Field - General FFAL #09-742018 Legal Services Corporation - Basic Field - Native American Eligibility Significant Deficiency in Internal Control over Compliance and Noncompliance Condition: The auditor's testing detecte...

Legal Services Corporation FFAL #09-742018 Legal Services Corporation - Basic Field - General FFAL #09-742018 Legal Services Corporation - Basic Field - Native American Eligibility Significant Deficiency in Internal Control over Compliance and Noncompliance Condition: The auditor's testing detected two instances in which U.S. Citizen Attestation was not retained. Management's Response: All employees have received additional training on compliance procedures, and new employees will receive the same. All files being closed are now reviewed first for accuracy by the case handler of that file. The files are double checked by the office secretary. At the end of the quarter, all files are sent to compliance for a third review. Any needed corrections are noted by compliance and the file is then sent back to the office where it originated from to be corrected. Then the corrections to the file are reported back to compliance to verify that they have been made. All Legal Secretary staff have just completed a mandatory two-day in-person training session, which in large part covered this and other compliance related issues. By the end of June 2024, all case handlers will receive in-person training on compliance issues. The program has also started a new procedure where any client coming into an office is asked to complete an attestation statement which can be added to the client file if needed. Responsible Individuals: Dawn Marshall, Co-Compliance Officer, Kaeleigh Lundberg, Co-Compliance Officer, Tom Mortland, Executive Director, Lori Stanford, Deputy Director. Anticipated Completion Date: July 31, 2024.

View Audit 306525

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