Corrective Action Plans

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The Uniform Guidance, as prescribed in 2 CFR section 200.305, requires that non-federal entities receiving federal awards establish and maintain internal control over federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with feder...
The Uniform Guidance, as prescribed in 2 CFR section 200.305, requires that non-federal entities receiving federal awards establish and maintain internal control over federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards.
Internal controls over compliance with RWB eligibility requirements should include formal policies and procedures to ensure that data used to determine eligibility are complete and accurate in compliance with RWB program requirements. Eligibility determination procedures should be performed by case...
Internal controls over compliance with RWB eligibility requirements should include formal policies and procedures to ensure that data used to determine eligibility are complete and accurate in compliance with RWB program requirements. Eligibility determination procedures should be performed by case managers and reviewed by a manager or knowledgeable employee.
HHHRC implemented a formal policy requiring a manager or knowledgeable employee other than the case manager to sign off on the annual and semi-annual certification forms for each client. This formal policy was implemented on April 1, 2022. As such, the certification forms that were prepared prior ...
HHHRC implemented a formal policy requiring a manager or knowledgeable employee other than the case manager to sign off on the annual and semi-annual certification forms for each client. This formal policy was implemented on April 1, 2022. As such, the certification forms that were prepared prior to this date were not reviewed in accordance with this policy.
Without appropriate internal controls, noncompliance with RWB eligibility requirements may occur. Refer to Finding 2023-002 for instances of noncompliance identified in the current year.
Without appropriate internal controls, noncompliance with RWB eligibility requirements may occur. Refer to Finding 2023-002 for instances of noncompliance identified in the current year.
Identification of a Repeat Finding
Identification of a Repeat Finding
This finding was reported as a federal award finding in the immediate previous audit as Finding 2022-001.
This finding was reported as a federal award finding in the immediate previous audit as Finding 2022-001.
Recommendation
Recommendation
We again recommend that HHHRC adhere to established policies and procedures to ensure that eligibility determinations performed by case managers during the in-take and re-assessment process are reviewed by a manager or knowledgeable employee other than the case manager for completeness and accuracy.
We again recommend that HHHRC adhere to established policies and procedures to ensure that eligibility determinations performed by case managers during the in-take and re-assessment process are reviewed by a manager or knowledgeable employee other than the case manager for completeness and accuracy.
Views of Responsible Officials and Planned Corrective Action
Views of Responsible Officials and Planned Corrective Action
HHHRC is continuing to implement its planned corrective action plan noted in the Current Status sections of the prior audit findings. To ensure further compliance, HHHRC hired a Case Management Assistant (CMA) in August 2023. The CMA’s responsibility includes reviewing client files to ensure require...
HHHRC is continuing to implement its planned corrective action plan noted in the Current Status sections of the prior audit findings. To ensure further compliance, HHHRC hired a Case Management Assistant (CMA) in August 2023. The CMA’s responsibility includes reviewing client files to ensure required documentation and certifications are present in the files and completed accurately. Additionally, the HIV leadership team has created a primary spreadsheet of all client’s receiving services and has assigned the monitoring of the spreadsheet to the CMA. This primary spreadsheet will assist the HIV team with tracking the receipt of documents, upcoming or expired certifications, and assist with document retrieval. The updated policies, improved training, along with the added support of the Quality Program Coordinator and Case Management Assistant should shore up gaps in the certification process.
Student Financial Aid Cluster: Federal Pell Grant Program – Assistance Listing No. 84.068 Federal Direct Student Loans – Assistance Listing No. 84.268 Recommendation: We recommend that the College work with their third-party servicer and implement procedures to ensure that enrollment data, changes ...
Student Financial Aid Cluster: Federal Pell Grant Program – Assistance Listing No. 84.068 Federal Direct Student Loans – Assistance Listing No. 84.268 Recommendation: We recommend that the College work with their third-party servicer and implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS are reported accurately and timely. And we recommend that the College implement formal review procedures to document the review process. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Registrar and Financial Aid departments have established a set schedule for enrollment reporting to the National Student Clearinghouse (NSC) and National Student Loan Database System (NSLDS) to ensure accurate and timely reporting happens each month and graduate reporting at the end of semester, within the 60-day window. To ensure CMC meets requirements to report all changes to enrollment and continuing enrollment within the 60-days, the monthly enrollment will follow best practice to submit every 30 days to allow time for correction of any errors prior to submission to NSLDS. The Student Affairs Systems Specialist will pull the enrollment report from CMC’s Student Information System (SIS) on the 19th for submission to NSC on the 20th of each month. If the 20th falls on the weekend it will be the Friday before. The Student Affairs Systems Specialist will correct any enrollment errors with NSC within 3 business days from the time of submission. The enrollment submission from NSC to NSLDS is scheduled for the 3rd of each month, and the Assistant Director of Financial Aid will pull a list from CMC’s SIS to match with NSLDS on the 15th of each month. If the 15th falls on the weekend it will be the Friday before. If there are any enrollment errors or missing students in NSLDS the Assistant Director of Financial Aid will notify the Student Affairs Systems Specialist to update student enrollment data within NSLDS. If there are no errors or missing enrollments in NSLDS, the Assistant Director of Financial Aid will send an email to the Student Affairs Systems Specialist to confirm the report is accurate and submitted. The graduate report will be submitted to NSC by the Student Affairs Systems Specialist on the second Friday after the end of the semester to allow for grade and graduation processing. The Assistant Director of Financial Aid will verify the graduate report within NSLDS two weeks after submission to NSC and email confirmation or request corrections with the Student Affairs Systems Specialist. Name(s) of the contact person(s) responsible for corrective action: Natalie Torres and Janelle Cook Planned completion date for corrective action plan: May 2024
Student Financial Aid Cluster: Federal Supplemental Educational Opportunity Grant – Assistance Listing No. 84.007 Federal Work Study Program – Assistance Listing No. 84.033 Federal Pell Grant Program – Assistance Listing No. 84.063 Federal Direct Student Loans – Assistance Listing No. 84.268 Reco...
Student Financial Aid Cluster: Federal Supplemental Educational Opportunity Grant – Assistance Listing No. 84.007 Federal Work Study Program – Assistance Listing No. 84.033 Federal Pell Grant Program – Assistance Listing No. 84.063 Federal Direct Student Loans – Assistance Listing No. 84.268 Recommendation: CLA recommends that the College review the requirement and implement a monitoring control to monitor the checks throughout the year. In addition, for the checks outstanding greater than 240 days, the College should return the funding to the U.S. Department of Education. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: To enhance the 240 Day Outstanding refund check processing efficiency and compliance, a streamlined procedure was developed and implemented to monitor all uncashed refund checks, including those from federal aid sources. This process will involve utilizing an Informer report every two weeks to compile a comprehensive list of uncashed refund checks for current and prior terms. Upon identification, a system-generated communication will be promptly dispatched to students, notifying them of the outstanding refund check and providing clear instructions to contact the Business Office. Calculations will be performed to ascertain if the refund originates from a federal aid source. For students with federal aid-related outstanding refunds, outreach efforts will be undertaken. Additionally, a progressive maintained cumulative report will serve as a real-time monitoring mechanism to track the status of refunds and ensure timely compliance. Continuous open communication will be maintained with the Financial Aid and Compliance team, facilitating the provision of student refunds requiring action and fostering collaboration across departments to address any outstanding issues effectively. The above-detailed process has already proven effective and noticeably successful in addressing the challenges associated with uncashed refund checks, particularly those originating from federal aid sources. Moving forward, this process will be continuously optimized and refined as system enhancements allow. Regular evaluations will be conducted to identify areas for improvement and implement necessary adjustments, ensuring that the refund processing workflow remains efficient, compliant, and responsive to the evolving needs of both students and regulatory requirements. This commitment to ongoing optimization underscores our dedication to providing timely and accurate refunds while upholding the highest standards of financial stewardship and accountability. Name(s) of the contact person(s) responsible for corrective action: Renee McBride Planned completion date for corrective action plan: January 2024
View Audit 300168 Questioned Costs: $1
Student Financial Aid Cluster: Federal Supplemental Educational Opportunity Grant – Assistance Listing No. 84.007 Federal Work Study Program – Assistance Listing No. 84.033 Federal Pell Grant Program – Assistance Listing No. 84.063 Federal Direct Student Loans – Assistance Listing No. 84.268 Reco...
Student Financial Aid Cluster: Federal Supplemental Educational Opportunity Grant – Assistance Listing No. 84.007 Federal Work Study Program – Assistance Listing No. 84.033 Federal Pell Grant Program – Assistance Listing No. 84.063 Federal Direct Student Loans – Assistance Listing No. 84.268 Recommendation: We recommend the college reevaluate their procedures regarding the return of Title IV funds including the implementation of secondary review of calculations. This would prevent future errors, and provide a greater level of internal control. Additionally, we recommend they review policies regarding the timeliness and accuracy of student enrollment. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: CMC established a new secondary review procedure to help prevent future errors and provide a greater level of internal control regarding the return of Title IV funds (R2T4). Going forward, after an R2T4 is completed, the Quality Assurance (QA) review will be processed. As part of this review, the Financial Aid and Scholarship Coordinator will be notified that all R2T4’s have been completed for the current week. They will then pull up the spreadsheet of students who had an R2T4 completed and select at random at least 10% of the students on that list to review. In this review they will examine the following data for each of the selected students:  Each class for that semester including the name of the class, the dates the class took place, the credit load of the class, the last date of attendance (LDA) for each class, if the class counts towards the program, if the class was marked as never attended, and if the class should be used in the R2T4.  The Institutional charges to ensure the correct charges were used.  The Days attended vs Total days to ensure that any break of 5 or more days was removed. To document the review, the Financial Aid and Scholarship Coordinator will initial next to each class that they check as they review. The Financial Aid and Scholarship Coordinator will also review that the awards were updated in the Colleague AIDE screen correctly based on the calculation and ensure that any Post-Withdrawal Disbursement (PWD) or return is processed accurately. They will also verify that the Exit counseling request was sent to the student (this is indicated in the CRI screen). Once the review is completed, the Financial Aid and Scholarship Coordinator will initial and date the spreadsheet for the student that they performed the review on. They will then change the color on the spreadsheet tab to indicate that it was reviewed. Name(s) of the contact person(s) responsible for corrective action: Reilly Watanabe, JoAnna Hulett and Janelle Cook Planned completion date for corrective action plan: July 2023
View Audit 300168 Questioned Costs: $1
2023‐014 – Reporting (Significant Deficiency) State Department of Defense AL Number: 97.067 Program Title: Homeland Security Grant Program Condition The auditing firm selected three subawards that were executed between July 1, 2022 – June 30, 2023, noting that FFATA reports for the selected subaward...
2023‐014 – Reporting (Significant Deficiency) State Department of Defense AL Number: 97.067 Program Title: Homeland Security Grant Program Condition The auditing firm selected three subawards that were executed between July 1, 2022 – June 30, 2023, noting that FFATA reports for the selected subawards were not filed timely. Current Status of Corrective Action Plan Concur. It is our commitment to address this issue promptly and implement necessary measures to prevent its recurrence. We understand the importance of accurate and timely data entry in the FFATA portal for federal awards and sub awards. In response to this issue, we have developed a corrective action plan to address the root causes and prevent similar occurrences in the future: -Review of Process: We will conduct a thorough review of our current process for entering funding amounts into the FFATA portal to identify any inefficiencies or gaps in the process. -Training and Awareness: We will provide additional training to other personnel in the grant section to ensure that there is continuity in the tasks. This will include reinforcing the importance of adhering to established deadlines and protocols. -Implement Reminders: We will implement automated reminders and notifications to alert grant staff members via shared Microsoft Outlook Calendar of impending deadlines for entering new federal award into the FFATA portal. These reminders will serve as a proactive measure to prevent delays and ensure timely completion of tasks. Lastly, reminder indicators such as; receiving the official grant award and executing a memorandum of agreement with sub recipients will be an indicator for action to process FFATA reporting. The FFATA information and process already exists in our Homeland Security Procedural Manual (Page 49) that we maintain annually. We will continue to maintain and make any necessary revisions if there are any changes. Person Responsible Glen Badua, Grants Manager Anticipated Date of Completion February 20, 2024
2023‐013 – Subrecipient Monitoring (Material Weakness) State Department of Labor and Industrial Relations AL Numbers and Program Title: 17.258 – WIOA Adult Program 17.259 – WIOA Youth Activities 17.278 – WIOA Dislocated Worker Formula Grant (WIOA Cluster) Condition No evidence of evaluation of the s...
2023‐013 – Subrecipient Monitoring (Material Weakness) State Department of Labor and Industrial Relations AL Numbers and Program Title: 17.258 – WIOA Adult Program 17.259 – WIOA Youth Activities 17.278 – WIOA Dislocated Worker Formula Grant (WIOA Cluster) Condition No evidence of evaluation of the subrecipients’ risk of noncompliance at the time of the subawards, and no evidence of on‐site monitoring procedures of the subrecipients. Current Status of Corrective Action Plan Concur. -The ASO will come up with a checklist of pertinent reports that are due for WIOA programs including but not limited to Risk Assessment Report to include the following information: - Subrecipient’s prior experience with the same or similar subawards. - Results of previous Single Audit of the same or similar program that has been audited as major program. - New and Departing Personnel Record. - Systems Changes/Update. - Completion of Subrecipient Monitoring Report. - A formal analysis of each subrecipient’s risk of noncompliance with each of the respective subaward requirements shall be performed at the time of the subaward. - In‐person, onsite monitoring of the activities of the subrecipient shall take place annually to ensure that the subaward is used for authorized purposes, in accordance with federal statute and regulations. Person Responsible Ferdinand Casabay, Accountant VI Anticipated Date of Completion May 31, 2024
2023‐012 – Reporting (Material Weakness) State Department of Labor and Industrial Relations AL Numbers and Program Title: 17.258 – WIOA Adult Program 17.259 – WIOA Youth Activities 17.278 – WIOA Dislocated Worker Formula Grant (WIOA Cluster) Condition Reporting required by Section 2, Full Disclosure...
2023‐012 – Reporting (Material Weakness) State Department of Labor and Industrial Relations AL Numbers and Program Title: 17.258 – WIOA Adult Program 17.259 – WIOA Youth Activities 17.278 – WIOA Dislocated Worker Formula Grant (WIOA Cluster) Condition Reporting required by Section 2, Full Disclosure of Entities Receiving Federal Funding, of the FFATA was not completed. Current Status of Corrective Action Plan Concur. -Due to changes in program personnel, there was miscommunication between the parties responsible for filing the FFATA reports. -Previous ASO left abruptly in 2023 with limited to no cross‐training. Other positions vacated in 2023 as well. The ASO and Accountant VI vacancies were filled on December 1, 2023 and February 1, 2024, respectively. -The ASO will come up with a checklist of pertinent reports that are due for WIOA programs including FFTA reporting and have the responsible staffs (Accountant and Supervisor) report to ASO Officer and WDD Administrator monthly for verification. Person Responsible Lynn Araki‐Regan, Administrative Services Officer Anticipated Date of Completion March 15, 2024
Finding No. 2023‐011 – Earmarking (Significant Deficiency) State Department of Labor and Industrial Relations AL Numbers and Program Title: 17.258 – WIOA Adult Program 17.259 – WIOA Youth Activities 17.278 – WIOA Dislocated Worker Formula Grant (WIOA Cluster) Condition The auditing firm noted the fo...
Finding No. 2023‐011 – Earmarking (Significant Deficiency) State Department of Labor and Industrial Relations AL Numbers and Program Title: 17.258 – WIOA Adult Program 17.259 – WIOA Youth Activities 17.278 – WIOA Dislocated Worker Formula Grant (WIOA Cluster) Condition The auditing firm noted the following instances of noncompliance: -A total of 15.61% of funds were allocated for employment and training activities for adults and dislocated workers. -A total of 74.60% of funds were allocated for services to out of school youth. Current Status of Corrective Action Plan Concur. -Administrative Services Office (ASO) has communicated with Workforce Development Division (WDD) that no more than 15% of funds shall be allocated to provide employment training activities for Adults and Dislocated Workers. If there are recaptured funds to spend from the local areas for the program year, ASO and WDD will make sure that recaptured funds will not exceed the maximum requirements of 15%. -WDD shall monitor the progress of subrecipients to meet the minimum 75% expenditure for out of school youth. If necessary, a monthly or bi‐monthly meeting with subrecipients shall be scheduled to monitor the progress and take pro‐active recommendations and action to meet the requirements. Person Responsible Maricar Pilotin‐Freitas, Workforce Development Division Administrator Anticipated Date of Completion March 2024
Finding No. 2023‐010 – Special Tests and Provisions (Material Weakness) State Department of Labor and Industrial Relations AL Number: 17.225 Program Title: Unemployment Insurance Condition Both and/or either the minimum number of cases and timeliness percentages for paid and denied claims including ...
Finding No. 2023‐010 – Special Tests and Provisions (Material Weakness) State Department of Labor and Industrial Relations AL Number: 17.225 Program Title: Unemployment Insurance Condition Both and/or either the minimum number of cases and timeliness percentages for paid and denied claims including monetary, separation, and nonseparation, were not met. Current Status of Corrective Action Plan Concur. -The BAM unit was short staffed an investigator from March 2022. The vacancy was filled on January 17, 2023. -The number of paid and denied claims were increased and the BAM supervisor was assigned denied cases. -The unit anticipates to meet the minimum number of 480 paid and 450 denied cases effective FY 23‐24 which began in July 2023. -The unit has made great strides and is currently meeting the denied timeliness requirements. -The unit has brought on an experienced adjudicator to fill a vacancy and learn BAM methodology. He is in the probationary period and is expected to continue to progress to the level where he will be able to function independently on simple to difficult and complex cases. The unit has worked cohesively to assist colleagues with investigative tasks. The TPS individual contributes to this effort by assisting with the assembly of new case files for the BAM investigators. This collective effort allows the unit to make progress to our goals. The BAM supervisor continues to help and monitor case completion and timeliness to ensure the unit works toward achieving the BAM requirements. Person Responsible Sheryl Maligro, UI Program Supervisor Anticipated Date of Completion June 2025
Finding No. 2023‐009 – Eligibility (Significant Deficiency) State Department of Labor and Industrial Relations AL Number: 17.225 Program Title: Unemployment Insurance Condition The audit identified two payments where the recipients did not make the minimum number of work search contacts. Current Sta...
Finding No. 2023‐009 – Eligibility (Significant Deficiency) State Department of Labor and Industrial Relations AL Number: 17.225 Program Title: Unemployment Insurance Condition The audit identified two payments where the recipients did not make the minimum number of work search contacts. Current Status of Corrective Action Plan Concur. Hawaii UI issued a memo, dated September 22, 2023, reminding the local offices of the minimum work search requirements under Administrative Rule 12‐5‐35(c) and for the adjudication unit to conduct a fact‐finding as to the reasons for the claimant’s non‐compliance. Hawaii UI is currently working on a project to enhance the work search process and requirements using a grant awarded to UI by US Department of Labor. The project will allow expansion to the work search reporting requirement on the front‐end of the online weekly claim certification process to include employer job search details. The process entails the use of Behavioral Insight techniques to encourage accurate reporting of the work search requirement and provide a log of their work search efforts. These enhancements will help claimants better understand UI program requirements including: -What claimants should report and why, -The reporting expectations at various decision points throughout the certification process while they still have time to meet the requirements, -Convey the consequences of intentionally providing false information or making mistakes during reporting, and -Imposing a denial of benefits for weeks in which the claimant does not meet the work search eligibility requirement. Person Responsible Sheryl Maligro, UI Program Supervisor Anticipated Date of Completion The enhancements to the Work Search Process are anticipated to be completed in June 2024.
View Audit 300162 Questioned Costs: $1
Finding No. 2023‐008 – Subrecipient Monitoring (Significant Deficiency) State Department of Land and Natural Resources AL Number: 15.634 Program Title: State Wildlife Grants (R&D Cluster) Condition The auditing firm examined a non‐statistical sample of two subawards and noted the following instances...
Finding No. 2023‐008 – Subrecipient Monitoring (Significant Deficiency) State Department of Land and Natural Resources AL Number: 15.634 Program Title: State Wildlife Grants (R&D Cluster) Condition The auditing firm examined a non‐statistical sample of two subawards and noted the following instances of noncompliance: -Subaward agreements did not include certain required federal award information. -No evidence of pass‐through entity verifying that subrecipients are audited as required by 2 CFR Section 200, Subpart F. Current Status of Corrective Action Plan Concur. DLNR DOFAW does provide subaward information to subrecipients and will ensure to include all required federal award information. DLNR DOFAW will ensure that documentation is retained when performing verification that subrecipients are audited as required by 2 CFR Section 200, Subpart F. Person Responsible Cynthia C. Gomez, Fiscal Management Officer David Smith, DOFAW Administrator Anticipated Date of Completion Completed.
Finding No. 2023‐007 – Suspension and Debarment (Significant Deficiency) State Department of Land and Natural Resources AL Number: 15.634 Program Title: State Wildlife Grants (R&D Cluster) Condition The auditing firm tested a non‐statistical sample of two subawards and found no evidence indicating t...
Finding No. 2023‐007 – Suspension and Debarment (Significant Deficiency) State Department of Land and Natural Resources AL Number: 15.634 Program Title: State Wildlife Grants (R&D Cluster) Condition The auditing firm tested a non‐statistical sample of two subawards and found no evidence indicating that program personnel verified whether any of the contractors were federally suspended or debarred. Current Status of Corrective Action Plan Concur. DLNR DOFAW has implemented procedures to ensure that a SAM.gov verification is performed for all subrecipients, and that documentation is printed out from SAM.gov and retained with the subrecipient file folder. Person Responsible Cynthia C. Gomez, Fiscal Management Officer David Smith, DOFAW Administrator Anticipated Date of Completion Completed.
Finding No. 2023‐006 – Reporting (Significant Deficiency) State Department of Land and Natural Resources AL Number: 15.615 Program Title: Cooperative Endangered Species Conservation Fund Condition A prime recipient of a federal award is required to file a Federal Funding Accountability and Transpar...
Finding No. 2023‐006 – Reporting (Significant Deficiency) State Department of Land and Natural Resources AL Number: 15.615 Program Title: Cooperative Endangered Species Conservation Fund Condition A prime recipient of a federal award is required to file a Federal Funding Accountability and Transparency Act (FFATA) report to the FFATA Subaward Reporting System (FSRS) by a specific period for any subaward greater than or equal to $30,000. The auditing firm haphazardly tested the one subaward executed in FY 2023 and noted FFATA report was not completed timely. Current Status of Corrective Action Plan Concur. DLNR has procedures in place for the submission of FFATA reports and will ensure that the reports are filed timely. Person Responsible Cynthia C. Gomez, Fiscal Management Officer Anticipated Date of Completion Completed.
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