Corrective Action Plans

Finding 16394 (2022-005)

None 2022

MI

Allowable Costs / Cost Principles § 200.430

Finding Number 2022-005 Education Stabilization Fund: Elementary and Secondary School Emergency Relief (ESSER) Assistance Listing Number 84.425D Allowable Costs/Cost Principles ? Documentation of Employee Time and Effort Immaterial Noncompliance Criteria: Per Federal regulations 2 CFR section 200.43...

Finding Number 2022-005 Education Stabilization Fund: Elementary and Secondary School Emergency Relief (ESSER) Assistance Listing Number 84.425D Allowable Costs/Cost Principles ? Documentation of Employee Time and Effort Immaterial Noncompliance Criteria: Per Federal regulations 2 CFR section 200.430(i)(1)(vii), the School District must maintain time and effort distribution records for an employee who works in part on the consolidated administrative cost objective and in part on a federal program whose administrative funds have not been consolidated or on activities funded from other revenue sources. Condition: The School District did not maintain time and effort distribution records for employees who were partially funded with ESSER Federal funds. Cause: Oversight. Effect: Time and effort reports were not completed. Questioned Costs: None. Recommendation: Time and effort reports should be completed throughout the year listing the employees name, position or job title, and percentage of time spent on each Federal award and signed by the employee?s supervisor. Management's Response and Corrective Actions: The Director of Finance and Superintendent completed time and effort reports for the ESSER funds expended for fiscal year ending June 30, 2022 and will continue to complete time and effort reports going forward. Person Responsible for Corrective Action: Justin Weston, Director of Finance, and Amiee Erfourth, Superintendent Completion Date: November 21, 2022.

View Audit 22357

Finding 16389 (2022-001)

Significant Deficiency 2022

Allegany County Human Resources Development Commission, Inc.

MD

Reporting

Allegany County HRDC agrees with the finding and will ensure that all reports are filed timely in the future.

View Audit 21653

Finding 16388 (2022-001)

None 2022

H.o.l.i.e. of Greenfield Avenue, Inc. - Valentino Square Apartments

WI

HUD Housing Programs Reporting Internal Control / Segregation of Duties

Management increased the security deposit bank account by $500 on September 15, 2022 to correct this finding.

View Audit 19955

Finding 16325 (2022-005)

Significant Deficiency 2022

Moorhead Public Housing Agency

MN

Internal Control / Segregation of Duties Eligibility Significant Deficiency

Contact Person Dawn Bacon, Executive Director Corrective Action Plan Staff will perform quality control review for the Public and Indian Housing program. Going forward a sample of files will be reviewed on a semi-annual basis. Planned Completion Date for CAP FY2023

View Audit 23038

Finding 16324 (2022-004)

Significant Deficiency 2022

Moorhead Public Housing Agency

MN

Eligibility Significant Deficiency

Contact Person Dawn Bacon, Executive Director Corrective Action Plan Error occurred due to lack of oversight in review of calculation of annual income and underlying support. We continue to confirm that all total tenant payment (TTP) calculations are matched to verification of income and deductions ...

Contact Person Dawn Bacon, Executive Director Corrective Action Plan Error occurred due to lack of oversight in review of calculation of annual income and underlying support. We continue to confirm that all total tenant payment (TTP) calculations are matched to verification of income and deductions documentation in tenant files. Planned Completion Date for CAP FY2023

View Audit 23038

Finding 16323 (2022-004)

Material Weakness 2022

West Holt Memorial Hospital

NE

Special Tests & Provisions Cash Management Material Weakness § 200.327 § 200.328

Criteria: The Hospital must establish and maintain effective internal control over federal awards that provides reasonable assurance that the Hospital is managing the federal awards in compliance with federal statutes, regulations and terms and conditions of the federal award. 2 CFR 200.327 and 2 CF...

Criteria: The Hospital must establish and maintain effective internal control over federal awards that provides reasonable assurance that the Hospital is managing the federal awards in compliance with federal statutes, regulations and terms and conditions of the federal award. 2 CFR 200.327 and 2 CFR 200.328 require the auditee to collect financial information and monitor its activities under federal awards to assure compliance with applicable federal requirements and performance expectations are being achieved and report these items in accordance with program requirements. Terms and conditions of the federal award require the Hospital to maintain a reserve fund at specified balance levels. Condition: During 2022, the accounts that represented the reserve fund had a balance below that required by the loan resolution agreements and required deposits were not being made to restore the balances to required levels. Planned Corrective Action: Management agrees with the finding and will deposit required amounts into the reserve fund. Planned Completion Date: Ongoing Person Responsible: Jeremy Bauer, CEO

View Audit 22832

Finding 16322 (2022-007)

None 2022

Town of Sullivan Sanitary District No. 1

WI

Subrecipient Monitoring

2022-007 Reserve Requirement not Met for the Sewerage System Mortgage Revenue Bond Condition: The District did not meet the reserve requirement for the bond issuance during the audit period. Criteria: The Sewerage System Mortgage Revenue Bond agreement, as outlined in Resolution No. 22-02, specie...

2022-007 Reserve Requirement not Met for the Sewerage System Mortgage Revenue Bond Condition: The District did not meet the reserve requirement for the bond issuance during the audit period. Criteria: The Sewerage System Mortgage Revenue Bond agreement, as outlined in Resolution No. 22-02, species that the District must maintain an amount equal to the least of (a) the amount required by the District ($86,500), (b) maximum annual debt service on the Bond in any Bond Year and (c) 125% of average annual debt service on the Bond, to ensure compliance with the terms and conditions of the bond issuance. Cause: The failure to meet the reserve requirement was primarily attributed to not transferring money to the reserve account. Effect: Failure to meet the reserve requirements could result in regulatory penalties. Auditor's Recommendation: We recommend the District develops a plan to replenish the reserve to meet the bond issuance requirements, implements a robust financial monitoring system to track compliance with bond issuance terms and ensure the reserve requirement is met on an ongoing basis, and conduct a comprehensive review of financial planning processes to prevent future reserve shortfalls. Management Response: The District acknowledges the audit finding and is committed to taking corrective measures in line with the recommendations provided. We will develop a detailed action plan to replenish the reserve and enhance financial monitoring and planning processes to prevent similar issues in the future. Contact Person: Dawn Bauer Anticipated Completion: December 31, 2023

View Audit 22335

Finding 16321 (2022-006)

None 2022

Town of Sullivan Sanitary District No. 1

WI

Reporting

2022-006 Late Submission of 2021 Data Collection Form with Federal Audit Clearinghouse Condition: The 2021 data collection form for the District was submitted after the prescribed nine month due date, as required by the Federal Audit Clearinghouse for the year ended December 31, 2021. Criteria: Th...

2022-006 Late Submission of 2021 Data Collection Form with Federal Audit Clearinghouse Condition: The 2021 data collection form for the District was submitted after the prescribed nine month due date, as required by the Federal Audit Clearinghouse for the year ended December 31, 2021. Criteria: The Federal Audit Clearinghouse requires that organizations submit their annual audit and the annual data collection form within nine months after the fiscal year-end. Cause: The delay in submitting the 2021 data collection form and the 2021 annual audit was primarily due to the audit was performed late. Effect: This delay in submission may hinder timely access to accurate financial information for decision-making and reporting. Auditor's Recommendation: We recommend that the District establishes a formalized process to track regulatory filing deadlines and responsibilities and conduct periodic reviews to ensure timely compliance with regulatory requirements. Management Response: The District acknowledges the audit finding and commits to implementing the recommended actions promptly to enhance compliance with regulatory requirements regarding data collection form submissions. Contact Person: Dawn Bauer Anticipated Completion: December 31, 2023

View Audit 22335

Finding 16320 (2022-005)

Material Weakness 2022

Town of Sullivan Sanitary District No. 1

WI

Reporting Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

2022-005 Federal Procedure Manual Condition: Internal controls over federal grants should be in place to provide reasonable assurance that misstatement in the schedule of expenditures of federal awards would be prevented or detected. Criteria: Non-federal entities who receive federal or state gra...

2022-005 Federal Procedure Manual Condition: Internal controls over federal grants should be in place to provide reasonable assurance that misstatement in the schedule of expenditures of federal awards would be prevented or detected. Criteria: Non-federal entities who receive federal or state grants or have grant programs should have documented policies and procedures in place over grants and grant expenditures. Cause: The District does not have documented policies and procedures in place over grants and grant expenditures. Effect: Without documented policies and procedures, the internal control over federal grants is low, and the risk of misstatement in the schedule of expenditures of federal and state awards is high. Auditor's Recommendation: We recommend that the District works on written policies and procedures over grants and grant expenditures. Management Response: The District will work with their auditor to develop and adopt written grant procedures that are in accordance with the Uniform Guidance. Contact Person: Dawn Bauer Anticipated Completion: December 31, 2023

View Audit 22335

Finding 16319 (2022-004)

Material Weakness 2022

Town of Sullivan Sanitary District No. 1

WI

Internal Control / Segregation of Duties Reporting

2022-004 Drafting Schedule of Expenditures of Federal Awards and Related Notes Condition: Like other entities of similar size, the District requires the assistance of the auditor to prepare the schedule of expenditures of federal awards in accordance with the Uniform Guidance. Criteria: Internal co...

2022-004 Drafting Schedule of Expenditures of Federal Awards and Related Notes Condition: Like other entities of similar size, the District requires the assistance of the auditor to prepare the schedule of expenditures of federal awards in accordance with the Uniform Guidance. Criteria: Internal controls over preparation of the schedule of expenditures of federal awards should be in place to provide reasonable assurance that a misstatement in the schedule of expenditures of federal awards would be prevented or detected. Cause: Management relies on the auditor to assist with the preparation of the schedule of expenditures of federal awards. Effect: The District's system of internal control may not prevent, detect, or correct misstatements in the schedule of expenditures of federal awards. Auditor's Recommendation: The auditor will continue to work with the District, providing information and training when necessary, to make the District?s personnel more knowledgeable about its responsibility for the schedule of expenditures of federal awards. Management Response: The control deficiency has been discussed with the District?s Board and they acknowledge their responsibility for the schedule of expenditures of federal awards. The District accepts responsibility for the schedule of expenditures of federal awards. Due to the technical nature of preparing the schedule of expenditures of federal awards, and due to limited resources, the District does not anticipate the need for this assistance to change in the foreseeable future. Contact Person: Dawn Bauer Anticipated Completion: Not Applicable

View Audit 22335

Finding 16316 (2022-002)

Significant Deficiency 2022

Chisholm School District I-42

OK

Internal Control / Segregation of Duties Allowable Costs / Cost Principles Material Weakness

Reference Number: 22-02 Name of Award ? Project Number (794, 628, 770) (Federal Findings) Condition/Finding: The District's final expenditure reports with the Oklahoma State Department of Education and Oklahoma Cost Accounting System (OCAS), did not match the actual allowable expense for their p...

Reference Number: 22-02 Name of Award ? Project Number (794, 628, 770) (Federal Findings) Condition/Finding: The District's final expenditure reports with the Oklahoma State Department of Education and Oklahoma Cost Accounting System (OCAS), did not match the actual allowable expense for their program. Three programs (794, 628, 770) had OCAS coding errors when final reports were submitted to the Oklahoma State Department of Education. Corrective steps that have already been implemented and/or the steps that will be implemented: All OCAS data, both receiving and expenditures, will be correct and accurate. All OCAS data involving Federal Programs will be reported correctly and accurately to the Oklahoma State Department of Education. Completion Date: Immediately The plan for monitoring adherence to the corrective action plan: All Chisholm Public Schools central office personnel involved with purchase orders, and OCAS data, will seek professional development and training to improve professionally. Additionally, all Chisholm Public Schools central office personnel will work collaboratively to ensure that all OCAS data is correct and accurate on an ongoing basis. Finally, all finalized OCAS data will be completely accurate when submitting to the Oklahoma State Department of Education. If warranted, reasons why the district does not consider a Corrective Action necessary. Superintendent's Signature Date

View Audit 21640

Finding 16244 (2022-001)

Significant Deficiency 2022

Northkey Community Care

KY

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

Northern Kentucky Mental Health ? Mental Retardation Regional Board, Inc. agrees with the finding and will complete necessary training with program employees regarding organizations established and required procedures along with the necessity of these procedures and the additional importance due to ...

Northern Kentucky Mental Health ? Mental Retardation Regional Board, Inc. agrees with the finding and will complete necessary training with program employees regarding organizations established and required procedures along with the necessity of these procedures and the additional importance due to federal program requirements.

View Audit 22999

Finding 16243 (2022-001)

Significant Deficiency 2022

Adam and Bruce Housing Corporation Dba Adam and Bruce Apts. 073-11568

CA

HUD Housing Programs Procurement, Suspension & Debarment Subrecipient Monitoring

Statement of Condition 2022-001 (Assistance Listing No. 14.155): The Property received a score of 35c* on a physical inspection of the Property performed on January 21, 2022 by a representative of HUD. By reference, the REAC inspection is included as a statement of condition. Recommendation: Manag...

Statement of Condition 2022-001 (Assistance Listing No. 14.155): The Property received a score of 35c* on a physical inspection of the Property performed on January 21, 2022 by a representative of HUD. By reference, the REAC inspection is included as a statement of condition. Recommendation: Management should ensure all necessary repairs have been made. Management should continue to conduct routine unit and general property inspections and deficiencies should be corrected in a timely manner. Action(s) taken or planned on the finding: Agree. Management has responded to HUD in regards to this inspection report and has addressed all health and safety issues. Management will continue to correct all remaining deficiencies noted and will implement a process of self-inspection of units and common areas.

View Audit 22324

Finding 16242 (2022-001)

Material Weakness 2022

Pontiac Housing Commission

MI

HUD Housing Programs Internal Control / Segregation of Duties

2022-1 Condition: Deficiencies Noted in Examination of Housing Choice Voucher Program Participant Files We concur with this finding and the Auditor?s recommendation. We will review the internal control procedures over tenant file re-certifications and documents. Management will implement proced...

2022-1 Condition: Deficiencies Noted in Examination of Housing Choice Voucher Program Participant Files We concur with this finding and the Auditor?s recommendation. We will review the internal control procedures over tenant file re-certifications and documents. Management will implement procedures to clear this finding in FY 2023 Timeframe: By the fiscal year end for March 31, 2023 Individual responsible for correction: Mr. Ahmad Taylor, Executive Director

View Audit 21563

Finding 16241 (2022-003)

Material Weakness 2022

County of Armstrong

PA

Subrecipient Monitoring

Contact Person: Tammie Gaff, Acting Controller Finding 2022-003 Subrecipient Monitoring AL 21.023 Emergency Rental Assistance Program Criteria: Internal control procedures require the County to perform subrecipient monitoring procedures over the funding disbursed to the Program?s vendor. These m...

Contact Person: Tammie Gaff, Acting Controller Finding 2022-003 Subrecipient Monitoring AL 21.023 Emergency Rental Assistance Program Criteria: Internal control procedures require the County to perform subrecipient monitoring procedures over the funding disbursed to the Program?s vendor. These monitoring procedures include documenting the procedures performed and the results of those procedures along with documenting the risk assessment associated with the selected procedures. Condition: During the audit, it was noted that the County was not performing subrecipient monitoring over the Program?s vendor. Cause: The County does not have adequate controls in place or the expertise to ensure proper subrecipient monitoring procedures. Effect: The Program?s vendor may be using grant funding inappropriately. This is a repeat finding from the prior year ? Finding 2021- 003. Questioned Costs: The amount of questioned costs, if any, is undeterminable. Recommendation: The County should implement internal control procedures that ensure the vendor is being properly monitored and document those procedures and results of procedures. Management Response: Management is working to implement and document proper subrecipient monitoring internal controls. Anticipate Completion Date: Immediate Respondent: (Name, Title, Department, Address, Telephone Number): Tammie Gaff Acting Controller Armstrong County 450 Market Street Kittanning PA 16201 724-548-3241

View Audit 19879

Finding 16239 (2022-002)

Material Weakness 2022

County of Armstrong

PA

Subrecipient Monitoring

Contact Person: Tammie Gaff, Acting Controller Finding 2022-002 Subrecipient Monitoring AL 93.778 and Medical Assistance Program and DHS Medical Assistance Transportation Program Criteria: Internal control procedures require the County to perform subrecipient monitoring procedures over the fund...

Contact Person: Tammie Gaff, Acting Controller Finding 2022-002 Subrecipient Monitoring AL 93.778 and Medical Assistance Program and DHS Medical Assistance Transportation Program Criteria: Internal control procedures require the County to perform subrecipient monitoring procedures over the funding disbursed to the Program?s vendor. These monitoring procedures include documenting the procedures performed and the results of those procedures along with documenting the risk assessment associated with the selected procedures. Condition: During the audit, it was noted that the County was not performing subrecipient monitoring over the Program?s vendor. Cause: The County does not have adequate controls in place or the expertise to ensure proper subrecipient monitoring procedures. Effect: The Program?s vendor may be using grant funding inappropriately. This is a repeat finding from the prior year ? Finding 2021- 002. Questioned Costs: The amount of questioned costs, if any, is undeterminable. Recommendation: The County should implement internal control procedures that ensure the vendor is being properly monitored and document those procedures and results of procedures. Management Response: Management is working to implement and document proper subrecipient monitoring internal controls. Anticipate Completion Date: Immediate Respondent: (Name, Title, Department, Address, Telephone Number): Tammie Gaff Acting Controller Armstrong County 450 Market Street Kittanning PA 16201 724-548-3241

View Audit 19879

Finding 16238 (2022-002)

Significant Deficiency 2022

Associated Universities, Inc.

DC

Equipment & Real Property Management Allowable Costs / Cost Principles Reporting § 200.313

2022-002 Equipment and Real Property Management Contact/s: Luther Lau, CFO (202) 462-5282 Mark Mackey, Controller (202) 298-5942 Completion Date: February 2023 Corrective Action: AUI maintains systems of internal controls of physical property to safeguard government assets from the risk of th...

2022-002 Equipment and Real Property Management Contact/s: Luther Lau, CFO (202) 462-5282 Mark Mackey, Controller (202) 298-5942 Completion Date: February 2023 Corrective Action: AUI maintains systems of internal controls of physical property to safeguard government assets from the risk of theft or loss. During the height of the COVID pandemic, the ALMA Observatory was necessarily staffed with a reduced number of personnel as a result of heightened restrictions on travel and cohabitation. The reduced staff ? in combination with the remote location of the Observatory ? resulted in the theft of a box of copper mesh at the Multicancha construction site. This copper mesh had a purchase price of approximately $3,200. Despite the theft being an isolated incident, AUI immediately reviewed its physical controls in place and took action to further improve monitoring and security at the site. Additional measures put in place include the following: ? During holidays and in-between shifts, valuable material was stored in a local locked warehouse. ? It was requested to ALMA to increase the frequency of guards patrolling. This is particularly important during the time the construction site is unoccupied for holidays or in-between shifts and nights. ? In Chile, the transportation of good requires an official paper called "Guia de despacho", which is a Chilean-IRS-certified document that demonstrates ownership of goods. Failing to show this paper to a local police officer may result in the detention of the driver under the alleged crime of theft. Since the incident, the Observatory is requesting this paper for all vehicles leaving the site carrying visible items. A visual inspection is performed to corroborate the paper and the cargo. ? A project to install CCTV cameras at the entrance and common areas is being developed. This is expected to mitigate risk of theft as well as having available records of events, if needed. The above internal controls over physical property, in combination with the controls already in place prior to the incident, have mitigated the risk of this type of occurrence from happening in the future.

View Audit 19698

Finding 16168 (2022-005)

Significant Deficiency 2022

Borough of Palisades Park School District

NJ

Eligibility

The District should ensure that students reported as low income meet eligibility requirements.

View Audit 22960

Finding 16165 (2022-001)

Significant Deficiency 2022

Granite City Community Unit School District No. 9

IL

Subrecipient Monitoring Eligibility

FY2022 Granite City Community Unit School District No. 9 Corrective Action Plan Finding Number: 2022-001 Finding Synopsis: During the year ended June 30, 2022, the District could not provide adequate supporting documentation for the public and nonpublic enrollment and low income counts that were use...

FY2022 Granite City Community Unit School District No. 9 Corrective Action Plan Finding Number: 2022-001 Finding Synopsis: During the year ended June 30, 2022, the District could not provide adequate supporting documentation for the public and nonpublic enrollment and low income counts that were used to allocate Title I services to District buildings. Action Steps: The District will implement additional controls in order to ensure that all necessary calculations are correctly computed and supported by appropriate supporting documentation. Contact Person(s): Zack Suhre, Director of Finance Anticipated Completion Date: 6/30/2023

View Audit 22314

Finding 16164 (2022-001)

None 2022

The Homeless Alliance, Inc.

OK

Subrecipient Monitoring Special Tests & Provisions Matching / Level of Effort / Earmarking § 200.334

Finding ? 2022-001 ? Inadequate Records Retention Federal AL# 14.241 ? Housing Opportunities for Persons with AIDS Criteria: Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three year...

Finding ? 2022-001 ? Inadequate Records Retention Federal AL# 14.241 ? Housing Opportunities for Persons with AIDS Criteria: Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient (2 CFR ?200.334). Condition: Documentation supporting the Housing Quality Standards inspections to ensure housing met quality standards listed in 24 CFR ?574.310(b)(1)-(2) for the special tests and provisions compliance requirement for AL# 14.241 was missing. Cause and Effect: Policies and procedures regarding records retention is not in accordance with 2 CFR ?200.334 as it does not explicitly state a time period for records retention. As a result, events occurred during the year with no records retained as support. Recommendation: We recommend management update the written records retention policies and procedures to include a time period that is in accordance with 2 CFR ?200.334 and then communicate that policy to all employees to following during the daily course of operations. Additionally, we recommend an annual review of the policies and procedures to ensure continued compliance with 2 CFR ?200.334. Management?s Response: Homeless Alliance management agrees with the finding. Finding 2022-00 1 Response and Corrective Action In conjunction with our FY22 annual audit, please see the agency's corrective action plan below: Condition: Documentation supporting the Housing Quality Standards inspections to ensure housing met quality standards listed in 24 CFR ?574.3 10(b)(1)-(2) for the special tests and provisions compliance requirement for AL# 14.241 was missing. Corrective action: The agency has hired a full time compliance specialist for the program in which the finding occurred. The compliance specialist will be responsible for ensuring that all required documentation is retained appropriately. Moreover, agency management will update our written records retention policy to include a time period that is in accordance with 2 CFR 200.334 and communicate that policy to all employees. An annual management review of the agency's records retention policy will also be implemented. Expected completion date: June 30, 2023 Party Responsible: Haley Phelps Contact information: 405-415-8410 hphelps@homelessalliance.org

View Audit 21392

Finding 16163 (2022-001)

Significant Deficiency 2022

Neighborhood Legal Services, Inc.

NY

Procurement, Suspension & Debarment Eligibility HUD Housing Programs

Name of Auditee: Neighborhood Legal Services, Inc. Name of Audit Firm: EFPR Group, CPAs, PLLC Period Covered by the Audit: December 31, 2022 CAP Prepared by: Lauren Breen, Executive Director Phone: (716) 847-0650 (A) Current Finding on the Schedule of Findings and Questioned Costs Finding 2022-001 (...

Name of Auditee: Neighborhood Legal Services, Inc. Name of Audit Firm: EFPR Group, CPAs, PLLC Period Covered by the Audit: December 31, 2022 CAP Prepared by: Lauren Breen, Executive Director Phone: (716) 847-0650 (A) Current Finding on the Schedule of Findings and Questioned Costs Finding 2022-001 (a) Comments with the finding and recommendation - NLS agrees with the finding. NLS also agrees with the recommendation, please see below for action taken. (b) Action taken - In April 2023, Neighborhood Legal Services (NLS) will conduct an office-wide training emphasizing the importance of careful file tracking. In addition, the Housing Unit shall develop a tracking system which will be implemented through the use of NLS?s new case management system. In the event that a staff member unexpectedly leaves on a temporary or permanent basis, inventory of the staff member?s open cases and matters shall be conducted prior to departure, where possible, and where an inventory prior to departure is not possible, it shall be conducted as soon as practicable, but in no event more than two weeks following the staff member?s temporary or permanent departure from the agency. NLS will implement additional office-wide procedural changes in 2023 to ensure that policies and procedures are effectively communicated to staff and that regular internal review of cash files ensures these procedures are followed in practice by staff.

View Audit 19624

Finding 16143 (2022-021)

Material Weakness 2022

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 requirements to perform risk assessments for subrecipients of the Coronavirus State and Local Fiscal Recovery Funds. Questioned Costs: Assistance Listing # 21.027 COVID-19 Amount $0 Sta...

Finding: The Department of Commerce did not have adequate internal controls over and did not comply with requirements to perform risk assessments for subrecipients of the Coronavirus State and Local Fiscal Recovery Funds. Questioned Costs: Assistance Listing # 21.027 COVID-19 Amount $0 Status: Corrective action in progress Corrective Action: The Department implemented procedures to strengthen internal controls to ensure the program complies with the subrecipient monitoring risk assessment requirements. The Homelessness Assistance Unit managing director completed the following corrective actions: ? Updated the unit risk assessment procedures to require risk assessment forms to be completed prior to contract execution for all subawards. ? Reviewed 2 CFR 200.332 to ensure procedures are updated to comply with all requirements for pass-through entities. ? Reviewed the updated procedures and risk assessment form with the Department?s central contract office. The federal team managers provided training to current staff and new hires on the updated procedures and are responsible for reviewing completed risk assessments. The Homelessness Assistance Unit managing director will perform a review of the process at the end of the current fiscal year to ensure procedures have been followed and the form is adequate to capture all required elements. Completion Date: Estimated September 2023 Agency Contact: Gena Allen Internal Control Officer PO Box 42525 Olympia, WA 98504-2525 (360) 480-5149 Gena.Allen@Commerce.wa.gov

View Audit 23129

Finding 16142 (2022-020)

Material Weakness 2022

State of Washington C/o Office of Financial Management

WA

Subrecipient Monitoring Reporting Allowable Costs / Cost Principles

Finding: The Office of Financial Management did not have adequate internal controls over and did not comply with reporting requirements for the Coronavirus State and Local Fiscal Recovery Funds. Questioned Costs: Assistance Listing # 21.027 COVID-19 Amount $0 Status: Corrective action comp...

Finding: The Office of Financial Management did not have adequate internal controls over and did not comply with reporting requirements for the Coronavirus State and Local Fiscal Recovery Funds. Questioned Costs: Assistance Listing # 21.027 COVID-19 Amount $0 Status: Corrective action complete Corrective Action: The Office has continued to strengthen internal controls for the Coronavirus State and Local Fiscal Recovery Fund (CSLFRF) reporting to ensure compliance with the federal requirements. As of May 2022, the Office: ? Transitioned the primary responsibility for centralized CSLFRF reporting to the Statewide Accounting Division. ? Hired a Budget and Grants Coordinator with experience in federal reporting to oversee the reporting process. The Office will continue to: ? Monitor updates to the U.S Treasury?s Project and Expenditure Report User Guide. ? Improve the quarterly reporting template and assist state agencies during the reporting process. ? Ensure reported amounts, including corrections or adjustments made during the reporting period, are properly tracked and documented for the subsequent reporting cycles. ? Perform reconciliations of reported expenditures to ensure agency expenditures are accurately reported, allowing for adjustments/ corrections required due to issues with the reporting system. ? Ensure reported expenditures are accurate and adequately supported by accounting records before the information is uploaded to the federal reporting system. ? Document correspondences with the U.S. Treasury when system errors are identified and resolutions recommended by the grantor, if received. Internal procedures have been developed to formally document the reporting process. Completion Date: May 2023 Agency Contact: Brian Tinney Statewide Accounting Director PO Box 43127 Olympia, WA 98504-3127 (564) 999-1781 brian.tinney@ofm.wa.gov

View Audit 23129

Finding 16141 (2022-019)

Material Weakness 2022

State of Washington C/o Office of Financial Management

WA

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

Finding: The Department of Commerce did not have adequate internal controls over and did not comply with requirements for monitoring subrecipients to ensure payments were allowable, properly supported, and met period of performance requirements for the Coronavirus State and Local Fiscal Recovery Fu...

Finding: The Department of Commerce did not have adequate internal controls over and did not comply with requirements for monitoring subrecipients to ensure payments were allowable, properly supported, and met period of performance requirements for the Coronavirus State and Local Fiscal Recovery Funds. Questioned Costs: Assistance Listing # 21.027 COVID-19 Amount $28,886,606 Status: Corrective action in progress Corrective Action: The Department implemented procedures to strengthen internal controls to ensure program expenditures are allowable, properly supported, and in compliance with the subrecipient fiscal monitoring requirements. The Homelessness Assistance Unit managing director completed the following corrective actions in July 2022: ? Updated unit reimbursement procedures to include a requirement for specific supporting documentation to accompany payment requests from all subrecipients. ? Provided training to staff on reviewing supporting documentation to ensure expenditures reconcile with reimbursement requests and to verify expenditures are within the period of performance. ? Reviewed 2 CFR 200.332 and updated procedures to include additional requirements for pass-through entities. ? Worked with the Department?s internal control officer for review and feedback of the updated procedures. The managing director will perform a review of the reimbursement process during the next fiscal year which begins July 1, 2023, to ensure procedures are followed. The Department increased the number of client files reviewed during program monitoring. The client file review included verifying household assistance expenses were allowable and incurred within the period of performance. Since the Department received the Coronavirus State and Local Fiscal Recovery Funds through legislative appropriation, resolution of the questioned costs with the grantor will be managed by the Office of Financial Management. Completion Date: Estimated September 2023 Agency Contact: Gena Allen Internal Control Officer PO Box 42525 Olympia, WA 98504 (360) 480-5149 Gena.Allen@Commerce.wa.gov

View Audit 23129 Questioned Costs: $1

Finding 16140 (2022-018)

Material Weakness 2022

State of Washington C/o Office of Financial Management

WA

Questioned Costs Allowable Costs / Cost Principles Reporting § 200.334 § 200.335 § 200.336 § 200.337 § 200.410

Finding: The Office of Financial Management did not have adequate internal controls over and did not comply with requirements to ensure Coronavirus State and Local Fiscal Recovery Funds were used only for allowable activities. Questioned Costs: Assistance Listing # 21.027 COVID-19 Amount $30...

Finding: The Office of Financial Management did not have adequate internal controls over and did not comply with requirements to ensure Coronavirus State and Local Fiscal Recovery Funds were used only for allowable activities. Questioned Costs: Assistance Listing # 21.027 COVID-19 Amount $300,000,000 Status: Corrective action not taken Corrective Action: The Office does not concur with the audit finding. The state of Washington created a separate fund to track the Coronavirus State and Local Fiscal Recovery Fund (CSLFRF) expenditures. The state, through legislation, approved the transfer from the CSLFRF account to various state transportation accounts. The Office reaffirms that all expenditures from the transportation accounts that received the CSLFRF funds were used to maintain government services. The State Administrative and Accounting Manual requires all state agencies to establish internal controls over payments for goods and services, including ensuring payments are lawful and for proper purposes, reviewing payments to ensure they are supported, as well as documenting the review of all payments. State agencies continued to follow their established internal controls to ensure expenditures from the transportation accounts were proper and allowable for both non-CSLFRF and CSLFRF funds. The Office will continue to: ? Work with the U.S. Treasury through upcoming desk audits to ensure no questioned costs are required to be repaid. ? Document all correspondence with the grantor during the audit resolution process. Completion Date: Not applicable Agency Contact: Brian Tinney Statewide Accounting Director PO Box 43127 Olympia, WA 98504-3127 (564) 999-1781 brian.tinney@ofm.wa.gov

View Audit 23129 Questioned Costs: $1

Corrective Action Plans

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