Corrective Action Plans

Finding 44786 (2022-030)

Material Weakness 2022

State of Oregon

OR

Allowable Costs / Cost Principles Subrecipient Monitoring Material Weakness § 200.303

2022-030 Oregon Housing and Community Services Ensure controls over administrative expenditure limits are properly designed and sufficiently detailed to ensure compliance Federal Awarding Agency: U.S. Department of the Treasury Assistance Listing Number and Name: 21.023 Emergency Rental Assistance...

2022-030 Oregon Housing and Community Services Ensure controls over administrative expenditure limits are properly designed and sufficiently detailed to ensure compliance Federal Awarding Agency: U.S. Department of the Treasury Assistance Listing Number and Name: 21.023 Emergency Rental Assistance Program (COVID-19) Federal Award Numbers and Years: ERA 1, 2021; ERA 2, 2021 (COVID-19) Compliance Requirement: Allowable Costs/Cost Principles Type of Finding: Material Weakness Prior Year Finding: N/A Questioned Costs: N/A Criteria: 2 CFR 200.303(a), (c)-(d); 15 U.S.C. 9058a(c)(5)(A); 15 U.S.C. 9058c(d)(1)(C) Department management is responsible for establishing and maintaining effective internal control that provides reasonable assurance the department is managing, evaluating, and monitoring the federal award in compliance with the terms and conditions of the award and taking prompt action when instances of noncompliance are identified. Federal regulations limit the amount of federal funds that can be used for administrative expenditures. The department periodically prepared tracking spreadsheets during the fiscal year to monitor spending and ensure administrative expenditure limitations were not exceeded. We reviewed four randomly selected tracking spreadsheets and noted two tracking spreadsheets where there was insufficient detail to determine what category expenditures were associated with (administrative versus programmatic); and three tracking spreadsheets where there was no indication that the expenditures were within administrative expenditures limitations due to the periodic nature of the tracking. Without sufficiently designed and implemented controls, the department is at risk for exceeding their allowable administrative cost limits. We recommend department management ensure tracking spreadsheets are properly designed and sufficiently detailed to ensure compliance with administrative expenditures limitations. MANAGEMENT RESPONSE: We agree with this recommendation. This was a very fast-paced, complex award with multiple layers of funding. OHCS did have and continues to have a pulse on administrative costs from the various admin funding sources and has not exceeded those allowable limits. Reporting was routinely compiled to show the various allocations and expenditures to date, which included administrative costs. Reporting was not provided in a consistent manner as information from multiple systems was needed, however program and fiscal staff met regularly to review. OHCS is taking careful steps to design a system that will consistently track awards while ensuring spending is in alignment with requirements and is distributed in a timely fashion. In doing so we will create a more consistent framework for tracking new awards to ensure limits and expenditures are consistently documented. Anticipated Completion Date: December 31, 2023 Contact: Jill Smith, Director of Housing Stabilization Division or Beth Brown, Accounting Manager

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Finding 44785 (2022-029)

Material Weakness 2022

State of Oregon

OR

Subrecipient Monitoring Allowable Costs / Cost Principles Eligibility § 200.302 § 200.332

2022-029 Oregon Housing and Community Services Ensure accessible documentation to evidence compliance with program requirements Federal Awarding Agency: U.S. Department of the Treasury Assistance Listing Number and Name: 21.023 Emergency Rental Assistance Program (COVID-19) Federal Award Numbers a...

2022-029 Oregon Housing and Community Services Ensure accessible documentation to evidence compliance with program requirements Federal Awarding Agency: U.S. Department of the Treasury Assistance Listing Number and Name: 21.023 Emergency Rental Assistance Program (COVID-19) Federal Award Numbers and Years: ERA 1, 2021 (COVID-19) Compliance Requirement: Activities Allowed or Unallowed; Allowable Costs/Cost Principles; Eligibility Type of Finding: Material Weakness Prior Year Finding: N/A Questioned Costs: N/A Criteria: 2 CFR 200.302(a); 2 CFR 200.332(a)(5) Department management is responsible for communicating to subrecipients that they are required to permit the department and auditors access to their records as necessary to ensure the department is compliant with program requirements. To ensure compliance with program requirements, subrecipient records must also be sufficiently detailed. The department passed through $140 million phase one program funds to community action agencies (subrecipients) to provide program delivery. The department performed limited fiscal monitoring during the audit period which included procedures to address compliance with activities allowed and allowable cost requirements for administrative costs. The department did not perform any program monitoring during the audit period which primarily addresses compliance with eligibility requirements. To determine whether the department complied with program requirements for the fiscal year, auditors attempted to reconcile detailed subrecipient ledgers with the intent of selecting and testing sample items at each individual subrecipient organization. We noted issues with two individual subrecipients, resulting in an inability to perform testing procedures over a total of $21,438,521 in program expenditures. For the first subrecipient we were able to reconcile their detailed ledgers to the department?s financial records, however their detailed ledger included pass-through payments to a third organization for program delivery. As a result of the combination of direct and pass-through payments, we were unable to obtain sufficiently detailed data that also reconciled to the department?s financial records to select individual transactions for testing. This subrecipient represents $19,877,962 of the unaudited expenditures. For the second subrecipient we were able to reconcile their detailed ledgers to the department?s financial records and select administrative and program transactions for testing. However, the subrecipient was unresponsive to documentation requests to substantiate expenditures. This subrecipient accounted for $1,560,559 of the unaudited expenditures. We recommend department management obtain and reconcile sufficiently detailed subrecipient ledgers and support to substantiate expenditures to allow for fiscal and program monitoring to ensure subrecipients are administering program funds in accordance with program requirements. MANAGEMENT RESPONSE: We agree with this recommendation. To effectively deliver much needed funds to maintain the housing stability of tens of thousands of Oregonians on the brink of experiencing homelessness during the pandemic, agency staff raced to stand up a first-of-its-kind ?single entry point? program for Oregonians to apply for assistance regardless of zip code. In our efforts to focus on speed we acknowledge that there was insufficient planning and capacity to stand up a large-scale emergency program including sufficient assurances our subrecipients could generate evidence of compliance with program requirements including transaction level details to assist with reconciliation. Oregon?s experience is in line with national findings. According to the January 2021 research brief conducted by the National Low Income Housing Coalition around key program challenges with administering emergency rental assistance programs. Survey respondents listed the two most common limitations to be staff capacity and the completeness of applications. Many agencies leaned on whatever local capacity was available to develop programs, review, and process applications, make payments and conduct outreach. Corrective action plan: OHCS had significant compliance monitoring staff turnover in FY22 leading to incomplete subrecipient monitoring reviews. OHCS completing these reviews would?ve ensured subrecipients had adequate time to produce necessary documentation to evaluate compliance, or if not, subrecipients would?ve been required to take corrective actions. For fiscal compliance, OHCS hired a contractor to perform fiscal monitoring of federal funded Grantees. OHCS also hired fiscal staff to pre-FY22 levels, fully trained them, conducted coordinated working sessions, and reached out to the CAA network for discussions on improving processes. OHCS continues to work with the contractor for much needed assistance in monitoring of back log while internal staff move forward to allow for all monitoring to be back on schedule and coordinating both fiscal and program compliance during future fiscal years. Program compliance employees have been hired and compliance efforts are underway. All providers will have internal compliance visits at regular intervals to ensure they have necessary documents and eligibility is being determined in compliance with program requirements. Additionally regular and ongoing check ins and trainings are being offered by program staff. Finally, program compliance teams are working with the Finance compliance team as well as a contracted expert to develop systems and processes in alignment with the Finance compliance team. As a result of program compliance efforts, a risk evaluation is being developed and incorporated into future contracting decisions. Efforts in hiring and systemic investments in infrastructure, processes, and procedures in addition to partner communications have taken place to ensure agency readiness in the event another emergency occurs. As part of our commitment to continual learning, our OHCS research team is collaborating closely with university and national partners to analyze our ERA program data and findings to see what themes emerge for improvement both nationally and in Oregon. Anticipated Completion Date: December 31, 2023 Contact: Jill Smith, Director of Housing Stabilization Division and Dean Criscola, Controller

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Finding 44784 (2022-028)

Material Weakness 2022

State of Oregon

OR

Subrecipient Monitoring Material Weakness Reporting § 200.303

2022-028 Oregon Housing and Community Services Ensure Federal Funding Accountability and Transparency Act reporting is completed Federal Awarding Agency: U.S. Department of the Treasury Assistance Listing Number and Name: 21.023 Emergency Rental Assistance Program (COVID-19) Federal Award Numbers...

2022-028 Oregon Housing and Community Services Ensure Federal Funding Accountability and Transparency Act reporting is completed Federal Awarding Agency: U.S. Department of the Treasury Assistance Listing Number and Name: 21.023 Emergency Rental Assistance Program (COVID-19) Federal Award Numbers and Years: ERA 1, 2021 (COVID-19); ERA 2, 2021 (COVID-19) Compliance Requirement: Reporting Type of Finding: Material Weakness, Material Noncompliance Prior Year Finding: N/A Questioned Costs: N/A Criteria: 2 CFR 200.303(a), (c)-(d); 2 CFR 170, Appendix A I(a) Department management is responsible for establishing and maintaining effective internal control that provides reasonable assurance the department is managing, evaluating, and monitoring the federal award in compliance with the terms and conditions of the award and taking prompt action when instances of noncompliance are identified. The Federal Funding Accountability and Transparency Act (FFATA) requires the department to submit information for any subaward action that equals or exceeds $30,000. Program guidance required the department to report detailed subaward information directly to the federal awarding agency. This detailed subaward information encompassed all requirements related to FFATA, and the federal awarding agency gave the department the option of filing required FFATA reports on their behalf. The department stated they did not provide the detailed subaward information to the federal awarding agency to complete FFATA reporting on their behalf, and they did not complete any alternate FFATA submissions during the fiscal year due to grant award information not being available on the federal website to file their reports. As a result, the department is not in compliance with FFATA reporting requirements. We recommend department management ensure FFATA reporting is completed. MANAGEMENT RESPONSE: We agree with this recommendation. Oregon was not unique. Many states experienced frustration with the lack of clarity in the reporting process. For example, the National Coalition for State Housing Agencies sent a Feb 8, 2022 letter to urge Treasury to fix technology problems with its reporting portal, streamline reporting requirements and provide technical assistance to ERA grantees. Oregon also experienced challenges getting responses from Treasury about around reporting questions, but we understand that our federal partners were also operating under emergency circumstances and were also strained to capacity. Corrective action plan: OHCS has attempted multiple times to submit the FFATA, however the award was never made available to report on within the system. OHCS has also reached out to US Treasury multiple times to confirm that we were not required to report but have yet to hear directly from US Treasury. OHCS was able to confirm and received a response from US Treasury that went to another state that grantees were not required to complete the FFATA on the federal reporting website as US Treasury was doing that on behalf of the recipient, and OHCS did share that correspondence with SOS. Although US Treasury has been nonresponsive, OHCS will continue to attempt to obtain a direct response from US Treasury for our own records. Anticipated Completion Date: December 31, 2023 Contact: Beth Brown, Accounting Manager

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Finding 44783 (2022-027)

Material Weakness 2022

State of Oregon

OR

Subrecipient Monitoring Allowable Costs / Cost Principles Eligibility § 200.302 § 200.303

2022-027 Oregon Housing and Community Services Ensure Monthly and Quarterly reports are accurate and adequately supported Federal Awarding Agency: U.S. Department of the Treasury Assistance Listing Number and Name: 21.023 Emergency Rental Assistance Program (COVID-19) Federal Award Numbers and Ye...

2022-027 Oregon Housing and Community Services Ensure Monthly and Quarterly reports are accurate and adequately supported Federal Awarding Agency: U.S. Department of the Treasury Assistance Listing Number and Name: 21.023 Emergency Rental Assistance Program (COVID-19) Federal Award Numbers and Years: ERA 1, 2021; ERA 2, 2021 (COVID-19) Compliance Requirement: Reporting Type of Finding: Material Weakness; Material Noncompliance Prior Year Finding: N/A Questioned Costs: N/A Criteria: 2 CFR 200.302(a) and (b)(3); 2 CFR 200.303(a), (c)-(d) Department management is responsible for establishing and maintaining effective internal control that provides reasonable assurance the department is managing, evaluating, and monitoring the federal award in compliance with the terms and conditions of the award and taking prompt action when instances of noncompliance are identified. Additionally, the department is responsible for maintaining records to allow for submission of reports that are accurate and adequately supported. We tested four randomly selected monthly reports and found one report did not accurately report the number of unique households assisted and the amount of the assistance based on the supporting documentation. The department stated the differences were likely due to a transition in subsystem reporting formats and delays in report processing. We tested four quarterly reports, two of which were randomly selected and two of which were judgmentally selected. We found one report where the cumulative obligation amount did not agree to supporting documentation and were not accurate, and one report where the cumulative obligation and cumulative expenditures amounts did not agree to supporting documentation and were not accurate. The department stated these errors were due to erroneously entered information in the federal awarding agency?s reporting portal. Information included in these reports is used by the federal awarding agency to determine whether the department qualifies for receiving reallocation payments, as well as how much of a reallocation would be awarded to the department. Errors in these reports could result in errors in the federal awarding agency?s determination of eligibility for funding, and/or the reallocation formula. We recommend department management update and correct erroneous reports and establish controls to ensure reported amounts are accurate and adequately supported. MANAGEMENT RESPONSE: We agree with this recommendation. Numerous Community Action Agencies (CAAs), after months of exponential growth in program resources without time to strategize and scale operations, reported major capacity issues a chronic backup of applications at the local level. OHCS took the unprecedented step to augment CAA staff to contract with a third-party vendor to clear the backlog. This approach rapidly increased production and moved the federal program closer in line with the state?s then 60-day safe harbor period but came with additional monitoring and reporting challenges. OHCS did meet the reporting timelines and requirements of US Treasury. OHCS relied on information within the applicant tracking system that does have some discrepancies when compared to our accounting records. These discrepancies are due to various factors such as dates within the system causing application activity to be pulled into the reporting detail more than once, or the application tracking system not being updated with the most current payment record information by some grantees disbursing payments. These variances were overcome by relying on our accounting system and records as a control source of actual disbursements. During the audit, it was brought to our attention that the compilation of the application tracking system data at a point in time was not stored to demonstrate the reconciliation with the accounting information. SOS was then not able to verify the application tracking system data figures in one monthly reporting instance that were used to support the numbers reported to US Treasury as the file had likely been overridden. Similarly in one instance, the quarterly cumulative report was also impacted, however future cumulative figures were reported correctly. Corrective action plan: While OHCS submitted monthly and quarterly reports since program inception that include program and fiscal information, we acknowledge that there were some discrepancies between systems when one file was overridden with new information and one other file contained an error. We have taken steps to ensure data integrity and records retention moving forward and future compilations of the application tracking system data will be stored to support the point in time reconciliations and figures reported to US Treasury. One quarterly report will also be refiled if allowable by US Treasury to ensure quarterly figures reported are accurate. Data integrity is of the utmost importance to the agency, and we appreciate the thorough review by the auditing team. Anticipated Completion Date: June 30, 2023 Contact: Beth Brown, Accounting Manager

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Finding 44782 (2022-026)

Material Weakness 2022

State of Oregon

OR

Questioned Costs Subrecipient Monitoring § 200.332 § 200.501

2022-026 Oregon Housing and Community Services Department Implement program monitoring over client assistance payments to ensure compliance Federal Awarding Agency: U.S. Department of the Treasury Assistance Listing Number and Name: 21.023 Emergency Rental Assistance Program (COVID-19) Federal Aw...

2022-026 Oregon Housing and Community Services Department Implement program monitoring over client assistance payments to ensure compliance Federal Awarding Agency: U.S. Department of the Treasury Assistance Listing Number and Name: 21.023 Emergency Rental Assistance Program (COVID-19) Federal Award Numbers and Years: ERA 1, 2021; ERA 2, 2021 (COVID-19) Compliance Requirement: Activities Allowed or Unallowed; Eligibility Type of Finding: Material Weakness; Material Noncompliance Prior Year Finding: N/A Questioned Costs: $21,624 (known); $11,067,350 (likely) (COVID-19) Criteria: 2 CFR 200.332(d); 2 CFR 200.501(g) Department management is responsible for monitoring the activities of subrecipients to ensure subawards are used for authorized purposes and are compliant with federal requirements. Additionally, department management is responsible for ensuring compliance when a contractor is responsible for program compliance or the contractor?s records must be reviewed to determine program compliance. The department provided $140 million and $46 million of phase one program funds to community action agencies (subrecipients) and a third-party vendor (contractor) to provide program delivery, respectively; and $132 million phase two program funds to only the contractor. Program delivery included determining client eligibility and making payments for direct client assistance for rent, utilities, internet, and other housing related costs. During implementation of the program, the department provided program manuals to the subrecipients and contractor. Due to the department?s limited staff, they focused on updating policies and procedures to address systemic issues identified; however, if a particularly challenging application required the department?s review, they were available to provide direct assistance. The department did not implement any predefined, systemic program monitoring of the subrecipients or contractor to ensure direct client assistance payments were paid to only eligible clients for only allowable and supported amounts. Therefore, auditors performed additional procedures at the subrecipient and contractor level to determine whether direct client assistance payments were paid to eligible clients for allowable activities. We tested a total of 62 randomly selected direct client assistance payments at 16 subrecipients totaling $183,515, and found the following: One subrecipient did not respond to audit requests for documentation, resulting in an inability to test one transaction in the amount of $360. One subrecipient did not obtain documentation to support that there was a lease agreement in place, resulting in questioned costs of $5,775. When extrapolated to the total population, these errors result in over $2.3 million in likely questioned costs. We tested 61 randomly selected contractor direct client assistance payments totaling $374,274, and found the following: One payment where an incorrect landlord was paid in the amount of $2,700. Attempts to recover the funds have been unsuccessful as of the date of the finding. Two payments where the rental amount was doubled, resulting in overpayments totaling $5,910. Seven payments where amounts already paid were not accurately reflected in the calculation of assistance provided, resulting in overpayments totaling $4,191. Three payments where amounts did not agree to supporting documentation, resulting in overpayments of $2,181. Three payments where there was insufficient documentation for amounts paid, resulting in overpayments of $432. One payment where costs were paid for the same household on alternate applications, resulting in an overpayment of $73. When extrapolated to the total population, these errors result in over $8.7 million in likely questioned costs. We recommend department management implement predefined, systemic program monitoring to ensure the subrecipients and contractor are administering program funds in accordance with program requirements. MANAGEMENT RESPONSE: We agree with this recommendation. OHCS agrees and had we not been operating during a global health pandemic and had we had adequate time and staffing, we would have addressed this issue more carefully as we have in previous years. However, given that this was a new program that lacked sufficient time and resources to design, launch and operate to meet the pressing needs of Oregonians facing eviction and homelessness, the work required unprecedented action that sometimes fell short of our usual standards for client assistance payment compliance. OHCS will use these lessons moving forward should we operate future emergency programs to move towards best practices. Corrective action plan: Lack of staff significantly limited our ability to perform the necessary monitoring. An additional contractor was brought on to monitor the work of our vendor in February of 2022. The contractor continued to provide program compliance support to OHCS through the end of January 2023. This contractor was also engaged in other projects and activities as needed during their contract term. The largest workload was investigating payments or cases that were identified as potentially non-compliant. All these cases were researched extensively, and findings were identified, and corrective action and collection activities were started if needed. Out of concern for the lack of administrative dollars associated with ERA staff knew an internal compliance effort would also be required. Since the summer of 2022 OHCS staff have been conducting internal random samples of applications and payments in addition to the work of our hired contractor. Additionally, this spring the program compliance team has engaged in a formalized review process focused on specific agencies administering ERA funds. Anticipated Completion Date: December 31, 2023 Contact: Jill Smith, Director of Housing Stabilization Division

View Audit 45093 Questioned Costs: $1

Finding 44781 (2022-025)

Material Weakness 2022

State of Oregon

OR

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles § 200.332

2022-025 Oregon Housing and Community Services Perform fiscal monitoring for subrecipients administrative expenditures to ensure compliance Federal Awarding Agency: U.S. Department of the Treasury Assistance Listing Number and Name: 21.023 Emergency Rental Assistance Program (COVID-19) Federal Aw...

2022-025 Oregon Housing and Community Services Perform fiscal monitoring for subrecipients administrative expenditures to ensure compliance Federal Awarding Agency: U.S. Department of the Treasury Assistance Listing Number and Name: 21.023 Emergency Rental Assistance Program (COVID-19) Federal Award Numbers and Years: ERA 1, 2021 (COVID-19) Compliance Requirement: Activities Allowed or Unallowed; Allowable Costs/Cost Principles Type of Finding: Material Weakness; Material Noncompliance Prior Year Finding: N/A Questioned Costs: $121,463 (known) (COVID-19) Criteria: 2 CFR 200.332(a)(5) and (d) Department management is responsible for monitoring the activities of subrecipients to ensure subawards are used for authorized purposes and in compliance with federal requirements. Additionally, department management is responsible for communicating to subrecipients that they are required to permit the department and auditors access to their records as necessary to ensure the department is in compliance with program requirements. The department passed through program funds to community action agencies (subrecipients) to provide program delivery, including administrative costs. The department performed fiscal monitoring for only five of their 18 subrecipients during the audit period due to staff turnover. Fiscal monitoring includes procedures to address compliance with activities allowed and allowable cost requirements for administrative costs. Due to the limited fiscal monitoring performed, auditors performed additional procedures at the subrecipient level to determine whether the department was compliant with program requirements. We tested a total of 82 transactions, 70 randomly selected and 12 judgmentally selected from the 13 subrecipients that did not receive subrecipient monitoring during the fiscal year. We noted the following: One subrecipient did not respond to audit requests for documentation, resulting in an inability to test four transactions totaling $4,114. One subrecipient did not provide sufficiently detailed documentation to determine whether 7 transactions were for accurate amounts totaling $117,349. Of those seven transactions, we were unable to determine whether two transactions were for allowable activities or appropriately categorized as administrative expenditures. Without adequate monitoring of subrecipients, the department?s ability to ensure compliance with program requirements is diminished. We recommend department management perform fiscal monitoring to ensure subrecipients are expending administrative funds in accordance with program requirements. MANAGEMENT RESPONSE: We agree with this recommendation. Corrective action plan: OHCS had significant compliance monitoring staff turnover in FY22 which led to a lack of monitoring. OHCS has subsequently hired a contractor to perform fiscal monitoring of all ESG funded grantees. OHCS also hired staff to pre-FY22 levels, fully trained all staff and began developing internal working relationships with program staff to assure operational efficiencies. This includes an annual workshop with all grantees, internal training, and standardizations of monitoring processes. Anticipated Completion Date: June 30, 2023 Contact: Dean Criscola, Controller

View Audit 45093 Questioned Costs: $1

Finding 44778 (2022-064)

Significant Deficiency 2022

State of Oregon

OR

Allowable Costs / Cost Principles § 200.303

2022-064 Oregon Department of Transportation Management should ensure timely review of transfers is documented Federal Awarding Agency: U.S. Department of Transportation Assistance Listing Number and Name: 20.205 Highway Planning and Construction Federal Award Numbers and Years: Various Complian...

2022-064 Oregon Department of Transportation Management should ensure timely review of transfers is documented Federal Awarding Agency: U.S. Department of Transportation Assistance Listing Number and Name: 20.205 Highway Planning and Construction Federal Award Numbers and Years: Various Compliance Requirement: Activities Allowed or Unallowed; Allowable Costs/Cost Principles Type of Finding: Significant Deficiency Prior Year Finding: N/A Questioned Costs: N/A Criteria: 2 CFR 200.303; GAO-17-704G ?10.03, 12.05; ODOT FASM 3.7 The department is responsible for establishing and maintaining internal controls to ensure entries posted in the accounting records are for costs and activities allowable under the federal program. Journal entry review and approval should be clearly documented and readily available for examination. The department has established Financial Administration Standard 3.7, Expenditure Journal Entries, which requires management to transmit signed hard copy supporting documentation of journal entries to financial services after they?ve been reviewed and approved. We tested 40 transfer journal entries moving costs between federal project sub jobs and found that 19 did not have documentation of timely approval. In two cases, approval was documented more than a year after costs were transferred. The 19 entries were all lump sum transfers processed by Program and Funding Services (P&FS). P&FS is authorized to process transfers, moving costs between sub jobs of the same project. These transfers are necessary to align project costs with the appropriate funding source. Per P&FS management, transfers are generally reviewed within a few days. However, documentation of the review has not been occurring until much later due to challenges associated with remote work and policies requiring hard copy documentation. Over $90 million in program costs were transferred between sub jobs in this manner during fiscal year 2022. Without timely review and documentation available to support transfers, unallowable costs or activities could be transferred and billed erroneously to the Federal government. We recommend management ensure procedures for review of transfer journal entries result in timely documented approvals. MANAGEMENT RESPONSE: We agree with this recommendation. Until electronic signatures are implemented, a Federal Aid Funding staff member will be required to print the hard copies, in the office at least monthly; as well as a member of the Statewide Investments Section management team will need to be present to sign the hard copies. Anticipated Completion Date: May 4, 2023 Contact: Katie Parlette, Federal Aid Funding Manager

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Finding 44777 (2022-063)

Significant Deficiency 2022

State of Oregon

OR

Subrecipient Monitoring § 200.332

2022-063 Oregon Department of Transportation Consistency needed when providing required federal award information to subrecipients Federal Awarding Agency: U.S. Department of Transportation Assistance Listing Number and Name: 20.205 Highway Planning and Construction Federal Award Numbers and Years...

2022-063 Oregon Department of Transportation Consistency needed when providing required federal award information to subrecipients Federal Awarding Agency: U.S. Department of Transportation Assistance Listing Number and Name: 20.205 Highway Planning and Construction Federal Award Numbers and Years: Various Compliance Requirements: Subrecipient Monitoring Type of Finding: Significant Deficiency, Noncompliance Prior Year Finding: N/A Questioned Costs: N/A Criteria: 2 CFR 200.332(a)(1) Federal regulations require pass-through entities to ensure every subaward is clearly identified to the subrecipient as a subaward and includes certain required information. We examined 17 subrecipient awards to ensure the information required under 2 CFR 200.332(a)(1) was communicated at the time of the subaward. Each award examined was missing one or more of the required elements: 15 samples did not include the subrecipient?s Unique Entity Identifier or DUNS number; 7 samples did not provide the Federal Award Identification Number (FAIN); 5 samples did not provide the Federal Award date; and 1 sample did not provide the correct assistance listing number. The required award information is necessary for the subrecipient to accurately report the subaward information in its accounting records and on the schedule of expenditure of federal awards. Procedures to communicate award information are not consistently followed across the department and as a result do not ensure that all the required award information is communicated. Specifically, some required information is included in the Federal Project Agreement from the Federal Management Information System (FMIS), but not all managers were aware it needed to be provided. In many cases an exhibit was included with the agreement that could have provided all the required information, but the exhibit was not completed. We recommend the department adopt procedures for preparing subaward agreements that ensure all required information is provided to subrecipients at the time of the subaward. MANAGEMENT RESPONSE: We agree with this recommendation. The Department will implement the following: 1. Communicate to all Program Managers of federal funds the requirements of sending the FMIS document to the sub-recipient. The FMIS document includes the FAIN, Award Date and starting 6/1/23 will also include the UEI. 2. Procurement will ensure the exhibit included with the agreement is completed and returned by the subrecipient. 3. Identify a staff person to enter data into the FFATA Subaward Reporting System (FSRS). Anticipated Completion Date: December 31, 2023 Contact: Katie Parlette, Federal Aid Funding Manager or Melissa Canfield, Procurement Manager

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Finding 44764 (2022-062)

Significant Deficiency 2022

State of Oregon

OR

Allowable Costs / Cost Principles Significant Deficiency § 200.303

2022-062 Higher Education Coordinating Commission Improve controls over payroll Federal Awarding Agency: U.S. Department of Labor Assistance Listing Number and Name: 17.258 WIOA Adult Program 17.259 WIOA Youth Activities 17.278 WIOA Dislocated Workers Formula Grant Federal Award Numbers and Yea...

2022-062 Higher Education Coordinating Commission Improve controls over payroll Federal Awarding Agency: U.S. Department of Labor Assistance Listing Number and Name: 17.258 WIOA Adult Program 17.259 WIOA Youth Activities 17.278 WIOA Dislocated Workers Formula Grant Federal Award Numbers and Years: AA33251LN0; 2019, AA33251L70; 2019, AA33251L90; 2019, AA33251R70; 2019, AA33251R90; 2019, AA34789VS0; 2020, AA34789V90; 2020, AA34789VQ0; 2020, AA347893L0; 2020, AA347895P0; 2020, AA36341E10; 2021, AA36341D90; 2021, AA36341DQ0; 2021, AA36341KY0; 2021,AA36341LA0; 2021 Compliance Requirement: Allowable Costs/Cost Principles Type of Finding: Significant Deficiency Prior Year Finding: N/A Questioned Costs: N/A Criteria: 2 CFR 200.303 Federal regulations require recipients of federal awards to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. The department has implemented the following procedures to ensure payroll costs are correctly charged to the program. Managers approve monthly timesheets submitted by the employees in the state?s payroll system. When managers do not approve by a specified date, the payroll system will automatically approve the timesheet, shown with the words ?system approved.? Additionally, each employee should have a signed position description, which details the duties of the position and the amount of time to be charged for the duties. We selected a nonstatistical random sample of 20 employee timesheets related to 12 employees to ensure payroll was appropriately charged to the program. Additionally, we selected one employee who was on job rotation with the agency from January 2022 through June 2022. We verified payroll timesheets were reviewed by a manager and signed position descriptions were retained per state guidelines, and identified the following exceptions: Two timesheets for one employee did not have evidence of manager approval and 2 timesheets for two employees were reviewed over three months later. For all 12 employees, the position descriptions provided were unsigned or signed upon our request. We did not question these costs as department management verified job duties were appropriate to the program. For the employee on job rotation, 4 of the 6 timesheets were not reviewed and a signed position description was not signed by the employee. According to department management, timesheets were not always approved by the manager as the system will automatically lock and approve the timesheet. For position descriptions, supervisor did not always follow through on obtaining signed position descriptions and for longer term employees a number of boxes could not be located when the agency moved. There is a risk that employees could be improperly charging to the federal program. We recommend department management ensure timesheets are timely reviewed and positions descriptions are completed and retained. MANAGEMENT RESPONSE: We agree with this recommendation. To improve controls over payroll, the HECC and the State of Oregon switched its payroll system from the old Legacy Oregon State Payroll Application (OSPA ? Epay) to the new Workday Payroll as of December 1, 2022. The HECC has since created reminder emails to all Management Staff to submit their respective employees? timesheets in a timely manner. In addition, the new Workday Payroll does not have a feature that automatically locks an employee?s timesheet and auto-approves a timesheet. Each Manager must now manually approve a timesheet for any employee that enters specific time codes for particular grants or use of funds. To address the finding regarding unsigned position descriptions (PDs), the HECC has since ensured that all of the identified PDs have been signed. HECC?s Human Resources Unit (HR) has created a new process going forward requiring all managers to sign the PD at the time of the offer letter and HECC HR to collect the signature from the employee on their first day when HR meets with them. HECC HR also has reviewed all of its existing employees? position description in this process to ensure all positions descriptions are signed. Anticipated Completion Date: August 31, 2023 Contact: Christopher Bui, Budget and Fiscal Manager

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Finding 44763 (2022-061)

Significant Deficiency 2022

State of Oregon

OR

Subrecipient Monitoring Reporting Significant Deficiency § 200.303

2022-061 Higher Education Coordinating Commission FFATA reports were not prepared or submitted Federal Awarding Agency: U.S. Department of Labor Assistance Listing Number and Name: 17.258 WIOA Adult Program 17.259 WIOA Youth Activities 17.278 WIOA Dislocated Worker Formula Grant Federal Award N...

2022-061 Higher Education Coordinating Commission FFATA reports were not prepared or submitted Federal Awarding Agency: U.S. Department of Labor Assistance Listing Number and Name: 17.258 WIOA Adult Program 17.259 WIOA Youth Activities 17.278 WIOA Dislocated Worker Formula Grant Federal Award Numbers and Years: AA33251LN0; 2019, AA33251L70; 2019, AA33251L90; 2019, AA33251R70; 2019, AA33251R90; 2019, AA34789VS0; 2020, AA34789V90; 2020, AA34789VQ0; 2020, AA347893L0; 2020, AA347895P0; 2020, AA36341E10; 2021, AA36341D90; 2021, AA36341DQ0; 2021, AA36341KY0; 2021, AA36341LA0; 2021 Compliance Requirement: Reporting Type of Finding: Significant Deficiency; Noncompliance Prior Year Finding: N/A Questioned Costs: N/A Criteria: 2 CFR 170; 2 CFR 200.303 The WIOA Cluster is subject to subaward reporting under the Federal Funding Accountability and Transparency Act (FFATA). FFATA requires the department to submit information for any subaward action that equals or exceeds $30,000 in the FFATA Subaward Reporting System (FSRS). Reports should be submitted no later than the end of the month following the month in which the subawards were made. Federal regulations also require recipients of federal awards to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Upon inquiry of the department, we determined it had not submitted any subaward information to the FSRS during fiscal year 2022. Department management stated FFATA reporting was not completed due to staff turnover. We also reviewed information the department had submitted at USAspending.gov and determined the department had not submitted any subaward information to FSRS since 2017. The agency is not in compliance with FFATA reporting requirements. Additionally, the department is not transparent in the spending decisions of these federal awards. We recommend department management implement controls to timely prepare and submit the monthly FFATA reports as required by federal regulations. The department should also work with the federal awarding agency to determine what actions it should take for older reports not submitted. MANAGEMENT RESPONSE: We agree with this recommendation. According to the findings, the HECC didn?t submit any subaward information to the FSRS during fiscal year 2022. Furthermore, the Department had not submitted any subaward information to FSRS since 2017. The HECC acknowledges these findings are correct. Due to these findings, HECC has implemented procedures to ensure timely entry into the FFATA Subaward Reporting System (FSRS) of all awards that equal or exceed $30,000. In addition, HECC has granted FSRS access to several high-level accountants to ensure that there is always staff on hand to make these entries. The procedures include a checkbox on the cover page of every agreement that delineates when a FSRS entry is required. Anticipated Completion Date: May 31, 2023 Contact: Christopher Bui, Budget and Fiscal Manager

View Audit 45093

Finding 44762 (2022-060)

Significant Deficiency 2022

State of Oregon

OR

Questioned Costs Period of Performance Significant Deficiency § 200.343

2022-060 Higher Education Coordinating Commission Strenthen controls to ensure expenditures are not obligated beyond the period of performance Federal Awarding Agency: U.S. Department of Labor Assistance Listing Number and Name: 17.258 WIOA Adult Program 17.259 WIOA Youth Activities 17.278 WIOA...

2022-060 Higher Education Coordinating Commission Strenthen controls to ensure expenditures are not obligated beyond the period of performance Federal Awarding Agency: U.S. Department of Labor Assistance Listing Number and Name: 17.258 WIOA Adult Program 17.259 WIOA Youth Activities 17.278 WIOA Dislocated Workers Formula Grant Federal Award Numbers and Years: AA32218F30; 2018, AA32218G10; 2018 AA32218G30; 2018, AA32218G70; 2018 AA32218H90; 2018, AA32218F31; 2018 Compliance Requirement: Period of Performance Type of Finding: Significant Deficiency; Noncompliance Prior Year Finding: N/A Questioned Costs: $47,523 (known) Criteria: 20 CFR 683.110; 2 CFR 200.343 (2018) WIOA grants are available for expenditure by the State during the grant program year and the two succeeding program years. In addition, the State must liquidate all financial obligations incurred no later than 90 calendar days after the end date of the period of performance. We judgmentally selected for review expenditures recorded in fiscal year 2022 related to 2018 grant award whose period of performance ended June 30, 2021. Our review of the supporting documentation found there were 3 out of 13 items with expenditures that were outside the period of performance. Total question cost for these expenditures were $47,523. Per management, these errors were due to a change in personnel and trying to balance out the 2018 grant after the fact. We recommend department management review and revise controls to ensure expenditures are only obligated during the period of performance federally mandated dates. MANAGEMENT RESPONSE: We agree with this recommendation. The three errors pertaining to those expenditures that were outside the period of performance, were due to a change in personnel and trying to balance out the 2018 grant, after the fact. The HECC have addressed these issues by ensuring that all new accountants are fully trained in a timely manner. Also, HECC has implemented training for all current accounting staff in identifying what is an allowable cost within the period of performance. This training also included a review of proper close-out procedures for all grants. Anticipated Completion Date: June 30, 2023 Contact: Christopher Bui, Budget and Fiscal Manager

View Audit 45093 Questioned Costs: $1

Finding 44761 (2022-024)

Significant Deficiency 2022

State of Oregon

OR

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.317 § 200.332

2022-024 Oregon Housing and Community Services Subrecipients need to be monitored to ensure compliance with procurement standards Federal Awarding Agency: U.S. Department of Housing and Urban Development Assistance Listing Number and Name: 14.231 Emergency Solutions Grants Program (COVID-19) Fede...

2022-024 Oregon Housing and Community Services Subrecipients need to be monitored to ensure compliance with procurement standards Federal Awarding Agency: U.S. Department of Housing and Urban Development Assistance Listing Number and Name: 14.231 Emergency Solutions Grants Program (COVID-19) Federal Award Numbers and Years: E-20-DW-41-0001, 2020 (COVID-19) Compliance Requirement: Procurement, and Suspension and Debarment Type of Finding: Significant Deficiency; Noncompliance Prior Year Finding: N/A Questioned Costs: N/A Criteria: 2 CFR 200.317 - .327; 2 CFR 200.332(d) Federal regulations state that non-federal entities, including subrecipients, are required to have and use procurement procedures consistent with state and local laws and regulations and that conform to the federal procurement standards identified in 2 CFR 200.317 - .327. Pass-through entities, like the department, are required to monitor subrecipients for compliance with federal regulations and the terms and conditions of the award. Inquiries and testing determined the department?s fiscal monitoring procedures, which normally include review of compliance with procurement standards, were not fully performed during the fiscal year and only 6 of 45 subrecipients were reviewed. As a result, subrecipients could be out of compliance with procurement requirements. We recommend the department ensure subrecipients are monitored for compliance with procurement requirements. MANAGEMENT RESPONSE: We agree with this recommendation. OHCS had significant staff turnover in FY22, and that coupled with the substantively increased number of subrecipients, lead to a lack of monitoring. OHCS has subsequently hired staff and established vendor relationships to perform fiscal monitoring as a backup for when staff vacancies exist. Additionally, OHCS is on track to complete fiscal and program monitoring for all subrecipients of ESG funds in FY23. Anticipated Completion Date: June 30, 2023 Contact: Dean Criscola, Controller

View Audit 45093

Finding 44760 (2022-023)

Significant Deficiency 2022

State of Oregon

OR

Special Tests & Provisions HUD Housing Programs Significant Deficiency

2022-023 Oregon Housing and Community Services Controls need to be strengthened to ensure the required expenditures are spent timely Federal Awarding Agency: U.S. Department of Housing and Urban Development Assistance Listing Number and Name: 14.231 Emergency Solutions Grants Program (COVID-19) F...

2022-023 Oregon Housing and Community Services Controls need to be strengthened to ensure the required expenditures are spent timely Federal Awarding Agency: U.S. Department of Housing and Urban Development Assistance Listing Number and Name: 14.231 Emergency Solutions Grants Program (COVID-19) Federal Award Numbers and Years: E-20-DW-41-0001, 2020 (COVID-19) Compliance Requirement: Special Tests and Provisions Type of Finding: Significant Deficiency; Noncompliance Prior Year Finding: N/A Questioned Costs: N/A Criteria: CPD 21-08(III)(B)(2)(c) Emergency Solutions Grants-Cares Act (ESG-CV) funds were intended to be spent quickly on allowable activities to address the public health and economic crisis stemming from COVID-19. At least 20% of the total award was to be spent by September 30, 2021. Based on our testing, the department was not adequately tracking the percentage or timeliness of expenditures and did not reach the expenditure milestone. Approximately 18% of the total award was expended by September 30, 2021. If the 20% milestone is not achieved, HUD is able to recapture up to 20%, or $11.2 million, of the total award. We recommend agency management develop procedures to ensure grant expenditures are adequately tracked and spent within the required time period. MANAGEMENT RESPONSE: We agree with this recommendation. OHCS did reach out to HUD and requested an extension of the obligation deadline, however, did not receive direct approval. Going forward, OHCS will ensure grant management reports and time-bound expenditure plans are consistently maintained and followed for all OHCS grants and grantees. In addition, OHCS will perform due diligence and ensure follow-up occurs when needed and documentation is retained to support our efforts. Anticipated Completion Date: December 31, 2023 Contact: Beth Brown, Accounting Manager

View Audit 45093

Finding 44759 (2022-022)

Significant Deficiency 2022

State of Oregon

OR

Procurement, Suspension & Debarment

2022-022 Oregon Housing and Community Services Documentation verifying subrecipients have not been suspended or debarred needs to be retained Federal Awarding Agency: U.S. Department of Housing and Urban Development Assistance Listing Number and Name: 14.231 Emergency Solutions Grants Program (CO...

2022-022 Oregon Housing and Community Services Documentation verifying subrecipients have not been suspended or debarred needs to be retained Federal Awarding Agency: U.S. Department of Housing and Urban Development Assistance Listing Number and Name: 14.231 Emergency Solutions Grants Program (COVID-19) Federal Award Numbers and Years: E-20-DW-41-0001, 2020 (COVID-19) Compliance Requirement: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency; Noncompliance Prior Year Finding: N/A Questioned Costs: N/A Criteria: 2 CFR 180.300; 2 CFR 180.305 Federal regulations require the department verify subrecipients are not suspended or debarred from receiving federal funds prior to making any disbursements. We randomly selected a sample of 14 subrecipients to verify whether they were federally suspended or debarred and determine whether the department performed a verification prior to disbursing program funds. Department management stated subrecipients? suspension/debarment status was reviewed in the federal database but was unable to provide documentation demonstrating the review was performed. Without performing this verification, the department could unknowingly pass federal funds to a subrecipient that has been federally suspended or debarred. Our independent verification confirmed the 14 subrecipients selected for testing were not suspended or debarred. We recommend department management maintain documentation demonstrating subrecipients have not been suspended or debarred. MANAGEMENT RESPONSE: We agree with this recommendation. Procurement will ensure documentation demonstrating subrecipients have not been suspended or debarred will be saved in the procurement file. Anticipated Completion Date: June 30, 2023 Contact: Sandra Flickinger, Procurement Manager

View Audit 45093

Finding 44758 (2022-021)

Significant Deficiency 2022

State of Oregon

OR

Matching / Level of Effort / Earmarking Subrecipient Monitoring

2022-021 Oregon Housing and Community Services Controls are needed to ensure compliance with level of effort requirements Federal Awarding Agency: U.S. Department of Housing and Urban Development Assistance Listing Number and Name: 14.231 Emergency Solutions Grants Program (COVID-19) Federal Awar...

2022-021 Oregon Housing and Community Services Controls are needed to ensure compliance with level of effort requirements Federal Awarding Agency: U.S. Department of Housing and Urban Development Assistance Listing Number and Name: 14.231 Emergency Solutions Grants Program (COVID-19) Federal Award Numbers and Years: E-20-DW-41-0001, 2020 (COVID-19) Compliance Requirement: Matching, Level of Effort, Earmarking Type of Finding: Significant Deficiency; Noncompliance Prior Year Finding: N/A Questioned Costs: N/A Criteria: 24 CFR 576.101(c) When a subrecipient is a unit of general-purpose local government, its ESG-CV program funds may not be used to replace funds the local government provided for street outreach and emergency shelter services during the preceding 12-month period unless U.S. Dept. of Housing and Urban Development determines the local government is in a severe financial deficit. ESG-CV funds should be used to supplement, not replace those funds. We determined the department was not monitoring its subrecipients for compliance with level of effort requirements during our review. Documentation was not available for review, and we were unable to determine the department?s compliance with this requirement. As a result, local governments could be using program funds to replace their funding allocated to street outreach and emergency shelter services. We recommend department management develop procedures to ensure compliance with federal requirements for level of effort and maintain documentation. MANAGEMENT RESPONSE: We agree with this recommendation. Level of Effort monitoring is part of program monitoring for State FY23 which is on track to be completed for all ESG recipients. OHCS is in the process of designing a self-certification form for subrecipients to acknowledge and agree to the compliance requirements in which funds may not be used to replace funds the local government provided for street outreach and emergency shelter services. Anticipated Completion Date: December 24, 2023 Contact: Jill Smith, Director of Housing Stabilization Division

View Audit 45093

Finding 44757 (2022-020)

Material Weakness 2022

State of Oregon

OR

Special Tests & Provisions Subrecipient Monitoring Material Weakness

2022-020 Oregon Housing and Community Services Controls are needed to ensure buildings renovated for use as emergency homeless shelters are maintained as shelters for the period required Federal Awarding Agency: U.S. Department of Housing and Urban Development Assistance Listing Number and Name: ...

2022-020 Oregon Housing and Community Services Controls are needed to ensure buildings renovated for use as emergency homeless shelters are maintained as shelters for the period required Federal Awarding Agency: U.S. Department of Housing and Urban Development Assistance Listing Number and Name: 14.231 Emergency Solutions Grants Program (COVID-19) Federal Award Numbers and Years: E-20-DW-41-0001, 2020 (COVID-19) Compliance Requirement: Special Tests and Provisions Type of Finding: Material Weakness; Material Noncompliance Prior Year Finding: N/A Questioned Costs: N/A Criteria: 24 CFR 576.102(c) Federal regulations require that buildings renovated with ESG-CV funds for use as emergency homeless shelters must be maintained as shelters for not less than a period of 3 or 10 years, depending on the type of renovation and value of the building. Initial inquiries with program staff determined that the department was not aware whether its subrecipients were using program funds to renovate buildings for use as emergency homeless shelters. Subsequently, program staff indicated the information may be contained in subrecipient implementation reports. However, there were no known procedures or processes in place to monitor the use of funds during the fiscal period. Therefore, it is possible buildings renovated with program funds may not be maintained as emergency shelters for the minimum required time period. We recommend agency management develop internal controls to ensure buildings renovated for use as emergency homeless shelters are maintained as shelters for the period required. MANAGEMENT RESPONSE: We agree with this recommendation. Program monitoring for all ESG recipients is on track to be completed for State FY23. Our program manuals state the restrictive use period requirements for any rehabilitation, renovation, conversion, or maintenance of real property. OHCS? program manuals clearly define and outline the requirements for approval of acquisition-renovation-rehabilitation, expectations regarding restrictive use periods based on project type, as well as a requirement for an annual certificate of continuing program compliance. The continuing program compliance requirement allows subrecipients to self-certify that a property is meeting the required restrictive use requirement and that all populations being served meet eligibility criteria of the program(s) funding the project. These requirements will be verified and reviewed as part of program monitoring. Anticipated Completion Date: December 24, 2023 Contact: Jill Smith, Director of Housing Stabilization Division

View Audit 45093

Finding 44756 (2022-019)

Material Weakness 2022

State of Oregon

OR

Equipment & Real Property Management Subrecipient Monitoring § 200.311 § 200.313

2022-019 Oregon Housing and Community Services Controls are needed to ensure subrecipients? compliance with equipment and real property requirements Federal Awarding Agency: U.S. Department of Housing and Urban Development Assistance Listing Number and Name: 14.231 Emergency Solutions Grants Progr...

2022-019 Oregon Housing and Community Services Controls are needed to ensure subrecipients? compliance with equipment and real property requirements Federal Awarding Agency: U.S. Department of Housing and Urban Development Assistance Listing Number and Name: 14.231 Emergency Solutions Grants Program (COVID-19) Federal Award Numbers and Years: E-20-DW-41-0001, 2020 (COVID-19) Compliance Requirement: Equipment and Real Property Management Type of Finding: Material Weakness; Material Noncompliance Prior Year Finding: N/A Questioned Costs: N/A Criteria: 2 CFR 200.311; 2 CFR 200.313 There are specific requirements when equipment is purchased using federal funds and in use. At a minimum, procedures for managing equipment must meet the following requirements: Property records must be maintained that include key details (e.g. property description, ID number, Title, etc);? A physical inventory of the property must be taken, and the results reconciled with the property records at least once every two years;? A control system must be developed to ensure adequate safeguards to prevent loss, damage, or theft of the property. Any loss, damage, or theft must be investigated; and? Adequate maintenance procedures must be developed to keep the property in good condition.? Real property purchased must be used for the originally authorized purpose as long as needed for that purpose. When real property is no longer needed for the originally authorized purpose, the non-federal entity must obtain disposition instructions from either the federal awarding agency or pass through entity. During our review, we determined OHCS was not monitoring its subrecipients to ensure the equipment and real property requirements were being met. Because subrecipients were not being monitored, we were unable to determine if there was a population of equipment and real property on which to perform our audit testing procedure. As a result, the department may not be in compliance with federal equipment and real property requirements. We recommend department management develop internal controls to ensure compliance with federal requirements for equipment and real property. MANAGEMENT RESPONSE: We agree with this recommendation. OHCS has instituted a procedure for State FY23 which is on track to be completed for all ESG recipients; this procedure currently includes a notification and approval process for the tracking of the acquisition, rehabilitation, renovation, or conversion of property and separately a vehicle purchase and equipment purchase. We are in the process of refining a control system to ensure adequate safeguards are in place to prevent loss, damage, or theft. Additionally, we are reviewing our maintenance procedures to ensure properties are in good condition. Anticipated Completion Date: December 24, 2023 Contact: Jill Smith, Director of Housing Stabilization Division

View Audit 45093

Finding 44755 (2022-018)

Material Weakness 2022

State of Oregon

OR

Questioned Costs Allowable Costs / Cost Principles

2022-018 Oregon Housing and Community Services Controls are needed to ensure program expenditures are allowable Federal Awarding Agency: U.S. Department of Housing and Urban Development Assistance Listing Number and Name: 14.231 Emergency Solutions Grants Program (COVID-19) Federal Award Numbers and...

2022-018 Oregon Housing and Community Services Controls are needed to ensure program expenditures are allowable Federal Awarding Agency: U.S. Department of Housing and Urban Development Assistance Listing Number and Name: 14.231 Emergency Solutions Grants Program (COVID-19) Federal Award Numbers and Years: E-20-DW-41-0001, 2020 (COVID-19) Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Type of Finding: Material Weakness; Material Noncompliance Prior Year Finding: N/A Questioned Costs: $245,362 (known) (COVID-19) Criteria: 24 CFR 576.100; CPD-21-08 III.E.3 Emergency Solutions Grants-Cares Act (ESG-CV) funds may be used for the five regular Emergency Solutions Grants (ESG) program components, as well as administrative activities: street outreach, emergency shelter, homelessness prevention, rapid re-housing, and homeless management information systems (HMIS). They may also be used for additional activities including, but not limited to, temporary emergency shelter, hazard pay, handwashing stations, cell phones and internet, personal protective equipment, and laundry. The funds are disbursed to the subrecipients after reimbursement requests are submitted. Federal funds totaling $31,894,565 were distributed to 44 subrecipients during fiscal year 2022. We randomly selected 61 individual distributions made by the department to subrecipients. Subsequently, we randomly selected an expenditure from each disbursement request and then judgmentally selected additional expenditures from select disbursements. While gaining an understanding of the department?s internal control process, we learned the review process for subrecipient disbursement requests did not include a detailed verification that underlying expenditures were for allowable activities and costs. Given the department?s incomplete review process, we were unable to verify compliance by testing those reviews. The department requested supporting documentation from the subrecipients, documentation that should have been reviewed and retained by the department, for the required audit procedures to be performed. Our audit procedures were performed in three stages. First, we randomly selected 61 individual distributions made by the department to subrecipients, totaling $5,580,560. These disbursements generally consisted of reimbursement for multiple expenditures made by a subrecipient. Next, we asked the department to request a listing of expenditures from the subrecipients related to those disbursements. Finally, if provided, we agreed the listings to the disbursement and randomly and judgmentally selected individual expenditures from the listings for testing. We were unable to perform any review of 20 disbursements either because we did not receive a listing of the subrecipient?s expenditures, or the listing did not agree to the disbursement selected for testing. These disbursements related to 10 of the 44 subrecipients receiving funds in fiscal year 2022 and $1,475,345 of the $5,580,560 in disbursements selected for testing noted above. From the expenditure listings we did receive, we randomly and judgmentally selected individual expenditures to determine whether the supporting documentation agreed to the amount requested for reimbursement by the subrecipient. Of those 41 individual transactions selected for testing, there was inadequate or no supporting documentation provided for 29 items, and one instance where the request exceeded the support. These exceptions resulted in total questioned costs of $245,362. If requests for funds are not supported by documented expenditures, the department could be unknowingly reimbursing subrecipients for unallowable costs and activities. We recommend management implement internal controls to ensure subrecipient reimbursements are for allowable expendiures. MANAGEMENT RESPONSE: We agree with this recommendation. OHCS had significant staff turnover in FY22, and that coupled with the substantively increased number of subrecipients, lead to a lack of monitoring. OHCS has subsequently hired staff and established vendor relationships to perform fiscal monitoring as a backup for when staff vacancies exist. Additionally, OHCS is on track to complete fiscal and program monitoring for all subrecipients of ESG funds in FY23. Anticipated Completion Date: June 30, 2023 Contact: Dean Criscola, Controller

View Audit 45093 Questioned Costs: $1

Finding 44754 (2022-059)

Significant Deficiency 2022

State of Oregon

OR

Questioned Costs HUD Housing Programs Significant Deficiency § 200.303

2022-059 Department of Human Services Ensure issued benefits are accurate Federal Awarding Agency: U.S. Department of Agriculture Assistance Listing Number and Name: 10.542 Pandemic EBT Food Benefits (COVID-19) Federal Award Numbers and Years: Not available (COVID-19) Compliance Requirement: Acti...

2022-059 Department of Human Services Ensure issued benefits are accurate Federal Awarding Agency: U.S. Department of Agriculture Assistance Listing Number and Name: 10.542 Pandemic EBT Food Benefits (COVID-19) Federal Award Numbers and Years: Not available (COVID-19) Compliance Requirement: Activities Allowed or Unallowed Type of Finding: Significant Deficiency; Noncompliance Prior Year Finding: N/A Questioned Costs: $3,692,215 (known); $13,554,666 (likely) (COVID-19) Criteria: Public Law 116-127; 2 CFR 200.303 The federal requirements for the Pandemic EBT (P-EBT) program require state agencies follow their approved state plan. Part of Oregon?s simplifying assumptions in their state plan was that the benefit amount was determined at the school level, not the individual level, based on the school?s operating status, for October 2020 ? May 2021. As part of Oregon?s Ready Schools, Safe Learners program, schools were required to weekly report their operating status/instructional model to the Oregon Department of Education (ODE). In fiscal year 2022, the Department of Human Services (department) paid retroactive P-EBT benefits for children related to the 2020-2021 school year. This sample population consisted of institutions (schools and other educational facilities) and months in which children at the institutions received benefits, totaling $391 million. We selected a random sample of 40 institutions and a random month to determine if the benefits provided to the children, based on the status reported by the institution, were accurate. We identified 4 institutions, for April/May, where the benefit paid status of the institution was not the same as reported by the institution to ODE. In all 4 cases, the benefits paid were at a higher level resulting in questioned costs of $38,931 and likely questioned costs of $9.2 million. One of the simplifying assumptions for the P-EBT program, approved in Oregon?s state plan, was ?Oregon will have a limited reconsideration process to revisit benefit allotments at a school level.? However, the department allowed institutions to update their status without additional review, explanation, or documentation. The department could not provide the auditors any support for the changes made by the institutions. Furthermore, the Oregon Governor issued a directive to schools, on March 5, 2021, to begin a phased approach to require all public schools to provide in-person instruction through either a fully on-site or hybrid model on or before the week of April 19, 2021, for all schools. Although benefits issued continued to decrease as the school year end approached, in May 2021, 26% of the institution?s benefits paid were for fully virtual totaling $17 million. We judgmentally selected 36 institutions classified as fully virtual in May with benefits totaling $7.9 million. For 25 institutions, the benefit paid status did not agree to the status reported by the institution to ODE resulting in questioned costs of $3,653,284 and likely questioned costs of $4.4 million. We recommend DHS perform review to identify any additional discrepancies between benefits paid and the institutions reported status, to determine if payments were appropriate, and communicate with the federal awarding agency to determine if repayment is necessary. MANAGEMENT RESPONSE: We respectfully disagree with the findings that schools were not able to directly update their learning mode according to the guidance provided in the P-EBT state plan. The department has included emails and documents that support the actions/decisions taken in the delivery of the Oregon P-EBT school year 2020-2021 state plan was in accordance with federal approval from Food and Nutrition Service (FNS). According to the USDA FNS approval letter received on May 7, 2021, and posted to the FNS website, FNS confirms that Oregon will ?develop(ed) a centralized database to collect student eligibility information and school status? to determine the monthly benefit level for each school (6th bullet on page 2). This information is also confirmed in email correspondence with FNS on April 29, 2021, and May 3, 2021. Within the email the Department details that Oregon will develop a database to collect school status, this is then confirmed by FNS. As part of Oregon?s federally approved simplified assumptions, the state plan allows the school points of contact to update their predominate learning model for each month of the 2020-2021 school year, which may be different than the Ready Schools, Safe Learners (RSSL) Weekly Status Report. An email communication was shared with all identified school points of contact on June 28, 2021. This email requested that school points of contact update their schools predominate learning mode into the Oregon School Meals Benefit (OSMB) system used by the Oregon Department of Human Services to issue P-EBT benefits no later than July 13, 2021. Information reported through the RSSL weekly status report was used to determine the predominate learning mode only in the event that the school point of contract did not update a learning mode manually within OSMB prior to July 13, 2021. On May 9, 2023, the P-EBT policy team confirmed school operating status during the selected months with 5 schools for SOS audit. Email responses from the schools are summarized below: ?See Corrective Action Plan for Table? At the recommendation of the auditors the Department has reached out to FNS Child Nutrition Program about the finding and we are waiting for a response. Anticipated completion date: N/A Contact: Heather Miles, SNAP, CSFP, and TEFAP Program Manager

View Audit 45093 Questioned Costs: $1

Finding 44751 (2022-005)

Material Weakness 2022

Anoka County

MN

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

Finding Number: 2022-005 Finding Title: Allowable Costs/Cost Principles and Reporting Program: Medical Assistance Program 93.778 Name of Contact Person Responsible for Corrective Action: Nicole Hegge - Sr. Manager, Accounting - Finance and Central Services Corrective Action Planned: In order to appr...

Finding Number: 2022-005 Finding Title: Allowable Costs/Cost Principles and Reporting Program: Medical Assistance Program 93.778 Name of Contact Person Responsible for Corrective Action: Nicole Hegge - Sr. Manager, Accounting - Finance and Central Services Corrective Action Planned: In order to appropriately report the revenue offset that may impact federal programs, we have updated our quarterly process ensuring that any federal revenue offsets are included in the appropriate fund and report. In some instances, this may still require the County to file amendments to federal reports; however, they will be completed no later than eight weeks following the end of the quarter. Anticipated Completion Date: December 31, 2023

View Audit 43802 Questioned Costs: $1

Finding 44747 (2022-003)

Material Weakness 2022

Anoka County

MN

Material Weakness Internal Control / Segregation of Duties

Finding Number: 2022-003 Finding Title: Internal Controls over Payroll Name of Contact Person Responsible for Corrective Action: Cory Kampf - CFO - Finance and Central Services Emily Wilson - Supervisor, Accounting - Finance and Central Services Corrective Action Planned: The Mass Approval Process d...

Finding Number: 2022-003 Finding Title: Internal Controls over Payroll Name of Contact Person Responsible for Corrective Action: Cory Kampf - CFO - Finance and Central Services Emily Wilson - Supervisor, Accounting - Finance and Central Services Corrective Action Planned: The Mass Approval Process does not overwrite the individual time sheet approval. The reports showing this were not available at the time of the audit and are being developed to resolve this issue. Discontinuing the Mass Approval may result in the need to process additional supplemental payrolls for those individuals that were not paid on the regular payday. We continue to develop additional training and tools for supervisors to help them with their responsibilities for approving time. Also, we are looking at developing procedures around supplemental payrolls with the plan to minimize the need for them. Anticipated Completion Date: December 31, 2023

View Audit 43802

Finding 44746 (2022-004)

Significant Deficiency 2022

Crookston Housing and Economic Development Authority

MN

HUD Housing Programs Reporting Significant Deficiency

1. Correcting Plan CHEDA staff are aware of Voucher for Payment of Annual Contributions and Operating Statement report monthly to HUD via the Voucher Management System (VMS) requirements and will implement appropriate review of statements prior to submission. 2. Explanation of Disagreement with the ...

1. Correcting Plan CHEDA staff are aware of Voucher for Payment of Annual Contributions and Operating Statement report monthly to HUD via the Voucher Management System (VMS) requirements and will implement appropriate review of statements prior to submission. 2. Explanation of Disagreement with the Audit Finding There is essentially no disagreement with the finding. 3. Official Responsible for Ensuring CAP Karie Kirschbaum ? Executive Director 4. Planned Completion Date for CAP Immediately. 5. Plan to Monitor Completion of CAP The Executive Director will monitor completion of the CAP.

View Audit 43800

Finding 44745 (2022-003)

Significant Deficiency 2022

Crookston Housing and Economic Development Authority

MN

HUD Housing Programs Eligibility Significant Deficiency

1. Correcting Plan CHEDA staff are aware of income eligibility documentation and will implement an internal control process. 2. Explanation of Disagreement with the Audit Finding There is essentially no disagreement with the finding.3. Official Responsible for Ensuring CAP Karie Kirschbaum ? Executi...

1. Correcting Plan CHEDA staff are aware of income eligibility documentation and will implement an internal control process. 2. Explanation of Disagreement with the Audit Finding There is essentially no disagreement with the finding.3. Official Responsible for Ensuring CAP Karie Kirschbaum ? Executive Director 4. Planned Completion Date for CAP Immediately. 5. Plan to Monitor Completion of CAP The Executive Director will monitor completion of the CAP.

View Audit 43800

Finding 44744 (2022-002)

Material Weakness 2022

Crookston Housing and Economic Development Authority

MN

Allowable Costs / Cost Principles HUD Housing Programs

1. Correcting Plan CHEDA staff are aware of allowable cost proper documentations, and will implement an internal control process. 2. Explanation of Disagreement with the Audit Finding There is essentially no disagreement with the finding. 3. Official Responsible for Ensuring CAP Karie Kirschbaum ? E...

1. Correcting Plan CHEDA staff are aware of allowable cost proper documentations, and will implement an internal control process. 2. Explanation of Disagreement with the Audit Finding There is essentially no disagreement with the finding. 3. Official Responsible for Ensuring CAP Karie Kirschbaum ? Executive Director 4. Planned Completion Date for CAP Immediately. 5. Plan to Monitor Completion of CAP The Executive Director will monitor completion of the CAP.

View Audit 43800

Finding 44743 (2022-002)

Significant Deficiency 2022

Galveston Bay Foundation, Inc.

TX

Procurement, Suspension & Debarment Reporting Significant Deficiency

Finding #2022-002 ? Significant Deficiency and Other Noncompliance Recommendation: Develop policies and procedures to meet the contract reporting requirements. Planned corrective action: In 2023, Galveston Bay Foundation created a new Director of Program Operations position. This person will be...

Finding #2022-002 ? Significant Deficiency and Other Noncompliance Recommendation: Develop policies and procedures to meet the contract reporting requirements. Planned corrective action: In 2023, Galveston Bay Foundation created a new Director of Program Operations position. This person will be responsible for the oversight of grant reporting in addition to the oversight of program operations. The Director of Program Operations will maintain a spreadsheet of all grant reporting requirements with applicable due dates. Although each grant program manager is responsible for submission of program and financial reporting related to their grant, the Director of Program Operations will work closely with each grant program manager to ensure reports due were submitted timely as required by the individual grant contract. Responsible officer: Robert Stokes, President and CEO Estimated completion date: Immediately

View Audit 40559

Corrective Action Plans

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