Corrective Action Plans

#2022-003 Untimely Data Collection Form and Single Audit Reporting Submission U.S. Department of Education Title I Grants to Local Educational Agencies #84.010 U.S. Department of Education Education Stabilization Fund (ESF) #84.425 Recommendation: We recommend that Management of the Board of Educati...

#2022-003 Untimely Data Collection Form and Single Audit Reporting Submission U.S. Department of Education Title I Grants to Local Educational Agencies #84.010 U.S. Department of Education Education Stabilization Fund (ESF) #84.425 Recommendation: We recommend that Management of the Board of Education take the necessary steps to ensure that the year-end financial statements are supported by accurate reconciliations and documentation in a timely manner so that the reporting package and data collection form can be submitted as required. Action Taken: Management of the Board of Education will properly plan and take the necessary steps to ensure that year-end financial statements are supported by accurate reconciliations and other documentation so that the reporting package and data collection form can be submitted as required by the Uniform Guidance. Joseph Campinelli III, Treasurer/Chief School Business Official is responsible for implementing these procedures by March 31, 2024.

View Audit 28309

Finding 32562 (2022-004)

Significant Deficiency 2022

City of Whitewood

SD

Allowable Costs / Cost Principles

Finding No. 2022-004: Written Uniform Guidance Policies The City is working on developing written Uniform Guidance policies. Cory Heckenlaible, Finance Officer, is responsible for this finding.

View Audit 27978

Finding 32561 (2022-001)

Material Weakness 2022

City of Whitewood

SD

Reporting

Finding No. 2022-001: Financial Statement and Schedule of Expenditures of Federal Awards Preparation The City has accepted the risk associated with Finding #2022-001 regarding the preparation of the financial statements and will continue to have the independent auditor prepare the annual financial ...

Finding No. 2022-001: Financial Statement and Schedule of Expenditures of Federal Awards Preparation The City has accepted the risk associated with Finding #2022-001 regarding the preparation of the financial statements and will continue to have the independent auditor prepare the annual financial statements. For future audits, Finance Officer Cory Heckenlaible will continue to monitor the financial statement preparation and determine if any modification is necessary.

View Audit 27978

Finding 32560 (2022-001)

Material Weakness 2022

Richland School District No. 400

WA

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Richland School District No. 400 September 1, 2021 through August 31, 2022 This schedule presents the corrective action the District is planning to take for findings included in this report in accordance with Title 2 U.S. Code of F...

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Richland School District No. 400 September 1, 2021 through August 31, 2022 This schedule presents the corrective action the District is planning to take for findings included in this report in accordance with Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Finding ref number: 2022-001 Finding caption: The District did not have adequate internal controls for ensuring compliance with allowable activities and costs and restricted purpose requirements. Name, address, and telephone of District contact person: Cynthia Robinette, Assistance Finance Director 6972 Keene Rd West Richland, WA 99353 Corrective action the auditee plans to take in response to the finding: This audit finding related to unique rules associated with one-time, pandemic-necessitated funding, so RSD is extremely unlikely to have to navigate these compliance expectations ever again. However, RSD will aspire to slow down the procurement and deployment of grant-funded resources as long as possible in the future in order to learn more of what the final audit expectations may be. Anticipated date to complete the corrective action: Undeterminable based on rarity of event

View Audit 28233 Questioned Costs: $1

Finding 32515 (2022-002)

Material Weakness 2022

Jardines De Aguada - Municipality of Aguada

PR

Reporting

Finding No. 2022-002: Late submission of single audit report package. Category: Federal Programs Internal Controls and Noncompliance Management Response and/or Action: To ensure the financial information to complete the Government Wide and Governmental Funds financial statements and Schedule of Expe...

Finding No. 2022-002: Late submission of single audit report package. Category: Federal Programs Internal Controls and Noncompliance Management Response and/or Action: To ensure the financial information to complete the Government Wide and Governmental Funds financial statements and Schedule of Expenditures of Federal Awards are available at a timely basis and free of errors, the Municipality has implemented a plan to improve the accounting reconciliation function and correct the financial system accounting balances that had not been in agreement with the financial statements for many previous years, therefore, was required extensive analyses of the information provided by the accounting system that results in significant manual adjusting entries to present accurate financial information in accordance with GAAP. The plan also includes training of current employees, recruiting capable finance personnel, timely oversight from the Finance Director over the year end reconciliation process and correction of errors. This will improve the flow and accuracy of the financial information and accounting balances being produced by the finance department that in turn will result in time savings and a more effective process of preparation of financial statements that will lead to having them available with enough time to be audited by the corresponding audit firm and be submitted to the federal government in compliance with the March 31 deadline. As mentioned before, part of this lag in accounting and reporting of the financial statements have been caused by the limitation on the personnel to perform accounting and financial reporting tasks on a timely basis due to a series of uncontrollable weather and COVID health factors that required the use of the personnel to address the emergency for the benefit of the community. In September 2022 we suffer a hurricane strike (Hurricane Fiona) that partially affected the working conditions of the municipal employees and their duties assigned. All the municipal employees were assigned also to attend the Fiona effects in the community, delivery of goods, coordination and attending the immediate needs, therefore the municipal efforts were directed to assist in hurricane recovery and address the community needs rather than at focus on administrative duties. Also, we still are working with the work integration of finance and administrative after the COVID Pandemic, we still have some employees that prefer to work on a remote status and part time basis. Part of these conditions had caused some of the delays in recording and submissions, however these are not intentionally situations. Such situations are in process of analysis and improvement taking in consideration the size of the municipality and its actual financial and budgetary resources. Assigned Responsibility: Geavelis Perez Ruiz, Finance Director Anticipated Completion Date: June 30, 2023

View Audit 32984

Finding 32514 (2022-002)

None 2022

Housing Partners for Positive Living, Inc.

RI

HUD Housing Programs

August 26, 2022 D?Ambra CPA 531 Harris Avenue Woonsocket, RI 02895 RE: Corrective Action Plan: HPPL Finding 2022-001: Federal program - Section 811: Criteria - HUD regulations require residual receipt escrow funds in excess of $250 per unit to be remitted to HUD upon expiration of the subsidy contra...

August 26, 2022 D?Ambra CPA 531 Harris Avenue Woonsocket, RI 02895 RE: Corrective Action Plan: HPPL Finding 2022-001: Federal program - Section 811: Criteria - HUD regulations require residual receipt escrow funds in excess of $250 per unit to be remitted to HUD upon expiration of the subsidy contract; Condition - the property's residual receipts liability for the prior year totaling $14,181 was not paid; Cause - management oversight; Recommendation - management remit to HUD the prior year residual receipts amount as required. In addition, the current year additional excess totaling $23,624 should also be remitted. Response: Management will remit to HUD the prior year's and current year's residual receipts amount. Finding 2022-002: Federal program - Section 811: Criteria - HUD regulations requires surplus cash be deposited within 90 days of year end; Condition - management deposited the prior year's surplus cash 28 days late; Cause - management oversight; Recommendation - management should deposit the surplus cash within the 90 day time period Response: Management will deposit future surplus cash in a timely manner. Corrective Action Plan: Management has adopted the attached internal control workflow to ensure that program requirements are more strictly adhered to. We have also expanded our finance department by 2 FTE?s in the past two years (including a new position of Financial Analyst/Asset Manager in July 2022) to ensure that we have proper staffing to monitor properties financial performance and compliance with program requirements. Responsible party: Frank Shea

View Audit 31725

Finding 32513 (2022-001)

None 2022

Housing Partners for Positive Living, Inc.

RI

HUD Housing Programs

August 26, 2022 D?Ambra CPA 531 Harris Avenue Woonsocket, RI 02895 RE: Corrective Action Plan: HPPL Finding 2022-001: Federal program - Section 811: Criteria - HUD regulations require residual receipt escrow funds in excess of $250 per unit to be remitted to HUD upon expiration of the subsidy contra...

August 26, 2022 D?Ambra CPA 531 Harris Avenue Woonsocket, RI 02895 RE: Corrective Action Plan: HPPL Finding 2022-001: Federal program - Section 811: Criteria - HUD regulations require residual receipt escrow funds in excess of $250 per unit to be remitted to HUD upon expiration of the subsidy contract; Condition - the property's residual receipts liability for the prior year totaling $14,181 was not paid; Cause - management oversight; Recommendation - management remit to HUD the prior year residual receipts amount as required. In addition, the current year additional excess totaling $23,624 should also be remitted. Response: Management will remit to HUD the prior year's and current year's residual receipts amount. Finding 2022-002: Federal program - Section 811: Criteria - HUD regulations requires surplus cash be deposited within 90 days of year end; Condition - management deposited the prior year's surplus cash 28 days late; Cause - management oversight; Recommendation - management should deposit the surplus cash within the 90 day time period Response: Management will deposit future surplus cash in a timely manner. Corrective Action Plan: Management has adopted the attached internal control workflow to ensure that program requirements are more strictly adhered to. We have also expanded our finance department by 2 FTE?s in the past two years (including a new position of Financial Analyst/Asset Manager in July 2022) to ensure that we have proper staffing to monitor properties financial performance and compliance with program requirements. Responsible party: Frank Shea

View Audit 31725

Finding 32512 (2022-001)

Material Weakness 2022

Uc Healthcare System

OH

Allowable Costs / Cost Principles Eligibility Special Tests & Provisions

Corrective Action Plan Federal Award Findings and Questioned Costs For the Fiscal Year Ended June 30, 2022 Finding 2022-001 ? A. Activities Allowed or Unallowed; B. Allowable Costs/Cost Principles; E. Eligibility; N. Special Tests and Provisions Federal program information: Federal Program: ...

Corrective Action Plan Federal Award Findings and Questioned Costs For the Fiscal Year Ended June 30, 2022 Finding 2022-001 ? A. Activities Allowed or Unallowed; B. Allowable Costs/Cost Principles; E. Eligibility; N. Special Tests and Provisions Federal program information: Federal Program: 93.461, HRSA COVID-19 Claims Reimbursement for the Uninsured Program and the COVID-19 Coverage Assistance Fund (COVID-19 Uninsured Program) Federal Agency: U.S. Department of Health and Human Services (HHS), Health Resources and Services Administration (HRSA) Locations: Various Award Numbers: Various Award Period: July 1, 2021 through June 30, 2022 Summary of finding: UC Health did not design or appropriately document internal controls to monitor the terms and conditions and underlying HRSA COVID-19 Uninsured Program regulations during the COVID-19 pandemic. Additionally, UC Health did not have internal controls in place to formally document its compliance with the HRSA COVID-19 Uninsured Program?s allowability and eligibility requirements. While management has processes in place to review claims for potential insurance coverage before initial billing, evidence of insurance reviews and subsequent verification of lack of coverage was not retained. Refunds required to be made to the HRSA COVID-19 Uninsured Program were not identified timely. Planned corrective action: Management has reviewed claims submitted to the HRSA COVID-19 Testing for the Uninsured Program for potential payments for ineligible services and timely processed refunds as appropriate. In March 2022, HRSA announced the discontinuance of the HRSA COVID-19 Testing for the Uninsured program and, therefore, remediation of internal controls in no longer applicable. Completion date: December 31, 2022 Responsible contact person: Crag Cain, Vice President of Revenue Cycle Management

View Audit 29116

Finding 32511 (2022-002)

Material Weakness 2022

Uc Healthcare System

OH

Questioned Costs Allowable Costs / Cost Principles Reporting

Corrective Action Plan Federal Award Findings and Questioned Costs For the Years Ended December 31, 2020 and 2021 Finding 2022-002 ? A. Activities Allowed or Unallowed; B. Allowable Costs/Cost Principles; L. Reporting Federal program information: Federal Program: 93.948, COVID-19 Provider Relief ...

Corrective Action Plan Federal Award Findings and Questioned Costs For the Years Ended December 31, 2020 and 2021 Finding 2022-002 ? A. Activities Allowed or Unallowed; B. Allowable Costs/Cost Principles; L. Reporting Federal program information: Federal Program: 93.948, COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Federal Agency: U.S. Department of Health and Human Services (HHS), Health Resources and Services Administration (HRSA) Locations: Various Award Numbers: Various Award Period: January 1, 2020 through June 30, 2022 Summary of finding: UC Health did not have effective internal controls in place to ensure expenses and lost revenues reported in the Portal were not duplicated. This resulted in the overstatements of expenses and lost revenues reported in the Portal. Planned corrective action: Management will establish processes for reviews of the reporting guidelines to better interpret and comply with the guidelines for future reporting. Anticipated completion date: Prior to next filing due September 30, 2023 Responsible contact person: Michael Wiedeman, Vice President and Controller

View Audit 29116 Questioned Costs: $1

Finding 32493 (2022-008)

Significant Deficiency 2022

Commonwealth of Pennsylvania

PA

Questioned Costs Subrecipient Monitoring § 200.332 § 200.425

New Directions DHS is exploring different possibilities to satisfy the audit finding to include the contracting of a certified public accounting firm to assist in conducting the financial portion of our subrecipient monitoring. Alternatives to Abortion Office of Policy Development (OPD) initiated n...

New Directions DHS is exploring different possibilities to satisfy the audit finding to include the contracting of a certified public accounting firm to assist in conducting the financial portion of our subrecipient monitoring. Alternatives to Abortion Office of Policy Development (OPD) initiated numerous conversations with the Alternatives to Abortion grantee regarding receiving the requested documentation for monitoring (communication occurred regularly from April 2021 through January 2023). The grantee disagrees that the disclosure of this information is a requirement of the grant agreement and as such has not provided the documentation needed to complete the monitoring. On October 27, 2022, DHS sent a letter to the grantee outlining specific action steps to establish compliance with their grant agreement. The grantee responded on November 28, 2022, disputing the claims of DHS and asserting that they are not out of compliance with their grant agreement. OPD will be scheduling time to visit the grantee to review documents required by the terms of their grant agreement in order to complete the monitoring. Monitoring will occur by June 30, 2023. Anticipated Completion Date: New Directions- 03/01/2024; Alternatives to Abortion- 06/30/2023 Contact Person and Title: New Directions- Joel O?Donnell, Director, Bureau of Program Support, OIM; Alternatives to Abortion- Ana Arcs, Acting Policy Director, OPD

View Audit 27724 Questioned Costs: $1

Finding 32489 (2022-013)

Significant Deficiency 2022

Commonwealth of Pennsylvania

PA

Questioned Costs Subrecipient Monitoring Reporting § 200.1 § 200.332

DHS: The Office of Children, Youth, and Families (OCYF) is sending out a Restrictions and Requirements document with each tentative and final allocation letter. This document lists all OCYF?s grants, the federal agency granting the fund and where to find the rules and regulations guiding the usage o...

DHS: The Office of Children, Youth, and Families (OCYF) is sending out a Restrictions and Requirements document with each tentative and final allocation letter. This document lists all OCYF?s grants, the federal agency granting the fund and where to find the rules and regulations guiding the usage of the funds. For the State fiscal year 2021-2022, Tentative Allocation Letters were sent out on April 1, 2021, with Federal Award Identification Numbers (FAIN) and funding amounts. Final Allocation Letters were sent out August 12, 2021, with the Amount, FAIN and Name. OCYF has a risk assessment process in place for Title IV-E and TANF awards. During the Quality Assurance reviews, which occur twice a year at a minimum, OCYF reviews a sample of Title IV-E eligible foster care cases, Title IV-E ineligible foster care cases, Title IV-E eligible adoption assistance cases, and TANF eligible cases. Depending on the number of eligibility and claiming errors identified during the review, OCYF schedules more frequent visits as the risk of repeated and continued errors in these County Children and Youth Agencies (CCYAs) is higher. Inaccurate eligibility determinations lead to inaccurate federal claiming, so basing the review schedule on a CCYA?s eligibility review outcome allows OCYF to target those CCYAs where inaccurate claiming is a higher risk. However, to further address this finding, the risk assessment now includes documentation. Anticipated Completion Date: Completed Contact Person and Title: TinaMarie Petrovitz, Director of County Support DOH: The Department plans to develop and implement a robust subrecipient monitoring program which includes establishing a new section within the Budget Office pending enacted budget funds and complement to support the creation of the section. Initiative goals/milestones include: - Assessment: Comprehensive assessment of all current federal grants and subawards and their processes. This assessment will document best practices and identify gaps within the agency?s processes. It will also provide an evaluation of current operational and technological resources that can be leveraged to facilitate compliance. Target start date: February 27, 2023. Target completion date: June 30, 2023. - Educate Department: Budget Office is developing a bulletin that will outline the subrecipient monitoring requirements with links to State and Federal Sources. The bulletin will be shared with all program office staff. The Budget Office will develop the following templates and provide to all program offices: - Determination of vendor status: Subrecipient or Contractor - Risk Assessment Form - Internal Control Self-Assessment for Subrecipient Template - Subrecipient Monitoring Template All materials will be updated with any additional information gained during the assessment. Start date: February 3, 2023. Target Completion Date: June 30, 2023 - Implementation of full compliance initiative: Recommendations provided in the assessment will be used to develop and implement comprehensive policies and procedures led by a new section in the Budget Office. Target start date July 1, 2023. Target fully operational date: June 30, 2024. Anticipated Completion Date: 06/30/2024 Contact Person and Title: Andrea Race, CFO

View Audit 27724 Questioned Costs: $1

Finding 32478 (2022-009)

Significant Deficiency 2022

Commonwealth of Pennsylvania

PA

Special Tests & Provisions Significant Deficiency Matching / Level of Effort / Earmarking

Office of Medical Assistance Programs? Bureau of Data and Claims Management (BDCM) is currently negotiating an amendment to the PROMISe contract with Gainwell Technologies which will bolster the NCCI performance requirement to explicitly include the elements identified in the finding. Anticipated C...

Office of Medical Assistance Programs? Bureau of Data and Claims Management (BDCM) is currently negotiating an amendment to the PROMISe contract with Gainwell Technologies which will bolster the NCCI performance requirement to explicitly include the elements identified in the finding. Anticipated Completion Date: 05/01/2023 Contact Person and Title: Toni Hoffecker, Dir., Div. of Systems, Monitoring and Oversight, BDCM

View Audit 27724

Finding 32472 (2022-012)

Material Weakness 2022

Commonwealth of Pennsylvania

PA

Subrecipient Monitoring Matching / Level of Effort / Earmarking

The following steps were taken to address this material weakness: ? FFATA procedures will be updated to populate the award date in the grant internal order (IO) when the grant is set up in SAP instead of when the grant is in FSRS. ? General Accounting will review their IOs to ensure the award da...

The following steps were taken to address this material weakness: ? FFATA procedures will be updated to populate the award date in the grant internal order (IO) when the grant is set up in SAP instead of when the grant is in FSRS. ? General Accounting will review their IOs to ensure the award date is populated. ? A procedure workgroup will be established to ensure a consistent FFATA review in General Accounting. Anticipated Completion Date: 05/31/2023 Contact Person and Title: Sandra Bruno, Integrated Financial Service Manager; Jamie Jerosky, Assistant Director

View Audit 27724

Finding 32463 (2022-004)

Significant Deficiency 2022

Commonwealth of Pennsylvania

PA

Questioned Costs Subrecipient Monitoring Reporting § 200.303

PDE uses its eGrants system to collect all LEA required records under ESSER I and ESSER II. The eGrants system is designed to allow licensed educational agencies and certain community-based programs within the Commonwealth, access to PDE grants. Through this system, the LEA can submit applications f...

PDE uses its eGrants system to collect all LEA required records under ESSER I and ESSER II. The eGrants system is designed to allow licensed educational agencies and certain community-based programs within the Commonwealth, access to PDE grants. Through this system, the LEA can submit applications for funding, e-sign contracting documents, upload back-up documentation, submit program quarterly reports, and file final expenditure reports. PDE Division of Federal Programs also utilizes Pennsylvania's Information Management System (PIMS) to collect and verify LEA data. PIMS has business rules built in to ensure valid data collection. The eGrants system makes it possible for records pertaining to the ESSER awards to be retained separately from other grant funds, including funds that an SEA or LEA receives under the CARES Act and CRRSA. This follows the requirements under 2 C.F.R. ? 200.334 and 34 C.F.R. ? 76.730, including financial records related to the use of grant funds. Through quarterly financial reporting, LEAs are required to report the amount of cash received, expended, and on hand. If the amount of cash-on-hand reported is determined to be too high, or the quarterly report is not submitted, monthly payments will be suspended until the next quarterly report is due. Current monitoring to verify data and ensure compliance with existing federal guidelines, typically occurs from January through May. LEAs receive a unique username and password to access Fedmonitor and complete an online self-assessment. Beginning in October 2022, all LEAs were placed on a four-year monitoring cycle and were monitored in the 2021?22 fiscal year and will be monitored again in the 2024?25 fiscal year. Data collected in eGrants, PIMS and Fedmonitor is verified during these monitoring visits. Anticipated Completion Date: Completed Contact Person and Title: Susan McCrone, Division Manager, Federal Programs; Brian Campbell, Director, Bureau of Curriculum, Assessment, and Instruction

View Audit 27724 Questioned Costs: $1

Finding 32457 (2022-011)

Significant Deficiency 2022

Commonwealth of Pennsylvania

PA

Subrecipient Monitoring Reporting Significant Deficiency

While the Governor?s Budget Office agrees with the fact cited in finding, it is not possible to correct the situation and the error had no impact on the implementation of the federal program. No corrective action is necessary, nor would it have any discernable impact. The Interim Report was a one-...

While the Governor?s Budget Office agrees with the fact cited in finding, it is not possible to correct the situation and the error had no impact on the implementation of the federal program. No corrective action is necessary, nor would it have any discernable impact. The Interim Report was a one-time progress report required by U.S. Treasury to document our state?s progress in spending State and Local Fiscal Recovery Funds and distributing, on the behalf of the U.S. Treasury, payments from the Treasury to Non-Entitlement Units (NEU) of local government as of July 31, 2021. The Interim Report also required states to provide revenue replacement calculations for calendar year 2020. This report was due on August 31, 2021. There were no follow up reports using the same format as the Interim Report. The figures reported as transfers to NEUs in the Interim Report accurately reflected the total dollars that had been electronically transferred to local governments as of July 31, 2021, as that was how we interpreted the federal guidance at the time. It was our interpretation that U.S. Treasury wanted information on how much had been distributed and received by NEUs as of July 31, 2021, rather than how many payments we had approved in our accounting system and were in the process of being paid. After filing the Interim Report, the Office of the Budget continued to report updates of distributions to NEUs both using a U.S. Treasury portal, and ultimately by exchanging spreadsheets of NEU data with the US Treasury to painstakingly ensure the data the U.S. Treasury had was correct. The Office of the Budget will continue to file compliance reports in accordance with U.S. Treasury?s guidance. At no time did the U.S. Treasury indicate there were issues with the composition or acceptability of our filed Interim Report. At this time, all NEU funds received from the federal government have been either distributed to NEUs or have been returned to the U.S. Treasury and this program is complete. Therefore, we are currently not required to, nor do we have plans to report on the progress of NEU distributions to the federal government in the future. Anticipated Completion Date: N/A Contact Person and Title: Mike Wood, Bureau Director, Bureau of Performance, Revenue, and Program Analysis; Colleen Kling, Division Manager, Division of Program Analysis and Performance Improvement

View Audit 27724

Finding 32455 (2022-007)

Significant Deficiency 2022

Commonwealth of Pennsylvania

PA

Questioned Costs Subrecipient Monitoring Reporting § 200.303

Similar to other DHS programs, DHS has implemented an after-action review of information submitted, using a contracted vendor. DHS faced challenges implementing a program with 67 counties and no central eligibility determination system. DHS has learned that implementing the supportive services and m...

Similar to other DHS programs, DHS has implemented an after-action review of information submitted, using a contracted vendor. DHS faced challenges implementing a program with 67 counties and no central eligibility determination system. DHS has learned that implementing the supportive services and multi-sector partnerships was challenging in the context of the global pandemic and workforce shortages. This made DHS dependent on local county reports to maintain program oversight and compile statewide data for submission to US Treasury. DHS plans to strengthen this control as we plan for future emergency or pandemic programs related to rental assistance. Anticipated Completion Date: 06/30/2023 Contact Person and Title: Joel O?Donnell, Director, Bureau of Program Support, OIM

View Audit 27724 Questioned Costs: $1

Finding 32453 (2022-005)

Material Weakness 2022

Commonwealth of Pennsylvania

PA

Questioned Costs Subrecipient Monitoring § 200.332 § 200.425 § 200.521

AMLR program representatives attended Department of Interior, Office of Surface Mining Reclamation and Enforcement online training covering 2 CFR 200 and contractor or subrecipient determinations. DEP ceased issuing AMLR grants under Management Directive 305.20, Grant Administration. DEP managem...

AMLR program representatives attended Department of Interior, Office of Surface Mining Reclamation and Enforcement online training covering 2 CFR 200 and contractor or subrecipient determinations. DEP ceased issuing AMLR grants under Management Directive 305.20, Grant Administration. DEP management has determined the recipients with existing agreements are subrecipients and DEP will follow this determination consistently with future agreements and accounting. DEP has developed written policies and procedures for subrecipient monitoring and has notified grantees to implement the policies and procedures immediately to ensure timely subrecipient compliance with federal regulations. Anticipated Completion Date: Completed Contact Person and Title: Patrick Webb, Acting Dir., Bureau of AMLR; Tim Golding, Executive Assistant, Office of Admin. and Management

View Audit 27724 Questioned Costs: $1

Finding 32431 (2022-014)

Material Weakness 2022

Commonwealth of Pennsylvania

PA

Questioned Costs Subrecipient Monitoring Reporting § 200.208 § 200.332 § 200.339 § 200.501 § 200.505

PDE: Audits retrieved from the Federal Audit Clearinghouse are now reviewed after entry into PDE?s SharePoint website, to ensure PDE remains compliant with federal guidelines to respond to any and all findings pertaining to federal dollars it passes to subrecipients. Likewise, PDE Audit Section cont...

PDE: Audits retrieved from the Federal Audit Clearinghouse are now reviewed after entry into PDE?s SharePoint website, to ensure PDE remains compliant with federal guidelines to respond to any and all findings pertaining to federal dollars it passes to subrecipients. Likewise, PDE Audit Section continues to improve upon its processes for timely determinations of those single audits with findings by multiple means, including periodic SharePoint enhancements designed to aid in timely review of single audit packages, working closely with PDE program areas to assist in timely responses and quickly addressing SharePoint access issues as they arise. Anticipated Completion Date: 06/30/2023 Contact Person and Title: Clayton P. Carroll, II, Audit Coordinator; Jessica Sites, Director, Bur. of Budget and Fiscal Mgmt DEP: BAFM now provides agencies with single audit reporting packages that have findings each week that have been accepted by the Federal Audit Clearinghouse (FAC). This allows for us to start our management decision process in a timelier manner and meet the six-month deadline for issuing our decision. This information first appeared in our notifications starting April 30, 2021. In addition, the DEP program that had been previously identifying agreements as contracts rather than subrecipient agreements has corrected this issue and all subrecipients have been notified in writing of this correction and provided the information for submitting their single audits (if necessary). The letters were sent to subrecipients on approximately May 31, 2022. DEP Fiscal Management staff will continue to monitor the BAFM SharePoint site and FAC for additional filings to attempt to avoid this issue in the future. DEP is also hiring additional staff for the oversight and monitoring of the subrecipient single audits to ensure compliance with all requirements. These positions are currently in the filing process, and we are hopeful that they will be filled, and staff trained by September 30, 2023. Anticipated Completion Date: 09/30/2023 Contact Person and Title: Jennifer L. Brandt, Senior Fiscal Management Specialist, Federal Grants and Audits DOH: NORTH Inc.?s Single Audit report for the period ending 9/30/2020 was officially submitted and showing on the FAC on 2/9/2023. Bureau of WIC staff reached out to the Director and CFO of NORTH Inc. by phone and email. Emails were sent with instructions on how to submit the report as well as the importance of submitting the report timely per their grant agreement. Each follow-up phone call included discussion on the importance of submitting their single audit as soon as possible. Moving forward the Bureau of WIC will implement the following procedure: 1 .Three months after the end of the audit period (Federal Fiscal Year), Project Officers will send an email that outlines the process for submitting a single audit reporting package to the FAC to their respective WIC local agencies. This email will provide a date that the single audit is due to be submitted to the FAC in order to stay in compliance with their current WIC grant agreement. 2. Six months after the end of the audit period (three months from the due date of the single audit reporting package) an official letter from the Bureau Director will go out to the WIC local agencies that are due to submit a single audit. The letters will include instructions on how to submit the single audit in FAC and the Audit Requirements link referenced in their grant agreement. 3. If the WIC local agency notifies the Bureau of WIC that their auditor will not be able to submit their agency?s single audit by the due date, then the Project Officer will work with the local agency to get a projected date of completion and a timeline on when the local agency?s auditor is able to finalize the audit and submit it to the FAC. The Bureau of WIC will then notify DOH?s Audit Coordinator and OB-BAFM of this information, so they are able to track it. 4. If the WIC local agency does not submit the report by the due date and fails to notify their project officer; a notice to cure letter will be sent to the agency. Concerning NORTH Inc.?s Single Audit report for the period ending September 30, 2021: 1. The Bureau of WIC will contact NORTH Inc. and request a meeting with their auditor. 2. Following the meeting with NORTH Inc.?s auditor, the Bureau Director will send an official letter to NORTH Inc. The letter will include the instructions on how to submit the single audit in the FAC and the Audit Requirements link referenced in their grant agreement. They will also be made aware of the actions that could result from them not submitting this audit by the agreed upon date. 3. If the single audit is not received by the agreed upon date, then the Bureau of WIC will send a notice to cure letter. Anticipated Completion Date: 03/24/2023 Contact Person and Title: Sally Zubairu-Cofield, Director, Bureau of WIC DHS: Regarding the timeliness of finding resolution and procedures related to the SEFA reviews, the Audit Resolution Section (ARS) hired an additional staff member in August 2021 and hired two additional staff members in February 2022, and an additional staff member in January 2023. Finally, the ARS worked with Office of the Budget, Bureau of Accounting and Financial Management to develop a risk-based approach for single audit reviews, which will greatly streamline the process of single audit reviews to gain substantial efficiencies. Regarding late audit report submissions, we will continue to follow the requirements of 2 CFR ?200.339 and Commonwealth Management Directive 325.8. We will continue to work with counties and their independent auditors to obtain any late Single Audit reports. Anticipated Completion Date: 06/30/2023 Contact Person and Title: David Bryan, Manager, ARS; Alexander Matolyak, Director, Division of Audit & Review

View Audit 27724 Questioned Costs: $1

Finding 32430 (2022-010)

Significant Deficiency 2022

Commonwealth of Pennsylvania

PA

Reporting School Nutrition Programs Equipment & Real Property Management

IT - PDA?s PA Meals team will incorporate appropriate migration strategies within the policy of ITP_INF000, along with providing a migration audit plan checklist for any future data migrations. Additionally, the INF000 will be incorporated into the Delivery Center?s development framework, where a...

IT - PDA?s PA Meals team will incorporate appropriate migration strategies within the policy of ITP_INF000, along with providing a migration audit plan checklist for any future data migrations. Additionally, the INF000 will be incorporated into the Delivery Center?s development framework, where appropriate. PDA added a Business Analyst to the team for assisting with future application testing and documentation. This individual will be directly involved in helping develop and orchestrate a testing strategy based on delivery center standards to include, but not limited to: - Determine appropriate criteria to be tested. - Assist in establishing a test group of qualified testers. - Coordinate with technical team on pass/fail criteria. - Utilize standard testing tasks/checklists ensuring consistency. - Assist the team, key business users and the technical team in reviewing testing results. The reports were reviewed electronically (100s of report pages) checking for various scenarios. As a result, these complete reports are similar and difficult to distinguish between without an associated checklist and specific report criteria. In the future, full test plans and execution results capturing pass/fail of the defined tests will be retained in pdf (or similar) format. The team will continue with best practices and delivery center standards, utilizing a Business Analyst as part of the testing and review process. The SEFA report had extensive testing, however, there is a timing issue that will always exist if the expectation is to provide the data in both January and September. The January report will be accurate for when it is run, along with what transactions were sent by the warehouse vendor. Subsequently, changes can and will occur to those commodities being reported on over the next 6 months. Additionally, it is reliant upon the warehouse vendor to report all transactions timely. As a result, running the same report after June 30th will consistently vary due to a physical inventory review in June, along with additional transactions being updated as part of the inventory review. PDA is recommending a one-time annual report in September, which will include all the adjustments from a June physical inventory and updated transactions. A January report is fine to run but should not be considered a fully accurate assessment due to the timing and missing data. Program - PDA strives to maintain accurate and complete records with respect to the receipt, distribution, and inventory of USDA donated foods, including end products processed from donated food. To that end, PDA has already or will put the following steps in place to strengthen procedures for future periods to ensure errors identified during the reconciliation process are corrected timely in the system: 1) All findings noted with regards to the Commodity Processors Inventory Report have been corrected and no known issues remain. 2) No further inventory balances remain on record with inactive distributors, as all product was previously transferred to active distributors. 3) Processor monthly performance reports (MPRs) will be completed and filed in accordance with USDA?s prescribed schedule (90 days after completion of month). 4) BFA will work with the Commodity Distributors and USDA to mutually resolve discrepancies and achieve reconciliation with USDA receipts. 5) Moving forward, all Commodity Distributor Inventory Reports will be reconciled by the beginning of a new federal fiscal year (October 1), and inventory balances at commodity distributors will agree with year-end physical inventory counts. Anticipated Completion Date: IT - 09/30/2023; Program 1-Completed; 2-Completed; 3-09/30/2023; 4-09/30/2023; 5-09/30/2023 Contact Person and Title: Caryn Long Earl, PDA, Director, Bureau of Food Assistance (BFA)

View Audit 27724

Finding 32426 (2022-006)

Material Weakness 2022

Commonwealth of Pennsylvania

PA

Questioned Costs Special Tests & Provisions Subrecipient Monitoring

Bureau of Operations (BOO): BOO will take the following actions to address the finding: 1. All CAOs and district offices will be reminded of the EBT Coordinators?, alternates?, pinners?, and card makers? responsibilities. The BOO will ensure users in the EBT Card Tracking Database know their respo...

Bureau of Operations (BOO): BOO will take the following actions to address the finding: 1. All CAOs and district offices will be reminded of the EBT Coordinators?, alternates?, pinners?, and card makers? responsibilities. The BOO will ensure users in the EBT Card Tracking Database know their responsibilities and segregation of duties and will ensure there is coverage for card pinning until 5:00 pm each business day. Also, reminders to be sent to review the OIM EBT Procedural Manual periodically and when updates occur. This has already taken place on October 7, 2022. 2. All CAOs and district offices will be reminded to maintain adequate security of the EBT cards, card inventory, pinning devices, and ribbons. The EBT office will ensure all offices have two pinning devices and that they are in working order. This has already taken place on October 7, 2022. 3. OIM mandates annual training for EBT personnel to be completed at the beginning of each year. The training includes reviewing the procedures that safeguard access to the EBT systems. Also included are the following: a. Review of roles and responsibilities and who may hold a role b. Card maker and pinner coverage for all business hours c. Proper security for EBT cards and associated items d. Timeframes for submitting changes e. Retention timeframes Training was completed in January 2023. Area managers and staff assistants monitor completion of the training. Bureau of Program Support (BPS)/EBT Project Office: BPS will take the following actions to address the finding: 1. The EBT Project Office will make updates to the EBT Procedures Manual (Manual) and OIM EPPIC EBT Systems Application form (application) as needed. Notification of updates will be sent to CAO staff via email. This is expected to occur by April 30, 2023. 2. The EBT Program office will provide guidelines for the CAOs to follow when reviewing/updating their written internal procedures for EBT security of card mailings. This is expected to occur by April 30, 2023. 3. The EBT Project Officer will start retraining parties that are responsible for the completion of the EBT Headquarters Card Destruction log. This is expected to occur by May 1, 2023. Bureau of Program Evaluation (BPE), Division of Corrective Action (DCA) will take the following actions to address the finding: BPE, DCA conducts EBT Card Security reviews at every CAO and District Office that issues EBT cards. These reviews are completed on a consistent basis, and in the future will be completed annually on a 3-year rotation basis, to ensure the improvement of the execution of documented policies and procedures. BPE/DCA will adjust the review criteria to incorporate any procedural changes implemented in the Electronic Benefit Transfer Handbook. Current rotation schedule spans FFY 2022- FFY 2024. The annual reviews for this cycle started October 2022. Anticipated Completion Date: BOO 1,2, 3- Completed; BPS 1, 2- 04/30/2023; BPS 3- 05/01/2023; BPE- Completed Contact Person and Title: BOO- Jeanette Coulston, Staff Assistant to Director of Bureau of Operations; BPS- Tonya Holloway, Division Director; BPE- Amira S. Milikin, Division Director

View Audit 27724 Questioned Costs: $1

Finding 32425 (2022-001)

Significant Deficiency 2022

Area Xv Multi-County Housing Agency

IA

HUD Housing Programs Special Tests & Provisions Subrecipient Monitoring

The Authority recognizes that the utility schedule was not updated in the most recent fiscal year. There has been staff turnover in the Authority in the roles that have oversight over these policies and in the transition, numerous things were not communicated as to whose responsibility it now is. Th...

The Authority recognizes that the utility schedule was not updated in the most recent fiscal year. There has been staff turnover in the Authority in the roles that have oversight over these policies and in the transition, numerous things were not communicated as to whose responsibility it now is. The Executive Director will be contacting HUD to determine the next course of action as the utility allowance schedule has been updated for 2023.

View Audit 27901

Finding 32418 (2022-003)

Significant Deficiency 2022

Crawford County Community School Corporation

IN

Subrecipient Monitoring Reporting Significant Deficiency § 200.302 § 200.303 § 200.328

Finding 2022-003 Information on the federal program: Subject: Education Stabilization Fund ? Internal Controls Federal Agency: Department of Education Federal Program: COVID-19 ? Education Stabilization Fund Assistance Listing Number: 84.425C, 84.425D, 84.425U Pass-Through Entity: Indiana Departmen...

Finding 2022-003 Information on the federal program: Subject: Education Stabilization Fund ? Internal Controls Federal Agency: Department of Education Federal Program: COVID-19 ? Education Stabilization Fund Assistance Listing Number: 84.425C, 84.425D, 84.425U Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Significant Deficiency Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirements. Context: The School Corporation was required to submit two Annual Data Reports to the Indiana Department of Education (IDOE) to meet federal reporting requirements for ESSER grant awards and the GEER grant award. The first report was for the period of March 13, 2020 to September 30, 2020 and was due by January 21, 2021. The second report was for the period of October 1, 2020 to June 30, 2021 and was due by May 13, 2022. We noted for both reports that were submitted, there was no documented review by someone other than the preparer of the report to ensure the information submitted was complete and accurate. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding. Crawford County Community School Corporation will continue submission of required data to the IDOE on federal spending with at least two people completing the curation. However, final drafts will be reviewed and then final reports will be signed by the at least two people who reviewed the final draft. This signed copy, if not required to be submitting to the IDOE, will be kept locally. Responsible party and timeline for completion: 1) Amy Belcher, Program Administrator, will ensure all final reports have been reviewed and signed by at least two people before submission to the IDOE immediately.

View Audit 27913

Finding 32417 (2022-002)

Material Weakness 2022

Crawford County Community School Corporation

IN

Matching / Level of Effort / Earmarking Special Tests & Provisions Subrecipient Monitoring § 200.303

Finding 2022-002 Information on the federal program: Subject: Education Stabilization Fund ? Special Tests and Provisions - Wage Rate Requirements Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listing Number: 84.425C, 84.425D, 84.425U P...

Finding 2022-002 Information on the federal program: Subject: Education Stabilization Fund ? Special Tests and Provisions - Wage Rate Requirements Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listing Number: 84.425C, 84.425D, 84.425U Pass-Through Entity: Indiana Department of Education Compliance Requirement: Special Tests and Provisions - Wage Rate Requirements Audit Findings: Material Weakness, Material Noncompliance Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Special Tests and Provisions ? Wage Rate Requirements compliance requirements. The School Corporation did not obtain the weekly payroll reports certifications from a construction company and its subcontractors for a building project. Context: The School Corporation did not have an internal control designed to collect the weekly payroll reports certifications from a construction company and its subcontractors for a building project. The construction payments represented 45% of the Education Stabilization Fund disbursements for the audit period. Therefore, no review was performed to ensure that pay rates complied with the federal wage rate requirements. The construction contracts did not include a clause for federal wage rate requirements. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding. In the future, when Crawford County Community School Corporation utilizes federal funding to supplement construction costs, the construction manager will ensure awarded contracts include Davis Bacon language and be assigned the task of collecting weekly pay rate data on all contractors and subcontractors. A school employee will then review. Responsible party and timeline for completion: Brandon Johnson, Superintendent, will collect weekly pay rate data from the construction manager and review.

View Audit 27913

Corrective Action Plans

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