Corrective Action Plans

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Finding Number: 2022-003 Condition: During the audit of federal expenditures, it was noted that the Charter Township incorrectly reported project expenditure categories to Treasury. Planned Corrective Action: The Township will put procedures into place to ensure appropriate layers of review are perf...
Finding Number: 2022-003 Condition: During the audit of federal expenditures, it was noted that the Charter Township incorrectly reported project expenditure categories to Treasury. Planned Corrective Action: The Township will put procedures into place to ensure appropriate layers of review are performed when reporting expenditures. Contact person responsible for corrective action: Finance Director Anticipated Completion Date: 3/31/2023
Finding No.: 2022-_ 002_ Condition: District personnel were unaware of their requirement to ensure that employees of vendors used on projects exceeding $2,000 and paid with federal funds were paid prevailing wage rates. Plan: Annually District personnel should read...
Finding No.: 2022-_ 002_ Condition: District personnel were unaware of their requirement to ensure that employees of vendors used on projects exceeding $2,000 and paid with federal funds were paid prevailing wage rates. Plan: Annually District personnel should read the 2 CFR Part 200, Appendix XI, Compliance Supplement for all federal programs received by the District to ensure they are aware of all applicable compliance requirements. Anticipated Date of Completion: 06/30/2023 Name of Contact Person: Melissa Ritter Management Response: Management will implement the auditor's recommendation in the year ended June 30, 2023.
Finding 23714 (2022-038)
Significant Deficiency 2022
Finding 2022-038 WIOA Cluster, ALN 17.258, 17.259, and 17.278 - FFATA Reporting Management Views LEO agrees with the finding. Planned Corrective Action LEO Finance will implement a tracking log to record FFATA reporting deadlines and will send reminders to staff on upcoming deadlines. In addition,...
Finding 2022-038 WIOA Cluster, ALN 17.258, 17.259, and 17.278 - FFATA Reporting Management Views LEO agrees with the finding. Planned Corrective Action LEO Finance will implement a tracking log to record FFATA reporting deadlines and will send reminders to staff on upcoming deadlines. In addition, LEO Finance will establish a timeline with staff responsible for FFATA reporting that allows ample time for supervisory review and approval prior to submission. Anticipated Completion Date September 30, 2023 Responsible Individual(s) Lora MacKay, LEO
Finding 23713 (2022-010)
Significant Deficiency 2022
Finding 2022-010 MARS User Access Management Views The Department of Labor and Economic Opportunity (LEO) agrees with the finding. LEO Administrative Services continues to experience challenges related to staffing shortages and competing priorities but recognizes the importance of maintaining sound...
Finding 2022-010 MARS User Access Management Views The Department of Labor and Economic Opportunity (LEO) agrees with the finding. LEO Administrative Services continues to experience challenges related to staffing shortages and competing priorities but recognizes the importance of maintaining sound access controls over the Michigan Administrative Review System (MARS). Accordingly, within LEO Administrative Services, the LEO Internal Controls Unit will assist the LEO Finance Unit in the interim with implementing corrective action until a permanent assignment is made. Planned Corrective Action LEO Administrative Services will continue to work with LEO Workforce Development to correct these exceptions. LEO will establish and fully implement a policy, procedure, and routine that addresses the following: a. Ensuring that LEO reviews MARS user access semiannually for privileged accounts or annually for all other accounts. b. Ensuring timely disabling of inactive user accounts (those not accessed in over 60 days). Anticipated Completion Date September 30, 2023 Responsible Individual(s) Lora MacKay, LEO Allen Williams, LEO
Finding 23712 (2022-037)
Significant Deficiency 2022
Finding 2022-037 Crime Victim Assistance, ALN 16.575 - Risk Assessment and During-the-Award Monitoring Management Views MDHHS agrees with the finding. Planned Corrective Action For part a., MDHHS included the grant agreement identified in the fiscal year 2023 monitoring plan. MDHHS will evaluate ...
Finding 2022-037 Crime Victim Assistance, ALN 16.575 - Risk Assessment and During-the-Award Monitoring Management Views MDHHS agrees with the finding. Planned Corrective Action For part a., MDHHS included the grant agreement identified in the fiscal year 2023 monitoring plan. MDHHS will evaluate current monitoring procedures and make updates, if necessary, to improve documentation of monitoring activity. For the grantees identified that only receive an administrative portion of VOCA funds, MDHHS has initiated the process to provide the grantees with access to the U.S. Department of Justice (DOJ) Office for Victims of Crime (OVC) reporting website. MDHHS is working with DOJ OVC to determine reporting elements for the administrative awards and will work with grantees to implement the required reporting elements. For part b., MDHHS will revise risk assessment and monitoring plan procedures to include all awards issued during the fiscal year. Anticipated Completion Date a. December 30, 2023 b. October 1, 2023 Responsible Individual(s) a. Twanisha Glass and Patsy Baker, MDHHS b. Tonya Avery, MDHHS
Finding 23711 (2022-036)
Significant Deficiency 2022
Finding 2022-036 Crime Victim Assistance, ALN 16.575 - Subrecipient Eligibility Management Views MDHHS agrees with the finding. Planned Corrective Action MDHHS Division of Victim Services (DVS) has distributed a comprehensive checklist to all Victims of Crime Act (VOCA) grant applicants that will...
Finding 2022-036 Crime Victim Assistance, ALN 16.575 - Subrecipient Eligibility Management Views MDHHS agrees with the finding. Planned Corrective Action MDHHS Division of Victim Services (DVS) has distributed a comprehensive checklist to all Victims of Crime Act (VOCA) grant applicants that will require certification of eligibility for funding by the applicant and DVS prior to awarding funds. This checklist has been incorporated into the rollover application for fiscal year 2024. Anticipated Completion Date The checklist will be certified by all grant applicants and DVS by October 1, 2023, for the fiscal year 2024 award period. Responsible Individual(s) Twanisha Glass, MDHHS Patsy Baker, MDHHS
Finding 23706 (2022-035)
Significant Deficiency 2022
Finding 2022-035 Community Development Block Grants/State?s Program, ALN 14.228 - FFATA Reporting Management Views MSF agrees with the finding. Planned Corrective Action MSF subsequently reported the two Community Development Block Grant subawards noted in the finding, and potential grantees are n...
Finding 2022-035 Community Development Block Grants/State?s Program, ALN 14.228 - FFATA Reporting Management Views MSF agrees with the finding. Planned Corrective Action MSF subsequently reported the two Community Development Block Grant subawards noted in the finding, and potential grantees are now required to have a Unique Entity Identifier as part of the grant application process. MSF also routinely reconciles the data that is reported in the Federal Subaward Reporting System to its financial and program reporting systems to ensure accuracy. MSF Financial Services will update existing procedures to ensure ongoing compliance with FFATA reporting requirements. In addition, MSF Financial Services will conduct supervisory oversight of the process, including a monthly comparison to the information reported on USASpending.gov to the monthly data upload file obtained from the MSF program reporting system to ensure accuracy, completeness, and timely submission. Anticipated Completion Date September 30, 2023 Responsible Individual(s) Alex Fox, MSF Paul Onan, MSF
Finding 23705 (2022-034)
Significant Deficiency 2022
Finding 2022-034 Community Development Block Grants/State?s Program, ALN 14.228 - Timeliness of Performance Reporting Management Views MSHDA agrees with the finding. Planned Corrective Action To ensure timely submission of the Consolidated Annual Performance and Evaluation Report (CAPER), MSHDA w...
Finding 2022-034 Community Development Block Grants/State?s Program, ALN 14.228 - Timeliness of Performance Reporting Management Views MSHDA agrees with the finding. Planned Corrective Action To ensure timely submission of the Consolidated Annual Performance and Evaluation Report (CAPER), MSHDA will develop a multi-agency (MSHDA, MSF, MEDC, and MDHHS) Microsoft Teams schedule of action steps to ensure that the reporting deadline is met. This action step calendar will be created in a Microsoft Teams shared workspace. Each agency will be assigned tasks to complete in advance of the deadline, to ensure that the submission deadline is met. The action step schedule will include all items necessary to meet the reporting timeline of September 30 of each year. Action steps will begin the first week of July, with a draft CAPER due for public comment period in mid-August, and the public comment period occurring thereafter. Per the U.S. Department of Housing and Urban Development regulations, and MSHDA?s citizen participation plan, the public comment period is required for at least 15 days before the final CAPER is submitted. A final copy of the CAPER will be submitted within the Integrated Disbursement and Information System one week prior to the due date to ensure no delays occur. Anticipated Completion Date The Microsoft Teams action step calendar will be implemented by July 7, 2023. Responsible Individual(s) Tonya Joy, MSHDA
Finding 23704 (2022-033)
Significant Deficiency 2022
Finding 2022-033 National Guard Military Operations & Maintenance (O&M) Projects, ALN 12.401 - Timeliness of Cash Draws Management Views DMVA agrees with the finding. Planned Corrective Action For part a., DMVA changed the process for Air National Guard federal billings effective January 24, 2023....
Finding 2022-033 National Guard Military Operations & Maintenance (O&M) Projects, ALN 12.401 - Timeliness of Cash Draws Management Views DMVA agrees with the finding. Planned Corrective Action For part a., DMVA changed the process for Air National Guard federal billings effective January 24, 2023. Expenditure reports will be sent to the program manager monthly for review and approval prior to generating reimbursement requests. Items in dispute will be discussed and either corrected or billed once a determination is made. For part b., DMVA implemented a new process effective June 1, 2023, to document when federal account coding is received from the federal Construction and Facilities Management Office (CFMO) for project expenditures. After the federal account coding is received, DMVA will prepare the Request for Advance or Reimbursement (SF-270) and send to the CFMO for final approval within 60 days. For part c., DMVA has communicated the importance of timely completion of fiscal year-end closing activities to staff to ensure final year end expenditure reports are generated within the acceptable timeframe. DMVA has established a deadline of January 5, 2024 to have fiscal year 2023 final expenditure reports (FER) prepared and distributed to federal program areas. Anticipated Completion Date a. Completed b. Completed c. January 5, 2024 Responsible Individual(s) Christine Apostol, DMVA
Finding 23703 (2022-002)
Significant Deficiency 2022
Finding 2022-002 SIGMA High-Risk Activity Monitoring Management Views DTMB agrees with the finding. Planned Corrective Action DTMB immediately, after the issue was identified in August 2022, reinstated processes to review transactions that have been bypassed and overridden in SIGMA and perform tas...
Finding 2022-002 SIGMA High-Risk Activity Monitoring Management Views DTMB agrees with the finding. Planned Corrective Action DTMB immediately, after the issue was identified in August 2022, reinstated processes to review transactions that have been bypassed and overridden in SIGMA and perform tasks according to the requirements. Furthermore, DTMB will continue to review their self-imposed limit for the number of users that have access to perform authorized bypass and override actions in SIGMA for DMVA and MSP. Anticipated Completion Date Completed Responsible Individual(s) Brenda Sprunger, DTMB
Finding 23702 (2022-001)
Significant Deficiency 2022
Finding 2022-001 Confidential Information in SIGMA Management Views The Department of Military and Veterans Affairs (DMVA) and MSP disagree that confidential information was included in SIGMA. Follow-up with DTMB confirmed that user ID is not considered confidential data at the DTMB enterprise lev...
Finding 2022-001 Confidential Information in SIGMA Management Views The Department of Military and Veterans Affairs (DMVA) and MSP disagree that confidential information was included in SIGMA. Follow-up with DTMB confirmed that user ID is not considered confidential data at the DTMB enterprise level. Planned Corrective Action DTMB revised DTMB Administrative Policy 900.01 effective June 16, 2023. Anticipated Completion Date Completed Responsible Individual(s) Christine Apostol, DMVA Amanda Baker, MSP
Finding 23697 (2022-032)
Significant Deficiency 2022
Finding 2022-032 Pandemic EBT Food Benefits, ALN 10.542 - Report of Disaster Supplemental Nutrition Assistance Benefit Issuance Management Views MDHHS disagrees that federal regulations require MDHHS to maintain copies or screenshots of the Report of Disaster Food Stamp Benefit Issuance (FNS-292B)...
Finding 2022-032 Pandemic EBT Food Benefits, ALN 10.542 - Report of Disaster Supplemental Nutrition Assistance Benefit Issuance Management Views MDHHS disagrees that federal regulations require MDHHS to maintain copies or screenshots of the Report of Disaster Food Stamp Benefit Issuance (FNS-292B) information reported on the federal website. MDHHS normally has the ability to access the information on the federal system. However, during audit fieldwork, the FNS-292B information that MDHHS submitted on the federal website was not viewable to the auditors because the reports were under federal review. MDHHS did not a retain a copy or screen prints of the submitted reports; however, MDHHS did maintain the underlying reports used to compile the submitted FNS-292B reports and this was provided to the auditors during fieldwork. Planned Corrective Action Although MDHHS disagrees that federal regulations require MDHHS to maintain copies or screenshots of FNS-292B information reported on the federal website, MDHHS will maintain screenshots of the report submission going forward. Anticipated Completion Date Completed Responsible Individual(s) Dawn Sweeney, MDHHS
Finding 23696 (2022-031)
Significant Deficiency 2022
Finding 2022-031 Pandemic EBT Food Benefits, ALN 10.542 - Overpayment of Benefits Management Views MDHHS agrees with the finding. Planned Corrective Action During the school year, the two students in the identified case were enrolled in GSRP and issued benefits on January 28, 2022, based on the s...
Finding 2022-031 Pandemic EBT Food Benefits, ALN 10.542 - Overpayment of Benefits Management Views MDHHS agrees with the finding. Planned Corrective Action During the school year, the two students in the identified case were enrolled in GSRP and issued benefits on January 28, 2022, based on the school file. These students enrolled in early childhood before the end of the school year, so they were also identified in the childcare group and were subsequently issued duplicate benefits as part of the Summer Pandemic EBT issuance on August 24, 2022. A technical solution is currently being evaluated to identify additional steps that may be implemented that cross references students across eligibility groups to ensure that duplicate payments are not issued. Anticipated Completion Date MDHHS expects to determine additional steps for a technical solution by September 30, 2023. Responsible Individual(s) Kathy Cornell, MDHHS
View Audit 20093 Questioned Costs: $1
Finding 2022-030 Food Distribution Cluster, ALN 10.565, 10.568, and 10.569 - Accountability for USDA Foods Management Views MDE agrees with the finding. During fiscal year 2022, MDE determined that The Emergency Food Assistance Program (TEFAP) State Plan was inefficient and discontinued reviewing e...
Finding 2022-030 Food Distribution Cluster, ALN 10.565, 10.568, and 10.569 - Accountability for USDA Foods Management Views MDE agrees with the finding. During fiscal year 2022, MDE determined that The Emergency Food Assistance Program (TEFAP) State Plan was inefficient and discontinued reviewing eligible recipient agencies (ERA) as outlined in the plan. MDE modified its TEFAP State Plan for fiscal year 2023 to be more reflective of TEFAP inventory movement and still meet the requirements of federal regulation 7 CFR 251.10(e). Planned Corrective Action MDE revised the fiscal year 2023 Michigan TEFAP State Plan, effective October 2022, to require MDE to review ERAs that are considered ?subdistributing agencies? onsite annually and all TEFAP ERAs to submit inventory records and TEFAP foods documentation to MDE as requested twice a year. The change was announced to TEFAP ERAs during the annual All Agency Meetings at the end of August 2022 and through follow up emails and communications. Anticipated Completion Date MDE has already completed the majority of fiscal year 2023 desk and on-site reviews under the revised process and will have completed all of the required fiscal year 2023 inventory reviews by July 31, 2023. Responsible Individual(s) Aimee Alaniz, MDE
Finding 23676 (2022-014)
Significant Deficiency 2022
Finding 2022-014 MDE, Change Management Process Management Views MDE agrees with the finding. Planned Corrective Action Beginning March 15, 2023, MDE performs monthly reviews on the status of resolved MiND change order requests to verify that the tickets are closed in a timely manner and documente...
Finding 2022-014 MDE, Change Management Process Management Views MDE agrees with the finding. Planned Corrective Action Beginning March 15, 2023, MDE performs monthly reviews on the status of resolved MiND change order requests to verify that the tickets are closed in a timely manner and documented accordingly. MDE will review the change management processes with NexSys staff to ensure they understand and complete the required change management process steps to document testing results and to close and document the completion of change order requests. Anticipated Completion Date July 31, 2023 Responsible Individual(s) Monica Butler, MDE Peter Cyril Jones, MDE
Finding 23675 (2022-013)
Significant Deficiency 2022
Finding 2022-013 MDE, Security Management and Access Controls Management Views MDE agrees with the finding. Planned Corrective Action For part a.1., MDE has reviewed the security authorization process for the Grant Electronic Monitoring System (GEMS)/MARS with staff who can approve and modify user...
Finding 2022-013 MDE, Security Management and Access Controls Management Views MDE agrees with the finding. Planned Corrective Action For part a.1., MDE has reviewed the security authorization process for the Grant Electronic Monitoring System (GEMS)/MARS with staff who can approve and modify user accounts. MDE also provided the same staff with training in April 2023 to review the correct procedure to help ensure appropriate documentation is maintained. MDE no longer used the functionality to directly replace a user with another user at the beginning of fiscal year 2023 and the functionality was removed entirely in April of 2023. For part a.2., MDE has reviewed its established policies and procedures over the granting of access to the Next Generation Grant, Application and Cash Management System (NexSys) with staff and will continue to work to appropriately process forms according to policy guidelines and minimize human error. For part b., MDE will notify program office directors during the collection of the Semi-Annual Reviews of Privileged Users that failure to return the certification will result in deactivation of program office users. The next collection of the Semi-Annual Reviews of Privileged Users will be completed by June 30, 2023. For part c., as part of the Annual Certification of Non-Privileged users, MDE now requests all entities to review and update all active users in the Michigan Electronic Grants System Plus (MEGS+), NexSys, GEMS/MARS and Michigan Nutrition Data (MiND). Entities can then submit the certification indicating they have either reviewed their system users or that they do not have any users in the listed system. MDE implemented the first Annual Certification of Non-Privileged users on March 23, 2023 and the certification will be released again in late 2023. For part d., MDE received an exception from the DTMB Enterprise Technical Review Board for the control that would have required MDE to deactivate users after 60 days of inactivity. The exception was issued in November 2023 and now allows MDE to keep inactive users up to 18 months. Anticipated Completion Date a.1. Completed a.2. Ongoing b. June 30, 2023 c. Completed d. Completed Responsible Individual(s) Aimee Alaniz, MDE David Judd, MDE Spencer Simmons, MDE
Finding 23656 (2022-029)
Significant Deficiency 2022
Finding 2022-029 SNAP Cluster, ALN 10.551 and 10.561 - EBT Card Security Management Views MDHHS agrees with the finding. Planned Corrective Action MDHHS switched to a new electronic benefits transfer (EBT) contractor beginning November 2021. MDHHS requires that the contractor provide monthly repor...
Finding 2022-029 SNAP Cluster, ALN 10.551 and 10.561 - EBT Card Security Management Views MDHHS agrees with the finding. Planned Corrective Action MDHHS switched to a new electronic benefits transfer (EBT) contractor beginning November 2021. MDHHS requires that the contractor provide monthly reports to support that physical inventories were conducted and all reports from November 2021 through September 2022 were provided. Anticipated Completion Date Completed Responsible Individual(s) Andrew Piper, MDHHS Dani Wager, MDHHS
Finding 2022-028 SNAP Cluster, ALN 10.551 and 10.561 - EBT Reconciliations Management Views MDHHS agrees with the finding. Planned Corrective Action MDHHS has been working with the vendor and DTMB data warehouse technical staff to update and correct the Benefit Issuer Food Stamp Report (BT-90) so ...
Finding 2022-028 SNAP Cluster, ALN 10.551 and 10.561 - EBT Reconciliations Management Views MDHHS agrees with the finding. Planned Corrective Action MDHHS has been working with the vendor and DTMB data warehouse technical staff to update and correct the Benefit Issuer Food Stamp Report (BT-90) so that it includes recipients who received Supplemental Nutrition Assistance Program (SNAP) benefits under the expanded COVID-19 eligibility requirements. The BT-90 is used to help ensure the client information in Bridges is accurate and does not have an impact on the federal draw. Anticipated Completion Date December 31, 2023 Responsible Individual(s) Sara Gross, MDHHS
Finding 23654 (2022-027)
Significant Deficiency 2022
Finding 2022-027 SNAP Cluster, ALN 10.551 and 10.561 - System and Organization Controls Management Views MDHHS agrees with the finding. Planned Corrective Action MDHHS will annually obtain and review the SOC reports for providers that perform key control activities on behalf of MDHHS. In May 202...
Finding 2022-027 SNAP Cluster, ALN 10.551 and 10.561 - System and Organization Controls Management Views MDHHS agrees with the finding. Planned Corrective Action MDHHS will annually obtain and review the SOC reports for providers that perform key control activities on behalf of MDHHS. In May 2023, MDHHS reviewed the FMG SOC report review requirements and, after further evaluation, determined that a review is not needed for 1 of the 2 SOC reports identified in part b. and both of the SOC reports identified in part c. because they did not perform key control activities on behalf of MDHHS, which will be documented on the required OIAS review template for future SOC report reviews. The review of the SOC reports for the remaining providers is now primarily conducted by the MDHHS Compliance Division. MDHHS will work with other State agencies to identify best practices and document a centralized process to monitor the completion of SOC report reviews. MDHHS will work with OIAS to provide training as necessary. Anticipated Completion Date MDHHS plans to document the centralized process by August 31, 2023 and implement additional monitoring of SOC report reviews by September 30, 2023. Responsible Individual(s) Jim Bowen, MDHHS Andrew Piper, MDHHS
Finding 23653 (2022-015)
Significant Deficiency 2022
Finding 2022-015 MDHHS, PACAP - Inappropriate PACAP Allocation Management Views MDHHS agrees with the finding. However, the comprehensive set of quality control measures in place during fiscal year 2022 were, and continue to be, effective in detecting errors as designed. For each quarterly cost all...
Finding 2022-015 MDHHS, PACAP - Inappropriate PACAP Allocation Management Views MDHHS agrees with the finding. However, the comprehensive set of quality control measures in place during fiscal year 2022 were, and continue to be, effective in detecting errors as designed. For each quarterly cost allocation run, statistical values varying greater than 5.00 percent of the total for that statistical group from the previous quarter are reviewed for accuracy and none of the errors cited in the finding fell outside of this range. Questioned costs from these errors is $426,682 out of $1,635,146,559 allocated in fiscal year 2022 (0.03 percent of all fiscal year 2022 allocated funds by MDHHS). Due to the linear nature of the MDHHS cost allocation process, the large administrative overhead cost pools that are included in the auditor?s samples, such as Rent/Building Occupancy and Departmentwide Administration are allocated across the entire department. The auditor?s review included all related statistical records within each statistical group for the sampled cost pools. This includes almost all statistics used in the cost allocation process for the entire fiscal year because the costs that originate in these cost pools are referenced in all other cost pools. Planned Corrective Action MDHHS implemented additional quality control analysis in comparing statistical values from the current quality control tracking file to the configuration file before loading any files into SIGMA. Any values that do not match will be analyzed and reconciled by MDHHS staff. This ensures that no values are overwritten and that any updated statistical values are reviewed in accordance with the existing quality control policies. Additional analysis steps have also been utilized for the Participants Random Moment Time Study (PRMTS) statistics to add a manual calculation column rather than submitting summarized data. For the Random Moment Time Study (RMTS) statistics, MDHHS has worked with the vendor and the vendor will add a verification check column to ensure that total responses and all adjustments are reconciled. MDHHS will verify completion upon receipt. Anticipated Completion Date MDHHS has implemented the additional quality control analysis to compare statistical values and new steps in analyzing the PRMTS statistics group. MDHHS will be incorporating the new vendor quality control steps related to the RMTS statistics effective July 2023. Responsible Individual(s) Suzanne Kyes, MDHHS Matthew McCool, MDHHS
Finding 23652 (2022-007)
Significant Deficiency 2022
Finding 2022-007 ADP Security Program Management Views MDHHS agrees with part a. of the finding. MDHHS and DTMB disagree with parts b. and c. of the finding. For part b., for the first system identified, although DTMB did not proactively schedule an annual disaster recovery test, DTMB successfully...
Finding 2022-007 ADP Security Program Management Views MDHHS agrees with part a. of the finding. MDHHS and DTMB disagree with parts b. and c. of the finding. For part b., for the first system identified, although DTMB did not proactively schedule an annual disaster recovery test, DTMB successfully performed an actual failover and supporting documentation was provided to the auditors. The actual failover demonstrated that the disaster recovery plan (DRP) worked, was complete, and no delays were experienced in restoring the critical system, therefore DTMB did not perform additional testing activities and it was unnecessary to perform a separate review or update. For the second system identified, the DRP was tested in accordance with the SOM Standard and DTMB provided the auditors with supporting documentation that updates were made to the DRP within the SOM DRP repository. The State?s environment and data centers leverage an infrastructure that is comprised of fully redundant load balanced systems at alternate sites, data mirroring, and data replication to help ensure high availability. For part c, although MDHHS agrees that system security plans were not updated timely for the systems cited, MDHHS disagrees that effective controls were not implemented to ensure confidentiality, integrity, and availability of its automated data processing (ADP) information systems. MDHHS also disagrees that the security of critical systems was at risk by failing to mitigate potential vulnerabilities as described above. MDHHS has compensating controls in place to ensure confidentiality, integrity, and availability of its ADP information systems in addition to mitigating potential vulnerabilities. MDHHS monitors remediation of Plans of Actions and Milestones for all information systems even after expiration of the authority to operate. In addition, MDHHS is required to audit a portion of these systems (Community Health Automated Medicaid Processing System (CHAMPS), Bridges, Enterprise Common Controls) as part of responsibilities related to the Affordable Care Act and the Medicaid Expansion marketplace. Those audits are conducted to show compliance with federal information security and privacy requirements related to the data stored in those systems. In addition, 2 of the 3 ADP systems cited for not having an updated risk assessment are reviewed biennially through the Internal Control Evaluation process where control evidence is updated to demonstrate effectiveness of controls. Planned Corrective Action For part a., MDHHS will add the missing elements identified to the business continuity plan (BCP) and perform annual reviewing and testing of the BCP. For parts b. and c., MDHHS and DTMB disagree with the finding and do not intend to take further action. Anticipated Completion Date a. December 31, 2023 b. and c. Not applicable Responsible Individual(s) Jim Bowen, MDHHS Nathan Buckwalter, DTMB Heather Frick, DTMB Alana Lowe, MDHHS Jennifer Tate, MDHHS
Finding 2022-006 Income Eligibility and Verification System Management Views MDHHS and DTMB agree with parts c., d., e., and g. of the finding. MDHHS and DTMB disagree with parts a., b., and f. of the finding. For parts a. and b., MDHHS agrees with the recommendations. However, MDHHS disagrees wi...
Finding 2022-006 Income Eligibility and Verification System Management Views MDHHS and DTMB agree with parts c., d., e., and g. of the finding. MDHHS and DTMB disagree with parts a., b., and f. of the finding. For parts a. and b., MDHHS agrees with the recommendations. However, MDHHS disagrees with the exceptions identified for 1 of the 6 cited interfaces. For one interface, that impacted three cases, the interface updated appropriately, as designed, where needed. The interface did not need to update the case for citizenship and worker action was not required because citizenship was verified appropriately using another method and citizenship was not in question. For part f., MDHHS disagrees that Income Eligibility Verification System (IEVS) information is required to be requested and obtained for modified adjusted gross income (MAGI) based recipients since eligibility is verified upon determination through the MAGI eligibility determination process and then granted for a 12-month continuous eligibility period. Requesting and obtaining IEVS information throughout the eligibility period would be irrelevant since eligibility is continuous. Planned Corrective Action For parts a., b., and c., MDHHS?s ESA will continue to provide training and policy support to ensure that the local office specialists appropriately utilize the IEVS interface information in determining recipients? eligibility when applicable. ESA is developing and prioritizing a technical solution that will ensure the IEVS information is being addressed timely and used correctly in eligibility determinations. For part d., MDHHS is collaborating with other work areas to facilitate the match process for the IEVS interfaces for recipients funded by Temporary Assistance for Needy Families adoption subsidies. For part e., DTMB will review the process of how it receives the Public Assistance Reporting Information System (PARIS) file from their partners and transmits it to MDHHS Bridges. DTMB will investigate potential process improvements to limit the likelihood of the PARIS file not being transmitted. For part f., MDHHS disagrees with the finding and does not intend to take further action. For part g., MDHHS, with U.S. Department of Agriculture (USDA) Food and Nutrition Service guidance, will explore opportunities with Treasury, Tribal partners, and independent casinos to determine the feasibility of a gaming data match. Anticipated Completion Date a., b., and c. Training and policy support is ongoing. MDHHS anticipates that the technical solution will be completed by December 31, 2023. d. September 30, 2024 e. DTMB anticipates the process improvements will be implemented by September 30, 2023. f. Not applicable g. September 30 2024 Responsible Individual(s) a., b., c., and g. Dawn Sweeney, MDHHS d. Kathonya Rice, MDHHS e. Nathan Buckwalter, DTMB f. Logan Dreasky, MDHHS
View Audit 20093 Questioned Costs: $1
Finding 23650 (2022-005)
Significant Deficiency 2022
Finding 2022-005 Bridges Change Management Process Management Views MDHHS agrees with the finding. Planned Corrective Action For Bridges releases that do not have field testers performing post-implementation validation, MDHHS will document an alternate validation approval following the release. MD...
Finding 2022-005 Bridges Change Management Process Management Views MDHHS agrees with the finding. Planned Corrective Action For Bridges releases that do not have field testers performing post-implementation validation, MDHHS will document an alternate validation approval following the release. MDHHS will send a communication within three business days after each release that validates the changes to Bridges were applied as expected and this validation will be documented as part of the release close-out process. Anticipated Completion Date Completed Responsible Individual(s) Holly Roderick, MDHHS
Finding 2022-004 Bridges Security Management and Access Controls Management Views MDHHS agrees with parts a., b., and d. through g. of the finding. MDHHS and DTMB disagree with part c. of the finding. For part c., although MDHHS and DTMB had not fully documented all database specific configuratio...
Finding 2022-004 Bridges Security Management and Access Controls Management Views MDHHS agrees with parts a., b., and d. through g. of the finding. MDHHS and DTMB disagree with part c. of the finding. For part c., although MDHHS and DTMB had not fully documented all database specific configuration standards until after the audit period, DTMB disagrees that during the audit period the system contained potentially vulnerable database configurations and disagrees that DTMB cannot ensure the security of the data. DTMB has been and continues to implement the manufacturer?s recommendations regarding security configurations. In addition, the databases reside in restricted trusted internal security zones, protected by firewalls, which are specific to each application and database, in conjunction with intrusion protection, antivirus software, and SOM standard security safeguards. Planned Corrective Action For parts a., d., and e., MDHHS will implement the Database Security Application (DSA) Bridges form which establishes a method to document user access request approval electronically and includes a semi-annual review of privileged users and an annual review of all users that is required to prevent automatic removal of access. For part b., MDHHS will prioritize updates to Bridges that will require the local office security coordinator (LOSC) to document security monitoring reports within Bridges alerts and generate a reminder to the LOSC and their manager to reconcile the report. Before the alert can be closed, the LOSC will be required to enter comments for actions taken and approve the report. For part c., DTMB developed an organization-wide framework for database security configuration management. For part f., MDHHS?s Economic Stability Administration (ESA) issued a revised memo on October 3, 2022, to Business Service Centers (BSCs) and local offices to reiterate the need for reviewing, documenting, and completing the required high-risk transaction reports timely. For part g., during February 2022, MDHHS?s Bridges Resource Center (BRC) revised their reconciliation process of high-risk transactions to comply with the changed policy requirements and ensure separate reviews are performed for each type of high-risk transaction. MDHHS?s ESA issued a revised memo on July 11, 2022, to address changes made for non-BRC Central Office staff transactions to reiterate the need for reviewing, documenting, and completing the required high-risk transactions timely. Also, an email reminder is sent out two days prior to the high-risk transaction report due date to help ensure timeliness of the reviews. Anticipated Completion Date a, d., and e. MDHHS anticipates the first phase of the DSA Bridges form will be implemented by October 2023 as a pilot and then roll out statewide with full automation by September 2024. Semi-annual and annual reviews will begin 6 months and 12 months, respectively, from the time each DSA Bridges form is implemented for each respective user. b. August 2024 c. DTMB anticipates having compliance documentation by September 30, 2023. f. Completed with ongoing monitoring. g. Completed Responsible Individual(s) a., b., d., and e. Deon Nelson, MDHHS c. Nathan Buckwalter, DTMB f. MDHHS ESA and BSC Directors g. Todd Gore and Russell Gruber, MDHHS
Finding 23648 (2022-003)
Significant Deficiency 2022
Finding 2022-003 Bridges Interface Controls Management Views DTMB disagrees with part a. of the finding. MDHHS agrees with part b. of the finding. For part a., DTMB disagrees the interface over the Bridges Integrated Automated Eligibility Determination System (Bridges) data exchanges is not operat...
Finding 2022-003 Bridges Interface Controls Management Views DTMB disagrees with part a. of the finding. MDHHS agrees with part b. of the finding. For part a., DTMB disagrees the interface over the Bridges Integrated Automated Eligibility Determination System (Bridges) data exchanges is not operating as needed. For one interface, the auditors sampled 27 different daily batches, including 9,945 records, and only four records (0.04 percent) were cited by the auditors as having inconsistencies. DTMB reviewed these four records and determined they were processed in accordance with business rules and the reporting inconsistency identified did not impact the accuracy of the reconciliation. Additionally, the auditors did not identify inconsistencies in the other eight interfaces sampled across multiple days, which totaled more than 2.95 million records. Therefore, the interface controls are effective and reasonably ensure that data transferred from a source system to a receiving system is processed accurately, completely, and timely. Planned Corrective Action For part a., DTMB disagrees with the finding and does not intend to take further action. For part b., MDHHS, in collaboration with the business program area, will work to establish all missing agreements. Anticipated Completion Date a. Not applicable b. September 30, 2023 Responsible Individual(s) a. Heather Frick and Nathan Buckwalter, DTMB b. James Bowen and Candy Calvert, MDHHS
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