Corrective Action Plans

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Currently, reports are submitted for review via email. The CMS-64 as well as the CMS-37 is prepared by a consulting firm who submits the copy of the reports for review and approval. Once the Medicaid Director is satisfied, an email is sent approving the report, for further entering into the MBES (CM...
Currently, reports are submitted for review via email. The CMS-64 as well as the CMS-37 is prepared by a consulting firm who submits the copy of the reports for review and approval. Once the Medicaid Director is satisfied, an email is sent approving the report, for further entering into the MBES (CMS system of record) and certification. To ensure access for audit purposes, the Department has implemented a shared folder where copies of approval emails and any time extension requests are stored, since the submission portal does not allow for attachments. Additionally, a Director of Federal Grants has been on-boarded who will assume the role of preparing the reports.
Conversion from VIMS to VIBES allowed system generated ex parte extensions beyond 12 months without requiring updated member contact or documentation. No process was in place to proactively require updated documentation when extensions exceeded one year, resulting in eligibility continuing without c...
Conversion from VIMS to VIBES allowed system generated ex parte extensions beyond 12 months without requiring updated member contact or documentation. No process was in place to proactively require updated documentation when extensions exceeded one year, resulting in eligibility continuing without current proof in file. DHS will: 1. Implementation of Annual In Person/Active Renewal for Extended Cases 2. If members fail to provide required documentation or complete the renewal process, the case is closed for failure to verify eligibility. Appropriate adverse action notices are issued in accordance with policy and timelines. 3. Staff have been instructed that eligibility determinations must not be maintained solely on a system generated extension; supporting documentation must be present in the electronic case record and/or document management system. A brief standard note template is used in VIBES to reference what documents were received, and the date eligibility was rerun. 4. System Configuration Changes with Vendor (RedMane). Worked with RedMane to adjust system logic so that eligibility cannot be approved or extended if no completed application (or renewal) is on record. 5. Updated written procedure includes, staff must confirm that a completed application (paper, phone, online, or converted electronic record) is present and imaged/recorded before approving eligibility. If the individual fails to submit required information by the due date, staff must proceed with denial/closure and document the action in case notes. 6. Conducted targeted staff training on, requirement for a completed application before approval/extension; proper use of pending status and timeframes; correct closure/denial procedures. Provided written job aids illustrating compliant workflows. 7. Implementation of Review Tracking in SharePoint, as of July 2025, an Excel tracking file housed on SharePoint is used to document: case worker name; member name and address; case number; type of case (new application, renewal, newborn, etc.). Each case is entered when assigned to the worker. 8. The supervisor reviews the case directly in VIBES, confirms eligibility determinations, and applies any needed updates. VIBES records the supervisor’s actions with date, time stamp, and staff ID to show who reviewed and approved the case. The supervisor also applies changes and documents a brief note in the VIBES notes section (e.g., “Supervisor [Name/ID] reviewed and approved eligibility determination; OK to issue Notice of Decision.”). After review, the supervisor updates the SharePoint tracker to reflect that review is complete.
The exceptions identified were limited in nature and did not result in questioned costs. In the instance where the project code on the employee's Notice of Personnel Action (NOPA) had not been updated, program personnel made the necessary adjustments to ensure payroll costs were charged to the appro...
The exceptions identified were limited in nature and did not result in questioned costs. In the instance where the project code on the employee's Notice of Personnel Action (NOPA) had not been updated, program personnel made the necessary adjustments to ensure payroll costs were charged to the appropriate grant. To strengthen internal controls, the Department transitioned from manual timekeeping to a biometric finger-punch time and attendance system utilizing TimeForce in the fall of 2024. This system provides enhanced tracking, reporting, and record retention capabilities and reduces the risk of discrepancies associated with manual timekeeping processes. The Department will continue to strengthen its review and documentation procedures to ensure compliance with federal requirements. The Department of Human Services (DHS) adopted the electronic Timeforce (STATS) system for payroll, replacing manual processes. Time and attendance are approved through management levels, with payroll based on Notice of Personnel Action (NOPA) cost centers. Financial Analysts now assigned to the grant reconciles the payroll. Additionally, in order to ensure that Notices of Personnel Actions are updated on a timely basis, ensuring that salaries are charged to the respective account, DHS has implemented the following process: - Provisional Payroll Codes are requested prior to the close of the Fiscal Year by the Department of Finance through the Office of Management and Budget through the established process. - Once the codes are received, the Division of Human Resources will update the most current Personnel Distribution Sheets to reflect active employees. - The sheets will be submitted to Fiscal for certification by the CFO. - NOPA’s are updated with the provisional codes.
DHS remains in collaboration with Federal Partners relative to the required change to reflect a consolidated report for both ACL and ACF in the Payment Management System financial reporting module. All parties are in agreement that one report is required representing the financial expenditure report...
DHS remains in collaboration with Federal Partners relative to the required change to reflect a consolidated report for both ACL and ACF in the Payment Management System financial reporting module. All parties are in agreement that one report is required representing the financial expenditure reporting mirroring the core concept of the consolidation of the various grants. Relative to the pre and post expenditures, reports are submitted through the portal, represented by a submission log. There are no provisions for approval or acceptance by the Federal partners apparent in said portal. While email notices are received acknowledging receipt, a formal acceptance is not received. Conversations are ongoing with the Federal partners relative to receiving a formal notification. A Federal Grants Financial Analyst has been onboarded dedicated to the SSBG. Monthly and quarterly reports are prepared to allow for a match to all reports inclusive of Federal draws.
Once payroll is processed by the Department of Finance (DOF), a Flex Earnings Report is generated by the Analyst on each payday. A reconciliation is then performed to ensure that all employees, along with their respective fringe benefits, are accurately captured and drawn. Following this process, DO...
Once payroll is processed by the Department of Finance (DOF), a Flex Earnings Report is generated by the Analyst on each payday. A reconciliation is then performed to ensure that all employees, along with their respective fringe benefits, are accurately captured and drawn. Following this process, DOF posts the payroll to the accounting system. However, staffing has identified that deficiencies can occur in DOF’s postings, sometimes arising in periods subsequent to the actual payday. To address this, the Department of Human Services (DHS) has incorporated an internal control requiring retrospective reconciliation of accounts against the Flex Earnings Report to verify accuracy. Additionally, DHS plans to engage with DOF to better understand the underlying factors and nuances that result in discrepancies between DOF postings and the account coding reflected in the Flex Earnings Report. The Federal Grants Financial Analyst also plays a key role in ensuring that transactions are recorded in the appropriate accounting period and that costs are properly allocated. In this particular instance, no federal funds were drawn.
The Government concurs with the auditor’s findings and recommendations. Management will conduct a comprehensive review of existing internal controls related to non-payroll expenditures. DHS will update policies and procedures to ensure all costs are properly documented and comply with federal allowa...
The Government concurs with the auditor’s findings and recommendations. Management will conduct a comprehensive review of existing internal controls related to non-payroll expenditures. DHS will update policies and procedures to ensure all costs are properly documented and comply with federal allowable cost principles. DHS is committed to addressing the identified issues and maintaining ongoing compliance with federal regulations. DHS will conduct a thorough review of current internal controls and procedures related to non-payroll expenditures to identify gaps and areas for improvement. Policies will be updated to ensure all costs are properly documented and comply with federal allowable cost principles. Staff responsible for processing and approving expenditures will receive targeted training on documentation and compliance requirements. DHS will implement periodic internal audits to monitor adherence to updated procedures and promptly address any exceptions.
The Government concurs with the auditor’s findings and recommendations. Management will review current procedures to strengthen monitoring and documentation of provider eligibility for ARP Act stabilization funds. DHS is committed to improving internal controls and ensuring compliance with all progr...
The Government concurs with the auditor’s findings and recommendations. Management will review current procedures to strengthen monitoring and documentation of provider eligibility for ARP Act stabilization funds. DHS is committed to improving internal controls and ensuring compliance with all program requirements. An internal programmatic audit process is actively utilized. Subsidy determinations are cross-checked by different workers according to federally and locally established policies. Additionally, DHS is in the process of developing an internal audit and compliance unit. With the requisite staffing, internal audits will be conducted to ensure alignment with the Federal mandates in addition to ensuring overall compliance.
Internal audits will be conducted quarterly by having OCCRS subsidy staff and Administrators review files for accuracy of eligibility and subsidy determinations. Quality staff will conduct at least 2 unannounced visits per child care facility to monitor attendance. DHS will implement a centralized, ...
Internal audits will be conducted quarterly by having OCCRS subsidy staff and Administrators review files for accuracy of eligibility and subsidy determinations. Quality staff will conduct at least 2 unannounced visits per child care facility to monitor attendance. DHS will implement a centralized, secure tracking matrix. This log will track all fraud referrals, audit start/end dates, findings, total funds identified for recovery, amounts recovered to date, and case closure signatures.
DHS has onboarded additional licensing staff which has built increased capacity to conduct provider visits for the purpose of assessing compliance with health and safety requirements. Efforts to recruit additional staff continue. A visual tracker of provider visits will be utilized to ensure visits ...
DHS has onboarded additional licensing staff which has built increased capacity to conduct provider visits for the purpose of assessing compliance with health and safety requirements. Efforts to recruit additional staff continue. A visual tracker of provider visits will be utilized to ensure visits are conducted across all providers.
A Federal Grants Financial Analyst for CCDF program has been hired and is tasked with ensuring the accuracy and submission of financial reports. Additionally, a Director of Federal Grants has been added to oversee the reporting process. Internal controls have been established, requiring final review...
A Federal Grants Financial Analyst for CCDF program has been hired and is tasked with ensuring the accuracy and submission of financial reports. Additionally, a Director of Federal Grants has been added to oversee the reporting process. Internal controls have been established, requiring final review and approval by the supervisor with final approval by the CFO or designee. Additionally, an Audit and Compliance unit has been established. Once staffed, regular monitoring will occur within the various divisions.
A Federal Grants Financial Analyst for CCDF program has been hired and is tasked with ensuring the accuracy and submission of financial reports to ensure compliance with earmarking. Additionally, a Director of Federal Grants has been added to oversee the reporting and earmarking process. Internal co...
A Federal Grants Financial Analyst for CCDF program has been hired and is tasked with ensuring the accuracy and submission of financial reports to ensure compliance with earmarking. Additionally, a Director of Federal Grants has been added to oversee the reporting and earmarking process. Internal controls have been established, requiring final review and approval by the supervisor with final approval by the CFO or designee. Additionally, an Audit and Compliance unit has been established. Once staffed, regular monitoring will occur within the various divisions.
DHS, has upgraded the child care database to more efficiently produce monthly vouchers without the historical connectivity disruptions that prevented an uninterrupted listing of provider vouchers and the associated subsidy payments. An independent audit will be conducted to verify processes, review ...
DHS, has upgraded the child care database to more efficiently produce monthly vouchers without the historical connectivity disruptions that prevented an uninterrupted listing of provider vouchers and the associated subsidy payments. An independent audit will be conducted to verify processes, review files and make recommendations. Additionally, An Audit and Compliance Unit has been established within the Fiscal Division. Staffing will include a program compliance monitor to work with the Child Care program to ensure compliance to Federal mandates.
To address the non-compliance related to the failure DHS will strengthen internal controls and governance oversight processes to ensure full compliance with Head Start Act requirements and Uniform Guidance. Specifically, DHS will: 1. Implement Monthly Financial Reporting • Develop and implement a st...
To address the non-compliance related to the failure DHS will strengthen internal controls and governance oversight processes to ensure full compliance with Head Start Act requirements and Uniform Guidance. Specifically, DHS will: 1. Implement Monthly Financial Reporting • Develop and implement a standardized process requiring monthly financial statements, including credit card expenditures, to be prepared and presented to both the Governing Board and Policy Council • Establish a recurring meeting schedule to ensure timely review • Maintain meeting minutes documenting review and approval 2. Establish Governance Training Program • Develop and implement an annual training plan for the governing body and Policy Council covering: • Financial statements and reporting • Roles and responsibilities under Head Start regulations • Oversight of Federal funds and internal controls • Maintain sign-in sheets, agendas, and training materials as documentation 3. Strengthen Audit Oversight Procedures • Require documented discussion in governing body meeting minutes demonstrating active monitoring and oversight to include: • Audit findings • Status of corrective actions
To address the non-compliance related to the failure to document and record the required Notices of Federal Interest (NFI) for facilities with major renovations, program management will implement the following corrective measures: 1. Immediate Remediation of Identified Facilities: The Program Admini...
To address the non-compliance related to the failure to document and record the required Notices of Federal Interest (NFI) for facilities with major renovations, program management will implement the following corrective measures: 1. Immediate Remediation of Identified Facilities: The Program Administrator conducted a review of the two facilities cited in the audit and took immediate steps to prepare and record the required Notices of Federal Interest in accordance with 45 CFR §§1303.46–1303.47. Documentation of recording in the appropriate jurisdiction was obtained and maintained in the official grant files. 2. Comprehensive Facilities Compliance Review: A full inventory and review of all facilities that have undergone purchase, construction, or major renovation using Head Start funds was conducted to ensure that all required NFIs are properly recorded. 3. Designation of Roles and Oversight Responsibility: Program Administrator will be assigned responsibility for ensuring compliance with all federal property requirements, including preparation, submission, and recordation of the NFI. A secondary level of review by senior management will be required to ensure accountability. 4. Training and Technical Assistance: Relevant program and fiscal staff will receive targeted training on Head Start facilities regulations (45 CFR Part 1303) and Uniform Guidance requirements, with emphasis on: o When an NFI is required o Proper preparation and recording procedures o Documentation and record retention requirements 5. Ongoing Monitoring and Internal Review: The development of an audit unit will perform periodic internal compliance reviews (at least annually) of facilities files to ensure adherence to federal requirements. Any issues identified will be addressed immediately to prevent recurrence.
DHS will: 1. Establish a Reporting Calendar and Tracking System: A comprehensive reporting calendar will be developed that clearly outlines all required federal reports (e.g., SF-429, SF-429A, SF-428 series), including submission deadlines. This calendar will be centrally maintained and shared with ...
DHS will: 1. Establish a Reporting Calendar and Tracking System: A comprehensive reporting calendar will be developed that clearly outlines all required federal reports (e.g., SF-429, SF-429A, SF-428 series), including submission deadlines. This calendar will be centrally maintained and shared with all relevant staff. Automated reminders will be implemented to ensure deadlines are met. 2. Assign Clear Roles and Responsibilities: Fiscal Analyst has been formally assigned responsibility for the preparation of each required report. Review and submission of the SF429 and 428 will be completed by the Program Administrator/designee. 3. Training and Capacity Building: Program staff will receive refresher training on federal reporting requirements, including timelines, documentation standards, and compliance expectations under 2 CFR §200.303 (Internal Controls). This will ensure a clear understanding of the importance of timely and accurate reporting. 4. Ongoing Monitoring and Compliance Review: The development of an audit unit will conduct periodic internal reviews (quarterly spot checks) to verify that reports are prepared and submitted timely. Any delays or issues identified will be addressed promptly to prevent recurrence. 5. Documentation and Record Retention: All submitted reports and supporting documentation will be retained in an organized, centralized filing system (electronically) to ensure accessibility for audit and monitoring purposes.
DHS maintains an internal asset listing. Additionally, DHS will be onboarding dedicated staff for Head Start inventory. DHS will continue to collaborate with the Department of Property and Procurement to ensure compliance with Federal regulations regarding equipment and its maintenance.
DHS maintains an internal asset listing. Additionally, DHS will be onboarding dedicated staff for Head Start inventory. DHS will continue to collaborate with the Department of Property and Procurement to ensure compliance with Federal regulations regarding equipment and its maintenance.
The Government concurs with the auditor’s findings and recommendations. Management will review current internal control procedures to determine if enhancements are needed. DHS is committed to ensuring compliance with Federal regulations and will take appropriate action as necessary. DHS will review ...
The Government concurs with the auditor’s findings and recommendations. Management will review current internal control procedures to determine if enhancements are needed. DHS is committed to ensuring compliance with Federal regulations and will take appropriate action as necessary. DHS will review and update its policies and procedures to ensure all non-payroll expenditures are approved by authorized personnel, provide staff training on proper approval processes and internal control requirements, and conduct periodic checks to monitor compliance and promptly address any exceptions.
The Government concurs with the auditor’s findings and recommendations and finalizing a comprehensive corrective action plan to strengthen grant management and compliance through the Public Finance Management initiative including the development of a three-tier overarching Financial and Compliance p...
The Government concurs with the auditor’s findings and recommendations and finalizing a comprehensive corrective action plan to strengthen grant management and compliance through the Public Finance Management initiative including the development of a three-tier overarching Financial and Compliance policy and procedures framework. The Government’s Audit Committee is leading the development of a structured, three-tier policy and procedures framework under the Public Finance Management project. This framework includes Tier 1, which establishes the overarching Financial and Compliance Policy; Tier 2, which defines Standard Operating Procedures (SOPs) to promote cross-agency consistency; and Tier 3, which outlines detailed, step-by-step procedures that clearly define roles and responsibilities and accountability measures to ensure compliance with all federal regulations including equipment and real property management. Additional staff will be needed to effectively support the initiative and regular training sessions will be provided to staff to ensure they understand and adhere to compliance requirements with monitoring and evaluation occurring by the OMB Compliance Unit supported by the Government’s Audit Committee, to assess and improve the effectiveness of controls.
The Government concurs with the auditor’s findings and recommendations and finalizing a comprehensive corrective action plan to strengthen grant management and compliance through the Public Finance Management initiative including the development of a three-tier overarching Financial and Compliance p...
The Government concurs with the auditor’s findings and recommendations and finalizing a comprehensive corrective action plan to strengthen grant management and compliance through the Public Finance Management initiative including the development of a three-tier overarching Financial and Compliance policy and procedures framework. The Government’s Audit Committee is leading the development of a structured, three-tier policy and procedures framework under the Public Finance Management project. This framework includes Tier 1, which establishes the overarching Financial and Compliance Policy; Tier 2, which defines Standard Operating Procedures (SOPs) to promote cross-agency consistency; and Tier 3, which outlines detailed, step-by-step procedures that clearly define roles and responsibilities and accountability measures to ensure compliance with all federal regulations including fiscal and administrative requirements for expending and accounting for payroll expenditures. Regular training sessions will be provided to staff involved in grant management to ensure they understand and adhere to compliance requirements with monitoring and evaluation occurring by the OMB Compliance Unit supported by the Government’s Audit Committee, to assess and improve the effectiveness of controls.
To immediately address the condition regarding the missing documentation, VIDE has compiled and provided the complete listing of applicable construction contracts to satisfy this specific documentation requirement. To address the root cause of the wage rate deficiencies for the COVID- 19 Education S...
To immediately address the condition regarding the missing documentation, VIDE has compiled and provided the complete listing of applicable construction contracts to satisfy this specific documentation requirement. To address the root cause of the wage rate deficiencies for the COVID- 19 Education Stabilization Fund, the Procurement Director has successfully implemented updated contract templates. These templates contain language that explicitly addresses all required wage rate provisions, directly resolving the contract language deficiency noted in the audit. Furthermore, VIDE is actively finalizing a comprehensive Standard Operating Procedure (SOPP) for wage rate requirements to ensure long-term compliance. This SOPP will mandate the consistent use of the approved contract templates and establish strict internal controls for project management personnel to obtain, review, and retain certified weekly payrolls from all contractors. Once the SOPP is finalized, mandatory training will be provided to all relevant staff involved in contract oversight, report preparation, and submission.
The Government’s Audit Committee is leading the development of a structured, three-tier policy and procedures framework under the Public Finance Management project. This framework includes Tier 1, which establishes the overarching Financial and Compliance Policy; Tier 2, which defines Standard Opera...
The Government’s Audit Committee is leading the development of a structured, three-tier policy and procedures framework under the Public Finance Management project. This framework includes Tier 1, which establishes the overarching Financial and Compliance Policy; Tier 2, which defines Standard Operating Procedures (SOPs) to promote cross-agency consistency; and Tier 3, which outlines detailed step-by-step procedures that clearly define roles and responsibilities and accountability measures to ensure compliance with all federal regulations including reporting. Regular training sessions will be provided to staff involved in grant management to ensure they understand and adhere to compliance requirements with monitoring and evaluation occurring by the OMB Compliance Unit supported by the Government’s Audit Committee, to assess and improve the effectiveness of controls.
As part of our ongoing commitment to strengthen internal controls, VIDE is finalizing its comprehensive Standard Operating Procedures (SOPs) for Equipment and Real Property Management. To directly address the recommendation for improved monitoring and communication, the Fixed Asset Director is imple...
As part of our ongoing commitment to strengthen internal controls, VIDE is finalizing its comprehensive Standard Operating Procedures (SOPs) for Equipment and Real Property Management. To directly address the recommendation for improved monitoring and communication, the Fixed Asset Director is implementing a formal process to perform and document quarterly inventory reconciliations, ensuring timely coordination across all divisions handling federal assets. Munis serves as our official system of record. Current controls dictate that all required data fields (as outlined in 2 CFR 200.313) must be inputted before an asset record can be created in the system. The Government acknowledges the current limitation where a system reporting error prevents certain populated information from exporting onto standard reports. The Third-Party Fiduciary Agent (TPFA) is actively escalating this issue with Munis technical support. To ensure compliance to date, no permanent system solution has been found; therefore, the Fixed Asset Director will implement an interim workaround. This will involve utilizing alternative data queries or manual consolidation from the Munis asset profiles to ensure that complete, fully compliant equipment listings can be successfully generated and provided upon request until the system reporting error is permanently resolved by the TPFA and Munis.
VIDE will reinforce its procedures for tracking, compiling, and storing documentation related to grant expenditures. To achieve the necessary level of control precision, VIDE has successfully finalized the Standard Operating Procedure (SOP) governing the calculation, tracking, and record retention o...
VIDE will reinforce its procedures for tracking, compiling, and storing documentation related to grant expenditures. To achieve the necessary level of control precision, VIDE has successfully finalized the Standard Operating Procedure (SOP) governing the calculation, tracking, and record retention of indirect costs. Currently, the Third-Party Fiduciary Agent (TPFA) controls and executes this specific process on behalf of the Department. To ensure the newly finalized procedures are fully operationalized, VIDE is scheduling mandatory training. VIDE will coordinate directly with the TPFA to facilitate this training for all relevant VIDE staff. This will ensure that internal personnel are fully equipped to actively verify, compile, and securely store the required check payment details and detailed project expenditure reports. Building this internal capacity will strengthen VIDE's oversight of the TPFA's processes and prevent future documentation gaps.
VIDE will strengthen payroll and personnel action controls by requiring the Budget Team and Deputy Commissioner to review and approve all personnel actions before NOPA execution to validate pay rates. Furthermore, Payroll will establish a final review step to reconcile approved hours against both th...
VIDE will strengthen payroll and personnel action controls by requiring the Budget Team and Deputy Commissioner to review and approve all personnel actions before NOPA execution to validate pay rates. Furthermore, Payroll will establish a final review step to reconcile approved hours against both the payroll processing register and the final reimbursement invoice. Approved timesheets, Notices of Per Diem, and related payroll support will be centrally retained in SharePoint by pay period and attached to applicable invoices or general ledger journal entries. Program staff and supervisors will receive mandatory training on updated timesheet procedures and federal time and effort requirements. The Office of Fiscal and Administrative Services will also conduct monthly spot checks of SharePoint repositories and ERP logs to document compliance, identify control gaps, and ensure timely corrective action. Finalization of the formal SOPs and supporting controls is a top priority to achieve the necessary level of control precision and prevent repeat findings.
VIDE is currently working towards developing formal procedures to establish controls operating at a level of precision that ensures timely and accurate reporting compliance. As part of this ongoing development, VIDE will govern these new procedures through the Integrated Fiscal Control Model within ...
VIDE is currently working towards developing formal procedures to establish controls operating at a level of precision that ensures timely and accurate reporting compliance. As part of this ongoing development, VIDE will govern these new procedures through the Integrated Fiscal Control Model within the Office of Federal Grants. To correct the discrepancies between the Annual Report and underlying data, VIDE will implement a mandatory multi-level reconciliation process. Prior to the submission of any Annual Report, Program Directors and the fiscal team must cross-reference and validate all reported programmatic and financial data against the ERP system of record and official source documents. A final sign-off will be required to certify data accuracy. Furthermore, to address the Transparency Act requirements, VIDE will institute a strict compliance workflow. The Office of Federal Grants will be required to identify, register, and report all applicable first-tier subawards of $30,000 or more into the FSRS portal within the federally mandated timeframe. To ensure FFATA submissions are consistently completed, a secondary review step will be implemented to verify the FSRS submission confirmation before any initial reimbursement drawdowns are approved for the respective subrecipient.
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