Corrective Action Plans

Finding 554608 (2024-014)

Significant Deficiency 2024

State of Oregon

OR

Questioned Costs Allowable Costs / Cost Principles § 200.400

2024-014 Oregon Department of Human Services/Oregon Health Authority Implement control procedures around cost allocation system inputs Management Response: We agree with this recommendation. The Office of Financial Services will review the existing controls in Cost Allocation system and identify are...

2024-014 Oregon Department of Human Services/Oregon Health Authority Implement control procedures around cost allocation system inputs Management Response: We agree with this recommendation. The Office of Financial Services will review the existing controls in Cost Allocation system and identify areas that need additional or new control procedures to ensure system inputs are appropriately identified and processed. In addition, we will review the noted errors and make appropriate corrections. Anticipated Completion Date: June 30,, 2025 Contact person: Jennifer Stallsworth, Chief of Staff, ODHS APD, April Gillette, OHA Medicaid Division, Strategic Operations & Improvement Director

View Audit 353285 Questioned Costs: $1

Finding 554607 (2024-013)

Significant Deficiency 2024

State of Oregon

OR

Eligibility Significant Deficiency Internal Control / Segregation of Duties

2024-013 Oregon Health Authority Improve documentation and controls over client eligibility Management Response: We agree with this recommendation. A specific case was discovered where the state failed to obtain a signature from an SSI individual. Due to the individual’s SSI status and being continu...

2024-013 Oregon Health Authority Improve documentation and controls over client eligibility Management Response: We agree with this recommendation. A specific case was discovered where the state failed to obtain a signature from an SSI individual. Due to the individual’s SSI status and being continuously on benefits, the ONE system attempts to passively approve renewals without requiring worker interaction, leading to potential gaps where signatures are not on file for cases that converted into the new system in 2020 and 2021. The operation lapse occurred because the SSI individual converted into the new system on continuous benefits going through passive renewal processes that do not require direct worker interaction. The State of Oregon is working with the local branch to obtain a verbal signature from the identified individual. Additionally, the State conducted a thorough review of current policies and procedures related to passive renewals for SSI individuals to ensure compliance with federal requirements. • Call center software recordings and verbal signatures has been updated as recently as February 2025 providing staff with clear direction on how to capture the verbal signatures and which recordings to play. • Establishing DOR/Filing Date Eligibility Guide was updated as recently as March 13, 2025, including a chart itemizing the signature types (electronic and paper forms), programs that accept each type, and the corresponding option to select in ONE • Rights and Responsibilities Eligibility Guide was enhanced on Oct. 7, 2024 to add detailed directions to staff on how to capture the signature in ONE, when rights and responsibilities are not issued automatically, the appropriate Rights and Responsibilities to provide for each program and where to find a current signature record on file. • Finally, the Case Action Eligibility Guide has been updated to include specific guidance and examples of when it's appropriate to extend processing timeframes for RFI's. Anticipated Completion Date: May 1, 2025 Contact person: Jennifer Stallsworth, Chief of Staff, ODHS APD, April Gillette, OHA Medicaid Division, Strategic Operations & Improvement Director

View Audit 353285

Finding 554606 (2024-012)

Significant Deficiency 2024

State of Oregon

OR

Questioned Costs Allowable Costs / Cost Principles Significant Deficiency

2024-012 Oregon Health Authority Ensure MMIS rates are accurate and updated timely Management Response: We agree with this recommendation. The conversion factor (CF) for Calendar Year (CY) 2023 was not properly updated in December 2022. The proposed CMS CF value of 86.7850 was incorrectly applied to...

2024-012 Oregon Health Authority Ensure MMIS rates are accurate and updated timely Management Response: We agree with this recommendation. The conversion factor (CF) for Calendar Year (CY) 2023 was not properly updated in December 2022. The proposed CMS CF value of 86.7850 was incorrectly applied to the Medicaid Management Information System (MMIS) instead of the finalized CMS CF value of 85.585. This error occurred due to confusion surrounding an earlier final rule announcement related to the outpatient prospective payment system (OPPS). Recent CMS OPPS publications have simplified the process of identifying the correct final conversion factor. For CY 2023, payments were processed using the proposed CF of 86.7850 rather than the finalized CF of 85.585, as it was the only rate available at the time. No adjustments have been made to date. To address this issue, we are partnering with our software vendor Gainwell to identify the total number of outpatient claims affected by the incorrect CF. We will then develop a timeline, communicate to impacted parties and prepare to implement a Standard Mass Adjustment Process (SMAP) to correct all impacted outpatient claims identified by Gainwell, which were processed with the wrong CF for CY 2023. Please see the timeline below for OHA actions. • Identify all CY 2023 outpatient claims that are impacted by the wrong conversion factor by May 20, 2025. • Change rate from 86.7850 to 85.585 by May 20, 2025. • Communicate with providers about the changes and next steps by May 20, 2025. • Implement a verification and validation process to confirm rates are accurately and delivered on time, completion deadline Dec. 31, 2025. Anticipated Completion Date: April 1, 2026 Contact person: Jennifer Stallsworth, Chief of Staff, ODHS APD, April Gillette, OHA Medicaid Division, Strategic Operations & Improvement Director

View Audit 353285 Questioned Costs: $1

Finding 554605 (2024-011)

Significant Deficiency 2024

State of Oregon

OR

Questioned Costs Period of Performance Significant Deficiency § 200.303

2024-011 Oregon Health Authority Strengthen existing controls to ensure only those costs incurred during the period of performance are charged to the grant Management Response: The agency agrees with the finding. While the appropriate internal controls are in place to review the period of performan...

2024-011 Oregon Health Authority Strengthen existing controls to ensure only those costs incurred during the period of performance are charged to the grant Management Response: The agency agrees with the finding. While the appropriate internal controls are in place to review the period of performance, a mistake was made while following the procedures. Secondary reviews will be performed going forward to ensure all expenditures are appropriately captured. The expenditures in question were moved to the correct phase 22 on Jan. 23, 2025 with document BTCG3186. Anticipated Completion Date: January 23, 2025 Contact Person: Travis Labrum, Accounting Manager

View Audit 353285 Questioned Costs: $1

Finding 554599 (2024-009)

Material Weakness 2024

State of Oregon

OR

Subrecipient Monitoring § 200.331

2024-009 Oregon Health Authority Continue to implement and strengthen controls to ensure subrecipients are appropriately identified and monitored. Management Response: The agency agrees with the finding. During state fiscal year 2024, the division was in the process of implementing controls for sub...

2024-009 Oregon Health Authority Continue to implement and strengthen controls to ensure subrecipients are appropriately identified and monitored. Management Response: The agency agrees with the finding. During state fiscal year 2024, the division was in the process of implementing controls for subrecipient determination or contractors, required reporting, risk assessment, and monitoring plan. Since this period, the division has fully implemented the internal controls to ensure compliance with the federal requirements as identified in prior audits. The division recognizes that there are opportunities to strengthen the controls for subrecipient contractor determination, risk assessments and monitoring activities are accurate, complete, and documented and will refine these tools. The division also recognizes the opportunity to continue to improve controls that ensure that corresponding disbursements of federal funds are appropriately reported. The division will collaborate with agency financial services to develop enhanced controls that will ensure prevention, detection, and correction of payment reporting. Contact Person: Mick Kincaid Business Operations Manager Behavioral Health Division

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Finding 554598 (2024-010)

Significant Deficiency 2024

State of Oregon

OR

Subrecipient Monitoring Reporting Significant Deficiency § 200.303

2024-010 Oregon Health Authority Submit required Federal Funding Accountability and Transparency Act reports Management Response: The agency agrees with the finding. The FFATA Reporting Coordinator position within the Office of Contracts & Procurement (OC&P) has been vacant for eight months but sho...

2024-010 Oregon Health Authority Submit required Federal Funding Accountability and Transparency Act reports Management Response: The agency agrees with the finding. The FFATA Reporting Coordinator position within the Office of Contracts & Procurement (OC&P) has been vacant for eight months but should be filled by April 15, 2025. On March 8, 2025, FSRS.gov was retired, and all subaward reporting data and functionality are now on SAM.gov. The new SAM.gov reporting system will allow for multiple Data Entry roles, allowing each program or division of ODHS/OHA to submit their own reporting, and allowing OC&P to conduct Quality Assurance/Quality Control. Once the FFATA Reporting Coordinator is onboard and trained, we anticipate the FFATA reporting will resume and any missing reports will be submitted by April 15, 2026. Anticipated Completion Date: April 15, 2026 Contact person: Noemi Schlegel, Compliance & Audits Program Manager

View Audit 353285

Finding 554597 (2024-027)

Significant Deficiency 2024

State of Oregon

OR

Questioned Costs Student Financial Aid Eligibility

2024-027 Oregon Department of Human Services Strengthen controls around background checks Management Response: Child Welfare has robust business processes that support the accurate and timely completion of fingerprint-based background checks. These include an OR-Kids provider record that ensures all...

2024-027 Oregon Department of Human Services Strengthen controls around background checks Management Response: Child Welfare has robust business processes that support the accurate and timely completion of fingerprint-based background checks. These include an OR-Kids provider record that ensures all required elements are completed prior to issuing a full certificate of approval, including management approval. Additionally, Title IV-E eligibility business processes require the verification of finger-print based background checks through review of the original documentation (1011f). The Foster Care Program completes regular quality assurance reviews in all districts as an ongoing effort to identify issues and ensure compliance. Any issues identified during reviews are discussed with local managers and staff to coordinate corrections and identify solutions and/or training needs. Program analysis of this error has determined the issue to be an isolated event of human error. Foster Care Program and Federal Policy and Resources will collaborate to ensure the error case is corrected and provide documentation to demonstrate those corrections. Anticipated Completion Date: April 30, 2025. Contact Persons: Megan Brazo-Erickson, Federal Policy and Resources, Donna Haney, Foster Care Program

View Audit 353285 Questioned Costs: $1

Finding 554596 (2024-033)

Significant Deficiency 2024

State of Oregon

OR

Reporting Significant Deficiency § 200.302 § 200.303

2024-033 Oregon Housing and Community Services Department Federal reports should contain accurate information Management Response: The agency agrees with this finding. A dedicated staff resource has been trained and has brought grant reconciliations and reporting current. Additional training has bee...

2024-033 Oregon Housing and Community Services Department Federal reports should contain accurate information Management Response: The agency agrees with this finding. A dedicated staff resource has been trained and has brought grant reconciliations and reporting current. Additional training has been provided for awareness of the obligation requirements as well. Anticipated Completion Date: June 30, 2025 Contact person: Beth Brown, Controller

View Audit 353285

Finding 554595 (2024-026)

Significant Deficiency 2024

State of Oregon

OR

Questioned Costs Eligibility Significant Deficiency

2024-026 Oregon Department of Human Services Ensure refugee status is verified and documented and income information is updated timely Management Response: The Refugee Program agrees with the findings. The Refugee Program has previously identified the need for additional training and has been taking...

2024-026 Oregon Department of Human Services Ensure refugee status is verified and documented and income information is updated timely Management Response: The Refugee Program agrees with the findings. The Refugee Program has previously identified the need for additional training and has been taking steps to address this issue. The Refugee Program has already conducted a comprehensive statewide training on Refugee Cash and Refugee Medical Assistance eligibility in January 2025. The training materials and recording are available for staff and leadership to access. The Refugee Program will continue providing training to individual branches and districts upon request. The Refugee Program offers monthly Analyst Hour calls to provide policy and program updates, address questions and troubleshoot complicated cases. To ensure better compliance, the Refugee Program will also focus on the recommended topics in the next three Analyst Hour calls. The Quality Assurance monthly reviews of Refugee Cash cases have resumed in March 2025. These reviews include all the items listed in the audit recommendations, which provides an additional layer for quality and accuracy check. In addition, the Refugee Program will discuss the recommended topics with service delivery statewide in ongoing meetings regarding eligibility and engagement. Anticipated completion date: June 30, 2025 Contact Person: Amra Biberić, Refugee program manager

View Audit 353285 Questioned Costs: $1

Finding 554594 (2024-032)

Significant Deficiency 2024

State of Oregon

OR

Questioned Costs Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking § 200.403

2024-032 Department of Justice Ensure program expenditures are supported Management Response: The Oregon Department of Justice agrees with the finding and provides the following information regarding the cause of this error and corrective action planned for implementation by June 30, 2025, which wil...

2024-032 Department of Justice Ensure program expenditures are supported Management Response: The Oregon Department of Justice agrees with the finding and provides the following information regarding the cause of this error and corrective action planned for implementation by June 30, 2025, which will be implemented by the Interim Financial Services Manager Richard Rylander. This error was caused through a lack of secondary validation of expenditures which resulted in incorrect expenditures being entered into the system. The correction action plan will update the Secondary Review of Expenditures and Batch Entry Process to ensure that the secondary review identifies and prevents errors which caused the finding above. Anticipated Completion Date: June 30, 2025 Contact person: Richard Rylander, Interim Financial Services Manager

View Audit 353285 Questioned Costs: $1

Finding 554593 (2024-025)

Significant Deficiency 2024

State of Oregon

OR

Special Tests & Provisions Subrecipient Monitoring Significant Deficiency

2024-025 Oregon Department of Human Services Ensure work participation rate calculation uses verified and accurate data Management Response: We agree with this recommendation. Office of Program Integrity’s leadership priorities are to update the risk assessment and to continue to meet weekly with th...

2024-025 Oregon Department of Human Services Ensure work participation rate calculation uses verified and accurate data Management Response: We agree with this recommendation. Office of Program Integrity’s leadership priorities are to update the risk assessment and to continue to meet weekly with the Chief Operating Officer to highlight the risks associated with inadequate staffing levels. Risk mitigation efforts to ensure JOBS reviews are performed in accordance with established procedures include cross training JOBS second level Quality Control beginning in March 2025 and time studies planned to determine adequate staffing levels for additional position requests. ODHS has a current workgroup led by the Project Management Office (PMO) that is tasked with conducting a training and coaching gap analysis for family coaches and making recommendations regarding Oregon’s Work Participation Rate. The workgroup consists of TANF policy analysts and the self- sufficiency training unit. In addition to the gap analysis, the workgroup is currently producing communications regarding documentation of work participation hours. ODHS will implement additional recommendations once they are identified. Anticipated Completion Date: 12/31/2025 Contact Person: Eva Ruiz, TANF program manager

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Finding 554592 (2024-024)

Significant Deficiency 2024

State of Oregon

OR

Special Tests & Provisions Eligibility Significant Deficiency

2024-024 Oregon Department of Human Services Improve controls relating to client non-cooperation with child support requirements Management Response: We agree with this recommendation. Department management acknowledges the finding and has already initiated actions to address the concerns. TANF poli...

2024-024 Oregon Department of Human Services Improve controls relating to client non-cooperation with child support requirements Management Response: We agree with this recommendation. Department management acknowledges the finding and has already initiated actions to address the concerns. TANF policy is developing a self-paced training on how to correctly process child support tasks. The training will be available to staff on the internal policy resource page, and communications will be sent advertising the training. ODHS will also continue to review a report of tasks that were marked as complete without a change in cooperation status in ONE and follow up with staff as necessary. In addition, the self- sufficiency training unit is in the process is developing a new family coach eligibility training in ONE which will include training on processing child support tasks that come through ONE. Anticipated Completion Date: 12/31/2025 Contact Person: Eva Ruiz, TANF program manager

View Audit 353285

Finding 554591 (2024-023)

Significant Deficiency 2024

State of Oregon

OR

Questioned Costs Allowable Costs / Cost Principles Significant Deficiency § 200.303

2024-023 Oregon Department of Human Services Strengthen controls over program expenditures Management Response: We agree with this recommendation. Department management acknowledges the finding and has already initiated actions to address the concerns. Quarterly collaboration meetings including TANF...

2024-023 Oregon Department of Human Services Strengthen controls over program expenditures Management Response: We agree with this recommendation. Department management acknowledges the finding and has already initiated actions to address the concerns. Quarterly collaboration meetings including TANF and TADVS policy, business security unit, business operations, and office of financial services began in July 2024. Issues and resolutions are discussed during these quarterly meetings; as a result, guidance for staff has been developed, and regular internal audits take place throughout the year. Business operations team in partnership with TANF policy will send out communication reminding staff of the process when a check is reported as lost, and the steps that must happen prior to a replacement check being issued. In addition, policy and business operations will attend meetings with those who have a leadership role in the system to approve payments and share the transmittal along with a discussion on ways to mitigate duplicate payments in the future. Child Welfare reviewed and corrected the transaction identified in this audit. Although the SPOTS card was reimbursed on July 21, 2023, the request in OR-Kids was not canceled on that day causing the transaction to hit the SFMA. During the audit, the error was discovered and Federal Policy and Resources worked with Office of Financial Services (OFS) to correct the reimbursement on February 26, 2025. The transaction was canceled in the OR-Kids system through financial cycle on February 26, 2025. OFS entered the correction in SFMA to reflect the reduction to TANF funding, which processed through OR-Kids on February 27, 2025, and interfaced to SFMA on the evening of February 27, 2025. Anticipated Completion Date: 12/31/2025 Contact Person: Eva Ruiz, TANF program manager

View Audit 353285 Questioned Costs: $1

Finding 554590 (2024-022)

Significant Deficiency 2024

State of Oregon

OR

Questioned Costs Special Tests & Provisions Eligibility § 200.303

2024-022 Oregon Department of Human Services Improve controls to ensure eligibility criteria are met Management Response: We agree with this recommendation. Beginning in April 2025 the Quality Control (QC) manager will have oversight of the process and be included in the emails between the QC lead a...

2024-022 Oregon Department of Human Services Improve controls to ensure eligibility criteria are met Management Response: We agree with this recommendation. Beginning in April 2025 the Quality Control (QC) manager will have oversight of the process and be included in the emails between the QC lead and administration concerning the error packets being sent to the branch for corrective action by the 15th of each month. The QC manager will check on the 16th of each month to ensure the task was completed. Department management acknowledges the finding and has already initiated actions to address the concerns. The State of Oregon has implemented a structured approach to address this concern. Since January 2025, the Oregon Eligibility Partnership (OEP) has updated and developed six eligibility guides aimed at improving, understanding, and execution of processes related to TANF enrollment, including asset pursuit and IEVS checks. These guides are now available as part of the training curriculum for eligibility workers. Additionally, the "Verification Take Time for Training" (TT4T) module, which was last presented in October 2022, will be reviewed by the OEP to assess potential gaps or outdated information. Any necessary updates will be incorporated by July 2025 to ensure comprehensive training is available to all eligibility workers. Finally, OEP will continue to monitor the effectiveness of the updated training materials and guides through ongoing reviews, feedback collection from eligibility workers, and periodic review and refreshing of the materials. Anticipated Completion Date: December 31, 2025 Contact Person: Eva Ruiz, TANF program manager

View Audit 353285 Questioned Costs: $1

Finding 554589 (2024-021)

Significant Deficiency 2024

State of Oregon

OR

Eligibility Reporting Significant Deficiency

2024-021 Oregon Department of Human Services Obtain accurate information from the ONE application Management Response: We agree with this recommendation. ODHS will continue to monitor and review the ACF-199 and ACF-209 prior to submission. The review will include a sample of JOBS eligible individual...

2024-021 Oregon Department of Human Services Obtain accurate information from the ONE application Management Response: We agree with this recommendation. ODHS will continue to monitor and review the ACF-199 and ACF-209 prior to submission. The review will include a sample of JOBS eligible individuals who do not have countable work activities in the ACF reports, to confirm that their TRACS personal development plan (PDP) accurately reflects engagement and activities in which the individual is engaged. Additionally, ODHS will implement a tracking system to ensure the review of reports is clearly documented. ODHS will continue to work with our vendor to secure a SOC 2 Type II audit of our processes and oversight of the ONE system in 2025. Additionally, ODHS will work on amending the ONE Maintenance & Operations agreement with Deloitte for them to obtain a scoped SOC 2 Type II audit related to their work within the ONE system. ODHS would expect to negotiate this additional audit requirement in 2025 with the first audit then happening in 2026. Anticipated Completion Date: December 31, 2025 Contact Person: Eva Ruiz, TANF program manager

View Audit 353285

Finding 554588 (2024-030)

Significant Deficiency 2024

State of Oregon

OR

Subrecipient Monitoring § 200.332

2024-030 Department of Education Perform regular fiscal monitoring as part of subrecipient monitoring Management Response: ODE agrees with this finding. ODE will ensure subrecipient fiscal monitoring is performed on the schedule set by department policy by: • Updating the internal procedure and time...

2024-030 Department of Education Perform regular fiscal monitoring as part of subrecipient monitoring Management Response: ODE agrees with this finding. ODE will ensure subrecipient fiscal monitoring is performed on the schedule set by department policy by: • Updating the internal procedure and timeline for requesting, reviewing and approving district submissions of claims for IDEA Fiscal Cyclical Monitoring. • Updating current IDEA Subrecipient Fiscal Monitoring manual to clarify updated internal procedure and timeline. The department will develop a procedure to track the completion of cyclical fiscal monitoring by: • Establishing a dedicated digital file to save district claims documentation and email communications for each cyclical monitoring review for each district. • Creating and utilizing a tracking document or system for each Cohort Group that will include the district, date of claim, amount of claim, approval status, date of approval, and location of documentation. • Develop a standard request notification and a standard approval notification for claims documentation. Anticipated Completion Date: June 30, 2025 Contact person: Allyson McNeil, OESO, Director of Resource Management and Operations and Rae Ann Ray, OESO IDEA Fiscal Team, IDEA Part B Grant Manager

View Audit 353285

Finding 554587 (2024-029)

Significant Deficiency 2024

State of Oregon

OR

Eligibility Period of Performance Reporting

2024-029 Oregon Commission for the Blind Strengthen internal controls to ensure performance data reports are accurate Management Response: We agree with the recommendation. The agency is committed to ensuring the RSA-911 client case information report is accurate, and to ensuring the agency’s case m...

2024-029 Oregon Commission for the Blind Strengthen internal controls to ensure performance data reports are accurate Management Response: We agree with the recommendation. The agency is committed to ensuring the RSA-911 client case information report is accurate, and to ensuring the agency’s case management system is well-documented and current. This issue was initially identified during the statewide single audit for the period ended June 30, 2023. In response to the prior year’s finding, the agency created a new case-note category for documenting client employment start date and wages at exit. Compliance with this new control is then verified as part of our pre-closure case file review process. The agency will continue to provide training to staff on the use of this case note category to ensure we are consistently documenting the start date of employment in the primary occupation and the hourly wage at exit. Anticipated Completion Date: July 1, 2025 Contact person: Angel Hale, Director of Vocational Rehabilitation Services

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Finding 554586 (2024-028)

Significant Deficiency 2024

State of Oregon

OR

Eligibility Period of Performance Reporting

2024-028 Oregon Department of Human Services Strengthen internal controls to ensure performance data reports are accurate Management Response: We agree with this recommendation. We agree with the recommendation and will ensure adequate supporting documentation is maintained and readily available to ...

2024-028 Oregon Department of Human Services Strengthen internal controls to ensure performance data reports are accurate Management Response: We agree with this recommendation. We agree with the recommendation and will ensure adequate supporting documentation is maintained and readily available to support information reported in the RSA-911. We will update internal controls related to this matter. Anticipated Completion Date: September 30, 2024 Contact Person: Bryan Campbell, Vocational Rehabilitation Operations Manager

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Finding 554585 (2024-043)

Significant Deficiency 2024

State of Oregon

OR

Eligibility Internal Control / Segregation of Duties § 200.303

2024-043 Department of Veterans' Affairs Encourage accuracy of per diem recalculations Management Response: ODVA agrees with this recommendation Reconciliation/recalculation procedures have been updated to fully align with regulations as established by 38 CFR 51.40. These procedures will include cal...

2024-043 Department of Veterans' Affairs Encourage accuracy of per diem recalculations Management Response: ODVA agrees with this recommendation Reconciliation/recalculation procedures have been updated to fully align with regulations as established by 38 CFR 51.40. These procedures will include calculation of days when a veteran may be absent for purposes other than receiving hospital care. In addition to strengthening procedures, the controller will review the reconciliation each month. Anticipated Completion Date: June 30, 2025 Contact person: Nicole Dolan, Budget and Fiscal Manager

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Finding 554584 (2024-038)

Significant Deficiency 2024

State of Oregon

OR

Reporting Significant Deficiency Internal Control / Segregation of Duties § 200.303

2024-038 Oregon Business Development Department Implement controls over reporting Management Response: We agree with this recommendation. The submission of the quarterly financial reports by Business Oregon to DAS CFRT is on-going and within the submission deadline of DAS CFRT staff. When preparing ...

2024-038 Oregon Business Development Department Implement controls over reporting Management Response: We agree with this recommendation. The submission of the quarterly financial reports by Business Oregon to DAS CFRT is on-going and within the submission deadline of DAS CFRT staff. When preparing for the quarterly financial report, the accounting/financial data has been prepared by our accountant and reviewed by Business Oregon’s accounting manager. The data is then submitted to program staff to complete the programmatic narrative and other performance-related information to further explain or describe the transactions for the reporting period, and then program staff submits the quarterly report to DAS CFRT. Going forward, to ensure reports submitted to DAS CFRT match with accounting records, management will make procedure changes by routing the report back to the accounting team for final review of financial data after program has entered their part of the report before sending to DAS CFRT. We will implement this process change effective immediately for the quarterly report ending March 2025. For the cumulative variance of $1.6 million, Business Oregon will conduct research to determine the cause of the variance. The under-reporting of expenses on the quarterly report ending June 2024 could be the result of data provided to DAS in mid-July 2024, to meet DAS CFRT reporting deadline, when the fiscal month of June 2024 was not officially closed until early August 2024. While the fiscal year-end process was still on-going through August 2024, the month of June is still open for accrual entries or adjustments, resulting to more expenditures in accounting records than what was reported to DAS in July. Business Oregon will perform reconciliation of data from 2020 to March 2025 to true up the expenditures reported in the accounting records and the reports submitted to DAS CFRT. Anticipated Completion Date: March 31, 2025 Contact person: Imee Anderson, Chief Financial Officer, Mia Seo, Deputy-Chief Financial Officer, Rory Spencer, Accounting Manager

View Audit 353285

Finding 554583 (2024-037)

Significant Deficiency 2024

State of Oregon

OR

Subrecipient Monitoring § 200.332 § 200.339 § 200.521

2024-037 Oregon Business Development Department Assign responsibility to ensure review of subrecipient audit reports Management Response: We agree with this recommendation. In January 2025, Business Oregon started the initial work by meeting with DAS SARS team on identifying specific tasks for Busin...

2024-037 Oregon Business Development Department Assign responsibility to ensure review of subrecipient audit reports Management Response: We agree with this recommendation. In January 2025, Business Oregon started the initial work by meeting with DAS SARS team on identifying specific tasks for Business Oregon as the assigned audit agency for the SLFRF award. Business Oregon completed the preliminary reviews and confirmed that 23 out of 24 recipients of the SLFRF award are required for the single audit. Business Oregon contacted the recipients and requested financial reports to proceed with review of subrecipient audits. As of March 2025, the work is still ongoing, and Business Oregon is currently communicating with the recipients. The estimated completion date of this review is 6/30/2025 Anticipated Completion Date: June 30, 2025 Contact person: Imee Anderson, Chief Financial Officer, Mia Seo, Deputy-Chief Financial Officer, Rory Spencer, Accounting Manager

View Audit 353285

Finding 554580 (2024-034)

Significant Deficiency 2024

State of Oregon

OR

HUD Housing Programs Reporting Significant Deficiency § 200.328

2024-034 Oregon Housing and Community Services Department Quarterly Performance Report should include all expenditures incurred to date Management Response: The agency agrees with this finding. Quarterly performance report requirements will be reviewed with staff and additional oversight will be add...

2024-034 Oregon Housing and Community Services Department Quarterly Performance Report should include all expenditures incurred to date Management Response: The agency agrees with this finding. Quarterly performance report requirements will be reviewed with staff and additional oversight will be added to ensure accurate reporting occurs. Corrective reports will be filed to the extent allowed by HUD. Anticipated Completion Date: June 30, 2025 Contact person: Beth Brown, Controller

View Audit 353285

Finding 554579 (2024-036)

Significant Deficiency 2024

State of Oregon

OR

Subrecipient Monitoring Reporting Significant Deficiency

2024-036 Oregon Business Development Department Implement controls and submit delinquent FFATA reports Management Response: We partially agree with this recommendation. Business Oregon has prepared and submitted FFATA reports in SAM.gov through 2023, and had done so yearly since 2011. Due to staff t...

2024-036 Oregon Business Development Department Implement controls and submit delinquent FFATA reports Management Response: We partially agree with this recommendation. Business Oregon has prepared and submitted FFATA reports in SAM.gov through 2023, and had done so yearly since 2011. Due to staff turnover, Business Oregon has not completed loading the data for FFATA reporting for 2024. Business Oregon is currently in the process of compiling the data pertaining to CDBG grant awards and other federal grant awards that met the criteria for FFATA reporting. Business Oregon will formally assign this reporting task and create written procedures regarding preparation of the FFATA reports to ensure a complete list of recipients or subawards is reported in SAM.gov in a timely manner. The estimated completion date of this corrective action is 6/30/2025. Anticipated Completion Date: June 30, 2025 Contact person: Imee Anderson, Chief Financial Officer, Mia Seo, Deputy-Chief Financial Officer, Rory Spencer, Accounting Manager, Jon Unger, CDBG Program Manager

View Audit 353285

Finding 554578 (2024-035)

Significant Deficiency 2024

State of Oregon

OR

HUD Housing Programs Period of Performance Reporting § 200.302

2024-035 Oregon Business Development Department Ensure CDBG expenditures are recorded in SFMA under the appropriate grant year Management Response: We agree with this recommendation. In February of 2025, the agency’s accountant assigned to this program began a full reconciliation of the CDBG program...

2024-035 Oregon Business Development Department Ensure CDBG expenditures are recorded in SFMA under the appropriate grant year Management Response: We agree with this recommendation. In February of 2025, the agency’s accountant assigned to this program began a full reconciliation of the CDBG program from FY 2020 to FY 2024. We have identified the differences between our accounting records in SFMA and what has been recorded through IDIS, our portal to request funds from the federal government. As of March 2025, we are beginning to finalize our reconciliation of administrative funds and our own agency’s matching contributions. Once incorporating this first step, our accounting staff will continue with a full project reconciliation for the current fiscal year, 2025. Any errors or adjustments identified will be corrected in this current fiscal year. This reconciliation between accounting records in SFMA and IDIS is expected to be complete in May of 2025. Anticipated Completion Date: May 31, 2025 Contact person: Imee Anderson, Chief Financial Officer, Mia Seo, Deputy-Chief Financial Officer, Rory Spencer, Accounting Manager, Jon Unger, CDBG Program Manager

View Audit 353285

Finding 554577 (2024-042)

Significant Deficiency 2024

State of Oregon

OR

Questioned Costs Period of Performance Cash Management

2024-042 Oregon Military Department Ensure payroll expenditures are coded to the correct period and errors are corrected timely Management Response: We agree with this recommendation. OMD acknowledges the finding regarding payroll expenditures coded outside the period of performance. We are committe...

2024-042 Oregon Military Department Ensure payroll expenditures are coded to the correct period and errors are corrected timely Management Response: We agree with this recommendation. OMD acknowledges the finding regarding payroll expenditures coded outside the period of performance. We are committed to strengthening controls to ensure payroll expenses are properly recorded and errors are promptly corrected. OMD will implement following corrective actions to address the recommendation made in the Audit Report. • All Payroll Coding Review Procedures: Establish a mandatory review process before finalizing payroll reimbursement requests to verify the correct coding of federal fiscal year allocations. • Timely Error Correction Process: Develop a formal procedure to ensure errors are identified and corrected within 60-90 days of discovery. • Training and Oversight: Conduct mandatory training for finance and payroll personnel on proper coding procedures and compliance with federal performance periods. • Review and Correction of Prior Year Coding Errors (FFY 2019, 2022, and 2023): Conduct a comprehensive review of payroll expenditures from FFY 2019, 2022, and 2023 to identify and correct any remaining errors. This process will involve reconciling payroll records with federal grant periods, adjusting accounting records, and ensuring proper documentation for any necessary retroactive corrections. Anticipated completion date: January 31, 2026. Contact person: Adam Giblin, Chief Financial Officer.

View Audit 353285 Questioned Costs: $1

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