ACDJFS will strengthen its internal controls and documentation practices related to the allocation of direct expenses and the completion of Random Moment Sampling (RMS) observations, particularly for programs serving both eligible and non eligible participants. 1. Strengthening Cost Allocation Controls ACDJFS will revise and reinforce its cost allocation procedures to ensure all direct expenses are properly assigned, consistently treated, and supported by clear documentation. Updated procedures will include supervisory review checkpoints and periodic reconciliation to ensure costs are charged in proportion to the benefit received by each program. 2. RMS Compliance and Documentation Standards ACDJFS provides a dedicated RMS Coordinator to maintain clear RMS compliance and documentation standards to ensure activities are coded accurately, consistently, and in accordance with state and federal requirements. Staff are expected to provide complete and accurate RMS responses that clearly describe the activity performed, its purpose, and the population served. Attention will be given to activities that support both eligible and non-eligible populations to ensure proper classification and allocation of costs. Allocation errors will be corrected promptly and documented. Incorrect RMS responses will be corrected and retrained immediately. All RMS responses are currently being reviewed. Supporting documentation must be maintained and readily available to substantiate RMS activities and demonstrate compliance during monitoring, audit, or review processes. Supervisors and management will routinely review RMS documentation and coding practices to ensure consistency, identify areas requiring clarification, and maintain the integrity of the agency's cost allocation methodology. The coding of direct expenses are reviewed prior to the processing month end to ensure that they are coded correctly. These standards help ensure RMS results accurately reflect agency operations and support the appropriate claiming of administrative costs. 3. Staff Training and Capacity Building ACDJFS will conduct targeted training for program and fiscal staff to ensure a consistent understanding of cost allocation principles, RMS documentation requirements, and compliance standards for programs serving mixed-eligibility populations. Annual refresher training will be incorporated into ongoing professional development efforts to reinforce expectations, maintain compliance, and support accurate coding practices. The RMS Coordinator will work closely with agency leadership and the Ohio Department of Job and Family Services (ODJFS) to monitor policy updates, guidance, and best practices related to Random Moment Sampling. The coordinator will obtain and disseminate updated information as quickly as possible to ensure staff receive timely communication, training, and technical assistance when changes occur. In addition, the RMS Coordinator will provide weekly reviews and updates to agency management, creating multiple levels of oversight and accountability. This ongoing review process allows leadership to identify trends, address potential concerns early, verify compliance, and ensure consistent application of RMS requirements across all programs. Through training, communication, and regular management review, ACDJFS strengthens internal controls and promotes the accuracy and integrity of its RMS activities. 4. Monitoring and Continuous Improvement ACDJFS leadership will conduct quarterly monitoring of allocation patterns, RMS samples, and documentation quality. Findings will be used to make timely corrections and guide additional staff training. Monitoring results will be retained and used to support continuous improvement. 5. Implementation Timeline All corrective actions, including updated procedures, training, and monitoring mechanisms—will be implemented within 90 days and maintained on an ongoing basis. Annual RMS training was completed in July 2025. ODJFS provided RMS training to all staff in December of 2025. ODJFS will provide annual RMS training scheduled for September 2, 2026. ODJFS will provide RMS Coordinator training on August 6, 2026. RMS training for Management/Fiscal is scheduled for July 7, 2026. Written documentation of fiscal procedures and policies is being reviewed and will be implemented by September 1, 2026.