EIN: 346000817
UEI: YJ4YYX15J6S3
Audited by: KEITH FABER / OHIO AUDITOR OF STATE
Oversight agency: 93 [Department of Health and Human Services]
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Data as of September 2, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on August 10, 2026. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by February 10, 2027 (159 days from today).
What is a management decision? →FAC accepted this audit on July 29, 2025 — management decision was due January 29, 2026.
FAC accepted this audit on June 9, 2026 — management decision was due December 9, 2026.
FAC accepted this audit on July 26, 2024 — management decision was due January 26, 2025.
FAC accepted this audit on June 24, 2025 — management decision was due December 24, 2025.
FAC accepted this audit on September 5, 2023 — management decision was due March 5, 2024.
The County incorrectly underreported the number of households that received ERA assistance and amounts paid on the monthly expenditure reports and overreported subrecipient expenditures on the quarterly project reports. Context: During our review of the monthly and quarterly compliance reports, we noted the following errors: ? The monthly compliance report for February 2022 reported 106 households served versus the 119 that were actually served. ? The monthly compliance report for February 2022 reported $447,839 expended to subrecipients versus $2,955,802 that was actually expended to subrecipients. ? The ERA 1 quarterly compliance report for Q3 2022 reported $2,680,575 expended versus $5,042,575 that was actually expended. ? The ERA 2 quarterly compliance report for Q3 2022 reported $20,012,525 expended versus $8,473,805 that was actually expended. Effect: The County was not in compliance with reporting requirements in 2022. Cause: Lack of sufficient internal controls over the reporting requirements of the ERA program. Recommendation: We recommend the County enhance its internal controls over the reporting requirements of the ERA program by reviewing the U.S. Department of Treasury?s federal guidance for reporting.
Show full finding ▾Hide full finding ▴2022-001 ? Reporting ? Significant Deficiency and Noncompliance ALN 21.023 ? COVID-19 Emergency Rental Assistance U.S. Department of Treasury Criteria: The U.S. Department of Treasury established reporting requirements for local governments. These requirements established methods for reporting Emergency Rental Assistance (ERA) expenditures to the U.S. Department of Treasury. Condition: The County incorrectly underreported the number of households that received ERA assistance and amounts paid on the monthly expenditure reports and overreported subrecipient expenditures on the quarterly project reports. Context: During our review of the monthly and quarterly compliance reports, we noted the following errors: ? The monthly compliance report for February 2022 reported 106 households served versus the 119 that were actually served. ? The monthly compliance report for February 2022 reported $447,839 expended to subrecipients versus $2,955,802 that was actually expended to subrecipients. ? The ERA 1 quarterly compliance report for Q3 2022 reported $2,680,575 expended versus $5,042,575 that was actually expended. ? The ERA 2 quarterly compliance report for Q3 2022 reported $20,012,525 expended versus $8,473,805 that was actually expended. Effect: The County was not in compliance with reporting requirements in 2022. Cause: Lack of sufficient internal controls over the reporting requirements of the ERA program. Recommendation: We recommend the County enhance its internal controls over the reporting requirements of the ERA program by reviewing the U.S. Department of Treasury?s federal guidance for reporting.
The Department of Development will implement policies and procedures to ensure the Emergency Rental Assistance (ERA) reporting processes are documented and followed to ensure compliance with Federal guidelines as well as Cuyahoga County policies. The Department of Development will ensure that they are submitting full compliance reports each calendar quarter throughout their award period of performance. Unless otherwise noted, the quarterly reports are due by the 15th of the month following the end of the quarterly reporting period. The Department of Development will provide their quarterly reports for the ERA program to Fiscal each quarter to ensure that the information reported to the U.S. Department of Treasury is in compliance with system reports
FAC accepted this audit on February 13, 2025 — management decision was due August 13, 2025.
The County incorrectly underreported the number of households that received ERA assistance and amounts paid on the monthly expenditure reports and overreported subrecipient expenditures on the quarterly project reports. Context: During our review of the monthly and quarterly compliance reports, we noted the following errors: ? The monthly compliance report for February 2022 reported 106 households served versus the 119 that were actually served. ? The monthly compliance report for February 2022 reported $447,839 expended to subrecipients versus $2,955,802 that was actually expended to subrecipients. ? The ERA 1 quarterly compliance report for Q3 2022 reported $2,680,575 expended versus $5,042,575 that was actually expended. ? The ERA 2 quarterly compliance report for Q3 2022 reported $20,012,525 expended versus $8,473,805 that was actually expended. Effect: The County was not in compliance with reporting requirements in 2022. Cause: Lack of sufficient internal controls over the reporting requirements of the ERA program. Recommendation: We recommend the County enhance its internal controls over the reporting requirements of the ERA program by reviewing the U.S. Department of Treasury?s federal guidance for reporting.
Show full finding ▾Hide full finding ▴2022-001 ? Reporting ? Significant Deficiency and Noncompliance ALN 21.023 ? COVID-19 Emergency Rental Assistance U.S. Department of Treasury Criteria: The U.S. Department of Treasury established reporting requirements for local governments. These requirements established methods for reporting Emergency Rental Assistance (ERA) expenditures to the U.S. Department of Treasury. Condition: The County incorrectly underreported the number of households that received ERA assistance and amounts paid on the monthly expenditure reports and overreported subrecipient expenditures on the quarterly project reports. Context: During our review of the monthly and quarterly compliance reports, we noted the following errors: ? The monthly compliance report for February 2022 reported 106 households served versus the 119 that were actually served. ? The monthly compliance report for February 2022 reported $447,839 expended to subrecipients versus $2,955,802 that was actually expended to subrecipients. ? The ERA 1 quarterly compliance report for Q3 2022 reported $2,680,575 expended versus $5,042,575 that was actually expended. ? The ERA 2 quarterly compliance report for Q3 2022 reported $20,012,525 expended versus $8,473,805 that was actually expended. Effect: The County was not in compliance with reporting requirements in 2022. Cause: Lack of sufficient internal controls over the reporting requirements of the ERA program. Recommendation: We recommend the County enhance its internal controls over the reporting requirements of the ERA program by reviewing the U.S. Department of Treasury?s federal guidance for reporting.
The Department of Development will implement policies and procedures to ensure the Emergency Rental Assistance (ERA) reporting processes are documented and followed to ensure compliance with Federal guidelines as well as Cuyahoga County policies. The Department of Development will ensure that they are submitting full compliance reports each calendar quarter throughout their award period of performance. Unless otherwise noted, the quarterly reports are due by the 15th of the month following the end of the quarterly reporting period. The Department of Development will provide their quarterly reports for the ERA program to Fiscal each quarter to ensure that the information reported to the U.S. Department of Treasury is in compliance with system reports
FAC accepted this audit on April 9, 2024 — management decision was due October 9, 2024.
During our testing we noted internal control weaknesses and noncompliance associated with the RMS requirements of the Foster Care and Adoption Assistance programs. Context: We noted the following errors during our test of a sample of 60 Child Welfare RMS observations: ? 3 out of 60 observations where the employee did not respond to the observation within 48 hours; ? 4 out of 60 observations in which vacant positions were selected; ? 8 out of 60 observations where the RMS coordinator did not accept the observation within 72 hours; and ? 8 out of 60 observations where there was no response by the employee and the RMS coordinator documented a response but did not maintain supporting documentation. Effect: The County is not in compliance with RMS requirements of the Ohio Administrative Code andDR Allowable Cost/Activity Requirements of Uniform Guidance. Cause: The County did not have a formalized process for ensuring that employees and supervisors respond accurately and timely to RMS samples. Recommendation: We recommend the County develop and implement procedures to ensure that employees, supervisors and RMS coordinators respond to RMS samples timely and accurately.
Show full finding ▾Hide full finding ▴2021-003 Random Moment Sampling Weaknesses ? Material Weakness and Noncompliance ALN # 93.658 ? Foster Care ? Title IV-E ALN # 93.659 ? Adoption Assistance ? Title IV-E Criteria: 45 CFR Section 75.416(a) states program costs must be ?identified and assigned to the benefitted activities on a reasonable and consistent basis.? Additionally, 45 CFR Section 75.430(i)(5) indicates random moment sampling (RMS) may be used to allocate salaries and wages to a Federal award, but such systems must ?meet acceptable statistical sampling standards.? Ohio Administrative Code Section 5101:9-7-20(A) states, in part: ?income maintenance random moment sample (IMRMS), workforce random moment sample (WFRMS), social services random moment sample (SSRMS), and child welfare random moment sample (CWRMS) time studies are designed to measure activity regarding various programs. The child support random moment sample (CSRMS) is described in rule 5101:9-7-23 of the Administrative Code. Data collected from these time studies are used to calculate allocation statistics used to distribute cost pool expenditures to the appropriate programs.? Ohio Administrative Code Section 5101:9-7-20(E)(2)(b)(ii) states ?the employee shall ensure that adequate backup documentation is available to verify the activity being performed.? The Ohio Department of Job and Family Services (ODJFS) also added the following in the ?RMS Frequently Asked Questions? in which they suggested that agencies have the caseworker make notes in SETS, CRISe, SACWIS, or other case management systems to further support the hit and/or make references to lead to the source documentation, (i.e. paper files, calendars, phone logs, etc.) for period under audit. Ohio Administrative Code Section 5101:9-7-20(E)(3) states ?an employee receiving an observation moment will have 48 hours to respond, not including weekends or holidays.? The Ohio Department of Job and Family Services (ODJFS) also added the following in the ?RMS Frequently Asked Questions,? ?the RMS Coordinator is only authorized to complete an observation on a participant?s behalf if the employee is unable to complete the observation within 48 hours. The moments are still due within 48 hours.? Ohio Administrative Code Section 5101:9-7-20(F)(3) and 5101:9-7-23(F)(3) state that ?in accordance with federally accepted timelines, the RMS/CSRMS coordinator shall review and approve by accepting all observation moment responses within seventy-two hours.? Ohio Administrative Code Section 5101:9-7-20(H) and 5101:9-7-23(H) state that to ?assure sampling accuracy and quality control, for each sampling period, ten percent of all IMRWS, WFRMS, SSRMS, CWRMS, and CSRMS observations are systematically selected from total RMS observations, and are known as control observations. Supervisors must validate at least forty percent of the control observations for each sampling period and shall have sufficient knowledge of the programs and activities performed by the employee(s) to determine the accuracy of the response. The supervisor shall be responsible for validation of responses within the same forty-eight-hour response period that is available to the employee. By approving the response, the supervisor is verifying that the appropriate program and activity was selected. After the supervisor approves the response, the RMS/CSRMS coordinator will accept the response within seventy-two hours.? Condition: During our testing we noted internal control weaknesses and noncompliance associated with the RMS requirements of the Foster Care and Adoption Assistance programs. Context: We noted the following errors during our test of a sample of 60 Child Welfare RMS observations: ? 3 out of 60 observations where the employee did not respond to the observation within 48 hours; ? 4 out of 60 observations in which vacant positions were selected; ? 8 out of 60 observations where the RMS coordinator did not accept the observation within 72 hours; and ? 8 out of 60 observations where there was no response by the employee and the RMS coordinator documented a response but did not maintain supporting documentation. Effect: The County is not in compliance with RMS requirements of the Ohio Administrative Code andDR Allowable Cost/Activity Requirements of Uniform Guidance. Cause: The County did not have a formalized process for ensuring that employees and supervisors respond accurately and timely to RMS samples. Recommendation: We recommend the County develop and implement procedures to ensure that employees, supervisors and RMS coordinators respond to RMS samples timely and accurately.
Finding Number: 2021-003 Planned Corrective Action: HHS will provide training and share information between program staff to help Foster Care and Adoption Assistance implement the same policies and procedures that the other HHS programs implemented in order to adhere to the RMS timeframes. Anticipated Completion Date: 12/31/22 Responsible Contact Person: Kathy Stark
2020-004
The subaward agreements issued to subrecipients under the Block Grant for the Prevention and Treatment of Substance Abuse program do not clearly identify all of the required information. Context: We selected 7 out of 42 subrecipient agreements during our audit. We noted that in all 7 of the subgrant agreements selected key award information was missing. None of the agreements specifically identified the subaward as federal funding, identified the Assistance Listing Number, or specifically identified the subaward as a subrecipient agreement. Effect: The County has not complied with subrecipient monitoring requirements and has not clearly identified required information to its subrecipients. Cause: The County has not implemented controls to ensure subrecipient agreements include all of the required language. Recommendation: We recommend the County implement training for agencies and departments to ensure they are aware of the subrecipient monitoring requirements, including the requirements associated with subrecipient agreements.
Show full finding ▾Hide full finding ▴2021-004 Subrecipient Agreements ? Material Weakness and Noncompliance ALN # 93.959 ? Block Grant for the Prevention and Treatment of Substance Abuse Criteria: 2 CFR 200.331 requires a pass-through entity to clearly identify to the subrecipient: (1) the award as a subaward at the time of subaward by providing the information described in 2 CFR section 200.331(a)(1); (2) all requirements imposed by the pass-through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award; and (3) any additional requirements that the pass-through entity imposes on the subrecipient in order for the pass-through entity to meet its own responsibilities for the Federal award. Condition: The subaward agreements issued to subrecipients under the Block Grant for the Prevention and Treatment of Substance Abuse program do not clearly identify all of the required information. Context: We selected 7 out of 42 subrecipient agreements during our audit. We noted that in all 7 of the subgrant agreements selected key award information was missing. None of the agreements specifically identified the subaward as federal funding, identified the Assistance Listing Number, or specifically identified the subaward as a subrecipient agreement. Effect: The County has not complied with subrecipient monitoring requirements and has not clearly identified required information to its subrecipients. Cause: The County has not implemented controls to ensure subrecipient agreements include all of the required language. Recommendation: We recommend the County implement training for agencies and departments to ensure they are aware of the subrecipient monitoring requirements, including the requirements associated with subrecipient agreements.
Finding Number: 2021-004 Planned Corrective Action: The ADAMHS Board will review 2 CFR 200.331 and then conduct a thorough review of its subgrant agreements to ensure that all new agreements are updated to meet the requirements of Uniform Guidance. For existing agreements, the ADAMHS Board will send contract modification notices to identify all the missing information for existing subrecipients. Anticipated Completion Date: 09/30/22 Responsible Contact Person: Felicia Harrison
The Department of Development did not report subaward data through FSRS during 2021. Context: The Department of Development passed through $4,172,479 to subrecipients during 2021 and did not report any of the data in FSRS. Effect: The County is not in compliance with FFATA reporting requirements. Cause: There were staffing changes during the pandemic and the responsibility for this requirement was not properly transitioned. Recommendation: We recommend the County implement policies and procedures that ensures compliance with FFATA reporting requirements and also document the policies and procedures and implement monitoring controls to ensure compliance is maintained even during periods of staff turnover.
Show full finding ▾Hide full finding ▴2021-005 Reporting ? Material Weakness and Noncompliance ALN # 14.218 ? CDBG Entitlement Grants Cluster Criteria: Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) that are codified in 2 CFR Part 170, direct recipients of grants or cooperative agreements who make first tier subawards of $30,000 or more are required to register in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS) and report subaward data through FSRS. Condition: The Department of Development did not report subaward data through FSRS during 2021. Context: The Department of Development passed through $4,172,479 to subrecipients during 2021 and did not report any of the data in FSRS. Effect: The County is not in compliance with FFATA reporting requirements. Cause: There were staffing changes during the pandemic and the responsibility for this requirement was not properly transitioned. Recommendation: We recommend the County implement policies and procedures that ensures compliance with FFATA reporting requirements and also document the policies and procedures and implement monitoring controls to ensure compliance is maintained even during periods of staff turnover.
Finding Number: 2021-005 Planned Corrective Action: The Department of Development will implement policies and procedures to ensure FFATA reporting processes are documented and followed to ensure compliance. The Department of Development will also go back and update past subrecipient data in FSRS. Anticipated Completion Date: 09/30/22 Responsible Contact Person: Laura Simms
FAC accepted this audit on September 15, 2022 — management decision was due March 15, 2023.
During our testing we noted internal control weaknesses and noncompliance associated with the RMS requirements of the Foster Care and Adoption Assistance programs. Context: We noted the following errors during our test of a sample of 60 Child Welfare RMS observations: ? 3 out of 60 observations where the employee did not respond to the observation within 48 hours; ? 4 out of 60 observations in which vacant positions were selected; ? 8 out of 60 observations where the RMS coordinator did not accept the observation within 72 hours; and ? 8 out of 60 observations where there was no response by the employee and the RMS coordinator documented a response but did not maintain supporting documentation. Effect: The County is not in compliance with RMS requirements of the Ohio Administrative Code andDR Allowable Cost/Activity Requirements of Uniform Guidance. Cause: The County did not have a formalized process for ensuring that employees and supervisors respond accurately and timely to RMS samples. Recommendation: We recommend the County develop and implement procedures to ensure that employees, supervisors and RMS coordinators respond to RMS samples timely and accurately.
Show full finding ▾Hide full finding ▴2021-003 Random Moment Sampling Weaknesses ? Material Weakness and Noncompliance ALN # 93.658 ? Foster Care ? Title IV-E ALN # 93.659 ? Adoption Assistance ? Title IV-E Criteria: 45 CFR Section 75.416(a) states program costs must be ?identified and assigned to the benefitted activities on a reasonable and consistent basis.? Additionally, 45 CFR Section 75.430(i)(5) indicates random moment sampling (RMS) may be used to allocate salaries and wages to a Federal award, but such systems must ?meet acceptable statistical sampling standards.? Ohio Administrative Code Section 5101:9-7-20(A) states, in part: ?income maintenance random moment sample (IMRMS), workforce random moment sample (WFRMS), social services random moment sample (SSRMS), and child welfare random moment sample (CWRMS) time studies are designed to measure activity regarding various programs. The child support random moment sample (CSRMS) is described in rule 5101:9-7-23 of the Administrative Code. Data collected from these time studies are used to calculate allocation statistics used to distribute cost pool expenditures to the appropriate programs.? Ohio Administrative Code Section 5101:9-7-20(E)(2)(b)(ii) states ?the employee shall ensure that adequate backup documentation is available to verify the activity being performed.? The Ohio Department of Job and Family Services (ODJFS) also added the following in the ?RMS Frequently Asked Questions? in which they suggested that agencies have the caseworker make notes in SETS, CRISe, SACWIS, or other case management systems to further support the hit and/or make references to lead to the source documentation, (i.e. paper files, calendars, phone logs, etc.) for period under audit. Ohio Administrative Code Section 5101:9-7-20(E)(3) states ?an employee receiving an observation moment will have 48 hours to respond, not including weekends or holidays.? The Ohio Department of Job and Family Services (ODJFS) also added the following in the ?RMS Frequently Asked Questions,? ?the RMS Coordinator is only authorized to complete an observation on a participant?s behalf if the employee is unable to complete the observation within 48 hours. The moments are still due within 48 hours.? Ohio Administrative Code Section 5101:9-7-20(F)(3) and 5101:9-7-23(F)(3) state that ?in accordance with federally accepted timelines, the RMS/CSRMS coordinator shall review and approve by accepting all observation moment responses within seventy-two hours.? Ohio Administrative Code Section 5101:9-7-20(H) and 5101:9-7-23(H) state that to ?assure sampling accuracy and quality control, for each sampling period, ten percent of all IMRWS, WFRMS, SSRMS, CWRMS, and CSRMS observations are systematically selected from total RMS observations, and are known as control observations. Supervisors must validate at least forty percent of the control observations for each sampling period and shall have sufficient knowledge of the programs and activities performed by the employee(s) to determine the accuracy of the response. The supervisor shall be responsible for validation of responses within the same forty-eight-hour response period that is available to the employee. By approving the response, the supervisor is verifying that the appropriate program and activity was selected. After the supervisor approves the response, the RMS/CSRMS coordinator will accept the response within seventy-two hours.? Condition: During our testing we noted internal control weaknesses and noncompliance associated with the RMS requirements of the Foster Care and Adoption Assistance programs. Context: We noted the following errors during our test of a sample of 60 Child Welfare RMS observations: ? 3 out of 60 observations where the employee did not respond to the observation within 48 hours; ? 4 out of 60 observations in which vacant positions were selected; ? 8 out of 60 observations where the RMS coordinator did not accept the observation within 72 hours; and ? 8 out of 60 observations where there was no response by the employee and the RMS coordinator documented a response but did not maintain supporting documentation. Effect: The County is not in compliance with RMS requirements of the Ohio Administrative Code andDR Allowable Cost/Activity Requirements of Uniform Guidance. Cause: The County did not have a formalized process for ensuring that employees and supervisors respond accurately and timely to RMS samples. Recommendation: We recommend the County develop and implement procedures to ensure that employees, supervisors and RMS coordinators respond to RMS samples timely and accurately.
Finding Number: 2021-003 Planned Corrective Action: HHS will provide training and share information between program staff to help Foster Care and Adoption Assistance implement the same policies and procedures that the other HHS programs implemented in order to adhere to the RMS timeframes. Anticipated Completion Date: 12/31/22 Responsible Contact Person: Kathy Stark
2020-004
The subaward agreements issued to subrecipients under the Block Grant for the Prevention and Treatment of Substance Abuse program do not clearly identify all of the required information. Context: We selected 7 out of 42 subrecipient agreements during our audit. We noted that in all 7 of the subgrant agreements selected key award information was missing. None of the agreements specifically identified the subaward as federal funding, identified the Assistance Listing Number, or specifically identified the subaward as a subrecipient agreement. Effect: The County has not complied with subrecipient monitoring requirements and has not clearly identified required information to its subrecipients. Cause: The County has not implemented controls to ensure subrecipient agreements include all of the required language. Recommendation: We recommend the County implement training for agencies and departments to ensure they are aware of the subrecipient monitoring requirements, including the requirements associated with subrecipient agreements.
Show full finding ▾Hide full finding ▴2021-004 Subrecipient Agreements ? Material Weakness and Noncompliance ALN # 93.959 ? Block Grant for the Prevention and Treatment of Substance Abuse Criteria: 2 CFR 200.331 requires a pass-through entity to clearly identify to the subrecipient: (1) the award as a subaward at the time of subaward by providing the information described in 2 CFR section 200.331(a)(1); (2) all requirements imposed by the pass-through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award; and (3) any additional requirements that the pass-through entity imposes on the subrecipient in order for the pass-through entity to meet its own responsibilities for the Federal award. Condition: The subaward agreements issued to subrecipients under the Block Grant for the Prevention and Treatment of Substance Abuse program do not clearly identify all of the required information. Context: We selected 7 out of 42 subrecipient agreements during our audit. We noted that in all 7 of the subgrant agreements selected key award information was missing. None of the agreements specifically identified the subaward as federal funding, identified the Assistance Listing Number, or specifically identified the subaward as a subrecipient agreement. Effect: The County has not complied with subrecipient monitoring requirements and has not clearly identified required information to its subrecipients. Cause: The County has not implemented controls to ensure subrecipient agreements include all of the required language. Recommendation: We recommend the County implement training for agencies and departments to ensure they are aware of the subrecipient monitoring requirements, including the requirements associated with subrecipient agreements.
Finding Number: 2021-004 Planned Corrective Action: The ADAMHS Board will review 2 CFR 200.331 and then conduct a thorough review of its subgrant agreements to ensure that all new agreements are updated to meet the requirements of Uniform Guidance. For existing agreements, the ADAMHS Board will send contract modification notices to identify all the missing information for existing subrecipients. Anticipated Completion Date: 09/30/22 Responsible Contact Person: Felicia Harrison
The Department of Development did not report subaward data through FSRS during 2021. Context: The Department of Development passed through $4,172,479 to subrecipients during 2021 and did not report any of the data in FSRS. Effect: The County is not in compliance with FFATA reporting requirements. Cause: There were staffing changes during the pandemic and the responsibility for this requirement was not properly transitioned. Recommendation: We recommend the County implement policies and procedures that ensures compliance with FFATA reporting requirements and also document the policies and procedures and implement monitoring controls to ensure compliance is maintained even during periods of staff turnover.
Show full finding ▾Hide full finding ▴2021-005 Reporting ? Material Weakness and Noncompliance ALN # 14.218 ? CDBG Entitlement Grants Cluster Criteria: Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) that are codified in 2 CFR Part 170, direct recipients of grants or cooperative agreements who make first tier subawards of $30,000 or more are required to register in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS) and report subaward data through FSRS. Condition: The Department of Development did not report subaward data through FSRS during 2021. Context: The Department of Development passed through $4,172,479 to subrecipients during 2021 and did not report any of the data in FSRS. Effect: The County is not in compliance with FFATA reporting requirements. Cause: There were staffing changes during the pandemic and the responsibility for this requirement was not properly transitioned. Recommendation: We recommend the County implement policies and procedures that ensures compliance with FFATA reporting requirements and also document the policies and procedures and implement monitoring controls to ensure compliance is maintained even during periods of staff turnover.
Finding Number: 2021-005 Planned Corrective Action: The Department of Development will implement policies and procedures to ensure FFATA reporting processes are documented and followed to ensure compliance. The Department of Development will also go back and update past subrecipient data in FSRS. Anticipated Completion Date: 09/30/22 Responsible Contact Person: Laura Simms
FAC accepted this audit on June 12, 2022 — management decision was due December 12, 2022.
SNAP, TANF, Medicaid, SSBG, CCDBG, Child Support Enforcement, Foster Care and Adoption Assistance - Costs Claimed to Incorrect Cost Pool See Schedule of Findings and Questioned Costs for table in place of the table within the text. Material Weakness and Noncompliance and Questioned Cost 2 CFR ? 200.400.1 gives regulatory effect to the Department of Agriculture for 2 CFR ? 200.405 (a) which states, in part: ?[a] cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.? 45 CFR ? 75.405(a) states, in part: ?[a] cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.? Ohio Admin. Code ? 5101:9-1-04(B) ?Shared administrative costs? states: ?(1) Shared administrative costs are incurred for a common purpose benefiting more than one major function and are not readily assignable to specific programs or cost pools. (2) In a county department of job and family services (CDJFS) or a combined agency, staff are identified with one or more programs and the information is imported to the Ohio department of job and family services (ODJFS) via the county finance information system (CFIS Web).? Ohio Admin. Code ? 5101:9-1-04(C) states the following: ?[a]dministrative costs associated with the major program area categories and ODJFS acknowledged CDJFS function or program cost category are grouped into cost pools. Cost pools are based on the program activity to which they relate. Expenditures reported through cost pools represent operating costs of the local agency. Administrative costs linked to direct casework activity are measured and allocated to various federal funding sources and programs through the random moment sample (RMS) time study.? Ohio Admin. Code ? 5101:9-1-04(C)(1)(a) defines ?Income Maintenance (IM) administrative costs? as ?costs that benefit one or more IM programs. The IM cost pool consists of costs relating to the administration of various IM programs and may include work activities under prevention, retention, and contingency (PRC), Ohio works first (OWF), or food assistance employment and training (FAET).? Ohio Admin. Code ? 5101:9-1-04(C)(2)(a) defines ?Social service (SS) administrative costs? as ?costs that benefit one or more SS programs. The SS cost pool consists of costs relating to the administration of various SS programs.? Ohio Admin. Code ? 5101:9-1-04(C)(4)(a) states "Child support (CS) administrative costs are all CS expenditures with the exception of direct Title IV-D or non-IV-D costs, shared costs, and countywide central service plan payments. The CS cost pool consists of costs relating to the administration of the CS program." Due to a lack of internal controls over cost charged to each pool, 46 expenditures totaling $519,165 disclosed four instances totaling $28,799, in which the non-payroll expenditures were charged to an improper cost pool in CFIS Web. These errors also resulted in questioned costs of $28,799. Failure to charge these costs to the appropriate cost pool resulted in the allocation of costs to non-benefiting programs, which subsequently resulted in the improper Federal reimbursement to these non-benefitting programs. The County Department of Health and Human Services (HHS) should implement procedures to evaluate expenditures to determine which program(s) they benefit in order to charge the associated costs to the appropriate indirect cost pool in CFIS Web. Costs which benefit one program area of the department, such as Income Maintenance should be claimed to the cost pool associated with that program area. Costs which benefit multiple program areas, such as Income Maintenance, Social Services, and Child Support should be claimed to the Shared Cost Pool. Additionally, HHS complete the necessary adjustment in CFIS Web to reclassify the aforementioned costs, and any similar ones, to the benefitting cost pool.
Show full finding ▾Hide full finding ▴SNAP, TANF, Medicaid, SSBG, CCDBG, Child Support Enforcement, Foster Care and Adoption Assistance - Costs Claimed to Incorrect Cost Pool See Schedule of Findings and Questioned Costs for table in place of the table within the text. Material Weakness and Noncompliance and Questioned Cost 2 CFR ? 200.400.1 gives regulatory effect to the Department of Agriculture for 2 CFR ? 200.405 (a) which states, in part: ?[a] cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.? 45 CFR ? 75.405(a) states, in part: ?[a] cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.? Ohio Admin. Code ? 5101:9-1-04(B) ?Shared administrative costs? states: ?(1) Shared administrative costs are incurred for a common purpose benefiting more than one major function and are not readily assignable to specific programs or cost pools. (2) In a county department of job and family services (CDJFS) or a combined agency, staff are identified with one or more programs and the information is imported to the Ohio department of job and family services (ODJFS) via the county finance information system (CFIS Web).? Ohio Admin. Code ? 5101:9-1-04(C) states the following: ?[a]dministrative costs associated with the major program area categories and ODJFS acknowledged CDJFS function or program cost category are grouped into cost pools. Cost pools are based on the program activity to which they relate. Expenditures reported through cost pools represent operating costs of the local agency. Administrative costs linked to direct casework activity are measured and allocated to various federal funding sources and programs through the random moment sample (RMS) time study.? Ohio Admin. Code ? 5101:9-1-04(C)(1)(a) defines ?Income Maintenance (IM) administrative costs? as ?costs that benefit one or more IM programs. The IM cost pool consists of costs relating to the administration of various IM programs and may include work activities under prevention, retention, and contingency (PRC), Ohio works first (OWF), or food assistance employment and training (FAET).? Ohio Admin. Code ? 5101:9-1-04(C)(2)(a) defines ?Social service (SS) administrative costs? as ?costs that benefit one or more SS programs. The SS cost pool consists of costs relating to the administration of various SS programs.? Ohio Admin. Code ? 5101:9-1-04(C)(4)(a) states "Child support (CS) administrative costs are all CS expenditures with the exception of direct Title IV-D or non-IV-D costs, shared costs, and countywide central service plan payments. The CS cost pool consists of costs relating to the administration of the CS program." Due to a lack of internal controls over cost charged to each pool, 46 expenditures totaling $519,165 disclosed four instances totaling $28,799, in which the non-payroll expenditures were charged to an improper cost pool in CFIS Web. These errors also resulted in questioned costs of $28,799. Failure to charge these costs to the appropriate cost pool resulted in the allocation of costs to non-benefiting programs, which subsequently resulted in the improper Federal reimbursement to these non-benefitting programs. The County Department of Health and Human Services (HHS) should implement procedures to evaluate expenditures to determine which program(s) they benefit in order to charge the associated costs to the appropriate indirect cost pool in CFIS Web. Costs which benefit one program area of the department, such as Income Maintenance should be claimed to the cost pool associated with that program area. Costs which benefit multiple program areas, such as Income Maintenance, Social Services, and Child Support should be claimed to the Shared Cost Pool. Additionally, HHS complete the necessary adjustment in CFIS Web to reclassify the aforementioned costs, and any similar ones, to the benefitting cost pool.
Health and Human Services (HHS) has implemented procedures to evaluate expenditures to determine which program(s) they benefit in order to charge the associated costs to the appropriate indirect cost pool, in CFIS Web. HHS put all new codes in CFIS and reviewed the mapping codes. Costs which benefit multiple program areas are claimed to the Shared Cost Pool. Anticipated Completion Date: 12/31/2021. Responsible Contact Person: Kathy Starks
2019-002
SNAP, TANF, Medicaid, SSBG, CCDBG, Child Support Enforcement, Adoption Assistance and Foster Care-Differences Between Cost Allocation Plan and Lawson Accounting System See Schedule of Findings and Questioned Costs for table in place of the table within the text. Material Weakness and Noncompliance and Questioned Cost 2 CFR ? 200.400.1 gives regulatory effect to the Department of Agriculture for 2 CFR 200 Appendix V A(1) which states in part: "All costs and other data used to distribute the costs included in the plan should be supported by formal accounting and other records that will support the propriety of the costs assigned to Federal awards." 45 CFR 75 Appendix V A(1) which states in part: "All costs and other data used to distribute the costs included in the plan should be supported by formal accounting and other records that will support the propriety of the costs assigned to Federal awards." 45 CFR Part 75 Appendix V G(3) and 2 CFR 200 Appendix V G(3) state in part: ?a carry-forward adjustment is not permitted, for a central service activity that was not included in the approved plan, or for unallowable costs that must be reimbursed immediately." Prior to the preparation and submission of the 2020 Cost Allocation Plan (CAP), the County utilized the 2019 CAP as an estimate to post indirect costs to the Lawson accounting system. In addition, the County posted 2019 CAP adjustments to the accounting system in 2020 instead of adding them to the 2020 CAP, as required. Further, the County never reconciled and adjusted the 2020 indirect cost postings to match the 2020 CAP. The differences between the 2020 Cost Allocation Plan (CAP) and the posting to Lawson are as follows: See Schedule of Findings and Questioned Costs for table in place of the table within the text. This internal control weakness resulted in questioned costs in excess of $25,000 for each of the federal programs denoted above, except the Social Services Block Grant and Child Care and Development Block Grant, which could affect future grant funding. The County should reconcile and adjust the 2020 indirect cost postings to match the 2020 CAP, prior to year-end. Further, any prior year CAP reconciling items need to be brought forward and included in the current CAP and not adjusted directly to the accounting system.
Show full finding ▾Hide full finding ▴SNAP, TANF, Medicaid, SSBG, CCDBG, Child Support Enforcement, Adoption Assistance and Foster Care-Differences Between Cost Allocation Plan and Lawson Accounting System See Schedule of Findings and Questioned Costs for table in place of the table within the text. Material Weakness and Noncompliance and Questioned Cost 2 CFR ? 200.400.1 gives regulatory effect to the Department of Agriculture for 2 CFR 200 Appendix V A(1) which states in part: "All costs and other data used to distribute the costs included in the plan should be supported by formal accounting and other records that will support the propriety of the costs assigned to Federal awards." 45 CFR 75 Appendix V A(1) which states in part: "All costs and other data used to distribute the costs included in the plan should be supported by formal accounting and other records that will support the propriety of the costs assigned to Federal awards." 45 CFR Part 75 Appendix V G(3) and 2 CFR 200 Appendix V G(3) state in part: ?a carry-forward adjustment is not permitted, for a central service activity that was not included in the approved plan, or for unallowable costs that must be reimbursed immediately." Prior to the preparation and submission of the 2020 Cost Allocation Plan (CAP), the County utilized the 2019 CAP as an estimate to post indirect costs to the Lawson accounting system. In addition, the County posted 2019 CAP adjustments to the accounting system in 2020 instead of adding them to the 2020 CAP, as required. Further, the County never reconciled and adjusted the 2020 indirect cost postings to match the 2020 CAP. The differences between the 2020 Cost Allocation Plan (CAP) and the posting to Lawson are as follows: See Schedule of Findings and Questioned Costs for table in place of the table within the text. This internal control weakness resulted in questioned costs in excess of $25,000 for each of the federal programs denoted above, except the Social Services Block Grant and Child Care and Development Block Grant, which could affect future grant funding. The County should reconcile and adjust the 2020 indirect cost postings to match the 2020 CAP, prior to year-end. Further, any prior year CAP reconciling items need to be brought forward and included in the current CAP and not adjusted directly to the accounting system.
Going forward the County will ensure that any prior year CAP adjustments are brought forward and added to the current Cost Allocation Plan and not adjusted directly to the accounting system. Anticipated Completion Date: 12/31/2021. Responsible Contact Person: Kathy Starks
2019-006
SNAP, TANF, Medicaid, SSBG, CCDBG, Child Support Enforcement, Adoption Assistance and Foster Care - Random Moment Sampling Weaknesses See Schedule of Findings and Questioned Costs for table in place of the table within the text. Material Weakness and Noncompliance 2 CFR ? 200.400.1 gives regulatory effect to the Department of Agriculture for 2 CFR ? 200.416(a) and 2 CFR ? 200.430(i)(5). 2 CFR ? 200.416(a) state?s program costs must be ?identified and assigned to the benefitted activities on a reasonable and consistent basis.? Additionally, 2 CFR ? 200.430(i)(5) indicates random moment sampling (RMS) may be used to allocate salaries and wages to a Federal award, but such systems must ?meet acceptable statistical sampling standards?. 45 CFR ? 75.416(a) state?s program costs must be ?identified and assigned to the benefitted activities on a reasonable and consistent basis.? Additionally, 45 CFR ? 75.430(i)(5) indicates random moment sampling (RMS) may be used to allocate salaries and wages to a Federal award, but such systems must ?meet acceptable statistical sampling standards?. Ohio Admin. Code ? 5101:9-7-20(A) states, in part: ?income maintenance random moment sample (IMRMS), workforce random moment sample (WFRMS), social services random moment sample (SSRMS), and child welfare random moment sample (CWRMS) time studies are designed to measure activity regarding various programs. The child support random moment sample (CSRMS) is described in rule 5101:9-7-23 of the Administrative Code. Data collected from these time studies are used to calculate allocation statistics used to distribute cost pool expenditures to the appropriate programs. The percentages are used by the county family services agencies (CFSA) and Workforce Innovation and Opportunity Act (WIOA) local areas to distribute administrative funds reported in accordance with rule 5101:9-7-29 of the Administrative Code.? Ohio Admin. Code ? 5101:9-7-20(E)(2bii) states ?the employee shall ensure that adequate backup documentation is available to verify the activity being performed.? The Ohio Department of Job and Family Services (ODJFS) also added the following in the "RMS Frequently Asked Questions" in which they suggested that agencies have the caseworker make notes in SETS, CRISe, SACWIS, or other case management systems to further support the hit and/or make references to lead to the source documentation, (i.e. paper files, calendars, phone logs, etc.) for period under audit. Ohio Admin. Code ? 5101:9-7-20(E)(3) states ?an employee receiving an observation moment will have 48 hours to respond, not including weekends or holidays.? The Ohio Department of Job and Family Services (ODJFS) also added the following in the "RMS Frequently Asked Questions." "the RMS Coordinator is only authorized to complete an observation on a participant's behalf if the employee is unable to complete the observation within 48 hours. The moments are still due within 48 hours." Ohio Admin. Code ?? 5101:9-7-20(F)(3) and 5101:9-7-23(F)(3) state that ?in accordance with federally accepted timelines, the RMS/CSRMS coordinator shall review and approve by accepting all observation moment responses within seventy-two hours.? Ohio Admin. Code ?? 5101:9-7-20(H) and 5101:9-7-23(H) state that "[to] assure sampling accuracy and quality control, for each sampling period, ten percent of all IMRMS, WFRMS, SSRMS, CWRMS, and CSRMS observations are systematically selected from the total RMS observations, and are known as control observations. Supervisors must validate at least forty percent of the control observations for each sampling period [supervisors] shall have sufficient knowledge of the programs and activities performed by the employee(s) to determine the accuracy of the response. The supervisor shall be responsible for validation of responses within the same forty-eight-hour response period that is available to the employee. By approving the response, the supervisor is verifying that the appropriate program and activity was selected. After the supervisor approves the response, the RMS/ CSRMS coordinator will accept the response within seventy-two hours." Due to the lack of controls over the validation process, the following errors in the test of 45 transactions from the Jobs and Family Services cost pools for Income Maintenance, Social Services and the Child Support were noted: ? One instance was noted in which a Social Services (SS) employee observation moment was not responded to (completed) directly or by the RMS Coordinator, on behalf of the employee. ? Four instances in which the Social Services (SS) employee?s respective supervisor did not validate the observation moment response. ? Five instances in which the Income Maintenance (IM) employee?s respective supervisor did not validate the observation moment response. ? Five instances in which an Income Maintenance (IM) employee did not provide documentation to substantiate the claimed program and / or activity on the RMS Sample Form. ? One instance in which the Income Maintenance (IM) RMS coordinator did not review and approve by accepting the observation moment response within seventy-two hours. ? One instance in which the Child Support (CS) RMS coordinator did not review and approve by accepting the observation moment response within seventy-two hours. RMS Employee response (completion) of observation moment within forty-eight hours is required in order to identify the time and effort spent on federal program related activities. Documentation required from the RMS Employee is needed to substantiate the claimed program and/or activity on the RMS Sample Form. Supervisor validation within forty-eight hours is required to verify that the appropriate program and activity was selected by the employee, and if needed, make any corrections in a timely manner. RMS coordinator approval within seventy-two hours is required to ensure the workers are accurately coding the sample, and if needed, make any corrections in a timely manner. RMS responses, validations and/or approvals outside of the required time frames resulted in non-compliance and may affect future funding. The County Department of Health and Human Services should develop procedures to ensure that employees, supervisors and RMS coordinators perform the appropriate random moment sampling procedure(s) within the required time frame and ensure the existence of adequate documentation to substantiate the claimed program and/or activity on the RMS Sample Form.
Show full finding ▾Hide full finding ▴SNAP, TANF, Medicaid, SSBG, CCDBG, Child Support Enforcement, Adoption Assistance and Foster Care - Random Moment Sampling Weaknesses See Schedule of Findings and Questioned Costs for table in place of the table within the text. Material Weakness and Noncompliance 2 CFR ? 200.400.1 gives regulatory effect to the Department of Agriculture for 2 CFR ? 200.416(a) and 2 CFR ? 200.430(i)(5). 2 CFR ? 200.416(a) state?s program costs must be ?identified and assigned to the benefitted activities on a reasonable and consistent basis.? Additionally, 2 CFR ? 200.430(i)(5) indicates random moment sampling (RMS) may be used to allocate salaries and wages to a Federal award, but such systems must ?meet acceptable statistical sampling standards?. 45 CFR ? 75.416(a) state?s program costs must be ?identified and assigned to the benefitted activities on a reasonable and consistent basis.? Additionally, 45 CFR ? 75.430(i)(5) indicates random moment sampling (RMS) may be used to allocate salaries and wages to a Federal award, but such systems must ?meet acceptable statistical sampling standards?. Ohio Admin. Code ? 5101:9-7-20(A) states, in part: ?income maintenance random moment sample (IMRMS), workforce random moment sample (WFRMS), social services random moment sample (SSRMS), and child welfare random moment sample (CWRMS) time studies are designed to measure activity regarding various programs. The child support random moment sample (CSRMS) is described in rule 5101:9-7-23 of the Administrative Code. Data collected from these time studies are used to calculate allocation statistics used to distribute cost pool expenditures to the appropriate programs. The percentages are used by the county family services agencies (CFSA) and Workforce Innovation and Opportunity Act (WIOA) local areas to distribute administrative funds reported in accordance with rule 5101:9-7-29 of the Administrative Code.? Ohio Admin. Code ? 5101:9-7-20(E)(2bii) states ?the employee shall ensure that adequate backup documentation is available to verify the activity being performed.? The Ohio Department of Job and Family Services (ODJFS) also added the following in the "RMS Frequently Asked Questions" in which they suggested that agencies have the caseworker make notes in SETS, CRISe, SACWIS, or other case management systems to further support the hit and/or make references to lead to the source documentation, (i.e. paper files, calendars, phone logs, etc.) for period under audit. Ohio Admin. Code ? 5101:9-7-20(E)(3) states ?an employee receiving an observation moment will have 48 hours to respond, not including weekends or holidays.? The Ohio Department of Job and Family Services (ODJFS) also added the following in the "RMS Frequently Asked Questions." "the RMS Coordinator is only authorized to complete an observation on a participant's behalf if the employee is unable to complete the observation within 48 hours. The moments are still due within 48 hours." Ohio Admin. Code ?? 5101:9-7-20(F)(3) and 5101:9-7-23(F)(3) state that ?in accordance with federally accepted timelines, the RMS/CSRMS coordinator shall review and approve by accepting all observation moment responses within seventy-two hours.? Ohio Admin. Code ?? 5101:9-7-20(H) and 5101:9-7-23(H) state that "[to] assure sampling accuracy and quality control, for each sampling period, ten percent of all IMRMS, WFRMS, SSRMS, CWRMS, and CSRMS observations are systematically selected from the total RMS observations, and are known as control observations. Supervisors must validate at least forty percent of the control observations for each sampling period [supervisors] shall have sufficient knowledge of the programs and activities performed by the employee(s) to determine the accuracy of the response. The supervisor shall be responsible for validation of responses within the same forty-eight-hour response period that is available to the employee. By approving the response, the supervisor is verifying that the appropriate program and activity was selected. After the supervisor approves the response, the RMS/ CSRMS coordinator will accept the response within seventy-two hours." Due to the lack of controls over the validation process, the following errors in the test of 45 transactions from the Jobs and Family Services cost pools for Income Maintenance, Social Services and the Child Support were noted: ? One instance was noted in which a Social Services (SS) employee observation moment was not responded to (completed) directly or by the RMS Coordinator, on behalf of the employee. ? Four instances in which the Social Services (SS) employee?s respective supervisor did not validate the observation moment response. ? Five instances in which the Income Maintenance (IM) employee?s respective supervisor did not validate the observation moment response. ? Five instances in which an Income Maintenance (IM) employee did not provide documentation to substantiate the claimed program and / or activity on the RMS Sample Form. ? One instance in which the Income Maintenance (IM) RMS coordinator did not review and approve by accepting the observation moment response within seventy-two hours. ? One instance in which the Child Support (CS) RMS coordinator did not review and approve by accepting the observation moment response within seventy-two hours. RMS Employee response (completion) of observation moment within forty-eight hours is required in order to identify the time and effort spent on federal program related activities. Documentation required from the RMS Employee is needed to substantiate the claimed program and/or activity on the RMS Sample Form. Supervisor validation within forty-eight hours is required to verify that the appropriate program and activity was selected by the employee, and if needed, make any corrections in a timely manner. RMS coordinator approval within seventy-two hours is required to ensure the workers are accurately coding the sample, and if needed, make any corrections in a timely manner. RMS responses, validations and/or approvals outside of the required time frames resulted in non-compliance and may affect future funding. The County Department of Health and Human Services should develop procedures to ensure that employees, supervisors and RMS coordinators perform the appropriate random moment sampling procedure(s) within the required time frame and ensure the existence of adequate documentation to substantiate the claimed program and/or activity on the RMS Sample Form.
The new RMS timeframes that became effective in 2020 now allows 48 hours to validate RMS, as opposed to the 24-hour timeframe prior to 2020. This new timeframe should enable employees, supervisors, supervisor designees, and RMS coordinators the time to perform the appropriate procedures within the required timeframe. If a validation is discovered after the RMS moment goes out, HHS now has the ability to change the participant sample file to a substitute supervisor to complete the validation. The additional time to complete should allow additional time to make the necessary changes to ascertain the validation is completed within the 48-hour timeframe. HHS will continue to strive to meet the 48-hour timeframe. Anticipated Completion Date: 12/31/2021. Responsible Contact Person: Kathy Starks
2019-003
Opioid Targeted Response- Procurement, Suspension, and Debarment See Schedule of Findings and Questioned Costs for table in place of the table within the text. Material Weakness and Noncompliance 2 CFR ? 376.10 gives regulatory effect to the Department of Health and Human Services for 2 CFR ? 180.305 which provides that grant recipients are prohibited from entering into covered transactions with excluded persons unless the Federal agency responsible for the transaction grants an exception under 2 CFR ? 180.135. 2 CFR ? 180.200 defines a ?covered transactions? as a nonprocurement or procurement transaction that is subject to the prohibitions of 2 CFR Part 180. It may be a transaction at the primary tier, between a Federal agency and a person; or at the lower tier, between a participant in a covered transaction and another person. 2 CFR ? 180.220 provides that contracts for goods and services awarded under a nonprocurement transaction are covered transactions if the amount of the contract is expected to equal or exceed $25,000 or meet certain other specified criteria outlined in 2 CFR ? 180.220. 2 CFR ? 180.210 provides that all nonprocurement transactions (including subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless listed in the exemptions in 2 CFR ? 180.215. 2 CFR ? 180.300 requires that when a grant recipient enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity is not excluded or disqualified. This verification may be accomplished by checking SAM exclusions on www.sam.gov, collecting a certification from the entity, or adding a clause or condition to the covered transactions with that entity. The County Alcohol, Drug Addiction and Mental Health Services Board (ADAMHS) Board did not have the proper internal controls in place to verify that all entities, with whom the ADAMHS Board had entered into covered transactions had not been excluded or disqualified. For four out of four subrecipient contracts tested (100%), entered into using the Opioid Targeted State Response Grant, the ADAMHS Board entered a contract with a subrecipient of more than $25,000 and there was no evidence the ADAMHS Board checked the SAM exclusions, collected a certification from the entity, or added a clause or condition to the covered transaction with the vendor. Failure to have the appropriate controls in place over covered transaction may result in a suspended or debarred vendor receiving federal funds Prior to contracting with vendors that will be paid with federal funds, the ADAMHS Board should verify the vendor is not suspended or debarred, by checking the SAM exclusions, collecting a certification from the vendor, or adding a clause or condition to the covered transaction with the vendor.
Show full finding ▾Hide full finding ▴Opioid Targeted Response- Procurement, Suspension, and Debarment See Schedule of Findings and Questioned Costs for table in place of the table within the text. Material Weakness and Noncompliance 2 CFR ? 376.10 gives regulatory effect to the Department of Health and Human Services for 2 CFR ? 180.305 which provides that grant recipients are prohibited from entering into covered transactions with excluded persons unless the Federal agency responsible for the transaction grants an exception under 2 CFR ? 180.135. 2 CFR ? 180.200 defines a ?covered transactions? as a nonprocurement or procurement transaction that is subject to the prohibitions of 2 CFR Part 180. It may be a transaction at the primary tier, between a Federal agency and a person; or at the lower tier, between a participant in a covered transaction and another person. 2 CFR ? 180.220 provides that contracts for goods and services awarded under a nonprocurement transaction are covered transactions if the amount of the contract is expected to equal or exceed $25,000 or meet certain other specified criteria outlined in 2 CFR ? 180.220. 2 CFR ? 180.210 provides that all nonprocurement transactions (including subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless listed in the exemptions in 2 CFR ? 180.215. 2 CFR ? 180.300 requires that when a grant recipient enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity is not excluded or disqualified. This verification may be accomplished by checking SAM exclusions on www.sam.gov, collecting a certification from the entity, or adding a clause or condition to the covered transactions with that entity. The County Alcohol, Drug Addiction and Mental Health Services Board (ADAMHS) Board did not have the proper internal controls in place to verify that all entities, with whom the ADAMHS Board had entered into covered transactions had not been excluded or disqualified. For four out of four subrecipient contracts tested (100%), entered into using the Opioid Targeted State Response Grant, the ADAMHS Board entered a contract with a subrecipient of more than $25,000 and there was no evidence the ADAMHS Board checked the SAM exclusions, collected a certification from the entity, or added a clause or condition to the covered transaction with the vendor. Failure to have the appropriate controls in place over covered transaction may result in a suspended or debarred vendor receiving federal funds Prior to contracting with vendors that will be paid with federal funds, the ADAMHS Board should verify the vendor is not suspended or debarred, by checking the SAM exclusions, collecting a certification from the vendor, or adding a clause or condition to the covered transaction with the vendor.
Prior to contracting with vendors that will be paid with federal funds, the Alcohol, Drug Addiction and Mental Health Services Board (ADAMHS) Board, will verify that vendors are not suspended or debarred, by checking the SAM exclusions, collecting a certification from the vendor, or adding a clause or condition to the covered transaction with the vendor Anticipated Completion Date: 12/31/2021 Responsible Contact Person: Felicia Harrison
Social Services Block Grant - Review of Audit Report See Schedule of Findings and Questioned Costs for table in place of the table within the text. Material Weakness and Noncompliance 45 CFR ? 75.501 states that a non-federal entity that expends $750,000 or more during the non-federal entity's fiscal year in federal awards must have a single or program-specific audit conducted for that year in accordance with the provisions of this part. 45 CFR ? 75.352 states, all pass-through entities must monitor the activities of the subrecipient as necessary. Pass-through entity monitoring of the subrecipient must include in part, following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and other means. The agreement between the County's Alcohol, Drug Addiction and Mental Health Services (ADAMHS) Board and Northcoast Behavioral Healthcare states that the provider shall provide audited financial reports within six months after end of fiscal year. The County Alcohol, Drug Addiction and Mental Health Services Board (ADAMHS) Board did not have proper internal controls in place to ensure subrecipient monitoring was properly performed. The ADAMHS Board did not receive audited financial statements for Northcoast Behaviorial Healthcare, a subrecipient that expended more than the $750,000, and therefore did not review for any timely and appropriate action on deficiencies pertaining to the Social Services Block Grant (SSBG) award provided to the subrecipient. This weakness resulted in inadequate subrecipient monitoring. Further, control and compliance deficiencies could remain uncorrected or not corrected in a timely manner. The ADAMHS Board should implement controls to verify they receive audited financial reports from subrecipients with Federal expenditures greater than $750,000 during the fiscal year, and review the report for timely and appropriate action on all deficiencies pertaining to the Social Services Block Grant (SSBG) award.
Show full finding ▾Hide full finding ▴Social Services Block Grant - Review of Audit Report See Schedule of Findings and Questioned Costs for table in place of the table within the text. Material Weakness and Noncompliance 45 CFR ? 75.501 states that a non-federal entity that expends $750,000 or more during the non-federal entity's fiscal year in federal awards must have a single or program-specific audit conducted for that year in accordance with the provisions of this part. 45 CFR ? 75.352 states, all pass-through entities must monitor the activities of the subrecipient as necessary. Pass-through entity monitoring of the subrecipient must include in part, following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and other means. The agreement between the County's Alcohol, Drug Addiction and Mental Health Services (ADAMHS) Board and Northcoast Behavioral Healthcare states that the provider shall provide audited financial reports within six months after end of fiscal year. The County Alcohol, Drug Addiction and Mental Health Services Board (ADAMHS) Board did not have proper internal controls in place to ensure subrecipient monitoring was properly performed. The ADAMHS Board did not receive audited financial statements for Northcoast Behaviorial Healthcare, a subrecipient that expended more than the $750,000, and therefore did not review for any timely and appropriate action on deficiencies pertaining to the Social Services Block Grant (SSBG) award provided to the subrecipient. This weakness resulted in inadequate subrecipient monitoring. Further, control and compliance deficiencies could remain uncorrected or not corrected in a timely manner. The ADAMHS Board should implement controls to verify they receive audited financial reports from subrecipients with Federal expenditures greater than $750,000 during the fiscal year, and review the report for timely and appropriate action on all deficiencies pertaining to the Social Services Block Grant (SSBG) award.
The Alcohol, Drug Addiction and Mental Health Services Board (ADAMHS) Board, will ensure that they receive audited financial reports from subrecipients, who expenditures are more than $750,000 during the fiscal year, and review the reports for timely and appropriate action on all deficiencies pertaining to the Social Services Block Grant (Title XX) award. Anticipated Completion Date: 12/31/2021 Responsible Contact Person: Felicia Harrison
SNAP, TANF, Medicaid, SSBG, CCDBG, Child Support Enforcement, Adoption Assistance and Foster Care- Lack of Evidence of Review/Approval of Federal Expenditures See Schedule of Findings and Questioned Costs for table in place of the table within the text. Material Weakness All expenditures charged to Federal Grants should be reviewed and approved by administrators or managerial personnel knowledgeable about the respective Federal Grant regulations. Evidence of these approvals (Electronic or Manual) on the payment vouchers and/or invoices are necessary in order to acknowledge that the expenditures are allowable, per specific grant regulations, and are compliant with Uniform Guidance requirements contained in Subpart E of 2 CFR part 200 and Subpart E of 45 CFR 75. In addition, in regards to Federal Programs that pass-through the Ohio Department of Job and Family Services (ODJFS), the accuracy of the Accounting Units charged is important for CFIS Web reporting purposes since there are four different cost pools that can be charged: Shared Cost (010), Income Maintenance (020), Social Services (030), and CSEA. Accounting Units, combined with other cost codes, are mapped to specific cost pools in CFIS Web. The expenditures pooled in the cost pools are then charged to certain Federal Programs, by Random Moment Sampling (RMS), based upon which cost pool they are reported under. Due to a lack of internal controls over the review of expenditures, a test of 40 voucher expenditures charged to Shared Cost (010), Income Maintenance (020), Social Services (030), and CSEA cost pools disclosed two instances (5%) in which the non-payroll expenditures had no evidence of review and approval by County Department of Health and Human Services (HHS) federal grant administrators or managerial personnel knowledgeable about the respective Federal Grant regulations. The two instances (errors) included Information Technology expenditures processed by the County Department of Information Technology which lacked any evidence of approval by knowledgeable HHS federal grant administrators or managerial personnel. In addition, for four of six (67%) tested County departmental charge backs there was no evidence of approvals by HHS grant administrators for copier / printing services and vehicle mileage charges charged to the CFIS Web cost pools. These weaknesses could result in unallowable expenditures being charged to the SNAP, TANF, Medicaid, SSBG, Child Care and Development Block Grant, Child Support Enforcement, Foster Care, and Adoption Assistance Federal Programs operated by the Department of HHS. Formal procedures should be developed and implemented to require the approval of Department of HHS federal grant expenditures. Procedures should include how approvals by management or administrators are documented for each expenditure and the approvals should be done by personnel knowledgeable about the federal program. In addition, the Department of HHS should request sufficient supporting interdepartmental charge back documentation from the Department of Public Works for copier / printing services and vehicle mileage billings.
Show full finding ▾Hide full finding ▴SNAP, TANF, Medicaid, SSBG, CCDBG, Child Support Enforcement, Adoption Assistance and Foster Care- Lack of Evidence of Review/Approval of Federal Expenditures See Schedule of Findings and Questioned Costs for table in place of the table within the text. Material Weakness All expenditures charged to Federal Grants should be reviewed and approved by administrators or managerial personnel knowledgeable about the respective Federal Grant regulations. Evidence of these approvals (Electronic or Manual) on the payment vouchers and/or invoices are necessary in order to acknowledge that the expenditures are allowable, per specific grant regulations, and are compliant with Uniform Guidance requirements contained in Subpart E of 2 CFR part 200 and Subpart E of 45 CFR 75. In addition, in regards to Federal Programs that pass-through the Ohio Department of Job and Family Services (ODJFS), the accuracy of the Accounting Units charged is important for CFIS Web reporting purposes since there are four different cost pools that can be charged: Shared Cost (010), Income Maintenance (020), Social Services (030), and CSEA. Accounting Units, combined with other cost codes, are mapped to specific cost pools in CFIS Web. The expenditures pooled in the cost pools are then charged to certain Federal Programs, by Random Moment Sampling (RMS), based upon which cost pool they are reported under. Due to a lack of internal controls over the review of expenditures, a test of 40 voucher expenditures charged to Shared Cost (010), Income Maintenance (020), Social Services (030), and CSEA cost pools disclosed two instances (5%) in which the non-payroll expenditures had no evidence of review and approval by County Department of Health and Human Services (HHS) federal grant administrators or managerial personnel knowledgeable about the respective Federal Grant regulations. The two instances (errors) included Information Technology expenditures processed by the County Department of Information Technology which lacked any evidence of approval by knowledgeable HHS federal grant administrators or managerial personnel. In addition, for four of six (67%) tested County departmental charge backs there was no evidence of approvals by HHS grant administrators for copier / printing services and vehicle mileage charges charged to the CFIS Web cost pools. These weaknesses could result in unallowable expenditures being charged to the SNAP, TANF, Medicaid, SSBG, Child Care and Development Block Grant, Child Support Enforcement, Foster Care, and Adoption Assistance Federal Programs operated by the Department of HHS. Formal procedures should be developed and implemented to require the approval of Department of HHS federal grant expenditures. Procedures should include how approvals by management or administrators are documented for each expenditure and the approvals should be done by personnel knowledgeable about the federal program. In addition, the Department of HHS should request sufficient supporting interdepartmental charge back documentation from the Department of Public Works for copier / printing services and vehicle mileage billings.
The Department of Information Technology and the Department of Public Works will provide copies of chargeback amounts to the various departments that are receiving charges at the beginning of the year, including HHS. HHS won't need to provide written approval to the originator but will instead be responsible for comparing the chargeback amounts provided to the actual amounts posting to their expense accounts. Anticipated Completion Date: 12/31/2021 Responsible Contact Person: Kathy Starks
2019-007
Child Support Enforcement- Lack of Evidence of Review/Approval of Direct Federal Expenditures See Schedule of Findings and Questioned Costs for table in place of the table within the text. Material Weakness All expenditures charged to Federal Grants should be reviewed and approved by administrators or managerial personnel knowledgeable about the respective Federal Grant regulations. Evidence of these approvals (Electronic or Manual) on the payment vouchers, invoices, and/or chargebacks are necessary in order to acknowledge that the expenditures are allowable, per specific grant regulations, and are compliant with Uniform Guidance requirements contained in Subpart E of 45 CFR 75. Due to the lack of controls over the review process of federal expenditures, two of the four chargeback expenditures tested, for vehicle mileage chargebacks were processed / approved by the County Department of Public Works but not approved by County Department of Health and Human Services (HHS) - Office of Child Support federal grant administrators or managerial personnel knowledgeable about the Federal Program. This weaknesses could result in unallowable expenditures being charged to the Child Support Enforcement Federal Program operated by the Department of HHS. Formal procedures should be developed and implemented to require review and approval of Department of HHS federal grant expenditures. Procedures should include how approvals by management or administrators are documented for chargeback expenditures and the approvals should be done by personnel knowledgeable about the Federal Program.
Show full finding ▾Hide full finding ▴Child Support Enforcement- Lack of Evidence of Review/Approval of Direct Federal Expenditures See Schedule of Findings and Questioned Costs for table in place of the table within the text. Material Weakness All expenditures charged to Federal Grants should be reviewed and approved by administrators or managerial personnel knowledgeable about the respective Federal Grant regulations. Evidence of these approvals (Electronic or Manual) on the payment vouchers, invoices, and/or chargebacks are necessary in order to acknowledge that the expenditures are allowable, per specific grant regulations, and are compliant with Uniform Guidance requirements contained in Subpart E of 45 CFR 75. Due to the lack of controls over the review process of federal expenditures, two of the four chargeback expenditures tested, for vehicle mileage chargebacks were processed / approved by the County Department of Public Works but not approved by County Department of Health and Human Services (HHS) - Office of Child Support federal grant administrators or managerial personnel knowledgeable about the Federal Program. This weaknesses could result in unallowable expenditures being charged to the Child Support Enforcement Federal Program operated by the Department of HHS. Formal procedures should be developed and implemented to require review and approval of Department of HHS federal grant expenditures. Procedures should include how approvals by management or administrators are documented for chargeback expenditures and the approvals should be done by personnel knowledgeable about the Federal Program.
The Department of Public Works will provide copies of chargeback amounts to the various departments that are receiving charges at the beginning of the year, including HHS. HHS won't need to provide written approval to the originator but will instead be responsible for comparing the chargeback amounts provided to the actual amounts posting to their expense accounts. Anticipated Completion Date: 12/31/2021 Responsible Contact Person: Kathy Starks
2019-007
Workforce Innovation and Opportunity Act (WIOA) - Eligibility Support See Schedule of Findings and Questioned Costs for table in place of the table within the text. Material Weakness Workforce Innovation and Opportunity Act Policy Letter No. 15-07.2 Part VI. states in part, ? Workforce service providers (WSPs) Local areas, career service providers, youth program providers, and CCMEP lead agencies must verify or confirm eligibility requirements through an examination of documents or by using one or more of the additional methods of source documentation. Documentation requirements to support Workforce Innovation and Opportunity Act (WIOA) adult and dislocated worker eligibility are tied to the level of service provided to the participant. For adults and dislocated workers receiving only basic career services which do not trigger participation in the WIOA program, the local area may accept information provided by these reportable individuals at face value to complete the basic intake process without requiring source documentation. Documentation requirements increase for participants who receive basic career services triggering participation, individualized career services or training services. Workforce Innovation and Opportunity Act Policy Letter No. 15-07.2 provides examples of source documentation for each of the programs offered. Due to the lack of proper controls over eligibility documentation requirements, of the 40 WIOA participants tested for eligibility requirements, the following errors due to the lack of required eligibility documentation were identified. ? Four of the youth participants did not have their individual opportunity plan ? Three of the four youth participants noted above did not have proper documentation of age, citizenship, selective service registration, or school status participation. Lack of supporting documentation could lead to the County providing ineligible persons benefits and eventually loss of federal funds. The County should maintain all source documentation used in determination of Workforce Innovation and Opportunity Act eligibility requirements
Show full finding ▾Hide full finding ▴Workforce Innovation and Opportunity Act (WIOA) - Eligibility Support See Schedule of Findings and Questioned Costs for table in place of the table within the text. Material Weakness Workforce Innovation and Opportunity Act Policy Letter No. 15-07.2 Part VI. states in part, ? Workforce service providers (WSPs) Local areas, career service providers, youth program providers, and CCMEP lead agencies must verify or confirm eligibility requirements through an examination of documents or by using one or more of the additional methods of source documentation. Documentation requirements to support Workforce Innovation and Opportunity Act (WIOA) adult and dislocated worker eligibility are tied to the level of service provided to the participant. For adults and dislocated workers receiving only basic career services which do not trigger participation in the WIOA program, the local area may accept information provided by these reportable individuals at face value to complete the basic intake process without requiring source documentation. Documentation requirements increase for participants who receive basic career services triggering participation, individualized career services or training services. Workforce Innovation and Opportunity Act Policy Letter No. 15-07.2 provides examples of source documentation for each of the programs offered. Due to the lack of proper controls over eligibility documentation requirements, of the 40 WIOA participants tested for eligibility requirements, the following errors due to the lack of required eligibility documentation were identified. ? Four of the youth participants did not have their individual opportunity plan ? Three of the four youth participants noted above did not have proper documentation of age, citizenship, selective service registration, or school status participation. Lack of supporting documentation could lead to the County providing ineligible persons benefits and eventually loss of federal funds. The County should maintain all source documentation used in determination of Workforce Innovation and Opportunity Act eligibility requirements
Workforce Innovation and Opportunity Act will maintain all source documentation used in the determination of Workforce Innovation and Opportunity Act eligibility requirements for each participant. Anticipated Completion Date: 12/31/2021 Responsible Contact Person: Norma Arasim
FAC accepted this audit on April 10, 2023 — management decision was due October 10, 2023.
SNAP, TANF, Medicaid, SSBG, CCDBG, Child Support Enforcement, Foster Care and Adoption Assistance - Costs Claimed to Incorrect Cost Pool See Schedule of Findings and Questioned Costs for table in place of the table within the text. Material Weakness and Noncompliance and Questioned Cost 2 CFR ? 200.400.1 gives regulatory effect to the Department of Agriculture for 2 CFR ? 200.405 (a) which states, in part: ?[a] cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.? 45 CFR ? 75.405(a) states, in part: ?[a] cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.? Ohio Admin. Code ? 5101:9-1-04(B) ?Shared administrative costs? states: ?(1) Shared administrative costs are incurred for a common purpose benefiting more than one major function and are not readily assignable to specific programs or cost pools. (2) In a county department of job and family services (CDJFS) or a combined agency, staff are identified with one or more programs and the information is imported to the Ohio department of job and family services (ODJFS) via the county finance information system (CFIS Web).? Ohio Admin. Code ? 5101:9-1-04(C) states the following: ?[a]dministrative costs associated with the major program area categories and ODJFS acknowledged CDJFS function or program cost category are grouped into cost pools. Cost pools are based on the program activity to which they relate. Expenditures reported through cost pools represent operating costs of the local agency. Administrative costs linked to direct casework activity are measured and allocated to various federal funding sources and programs through the random moment sample (RMS) time study.? Ohio Admin. Code ? 5101:9-1-04(C)(1)(a) defines ?Income Maintenance (IM) administrative costs? as ?costs that benefit one or more IM programs. The IM cost pool consists of costs relating to the administration of various IM programs and may include work activities under prevention, retention, and contingency (PRC), Ohio works first (OWF), or food assistance employment and training (FAET).? Ohio Admin. Code ? 5101:9-1-04(C)(2)(a) defines ?Social service (SS) administrative costs? as ?costs that benefit one or more SS programs. The SS cost pool consists of costs relating to the administration of various SS programs.? Ohio Admin. Code ? 5101:9-1-04(C)(4)(a) states "Child support (CS) administrative costs are all CS expenditures with the exception of direct Title IV-D or non-IV-D costs, shared costs, and countywide central service plan payments. The CS cost pool consists of costs relating to the administration of the CS program." Due to a lack of internal controls over cost charged to each pool, 46 expenditures totaling $519,165 disclosed four instances totaling $28,799, in which the non-payroll expenditures were charged to an improper cost pool in CFIS Web. These errors also resulted in questioned costs of $28,799. Failure to charge these costs to the appropriate cost pool resulted in the allocation of costs to non-benefiting programs, which subsequently resulted in the improper Federal reimbursement to these non-benefitting programs. The County Department of Health and Human Services (HHS) should implement procedures to evaluate expenditures to determine which program(s) they benefit in order to charge the associated costs to the appropriate indirect cost pool in CFIS Web. Costs which benefit one program area of the department, such as Income Maintenance should be claimed to the cost pool associated with that program area. Costs which benefit multiple program areas, such as Income Maintenance, Social Services, and Child Support should be claimed to the Shared Cost Pool. Additionally, HHS complete the necessary adjustment in CFIS Web to reclassify the aforementioned costs, and any similar ones, to the benefitting cost pool.
Show full finding ▾Hide full finding ▴SNAP, TANF, Medicaid, SSBG, CCDBG, Child Support Enforcement, Foster Care and Adoption Assistance - Costs Claimed to Incorrect Cost Pool See Schedule of Findings and Questioned Costs for table in place of the table within the text. Material Weakness and Noncompliance and Questioned Cost 2 CFR ? 200.400.1 gives regulatory effect to the Department of Agriculture for 2 CFR ? 200.405 (a) which states, in part: ?[a] cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.? 45 CFR ? 75.405(a) states, in part: ?[a] cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.? Ohio Admin. Code ? 5101:9-1-04(B) ?Shared administrative costs? states: ?(1) Shared administrative costs are incurred for a common purpose benefiting more than one major function and are not readily assignable to specific programs or cost pools. (2) In a county department of job and family services (CDJFS) or a combined agency, staff are identified with one or more programs and the information is imported to the Ohio department of job and family services (ODJFS) via the county finance information system (CFIS Web).? Ohio Admin. Code ? 5101:9-1-04(C) states the following: ?[a]dministrative costs associated with the major program area categories and ODJFS acknowledged CDJFS function or program cost category are grouped into cost pools. Cost pools are based on the program activity to which they relate. Expenditures reported through cost pools represent operating costs of the local agency. Administrative costs linked to direct casework activity are measured and allocated to various federal funding sources and programs through the random moment sample (RMS) time study.? Ohio Admin. Code ? 5101:9-1-04(C)(1)(a) defines ?Income Maintenance (IM) administrative costs? as ?costs that benefit one or more IM programs. The IM cost pool consists of costs relating to the administration of various IM programs and may include work activities under prevention, retention, and contingency (PRC), Ohio works first (OWF), or food assistance employment and training (FAET).? Ohio Admin. Code ? 5101:9-1-04(C)(2)(a) defines ?Social service (SS) administrative costs? as ?costs that benefit one or more SS programs. The SS cost pool consists of costs relating to the administration of various SS programs.? Ohio Admin. Code ? 5101:9-1-04(C)(4)(a) states "Child support (CS) administrative costs are all CS expenditures with the exception of direct Title IV-D or non-IV-D costs, shared costs, and countywide central service plan payments. The CS cost pool consists of costs relating to the administration of the CS program." Due to a lack of internal controls over cost charged to each pool, 46 expenditures totaling $519,165 disclosed four instances totaling $28,799, in which the non-payroll expenditures were charged to an improper cost pool in CFIS Web. These errors also resulted in questioned costs of $28,799. Failure to charge these costs to the appropriate cost pool resulted in the allocation of costs to non-benefiting programs, which subsequently resulted in the improper Federal reimbursement to these non-benefitting programs. The County Department of Health and Human Services (HHS) should implement procedures to evaluate expenditures to determine which program(s) they benefit in order to charge the associated costs to the appropriate indirect cost pool in CFIS Web. Costs which benefit one program area of the department, such as Income Maintenance should be claimed to the cost pool associated with that program area. Costs which benefit multiple program areas, such as Income Maintenance, Social Services, and Child Support should be claimed to the Shared Cost Pool. Additionally, HHS complete the necessary adjustment in CFIS Web to reclassify the aforementioned costs, and any similar ones, to the benefitting cost pool.
Health and Human Services (HHS) has implemented procedures to evaluate expenditures to determine which program(s) they benefit in order to charge the associated costs to the appropriate indirect cost pool, in CFIS Web. HHS put all new codes in CFIS and reviewed the mapping codes. Costs which benefit multiple program areas are claimed to the Shared Cost Pool. Anticipated Completion Date: 12/31/2021. Responsible Contact Person: Kathy Starks
2019-002
SNAP, TANF, Medicaid, SSBG, CCDBG, Child Support Enforcement, Adoption Assistance and Foster Care-Differences Between Cost Allocation Plan and Lawson Accounting System See Schedule of Findings and Questioned Costs for table in place of the table within the text. Material Weakness and Noncompliance and Questioned Cost 2 CFR ? 200.400.1 gives regulatory effect to the Department of Agriculture for 2 CFR 200 Appendix V A(1) which states in part: "All costs and other data used to distribute the costs included in the plan should be supported by formal accounting and other records that will support the propriety of the costs assigned to Federal awards." 45 CFR 75 Appendix V A(1) which states in part: "All costs and other data used to distribute the costs included in the plan should be supported by formal accounting and other records that will support the propriety of the costs assigned to Federal awards." 45 CFR Part 75 Appendix V G(3) and 2 CFR 200 Appendix V G(3) state in part: ?a carry-forward adjustment is not permitted, for a central service activity that was not included in the approved plan, or for unallowable costs that must be reimbursed immediately." Prior to the preparation and submission of the 2020 Cost Allocation Plan (CAP), the County utilized the 2019 CAP as an estimate to post indirect costs to the Lawson accounting system. In addition, the County posted 2019 CAP adjustments to the accounting system in 2020 instead of adding them to the 2020 CAP, as required. Further, the County never reconciled and adjusted the 2020 indirect cost postings to match the 2020 CAP. The differences between the 2020 Cost Allocation Plan (CAP) and the posting to Lawson are as follows: See Schedule of Findings and Questioned Costs for table in place of the table within the text. This internal control weakness resulted in questioned costs in excess of $25,000 for each of the federal programs denoted above, except the Social Services Block Grant and Child Care and Development Block Grant, which could affect future grant funding. The County should reconcile and adjust the 2020 indirect cost postings to match the 2020 CAP, prior to year-end. Further, any prior year CAP reconciling items need to be brought forward and included in the current CAP and not adjusted directly to the accounting system.
Show full finding ▾Hide full finding ▴SNAP, TANF, Medicaid, SSBG, CCDBG, Child Support Enforcement, Adoption Assistance and Foster Care-Differences Between Cost Allocation Plan and Lawson Accounting System See Schedule of Findings and Questioned Costs for table in place of the table within the text. Material Weakness and Noncompliance and Questioned Cost 2 CFR ? 200.400.1 gives regulatory effect to the Department of Agriculture for 2 CFR 200 Appendix V A(1) which states in part: "All costs and other data used to distribute the costs included in the plan should be supported by formal accounting and other records that will support the propriety of the costs assigned to Federal awards." 45 CFR 75 Appendix V A(1) which states in part: "All costs and other data used to distribute the costs included in the plan should be supported by formal accounting and other records that will support the propriety of the costs assigned to Federal awards." 45 CFR Part 75 Appendix V G(3) and 2 CFR 200 Appendix V G(3) state in part: ?a carry-forward adjustment is not permitted, for a central service activity that was not included in the approved plan, or for unallowable costs that must be reimbursed immediately." Prior to the preparation and submission of the 2020 Cost Allocation Plan (CAP), the County utilized the 2019 CAP as an estimate to post indirect costs to the Lawson accounting system. In addition, the County posted 2019 CAP adjustments to the accounting system in 2020 instead of adding them to the 2020 CAP, as required. Further, the County never reconciled and adjusted the 2020 indirect cost postings to match the 2020 CAP. The differences between the 2020 Cost Allocation Plan (CAP) and the posting to Lawson are as follows: See Schedule of Findings and Questioned Costs for table in place of the table within the text. This internal control weakness resulted in questioned costs in excess of $25,000 for each of the federal programs denoted above, except the Social Services Block Grant and Child Care and Development Block Grant, which could affect future grant funding. The County should reconcile and adjust the 2020 indirect cost postings to match the 2020 CAP, prior to year-end. Further, any prior year CAP reconciling items need to be brought forward and included in the current CAP and not adjusted directly to the accounting system.
Going forward the County will ensure that any prior year CAP adjustments are brought forward and added to the current Cost Allocation Plan and not adjusted directly to the accounting system. Anticipated Completion Date: 12/31/2021. Responsible Contact Person: Kathy Starks
2019-006
SNAP, TANF, Medicaid, SSBG, CCDBG, Child Support Enforcement, Adoption Assistance and Foster Care - Random Moment Sampling Weaknesses See Schedule of Findings and Questioned Costs for table in place of the table within the text. Material Weakness and Noncompliance 2 CFR ? 200.400.1 gives regulatory effect to the Department of Agriculture for 2 CFR ? 200.416(a) and 2 CFR ? 200.430(i)(5). 2 CFR ? 200.416(a) state?s program costs must be ?identified and assigned to the benefitted activities on a reasonable and consistent basis.? Additionally, 2 CFR ? 200.430(i)(5) indicates random moment sampling (RMS) may be used to allocate salaries and wages to a Federal award, but such systems must ?meet acceptable statistical sampling standards?. 45 CFR ? 75.416(a) state?s program costs must be ?identified and assigned to the benefitted activities on a reasonable and consistent basis.? Additionally, 45 CFR ? 75.430(i)(5) indicates random moment sampling (RMS) may be used to allocate salaries and wages to a Federal award, but such systems must ?meet acceptable statistical sampling standards?. Ohio Admin. Code ? 5101:9-7-20(A) states, in part: ?income maintenance random moment sample (IMRMS), workforce random moment sample (WFRMS), social services random moment sample (SSRMS), and child welfare random moment sample (CWRMS) time studies are designed to measure activity regarding various programs. The child support random moment sample (CSRMS) is described in rule 5101:9-7-23 of the Administrative Code. Data collected from these time studies are used to calculate allocation statistics used to distribute cost pool expenditures to the appropriate programs. The percentages are used by the county family services agencies (CFSA) and Workforce Innovation and Opportunity Act (WIOA) local areas to distribute administrative funds reported in accordance with rule 5101:9-7-29 of the Administrative Code.? Ohio Admin. Code ? 5101:9-7-20(E)(2bii) states ?the employee shall ensure that adequate backup documentation is available to verify the activity being performed.? The Ohio Department of Job and Family Services (ODJFS) also added the following in the "RMS Frequently Asked Questions" in which they suggested that agencies have the caseworker make notes in SETS, CRISe, SACWIS, or other case management systems to further support the hit and/or make references to lead to the source documentation, (i.e. paper files, calendars, phone logs, etc.) for period under audit. Ohio Admin. Code ? 5101:9-7-20(E)(3) states ?an employee receiving an observation moment will have 48 hours to respond, not including weekends or holidays.? The Ohio Department of Job and Family Services (ODJFS) also added the following in the "RMS Frequently Asked Questions." "the RMS Coordinator is only authorized to complete an observation on a participant's behalf if the employee is unable to complete the observation within 48 hours. The moments are still due within 48 hours." Ohio Admin. Code ?? 5101:9-7-20(F)(3) and 5101:9-7-23(F)(3) state that ?in accordance with federally accepted timelines, the RMS/CSRMS coordinator shall review and approve by accepting all observation moment responses within seventy-two hours.? Ohio Admin. Code ?? 5101:9-7-20(H) and 5101:9-7-23(H) state that "[to] assure sampling accuracy and quality control, for each sampling period, ten percent of all IMRMS, WFRMS, SSRMS, CWRMS, and CSRMS observations are systematically selected from the total RMS observations, and are known as control observations. Supervisors must validate at least forty percent of the control observations for each sampling period [supervisors] shall have sufficient knowledge of the programs and activities performed by the employee(s) to determine the accuracy of the response. The supervisor shall be responsible for validation of responses within the same forty-eight-hour response period that is available to the employee. By approving the response, the supervisor is verifying that the appropriate program and activity was selected. After the supervisor approves the response, the RMS/ CSRMS coordinator will accept the response within seventy-two hours." Due to the lack of controls over the validation process, the following errors in the test of 45 transactions from the Jobs and Family Services cost pools for Income Maintenance, Social Services and the Child Support were noted: ? One instance was noted in which a Social Services (SS) employee observation moment was not responded to (completed) directly or by the RMS Coordinator, on behalf of the employee. ? Four instances in which the Social Services (SS) employee?s respective supervisor did not validate the observation moment response. ? Five instances in which the Income Maintenance (IM) employee?s respective supervisor did not validate the observation moment response. ? Five instances in which an Income Maintenance (IM) employee did not provide documentation to substantiate the claimed program and / or activity on the RMS Sample Form. ? One instance in which the Income Maintenance (IM) RMS coordinator did not review and approve by accepting the observation moment response within seventy-two hours. ? One instance in which the Child Support (CS) RMS coordinator did not review and approve by accepting the observation moment response within seventy-two hours. RMS Employee response (completion) of observation moment within forty-eight hours is required in order to identify the time and effort spent on federal program related activities. Documentation required from the RMS Employee is needed to substantiate the claimed program and/or activity on the RMS Sample Form. Supervisor validation within forty-eight hours is required to verify that the appropriate program and activity was selected by the employee, and if needed, make any corrections in a timely manner. RMS coordinator approval within seventy-two hours is required to ensure the workers are accurately coding the sample, and if needed, make any corrections in a timely manner. RMS responses, validations and/or approvals outside of the required time frames resulted in non-compliance and may affect future funding. The County Department of Health and Human Services should develop procedures to ensure that employees, supervisors and RMS coordinators perform the appropriate random moment sampling procedure(s) within the required time frame and ensure the existence of adequate documentation to substantiate the claimed program and/or activity on the RMS Sample Form.
Show full finding ▾Hide full finding ▴SNAP, TANF, Medicaid, SSBG, CCDBG, Child Support Enforcement, Adoption Assistance and Foster Care - Random Moment Sampling Weaknesses See Schedule of Findings and Questioned Costs for table in place of the table within the text. Material Weakness and Noncompliance 2 CFR ? 200.400.1 gives regulatory effect to the Department of Agriculture for 2 CFR ? 200.416(a) and 2 CFR ? 200.430(i)(5). 2 CFR ? 200.416(a) state?s program costs must be ?identified and assigned to the benefitted activities on a reasonable and consistent basis.? Additionally, 2 CFR ? 200.430(i)(5) indicates random moment sampling (RMS) may be used to allocate salaries and wages to a Federal award, but such systems must ?meet acceptable statistical sampling standards?. 45 CFR ? 75.416(a) state?s program costs must be ?identified and assigned to the benefitted activities on a reasonable and consistent basis.? Additionally, 45 CFR ? 75.430(i)(5) indicates random moment sampling (RMS) may be used to allocate salaries and wages to a Federal award, but such systems must ?meet acceptable statistical sampling standards?. Ohio Admin. Code ? 5101:9-7-20(A) states, in part: ?income maintenance random moment sample (IMRMS), workforce random moment sample (WFRMS), social services random moment sample (SSRMS), and child welfare random moment sample (CWRMS) time studies are designed to measure activity regarding various programs. The child support random moment sample (CSRMS) is described in rule 5101:9-7-23 of the Administrative Code. Data collected from these time studies are used to calculate allocation statistics used to distribute cost pool expenditures to the appropriate programs. The percentages are used by the county family services agencies (CFSA) and Workforce Innovation and Opportunity Act (WIOA) local areas to distribute administrative funds reported in accordance with rule 5101:9-7-29 of the Administrative Code.? Ohio Admin. Code ? 5101:9-7-20(E)(2bii) states ?the employee shall ensure that adequate backup documentation is available to verify the activity being performed.? The Ohio Department of Job and Family Services (ODJFS) also added the following in the "RMS Frequently Asked Questions" in which they suggested that agencies have the caseworker make notes in SETS, CRISe, SACWIS, or other case management systems to further support the hit and/or make references to lead to the source documentation, (i.e. paper files, calendars, phone logs, etc.) for period under audit. Ohio Admin. Code ? 5101:9-7-20(E)(3) states ?an employee receiving an observation moment will have 48 hours to respond, not including weekends or holidays.? The Ohio Department of Job and Family Services (ODJFS) also added the following in the "RMS Frequently Asked Questions." "the RMS Coordinator is only authorized to complete an observation on a participant's behalf if the employee is unable to complete the observation within 48 hours. The moments are still due within 48 hours." Ohio Admin. Code ?? 5101:9-7-20(F)(3) and 5101:9-7-23(F)(3) state that ?in accordance with federally accepted timelines, the RMS/CSRMS coordinator shall review and approve by accepting all observation moment responses within seventy-two hours.? Ohio Admin. Code ?? 5101:9-7-20(H) and 5101:9-7-23(H) state that "[to] assure sampling accuracy and quality control, for each sampling period, ten percent of all IMRMS, WFRMS, SSRMS, CWRMS, and CSRMS observations are systematically selected from the total RMS observations, and are known as control observations. Supervisors must validate at least forty percent of the control observations for each sampling period [supervisors] shall have sufficient knowledge of the programs and activities performed by the employee(s) to determine the accuracy of the response. The supervisor shall be responsible for validation of responses within the same forty-eight-hour response period that is available to the employee. By approving the response, the supervisor is verifying that the appropriate program and activity was selected. After the supervisor approves the response, the RMS/ CSRMS coordinator will accept the response within seventy-two hours." Due to the lack of controls over the validation process, the following errors in the test of 45 transactions from the Jobs and Family Services cost pools for Income Maintenance, Social Services and the Child Support were noted: ? One instance was noted in which a Social Services (SS) employee observation moment was not responded to (completed) directly or by the RMS Coordinator, on behalf of the employee. ? Four instances in which the Social Services (SS) employee?s respective supervisor did not validate the observation moment response. ? Five instances in which the Income Maintenance (IM) employee?s respective supervisor did not validate the observation moment response. ? Five instances in which an Income Maintenance (IM) employee did not provide documentation to substantiate the claimed program and / or activity on the RMS Sample Form. ? One instance in which the Income Maintenance (IM) RMS coordinator did not review and approve by accepting the observation moment response within seventy-two hours. ? One instance in which the Child Support (CS) RMS coordinator did not review and approve by accepting the observation moment response within seventy-two hours. RMS Employee response (completion) of observation moment within forty-eight hours is required in order to identify the time and effort spent on federal program related activities. Documentation required from the RMS Employee is needed to substantiate the claimed program and/or activity on the RMS Sample Form. Supervisor validation within forty-eight hours is required to verify that the appropriate program and activity was selected by the employee, and if needed, make any corrections in a timely manner. RMS coordinator approval within seventy-two hours is required to ensure the workers are accurately coding the sample, and if needed, make any corrections in a timely manner. RMS responses, validations and/or approvals outside of the required time frames resulted in non-compliance and may affect future funding. The County Department of Health and Human Services should develop procedures to ensure that employees, supervisors and RMS coordinators perform the appropriate random moment sampling procedure(s) within the required time frame and ensure the existence of adequate documentation to substantiate the claimed program and/or activity on the RMS Sample Form.
The new RMS timeframes that became effective in 2020 now allows 48 hours to validate RMS, as opposed to the 24-hour timeframe prior to 2020. This new timeframe should enable employees, supervisors, supervisor designees, and RMS coordinators the time to perform the appropriate procedures within the required timeframe. If a validation is discovered after the RMS moment goes out, HHS now has the ability to change the participant sample file to a substitute supervisor to complete the validation. The additional time to complete should allow additional time to make the necessary changes to ascertain the validation is completed within the 48-hour timeframe. HHS will continue to strive to meet the 48-hour timeframe. Anticipated Completion Date: 12/31/2021. Responsible Contact Person: Kathy Starks
2019-003
Opioid Targeted Response- Procurement, Suspension, and Debarment See Schedule of Findings and Questioned Costs for table in place of the table within the text. Material Weakness and Noncompliance 2 CFR ? 376.10 gives regulatory effect to the Department of Health and Human Services for 2 CFR ? 180.305 which provides that grant recipients are prohibited from entering into covered transactions with excluded persons unless the Federal agency responsible for the transaction grants an exception under 2 CFR ? 180.135. 2 CFR ? 180.200 defines a ?covered transactions? as a nonprocurement or procurement transaction that is subject to the prohibitions of 2 CFR Part 180. It may be a transaction at the primary tier, between a Federal agency and a person; or at the lower tier, between a participant in a covered transaction and another person. 2 CFR ? 180.220 provides that contracts for goods and services awarded under a nonprocurement transaction are covered transactions if the amount of the contract is expected to equal or exceed $25,000 or meet certain other specified criteria outlined in 2 CFR ? 180.220. 2 CFR ? 180.210 provides that all nonprocurement transactions (including subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless listed in the exemptions in 2 CFR ? 180.215. 2 CFR ? 180.300 requires that when a grant recipient enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity is not excluded or disqualified. This verification may be accomplished by checking SAM exclusions on www.sam.gov, collecting a certification from the entity, or adding a clause or condition to the covered transactions with that entity. The County Alcohol, Drug Addiction and Mental Health Services Board (ADAMHS) Board did not have the proper internal controls in place to verify that all entities, with whom the ADAMHS Board had entered into covered transactions had not been excluded or disqualified. For four out of four subrecipient contracts tested (100%), entered into using the Opioid Targeted State Response Grant, the ADAMHS Board entered a contract with a subrecipient of more than $25,000 and there was no evidence the ADAMHS Board checked the SAM exclusions, collected a certification from the entity, or added a clause or condition to the covered transaction with the vendor. Failure to have the appropriate controls in place over covered transaction may result in a suspended or debarred vendor receiving federal funds Prior to contracting with vendors that will be paid with federal funds, the ADAMHS Board should verify the vendor is not suspended or debarred, by checking the SAM exclusions, collecting a certification from the vendor, or adding a clause or condition to the covered transaction with the vendor.
Show full finding ▾Hide full finding ▴Opioid Targeted Response- Procurement, Suspension, and Debarment See Schedule of Findings and Questioned Costs for table in place of the table within the text. Material Weakness and Noncompliance 2 CFR ? 376.10 gives regulatory effect to the Department of Health and Human Services for 2 CFR ? 180.305 which provides that grant recipients are prohibited from entering into covered transactions with excluded persons unless the Federal agency responsible for the transaction grants an exception under 2 CFR ? 180.135. 2 CFR ? 180.200 defines a ?covered transactions? as a nonprocurement or procurement transaction that is subject to the prohibitions of 2 CFR Part 180. It may be a transaction at the primary tier, between a Federal agency and a person; or at the lower tier, between a participant in a covered transaction and another person. 2 CFR ? 180.220 provides that contracts for goods and services awarded under a nonprocurement transaction are covered transactions if the amount of the contract is expected to equal or exceed $25,000 or meet certain other specified criteria outlined in 2 CFR ? 180.220. 2 CFR ? 180.210 provides that all nonprocurement transactions (including subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless listed in the exemptions in 2 CFR ? 180.215. 2 CFR ? 180.300 requires that when a grant recipient enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity is not excluded or disqualified. This verification may be accomplished by checking SAM exclusions on www.sam.gov, collecting a certification from the entity, or adding a clause or condition to the covered transactions with that entity. The County Alcohol, Drug Addiction and Mental Health Services Board (ADAMHS) Board did not have the proper internal controls in place to verify that all entities, with whom the ADAMHS Board had entered into covered transactions had not been excluded or disqualified. For four out of four subrecipient contracts tested (100%), entered into using the Opioid Targeted State Response Grant, the ADAMHS Board entered a contract with a subrecipient of more than $25,000 and there was no evidence the ADAMHS Board checked the SAM exclusions, collected a certification from the entity, or added a clause or condition to the covered transaction with the vendor. Failure to have the appropriate controls in place over covered transaction may result in a suspended or debarred vendor receiving federal funds Prior to contracting with vendors that will be paid with federal funds, the ADAMHS Board should verify the vendor is not suspended or debarred, by checking the SAM exclusions, collecting a certification from the vendor, or adding a clause or condition to the covered transaction with the vendor.
Prior to contracting with vendors that will be paid with federal funds, the Alcohol, Drug Addiction and Mental Health Services Board (ADAMHS) Board, will verify that vendors are not suspended or debarred, by checking the SAM exclusions, collecting a certification from the vendor, or adding a clause or condition to the covered transaction with the vendor Anticipated Completion Date: 12/31/2021 Responsible Contact Person: Felicia Harrison
Social Services Block Grant - Review of Audit Report See Schedule of Findings and Questioned Costs for table in place of the table within the text. Material Weakness and Noncompliance 45 CFR ? 75.501 states that a non-federal entity that expends $750,000 or more during the non-federal entity's fiscal year in federal awards must have a single or program-specific audit conducted for that year in accordance with the provisions of this part. 45 CFR ? 75.352 states, all pass-through entities must monitor the activities of the subrecipient as necessary. Pass-through entity monitoring of the subrecipient must include in part, following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and other means. The agreement between the County's Alcohol, Drug Addiction and Mental Health Services (ADAMHS) Board and Northcoast Behavioral Healthcare states that the provider shall provide audited financial reports within six months after end of fiscal year. The County Alcohol, Drug Addiction and Mental Health Services Board (ADAMHS) Board did not have proper internal controls in place to ensure subrecipient monitoring was properly performed. The ADAMHS Board did not receive audited financial statements for Northcoast Behaviorial Healthcare, a subrecipient that expended more than the $750,000, and therefore did not review for any timely and appropriate action on deficiencies pertaining to the Social Services Block Grant (SSBG) award provided to the subrecipient. This weakness resulted in inadequate subrecipient monitoring. Further, control and compliance deficiencies could remain uncorrected or not corrected in a timely manner. The ADAMHS Board should implement controls to verify they receive audited financial reports from subrecipients with Federal expenditures greater than $750,000 during the fiscal year, and review the report for timely and appropriate action on all deficiencies pertaining to the Social Services Block Grant (SSBG) award.
Show full finding ▾Hide full finding ▴Social Services Block Grant - Review of Audit Report See Schedule of Findings and Questioned Costs for table in place of the table within the text. Material Weakness and Noncompliance 45 CFR ? 75.501 states that a non-federal entity that expends $750,000 or more during the non-federal entity's fiscal year in federal awards must have a single or program-specific audit conducted for that year in accordance with the provisions of this part. 45 CFR ? 75.352 states, all pass-through entities must monitor the activities of the subrecipient as necessary. Pass-through entity monitoring of the subrecipient must include in part, following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and other means. The agreement between the County's Alcohol, Drug Addiction and Mental Health Services (ADAMHS) Board and Northcoast Behavioral Healthcare states that the provider shall provide audited financial reports within six months after end of fiscal year. The County Alcohol, Drug Addiction and Mental Health Services Board (ADAMHS) Board did not have proper internal controls in place to ensure subrecipient monitoring was properly performed. The ADAMHS Board did not receive audited financial statements for Northcoast Behaviorial Healthcare, a subrecipient that expended more than the $750,000, and therefore did not review for any timely and appropriate action on deficiencies pertaining to the Social Services Block Grant (SSBG) award provided to the subrecipient. This weakness resulted in inadequate subrecipient monitoring. Further, control and compliance deficiencies could remain uncorrected or not corrected in a timely manner. The ADAMHS Board should implement controls to verify they receive audited financial reports from subrecipients with Federal expenditures greater than $750,000 during the fiscal year, and review the report for timely and appropriate action on all deficiencies pertaining to the Social Services Block Grant (SSBG) award.
The Alcohol, Drug Addiction and Mental Health Services Board (ADAMHS) Board, will ensure that they receive audited financial reports from subrecipients, who expenditures are more than $750,000 during the fiscal year, and review the reports for timely and appropriate action on all deficiencies pertaining to the Social Services Block Grant (Title XX) award. Anticipated Completion Date: 12/31/2021 Responsible Contact Person: Felicia Harrison
SNAP, TANF, Medicaid, SSBG, CCDBG, Child Support Enforcement, Adoption Assistance and Foster Care- Lack of Evidence of Review/Approval of Federal Expenditures See Schedule of Findings and Questioned Costs for table in place of the table within the text. Material Weakness All expenditures charged to Federal Grants should be reviewed and approved by administrators or managerial personnel knowledgeable about the respective Federal Grant regulations. Evidence of these approvals (Electronic or Manual) on the payment vouchers and/or invoices are necessary in order to acknowledge that the expenditures are allowable, per specific grant regulations, and are compliant with Uniform Guidance requirements contained in Subpart E of 2 CFR part 200 and Subpart E of 45 CFR 75. In addition, in regards to Federal Programs that pass-through the Ohio Department of Job and Family Services (ODJFS), the accuracy of the Accounting Units charged is important for CFIS Web reporting purposes since there are four different cost pools that can be charged: Shared Cost (010), Income Maintenance (020), Social Services (030), and CSEA. Accounting Units, combined with other cost codes, are mapped to specific cost pools in CFIS Web. The expenditures pooled in the cost pools are then charged to certain Federal Programs, by Random Moment Sampling (RMS), based upon which cost pool they are reported under. Due to a lack of internal controls over the review of expenditures, a test of 40 voucher expenditures charged to Shared Cost (010), Income Maintenance (020), Social Services (030), and CSEA cost pools disclosed two instances (5%) in which the non-payroll expenditures had no evidence of review and approval by County Department of Health and Human Services (HHS) federal grant administrators or managerial personnel knowledgeable about the respective Federal Grant regulations. The two instances (errors) included Information Technology expenditures processed by the County Department of Information Technology which lacked any evidence of approval by knowledgeable HHS federal grant administrators or managerial personnel. In addition, for four of six (67%) tested County departmental charge backs there was no evidence of approvals by HHS grant administrators for copier / printing services and vehicle mileage charges charged to the CFIS Web cost pools. These weaknesses could result in unallowable expenditures being charged to the SNAP, TANF, Medicaid, SSBG, Child Care and Development Block Grant, Child Support Enforcement, Foster Care, and Adoption Assistance Federal Programs operated by the Department of HHS. Formal procedures should be developed and implemented to require the approval of Department of HHS federal grant expenditures. Procedures should include how approvals by management or administrators are documented for each expenditure and the approvals should be done by personnel knowledgeable about the federal program. In addition, the Department of HHS should request sufficient supporting interdepartmental charge back documentation from the Department of Public Works for copier / printing services and vehicle mileage billings.
Show full finding ▾Hide full finding ▴SNAP, TANF, Medicaid, SSBG, CCDBG, Child Support Enforcement, Adoption Assistance and Foster Care- Lack of Evidence of Review/Approval of Federal Expenditures See Schedule of Findings and Questioned Costs for table in place of the table within the text. Material Weakness All expenditures charged to Federal Grants should be reviewed and approved by administrators or managerial personnel knowledgeable about the respective Federal Grant regulations. Evidence of these approvals (Electronic or Manual) on the payment vouchers and/or invoices are necessary in order to acknowledge that the expenditures are allowable, per specific grant regulations, and are compliant with Uniform Guidance requirements contained in Subpart E of 2 CFR part 200 and Subpart E of 45 CFR 75. In addition, in regards to Federal Programs that pass-through the Ohio Department of Job and Family Services (ODJFS), the accuracy of the Accounting Units charged is important for CFIS Web reporting purposes since there are four different cost pools that can be charged: Shared Cost (010), Income Maintenance (020), Social Services (030), and CSEA. Accounting Units, combined with other cost codes, are mapped to specific cost pools in CFIS Web. The expenditures pooled in the cost pools are then charged to certain Federal Programs, by Random Moment Sampling (RMS), based upon which cost pool they are reported under. Due to a lack of internal controls over the review of expenditures, a test of 40 voucher expenditures charged to Shared Cost (010), Income Maintenance (020), Social Services (030), and CSEA cost pools disclosed two instances (5%) in which the non-payroll expenditures had no evidence of review and approval by County Department of Health and Human Services (HHS) federal grant administrators or managerial personnel knowledgeable about the respective Federal Grant regulations. The two instances (errors) included Information Technology expenditures processed by the County Department of Information Technology which lacked any evidence of approval by knowledgeable HHS federal grant administrators or managerial personnel. In addition, for four of six (67%) tested County departmental charge backs there was no evidence of approvals by HHS grant administrators for copier / printing services and vehicle mileage charges charged to the CFIS Web cost pools. These weaknesses could result in unallowable expenditures being charged to the SNAP, TANF, Medicaid, SSBG, Child Care and Development Block Grant, Child Support Enforcement, Foster Care, and Adoption Assistance Federal Programs operated by the Department of HHS. Formal procedures should be developed and implemented to require the approval of Department of HHS federal grant expenditures. Procedures should include how approvals by management or administrators are documented for each expenditure and the approvals should be done by personnel knowledgeable about the federal program. In addition, the Department of HHS should request sufficient supporting interdepartmental charge back documentation from the Department of Public Works for copier / printing services and vehicle mileage billings.
The Department of Information Technology and the Department of Public Works will provide copies of chargeback amounts to the various departments that are receiving charges at the beginning of the year, including HHS. HHS won't need to provide written approval to the originator but will instead be responsible for comparing the chargeback amounts provided to the actual amounts posting to their expense accounts. Anticipated Completion Date: 12/31/2021 Responsible Contact Person: Kathy Starks
2019-007
Child Support Enforcement- Lack of Evidence of Review/Approval of Direct Federal Expenditures See Schedule of Findings and Questioned Costs for table in place of the table within the text. Material Weakness All expenditures charged to Federal Grants should be reviewed and approved by administrators or managerial personnel knowledgeable about the respective Federal Grant regulations. Evidence of these approvals (Electronic or Manual) on the payment vouchers, invoices, and/or chargebacks are necessary in order to acknowledge that the expenditures are allowable, per specific grant regulations, and are compliant with Uniform Guidance requirements contained in Subpart E of 45 CFR 75. Due to the lack of controls over the review process of federal expenditures, two of the four chargeback expenditures tested, for vehicle mileage chargebacks were processed / approved by the County Department of Public Works but not approved by County Department of Health and Human Services (HHS) - Office of Child Support federal grant administrators or managerial personnel knowledgeable about the Federal Program. This weaknesses could result in unallowable expenditures being charged to the Child Support Enforcement Federal Program operated by the Department of HHS. Formal procedures should be developed and implemented to require review and approval of Department of HHS federal grant expenditures. Procedures should include how approvals by management or administrators are documented for chargeback expenditures and the approvals should be done by personnel knowledgeable about the Federal Program.
Show full finding ▾Hide full finding ▴Child Support Enforcement- Lack of Evidence of Review/Approval of Direct Federal Expenditures See Schedule of Findings and Questioned Costs for table in place of the table within the text. Material Weakness All expenditures charged to Federal Grants should be reviewed and approved by administrators or managerial personnel knowledgeable about the respective Federal Grant regulations. Evidence of these approvals (Electronic or Manual) on the payment vouchers, invoices, and/or chargebacks are necessary in order to acknowledge that the expenditures are allowable, per specific grant regulations, and are compliant with Uniform Guidance requirements contained in Subpart E of 45 CFR 75. Due to the lack of controls over the review process of federal expenditures, two of the four chargeback expenditures tested, for vehicle mileage chargebacks were processed / approved by the County Department of Public Works but not approved by County Department of Health and Human Services (HHS) - Office of Child Support federal grant administrators or managerial personnel knowledgeable about the Federal Program. This weaknesses could result in unallowable expenditures being charged to the Child Support Enforcement Federal Program operated by the Department of HHS. Formal procedures should be developed and implemented to require review and approval of Department of HHS federal grant expenditures. Procedures should include how approvals by management or administrators are documented for chargeback expenditures and the approvals should be done by personnel knowledgeable about the Federal Program.
The Department of Public Works will provide copies of chargeback amounts to the various departments that are receiving charges at the beginning of the year, including HHS. HHS won't need to provide written approval to the originator but will instead be responsible for comparing the chargeback amounts provided to the actual amounts posting to their expense accounts. Anticipated Completion Date: 12/31/2021 Responsible Contact Person: Kathy Starks
2019-007
Workforce Innovation and Opportunity Act (WIOA) - Eligibility Support See Schedule of Findings and Questioned Costs for table in place of the table within the text. Material Weakness Workforce Innovation and Opportunity Act Policy Letter No. 15-07.2 Part VI. states in part, ? Workforce service providers (WSPs) Local areas, career service providers, youth program providers, and CCMEP lead agencies must verify or confirm eligibility requirements through an examination of documents or by using one or more of the additional methods of source documentation. Documentation requirements to support Workforce Innovation and Opportunity Act (WIOA) adult and dislocated worker eligibility are tied to the level of service provided to the participant. For adults and dislocated workers receiving only basic career services which do not trigger participation in the WIOA program, the local area may accept information provided by these reportable individuals at face value to complete the basic intake process without requiring source documentation. Documentation requirements increase for participants who receive basic career services triggering participation, individualized career services or training services. Workforce Innovation and Opportunity Act Policy Letter No. 15-07.2 provides examples of source documentation for each of the programs offered. Due to the lack of proper controls over eligibility documentation requirements, of the 40 WIOA participants tested for eligibility requirements, the following errors due to the lack of required eligibility documentation were identified. ? Four of the youth participants did not have their individual opportunity plan ? Three of the four youth participants noted above did not have proper documentation of age, citizenship, selective service registration, or school status participation. Lack of supporting documentation could lead to the County providing ineligible persons benefits and eventually loss of federal funds. The County should maintain all source documentation used in determination of Workforce Innovation and Opportunity Act eligibility requirements
Show full finding ▾Hide full finding ▴Workforce Innovation and Opportunity Act (WIOA) - Eligibility Support See Schedule of Findings and Questioned Costs for table in place of the table within the text. Material Weakness Workforce Innovation and Opportunity Act Policy Letter No. 15-07.2 Part VI. states in part, ? Workforce service providers (WSPs) Local areas, career service providers, youth program providers, and CCMEP lead agencies must verify or confirm eligibility requirements through an examination of documents or by using one or more of the additional methods of source documentation. Documentation requirements to support Workforce Innovation and Opportunity Act (WIOA) adult and dislocated worker eligibility are tied to the level of service provided to the participant. For adults and dislocated workers receiving only basic career services which do not trigger participation in the WIOA program, the local area may accept information provided by these reportable individuals at face value to complete the basic intake process without requiring source documentation. Documentation requirements increase for participants who receive basic career services triggering participation, individualized career services or training services. Workforce Innovation and Opportunity Act Policy Letter No. 15-07.2 provides examples of source documentation for each of the programs offered. Due to the lack of proper controls over eligibility documentation requirements, of the 40 WIOA participants tested for eligibility requirements, the following errors due to the lack of required eligibility documentation were identified. ? Four of the youth participants did not have their individual opportunity plan ? Three of the four youth participants noted above did not have proper documentation of age, citizenship, selective service registration, or school status participation. Lack of supporting documentation could lead to the County providing ineligible persons benefits and eventually loss of federal funds. The County should maintain all source documentation used in determination of Workforce Innovation and Opportunity Act eligibility requirements
Workforce Innovation and Opportunity Act will maintain all source documentation used in the determination of Workforce Innovation and Opportunity Act eligibility requirements for each participant. Anticipated Completion Date: 12/31/2021 Responsible Contact Person: Norma Arasim
FAC accepted this audit on January 21, 2021 — management decision was due July 21, 2021.
GSA_MIGRATION
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GSA_MIGRATION
2018-005
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GSA_MIGRATION
2018-006
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GSA_MIGRATION
2018-004
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2018-007
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2018-008
FAC accepted this audit on April 4, 2022 — management decision was due October 4, 2022.
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2018-005
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GSA_MIGRATION
2018-006
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GSA_MIGRATION
2018-004
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GSA_MIGRATION
2018-007
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2018-008
FAC accepted this audit on February 11, 2020 — management decision was due August 11, 2020.
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2017-010
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2017-006
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2017-011
FAC accepted this audit on September 25, 2019 — management decision was due March 25, 2020.
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2017-010
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2017-006
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2017-011
FAC accepted this audit on November 6, 2018 — management decision was due May 6, 2019.
GSA_MIGRATION
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GSA_MIGRATION
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2016-004
FAC accepted this audit on December 30, 2018 — management decision was due June 30, 2019.
GSA_MIGRATION
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GSA_MIGRATION
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2016-004
FAC accepted this audit on December 11, 2017 — management decision was due June 11, 2018.
GSA_MIGRATION
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2015-007
FAC accepted this audit on October 10, 2017 — management decision was due April 10, 2018.
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GSA_MIGRATION
2015-007
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