County of SpotsylvaniaLocal Government

Recommendation: We recommend that the management of the school system implement policies and procedures to ensure that documentation evidencing the separate preparation and approval of the monthly reimbursement requests are retained for audit purposes. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Example- The School Board will establish an additional level of segregation of duties within the monthly reimbursement process, prior to submission, to ensure appropriate oversight and review. Procedures now require that the preparation of reimbursement reports be performed by one staff member, while the review and approval of the reports are completed by a separate individual, independent of the preparer, prior to submission. Evidence of review and approval is documented and retained in accordance with Federal record-retention requirements.

Federal Agency: U.S. Department of Treasury Federal Program: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Award Number: SLFRP1026 Compliance Requirement: Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Over Compliance Prior Year Finding: No Criteria: Compliance: 2 CFR 200.213 Suspension and Debarment restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person (7) Distribution of work to individuals and firms or economic considerations. Control: Per 2 CFR Section 200.303(a), a non‐Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non‐Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: Spotsylvania County Public Schools could not provide supporting documentation that suspension and debarment status was determined prior to award. Questioned Costs: None Context: The suspension and debarment status for one out of two vendors was not retained related to the Coronavirus and Local Fiscal Recovery Funds Program Cause: Spotsylvania County Public Schools did not adhere to established internal controls over suspension and debarment transactions. Effect: In the absence of required documentation, it is not possible to verify that particular vendors were not suspended or debarred at the time that the applicable agreement or contract was finalized. Recommendation: Spotsylvania County Public Schools should ensure that employees are following the requirements they have outlined in their procurement policy. Views of Responsible Officials and Planned Corrective Action: Our procurement office will complete a check list to ensure compliance. Current procedures already require for suspension and debarment verification prior to entering into contracts/agreements with vendors. In this case, the procedure was followed appropriately, but documentation was not retained. Failure to retain a screenshot of the debarment search is easily corrected and staff will ensure such screenshots are saved when the search is completed. Action taken in response to finding: Spotsylvania County Public Schools will ensure the procurement checklist is followed and all supporting documentation is retained on file. Name of contact person (s) responsible for the corrective action plan: Phil Trayer and Jamie Pitts

Federal Agency: U.S. Department of Treasury Federal Program: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Award Number: SLFRP1026 Compliance Requirement: Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Over Compliance Prior Year Finding: No Criteria: Compliance: 2 CFR 200.213 Suspension and Debarment restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person (7) Distribution of work to individuals and firms or economic considerations. Control: Per 2 CFR Section 200.303(a), a non‐Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non‐Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: Spotsylvania County Public Schools could not provide supporting documentation that suspension and debarment status was determined prior to award. Questioned Costs: None Context: The suspension and debarment status for one out of two vendors was not retained related to the Coronavirus and Local Fiscal Recovery Funds Program Cause: Spotsylvania County Public Schools did not adhere to established internal controls over suspension and debarment transactions. Effect: In the absence of required documentation, it is not possible to verify that particular vendors were not suspended or debarred at the time that the applicable agreement or contract was finalized. Recommendation: Spotsylvania County Public Schools should ensure that employees are following the requirements they have outlined in their procurement policy. Views of Responsible Officials and Planned Corrective Action: Our procurement office will complete a check list to ensure compliance. Current procedures already require for suspension and debarment verification prior to entering into contracts/agreements with vendors. In this case, the procedure was followed appropriately, but documentation was not retained. Failure to retain a screenshot of the debarment search is easily corrected and staff will ensure such screenshots are saved when the search is completed. Action taken in response to finding: Spotsylvania County Public Schools will ensure the procurement checklist is followed and all supporting documentation is retained on file. Name of contact person (s) responsible for the corrective action plan: Phil Trayer and Jamie Pitts

Federal Agency: U.S. Department of Treasury Federal Program: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Award Number: SLFRP1026 Compliance Requirement: Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Over Compliance Prior Year Finding: No Criteria: Compliance: 2 CFR 200.213 Suspension and Debarment restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person (7) Distribution of work to individuals and firms or economic considerations. Control: Per 2 CFR Section 200.303(a), a non‐Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non‐Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: Spotsylvania County Public Schools could not provide supporting documentation that suspension and debarment status was determined prior to award. Questioned Costs: None Context: The suspension and debarment status for one out of two vendors was not retained related to the Coronavirus and Local Fiscal Recovery Funds Program Cause: Spotsylvania County Public Schools did not adhere to established internal controls over suspension and debarment transactions. Effect: In the absence of required documentation, it is not possible to verify that particular vendors were not suspended or debarred at the time that the applicable agreement or contract was finalized. Recommendation: Spotsylvania County Public Schools should ensure that employees are following the requirements they have outlined in their procurement policy. Views of Responsible Officials and Planned Corrective Action: Our procurement office will complete a check list to ensure compliance. Current procedures already require for suspension and debarment verification prior to entering into contracts/agreements with vendors. In this case, the procedure was followed appropriately, but documentation was not retained. Failure to retain a screenshot of the debarment search is easily corrected and staff will ensure such screenshots are saved when the search is completed. Action taken in response to finding: Spotsylvania County Public Schools will ensure the procurement checklist is followed and all supporting documentation is retained on file. Name of contact person (s) responsible for the corrective action plan: Phil Trayer and Jamie Pitts

Federal Agency: U.S. Department of Treasury Federal Program: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Award Number: SLFRP1026 Compliance Requirement: Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Over Compliance Prior Year Finding: No Criteria: Compliance: 2 CFR 200.213 Suspension and Debarment restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person (7) Distribution of work to individuals and firms or economic considerations. Control: Per 2 CFR Section 200.303(a), a non‐Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non‐Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: Spotsylvania County Public Schools could not provide supporting documentation that suspension and debarment status was determined prior to award. Questioned Costs: None Context: The suspension and debarment status for one out of two vendors was not retained related to the Coronavirus and Local Fiscal Recovery Funds Program Cause: Spotsylvania County Public Schools did not adhere to established internal controls over suspension and debarment transactions. Effect: In the absence of required documentation, it is not possible to verify that particular vendors were not suspended or debarred at the time that the applicable agreement or contract was finalized. Recommendation: Spotsylvania County Public Schools should ensure that employees are following the requirements they have outlined in their procurement policy. Views of Responsible Officials and Planned Corrective Action: Our procurement office will complete a check list to ensure compliance. Current procedures already require for suspension and debarment verification prior to entering into contracts/agreements with vendors. In this case, the procedure was followed appropriately, but documentation was not retained. Failure to retain a screenshot of the debarment search is easily corrected and staff will ensure such screenshots are saved when the search is completed. Action taken in response to finding: Spotsylvania County Public Schools will ensure the procurement checklist is followed and all supporting documentation is retained on file. Name of contact person (s) responsible for the corrective action plan: Phil Trayer and Jamie Pitts

2019-001: Significant Deficiency and Non-material Noncompliance ? Eligibility (Repeat Finding ? 2018-002) Program: Medical Assistance Program (CFDA Number 93.778 ? U.S. Department of Health and Human Services ? Virginia Department of Social Services; Federal Award Number: not available; Federal Award Year: 2019) Criteria: Per Title 2 Subpart Section 200.303, ?The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). (b) Comply with Federal statutes, regulations, and the terms and conditions of the Federal awards. (c) Evaluate and monitor the non-Federal entity's compliance with statutes, regulations, and the terms and conditions of Federal awards. (d) Take prompt action when instances of noncompliance are identified including noncompliance identified in audit findings.? Per Subchapter M1520.001 of the Virginia Medical Assistance Eligibility Manual, ?An annual review of all of the enrollee's eligibility requirements is called a renewal. A renewal of the enrollee's eligibility must be completed at least once every 12 months. The renewal should be initiated in the 11th month to ensure timely completion of the renewal?. Condition: During our testing of sixty (60) eligibility determinations, we noted the following exceptions: ? One (1) beneficiary case file did not contain evidence for proof of citizenship. ? One (1) eligible beneficiary?s redetermination was completed, but not within twelve (12) months of the prior determination of eligibility. Cause: An increase in the number of applicants during the year as a result of continued implementation of Affordable Care Act measures, as well as a lack of personnel to assist in processing and reviewing these applications, prevented the County from complying with the program?s requirements for determination of participant?s eligibility. Effect: The County?s noncompliance could result in costs disallowed by the grantor or a reduction in future funding for this program. Questioned Cost: Undeterminable. Recommendation: The County should implement a plan to enhance internal controls related to participant eligibility to ensure files contain adequate supporting documentation in accordance with the program requirements. Views of Responsible Officials and Planned Corrective Action: Responsible Person: Luana Cheatham, Erin Turner, Leanne Richardson and Jamillah Jefferson. Benefits Division Director: Currently vacant. Estimated Completion: Latest deployment date: 1/13/20, all activity will be on-going. Corrected Action: The prior year?s corrective action plan was not shared with Ms. Cheatham, the individual identified as the ?responsible person?. As a result, the Benefits leadership team was unaware of the planned corrective actions and subsequently did not successfully implement the corrective action plan submitted. Once a worker completes all mandatory trainings and is performing required duties and completing associated tasks accurately and timely, a worker is moved from 100% monitoring to general supervision. The optimal process for evaluation of on-going performance includes random case monitoring for accuracy in determination and quality of documentation. Worker knowledge and ability to perform accurate, timely determination and maintain quality case documentation is supported by regular communication and training in policy updates and system changes. Due the high number of Eligibility Workers with less than one year experience and therefore requiring elevated levels of supervision and case review, the ability of Supervisors to engage in random case monitoring of existing workers and deliver regular unit refresher training on policy or systems issues was very limited. Existing workers, due to high caseloads but still accountable to process cases timely, and experiencing ongoing challenges presented by state system access issues, were at risk for errors in eligibility determination actions and decisions. Errors in performance by existing workers were not noted timely due to priority given to training and supporting new workers. Specific Corrective Action: All Eligibility Supervisor positions are now filled, which will allow capacity for random case monitoring to be conducted monthly inclusive of all workers in the sample pool. Supervisors and Senior Worker level staff will conduct one random case readings per month, per eligibility worker. The findings from these case readings will be logged, tracked, and discussed monthly at Benefit Division Leadership meetings and used to develop targeted training. The findings will also be reviewed and discussed at employee staffing meetings. Start date: February 2020 A Medicaid focus workgroup will meet regularly to review caseload management, processing deadlines, policy updates, peer trainings, ?Q&A? sessions, and other needs as determined. Start date: November 2019 Each month, Supervisors will provide policy and/or procedure refresher at the monthly Division meetings. Training topics will be decided based on evaluation of Division case reading findings, internal and external audit finding and employee requests. Start date: October 2019

2018-002

2019-002: Significant Deficiency and Non-material Noncompliance ? Eligibility Program: Adoption Assistance (CFDA Number 93.659 ? U.S. Department of Health and Human Services ? Virginia Department of Social Services; Federal Award Number: not available; Federal Award Year: 2019) Criteria: Per the Code of Virginia, Section 63.2-1302, adoptive parents shall submit annually to the local board within thirty (30) days of the anniversary date of the approved agreement an affidavit which certifies that (i) the child on whose behalf they are receiving adoption assistance payments remains in their care, (ii) the child's condition requiring adoption assistance continues to exist, and (iii) whether or not changes to the adoption assistance agreement are requested. Condition: During our testing of forty (40) eligibility determinations, we noted two (2) instances in which the adoptive parents submitted the annual affidavit to the County, but not within thirty (30) days of the anniversary date of the approved adoption agreement. Cause: Parents did not submit the annual affidavit with the required time period. Effect: The County?s noncompliance could result in costs disallowed by the grantor or a reduction in future funding for this program. Questioned Cost: None noted. Recommendation: The County should implement a plan to enhance internal controls to ensure the timely submission of program required documentation. Views of Responsible Officials and Planned Corrective Action: Responsible Person: Services Supervisor: LaCora Harris Estimated Completion: Effective 1/13/20 Corrected Action: To ensure files contain adequate supporting documentation the Case Aide position, under supervision of the Services Supervisor, will be responsible for monthly monitoring of all Adoption Subsidy cases agreement dates. At a minimum the Case Aide will mail out a request for the annual Affidavit one month prior to the anniversary of an Adoption Subsidy agreement. The Case Aide will then update the case accordingly, prior to the anniversary date, to document if the Affidavit is received or if it is not returned.

GSA_MIGRATION

GSA_MIGRATION

2016-003

GSA_MIGRATION

2015-001

GSA_MIGRATION

2015-002