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State of South CarolinaState Government

EIN: 576000286

UEI: SJQQPFZKKCV1

Audit also covers 24 related EINs — show all

010936007, 257864818, 300757407, 453695561, 472655107, 566000286, 570082454, 570859576, 570882454, 570906962, 571040290, 571126149, 576000269, 576000285, 576000288, 576000302, 576000919, 576000922, 576001153, 576007591, 582307243, 770697491, 800484953, 831614425 · unlinked EINs have no separate FAC filing

Audited by: South Carolina Office of the State Auditor

Cognizant agency: 93 [Department of Health and Human Services]

View federal awards & risk assessment →

Data as of August 28, 2026

State of South Carolina18 audit years324 findings100 repeat
18
Audit Years
324
Total Findings
100
Repeat Findings
$13.3B
Federal Awards Expended (FY 2025)

FY 2025-06-30

$13,258,579,720 federal awards expended

Management decision deadline — for entities that funded this organization

The FAC accepted this audit on March 25, 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 September 25, 2026 (26 days from today).

What is a management decision? →
2025-003
Period of Performance
SIGNIFICANT DEFICIENCYQUESTIONED COSTSOTHER MATTERS

Expenditures were incurred and charged to the grant after the authorized period of performance. Cause: Office controls failed to prevent costs incurred outside the applicable period of performance from being charged to the grant. Effect: Costs charged outside the period of performance may be unallowable. Questioned Costs: Questioned costs totaled $2,231 for expenditures improperly charged to the federal award in noncompliance of period of performance requirements. Context: One of thirty-four transactions selected for testing costs for which the obligation had not been paid as of the end of period of performance was incurred after the period of performance ended, totaling $2,231. Prior Year Single Audit Report Finding Number: Not applicable Recommendation: We recommend that the Office strengthen its internal controls to ensure that expenditures charged to federal grants are incurred within the applicable period of performance. Views of responsible officials and planned corrective actions: See management’s response on page 181.

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2025 – 003. Period of Performance Federal Agency: Department of Homeland Security Federal Program Title: Disaster Grants – Public Assistance (Presidentially Declared Disasters) Assistance Listing: 97.036 Federal Grant ID Number: 4286-DR-SC Pass-Through Entity: Not applicable Award Period: October 11, 2016 through April 10, 2017 Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: 2 CFR § 200.403(h) requires that all costs, excluding administrative costs, be incurred during the approved budget period. 2 CFR § 200.303 requires that the recipient and subrecipient establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations and the terms and conditions of the federal award. Condition: Expenditures were incurred and charged to the grant after the authorized period of performance. Cause: Office controls failed to prevent costs incurred outside the applicable period of performance from being charged to the grant. Effect: Costs charged outside the period of performance may be unallowable. Questioned Costs: Questioned costs totaled $2,231 for expenditures improperly charged to the federal award in noncompliance of period of performance requirements. Context: One of thirty-four transactions selected for testing costs for which the obligation had not been paid as of the end of period of performance was incurred after the period of performance ended, totaling $2,231. Prior Year Single Audit Report Finding Number: Not applicable Recommendation: We recommend that the Office strengthen its internal controls to ensure that expenditures charged to federal grants are incurred within the applicable period of performance. Views of responsible officials and planned corrective actions: See management’s response on page 181.

Corrective Action Plan

The South Carolina Office of the Adjutant General respectfully submits the following corrective action plan for the year ended June 30, 2025, on behalf of the State of South Carolina. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Findings — FEDERAL AWARD PROGRAM AUDIT United States Department of Homeland Security 2025-003 Public Assistance (Presidentially Declared Disasters) - Assistance Listing No. 97.036 Disposition of Audit Finding: The South Carolina Emergency Management Division (SCEMD) of the Office of the Adjutant General concurs with the audit finding. Corrective Action: The Agency will refine its Public Assistance (PA) Reimbursement Review SOP and related Recovery Grants and Finance staff training to specify a requirement to validate that for projects under PA grants declared in 2018 and before, Direct Administrative Costs (DAC) were expended before the end of the project period of performance. In addition, the Recipient has submitted a time extension for the project period of performance but does not yet have approval from FEMA. Notes: • DAC was an eligible category of costs in PA projects under disaster grants through 2017 and optional for those declared August 1, 2017, through October 04, 2018 (opt-in). • Federal PA policy shifted to a management costs approach for projects under incidents declared on or after October 05, 2018. See attached FEMA Recovery Policy FP 104-11-2. Management costs are eligible for reimbursement up to 180 days after the subrecipient completes its last non-management cost project (p. 5). • Guidance regarding Direct Administrative Costs (see FEMA table attached) indicates that project closeout activities are eligible direct costs,which may have led to the Recipient considering DAC during the closeout period as eligible even when the project period of performance had ended. • The Federal Agency involved, FEMA, closed the project without noting an issue with reimbursement of these expenditures. Anticipated Completion Date: June 30, 2026 2 Name of the contact person responsible for corrective action: • Emily Bentley, SCEMD Chief of Mitigation and Recovery, at (803) 737-8774 • Antonio Johnson, SCEMD Grants and Finance Manager, at (803) 737-8606

About Period of Performance →
2025-004
Reporting
SIGNIFICANT DEFICIENCYREPEAT OF 2024-003OTHER MATTERS

FFATA reporting and timing errors were identified. Cause: Date entry errors and lack of retaining submitted reports led to the compliance errors identified during testing. Effect: The Office was not in compliance with FFATA reporting requirements. Questioned Costs: None, as this finding relates to reporting requirements, rather than unallowable expenditures. Context: Twelve subawards were selected for testing and the following compliance errors were identified during the testing: • For one of the subawards tested, incorrect information was reported in the FSRS regarding the subaward obligated amount. • For six of the subawards tested, the Office could not provide documentation of the original submission date in order to test the reports for timely submission. This is a repeat finding from the fiscal year 2024 Single Audit. The Office stated on its Summary Schedule of Prior Year Audit Findings that this issue was “Fully Corrected with Previously Reported Corrective Action Implemented”. Due to this issue repeating for fiscal year 2025, this issue has not been fully corrected. Prior Year Single Audit Report Finding Number: 2024-003 Recommendation: We recommend that the Office update their current internal controls to include continuous monitoring and reviewing of project obligations and retaining all submitted FFATA reports. Views of responsible officials and planned corrective actions: See management’s response on page 182.

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2025 – 004. Reporting Federal Agency: Department of Homeland Security Federal Program Title: Disaster Grants – Public Assistance (Presidentially Declared Disasters) Assistance Listing: 97.036 Federal Grant ID Number: Various Pass-Through Entity: Not applicable Award Period: Various Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: 2 CFR § 170 Appendix A requires that recipients of grants or cooperative agreements report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act (FFATA) Subaward Reporting System (FSRS) no later than the end of the month following the month in which the obligation was made. 2 CFR § 200.303 requires that the recipient and subrecipient establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations and the terms and conditions of the federal award. Condition: FFATA reporting and timing errors were identified. Cause: Date entry errors and lack of retaining submitted reports led to the compliance errors identified during testing. Effect: The Office was not in compliance with FFATA reporting requirements. Questioned Costs: None, as this finding relates to reporting requirements, rather than unallowable expenditures. Context: Twelve subawards were selected for testing and the following compliance errors were identified during the testing: • For one of the subawards tested, incorrect information was reported in the FSRS regarding the subaward obligated amount. • For six of the subawards tested, the Office could not provide documentation of the original submission date in order to test the reports for timely submission. This is a repeat finding from the fiscal year 2024 Single Audit. The Office stated on its Summary Schedule of Prior Year Audit Findings that this issue was “Fully Corrected with Previously Reported Corrective Action Implemented”. Due to this issue repeating for fiscal year 2025, this issue has not been fully corrected. Prior Year Single Audit Report Finding Number: 2024-003 Recommendation: We recommend that the Office update their current internal controls to include continuous monitoring and reviewing of project obligations and retaining all submitted FFATA reports. Views of responsible officials and planned corrective actions: See management’s response on page 182.

Corrective Action Plan

The South Carolina Office of the Adjutant General respectfully submits the following corrective action plan for the year ended June 30, 2025, on behalf of the State of South Carolina. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Findings — FEDERAL AWARD PROGRAM AUDIT United States Department of Homeland Security Public Assistance (Presidentially Declared Disasters) - Assistance Listing No. 97.036 Disposition of Audit Finding: The SCEMD of the Office of the Adjutant General concurs with the audit finding. Corrective Action: 1. The SCEMD Finance and Administration staff will implement and/or update the succession plan for any role or team member responsible for duties within the FFATA reporting process. 2. SCEMD will continue its monthly review of the South Carolina Recovery Grants (SCRG) platform by the SCEMD Finance and Administration staff to ensure the accuracy of information gathered for FFATA reporting. Where any prior reporting inaccuracies may be identified, FFATA reporting corrections of subrecipient obligations will be made. Anticipated Completion Date: June 30, 2026 Name of the contact person responsible for corrective action: Landry Phillips at LPhillips@emd.sc.gov or 803-737-8559

Prior Finding References

2024-003

About Reporting →
2025-005
Activities Allowed or Unallowed / Cost Allowability
SIGNIFICANT DEFICIENCY

Personnel expenditures were charged to the federal award without documented approval as required by the Office’s internal control procedure. Cause: The Office did not document all required approvals of payroll changes for grant employees. Effect: Personnel costs could be incorrectly charged to the federal award. Questioned Costs: Questioned costs are undetermined because this finding relates to missing approvals, rather than a specifically identifiable unallowable amount. Context: Two out of sixty employees tested were missing one or more of the required management approvals on their State Personnel Action Form applicable to the pay received in the selected period. Prior Year Single Audit Report Finding Number: Not applicable Recommendation: We recommend that the Office strengthen its efforts to consistently adhere to its procedures, including maintaining the approved State Personnel Action Form to support the personnel charges and allocations to applicable funding sources. Views of responsible officials and planned corrective actions: See management’s response on page 182.

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2025 – 005. Activities Allowed or Unallowed and Allowable Costs/Cost Principles Federal Agency: Department of Defense Federal Program Title: National Guard Military Operations and Maintenance (O&M) Projects Assistance Listings: 12.401 Federal Grant ID Numbers: Various Pass-Through Entity: Not applicable Award Period: Various Type of Finding: Significant deficiency in internal control over compliance Criteria: 2 CFR § 200.430 states that (a) Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the recipient or subrecipient consistently applied to both federal and non-federal activities; (2) Follows an appointment made in accordance with recipient’s or subrecipient’s laws, rules or written policies and meets the requirements of federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (g) of this section, Standards for Documentation of Personnel Expenses, when applicable. 2 CFR § 200.303 requires that the recipient and subrecipient establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations and the terms and conditions of the federal award. Condition: Personnel expenditures were charged to the federal award without documented approval as required by the Office’s internal control procedure. Cause: The Office did not document all required approvals of payroll changes for grant employees. Effect: Personnel costs could be incorrectly charged to the federal award. Questioned Costs: Questioned costs are undetermined because this finding relates to missing approvals, rather than a specifically identifiable unallowable amount. Context: Two out of sixty employees tested were missing one or more of the required management approvals on their State Personnel Action Form applicable to the pay received in the selected period. Prior Year Single Audit Report Finding Number: Not applicable Recommendation: We recommend that the Office strengthen its efforts to consistently adhere to its procedures, including maintaining the approved State Personnel Action Form to support the personnel charges and allocations to applicable funding sources. Views of responsible officials and planned corrective actions: See management’s response on page 182.

Corrective Action Plan

The South Carolina Office of the Adjutant General respectfully submits the following corrective action plan for the year ended June 30, 2025, on behalf of the State of South Carolina. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Findings — FEDERAL AWARD PROGRAM AUDIT U.S. Department of Defense National Guard Military Operations and Maintenance (O&M) Projects – Assistance Listing No. 12.401 Disposition of Audit Finding: The Office of the Adjutant General concurs with the audit finding. Corrective Action: The Agency has added additional quality control measures within the approval process, is hiring an additional staff member who will be responsible for auditing personnel actions and personnel files, and has implemented monthly audits in addition to the current standard of annual audits. Anticipated Completion Date: 6/30/2026 Name of the contact person responsible for corrective action: Robert Faulk at 803-299-4337

About Activities Allowed or Unallowed, Allowable Costs / Cost Principles →
2025-006
Activities Allowed or Unallowed / Cost Allowability / Matching, Level of Effort, Earmarking
SIGNIFICANT DEFICIENCYQUESTIONED COSTSOTHER MATTERS

Costs were improperly charged to the federal award. Cause: The Office’s controls failed to ensure that all costs were allowable and properly allocated. Effect: Improper allocation of costs resulted in the federal award being overcharged. Questioned Costs: Questioned costs totaled $1,969 for expenditures improperly allocated to the federal award in noncompliance of matching requirements. Context: For one out of sixty non-payroll transactions tested, the costs were not properly allocated in accordance with the federal award matching requirements. Prior Year Single Audit Report Finding Number: Not applicable Recommendation: We recommend that the Office review and update its procedures to ensure proper allocation of costs according to matching requirements. Views of responsible officials and planned corrective actions: See management’s response on page 183.

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2025 – 006. Activities Allowed or Unallowed and Allowable Costs/Cost Principles and Matching Federal Agencies: Department of Defense Federal Program Title: National Guard Military Operations and Maintenance (O&M) Projects Assistance Listing: 12.401 Federal Grant ID Number: W912QG-24-2-1001 Pass-Through Entity: Not applicable Award Period: October 1, 2023 through September 30, 2026 Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: 2 CFR § 75.403 outlines factors affecting allowability of cost, including that costs should not be used to meet cost sharing or matching requirements of federally-financed programs. 2 CFR § 200.303 requires that the recipient and subrecipient establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations and the terms and conditions of the federal award. Condition: Costs were improperly charged to the federal award. Cause: The Office’s controls failed to ensure that all costs were allowable and properly allocated. Effect: Improper allocation of costs resulted in the federal award being overcharged. Questioned Costs: Questioned costs totaled $1,969 for expenditures improperly allocated to the federal award in noncompliance of matching requirements. Context: For one out of sixty non-payroll transactions tested, the costs were not properly allocated in accordance with the federal award matching requirements. Prior Year Single Audit Report Finding Number: Not applicable Recommendation: We recommend that the Office review and update its procedures to ensure proper allocation of costs according to matching requirements. Views of responsible officials and planned corrective actions: See management’s response on page 183.

Corrective Action Plan

The South Carolina Office of the Adjutant General respectfully submits the following corrective action plan for the year ended June 30, 2025, on behalf of the State of South Carolina. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Findings — FEDERAL AWARD PROGRAM AUDIT U.S. Department of Defense National Guard Military Operations and Maintenance (O&M) Projects – Assistance Listing No. 12.401 Disposition of Audit Finding: The Office of the Adjutant General concurs with the audit finding. Corrective Action: The Agency will continue to monitor reports and ensure each Cooperative Agreement adheres to the established Chart of Accounts. The Agency will continue to review purchase submissions in the SCEIS system for adherence to Cooperative Agreement matching requirements. Anticipated Completion Date: 10/01/2026 Name of the contact person responsible for corrective action: Anita Ballington at 803-229-4294

About Activities Allowed or Unallowed, Allowable Costs / Cost Principles, Matching, Level of Effort, Earmarking →
2025-007
Cash Management
SIGNIFICANT DEFICIENCYOTHER MATTERS

Federal funds were received and held for more than 45 days before being paid out for allowable program expenditures, resulting in federal cash on hand in excess of immediate cash needs. Cause: Drawdowns were based on estimated expenditures of total contract amounts rather than actual or near-term payment activity. Effect: The Office did not comply with the awarding federal agency cash management requirements, increasing the risk of excess federal funds or interest liability. Questioned Costs: None, as this finding relates to the timing of federal cash drawdowns and the holding of funds in excess of 45 days needs, rather than unallowable expenditures. Context: One out of thirty-nine cash disbursements tested indicated that the Office retained a material amount of federal funds in excess of 45 days after the covered period identified on the cash advancement request. Prior Year Single Audit Report Finding Number: Not applicable Recommendation: We recommend that the Office strengthen its cash management controls by aligning federal drawdowns with actual or near-term disbursement activity. Views of responsible officials and planned corrective actions: See management’s response on page 183. Auditor’s Conclusion: In response to the Office’s corrective action plan, GCAPL #20-02 references back to NGR 5-1 for applicable guidance including the 45 day requirement. Additionally, our testing methodology was performed in accordance with the OMB Compliance Supplement, which requires auditors to assess whether individual cash drawdowns align with immediate cash needs. We also did not identify documentation indicating that the federal awarding agency granted a waiver from federal cash management requirements for capital projects. Therefore, based on our review, the Office did not fully comply with federal cash management requirements.

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2025 – 007. Cash Management Federal Agencies: Department of Defense Federal Program Title: National Guard Military Operations and Maintenance (O&M) Projects Assistance Listing: 12.401 Federal Grant ID Number: Various Pass-Through Entity: Not applicable Award Period: Various Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: NGR 5-1-11-5 (5) requires the grantee to minimize the time elapsing between the transfer of funds from the United States Treasury and their disbursement by the State. (no more than 45 days) 2 CFR § 200.303 requires that the recipient and subrecipient establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations and the terms and conditions of the federal award. Condition: Federal funds were received and held for more than 45 days before being paid out for allowable program expenditures, resulting in federal cash on hand in excess of immediate cash needs. Cause: Drawdowns were based on estimated expenditures of total contract amounts rather than actual or near-term payment activity. Effect: The Office did not comply with the awarding federal agency cash management requirements, increasing the risk of excess federal funds or interest liability. Questioned Costs: None, as this finding relates to the timing of federal cash drawdowns and the holding of funds in excess of 45 days needs, rather than unallowable expenditures. Context: One out of thirty-nine cash disbursements tested indicated that the Office retained a material amount of federal funds in excess of 45 days after the covered period identified on the cash advancement request. Prior Year Single Audit Report Finding Number: Not applicable Recommendation: We recommend that the Office strengthen its cash management controls by aligning federal drawdowns with actual or near-term disbursement activity. Views of responsible officials and planned corrective actions: See management’s response on page 183. Auditor’s Conclusion: In response to the Office’s corrective action plan, GCAPL #20-02 references back to NGR 5-1 for applicable guidance including the 45 day requirement. Additionally, our testing methodology was performed in accordance with the OMB Compliance Supplement, which requires auditors to assess whether individual cash drawdowns align with immediate cash needs. We also did not identify documentation indicating that the federal awarding agency granted a waiver from federal cash management requirements for capital projects. Therefore, based on our review, the Office did not fully comply with federal cash management requirements.

Corrective Action Plan

The South Carolina Office of the Adjutant General respectfully submits the following corrective action plan for the year ended June 30, 2025, on behalf of the State of South Carolina. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Findings — FEDERAL AWARD PROGRAM AUDIT U.S. Department of Defense National Guard Military Operations and Maintenance (O&M) Projects – Assistance Listing No. 12.401 Disposition of Audit Finding: The Office of the Adjutant General non-concurs with the audit finding. 1. The cited Regulation (National Guard Regulation 5-1) was changed from a Regulation to a policy guideline in 2020 by the National Guard Bureau (NGB) Grants and Cooperative Agreements Policy Letter (GCAPL) #20-02 dated 04 February 2020. 2. There is not a risk for interest liability to the State. The basis and thresholds for determining if a program is subject to interest payments is defined in Federal Code 31 CFR Part 205 and Treasury Financial Manual (TFM) 4A-2000, “Overall Disbursing Rules for All Federal Agencies.” In addition, the Cash Management Improvement Act Agreement (CIMA) between The State of South Carolina and The Secretary of the Treasury, United States Department of the Treasury, dated 6/30/2025, does not list the Agency’s Catalogue of Federal Domestic Assistance (CFDA) 12.401 as one of the State’s programs that meets or exceeds the State’s threshold for major Federal assistance programs. 3. The Cash Management testing used a one-to-one analysis based on monthly cash advance requests and monthly expenditures during the same time period. However, the testing, based on NGB Policy 5-1, should be from the date of receipt to the date of disbursement. 4. Lastly, the State of South Carolina’s Department of Administration does not allow submissions for Capital Projects (projects over $250,000) without the funding in possession of the requesting Agency. In addition, neither the Legislative Joint Bond Review Committee (JBRC) nor the State Fiscal Accountability Authority (SFAA) will approve a Capital Project without the Agency having the required funds on-hand. The average Readiness Center Revitalization (Capital Project) can take 2-3 years to complete, and the total funds have to be on-hand to receive approval for the start of the projects. This requires Cooperative Agreement 1001 to advance funding for projects months ahead of the execution of any Purchase Orders. Corrective Action: The Agency will continue to strive to minimize the time elapsed between transfer of funds from the United States Treasury and their disbursement by the State in accordance with the annual Request for Advance Payment Method Authorization signed between the State/Agency and the United States Property and Fiscal Officer (USPFO). Anticipated Completion Date: Current Name of the contact person responsible for corrective action: Anita Ballington at 803-299-4294

About Cash Management →
2025-008
Period of Performance
SIGNIFICANT DEFICIENCYQUESTIONED COSTSOTHER MATTERS

Expenditures were incurred and charged to the grant both before and after the authorized period of performance. Cause: Office controls failed to prevent costs incurred outside the applicable period of performance from being charged to the grant. Effect: Costs charged outside the period of performance may be unallowable. Questioned Costs: Questioned costs totaled $33,061 for expenditures incurred outside the authorized period of performance. Context: Two of twenty transactions selected for testing costs recorded during the first period of the grant were for costs incurred prior to the applicable period of performance, totaling $30,490. One of five transactions selected for testing costs for which the obligation had not been paid as of the end of period of performance was incurred after the period of performance ended, totaling $2,571. Prior Year Single Audit Report Finding Number: Not applicable Recommendation: We recommend that the Office strengthen its internal controls to ensure that expenditures charged to federal grants are incurred within the applicable period of performance. Views of responsible officials and planned corrective actions: See management’s response on page 184.

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2025 – 008. Period of Performance Federal Agency: Department of Defense Federal Program Title: National Guard Military Operations and Maintenance (O&M) Projects Assistance Listing: 12.401 Federal Grant ID Number: Various Pass-Through Entity: Not applicable Award Period: Various Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: 2 CFR § 200.403(h) requires that all costs, excluding administrative costs, be incurred during the approved budget period. 2 CFR § 200.303 requires that the recipient and subrecipient establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations and the terms and conditions of the federal award. Condition: Expenditures were incurred and charged to the grant both before and after the authorized period of performance. Cause: Office controls failed to prevent costs incurred outside the applicable period of performance from being charged to the grant. Effect: Costs charged outside the period of performance may be unallowable. Questioned Costs: Questioned costs totaled $33,061 for expenditures incurred outside the authorized period of performance. Context: Two of twenty transactions selected for testing costs recorded during the first period of the grant were for costs incurred prior to the applicable period of performance, totaling $30,490. One of five transactions selected for testing costs for which the obligation had not been paid as of the end of period of performance was incurred after the period of performance ended, totaling $2,571. Prior Year Single Audit Report Finding Number: Not applicable Recommendation: We recommend that the Office strengthen its internal controls to ensure that expenditures charged to federal grants are incurred within the applicable period of performance. Views of responsible officials and planned corrective actions: See management’s response on page 184.

Corrective Action Plan

The South Carolina Office of the Adjutant General respectfully submits the following corrective action plan for the year ended June 30, 2025, on behalf of the State of South Carolina. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Findings — FEDERAL AWARD PROGRAM AUDIT U.S. Department of Defense National Guard Military Operations and Maintenance (O&M) Projects – Assistance Listing No. 12.401 Disposition of Audit Finding: The Office of the Adjutant General concurs with the audit finding. The $2,571 finding was identified by the Agency prior to the audit. The Agency was only able make corrections to the grants which remained open (total of $1,421). The Agency was unable to make corrections for the remaining amount as those grants had been closed. Corrective Action: The Agency relies on SCEIS workflow approvals to verify and approve the period of performance. The Agency currently has three or four levels of approvals (depending on the specific grant) for each Shopping Cart. During this process, the Shopping Carts are reviewed and approved/disapproved by the Cooperative Agreement budget analyst, the Grants Department, the Procurement Department and the Budget & Finance Department. Annual reminders are sent to each Cooperative Agreement and email verification of disbursements are filed. Additional quarterly quality control checks will be added to the process. Anticipated Completion Date: 6/30/2026 Name of the contact person responsible for corrective action: Anita Ballington at 803-299-4294

About Period of Performance →
2025-009
Matching, Level of Effort, Earmarking
SIGNIFICANT DEFICIENCYOTHER MATTERS

The Office did not apply required matching contributions to federal expenditures by the applicable expenditure categories as required by the federal award. Cause: Office controls failed to ensure that matching costs were tracked and applied to federal expenditures at the expenditure-category level. Effect: Matching requirements were not met in accordance with federal regulations and award terms, and federal expenditures were not consistently supported by properly applied matching contributions. Questioned Costs: Questioned costs are undetermined because matching compliance was evaluated in total by category across multiple transactions, and the specific unsupported portion could not be reasonably isolated. Context: For all three grants that closed during the fiscal year, federal expenditures were not matched to the required amounts by expenditure category; testing identified one grant where the required match total was not met, one grant where the matching total was met, but was misapplied to multiple expenditure categories, and one grant where the required match total was not met and the requirement was misapplied to multiple expenditure categories. Prior Year Single Audit Report Finding Number: Not applicable Recommendation: We recommend that the Office strengthen controls to ensure matching contributions are properly tracked, documented, and applied to federal expenditures as required by the federal award. Views of responsible officials and planned corrective actions: See management’s response on page 184.

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2025 – 009. Matching Federal Agency: Department of Defense Federal Program Title: National Guard Military Operations and Maintenance (O&M) Projects Assistance Listing: 12.401 Federal Grant ID Number: Various Pass-Through Entity: Not applicable Award Period: Various Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: 2 CFR § 200.306 requires that matching contributions be allowable, properly allocated, and used in accordance with the terms and conditions of the federal award. 2 CFR § 200.303 requires that the recipient and subrecipient establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations and the terms and conditions of the federal award. Condition: The Office did not apply required matching contributions to federal expenditures by the applicable expenditure categories as required by the federal award. Cause: Office controls failed to ensure that matching costs were tracked and applied to federal expenditures at the expenditure-category level. Effect: Matching requirements were not met in accordance with federal regulations and award terms, and federal expenditures were not consistently supported by properly applied matching contributions. Questioned Costs: Questioned costs are undetermined because matching compliance was evaluated in total by category across multiple transactions, and the specific unsupported portion could not be reasonably isolated. Context: For all three grants that closed during the fiscal year, federal expenditures were not matched to the required amounts by expenditure category; testing identified one grant where the required match total was not met, one grant where the matching total was met, but was misapplied to multiple expenditure categories, and one grant where the required match total was not met and the requirement was misapplied to multiple expenditure categories. Prior Year Single Audit Report Finding Number: Not applicable Recommendation: We recommend that the Office strengthen controls to ensure matching contributions are properly tracked, documented, and applied to federal expenditures as required by the federal award. Views of responsible officials and planned corrective actions: See management’s response on page 184.

Corrective Action Plan

The South Carolina Office of the Adjutant General respectfully submits the following corrective action plan for the year ended June 30, 2025, on behalf of the State of South Carolina. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Findings — FEDERAL AWARD PROGRAM AUDIT U.S. Department of Defense National Guard Military Operations and Maintenance (O&M) Projects – Assistance Listing No. 12.401 Disposition of Audit Finding: The Office of the Adjutant General concurs with the audit finding. Corrective Action: The Agency will strengthen controls by enhancing annual trainings to ensure matching requirements are properly tracked, documented, and applied to Federal expenditures as required by the Federal award. Additional notes will be added on the Federal Final Modification forms to address any differences required by the Cooperative Agreement. Anticipated Completion Date: 10/01/2026 Name of the contact person responsible for corrective action: Anita Ballington at 803-299-2031

About Matching, Level of Effort, Earmarking →
2025-010
Special Tests & Provisions
SIGNIFICANT DEFICIENCYOTHER MATTERS

The Department’s monitoring process and provider eligibility system did not ensure that the provider's license was not expired or had imposed limitations. Cause: The Department did not revoke or subsequently update the Medicaid Management Information System and licensure and certification information for providers with expired or imposed licenses when updates were made within the enrollment process, nor did the Department complete the close out process to remove providers from the list of eligible providers. Effect: We were unable to verify that the State ensured providers met the prescribed health and safety standards and providers who were no longer qualified providers remained eligible to receive payment. Questioned Costs: None. There were no federal expenditures associated when testing this area of compliance. Context: We tested sixty eligible providers to ensure that the provider’s license was unexpired or have imposed limitations. We determined the Department did not confirm that the provider's license was not expired or limited for five providers. Prior Year Single Audit Finding Number: Not applicable Recommendation: We recommend the Department strengthen procedures to ensure that providers do not have expired or imposed limitations on their licenses and that providers who have expired and imposed limitations on licenses have their enrollment terminated. Views of responsible officials and planned corrective actions: See management’s response on page 185.

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2025 – 010. Special Tests and Provisions (Provider Eligibility) Federal Agency: Department of Health and Human Services Federal Program Title: Medicaid Cluster Assistance Listing: 93.775, 93.777, and 93.778 Federal Grant ID Number: 05-2405-SC-5MAP and 05-2505-SC-5MAP Pass-Through Entity: Not Applicable Award Period: October 1, 2023, through September 30, 2025 Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: Per 42 CFR § 455.412 (b), the State Medicaid agency must confirm that the provider's license has not expired and that there are no current limitations on the provider's license. 2 CFR § 200.303 requires that the recipient and subrecipient establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations and the terms and conditions of the federal award. Condition: The Department’s monitoring process and provider eligibility system did not ensure that the provider's license was not expired or had imposed limitations. Cause: The Department did not revoke or subsequently update the Medicaid Management Information System and licensure and certification information for providers with expired or imposed licenses when updates were made within the enrollment process, nor did the Department complete the close out process to remove providers from the list of eligible providers. Effect: We were unable to verify that the State ensured providers met the prescribed health and safety standards and providers who were no longer qualified providers remained eligible to receive payment. Questioned Costs: None. There were no federal expenditures associated when testing this area of compliance. Context: We tested sixty eligible providers to ensure that the provider’s license was unexpired or have imposed limitations. We determined the Department did not confirm that the provider's license was not expired or limited for five providers. Prior Year Single Audit Finding Number: Not applicable Recommendation: We recommend the Department strengthen procedures to ensure that providers do not have expired or imposed limitations on their licenses and that providers who have expired and imposed limitations on licenses have their enrollment terminated. Views of responsible officials and planned corrective actions: See management’s response on page 185.

Corrective Action Plan

The South Carolina Department of Health and Human Services (SCDHHS) respectfully submits the following corrective action plan for the year ended June 30, 2025, on behalf of the State of South Carolina. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAM AUDIT U.S. Department of Health and Human Services 2025-010 Medicaid Cluster – Assistance Listing No. 93.775, 93.777, and 93.778 Disposition of Audit Finding: The SCDHHS management concurs with the audit finding. Corrective Action: • Regarding the five providers identified as not meeting SCDHHS eligibility requirements, we do not currently have a process, nor a mechanism in place, that allows SCDHHS to monitor the status of provider licenses issued by South Carolina Department of Labor, Licensing and Regulation (SCLLR) or Department of Public Health (DPH). Currently, a provider’s license status is verified during initial enrollment and revalidation. • Recently, SCDHHS completed a project with SCLLR to implement a data exchange allowing access to South Carolina provider licensing information specific to independent pharmacy services. We intend to broaden the scope of our project work with SCLLR to include the license status information for all South Carolina Medicaid providers. While we are actively engaged with SCLLR, we have had initial conversations with DPH and intend to replicate the data exchange process with them for entities licensed by DPH. Anticipated Completion Date: Currently, we do not have a final implementation date but estimate that this could be a six – 12-month timeline following execution of a signed Data Sharing Agreement (DSA). This estimate not only includes work with SCLLR but also required updates to our Medicaid Management Information System (MMIS) and development of associated policies and procedures. Once we have additional information, we will provide an update. Contact persons responsible for corrective action: • Dawn Hunt at (803) 898-1843 • Nick Constantino at (803) 898-2561

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2025-011
Special Tests & Provisions
SIGNIFICANT DEFICIENCYOTHER MATTERS

The Department did not confirm that the provider's enrollment was revalidated at least every five years. Cause: Through the Department’s enrollment requests and updates process the Department did not detect to ensure that providers’ enrollments are being revalidated at least every five years. Effect: Providers who no longer meet the revalidation requirements remain eligible and receive payment. Questioned Costs: None. There were no federal expenditures associated when testing this area of compliance. Context: We tested sixty eligible providers to ensure the Department confirmed that the provider’s enrollment was revalidated at least every five years. We determined the Department did not confirm that the providers enrollment was revalidated at least every five years for one provider. Prior Year Single Audit Finding Number: Not applicable Recommendation: We recommend the Department strengthen procedures to ensure that provider enrollment is being revalidated at least every five years in accordance with 42 CFR § 455.414. Views of responsible officials and planned corrective actions: See management’s response on page 186.

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2025 – 011. Special Tests and Provisions (Provider Eligibility) Federal Agency: Department of Health and Human Services Federal Program Title: Medicaid Cluster Assistance Listing: 93.775, 93.777, and 93.778 Federal Grant ID Number: 05-2405-SC-5MAP and 05-2505-SC-5MAP Pass-Through Entity: Not Applicable Award Period: October 1, 2023, through September 30, 2025 Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: Per 42 CFR § 455.414, The State Medicaid agency must revalidate the enrollment of all providers regardless of provider type at least every five years. Per 2 CFR § 200.303 requires that the recipient and subrecipient establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations and the terms and conditions of the federal award. Condition: The Department did not confirm that the provider's enrollment was revalidated at least every five years. Cause: Through the Department’s enrollment requests and updates process the Department did not detect to ensure that providers’ enrollments are being revalidated at least every five years. Effect: Providers who no longer meet the revalidation requirements remain eligible and receive payment. Questioned Costs: None. There were no federal expenditures associated when testing this area of compliance. Context: We tested sixty eligible providers to ensure the Department confirmed that the provider’s enrollment was revalidated at least every five years. We determined the Department did not confirm that the providers enrollment was revalidated at least every five years for one provider. Prior Year Single Audit Finding Number: Not applicable Recommendation: We recommend the Department strengthen procedures to ensure that provider enrollment is being revalidated at least every five years in accordance with 42 CFR § 455.414. Views of responsible officials and planned corrective actions: See management’s response on page 186.

Corrective Action Plan

The South Carolina Department of Health and Human Services (SCDHHS) respectfully submits the following corrective action plan for the year ended June 30, 2025, on behalf of the State of South Carolina. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAM AUDIT U.S. Department of Health and Human Services Medicaid Cluster – Assistance Listing No. 93.775, 93.777, and 93.778 Disposition of Audit Finding: The SCDHHS management concurs with the audit finding. Corrective Action: Regarding the Provider Enrollment Revalidation finding - One provider whose last enrollment validation date was 5/10/2014. The revalidation date for this provider would have been due by 5/10/2019 which would have been before the start of the Public Health Emergency (PHE). The current Provider Enrollment and Support Functions Team Director was not with SCDHHS at the time of the missed revalidation and we are unable to attest to reasons this provider did not complete revalidation, as required. Anticipated Completion Date: Our post-PHE revalidation restart began in July 2024 and will conclude by the required completion date of February 28, 2027. Once SCDHHS completes our current revalidation schedule, we will resume normal revalidation cadence. Contact persons responsible for corrective action: • Dawn Hunt at (803) 898-1843 • Nick Constantino at (803) 898-2561

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2025-012
Special Tests & Provisions
SIGNIFICANT DEFICIENCYREPEAT OF 2024-006OTHER MATTERS

The Department was unable to provide documentation to verify that annual health and safety surveys were performed during the fiscal year. Cause: The Department did not maintain a record of completed annual health and safety surveys. Effect: We were unable to verify that the State ensured providers met the prescribed health and safety standards. Questioned Costs: None. There were no federal expenditures associated when testing this area of compliance. Context: The Department could not provide annual health and safety surveys in accordance with the State Plan. Therefore, we were unable to perform audit procedures. Prior Year Single Audit Finding Number: 2024-006 Recommendation: We recommend that the Department ensure that provider health and safety surveys are conducted in accordance with the State Plan and documentation is adequately maintained and monitored. Views of responsible officials and planned corrective actions: See management’s response on page 186.

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2025 – 012. Special Tests and Provisions (Provider Health and Safety Standards) Federal Agency: Department of Health and Human Services Federal Program Title: Medicaid Cluster Assistance Listing: 93.775, 93.777, and 93.778 Federal Grant ID Number: 05-2405-SC-5MAP and 05-2505-SC-5MAP Pass-Through Entity: Not Applicable Award Period: October 1, 2023, through September 30, 2025 Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: Per 2 CFR § 200.303 requires that the recipient and subrecipient establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations and the terms and conditions of the federal award. Per Section 4 of the South Carolina Department of Health and Human Services State Plan (h) the State assures that each facility shall have a standard survey which includes (for a case-mix stratified sample of residents) a survey of the quality of care furnished, as measured by indicators of medical, nursing and rehabilitative care, dietary and nutritional services, activities and social participation, and sanitation, infection control, and the physical environment, written plans of care and audit of resident’s assessments, and a review of compliance with resident’s rights not later than 15 months after the date of the previous standard survey. Additionally, Section 4 (i) states that the State assures that the Statewide average interval between standard surveys of nursing facilities does not exceed 12 months. Condition: The Department was unable to provide documentation to verify that annual health and safety surveys were performed during the fiscal year. Cause: The Department did not maintain a record of completed annual health and safety surveys. Effect: We were unable to verify that the State ensured providers met the prescribed health and safety standards. Questioned Costs: None. There were no federal expenditures associated when testing this area of compliance. Context: The Department could not provide annual health and safety surveys in accordance with the State Plan. Therefore, we were unable to perform audit procedures. Prior Year Single Audit Finding Number: 2024-006 Recommendation: We recommend that the Department ensure that provider health and safety surveys are conducted in accordance with the State Plan and documentation is adequately maintained and monitored. Views of responsible officials and planned corrective actions: See management’s response on page 186.

Corrective Action Plan

The South Carolina Department of Health and Human Services (SCDHHS) respectfully submits the following corrective action plan for the year ended June 30, 2025, on behalf of the State of South Carolina. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAM AUDIT U.S. Department of Health and Human Services Medicaid Cluster – Assistance Listing No. 93.775, 93.777, and 93.778 Disposition of Audit Finding: The SCDHHS concurs with the audit finding. Corrective Action: In accordance with the current contract with the state survey and certification agency, the South Carolina Department of Public Health (DPH), SCDHHS has implemented the following actions to address the Provider Health and Safety Standards audit finding: • SCDHHS requires DPH to submit a quarterly summary report to SCDHHS which identifies nursing facilities surveyed, and F tags cited, including scope and severity measures. • SCDHHS requires DPH to submit a cumulative end-of-year report confirming that each facility has had a survey within an average interval not to exceed 12 months, and no later than 15 months after the date of the previous survey. • SCDHHS and DPH hold quarterly meetings to review the submitted reports and discuss findings. Meetings were held on 7-25-25 and 10-30-25, and the next meeting is scheduled for 1-15-26. Anticipated Completion Date: Completed Contact persons responsible for corrective action: • Margaret Alewine at (803) 898-0047 • Lisa Ragland at (803) 898-1387

Prior Finding References

2024-006

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2025-013
Special Tests & Provisions
SIGNIFICANT DEFICIENCYOTHER MATTERS

The Department has not completed or maintained a record of the completed periodic audits of the five contracted Managed Care Organizations (MCOs) within the most recent three-year period nor did they post the information on their website. Cause: The Department did not ensure that the MCOs were receiving periodic audits or that the information was posted on the Department's website. Effect: We are unable to determine the accuracy, truthfulness, and completeness of the financial data submitted by each MCO. Questioned Costs: None. There were no federal expenditures associated when testing this area of compliance. Context: The Department did not complete any periodic audits in the most recent three-year period or post the required information to the Department's website. Prior Year Single Audit Finding Number: Not applicable Recommendation: We recommend that the Department ensure that MCOs are fulfilling the requirement of receiving periodic audits within the most recent three-year period as well as posting the required information to their website in accordance with 2 CFR § 438.602 (e) and (g). Views of responsible officials and planned corrective actions: See management’s response on page 187.

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2025 – 013. Special Tests and Provisions (Managed Care Financial Audit) Federal Agency: Department of Health and Human Services Federal Program Title: Medicaid Cluster Assistance Listing: 93.775, 93.777, and 93.778 Federal Grant ID Number: 05-2405-SC-5MAP and 05-2505-SC-5MAP Pass-Through Entity: Not Applicable Award Period: October 1, 2023, through September 30, 2025 Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: Per 2 CFR § 438.602 (e), The State must periodically, but no less frequently than once every three years, conduct, or contract for the conduct of, an independent audit of the accuracy, truthfulness, and completeness of the encounter and financial data submitted by, or on behalf of, each MCO, PIHP or PAHP. Per 2 CFR § 438.602 (g), The State must post on its Web site, as required in § 438.10(c)(3), the following documents and reports: (1) The MCO, PIHP, PAHP, or PCCM entity contract; (2) The data at § 438.604(a)(5); (3) The name and title of individuals included in § 438.604(a)(6); (4) The results of any audits under paragraph (e) of this section; (5) Enrollee handbooks, provider directories, and formularies required at § 438.10(g) through (i); (6) The information on rate ranges required at § 438.4(c)(2)(iv), if applicable; (7) The reports required at §§ 438.66(e) and 438.207(d); (8) The network adequacy standards required at § 438.68(b)(1) through (2) and (e); (9) The results of secret shopper surveys required at § 438.68(f); (10) State directed payment evaluation reports required in § 438.6(c)(2)(v)(C); (11) Information on all required Application Programming Interfaces including as specified in § 431.60(d) and (f); (12) Quality related information as required in §§ 438.332(c)(1), 438.340(d), 438.362(c) and 438.364(c)(2)(i); (13) Documentation of compliance with requirements in subpart K—Parity in Mental Health and Substance Use Disorder Benefits. Per 2 CFR § 200.303 requires that the recipient and subrecipient establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations and the terms and conditions of the federal award. Condition: The Department has not completed or maintained a record of the completed periodic audits of the five contracted Managed Care Organizations (MCOs) within the most recent three-year period nor did they post the information on their website. Cause: The Department did not ensure that the MCOs were receiving periodic audits or that the information was posted on the Department's website. Effect: We are unable to determine the accuracy, truthfulness, and completeness of the financial data submitted by each MCO. Questioned Costs: None. There were no federal expenditures associated when testing this area of compliance. Context: The Department did not complete any periodic audits in the most recent three-year period or post the required information to the Department's website. Prior Year Single Audit Finding Number: Not applicable Recommendation: We recommend that the Department ensure that MCOs are fulfilling the requirement of receiving periodic audits within the most recent three-year period as well as posting the required information to their website in accordance with 2 CFR § 438.602 (e) and (g). Views of responsible officials and planned corrective actions: See management’s response on page 187.

Corrective Action Plan

The South Carolina Department of Health and Human Services (SCDHHS) respectfully submits the following corrective action plan for the year ended June 30, 2025, on behalf of the State of South Carolina. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAM AUDIT U.S. Department of Health and Human Services Medicaid Cluster – Assistance Listing No. 93.775, 93.777, and 93.778 Disposition of Audit Finding: The SCDHHS concurs with the audit finding. Corrective Action: Management hereby proposes the Corrective Action Plan below. The Department will implement a control to ensure that the following Codes of Federal Regulations are being met: 42 CFR 438.602 (e) The state has implemented this requirement into its’ July 1, 2024 through June 30, 2027 contract with the MCOs. While the contract gives the MCOs a three-year period to have this audit completed, SC DHHS will engage each MCO to make a commitment to the date to have this audit completed and submitted. The audits will be submitted to the Director, Medicaid Managed Care Financing with copies to the Bureau Chief of the Bureau of Managed Care, and the Director of Strategic Communications in the Office of Communications and Public Relations. The Director, Medicaid Managed Care Financing will be responsible for tracking the submissions. 42 CFR 438.602 (g) The specific reference to the posting of the results of any audits under paragraph (e) is 42 CFR 438.602 (g)(4). The expected date of submission of the audits required under paragraph (e) will be provided to the Bureau Chief of the Bureau of Managed Care and the Director of Strategic Communications in the Office of Communications and Public Relations. The Director, Medicaid Managed Care Financing will be responsible for tracking the submissions and confirming with the Office of Communications and Public Relations the audits have been posted to the agency’s website. Anticipated Completion Date: June 30, 2026 Name of the contact person responsible for corrective action: • T Clark Phillip at (803) 898-1017

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2025-014
Reporting
SIGNIFICANT DEFICIENCYREPEAT OF 2024-008OTHER MATTERS

Discrepancies were identified in the reported amounts on SF-425 reports. Cause: Department’s review of semi-annual SF-425 reports submitted during fiscal year 2025 failed to detect discrepancies in reported amounts. Effect: Without proper supervisory review, there is an increased risk of inaccurate reporting. Questioned Costs: None, as this finding relates to reporting requirements, rather than unallowable expenditures. Context: In all seven of the SF-425 reports tested, reporting discrepancies in financial data were identified related to federal share of expenditures, and recipient share of expenditures. Additionally, in all seven of the SF-425 reports tested, they lacked sufficient support of proper review and approval prior to submission. This is a repeat finding from the fiscal year 2024 Single Audit. The Department stated on its Summary Schedule of Prior Year Audit Findings that this issue was “Fully Corrected with Previously Reported Corrective Action Implemented”. Due to this issue repeating for fiscal year 2025, this issue has not been fully corrected. Prior Year Single Audit Report Finding Number: 2024-008 Recommendation: We recommend the Department strengthen procedures to ensure an adequate review is completed prior to report submission and records are maintained of adjustments made within the period. Views of responsible officials and planned corrective actions: See management’s response on page 189.

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2025 – 014. Reporting Federal Agency: Department of Health and Human Agencies Federal Program Title: Aging Cluster Assistance Listing: 93.044, 93.045, and 93.053 Federal Grant ID Number: None Pass-Through Entity: Not applicable Award Period: July 1, 2023, through June 30, 2025 Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: 2 CFR § 200.303 requires that the recipient or subrecipient must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: Discrepancies were identified in the reported amounts on SF-425 reports. Cause: Department’s review of semi-annual SF-425 reports submitted during fiscal year 2025 failed to detect discrepancies in reported amounts. Effect: Without proper supervisory review, there is an increased risk of inaccurate reporting. Questioned Costs: None, as this finding relates to reporting requirements, rather than unallowable expenditures. Context: In all seven of the SF-425 reports tested, reporting discrepancies in financial data were identified related to federal share of expenditures, and recipient share of expenditures. Additionally, in all seven of the SF-425 reports tested, they lacked sufficient support of proper review and approval prior to submission. This is a repeat finding from the fiscal year 2024 Single Audit. The Department stated on its Summary Schedule of Prior Year Audit Findings that this issue was “Fully Corrected with Previously Reported Corrective Action Implemented”. Due to this issue repeating for fiscal year 2025, this issue has not been fully corrected. Prior Year Single Audit Report Finding Number: 2024-008 Recommendation: We recommend the Department strengthen procedures to ensure an adequate review is completed prior to report submission and records are maintained of adjustments made within the period. Views of responsible officials and planned corrective actions: See management’s response on page 189.

Corrective Action Plan

The South Carolina Department on Aging (SCDOA) respectfully submits the following corrective action plan for the year ended June 30, 2025, on behalf of the State of South Carolina. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAM AUDIT U.S. Department of Health and Human Services (HHS) – Administration for Community Living (ACL) 2025-014 Aging Cluster – Assistance Listing No. 93.044, 93.045, and 93.053 Disposition of Audit Finding: The SCDOA concurs with the audit finding. Corrective Action: To prevent future occurrences, the Department will implement the following measures: • A secondary review process has been established requiring supervisory approval before report submission. • Supporting documentation including general ledgers will be cross-referenced prior to finalization and documentation will be saved. Anticipated Completion Date: 12/05/2026 Names of the contact persons responsible for corrective action: • Syeeda Gallman, Finance Director at 1-803-734-9917 • Towanda Prior, Grants Manager at 1-803-734-9950

Prior Finding References

2024-008

About Reporting →
2025-015
Activities Allowed or Unallowed / Cost Allowability
SIGNIFICANT DEFICIENCYREPEAT OF 2024-015

The Academy failed to provide documentation to prove the existence of an internal control. Cause: There was an absence of documented evidence to support the internal control process. Effect: Without adequate controls in place, unallowable expenditures may be charged to the grant. Questioned Costs: None, as this finding relates to missing approvals, rather than a specifically identifiable unallowable amount. Context: For one of ten transactions tested, no documentation was available to prove the existence of an internal control. This is a repeat finding from the fiscal year 2024 Single Audit. The Departments stated on its Summary Schedule of Prior Year Audit Findings that this issue was “Fully Corrected with Previously Reported Corrective Action Implemented”. Due to this issue repeating for fiscal year 2025, this issue has not been fully corrected. Prior Year Single Audit Report Finding Number: 2024-015 Recommendation: We recommend that the Academy strengthen controls to ensure that documentation is maintained to support that costs charged to the grant were properly reviewed and approved for allowability. Views of responsible officials and planned corrective actions: See management’s response on page 190.

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2025 – 015. Activities Allowed or Unallowed and Allowable Costs/Cost Principles Federal Agency: Department of Transportation Federal Program Title: Highway Safety Cluster Assistance Listing: 20.600 and 20.616 Federal Grant ID Number: M5TR-2024-HS-26-24 Pass-Through Entity: Not applicable Award Period: October 1, 2023, through September 30, 2024 Type of Finding: Significant deficiency in internal control over compliance Criteria: 2 CFR § 200.303 requires that the recipient or subrecipient must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: The Academy failed to provide documentation to prove the existence of an internal control. Cause: There was an absence of documented evidence to support the internal control process. Effect: Without adequate controls in place, unallowable expenditures may be charged to the grant. Questioned Costs: None, as this finding relates to missing approvals, rather than a specifically identifiable unallowable amount. Context: For one of ten transactions tested, no documentation was available to prove the existence of an internal control. This is a repeat finding from the fiscal year 2024 Single Audit. The Departments stated on its Summary Schedule of Prior Year Audit Findings that this issue was “Fully Corrected with Previously Reported Corrective Action Implemented”. Due to this issue repeating for fiscal year 2025, this issue has not been fully corrected. Prior Year Single Audit Report Finding Number: 2024-015 Recommendation: We recommend that the Academy strengthen controls to ensure that documentation is maintained to support that costs charged to the grant were properly reviewed and approved for allowability. Views of responsible officials and planned corrective actions: See management’s response on page 190.

Corrective Action Plan

Criminal Justice Academy respectfully submits the following corrective action plan for the year ended June 30, 2025, on behalf of the State of South Carolina. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAM AUDIT Department of Transportation 2025-015 State and Community Highway Safety & National Priority Safety Programs – Assistance Listing No. 20.600 & 20.616 Disposition of Audit Finding: The South Carolina Criminal Justice Academy (SCCJA) concurs with the audit finding. Corrective Action: Agency policy was previously amended to ensure adequate internal controls. Additional staff training has been conducted to ensure full understanding of the policy changes to prevent future errors. Anticipated Completion Date: 10/30/2025 Name of the contact person responsible for corrective action: • Lauren Wright at (803) 896-8115

Prior Finding References

2024-015

About Activities Allowed or Unallowed, Allowable Costs / Cost Principles →
2025-016
Period of Performance
SIGNIFICANT DEFICIENCYREPEAT OF 2024-016

The Academy failed to provide documentation to prove the existence of an internal control. Cause: There was an absence of documented evidence to support the internal control process. Effect: The costs charged outside the period of performance may not be allowable. Questioned Costs: None, as this finding relates to missing approvals, rather than a specifically identifiable unallowable amount. Context: For one of ten expenditures tested, the CFO was unable to provide sufficient documentation of a review and approval. This is a repeat finding from the fiscal year 2024 Single Audit. The Departments stated on its Summary Schedule of Prior Year Audit Findings that this issue was “Fully Corrected with Previously Reported Corrective Action Implemented”. Due to this issue repeating for fiscal year 2025, this issue has not been fully corrected. Prior Year Single Audit Report Finding Number: 2024-016 Recommendation: We recommend that the Academy strengthen controls to ensure that documentation is maintained to support that period of performance requirements are reviewed and approved. Views of responsible officials and planned corrective actions: See management’s response on page 190.

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2025 – 016. Period of Performance Federal Agency: Department of Transportation Federal Program Title: Highway Safety Cluster Assistance Listing: 20.600 and 20.616 Federal Grant ID Number: Various Pass-Through Entity: Not applicable Award Period: October 1, 2023, through September 30, 2024 Type of Finding: Significant deficiency in internal control over compliance Criteria: 2 CFR § 200.303 requires that the recipient or subrecipient must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: The Academy failed to provide documentation to prove the existence of an internal control. Cause: There was an absence of documented evidence to support the internal control process. Effect: The costs charged outside the period of performance may not be allowable. Questioned Costs: None, as this finding relates to missing approvals, rather than a specifically identifiable unallowable amount. Context: For one of ten expenditures tested, the CFO was unable to provide sufficient documentation of a review and approval. This is a repeat finding from the fiscal year 2024 Single Audit. The Departments stated on its Summary Schedule of Prior Year Audit Findings that this issue was “Fully Corrected with Previously Reported Corrective Action Implemented”. Due to this issue repeating for fiscal year 2025, this issue has not been fully corrected. Prior Year Single Audit Report Finding Number: 2024-016 Recommendation: We recommend that the Academy strengthen controls to ensure that documentation is maintained to support that period of performance requirements are reviewed and approved. Views of responsible officials and planned corrective actions: See management’s response on page 190.

Corrective Action Plan

Criminal Justice Academy respectfully submits the following corrective action plan for the year ended June 30, 2025, on behalf of the State of South Carolina. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAM AUDIT Department of Transportation State and Community Highway Safety & National Priority Safety Programs – Assistance Listing No. 20.600 & 20.616 Disposition of Audit Finding: The South Carolina Criminal Justice Academy (SCCJA) concurs with the audit finding. Corrective Action: Agency policy was previously amended to ensure adequate internal controls. Additional staff training has been conducted to ensure full understanding of the policy changes to prevent future errors. Anticipated Completion Date: 10/30/2025 Name of the contact person responsible for corrective action: • Lauren Wright at (803) 896-8115

Prior Finding References

2024-016

About Period of Performance →
2025-017
Activities Allowed or Unallowed / Cost Allowability
SIGNIFICANT DEFICIENCYQUESTIONED COSTSOTHER MATTERS

The Department did not accurately calculate time and effort costs associated with the grant. Cause: The Department’s internal control did not ensure that time and effort was allocated appropriately. Effect: The Department could improperly allocate additional labor cost to the grant. Questioned Costs: $678 was the amount overcharged to program after evaluation of time and effort documentation. Context: We tested eleven individuals to ensure time and effort requirements were being properly met. We determined the Department did not properly allocate time and effort for ten of the eleven individuals tested. Prior Year Single Audit Finding Number: Not applicable Recommendation: We recommended the Department strengthen its controls to ensure that time and effort is tracked and allocated accurately. Views of responsible officials and planned corrective actions: See management’s response on page 192.

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2025 – 017. Activities Allowed or Unallowed & Allowable Costs/Costs Principles Federal Agency: Environmental Protection Agency Federal Program Title: Drinking Water State Revolving Fund Assistance Listing: 66.468 Federal Grant ID Number: Various Pass-Through Entity: Not Applicable Award Period: Various Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: 2 CFR § 200.430(g)(1)(vi) requires charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. 2 CFR § 200.303 requires that the recipient and subrecipient establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations and the terms and conditions of the federal award. Condition: The Department did not accurately calculate time and effort costs associated with the grant. Cause: The Department’s internal control did not ensure that time and effort was allocated appropriately. Effect: The Department could improperly allocate additional labor cost to the grant. Questioned Costs: $678 was the amount overcharged to program after evaluation of time and effort documentation. Context: We tested eleven individuals to ensure time and effort requirements were being properly met. We determined the Department did not properly allocate time and effort for ten of the eleven individuals tested. Prior Year Single Audit Finding Number: Not applicable Recommendation: We recommended the Department strengthen its controls to ensure that time and effort is tracked and allocated accurately. Views of responsible officials and planned corrective actions: See management’s response on page 192.

Corrective Action Plan

The South Carolina Department of Environmental Services (SCDES) respectfully submits the following corrective action plan for the year ended June 30, 2025, on behalf of the State of South Carolina. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAM AUDIT U.S. Environmental Protection Agency 2025-017 Drinking Water – Assistance Listing No. 66.468 Disposition of Audit Finding: The SCDES concurs with the audit finding. Corrective Action: According to (g),(vii),(B) Significant changes in the related work activity (as defined by the recipient's or subrecipient's written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; Many DES staff will work on multiple grants, and effort between grants may change from week to week. Reviewing the effort compared to amounts charged to a Federal grant for a single pay period may not be an accurate reflection of what the DES employees work over the life of that grant award. Reconciliations between payroll and effort occur over the life of the grant to ensure that all charges applied are reasonable and support the overall goal of the project on the longer term. To support this effort, budget staff will perform more periodic reviews of effort as compared to funding to identify situations where the difference between payroll and effort recorded are not on track to support the overall charges to a federal award. Anticipated Completion Date: Will have to be ongoing Budget and Program staff will be responsible for the corrective action plan. Simon Li 803-898-3443

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2025-018
Cash Management
SIGNIFICANT DEFICIENCYOTHER MATTERS

Supporting documentation was not adequate to determine if federal reimbursement requests had a separate preparer and reviewer prior to requesting a drawdown request as required by the Department's policies and procedures. Cause: The documentation that was provided was inadequate to support that the employee who completed the drawdown request was a different individual than the employee who reviewed and approved the drawdown request prior to the reimbursement request. Effect: The Department may request improper drawdowns due to a lack of segregation of duties. Questioned Costs: None. There were no federal expenditures associated when testing this area of compliance. Context: We tested ten drawdowns for set-asides to ensure there were two different signatures approving the draw. We determined the Department did not appropriately approve any of the ten drawdowns. Prior Year Single Audit Finding Number: Not applicable Recommendation: We recommended the Department strengthen its controls to ensure proper documentation of supervisory review is maintained and that there is a segregation of duties between the individual completing the drawdown request and the individual approving the drawdown request. Views of responsible officials and planned corrective actions: See management’s response on page 193.

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2025 – 018. Cash Management Federal Agency: Environmental Protection Agency Federal Program Title: Drinking Water State Revolving Fund Assistance Listing: 66.468 Federal Grant ID Number: Various Pass-Through Entity: Not Applicable Award Period: Various Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: 2 CFR § 200.303 requires that the recipient and subrecipient establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations and the terms and conditions of the federal award. Condition: Supporting documentation was not adequate to determine if federal reimbursement requests had a separate preparer and reviewer prior to requesting a drawdown request as required by the Department's policies and procedures. Cause: The documentation that was provided was inadequate to support that the employee who completed the drawdown request was a different individual than the employee who reviewed and approved the drawdown request prior to the reimbursement request. Effect: The Department may request improper drawdowns due to a lack of segregation of duties. Questioned Costs: None. There were no federal expenditures associated when testing this area of compliance. Context: We tested ten drawdowns for set-asides to ensure there were two different signatures approving the draw. We determined the Department did not appropriately approve any of the ten drawdowns. Prior Year Single Audit Finding Number: Not applicable Recommendation: We recommended the Department strengthen its controls to ensure proper documentation of supervisory review is maintained and that there is a segregation of duties between the individual completing the drawdown request and the individual approving the drawdown request. Views of responsible officials and planned corrective actions: See management’s response on page 193.

Corrective Action Plan

The South Carolina Department of Environmental Services (SCDES) respectfully submits the following corrective action plan for the year ended June 30, 2025, on behalf of the State of South Carolina. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAM AUDIT U.S. Environmental Protection Agency Drinking Water – Assistance Listing No. 66.468 Disposition of Audit Finding: The SCDES concurs with the audit finding. Corrective Action: Grant draws will be created by one Budget staff member and reviewed by another Budget staff member. The creation and review process of the draws will be supported by two signatures recorded on the draw form, that of the creator and that of the reviewer. Anticipated completion date: July 1, 2025 the process was put into place. The Budget staff along with the Program staff will be responsible for the corrective action plan. Simon Li 803-898-3443

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2025-019
Cash Management
SIGNIFICANT DEFICIENCYOTHER MATTERS

The Department overdrew federal funds. Cause: The Department's internal control did not ensure that drawdown requests were supported by adequate supporting documentation prior to the reimbursement request. Effect: The Department may request and drawdown inappropriate federal funds. Questioned Costs: None, as this finding relates to the timing of federal cash drawdowns and the holding of funds in excess of 45 days needs, rather than unallowable expenditures. Context: We tested ten drawdowns for set-asides to ensure compliance requirements were being met. We determined the Department overdrew federal funds for one of ten drawdowns for a total of $8,252. Prior Year Single Audit Finding Number: Not applicable Recommendation: We recommend the Department strengthen its controls to ensure that policies and procedures are followed to ensure expenditures are incurred prior to submitting drawdown requests. Views of responsible officials and planned corrective actions: See management’s response on page 193.

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2025 – 019. Cash Management Federal Agency: Environmental Protection Agency Federal Program Title: Drinking Water State Revolving Fund Assistance Listing: 66.468 Federal Grant ID Number: Various Pass-Through Entity: Not Applicable Award Period: Various Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: 40 CFR § 35.3560(e) a State may draw cash through the Automated Clearing House for the full amount of costs incurred for set-aside expenditures based on Environmental Protection Agency approved workplans. A State may draw cash in advance to ensure funds are available to meet State payroll expenses. However, cash should be drawn no sooner than necessary to meet immediate payroll disbursement needs. 2 CFR § 200.303 requires that the recipient and subrecipient establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations and the terms and conditions of the federal award. Condition: The Department overdrew federal funds. Cause: The Department's internal control did not ensure that drawdown requests were supported by adequate supporting documentation prior to the reimbursement request. Effect: The Department may request and drawdown inappropriate federal funds. Questioned Costs: None, as this finding relates to the timing of federal cash drawdowns and the holding of funds in excess of 45 days needs, rather than unallowable expenditures. Context: We tested ten drawdowns for set-asides to ensure compliance requirements were being met. We determined the Department overdrew federal funds for one of ten drawdowns for a total of $8,252. Prior Year Single Audit Finding Number: Not applicable Recommendation: We recommend the Department strengthen its controls to ensure that policies and procedures are followed to ensure expenditures are incurred prior to submitting drawdown requests. Views of responsible officials and planned corrective actions: See management’s response on page 193.

Corrective Action Plan

The South Carolina Department of Environmental Services (SCDES) respectfully submits the following corrective action plan for the year ended June 30, 2025, on behalf of the State of South Carolina. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAM AUDIT U.S. Environmental Protection Agency Drinking Water – Assistance Listing No. 66.468 Disposition of Audit Finding: The SCDES concurs with the audit finding. Corrective Action: An error was found in the report used to perform draws. Due to the number of draws performed at a time, the duplicate draw was not caught by the drawing staff. The report has been corrected. Also, two Budget staff review the draws to ensure that the amounts are correct. This dual control will be supported by two signatures on the draw forms. Anticipated Completion Date: 7/1/2025. The Budget staff will be responsible for the corrective action plan. Simon Li 803-898-3443

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2025-020
Activities Allowed or Unallowed / Cost Allowability
SIGNIFICANT DEFICIENCYQUESTIONED COSTSOTHER MATTERS

The Department did not maintain adequate time and effort documentation to support salaries and wages charged to federal awards. Specifically, payroll charges were not consistently supported by records that accurately reflected actual work performed and/or did not properly document the allocation of time between federal and non-federal activities. Indirect costs are directly correlated to the payroll expenditures thus if the payroll expenditures are inaccurate then the indirect cost will also be inaccurate. Cause: The Department lacked sufficient internal controls and/or written procedures to ensure time and effort was allocated among payroll accurately. Effect: As a result, there is an increased risk that salaries and wages charged to federal awards were inaccurate, unallowable, or improperly allocated, which could result in questioned costs and noncompliance with federal grant requirements. Questioned Costs: $17,445 for payroll testing. The overall variance between hours worked and amounts paid represents the questioned costs for payroll. Unknown for journal entry testing. Indirect costs were allocated based on budgeted personnel amounts rather than actual time and effort recorded in the Personnel Cost Account System (PCAS) and discrepancies were identified during our testing of time and effort requirements. Context: We selected thirty-six individuals to ensure time and effort requirements were properly met. Eleven out of thirty-six employees tested were paid more from the grant funds than they actually worked during the pay period. Twenty-three out of thirty-six employees tested, were paid less from the grant funds than they worked during the pay period. We selected seven indirect cost transactions to ensure time and effort requirements were being met properly. Because the journal entries related to indirect cost were made based on the budget for the grant and not the actual time and effort contributed by the individual employees per the PCAS, we were unable to provide reasonable assurance that time and effort was calculated accurately. Prior Year Single Audit Finding Numbers: Not applicable Recommendation: We recommend the Department develop and/or strengthen written policies and procedures for time and effort reporting; Ensure time and effort recordings accurately reflect actual work performed and total compensated activity; Implement supervisory review of time and effort documentation; and perform periodic after-the-fact reviews and adjustments to payroll charges to ensure compliance with federal requirements. Views of responsible officials and planned corrective actions: See management’s response on page 194.

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2025 – 020. Activities Allowed or Unallowed and Allowable Costs/Cost Principles – Payroll and Indirect Costs Federal Agency: Environmental Protection Agency Federal Program Title: Performance Partnership Grants Assistance Listing: 66.605 Federal Grant ID Number: Various Pass-Through Entity: Not Applicable Award Period: Various Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: 2 CFR §200.404 states that a cost is reasonable when the charge is consistent with the recipient’s or subrecipient’s established written personnel policies. 2 CFR § 200.430 requires that charges to federal awards for salaries and wages must be supported by accurate time and effort records that reflect the actual work performed. The records must: be supported by a system of internal controls that provides reasonable assurance payroll costs are accurate, allowable, and properly allocated; be incorporated into the recipient’s official accounting records; reasonably reflect the employee’s total compensated activity, not exceeding 100 percent of compensated time; properly allocate payroll costs when employees work on multiple cost objectives, including federal and non-federal activities; comply with the recipient’s established accounting policies and procedures. Charges should not rely solely on budget estimates unless: the estimates reasonably approximate actual work performed; significant changes in work activity are promptly identified and recorded and periodic after-the-fact reviews and adjustments are performed to ensure final charges are accurate, allowable, and properly allocated. 2 CFR § 200.303 requires that the recipient and subrecipient establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: The Department did not maintain adequate time and effort documentation to support salaries and wages charged to federal awards. Specifically, payroll charges were not consistently supported by records that accurately reflected actual work performed and/or did not properly document the allocation of time between federal and non-federal activities. Indirect costs are directly correlated to the payroll expenditures thus if the payroll expenditures are inaccurate then the indirect cost will also be inaccurate. Cause: The Department lacked sufficient internal controls and/or written procedures to ensure time and effort was allocated among payroll accurately. Effect: As a result, there is an increased risk that salaries and wages charged to federal awards were inaccurate, unallowable, or improperly allocated, which could result in questioned costs and noncompliance with federal grant requirements. Questioned Costs: $17,445 for payroll testing. The overall variance between hours worked and amounts paid represents the questioned costs for payroll. Unknown for journal entry testing. Indirect costs were allocated based on budgeted personnel amounts rather than actual time and effort recorded in the Personnel Cost Account System (PCAS) and discrepancies were identified during our testing of time and effort requirements. Context: We selected thirty-six individuals to ensure time and effort requirements were properly met. Eleven out of thirty-six employees tested were paid more from the grant funds than they actually worked during the pay period. Twenty-three out of thirty-six employees tested, were paid less from the grant funds than they worked during the pay period. We selected seven indirect cost transactions to ensure time and effort requirements were being met properly. Because the journal entries related to indirect cost were made based on the budget for the grant and not the actual time and effort contributed by the individual employees per the PCAS, we were unable to provide reasonable assurance that time and effort was calculated accurately. Prior Year Single Audit Finding Numbers: Not applicable Recommendation: We recommend the Department develop and/or strengthen written policies and procedures for time and effort reporting; Ensure time and effort recordings accurately reflect actual work performed and total compensated activity; Implement supervisory review of time and effort documentation; and perform periodic after-the-fact reviews and adjustments to payroll charges to ensure compliance with federal requirements. Views of responsible officials and planned corrective actions: See management’s response on page 194.

Corrective Action Plan

The Department of Environmental Services respectfully submits the following corrective action plan for the year ended June 30, 2025, on behalf of the State of South Carolina. The finding from the schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAM AUDIT U.S. Environmental Protection Agency Performance Partnership Grants – Assistance Listing No. 66.605 Disposition of Audit Finding: The Department of Environmental Services agrees with the audit finding. Corrective Action: According to (g),(vii),(B) Significant changes in the related work activity (as defined by the recipient's or subrecipient's written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; Many DES staff will work on multiple grants, and effort between grants may change from week to week. Reviewing the effort compared to amounts charged to a Federal grant for a single pay period may not be an accurate reflection of what the DES employees work over the life of that grant award. Reconciliations between payroll and effort occur over the life of the grant to ensure that all charges applied are reasonable and support the overall goal of the project on the longer term. To support this effort, budget staff will perform more periodic reviews of effort as compared to funding to identify situations where the difference between payroll and effort recorded are not on track to support the overall charges to a federal award. Anticipated Completion Date: Processed started July 1, 2025 and will ongoing. Simon Li will be responsible for corrective action: • Simon Li at 803-898-3443

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2025-021
Cash Management
SIGNIFICANT DEFICIENCY

The Department provided documentation that does not show a separate preparer and reviewer signature. Cause: The Department lacked sufficient internal controls to ensure that the drawdowns had separate preparers and reviewers. Effect: The Department may request improper drawdowns due to a lack of segregation of duties. Questioned Costs: None: The finding is related to insufficient documentation due to lack of approval signatures and thus we do not question any of the drawdown amounts. Context: We tested six drawdowns to ensure there were two different signatures approving the draw. We determined the Department did not appropriately approve for all six drawdowns. Prior Year Single Audit Finding Numbers: Not applicable Recommendation: We recommend that the Department strengthen its controls to ensure that drawdowns are reviewed appropriately. Views of responsible officials and planned corrective actions: See management’s response on page 195.

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2025 – 021. Cash Management Federal Agency: Environmental Protection Agency Federal Program Title: Performance Partnership Grants Assistance Listing: 66.605 Federal Grant ID Number: Various Pass-Through Entity: Not Applicable Award Period: Various Type of Finding: Significant deficiency in internal control over compliance Criteria: 2 CFR § 200.303 requires that the recipient and subrecipient establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations and the terms and conditions of the federal award. Condition: The Department provided documentation that does not show a separate preparer and reviewer signature. Cause: The Department lacked sufficient internal controls to ensure that the drawdowns had separate preparers and reviewers. Effect: The Department may request improper drawdowns due to a lack of segregation of duties. Questioned Costs: None: The finding is related to insufficient documentation due to lack of approval signatures and thus we do not question any of the drawdown amounts. Context: We tested six drawdowns to ensure there were two different signatures approving the draw. We determined the Department did not appropriately approve for all six drawdowns. Prior Year Single Audit Finding Numbers: Not applicable Recommendation: We recommend that the Department strengthen its controls to ensure that drawdowns are reviewed appropriately. Views of responsible officials and planned corrective actions: See management’s response on page 195.

Corrective Action Plan

The Department of Environmental Services respectfully submits the following corrective action plan for the year ended June 30, 2025, on behalf of the State of South Carolina. The finding from the schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAM AUDIT U.S. Environmental Protection Agency Performance Partnership Grants – Assistance Listing No. 66.605 Disposition of Audit Finding: The Department of Environmental Services agrees with the audit finding. Corrective Action: A new process has been put into place where the draws are performed by one staff member and then reviewed by another. This process is documented with signatures of both staff members. Anticipated Completion Date: Processed started July 1, 2025, and will ongoing Simon Li and Doug Beaty are responsible for corrective action: • Simon Li at 803-898-3443 • Doug Beaty at 803-898-3453

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2025-022
Period of Performance
SIGNIFICANT DEFICIENCYQUESTIONED COSTSOTHER MATTERS

The Department charged costs to a grant after the grant period ended. Cause: The Department lacked sufficient internal controls to ensure all costs to grants occurred during the grant period. Effect: Costs charged outside the period of performance may not be allowable. Questioned Costs: $2,771. The six transactions that occurred outside of the Period of Performance totaled this amount. Context: We tested the one journal entry transaction that occurred during the liquidation period for a grant that ended 9/30/2024. We determined that six of the transactions involved with the journal entry occurred after the grant period ended. Prior Year Single Audit Finding Numbers: Not applicable Recommendation: We recommend that the Department strengthen its controls to ensure that costs are incurred within the grant period. Views of responsible officials and planned corrective actions: See management’s response on page 195.

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2025 – 022. Period of Performance Federal Agency: Environmental Protection Agency Federal Program Title: Performance Partnership Grants Assistance Listing: 66.605 Federal Grant ID Number: Various Pass-Through Entity: Not Applicable Award Period: Various Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: 2 CFR § 200.403(h) requires costs must be incurred during the approved budget period. 2 CFR § 200.303 requires that the recipient and subrecipient establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations and the terms and conditions of the federal award. Condition: The Department charged costs to a grant after the grant period ended. Cause: The Department lacked sufficient internal controls to ensure all costs to grants occurred during the grant period. Effect: Costs charged outside the period of performance may not be allowable. Questioned Costs: $2,771. The six transactions that occurred outside of the Period of Performance totaled this amount. Context: We tested the one journal entry transaction that occurred during the liquidation period for a grant that ended 9/30/2024. We determined that six of the transactions involved with the journal entry occurred after the grant period ended. Prior Year Single Audit Finding Numbers: Not applicable Recommendation: We recommend that the Department strengthen its controls to ensure that costs are incurred within the grant period. Views of responsible officials and planned corrective actions: See management’s response on page 195.

Corrective Action Plan

The Department of Environmental Services respectfully submits the following corrective action plan for the year ended June 30, 2025, on behalf of the State of South Carolina. The finding from the schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAM AUDIT U.S. Environmental Protection Agency Performance Partnership Grants – Assistance Listing No. 66.605 Disposition of Audit Finding: The Department of Environmental Services agrees with the audit finding. Corrective Action: There will be one staff member in Budgets that prepares the document and the JE and supporting documentation will be reviewed by another to ensure that the JE is not moving an expenditure onto a closed Federal grant. Anticipated Completion Date: Process began July 1, 2025, and will be ongoing. Simon Li will be responsible for corrective action: • Simon Li at 803-898-3443

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2025-023
Activities Allowed or Unallowed / Cost Allowability
SIGNIFICANT DEFICIENCY

The Department did not document approved payments in the accounting system. Cause: The documentation that was provided was inadequate to support that the subsidy payments were appropriately approved in the accounting system. Effect: The Department could allocate incorrect payments to the grant. Questioned Costs: None, as this finding relates to missing approvals, rather than a specifically identifiable unallowable amount. Context: For four of sixty individual payments tested, the Department did not properly document approval. Prior Year Single Audit Finding Numbers: Not applicable Recommendation: We recommend the Department strengthen internal controls to ensure that batch payments are reviewed and approved prior to submission. Views of responsible officials and planned corrective actions: See management’s response on page 196.

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2025 – 023. Activities Allowed or Unallowed and Allowable Costs/Cost Principles Federal Agencies: Department of Health and Human Services Federal Program Titles: Adoption Assistance Assistance Listings: 93.659 Federal Grant ID Numbers: Various Pass-Through Entity: Not applicable Award Period: Various Type of Finding: Significant deficiency in internal control over compliance Criteria: 2 CFR § 200.303 requires that the recipient and subrecipient establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms of conditions of the federal award. Condition: The Department did not document approved payments in the accounting system. Cause: The documentation that was provided was inadequate to support that the subsidy payments were appropriately approved in the accounting system. Effect: The Department could allocate incorrect payments to the grant. Questioned Costs: None, as this finding relates to missing approvals, rather than a specifically identifiable unallowable amount. Context: For four of sixty individual payments tested, the Department did not properly document approval. Prior Year Single Audit Finding Numbers: Not applicable Recommendation: We recommend the Department strengthen internal controls to ensure that batch payments are reviewed and approved prior to submission. Views of responsible officials and planned corrective actions: See management’s response on page 196.

Corrective Action Plan

The South Carolina Department of Social Services (SCDSS) respectfully submits the following corrective action plan for the year ended June 30, 2025, on behalf of the State of South Carolina. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAM AUDIT U.S. Department of Health and Human Services 2025-023 Adoption Assistance – Assistance Listing No. 93.659 Disposition of Audit Finding: The SCDSS concurs with the audit finding. Corrective Action: The Department’s internal controls require the monthly batch reports to be uploaded with all payment documents. During the audit, four payment documents were identified that did not have the required supporting documentation attached. Department staff have retrieved the necessary backup for the four payments and have uploaded the required documentation to the accounting system. Anticipated Completion Date: Completed Names of the contact persons responsible for corrective action: • Courtney Hogue, Controller at 803-898-7488

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2025-024
Eligibility
SIGNIFICANT DEFICIENCYQUESTIONED COSTSOTHER MATTERS

The Department did not ensure benefits were properly terminated. Cause: The Department's controls did not ensure that the child was still the legal responsibility of the parents. Effect: The Department could continue providing benefits to ineligible individuals. Questioned Costs: $532. We determined that the Department overpaid federal expenditures associated with this area of compliance requirements. Context: We tested sixty individuals to ensure they were eligible for adoption assistance. We determined the Department did not terminate benefits timely for one of the sixty individuals. Prior Year Single Audit Finding Numbers: Not applicable Recommendation: We recommend the Department strengthen internal controls to ensure that individuals are removed from the program when deemed ineligible. Views of responsible officials and planned corrective actions: See management’s response on page 196.

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2025 – 024. Eligibility Federal Agencies: Department of Health and Human Services Federal Program Titles: Adoption Assistance Assistance Listings: 93.659 Federal Grant ID Numbers: Various Pass-Through Entity: Not applicable Award Period: Various Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: 42 USC § 673(A)(4)(a)(iii) requires a payment may not be made pursuant to this section to parents or relative guardians with respect to a child if the State determines that the child is no longer receiving any support from the parents or relative guardians, as the case may be. 2 CFR § 200.303 requires that the recipient and subrecipient establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms of conditions of the federal award. Condition: The Department did not ensure benefits were properly terminated. Cause: The Department's controls did not ensure that the child was still the legal responsibility of the parents. Effect: The Department could continue providing benefits to ineligible individuals. Questioned Costs: $532. We determined that the Department overpaid federal expenditures associated with this area of compliance requirements. Context: We tested sixty individuals to ensure they were eligible for adoption assistance. We determined the Department did not terminate benefits timely for one of the sixty individuals. Prior Year Single Audit Finding Numbers: Not applicable Recommendation: We recommend the Department strengthen internal controls to ensure that individuals are removed from the program when deemed ineligible. Views of responsible officials and planned corrective actions: See management’s response on page 196.

Corrective Action Plan

The South Carolina Department of Social Services (SCDSS) respectfully submits the following corrective action plan for the year ended June 30, 2025, on behalf of the State of South Carolina. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAM AUDIT U.S. Department of Health and Human Services Adoption Assistance – Assistance Listing No. 93.659 Disposition of Audit Finding: The SCDSS concurs with the audit finding. Corrective Action: The program will work with IT to establish a notification method sent to State Office Adoptions when a foster care maintenance payment and an adoption subsidy payment are being paid for the benefit of a child at the same time. This will allow State Office Adoptions to be able to research whether the adoption subsidy payment needs to be terminated, adjusted, or if the adoptive parent must submit proof of support for the child. Anticipated Completion Date: December 31, 2026 Names of the contact persons responsible for corrective action: • Melissa S. Lowe at 803-898-7194

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2025-025
Eligibility
SIGNIFICANT DEFICIENCYOTHER MATTERS

The Department approved inappropriate eligibility criteria documentation. Cause: The Department reviewed and approved inappropriate documentation that determines program eligibility. Effect: The Department could inappropriately deem individuals eligible. Questioned Costs: None. There were no federal expenditures associated with this area of compliance. Context: We tested sixty individuals against program eligibility requirements. We determined the Department approved inappropriate eligibility determination checklists for three of sixty individuals Prior Year Single Audit Finding Numbers: Not applicable Recommendation: We recommend the Department strengthen its internal control procedures to ensure individuals are deemed eligible using appropriate eligibility criteria. Views of responsible officials and planned corrective actions: See management’s response on page 197.

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2025 – 025. Eligibility Federal Agencies: Department of Health and Human Services Federal Program Titles: Adoption Assistance Assistance Listings: 93.659 Federal Grant ID Numbers: Various Pass-Through Entity: Not applicable Award Period: Various Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: 2 CFR § 200.303 requires that the recipient and subrecipient establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms of conditions of the federal award. Condition: The Department approved inappropriate eligibility criteria documentation. Cause: The Department reviewed and approved inappropriate documentation that determines program eligibility. Effect: The Department could inappropriately deem individuals eligible. Questioned Costs: None. There were no federal expenditures associated with this area of compliance. Context: We tested sixty individuals against program eligibility requirements. We determined the Department approved inappropriate eligibility determination checklists for three of sixty individuals Prior Year Single Audit Finding Numbers: Not applicable Recommendation: We recommend the Department strengthen its internal control procedures to ensure individuals are deemed eligible using appropriate eligibility criteria. Views of responsible officials and planned corrective actions: See management’s response on page 197.

Corrective Action Plan

The South Carolina Department of Social Services (SCDSS) respectfully submits the following corrective action plan for the year ended June 30, 2025, on behalf of the State of South Carolina. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAM AUDIT U.S. Department of Health and Human Services Adoption Assistance – Assistance Listing No. 93.659 Disposition of Audit Finding: The SCDSS concurs with the audit finding. Corrective Action: As of July 1, 2024, all children are considered applicable no matter their age. Due to this change, there is only one eligibility determination form to be completed. The department has archived the non-applicable form, and it is no longer accessible to the Regional Staff. Anticipated Completion Date: Completed Names of the contact persons responsible for corrective action: • Melissa S. Lowe at 803-898-7194

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2025-026
Reporting
SIGNIFICANT DEFICIENCYREPEAT OF 2024-019, 2024-020OTHER MATTERS

The Department did not report accurate financial information to the federal reporting agency. Cause: The Department did not fully implement the corrective action associated with this finding from the prior year. Effect: The Department reported inaccurate financial information to the federal reporting agency. Questioned Costs: None. We did not question any costs, the costs were only reported incorrectly. Context: In two of the six SF-425 reports (FFR) tested, the Department failed to report the accurate amount of expenditures either through not matching cash receipts and disbursements, not drawing upon the appropriate information from the general ledger, or failing to provide the general ledger detail to substantiate reported costs. In one of the five ORR-2 reports tested, the Department failed to report the accurate amount of expenses for administrative costs (Refugee Cash Assistance (RCA) and Refugee Medical Assistance (RMA) Administration). This took place because the underlying general ledger had an error that caused RCA and RMA administrative costs to have a credit balance. The Department appeared to make an adjustment to take from overall expenditures to eliminate the credit balances, resulting in a second layer of errors. In two of the six FFATA reports submitted, the report was not submitted by the designated deadline. Prior Year Single Audit Finding Numbers: 2024-019 and 2024-020 Recommendation: We recommend the Department strengthen its internal controls to ensure all reports are accurately prepared and submitted by the appropriate deadline. Views of responsible officials and planned corrective actions: See management’s response on page 197.

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2025 – 026. Reporting Federal Agencies: Department of Health and Human Services Federal Program Titles: Refugee and Entrant Assistance-State/Replacement Designee Administered Programs Assistance Listings: 93.566 Federal Grant ID Numbers: 2201SCRSSS & 2401SCRSSS Pass-Through Entity: Not applicable Award Period: October 1, 2022 through September 30, 2025 Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: 2 CFR § 200.303(a) requires that the recipient and subrecipient establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. 2 CFR § 170 Appendix A requires that recipients of grants or cooperative agreements report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act (FFATA) Subaward Reporting System (FSRS) no later than the end of the month following the month in which the obligation was made. Condition: The Department did not report accurate financial information to the federal reporting agency. Cause: The Department did not fully implement the corrective action associated with this finding from the prior year. Effect: The Department reported inaccurate financial information to the federal reporting agency. Questioned Costs: None. We did not question any costs, the costs were only reported incorrectly. Context: In two of the six SF-425 reports (FFR) tested, the Department failed to report the accurate amount of expenditures either through not matching cash receipts and disbursements, not drawing upon the appropriate information from the general ledger, or failing to provide the general ledger detail to substantiate reported costs. In one of the five ORR-2 reports tested, the Department failed to report the accurate amount of expenses for administrative costs (Refugee Cash Assistance (RCA) and Refugee Medical Assistance (RMA) Administration). This took place because the underlying general ledger had an error that caused RCA and RMA administrative costs to have a credit balance. The Department appeared to make an adjustment to take from overall expenditures to eliminate the credit balances, resulting in a second layer of errors. In two of the six FFATA reports submitted, the report was not submitted by the designated deadline. Prior Year Single Audit Finding Numbers: 2024-019 and 2024-020 Recommendation: We recommend the Department strengthen its internal controls to ensure all reports are accurately prepared and submitted by the appropriate deadline. Views of responsible officials and planned corrective actions: See management’s response on page 197.

Corrective Action Plan

The South Carolina Department of Social Services (SCDSS) respectfully submits the following corrective action plan for the year ended June 30, 2025, on behalf of the State of South Carolina. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAM AUDIT U.S. Department of Health and Human Services Refugee and Entrant Assistance – Assistance Listing No. 93.566 Disposition of Audit Finding: The SCDSS concurs with the audit finding. Corrective Action: The Department now has controls in place for a more in-depth review by the Grants Accounting Manager of federal reporting to ensure expenditures and cash receipts are reported accurately on the SF-425 reports. The Department has established training for grants accountant staff and an internal tracking log to track subawards issued to ensure FFATA submissions to SAM.gov within the required timeframe. This process was implemented on July 1, 2025. Anticipated Completion Date: Completed Names of the contact persons responsible for corrective action: • Courtney Hogue, Controller at 803-898-7488 • Hiba Khalaf, Grants Accounting Manager at 803-898-7484

Prior Finding References

2024-019, 2024-020

About Reporting →
2025-027
Subrecipient Monitoring
MATERIAL WEAKNESSMODIFIED OPINIONREPEAT OF 2024-021

The Department did not maintain the subrecipient monitoring and did not comply with federal subrecipient monitoring requirements. Cause: The Department has not fully implemented the corrective action associated with this finding from the prior year. Effect: The Department is not in compliance with federal subrecipient monitoring requirements. Questioned Costs: None, as the finding relates to monitoring and not unallowable expenditures. Context: The checklists were not maintained, and the Department could not provide the completed checklist to demonstrate monitoring of any subrecipients during FY 2025. For one subrecipient, the Department did not provide documentation to demonstrate that a verification was performed to confirm the subrecipient was not excluded or disqualified. Additionally, the Department failed to evaluate subrecipients for risks, create a monitoring plan that considered those risks, or sufficiently monitor and address the audit findings of the subrecipient. Prior Year Single Audit Finding Number: 2024-021 Recommendation: We recommend the Department continue its efforts to strengthen their current policies and procedures and to ensure that the subrecipient monitoring checklist is being completed and maintained. Views of responsible officials and planned corrective actions: See management’s response on page 198.

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2025-027. Subrecipient Monitoring Federal Agencies: Department of Health and Human Services Federal Program Titles: Refugee and Entrant Assistance-State/Replacement Designee Administered Programs Assistance Listings: 93.566 Federal Grant ID Numbers: 2201SCRSSS & 2401SCRSSS Pass-Through Entity: Not applicable Award Period: October 1, 2022 through September 30, 2025 Type of Finding: Material weakness in internal control over compliance, material noncompliance Criteria: 2 CFR § 200.303(a) requires that the recipient and subrecipient establish and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. 2 CFR § 200.332(c) requires that all pass-through entities evaluate each subrecipient's fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring. 2 CFR § 200.332(e) requires that all pass-through entities monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. Condition: The Department did not maintain the subrecipient monitoring and did not comply with federal subrecipient monitoring requirements. Cause: The Department has not fully implemented the corrective action associated with this finding from the prior year. Effect: The Department is not in compliance with federal subrecipient monitoring requirements. Questioned Costs: None, as the finding relates to monitoring and not unallowable expenditures. Context: The checklists were not maintained, and the Department could not provide the completed checklist to demonstrate monitoring of any subrecipients during FY 2025. For one subrecipient, the Department did not provide documentation to demonstrate that a verification was performed to confirm the subrecipient was not excluded or disqualified. Additionally, the Department failed to evaluate subrecipients for risks, create a monitoring plan that considered those risks, or sufficiently monitor and address the audit findings of the subrecipient. Prior Year Single Audit Finding Number: 2024-021 Recommendation: We recommend the Department continue its efforts to strengthen their current policies and procedures and to ensure that the subrecipient monitoring checklist is being completed and maintained. Views of responsible officials and planned corrective actions: See management’s response on page 198.

Corrective Action Plan

The South Carolina Department of Social Services (SCDSS) respectfully submits the following corrective action plan for the year ended June 30, 2025, on behalf of the State of South Carolina. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAM AUDIT U.S. Department of Health and Human Services Refugee and Entrant Assistance – Assistance Listing No. 93.566 Disposition of Audit Finding: The SCDSS concurs with the audit finding. Corrective Action: The Refugee Resettlement Program (RRP) will implement a semiannual subrecipient monitoring process conducted by the State Refugee Coordinator and Refugee Contract Monitor. Monitoring activities will utilize standardized checklists aligned with the Code of Federal Regulations governing the Refugee Support Services (RSS) Program, including requirements under Assistance Listing 93.566. All documentation and follow-up actions will be maintained to ensure compliance with federal and state requirements and to support ongoing program integrity. Anticipated Completion Date: May 1, 2026 Names of the contact persons responsible for corrective action: • Ambrea Jones, State Refugee Coordinator at 803-898-7303

Prior Finding References

2024-021

About Subrecipient Monitoring →
2025-028
Eligibility
SIGNIFICANT DEFICIENCYREPEAT OF 2024-018QUESTIONED COSTSOTHER MATTERS

The Department did not maintain controls over eligibility for this program, forms necessary for determining eligibility were not appropriately completed, forms completed were not completed in a timely fashion. Cause: The Department did not develop a control with a 100% implementation target and is utilizing un-auditable stop-gap measures such as live documents to facilitate processing of program participant applications. Effect: The Department’s system can fail to catch errors in each applicant’s application or payments and has resulted in overcharging grants. Questioned Costs: $15,126. Payments to program participants with control findings. Context: The following discrepancies were encountered during our testing of forty-nine case files. • The Department did not have a preventive control to ensure all RCA eligibility criteria were reviewed, as the existing Quality Assurance Checklist was not designated to check all cases or be timely. • In the files of thirty-eight, the Authorization of Refugee Cash Assistance Payment (Form 1325) was not signed until after it had been approved and payments had already been issued, and for six cases, the form was either not dated or had no sign-offs at all. • We noted that applicant reviews and aid amount authorizations for the Refugee Employment Services Registration/Participation Status form and the Notification of Eligibility Determination for Refugee Resettlement Program form (Forms 1324 and 1326, respectively) were completed after applicants had already begun receiving aid, resulting in grant overcharges. • In forty-one cases, the employment service provider did not return Part II of the Form 1324, which, according to the form instructions, must be submitted prior to approval of RCA benefits. • In one case, Form 1326 did not specify the date on which participant payments would end, which is needed to evaluate compliance with the eligibility period. Prior Year Single Audit Finding Number: 2024-018 Recommendation: We recommend the Department continue its efforts to strengthen their current policies and procedures and to ensure that all RCA applicants are reviewed with the quality assurance audit checklist and that all appropriate forms are signed, dated, and reviewed in a timely manner. Views of responsible officials and planned corrective actions: See management’s response on page 198.

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2025 – 028. Eligibility – Refugee Cash Assistance (RCA) Federal Agencies: Department of Health and Human Services Federal Program Titles: Refugee and Entrant Assistance-State/Replacement Designee Administered Programs Assistance Listings: 93.566 Federal Grant ID Numbers: 2201SCRCMA & 2401SCRCMA Pass-Through Entity: Not applicable Award Period: October 1, 2021 through September 30, 2025 Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: 2 CFR § 200.303(a) requires that the recipient and subrecipient establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statues, regulations, and the terms and conditions of the Federal award. The Standards for Internal Control in the Federal Government (the Green Book) as issued by the Comptroller General of the United States emphasize that "The effectiveness of a detective control activity depends on timeliness" (10.10) and when detective controls are employed "management strengthens and expedites detective control activities and may also expedite monitoring activities to enable the entity to effectively mitigate the risk to acceptable levels" (10.13). Condition: The Department did not maintain controls over eligibility for this program, forms necessary for determining eligibility were not appropriately completed, forms completed were not completed in a timely fashion. Cause: The Department did not develop a control with a 100% implementation target and is utilizing un-auditable stop-gap measures such as live documents to facilitate processing of program participant applications. Effect: The Department’s system can fail to catch errors in each applicant’s application or payments and has resulted in overcharging grants. Questioned Costs: $15,126. Payments to program participants with control findings. Context: The following discrepancies were encountered during our testing of forty-nine case files. • The Department did not have a preventive control to ensure all RCA eligibility criteria were reviewed, as the existing Quality Assurance Checklist was not designated to check all cases or be timely. • In the files of thirty-eight, the Authorization of Refugee Cash Assistance Payment (Form 1325) was not signed until after it had been approved and payments had already been issued, and for six cases, the form was either not dated or had no sign-offs at all. • We noted that applicant reviews and aid amount authorizations for the Refugee Employment Services Registration/Participation Status form and the Notification of Eligibility Determination for Refugee Resettlement Program form (Forms 1324 and 1326, respectively) were completed after applicants had already begun receiving aid, resulting in grant overcharges. • In forty-one cases, the employment service provider did not return Part II of the Form 1324, which, according to the form instructions, must be submitted prior to approval of RCA benefits. • In one case, Form 1326 did not specify the date on which participant payments would end, which is needed to evaluate compliance with the eligibility period. Prior Year Single Audit Finding Number: 2024-018 Recommendation: We recommend the Department continue its efforts to strengthen their current policies and procedures and to ensure that all RCA applicants are reviewed with the quality assurance audit checklist and that all appropriate forms are signed, dated, and reviewed in a timely manner. Views of responsible officials and planned corrective actions: See management’s response on page 198.

Corrective Action Plan

The South Carolina Department of Social Services (SCDSS) respectfully submits the following corrective action plan for the year ended June 30, 2025, on behalf of the State of South Carolina. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAM AUDIT U.S. Department of Health and Human Services Refugee and Entrant Assistance – Assistance Listing No. 93.566 Disposition of Audit Finding: The SCDSS concurs with the audit finding. Corrective Action: The South Carolina Department of Social Services (SCDSS) has formally implemented the Refugee Information Management System (RIMS), the agency’s case management system for the Refugee Resettlement Program. RIMS supports timely processing of Refugee Cash Assistance (RCA) applications and maintains essential program data for individuals applying for refugee benefits. RIMS includes automated, time-sensitive reminders to ensure case managers and eligibility specialists meet the 30-day federal requirement for RCA application processing and determination, prompt generation of required forms at approval, and ensure timely completion of employment services registration or documentation of non-participation with good cause within 30 days of aid approval. Implementation of RIMS will enhance program accuracy, reduce processing delays, and support compliance with federal regulations and agency policies. Anticipated Completion Date: October 1, 2026 Names of the contact persons responsible for corrective action: • Ambrea Jones, State Refugee Coordinator at 803-898-7303

Prior Finding References

2024-018

About Eligibility →
2025-029
Eligibility
MATERIAL WEAKNESSMODIFIED OPINIONREPEAT OF 2024-018QUESTIONED COSTS

The South Carolina Department of Health and Human Services (SCDHHS), a partnering state agency contracted by the Department to perform eligibility determinations, did not remove higher education students from the RMA system or terminate benefits after the one-year eligibility period expired. Cause: SCDHHS did not collect the information noted and the Department lacked sufficient oversight of SCDHHS’s eligibility determinations and removal of ineligible participants. Effect: Overcharging federal grants can occur through either payments past their eligible period or payments to individuals who never were eligible. Questioned Costs: $1,923 based upon the total amount of ineligible payments identified in testing. It is known that these participants received additional amounts inappropriately in other months and periods but the scope of these could not be determined. Context: Out of the eleven cases selected for testing, we noted the following: • One individual was a child eligible for another federal funded cash assistance program but was assigned to RMA. • There is no current process to identify and disallow applicants enrolled in higher education. • Four program participants were given assistance beyond the twelve-month eligibility period. Prior Year Single Audit Finding Number: 2024-018 Recommendation: We recommend the Department ensure that partnering Departments are checking for the appropriate information to exclude ineligible program participants and to take participants off the program when their eligible period has ended. Views of responsible officials and planned corrective actions: See management’s response on page 199.

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2025 – 029. Eligibility – Refugee Medical Assistance (RMA) Federal Agencies: Department of Health and Human Services Federal Program Titles: Refugee and Entrant Assistance-State/Replacement Designee Administered Programs Assistance Listings: 93.566 Federal Grant ID Numbers: 2201SCRCMA & 2401SCRCMA Pass-Through Entity: Not applicable Award Period: October 1, 2021 through September 30, 2025 Type of Finding: Material weakness in internal control over compliance, material noncompliance Criteria: 45 CFR § 400.100 requires that recipients of RMA payments are not full-time students in institutions of higher education, as defined by the Director, except where such enrollment is approved by the State, or its designee, as part of an individual employability plan for a refugee under § 400.79 of this part or a plan for an unaccompanied minor in accordance with § 400.112. 45 CFR § 400.100 also requires that the RMA eligibility only applies during a period of time to be determined by the Director in accordance with § 400.112. Condition: The South Carolina Department of Health and Human Services (SCDHHS), a partnering state agency contracted by the Department to perform eligibility determinations, did not remove higher education students from the RMA system or terminate benefits after the one-year eligibility period expired. Cause: SCDHHS did not collect the information noted and the Department lacked sufficient oversight of SCDHHS’s eligibility determinations and removal of ineligible participants. Effect: Overcharging federal grants can occur through either payments past their eligible period or payments to individuals who never were eligible. Questioned Costs: $1,923 based upon the total amount of ineligible payments identified in testing. It is known that these participants received additional amounts inappropriately in other months and periods but the scope of these could not be determined. Context: Out of the eleven cases selected for testing, we noted the following: • One individual was a child eligible for another federal funded cash assistance program but was assigned to RMA. • There is no current process to identify and disallow applicants enrolled in higher education. • Four program participants were given assistance beyond the twelve-month eligibility period. Prior Year Single Audit Finding Number: 2024-018 Recommendation: We recommend the Department ensure that partnering Departments are checking for the appropriate information to exclude ineligible program participants and to take participants off the program when their eligible period has ended. Views of responsible officials and planned corrective actions: See management’s response on page 199.

Corrective Action Plan

The South Carolina Department of Social Services (SCDSS) respectfully submits the following corrective action plan for the year ended June 30, 2025, on behalf of the State of South Carolina. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAM AUDIT U.S. Department of Health and Human Services Refugee and Entrant Assistance – Assistance Listing No. 93.566 Disposition of Audit Finding: The SCDSS concurs with the audit finding. Corrective Action: SCDSS will collaborate closely with SCDHHS to ensure eligibility policies and procedures for the Refugee Medical Assistance (RMA) program clearly and accurately define program eligibility requirements. SCDSS will also ensure that staff responsible for processing RMA applications receive appropriate training to apply these policies consistently and correctly. To support ongoing compliance, SCDSS will implement a quarterly monitoring plan designed to identify any individuals incorrectly categorized under RMA. SCDSS will maintain continuous communication and follow-up with SCDHHS to verify timely implementation of these corrective actions and to address any issues that arise. Anticipated Completion Date: July 1, 2026 Names of the contact persons responsible for corrective action: • Ambrea Jones, State Refugee Coordinator at 803-898-7303 • Brittney White, State Refugee Health Coordinator at 803-898-7545

Prior Finding References

2024-018

About Eligibility →
2025-030
Activities Allowed or Unallowed / Cost Allowability
MATERIAL WEAKNESSMODIFIED OPINIONREPEAT OF 2024-017QUESTIONED COSTS

Expenditures charged to the program were not adequately supported or were inappropriate. Cause: The Department did not maintain appropriate review and approval controls over program participant payments to RCA and RMA participants nor over invoice payments to subrecipients. Effect: The federal grants were overcharged through payments for unallowable costs or reimbursing ineligible program participants. Questioned Costs: $876,636. Payments for insufficiently reviewed invoices or to ineligible program participants Context: We identified several payments made to subrecipients that the Department did not review nor did the Department retain documentation at the appropriate level of detail to support the allowability of the costs. We noted that the Department did not have the details on RMA program participants (determined and paid via the South Carolina Department of Health and Human Services) sufficient to verify that the payments were allowable. Multiple ineligible payments were made (see finding 2025-029). Prior Year Single Audit Finding Number: 2024-017 Recommendation: We recommend that the Department ensure appropriate controls over subrecipient payments and payments to program participants. Views of responsible officials and planned corrective actions: See management’s response on page 200.

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2025 – 030. Activities Allowed or Unallowed & Allowable Costs/Cost Principles Federal Agencies: Department of Health and Human Services Federal Program Titles: Refugee and Entrant Assistance-State/Replacement Designee Administered Programs Assistance Listings: 93.566 Federal Grant ID Numbers: 2201SCRCMA, 2401SCRCMA, 2201SCRSSS & 2401SCRSSS Pass-Through Entity: Not applicable Award Period: October 1, 2021 through September 30, 2025 Type of Finding: Material weakness in internal control over compliance, material noncompliance Criteria: 2 CFR § 200.303(a) requires that the recipient and subrecipient establish and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: Expenditures charged to the program were not adequately supported or were inappropriate. Cause: The Department did not maintain appropriate review and approval controls over program participant payments to RCA and RMA participants nor over invoice payments to subrecipients. Effect: The federal grants were overcharged through payments for unallowable costs or reimbursing ineligible program participants. Questioned Costs: $876,636. Payments for insufficiently reviewed invoices or to ineligible program participants Context: We identified several payments made to subrecipients that the Department did not review nor did the Department retain documentation at the appropriate level of detail to support the allowability of the costs. We noted that the Department did not have the details on RMA program participants (determined and paid via the South Carolina Department of Health and Human Services) sufficient to verify that the payments were allowable. Multiple ineligible payments were made (see finding 2025-029). Prior Year Single Audit Finding Number: 2024-017 Recommendation: We recommend that the Department ensure appropriate controls over subrecipient payments and payments to program participants. Views of responsible officials and planned corrective actions: See management’s response on page 200.

Corrective Action Plan

The South Carolina Department of Social Services (SCDSS) respectfully submits the following corrective action plan for the year ended June 30, 2025, on behalf of the State of South Carolina. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAM AUDIT U.S. Department of Health and Human Services Refugee and Entrant Assistance – Assistance Listing No. 93.566 Disposition of Audit Finding: The SCDSS concurs with the audit finding. Corrective Action: SCDSS now has direct access to SCDHHS’s Curam eligibility system, enabling the agency to review individuals categorized under Refugee Medical Assistance (RMA) and ensure they do not remain in the category beyond the federally mandated four-month eligibility period. This access allows SCDSS to verify that no program expenditures are issued for individuals who exceed the allowable timeframe. SCDSS also receives a monthly detailed expense report and invoice from both RSS and RMA subrecipients, which provide documentation sufficient to validate that all expenditures are appropriate and properly attributable to individuals eligible. This report will be used to reconcile payments and confirm alignment between eligibility records and financial activity. Anticipated Completion Date: July 1, 2026 Names of the contact persons responsible for corrective action: • Ambrea Jones, State Refugee Coordinator at 803-898-7303 • Brittney White, State Refugee Health Coordinator at 803-898-7545

Prior Finding References

2024-017

About Activities Allowed or Unallowed, Allowable Costs / Cost Principles →
2025-031
Period of Performance
SIGNIFICANT DEFICIENCYQUESTIONED COSTSOTHER MATTERS

Expenditures were incurred after the end of the grant’s period of performance. Cause: The Department’s internal controls failed to identify and prevent charging costs incurred outside the applicable period of performance. Effect: Costs charged outside the period of performance may not be allowable. Questioned Costs: $11 is based on the sum of the three transactions that incurred program expenditures that were outside of the period of performance Context: Three of sixty expenditure transactions tested had incurred program expenditures at the end of the obligation period that were not obligated and expended in accordance with program requirements. Prior Year Single Audit Finding Number: Not applicable Recommendation: We recommend the Department review and update internal controls to ensure all expenditures charged to federal awards are incurred within the grant's period of performance. Views of responsible officials and planned corrective actions: See management’s response on page 200.

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2025 – 031. Period of Performance Federal Agency: Department of Health and Human Services Federal Program Title: CCDF Cluster Assistance Listing: 93.575, 93.596, and 93.489 Federal Grant ID Number: 2201SCCCDD Pass-Through Entity: Not applicable Award Period: October 1, 2021, through September 30, 2024 Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: 45 CFR § 98.60(d)(1) requires that discretionary funds (Assistance Listing 93.575) be obligated in the fiscal year in which funds are awarded or in the succeeding fiscal year. Unliquidated obligations as of the end of the succeeding fiscal year shall be liquidated within one year. 2 CFR § 200.303 requires that the recipient and subrecipient establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations and the terms and conditions of the federal award. 2 CFR § 200.403(h) requires costs be incurred during the approved budget period. Condition: Expenditures were incurred after the end of the grant’s period of performance. Cause: The Department’s internal controls failed to identify and prevent charging costs incurred outside the applicable period of performance. Effect: Costs charged outside the period of performance may not be allowable. Questioned Costs: $11 is based on the sum of the three transactions that incurred program expenditures that were outside of the period of performance Context: Three of sixty expenditure transactions tested had incurred program expenditures at the end of the obligation period that were not obligated and expended in accordance with program requirements. Prior Year Single Audit Finding Number: Not applicable Recommendation: We recommend the Department review and update internal controls to ensure all expenditures charged to federal awards are incurred within the grant's period of performance. Views of responsible officials and planned corrective actions: See management’s response on page 200.

Corrective Action Plan

The South Carolina Department of Social Services (SCDSS) respectfully submits the following corrective action plan for the year ended June 30, 2025, on behalf of the State of South Carolina. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAM AUDIT U.S. Department of Health and Human Services Child Care and Development Fund (CCDF) Cluster – Assistance Listing No. 93.575, 93.596, and 93.489 Disposition of Audit Finding: The SCDSS concurs with the audit finding. Corrective Action: The Department is in the process of closing grants within the accounting system to prevent system-generated payroll expenses from posting after the grant period of performance has ended. This control ensures that payroll charges are restricted to the allowable grant period. Anticipated Completion Date: December 31, 2026 Names of the contact persons responsible for corrective action: • Courtney Hogue, Controller at 803-898-7488 • Hiba Khalaf, Grants Accounting Manager at 803-898-7484

About Period of Performance →
2025-032
Reporting
SIGNIFICANT DEFICIENCYOTHER MATTERS

The Department did not report accurate financial information to the federal reporting agency. Cause: The Department's internal control failed to ensure retention of documentation. Effect: The Department could fail to appropriately report the FFATA. Questioned Costs: None. There were no federal expenditures associated with this area of compliance. Context: In our testing of the four subrecipients, it was determined that the department could not provide the FFATA submission documentation for one of them. Prior Year Single Audit Finding Numbers: Not applicable Recommendation: We recommend that the Department strengthen its internal controls to ensure that FFATA reports are submitted and documented appropriately. Views of responsible officials and planned corrective actions: See management’s response on page 201.

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2025 – 032. Reporting Federal Agencies: Department of Health and Human Services Federal Program Titles: CCDF Cluster Assistance Listings: 93.575 Federal Grant ID Numbers: 2302SCCCDD & 2402SCCCDD Pass-Through Entity: Not applicable Award Period: Various Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: 2 CFR § 170 Appendix A requires that recipients of grants or cooperative agreements report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act (FFATA) Subaward Reporting System (FSRS) no later than the end of the month following the month in which the obligation was made. 2 CFR § 200.303(a) requires that the recipient and subrecipient must establish and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms of conditions of the federal award. Condition: The Department did not report accurate financial information to the federal reporting agency. Cause: The Department's internal control failed to ensure retention of documentation. Effect: The Department could fail to appropriately report the FFATA. Questioned Costs: None. There were no federal expenditures associated with this area of compliance. Context: In our testing of the four subrecipients, it was determined that the department could not provide the FFATA submission documentation for one of them. Prior Year Single Audit Finding Numbers: Not applicable Recommendation: We recommend that the Department strengthen its internal controls to ensure that FFATA reports are submitted and documented appropriately. Views of responsible officials and planned corrective actions: See management’s response on page 201.

Corrective Action Plan

The South Carolina Department of Social Services (SCDSS) respectfully submits the following corrective action plan for the year ended June 30, 2025, on behalf of the State of South Carolina. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAM AUDIT U.S. Department of Health and Human Services Child Care and Development Fund (CCDF) Cluster – Assistance Listing No.93.575 Disposition of Audit Finding: The SCDSS concurs with the audit finding. Corrective Action: The Department has established training for grants accountant staff and an internal tracking log to track subawards issued to ensure FFATA submissions to SAM.gov within the required timeframe. This process was implemented on July 1,2025 Anticipated Completion Date: Completed Names of the contact persons responsible for corrective action: • Courtney Hogue, Controller at 803-898-7488 • Hiba Khalaf, Grants Accounting Manager at 803-898-7484

About Reporting →
2025-033
Matching, Level of Effort, Earmarking / Reporting
SIGNIFICANT DEFICIENCYOTHER MATTERS

The Department did not ensure four key line-items were accurately reported on the financial report. Cause: The Department's internal controls failed to prevent inaccurate reporting of expenditures. Effect: The accuracy of the financial report could not be validated. Questioned Costs: None. We did not question any costs, the costs were only reported incorrectly. Context: In our testing of four key line-items, it was determined that the department miscategorized transactions when grouping the line-item totals on the report. Prior Year Single Audit Finding Numbers: Not applicable Recommendation: We recommend the Department strengthen its internal controls to ensure all reports are accurately prepared and submitted. Views of responsible officials and planned corrective actions: See management’s response on page 201.

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2025 – 033. Reporting and Earmarking Federal Agencies: Department of Health and Human Services Federal Program Titles: CCDF Cluster Assistance Listings: 93.575 and 93.596 Federal Grant ID Numbers: 2201SCCCDD and 2201SCCCDF Pass-Through Entity: Not applicable Award Period: October 1, 2021, through September 30, 2024 Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: 2 CFR § 200.303(a) requires that the recipient and subrecipient must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms of conditions of the federal award. 45 CFR § 98.50(f) requires that the Lead Agency shall: (1) Reserve the minimum amount required under paragraph (b) of section 45 CFR § 98.50 for quality activities, and the funds for administrative costs described at paragraph (d) of section 45 CFR § 98.50; and (2) From the remainder, use not less than 70 percent to fund direct services (provided by the Lead Agency). Condition: The Department did not ensure four key line-items were accurately reported on the financial report. Cause: The Department's internal controls failed to prevent inaccurate reporting of expenditures. Effect: The accuracy of the financial report could not be validated. Questioned Costs: None. We did not question any costs, the costs were only reported incorrectly. Context: In our testing of four key line-items, it was determined that the department miscategorized transactions when grouping the line-item totals on the report. Prior Year Single Audit Finding Numbers: Not applicable Recommendation: We recommend the Department strengthen its internal controls to ensure all reports are accurately prepared and submitted. Views of responsible officials and planned corrective actions: See management’s response on page 201.

Corrective Action Plan

The South Carolina Department of Social Services (SCDSS) respectfully submits the following corrective action plan for the year ended June 30, 2025, on behalf of the State of South Carolina. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAM AUDIT U.S. Department of Health and Human Services Child Care and Development Fund (CCDF) Cluster – Assistance Listing No. 93.575 and 93.596 Disposition of Audit Finding: The SCDSS concurs with the audit finding. Corrective Action: The Department now has controls in place for a more in-depth review by the Grants Accounting Manager of federal reporting to ensure expenditures are reported accurately on the Federal ACF 696 Form. Anticipated Completion Date: Completed Names of the contact persons responsible for corrective action: • Courtney Hogue, Controller at 803-898-7488 • Hiba Khalaf, Grants Accounting Manager at 803-898-7484

About Matching, Level of Effort, Earmarking, Reporting →
2025-034
Eligibility
SIGNIFICANT DEFICIENCYOTHER MATTERS

The Department was unable to provide documentation to verify seven institutions were notified of approval or disapproval within thirty calendar days of the State agency's receipt of a completed application. Cause: Internal controls failed to ensure that subrecipients were notified of approval/disapproval. Effect: Without adequate controls in place, the Department will not be in compliance with eligibility requirements. Questioned Costs: None. There were no federal expenditures associated when testing this area of compliance. Context: The Department could not provide supporting documentation that seven out of sixty subrecipients tested received notification of approval/disapproval within thirty calendar days of completion of application. Prior Year Single Audit Finding Number: Not Applicable Recommendation: We recommend the Department strengthen controls to ensure that documentation exists that subrecipients were notified of approval/disapproval. Views of responsible officials and planned corrective actions: See management’s response on page 201.

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2025 – 034. Eligibility Federal Agency: Department of Agriculture Federal Program Title: Child and Adult Care Food Program Assistance Listing: 10.558 Federal Grant ID Number: 5SC300329 Pass-Through Entity: Not Applicable Award Period: October 1, 2023, through September 30, 2025 Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: Per 7 CFR 226.6(b)(3), any new or renewing institution applying for participation in the Program must be notified in writing of approval or disapproval by the State agency, within thirty calendar days of the State agency's receipt of a complete application. 2 CFR § 200.303 requires that the recipient and subrecipient establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: The Department was unable to provide documentation to verify seven institutions were notified of approval or disapproval within thirty calendar days of the State agency's receipt of a completed application. Cause: Internal controls failed to ensure that subrecipients were notified of approval/disapproval. Effect: Without adequate controls in place, the Department will not be in compliance with eligibility requirements. Questioned Costs: None. There were no federal expenditures associated when testing this area of compliance. Context: The Department could not provide supporting documentation that seven out of sixty subrecipients tested received notification of approval/disapproval within thirty calendar days of completion of application. Prior Year Single Audit Finding Number: Not Applicable Recommendation: We recommend the Department strengthen controls to ensure that documentation exists that subrecipients were notified of approval/disapproval. Views of responsible officials and planned corrective actions: See management’s response on page 201.

Corrective Action Plan

The South Carolina Department of Social Services (SCDSS) respectfully submits the following corrective action plan for the year ended June 30, 2025, on behalf of the State of South Carolina. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAM AUDIT U.S. Department of Health and Human Services Child and Adult Care Food Program – Assistance Listing No. 10.558 Disposition of Audit Finding: The SCDSS concurs with the audit finding. Corrective Action: SC CACFP staff has reviewed USDA CACFP Federal Regulation 7 CFR 226.6(b)(3) and 2 CFR 200.303 regarding notifying new and renewing institutions applying of the approval or disapproval by the State agency. Additional training will be provided to staff processing CACFP applications. State agency staff reviewing applications for approval will monitor the SC CACFP Online Application Dashboard and emails for pending final approvals for CACFP Applications and will complete the approval or denial within 30 days of the pending final approval date. Anticipated Completion Date: March 31, 2026 Names of the contact persons responsible for corrective action: • Greta F. Avery, CACFP Supervisor at (803) 898-7576 • Dyeretta M. Fashion, CACFP Supervisor at (803) 898-0945 • Mary A. Young, CACFP Manager at (803) 898-0958

About Eligibility →
2025-035
Reporting
SIGNIFICANT DEFICIENCYREPEAT OF 2024-024OTHER MATTERS

Discrepancies existed between the ACF-199 (TANF Data Report) and the Department’s records. The agency did not comply with their approved corrective action plan for formal documentation of report review. Cause: The incorrect source data was utilized when completing the referenced data element on the performance report. Effect: Some of the data fields reported on the ACF-199 report are inconsistent with the supporting case records. Questioned Costs: None. There were no federal expenditures associated when testing this area of compliance. Context: Key data elements for ten families were tested from one quarterly ACF-199 report. A discrepancy was noted for one data element related to recording the number of months countable towards the federal time limit for assistance. This is a repeat finding from the fiscal year 2024 Single Audit. The Department stated on its Summary Schedule of Prior Year Audit Findings that this issue was “Fully Corrected with Previously Reported Correction Action Implemented”. Due to this issue repeating for fiscal year 2025, this issue has not been fully corrected. Prior Year Single Audit Finding Number: 2024-024 Recommendation: We recommend that the Department strengthen its processes to ensure that federal reports are free from error prior to submission. We also recommend that the Department update and review processes to ensure proper documentation of supervisory review is maintained. Views of responsible officials and planned corrective actions: See management’s response on page 202.

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2025 – 035. Reporting Federal Agency: Department of Health and Human Services Federal Program Title: Temporary Assistance for Needy Families Assistance Listing: 93.558 Federal Grant ID Numbers: 2201SCTANF and 2501SCTANF Pass-Through Entity: Not applicable Award Period: Various Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: 45 CFR § 265.7(a) requires that each state's quarterly reports, including the TANF Data Report, be complete and accurate. 2 CFR § 200.303 requires that the recipient and subrecipient establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations and the terms and conditions of the federal award. Condition: Discrepancies existed between the ACF-199 (TANF Data Report) and the Department’s records. The agency did not comply with their approved corrective action plan for formal documentation of report review. Cause: The incorrect source data was utilized when completing the referenced data element on the performance report. Effect: Some of the data fields reported on the ACF-199 report are inconsistent with the supporting case records. Questioned Costs: None. There were no federal expenditures associated when testing this area of compliance. Context: Key data elements for ten families were tested from one quarterly ACF-199 report. A discrepancy was noted for one data element related to recording the number of months countable towards the federal time limit for assistance. This is a repeat finding from the fiscal year 2024 Single Audit. The Department stated on its Summary Schedule of Prior Year Audit Findings that this issue was “Fully Corrected with Previously Reported Correction Action Implemented”. Due to this issue repeating for fiscal year 2025, this issue has not been fully corrected. Prior Year Single Audit Finding Number: 2024-024 Recommendation: We recommend that the Department strengthen its processes to ensure that federal reports are free from error prior to submission. We also recommend that the Department update and review processes to ensure proper documentation of supervisory review is maintained. Views of responsible officials and planned corrective actions: See management’s response on page 202.

Corrective Action Plan

The South Carolina Department of Social Services (SCDSS) respectfully submits the following corrective action plan for the year ended June 30, 2025, on behalf of the State of South Carolina. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAM AUDIT U.S. Department of Health and Human Services Temporary Assistance for Needy Families – Assistance Listing No. 93.558 Disposition of Audit Finding: The SCDSS concurs with the audit finding. Corrective Action: Management will ensure that the discrepancy noted for one data element related to recording the number of months countable toward the federal time limit for assistance is corrected and retransmitted. Management and a lead worker will review 15 to 25 cases per reviewer per month using the form developed that will be completed with each review. The form will be signed by the reviewer, the lead worker, and the Program Coordinator II. If an error is found during the review process, that case will be corrected within 10 days and re-transmitted. Trainings will be conducted monthly to discuss errors and ensure everyone is trained on policies and procedures. Anticipated Completion Date: June 30,2026 Names of the contact persons responsible for corrective action: • Kimberly Boyd, Program Coordinator II at 803-898-7590 • Michelle Harley, Lead Worker at 803-898-7595

Prior Finding References

2024-024

About Reporting →
2025-036
Activities Allowed or Unallowed / Cost Allowability
SIGNIFICANT DEFICIENCYQUESTIONED COSTSOTHER MATTERS

Costs charged to the program were not adequately allocated. Cause: The Office failed to ensure costs were properly allocated based upon the approved cost allocation plan for FY25. Effect: The potential for overcharging the grant exists when costs charged to the federal award are not properly allocated. Questioned Costs: $12,949. The Disaster Relief and Mitigation grants were overcharged by $4,316 and $8,633, respectively. Context: One of twenty-two expenditures tested had costs improperly charged to the federal award. The transaction involved allowable charges that benefited multiple grant programs and activities but were not properly allocated to match the Office’s cost allocation plan for FY25. Prior Year Single Audit Report Finding Number: Not applicable Recommendation: We recommend the Office review and update its procedures to ensure all costs charged to the grant are properly allocated to applicable grants and funding sources based upon their yearly cost allocation plan. Views of responsible officials and planned corrective actions: See management’s response on page 203.

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2025 – 036. Activities Allowed or Unallowed and Allowable Costs/Cost Principles Federal Agency: Department of Housing and Urban Development Federal Program Title: Community Development Block Grants/State's program and Non-Entitlement Grants in Hawaii Assistance Listing: 14.228 Federal Grant ID Number: Various Pass-Through Entity: Not applicable Award Period: Various Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: 2 CFR § 200.405(a) states that a cost is allocable to a 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. 2 CFR § 200.303 requires that the recipient and subrecipient establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations and the terms and conditions of the federal award. Condition: Costs charged to the program were not adequately allocated. Cause: The Office failed to ensure costs were properly allocated based upon the approved cost allocation plan for FY25. Effect: The potential for overcharging the grant exists when costs charged to the federal award are not properly allocated. Questioned Costs: $12,949. The Disaster Relief and Mitigation grants were overcharged by $4,316 and $8,633, respectively. Context: One of twenty-two expenditures tested had costs improperly charged to the federal award. The transaction involved allowable charges that benefited multiple grant programs and activities but were not properly allocated to match the Office’s cost allocation plan for FY25. Prior Year Single Audit Report Finding Number: Not applicable Recommendation: We recommend the Office review and update its procedures to ensure all costs charged to the grant are properly allocated to applicable grants and funding sources based upon their yearly cost allocation plan. Views of responsible officials and planned corrective actions: See management’s response on page 203.

Corrective Action Plan

The Office of Resilience respectfully submits the following corrective action plan for the year ended June 30, 2025, on behalf of the State of South Carolina. The finding from the schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAM AUDIT U.S. Department of Housing and Urban Development 2025-036 Community Development Block Grant – Assistance Listing No. 14.228 Disposition of Audit Finding: The Office of Resilience does not agree this item rises to the level of a finding and could be sufficiently addressed with a recommendation. SCOR acknowledges this process could be improved and will act to better support this transaction going forward. Corrective Action: To provide additional support and clarification on the use of cost allocation percentages, SCOR Finance will create a memo to file each time the cost allocation changes. The current methodology is based on headcount and is subject to change frequently. At the beginning of each quarter, SCOR Finance will recalculate the cost allocation percentage based on agency headcount on the last day of the previous quarter. The quarterly updated allocation percentages will be the basis of allocating agency wide shared costs. A copy of the memo will be attached to the SCEIS payable document as support. Anticipated Completion Date: Immediately. SCOR Finance will go back to the beginning of FY26, recalculate the cost allocation percentages, create the memo to file and post correcting journal entries as needed. Names of the contact persons responsible for corrective action: • Andrew DeRienzo - CFO at 803-422-0092 • Sarah Reynolds – Accounting Manager at 803-896-0038 • Tiffany Frye -Budget Manager at 803-896-6704

About Activities Allowed or Unallowed, Allowable Costs / Cost Principles →
2025-037
Reporting
SIGNIFICANT DEFICIENCYOTHER MATTERS

The Department did not submit FFATA reports on time for FY25. Cause: The Department lacked sufficient internal controls and/or written procedures to ensure FFATA reports were submitted on time. Effect: The Department was not in compliance with FFATA reporting requirements. Questioned Costs: None, as it relates to timely reporting, rather than unallowable expenditures Context: Eight of the forty FFATA reports tested were submitted after the reporting deadline. Prior Year Single Audit Finding Number: Not applicable Recommendation: We recommend that the Department implement procedures to ensure reports are submitted in compliance with FFATA reporting requirements. Views of responsible officials and planned corrective actions: See management’s response on page 204.

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2025 – 037. Reporting Federal Agency: Department of Housing and Urban Development Federal Program Title: Community Development Block Grants/State's program and Non-Entitlement Grants in Hawaii Assistance Listing: 14.228 Federal Grant ID Number: Various Pass-Through Entity: Not applicable Award Period: Various Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: 2 CFR § 170 Appendix A requires that recipients of grants or cooperative agreements report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act (FFATA) Subaward Reporting System. 2 CFR § 200.303 requires that the recipient and subrecipient establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations and the terms and conditions of the federal award. Condition: The Department did not submit FFATA reports on time for FY25. Cause: The Department lacked sufficient internal controls and/or written procedures to ensure FFATA reports were submitted on time. Effect: The Department was not in compliance with FFATA reporting requirements. Questioned Costs: None, as it relates to timely reporting, rather than unallowable expenditures Context: Eight of the forty FFATA reports tested were submitted after the reporting deadline. Prior Year Single Audit Finding Number: Not applicable Recommendation: We recommend that the Department implement procedures to ensure reports are submitted in compliance with FFATA reporting requirements. Views of responsible officials and planned corrective actions: See management’s response on page 204.

Corrective Action Plan

The Department of Commerce respectfully submits the following corrective action plan for the year ended June 30, 2025, on behalf of the State of South Carolina. The finding from the schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAM AUDIT U.S. Department of Housing and Urban Development 2025-037 Community Development Block Grant – Assistance Listing No. 14.228 Disposition of Audit Finding: The Department of Commerce accepts the finding that the FFATA was submitted late. This delay was not the result of inattention or disregard for compliance requirements. Rather, it occurred during a period of significant transition in federal reporting requirements. Specifically, the U.S. Department of Housing and Urban Development (HUD) migrated FFATA reporting to a new platform without providing sufficient implementation guidance to CPD prime recipients, including South Carolina’s State CDBG Program. Compounding this challenge, the HUD Exchange website, previously a primary source of program guidance, was taken offline on July 31, 2024, for redesign and did not relaunch until November 21, 2025, creating a prolonged information gap. During this time, the State CDBG Program relied on communications from the regional HUD Field Office and made inquiries regarding FFATA reporting requirements and system processes. Once the State CDBG Program was informed that the new reporting system was operational and prepared to accept FFATA data, staff promptly followed established internal review protocols and submitted the required information. Corrective Action: The State CDBG Program management will continue to follow program review protocols and will make every attempt to collect update information from the appropriate federal sources, national Community Development organizations (i.e.: COSCDA – Council of State Community Development Agencies) and contract consultants to the State CDBG Program to ensure adherence with federal regulations and reporting deadlines. Anticipated Completion Date: March 1, 2026, CDBG program management has adopted this corrective action plan to ensure timely submission of all required FFATA reporting. South Carolina Department of Commerce contact(s) responsible for corrective action: • Caroline Griffin, Deputy Director – Business Incentives and Community Development (803)737-0472 or cgriffin@sccommerce.com • Lisa Huff, Federal Program Data Manager - Business Incentives and Community Development (803)737-0292 or ehuff@sccommerce.com The Department remains committed to maintaining full compliance with federal reporting requirements and continues `to closely monitor evolving federal guidance to safeguard critical funding for the communities we serve.

About Reporting →
2025-038
Activities Allowed or Unallowed / Cost Allowability
SIGNIFICANT DEFICIENCYREPEAT OF 2024-026OTHER MATTERS

Amounts charged to the program did not agree to the supporting invoices. Cause: The Department’s review process and internal controls did not detect discrepancies between the invoiced amounts and the amounts recorded and charged to the grant. Effect: Program expenditures were not accurately recorded in the Department’s financial records. Questioned Costs: None, as this finding relates to an underpayment. Context: One out of four transactions tested, the amount charged to the Federal program did not agree to the amount reflected on the supporting invoice. The Department recorded and reimbursed an amount that was less than the invoiced amount, resulting in an underpayment totaling $313. This is a repeat finding from the fiscal year 2024 Single Audit. The Office stated on its Summary Schedule of Prior Year Audit Findings that this issue was “Fully Corrected with Previously Reported Corrective Action Implemented”. Due to this issue repeating for fiscal year 2024, this issue has not been fully corrected. Prior Year Single Audit Report Finding Number: 2024-026 Recommendation: We recommend that the Department strengthen controls to ensure the review process includes verification that amounts charged to the grant agree to the supporting invoices prior to reimbursement. Views of responsible officials and planned corrective actions: See management’s response on page 206.

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2025 – 038. Activities Allowed or Unallowed and Allowable Costs/Cost Principles Federal Agency: Department of the Treasury Federal Program Title: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing: 21.027 Federal Grant ID Number: None Provided Pass-Through Entity: Not applicable Award Period: March 3, 2021, through December 31, 2026 Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: 45 CFR § 75.403 (a) costs must be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. 2 CFR § 200.302 (b)(3) states each recipient’s and subrecipient’s financial management system must provide maintaining records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation. 2 CFR § 200.303 requires that the recipient and subrecipient establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations and the terms and conditions of the federal award. Condition: Amounts charged to the program did not agree to the supporting invoices. Cause: The Department’s review process and internal controls did not detect discrepancies between the invoiced amounts and the amounts recorded and charged to the grant. Effect: Program expenditures were not accurately recorded in the Department’s financial records. Questioned Costs: None, as this finding relates to an underpayment. Context: One out of four transactions tested, the amount charged to the Federal program did not agree to the amount reflected on the supporting invoice. The Department recorded and reimbursed an amount that was less than the invoiced amount, resulting in an underpayment totaling $313. This is a repeat finding from the fiscal year 2024 Single Audit. The Office stated on its Summary Schedule of Prior Year Audit Findings that this issue was “Fully Corrected with Previously Reported Corrective Action Implemented”. Due to this issue repeating for fiscal year 2024, this issue has not been fully corrected. Prior Year Single Audit Report Finding Number: 2024-026 Recommendation: We recommend that the Department strengthen controls to ensure the review process includes verification that amounts charged to the grant agree to the supporting invoices prior to reimbursement. Views of responsible officials and planned corrective actions: See management’s response on page 206.

Corrective Action Plan

Department of Public Health respectfully submits the following corrective action plan for the year ended June 30, 2025, on behalf of the State of South Carolina. The findings from the schedule of findings and questioned costs are discussed below. The findings numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAM AUDIT Department of the Treasury [2025-038] (Activities Allowed or Unallowed and Allowable Costs/Cost Principles) Coronavirus State and Local Fiscal Recovery Funds Assistance Listing: 21.027 Disposition of Audit Finding: The Department of Public Health concurs with the audit finding. Corrective Action: Although significant progress has been made and the invoice in question was short-paid for unallowable charges, there was a mistake in a formula calculation which caused the contractor to be underpaid by $313. We will continue with our strengthened review process and verify the documentation as well as the formulas in the spreadsheet prior to reimbursement. Anticipated Completion Date: June 30, 2026 The contact persons responsible for corrective action: . Trey Reed, Director, Bureau of Business Management at 803-898- 3522 . Marshall Rock, Director, Facilities, Bureau of Business Management 803-898-3510

Prior Finding References

2024-026

About Activities Allowed or Unallowed, Allowable Costs / Cost Principles →
2025-039
Matching, Level of Effort, Earmarking / Reporting
SIGNIFICANT DEFICIENCYOTHER MATTERS

Discrepancies existed between the Federal Financial Report (FFR) and the accounting system. In addition, although the Department met their matching requirement, the Department’s calculation did not align with expenditures from the accounting system. Cause: For the recipient share of expenditures reported on the FFR, the Department reported the matching amount included on the grant award document instead of the calculated match prepared by the Budget Analyst. For indirect costs, the base expenditures were not reported with the correct applicable rate for each applicable period. Finally, the internal database the Department used to make the matching calculation contained incomplete expenditure data causing an incorrect calculation. The Department’s internal controls failed to detect that the expenditures in the internal database did not reconcile with the actual expenditures from the accounting system. Effect: The Department’s control procedures did not detect the calculation errors identified in our testing. Questioned Costs: None, as the finding relates to reporting requirements, and the Department met their matching requirement. Context: We tested the sole FFR report submitted during fiscal year 2025 and identified reporting discrepancies in financial data related to the recipient share of expenditures and indirect expenditures. In addition, we noted that the Department’s calculation of the state match differed from the recipient share of expenditures reported on the FFR and was based on inaccurate data. Prior Year Single Audit Finding Number: Not applicable Recommendation: We recommend the Department strengthen its internal controls and processes to ensure that federal reports are free from error prior to submission and that matching calculations are based on accurate accounting records. Views of responsible officials and planned corrective actions: See management’s response on page 207.

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2025 – 039. Reporting and Matching Federal Agency: Department of Health and Human Services Federal Program Title: Maternal and Child Health Services Block Grant to the States Assistance Listing: 93.994 Federal Grant ID Number: B04MC47445 Pass-Through Entity: Not Applicable Award Period: October 1, 2022, through September 30, 2024 Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: 2 CFR § 200.303(a) requires that the recipient and subrecipient establish and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: Discrepancies existed between the Federal Financial Report (FFR) and the accounting system. In addition, although the Department met their matching requirement, the Department’s calculation did not align with expenditures from the accounting system. Cause: For the recipient share of expenditures reported on the FFR, the Department reported the matching amount included on the grant award document instead of the calculated match prepared by the Budget Analyst. For indirect costs, the base expenditures were not reported with the correct applicable rate for each applicable period. Finally, the internal database the Department used to make the matching calculation contained incomplete expenditure data causing an incorrect calculation. The Department’s internal controls failed to detect that the expenditures in the internal database did not reconcile with the actual expenditures from the accounting system. Effect: The Department’s control procedures did not detect the calculation errors identified in our testing. Questioned Costs: None, as the finding relates to reporting requirements, and the Department met their matching requirement. Context: We tested the sole FFR report submitted during fiscal year 2025 and identified reporting discrepancies in financial data related to the recipient share of expenditures and indirect expenditures. In addition, we noted that the Department’s calculation of the state match differed from the recipient share of expenditures reported on the FFR and was based on inaccurate data. Prior Year Single Audit Finding Number: Not applicable Recommendation: We recommend the Department strengthen its internal controls and processes to ensure that federal reports are free from error prior to submission and that matching calculations are based on accurate accounting records. Views of responsible officials and planned corrective actions: See management’s response on page 207.

Corrective Action Plan

Department of Public Health respectfully submits the following corrective action plan for the year ended June 30, 2025, on behalf of the State of South Carolina. The findings from the schedule of findings and questioned costs are discussed below. The findings numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAM AUDIT Department of Health and Human Services [2025-039] (Reporting and Matching) Maternal and Child Health Services Block Grant to the States Assistance Listings: 93.994 Disposition of Audit Finding: The Department of Public Health concurs with the audit finding. Corrective Action: We provided a reconciliation for the MCH Block Grant that shows that the expenditures reconcile to the amounts reported on the Federal Financial Report (FFR). This report was generated using the KSB1 report in the SC Enterprise Information System (SCEIS). The indirect cost (IDC) amount may not fully align because an incorrect rate was entered on the FFR. The applicable rates should have been applied as follows: . 19.40% for the period 10/1/2022 – 6/30/2023 . 20.30% for the period 7/1/2023 – 6/30/2024 . 24.00% for the period 7/1/2024 – 9/30/2024 Additionally, in the Payment Management System (PMS) the IDC calculation requires entry of the rate and the base amount, and the system automatically calculates the federal share. Because the system performs this calculation, minor rounding differences may occur. At the time of submission, the employee responsible for preparing and submitting the FFR was new to the role and relied on the matching requirement as presented in the Notice of Award (NOA) that was in effect at that time. The NOA included an incorrect matching amount, which was not removed until an amendment was issued after the FFR was submitted and approved in PMS. For the matching and indirect cost, we will have a more detailed second level of review. We will also require that the Cost Accountant obtains any matching information from the Budget Analyst assigned to the grant. Anticipated Completion Date: June 30, 2026 The contact person responsible for corrective action: . Katie Tillman, Director, Grant Compliance at 803-898-4103

About Matching, Level of Effort, Earmarking, Reporting →
2025-040
Matching, Level of Effort, Earmarking
SIGNIFICANT DEFICIENCYQUESTIONED COSTSOTHER MATTERS

The Department was not in compliance with the ten percent administrative expenses requirement. In addition, although the Department exceeded the level of effort requirement threshold, the calculated amount was less than what was actually expended. Cause: The internal database the Department used to calculate the earmarking and level of effort requirements contained incomplete expenditure data causing incorrect calculations. The Department’s internal controls failed to detect that the expenditures in the internal database did not reconcile with the actual expenditures from the accounting system. Effect: The Department’s control procedures did not detect the calculation errors identified in our testing, which leads to an increased risk of not meeting earmarking or level of effort requirements. Questioned Costs: Questioned costs totaled $142,775 as this was the amount expended over the allotted ten percent earmarking threshold for administrative expenses. There were no questioned costs related to the level of effort requirement. Context: The Department reviews the earmarking and level of effort calculations and reports these amounts as part of the annual Maternal and Child Health Services Block Grant Application/Annual Report. We selected for testing the most recently submitted 2025 report which contain expenditure details related to fiscal year 2024 and noted discrepancies between Department support and the accounting system. Prior Year Single Audit Finding Number: Not applicable Recommendation: We recommend the Department strengthen its controls to ensure that earmarking and level of effort calculations are based on accurate data from the accounting system. Views of responsible officials and planned corrective actions: See management’s response on page 208.

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2025 – 040. Earmarking and Level of Effort Federal Agency: Department of Health and Human Services Federal Program Title: Maternal and Child Health Services Block Grant to the States Assistance Listing: 93.994 Federal Grant ID Number: Various Pass-Through Entity: Not Applicable Award Period: Various Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: 42 USC 704(d) requires that a state may not use more than ten percent of allotted funds for administrative expenses. 42 USC 705(a)(4) requires that the state must maintain the level of funds provided solely by the state for maternal and child health programs at a level at least equal to the level provided in fiscal year 1989. 2 CFR § 200.303(a) requires that the recipient and subrecipient establish and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: The Department was not in compliance with the ten percent administrative expenses requirement. In addition, although the Department exceeded the level of effort requirement threshold, the calculated amount was less than what was actually expended. Cause: The internal database the Department used to calculate the earmarking and level of effort requirements contained incomplete expenditure data causing incorrect calculations. The Department’s internal controls failed to detect that the expenditures in the internal database did not reconcile with the actual expenditures from the accounting system. Effect: The Department’s control procedures did not detect the calculation errors identified in our testing, which leads to an increased risk of not meeting earmarking or level of effort requirements. Questioned Costs: Questioned costs totaled $142,775 as this was the amount expended over the allotted ten percent earmarking threshold for administrative expenses. There were no questioned costs related to the level of effort requirement. Context: The Department reviews the earmarking and level of effort calculations and reports these amounts as part of the annual Maternal and Child Health Services Block Grant Application/Annual Report. We selected for testing the most recently submitted 2025 report which contain expenditure details related to fiscal year 2024 and noted discrepancies between Department support and the accounting system. Prior Year Single Audit Finding Number: Not applicable Recommendation: We recommend the Department strengthen its controls to ensure that earmarking and level of effort calculations are based on accurate data from the accounting system. Views of responsible officials and planned corrective actions: See management’s response on page 208.

Corrective Action Plan

Department of Public Health respectfully submits the following corrective action plan for the year ended June 30, 2025, on behalf of the State of South Carolina. The findings from the schedule of findings and questioned costs are discussed below. The findings numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAM AUDIT Department of Health and Human Services [2025-040] (Earmarking and Level of Effort) Maternal and Child Health Services Block Grant to the States Assistance Listings: 93.994 Disposition of Audit Finding: The Department of Public Health concurs with the audit finding. Corrective Action: We acknowledge that the level of effort amount reflected in the electronic signature approval for the FY26 Application/FY24 Annual Report was understated by $279,390. This variance resulted from a data extraction issue and does not reflect unallowable expenditures or misallocation of funds. The overall level of effort for the grant remains supported and exceeds the minimum required, and the impact of the discrepancy is immaterial relative to the total grant award. Controls are in place to review and validate level of effort allocations during report preparation, and any updates identified during this process will be accurately reflected in the submitted documentation. The agency has had ongoing discussions with the Grantor regarding our methodology for allocating administrative costs. During those discussions, we were informed that states have flexibility in how the calculation is prepared and we were provided with examples of methodologies used by several other states. While our administrative percentage for the current reporting period slightly exceeded the 10 percent, we have been actively working with the Grantor to evaluate alternative approaches for calculating these costs. Due to the recent agency split, HPS reorganization, and bureau management transitions, we have continued using our current methodology while considering potential adjustments. While reviewing these methodologies, we will assess administrative costs to ensure compliance with the 10 percent cap in future periods. Anticipated Completion Date: June 30, 2026 The contact person responsible for corrective action: . Meredith Murphy, Director, Budgets & Financial Planning at 803-898-4222

About Matching, Level of Effort, Earmarking →
2025-041
Period of Performance
SIGNIFICANT DEFICIENCYQUESTIONED COSTSOTHER MATTERS

Expenditures were incurred and charged outside of the period of performance. Cause: The Department’s internal controls failed to identify and prevent charging costs incurred outside the applicable period of performance. Effect: Costs charged outside the period of performance may not be allowable. Questioned Costs: $1,338. The amount is based on the sum of the five transactions that had incurred program expenditures outside of the applicable period of performance date. Context: For a total of sixty expenditure transactions tested, one transaction had costs that were incurred before the start of the period of performance date and four transactions had incurred program expenditures that were not obligated and expended in accordance with program requirements. Recommendation: We recommend the Department review and update its internal controls to ensure that all expenditures charged to federal awards are incurred within the grant's period of performance. Prior Year Single Audit Finding Number: Not applicable Views of responsible officials and planned corrective actions: See management’s response on page 209.

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2025 – 041. Period of Performance Federal Agency: Department of Health and Human Services Federal Program Title: Maternal and Child Health Services Block Grant to the States Assistance Listing: 93.994 Federal Grant ID Numbers: B04MC47445 and B04MC54575 Pass-Through Entity: Not Applicable Award Period: October 1, 2022, through September 30, 2026 Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: 2 CFR § 200.403(h) requires costs to be incurred during the approved budget period. Criteria: 2 CFR § 200.303(a) requires that the recipient and subrecipient establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: Expenditures were incurred and charged outside of the period of performance. Cause: The Department’s internal controls failed to identify and prevent charging costs incurred outside the applicable period of performance. Effect: Costs charged outside the period of performance may not be allowable. Questioned Costs: $1,338. The amount is based on the sum of the five transactions that had incurred program expenditures outside of the applicable period of performance date. Context: For a total of sixty expenditure transactions tested, one transaction had costs that were incurred before the start of the period of performance date and four transactions had incurred program expenditures that were not obligated and expended in accordance with program requirements. Recommendation: We recommend the Department review and update its internal controls to ensure that all expenditures charged to federal awards are incurred within the grant's period of performance. Prior Year Single Audit Finding Number: Not applicable Views of responsible officials and planned corrective actions: See management’s response on page 209.

Corrective Action Plan

Department of Public Health respectfully submits the following corrective action plan for the year ended June 30, 2025, on behalf of the State of South Carolina. The findings from the schedule of findings and questioned costs are discussed below. The findings numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAM AUDIT Department of Health and Human Services [2025-041] (Period of Performance) Maternal and Child Health Services Block Grant to the States Assistance Listings: 93.994 Disposition of Audit Finding: The Department of Public Health concurs with the audit finding. Corrective Action: For 5 of the 60 transactions tested, 1 had costs incurred before the period of performance date and 4 had program expenditures not obligated and expended in accordance with program requirements. This was the result of human error/misclassification during processing. We are reinforcing guidance with both program and budget staff to prevent similar errors in future reporting periods. Anticipated Completion Date: June 30, 2026 The contact persons responsible for corrective action: . Meredith Murphy, Director, Budgets & Financial Planning at 803-898-4222 . Danielle Wingo, Director, MCH Bureau at 640-649-9292

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2025-042
Reporting
SIGNIFICANT DEFICIENCYOTHER MATTERS

Discrepancies existed between the Maternal and Child Health Services Block Grant Application/Annual Report and the accounting system. Cause: The internal database the Department used to compile the report contained incomplete expenditure data causing incorrect calculations. The Department’s internal controls failed to detect that the expenditures in the internal database did not reconcile with the actual expenditures from the accounting system. Effect: Although the Department still met matching and earmarking requirements, several reported amounts of 2023 expenditures were not accurately stated within the report. Questioned Costs: None, as this finding relates to reporting requirements, rather than unallowable expenditures. Context: For the sole Maternal and Child Health Services Block Grant Application/Annual Report submitted during fiscal year 2025, the Department reported inaccurate expended fiscal year 2023 data on Form 2 including amounts related to state matching and earmarking requirements. Prior Year Single Audit Finding Number: Not applicable Recommendation: We recommend the Department strengthen procedures to ensure accurate filing of the Maternal and Child Health Services Block Grant Application/Annual Report. Views of responsible officials and planned corrective actions: See management’s response on page 209.

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2025 – 042. Reporting Federal Agency: Department of Health and Human Services Federal Program Title: Maternal and Child Health Services Block Grant to the States Assistance Listing: 93.994 Federal Grant ID Number: Various Pass-Through Entity: Not Applicable Award Period: Various Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: 2 CFR § 200.303(a) requires that the recipient and subrecipient establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: Discrepancies existed between the Maternal and Child Health Services Block Grant Application/Annual Report and the accounting system. Cause: The internal database the Department used to compile the report contained incomplete expenditure data causing incorrect calculations. The Department’s internal controls failed to detect that the expenditures in the internal database did not reconcile with the actual expenditures from the accounting system. Effect: Although the Department still met matching and earmarking requirements, several reported amounts of 2023 expenditures were not accurately stated within the report. Questioned Costs: None, as this finding relates to reporting requirements, rather than unallowable expenditures. Context: For the sole Maternal and Child Health Services Block Grant Application/Annual Report submitted during fiscal year 2025, the Department reported inaccurate expended fiscal year 2023 data on Form 2 including amounts related to state matching and earmarking requirements. Prior Year Single Audit Finding Number: Not applicable Recommendation: We recommend the Department strengthen procedures to ensure accurate filing of the Maternal and Child Health Services Block Grant Application/Annual Report. Views of responsible officials and planned corrective actions: See management’s response on page 209.

Corrective Action Plan

Department of Public Health respectfully submits the following corrective action plan for the year ended June 30, 2025, on behalf of the State of South Carolina. The findings from the schedule of findings and questioned costs are discussed below. The findings numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAM AUDIT Department of Health and Human Services [2025-042] (Reporting) Maternal and Child Health Services Block Grant to the States Assistance Listings: 93.994 Disposition of Audit Finding: The Department of Public Health concurs with the audit finding. Corrective Action: The variance identified occurred because the amounts reported were compiled from internal supporting documentation rather than directly from SCEIS. While reported totals met the minimum required thresholds for Matching and Earmarking, the department recognizes the importance of alignment with the official accounting system. Going forward, the budget analyst will prioritize using SCEIS data when preparing reports, and the department will continue to monitor reporting procedures to ensure accuracy and consistency. Anticipated Completion Date: June 30, 2026 The contact persons responsible for corrective action: . Meredith Murphy, Director, Budgets & Financial Planning at 803-898-4222

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2025-043
Cash Management
SIGNIFICANT DEFICIENCYOTHER MATTERS

Supporting documentation was not adequate to determine if federal reimbursements were properly reviewed and approved by a programmatic supervisor prior to requesting a drawdown as required by the Department’s policies and procedures. In addition, some draws were made in excess of allowable incurred expenditures. Cause: The Department failed to retain documentation demonstrating performance of a programmatic supervisory review and approval. In addition, Department controls failed to detect potential overcharging of the grant. Effect: The Department may drawdown funds in excess of eligible reimbursable expenditures. Questioned Costs: Total questioned costs could not be determined due to the Department’s methodology of calculating grant draws. Context: The following discrepancies were encountered during testing of cash management: • Five of seven Immunization Cooperative Agreements drawdowns and six of eight Centers for Disease Control and Prevention Collaboration with Academia to Strengthen Public Health drawdowns selected for testing lacked sufficient documentation to confirm whether the federal reimbursement requests had a separate and appropriate preparer and reviewer prior to requesting a drawdown. • In addition, each respective program had one tested drawdown where the requested grant reimbursement amount was greater than the eligible costs recorded in the accounting system. Prior Year Single Audit Finding Number: Not applicable Recommendation: We recommend the Department strengthen its controls to ensure that drawdowns are reviewed appropriately and that drawdowns are reconciled to grant expenditures prior to the submission of the reimbursement request to prevent overdrawing the grant. Views of responsible officials and planned corrective actions: See management’s response on page 210.

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2025 – 043. Cash Management Federal Agency: Department of Health and Human Services Federal Program Title: Immunization Cooperative Agreements and Centers for Disease Control and Prevention Collaboration with Academia to Strengthen Public Health Assistance Listing: 93.268 and 93.967 Federal Grant ID Numbers: Various Pass-Through Entity: Not applicable Award Period: Various Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: 2 CFR § 200.303(a) requires that the recipient and subrecipient establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. 2 CFR § 205.11(a) requires a State and a Federal Program Agency must minimize the time elapsing between the transfer of funds from the United States Treasury and the State's payout of funds for Federal assistance program purposes, whether the transfer occurs before or after the payout of funds. Condition: Supporting documentation was not adequate to determine if federal reimbursements were properly reviewed and approved by a programmatic supervisor prior to requesting a drawdown as required by the Department’s policies and procedures. In addition, some draws were made in excess of allowable incurred expenditures. Cause: The Department failed to retain documentation demonstrating performance of a programmatic supervisory review and approval. In addition, Department controls failed to detect potential overcharging of the grant. Effect: The Department may drawdown funds in excess of eligible reimbursable expenditures. Questioned Costs: Total questioned costs could not be determined due to the Department’s methodology of calculating grant draws. Context: The following discrepancies were encountered during testing of cash management: • Five of seven Immunization Cooperative Agreements drawdowns and six of eight Centers for Disease Control and Prevention Collaboration with Academia to Strengthen Public Health drawdowns selected for testing lacked sufficient documentation to confirm whether the federal reimbursement requests had a separate and appropriate preparer and reviewer prior to requesting a drawdown. • In addition, each respective program had one tested drawdown where the requested grant reimbursement amount was greater than the eligible costs recorded in the accounting system. Prior Year Single Audit Finding Number: Not applicable Recommendation: We recommend the Department strengthen its controls to ensure that drawdowns are reviewed appropriately and that drawdowns are reconciled to grant expenditures prior to the submission of the reimbursement request to prevent overdrawing the grant. Views of responsible officials and planned corrective actions: See management’s response on page 210.

Corrective Action Plan

Department of Public Health respectfully submits the following corrective action plan for the year ended June 30, 2025, on behalf of the State of South Carolina. The findings from the schedule of findings and questioned costs are discussed below. The findings numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAM AUDIT Department of Health and Human Services [2025-043] (Cash Management) Immunization Cooperative Agreements and Centers for Disease Control and Prevention Collaboration with Academia to Strengthen Public Health Assistance Listings: 93.268 and 93.967 Disposition of Audit Finding: The Department of Public Health concurs with the audit finding. Corrective Action: The agency has implemented additional procedures to ensure that all applicable documents receive the required second-level review and signature prior to final processing. These processes include reinforcing review requirements with staff and incorporating additional verification steps to confirm that a second signature is obtained and documented. The agency will continue to monitor this control to ensure compliance going forward. The overdraw observed for Immunizations was the result of a timing issue. A draw was processed based on the cash balance at that time, and a subsequent journal entry reclassified revenue. This sequence temporarily created an overstated cash balance; however, the balance was then applied to payroll and other eligible expenses. Regarding the Collaboration with Academia grants, these discrepancies occurred during a period when the agency was utilizing the draw database, which at that time was not pulling accurate data. The agency has since corrected the process used to perform federal draws to ensure accuracy and proper reconciliation. Any remaining balance was applied to allowable program expenses, and the grant has since been properly closed out with no remaining balance. Anticipated Completion Date: June 30, 2026 The contact person responsible for corrective action: . Katie Tillman, Director, Grant Compliance at 803-898-4103

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2025-044
Special Tests & Provisions
SIGNIFICANT DEFICIENCY

The Department did not perform a review and approval of a VFC compliance site visit in accordance with its policies. Cause: Due to staffing turnover, there were delays in reviewing compliance visits. Effect: In the absence of a compliance visit review, providers could have unresolved issues that could affect the quality and quantity of vaccines provided to VFC recipients. Questioned Costs: None, as this finding relates to an untimely approval of a compliance site visit, rather than unallowable expenditures. Context: For sixty providers selected for testing, one compliance site visit did not have approval completed by the VFC Coordinator, Immunization Program Manager, or a designee. Prior Year Single Audit Finding Number: Not applicable Recommendation: We recommend the Department ensure compliance visits are reviewed in accordance with Department policy. Views of responsible officials and planned corrective actions: See management’s response on page 211. Auditor’s Conclusion: The compliance site visit where we noted the untimely review was performed on June 6, 2025. Although the Department had been tracking and monitoring the site visit, it was not reviewed or approved by the VFC-Coordinator or their designee as of our audit fieldwork in early February of 2026. Based on our audit inquiries, the documentation relating to the provider’s compliance site visit was updated, which enabled the site visit to be approved a few days later. We understand there were difficulties with staffing turnover, but in instances of prolonged vacancies, there should be policies to help reduce the timing between when site visits are conducted and when they can be reviewed.

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2025 – 044. Special Tests and Provisions Federal Agency: Department of Health and Human Services Federal Program Title: Immunization Cooperative Agreements Assistance Listing: 93.268 Federal Grant ID Number: Various Pass-Through Entity: Not Applicable Award Period: Various Type of Finding: Significant deficiency in internal control over compliance Criteria: The Office of Management and Budget’s (OMB) 2025 Compliance Supplement states that effective control and accountability must be maintained for all vaccines under the Vaccines for Children (VFC) program. Vaccines must be adequately safeguarded and used solely for authorized purposes in accordance with guidance set forth in 42 USC 1396s. To comply with this requirement, the Department’s Vaccines for Children Operation Guide requires that all completed VFC compliance site visits be reviewed by the VFC coordinator, immunization program manager, or a designee. 2 CFR § 200.303(a) requires that the recipient and subrecipient establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: The Department did not perform a review and approval of a VFC compliance site visit in accordance with its policies. Cause: Due to staffing turnover, there were delays in reviewing compliance visits. Effect: In the absence of a compliance visit review, providers could have unresolved issues that could affect the quality and quantity of vaccines provided to VFC recipients. Questioned Costs: None, as this finding relates to an untimely approval of a compliance site visit, rather than unallowable expenditures. Context: For sixty providers selected for testing, one compliance site visit did not have approval completed by the VFC Coordinator, Immunization Program Manager, or a designee. Prior Year Single Audit Finding Number: Not applicable Recommendation: We recommend the Department ensure compliance visits are reviewed in accordance with Department policy. Views of responsible officials and planned corrective actions: See management’s response on page 211. Auditor’s Conclusion: The compliance site visit where we noted the untimely review was performed on June 6, 2025. Although the Department had been tracking and monitoring the site visit, it was not reviewed or approved by the VFC-Coordinator or their designee as of our audit fieldwork in early February of 2026. Based on our audit inquiries, the documentation relating to the provider’s compliance site visit was updated, which enabled the site visit to be approved a few days later. We understand there were difficulties with staffing turnover, but in instances of prolonged vacancies, there should be policies to help reduce the timing between when site visits are conducted and when they can be reviewed.

Corrective Action Plan

Department of Public Health respectfully submits the following corrective action plan for the year ended June 30, 2025, on behalf of the State of South Carolina. The findings from the schedule of findings and questioned costs are discussed below. The findings numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAM AUDIT Department of Health and Human Services [2025-044] (Special Tests and Provisions) Immunization Cooperative Agreements Assistance Listing: 93.268 Disposition of Audit Finding: Management understands and respects the audit process, while maintaining our disagreement with this finding. The tardiness of the data entry was due to staff turnover and overburdening of remaining staff, not due to lack of oversite or "falling through the cracks". Internal email communication forwarded to the audit team evidences that the specific item in question was being tracked and followed up on to ensure completion. Corrective Action: The 1 of the 60 site visit follow-ups was completed within the appropriate timeframe for this site. However, due to loss of staff, the documentation was not completely done in a timely manner. The documentation has since been updated by the Lowcountry Compliance Unit Manager in lieu of the former staff member, and the site visit reviewed by VFC Coordinator in Secured Access Management Services. VFC Coordinator continues to monitor and track site visit data and communicates to compliance unit managers to stay ahead of upcoming due dates and assist in supporting teams as needed. These communications will be increased to occur monthly in the last week of the month. Anticipated Completion Date: Ongoing The contact person(s) responsible for corrective action and phone number(s): McColloch Salehi - 803-587-1537

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2025-045
Activities Allowed or Unallowed / Cost Allowability
SIGNIFICANT DEFICIENCY

The Department did not maintain appropriate documentation supporting the review and approval over one journal entry. Cause: The Department failed to retain documentation demonstrating performance of a supervisory review and approval. Effect: Without a proper supervisory review, there is an increased risk that the Department could allocate unallowable costs to the grant. Questioned Costs: None, as the issue is only related to the review of the entry and not unallowable expenditures. Context: For one of seventy transactions selected for testing, supporting documentation was not adequate to demonstrate that a proper review and approval by a programmatic supervisor occurred on the journal entry form. Prior Year Single Audit Finding Number: Not applicable Recommendation: We recommend the Department strengthen controls to ensure that documentation is maintained to support that costs charged to the grant were properly reviewed and approved for allowability. Views of responsible officials and planned corrective actions: See management’s response on page 212.

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2025 – 045. Activities Allowed or Unallowed and Allowable Costs/Cost Principles Federal Agency: Department of Health and Human Services Federal Program Title: Centers for Disease Control and Prevention Collaboration with Academia to Strengthen Public Health Assistance Listing: 93.967 Federal Grant ID Number: NE11OE000041 Pass-Through Entity: Not Applicable Award Period: December 1, 2023, through November 30, 2025 Type of Finding: Significant deficiency in internal control over compliance Criteria: 2 CFR § 200.303(a) requires that the recipient and subrecipient establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms of conditions of the federal award. Condition: The Department did not maintain appropriate documentation supporting the review and approval over one journal entry. Cause: The Department failed to retain documentation demonstrating performance of a supervisory review and approval. Effect: Without a proper supervisory review, there is an increased risk that the Department could allocate unallowable costs to the grant. Questioned Costs: None, as the issue is only related to the review of the entry and not unallowable expenditures. Context: For one of seventy transactions selected for testing, supporting documentation was not adequate to demonstrate that a proper review and approval by a programmatic supervisor occurred on the journal entry form. Prior Year Single Audit Finding Number: Not applicable Recommendation: We recommend the Department strengthen controls to ensure that documentation is maintained to support that costs charged to the grant were properly reviewed and approved for allowability. Views of responsible officials and planned corrective actions: See management’s response on page 212.

Corrective Action Plan

Department of Public Health respectfully submits the following corrective action plan for the year ended June 30, 2025, on behalf of the State of South Carolina. The findings from the schedule of findings and questioned costs are discussed below. The findings numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAM AUDIT Department of Health and Human Services [2025-045] (Activities Allowed or Unallowed and Allowable Costs/Cost Principles) Centers for Disease Control and Prevention Collaboration with Academia to Strengthen Public Health Assistance Listings: 93.967 Disposition of Audit Finding: The Department of Public Health concurs with the audit finding. Corrective Action: In this case, 1 of 70 transactions tested did not contain a supervisory review and approval of a journal entry. The agency has implemented additional procedures to ensure that all applicable documents receive the required second-level review and signature prior to final processing. These processes include reinforcing review requirements with staff and incorporating additional verification steps to confirm that a second signature is obtained and documented. The agency will continue to monitor this control to ensure compliance going forward. Anticipated Completion Date: June 30, 2026 The contact person responsible for corrective action: . Katie Tillman, Director, Grant Compliance at 803-898-4103

About Activities Allowed or Unallowed, Allowable Costs / Cost Principles →
2025-046
Procurement & Suspension/Debarment
SIGNIFICANT DEFICIENCYREPEAT OF 2024-032QUESTIONED COSTSOTHER MATTERS

Compliance with suspension and debarment regulations could not be confirmed for one vendor contract. Cause: The Department was unable to locate the documentation demonstrating that they checked the SAM.gov Exclusions for that vendor. Effect: The Department’s compliance with federal suspension and debarment requirements was not supported by adequate documentation. Questioned Costs: None, as the finding is related to insufficient verification documentation rather than unallowable expenditures. Context: The Department verifies suspension and debarment through checking SAM.gov Exclusions. For one out of six vendors tested, the Department was unable to provide support that they checked the SAM.gov Exclusions. Suspension and debarment is performed on an agencywide basis for all grant programs. In the fiscal year 2024 Single Audit, there was a similar finding for the Epidemiology and Laboratory Capacity for Infectious Disease (Assistance Listing Number 93.323) program. The Department stated on its Summary Schedule of Prior Year Audit Findings that this issue was “Fully Corrected” with Previously Reported Corrective Action Implemented”. Due to this issue repeating for fiscal year 2025, the issue has not been fully corrected. Prior Year Single Audit Finding Number: 2024-032 for Epidemiology and Laboratory Capacity for Infectious Disease (ELC) (Assistance Listing Number 93.323). Recommendation: We recommend the Department consistently adhere to its procedures including maintaining the SAM.gov Exclusions check for all applicable vendors. Views of responsible officials and planned corrective actions: See management’s response on page 212.

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2025 – 046. Suspension and Debarment Federal Agency: Department of Health and Human Services Federal Program Titles: Centers for Disease Control and Prevention Collaboration with Academia to Strengthen Public Health and Epidemiology and Laboratory Capacity for Infectious Disease (ELC) Assistance Listings: 93.967 and 93.323 Federal Grant ID Number: Various Pass-Through Entity: Not Applicable Award Period: Various. Type of Finding: Significant deficiency in internal control over compliance, other matters. Criteria: 2 CFR § 180.300 requires that when a non-federal entity enters into a covered transaction (contracts for goods and services that are expected to equal or exceed $25,000, as well as all subawards to subrecipients, irrespective of award amount) with an entity at a lower tier, the non-Federal entity must verify that the entity is not suspended or debarred or otherwise excluded from participating in the transaction. The regulation lists several permitted methods for verification, including checking the System for Award Management (SAM.gov) Exclusions maintained by the United States General Services Administration. Criteria: 2 CFR § 200.303(a) requires that the recipient and subrecipient establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations, and the terms of conditions of the federal award. Condition: Compliance with suspension and debarment regulations could not be confirmed for one vendor contract. Cause: The Department was unable to locate the documentation demonstrating that they checked the SAM.gov Exclusions for that vendor. Effect: The Department’s compliance with federal suspension and debarment requirements was not supported by adequate documentation. Questioned Costs: None, as the finding is related to insufficient verification documentation rather than unallowable expenditures. Context: The Department verifies suspension and debarment through checking SAM.gov Exclusions. For one out of six vendors tested, the Department was unable to provide support that they checked the SAM.gov Exclusions. Suspension and debarment is performed on an agencywide basis for all grant programs. In the fiscal year 2024 Single Audit, there was a similar finding for the Epidemiology and Laboratory Capacity for Infectious Disease (Assistance Listing Number 93.323) program. The Department stated on its Summary Schedule of Prior Year Audit Findings that this issue was “Fully Corrected” with Previously Reported Corrective Action Implemented”. Due to this issue repeating for fiscal year 2025, the issue has not been fully corrected. Prior Year Single Audit Finding Number: 2024-032 for Epidemiology and Laboratory Capacity for Infectious Disease (ELC) (Assistance Listing Number 93.323). Recommendation: We recommend the Department consistently adhere to its procedures including maintaining the SAM.gov Exclusions check for all applicable vendors. Views of responsible officials and planned corrective actions: See management’s response on page 212.

Corrective Action Plan

Department of Public Health respectfully submits the following corrective action plan for the year ended June 30, 2025, on behalf of the State of South Carolina. The findings from the schedule of findings and questioned costs are discussed below. The findings numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAM AUDIT Department of Health and Human Services [2025-046] (Suspension and Debarment) Centers for Disease Control and Prevention Collaboration with Academia to Strengthen Public Health Assistance Listing: 93.967 Disposition of Audit Finding: The Department of Public Health concurs with the audit finding. Corrective Action: In this case, one of the six contracts tested did not have documentation on file to show that a SAM check was done. It is standard practice that when the SAM check is performed, a copy of the results is printed from the SAM.gov website. This is typically a page showing "no exclusions" or, frequently, if the vendor has no Federal contracting history, a screen showing "no results found." If the purchase is the result of a formal written solicitation, the solicitation contains the standard Compendium clause, “Certification Regarding Debarment and Other Responsibility Matters”. To strengthen compliance, the agency procurement director created an instructional video on March 15, 2024, guiding staff through the SAM check process, which is complex and lacks clear federal instructions, and distributed it to procurement staff. On January 27, 2025, this requirement was reinforced again in an email to all buyers, which included the video link and a detailed explanation of when SAM checks are necessary. The importance of, and process for, the SAM check is also a frequent topic at our monthly staff meetings. Most recently, it was a "Reminder" topic at both our January and February 2026 staff meetings. Moving forward, we will continue reminding staff of this requirement and incorporate it as a checkpoint in our quality assurance review before issuing purchase orders. Anticipated Completion Date: June 30, 2026 The contact persons responsible for corrective action: . Trey Reed, Director, Bureau of Business Management at 803-898-3522 . Tripp Clark, Director, Procurement, Bureau of Business Management at 803-898-3485

Prior Finding References

2024-032

About Procurement and Suspension and Debarment →
2025-047
Equipment & Real Property
SIGNIFICANT DEFICIENCYREPEAT OF 2023-026OTHER MATTERS

The Department was not in compliance with several equipment and real property requirements. Cause: The Department’s processes did not ensure that assets transferred during the transition from the Department of Health and Environmental Control (DHEC) to the Department of Public Health (DPH) were properly associated with the applicable federal funding source or grant information within the asset management system. Effect: Incomplete property records increase the risk that equipment purchased with federal funds may not be properly tracked, monitored, or reported in accordance with federal regulations. Questioned Costs: None, as this finding relates to equipment record keeping, rather than unallowable expenditures. Context: During follow-up procedures related to equipment and real property management, the Department provided an asset history listing for review. However, the listing did not clearly identify assets purchased with federal funds. Additionally, assets transferred from DHEC to DPH in the South Carolina Enterprise Information System (SCEIS) were not associated with a federal funding source or specific grant. As a result, the Department was unable to demonstrate that equipment purchased with federal funds was being tracked in accordance with federal requirements. In addition, since assets were not listed under federal grants, we were unable to obtain a population to test whether assets bought with federal grants were accounted for in the Department’s annual physical inventory. This is a repeat finding from the fiscal year 2023 Single Audit. The Office stated on its Summary Schedule of Prior Year Audit Findings that this issue was “Fully Corrected with Previously Reported Corrective Action Implemented”. Due to this issue repeating for fiscal year 2023, this issue has not been fully corrected. Prior Year Single Audit Report Finding Number: 2023-026 Recommendation: We recommend the Department strengthen procedures to ensure equipment purchased with federal funds is properly tracked and associated with the applicable federal funding source within the asset management system and property records should include all elements required by federal regulations. Views of responsible officials and planned corrective actions: See management’s response on page 213.

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2025 – 047. Equipment and Real Property Management Federal Agency: Department of Health and Human Services Federal Program Title: Public Health Emergency Preparedness and Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response Assistance Listing: 93.069 and 93.354 Federal Grant ID Number: Various Pass-Through Entity: Not applicable Award Period: Various Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: 2 CFR § 200.303 requires that the recipient and subrecipient establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with federal statutes, regulations and the terms and conditions of the federal award. 2 CFR § 200.313(d)(1) requires property records include a description of the property, a serial number or another identification number, the source of funding for the property (including the Federal Award Identification Number (FAIN)), the title holder, the acquisition date, the cost of the property, the percentage of the Federal agency contribution towards the original purchase, the location, use, and condition of the property, and any disposition data including the date of disposal and sale price of the property. Condition: The Department was not in compliance with several equipment and real property requirements. Cause: The Department’s processes did not ensure that assets transferred during the transition from the Department of Health and Environmental Control (DHEC) to the Department of Public Health (DPH) were properly associated with the applicable federal funding source or grant information within the asset management system. Effect: Incomplete property records increase the risk that equipment purchased with federal funds may not be properly tracked, monitored, or reported in accordance with federal regulations. Questioned Costs: None, as this finding relates to equipment record keeping, rather than unallowable expenditures. Context: During follow-up procedures related to equipment and real property management, the Department provided an asset history listing for review. However, the listing did not clearly identify assets purchased with federal funds. Additionally, assets transferred from DHEC to DPH in the South Carolina Enterprise Information System (SCEIS) were not associated with a federal funding source or specific grant. As a result, the Department was unable to demonstrate that equipment purchased with federal funds was being tracked in accordance with federal requirements. In addition, since assets were not listed under federal grants, we were unable to obtain a population to test whether assets bought with federal grants were accounted for in the Department’s annual physical inventory. This is a repeat finding from the fiscal year 2023 Single Audit. The Office stated on its Summary Schedule of Prior Year Audit Findings that this issue was “Fully Corrected with Previously Reported Corrective Action Implemented”. Due to this issue repeating for fiscal year 2023, this issue has not been fully corrected. Prior Year Single Audit Report Finding Number: 2023-026 Recommendation: We recommend the Department strengthen procedures to ensure equipment purchased with federal funds is properly tracked and associated with the applicable federal funding source within the asset management system and property records should include all elements required by federal regulations. Views of responsible officials and planned corrective actions: See management’s response on page 213.

Corrective Action Plan

Department of Public Health respectfully submits the following corrective action plan for the year ended June 30, 2025, on behalf of the State of South Carolina. The findings from the schedule of findings and questioned costs are discussed below. The findings numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAM AUDIT Department of Health and Human Services [2025-047] (Equipment and Real Property Management) Public Health Emergency Preparedness and Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response Assistance Listing: 93.069 and 93.354 Disposition of Audit Finding: The Department of Public Health concurs with the audit finding. Corrective Action: At the time of the agency restructuring and transfer of assets from the Department of Health and Environmental Control (DHEC) to the Department of Public Health (DPH) and the Department of Environmental Services (DES), the DHEC Asset Manager oversaw the asset transfers to both successor agencies (J060 and P500). During this transition, we were advised by the SCEIS team to temporarily move all agency assets into a single generic fund for each new agency to ensure the transfer process could be completed without system errors. Specifically, one generic funding stream was established for J060 and one for P500 to facilitate the transfer of assets from the previous J040 designations. We gave the auditors an email from the SCEIS team that provided this guidance. To complete the transition, the assets were placed on large transfer documents that were uploaded into SCEIS in bulk. This process was facilitated by the SCEIS team, and we followed their direction throughout the entire transfer process. Due to the complexity and volume of assets involved, it ultimately took close to a year after the agency split for all assets to be successfully moved from their original J040 designations to the new agency structures. Following the transition, our Budget team developed a crosswalk identifying which former J040 grants would correspond to the new J060 grant designations. Based on the information you shared, it appears that the updated grant designations for certain assets were not fully applied or uploaded into SCEIS after the initial transfer into the generic funding stream. As a result, those assets are still present in the system under DPH but are not currently associated with the applicable federal program when reports are generated. To address this, we will work with the SCEIS Asset Management team to determine why the grant designations were not updated as expected and to ensure the affected assets are reassigned to the appropriate grant funding sources in the system. We are unsure how long the correction process will take. If the adjustments must be made individually at the asset level, the updates will be completed by October. Anticipated Completion Date: October 31, 2026 The contact persons responsible for corrective action: . Trey Reed, Director, Bureau of Business Management at 803-898-3522 . Ryan Sims, Director, Support Services, Bureau of Business Management 803-898-3523

Prior Finding References

2023-026

About Equipment and Real Property Management →

FY 2024-06-30

MATERIAL NONCOMPLIANCE DISCLOSED$13,316,999,377 federal awards expended

FAC accepted this audit on March 27, 2025 — management decision was due September 27, 2025.

2024-003
Reporting
SIGNIFICANT DEFICIENCYREPEAT OF 2023-006OTHER MATTERS

FFATA reporting and timing errors were identified. Cause: Administrative turnover increased workloads which led to delays in submission and retention of the FFATA reports. Effect: The Office was not in compliance with FFATA reporting requirements. Questioned Costs: None Context: Seven subawards were selected for testing and the following compliance errors were identified during the testing: • For six of the subawards tested, the action was not reported in the FSRS by the last day of the month following the month that the subaward was made. • For two of the subawards tested, incorrect information was reported in the FSRS regarding the obligation date for the subaward. The incorrect information was not properly reviewed and approved by the Office staff prior to submission. This is a repeat finding from the fiscal year 2023 Single Audit. The Office stated on its Summary Schedule of Prior Year Audit Findings that this issue was “Fully Corrected” with Previously Reported Corrective Action Implemented”. Due to this issue repeating for fiscal year 2024, this issue has not been fully corrected. Prior Year Single Audit Report Finding Number: 2023-006 Recommendation: We recommend the Office continue its efforts to strengthen internal controls to ensure continuous monitoring and reviewing of project obligations resulting in reports that are submitted in compliance with FFATA reporting requirements. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 130.

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Federal Agency: Department of Homeland Security Federal Program Title: Disaster Grants – Public Assistance (Presidentially Declared Disasters) Assistance Listing: 97.036 Federal Grant ID Number: Various Pass-Through Entity: Not applicable Award Period: Various Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: 2 CFR § 170 Appendix A requires that recipients of grants or cooperative agreements report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act (FFATA) Subaward Reporting System (FSRS) no later than the end of the month following the month in which the obligation was made. Condition: FFATA reporting and timing errors were identified. Cause: Administrative turnover increased workloads which led to delays in submission and retention of the FFATA reports. Effect: The Office was not in compliance with FFATA reporting requirements. Questioned Costs: None Context: Seven subawards were selected for testing and the following compliance errors were identified during the testing: • For six of the subawards tested, the action was not reported in the FSRS by the last day of the month following the month that the subaward was made. • For two of the subawards tested, incorrect information was reported in the FSRS regarding the obligation date for the subaward. The incorrect information was not properly reviewed and approved by the Office staff prior to submission. This is a repeat finding from the fiscal year 2023 Single Audit. The Office stated on its Summary Schedule of Prior Year Audit Findings that this issue was “Fully Corrected” with Previously Reported Corrective Action Implemented”. Due to this issue repeating for fiscal year 2024, this issue has not been fully corrected. Prior Year Single Audit Report Finding Number: 2023-006 Recommendation: We recommend the Office continue its efforts to strengthen internal controls to ensure continuous monitoring and reviewing of project obligations resulting in reports that are submitted in compliance with FFATA reporting requirements. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 130.

Corrective Action Plan

The South Carolina Adjutant General’s Office respectfully submits the following corrective action plan for the year ended June 30, 2025, on behalf of the State of South Carolina. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Findings — FEDERAL AWARD PROGRAM AUDIT United States Department of Homeland Security 2024-003 Public Assistance (Presidentially Declared Disasters) - Assistance Listing No. 97.036 Disposition of Audit Finding: The South Carolina Adjutant General’s Office concurs with the audit finding. Corrective Action: 1. The SCEMD Finance and Administration staff will implement a report verification process to ensure accuracy of reporting. Each month prior to submission, the responsible SCEMD Finance staff will submit a draft of all FFATA reports to the SCEMD Chief of Finance and Administration for review and approval. 2. SCEMD utilizes the South Carolina Recovery Grants (SCRG) platform to obtain information necessary for FFATA reporting. This information is currently gathered by the SCEMD PA and Grants and Finance staff. SCEMD will institute an additional monthly review of the South Carolina Recovery Grants (SCRG) platform by the SCEMD Finance and Administration staff to ensure the completeness of information gathered for timely FFATA reporting. Anticipated Completion Date: June 30, 2025 Name of the contact person responsible for corrective action: • Landry Phillips at LPhillips@emd.sc.gov or 803-737-8559

Prior Finding References

2023-006

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2024-004
Cash Management
SIGNIFICANT DEFICIENCYREPEAT OF 2023-011

Supporting documentation was not adequate to determine if federal reimbursements had a separate preparer and reviewer prior to requesting a drawdown as required by the Department’s policies and procedures. Cause: Documentation that was provided was inadequate to support that the employee who completes the drawdown request was a different individual than the employee who reviewed and approved the drawdown prior to the reimbursement request. Effect: The Department may request improper drawdowns due to a lack of segregation of duties. Questioned Costs: None Context: For all five drawdown requests tested, supporting documentation was not adequate to demonstrate who prepared and reviewed the drawdown request. Therefore, it could not be confirmed whether the federal reimbursements had a separate preparer and reviewer prior to requesting a drawdown. This is a repeat finding from the fiscal year 2023 Single Audit. The Department stated on its Summary Schedule of Prior Year Audit Findings that this issue was “Fully Corrected with Previously Reported Corrective Action Implemented”. Due to this issue repeating for fiscal year 2024, this issue has not been fully corrected. Prior Year Single Audit Report Finding Number: 2023-011 Recommendation: We recommend that the Department strengthen its policies and procedures to ensure proper documentation of supervisory review is maintained and that there is a segregation of duties between the individual completing the drawdown request and the individual approving the drawdown request. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 132.

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Federal Agency: Department of Health and Human Services Federal Program Title: Block Grants for Prevention and Treatment of Substance Abuse Assistance Listing: 93.959 Federal Grant ID Number: B08TI085832, B08TI083544, B08TI083966 Pass-Through Entity: Not applicable Award Period: March 15, 2021, through September 30, 2025 Type of Finding: Significant deficiency in internal control over compliance Criteria: 2 CFR § 200.303 requires that the 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 of conditions of the federal award. Condition: Supporting documentation was not adequate to determine if federal reimbursements had a separate preparer and reviewer prior to requesting a drawdown as required by the Department’s policies and procedures. Cause: Documentation that was provided was inadequate to support that the employee who completes the drawdown request was a different individual than the employee who reviewed and approved the drawdown prior to the reimbursement request. Effect: The Department may request improper drawdowns due to a lack of segregation of duties. Questioned Costs: None Context: For all five drawdown requests tested, supporting documentation was not adequate to demonstrate who prepared and reviewed the drawdown request. Therefore, it could not be confirmed whether the federal reimbursements had a separate preparer and reviewer prior to requesting a drawdown. This is a repeat finding from the fiscal year 2023 Single Audit. The Department stated on its Summary Schedule of Prior Year Audit Findings that this issue was “Fully Corrected with Previously Reported Corrective Action Implemented”. Due to this issue repeating for fiscal year 2024, this issue has not been fully corrected. Prior Year Single Audit Report Finding Number: 2023-011 Recommendation: We recommend that the Department strengthen its policies and procedures to ensure proper documentation of supervisory review is maintained and that there is a segregation of duties between the individual completing the drawdown request and the individual approving the drawdown request. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 132.

Corrective Action Plan

The South Carolina Department of Alcohol and Other Drug Abuse Services respectfully submits the following corrective action plan for the year ended June 30, 2024, on behalf of the State of South Carolina. The findings from the Schedule of Findings and Questioned Costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAM AUDIT U.S. Department of Health and Human Services 2024-004 Block Grants for Prevention and Treatment of Substance Abuse – Assistance Listing No. 93.959 Disposition of Audit Finding: The Department concurs with the audit finding. Corrective Action: The Department will establish additional procedures and a new control to ensure all drawdowns are reviewed for accuracy. The Department will institute a standardize checklist that will require each drawdown request to include a listing of each expenditure eligible for reimbursement as support for the drawdown. A supervisor will certify the expenditures were incurred prior to the drawdown date and were not included in a previous drawdown request. The documentation will be stored in the State’s accounting system and/or the Department’s file management system. Programmatic and finance staff will receive training on this new process. Additionally, the internal audit group will monitor drawdowns to ensure the proper support is documented and stored for review when applicable. Anticipated Completion Date: June 1, 2025 Name of the contact person responsible for corrective action: Angela Outing, Administrative Manager, at 803-896-5547

Prior Finding References

2023-011

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2024-005
Period of Performance
SIGNIFICANT DEFICIENCYREPEAT OF 2023-013QUESTIONED COSTSOTHER MATTERS

Expenditures were incurred and charged after the period of performance had ended. Cause: Department controls failed to prevent charging the grant for costs incurred outside the applicable period of performance. Effect: Costs charged outside the period of performance may not be allowable. Questioned Costs: $1,540 Context: One of the five transactions selected for testing costs for which the obligation had not been paid as of the end of period of performance had cost incurred after the ending period of performance. This is a repeat finding from the fiscal year 2023 Single Audit. The Department stated on its Summary Schedule of Prior Year Audit Findings that this issue was “Fully Corrected with Previously Reported Corrective Action Implemented”. Due to this issue repeating for fiscal year 2024, this issue has not been fully corrected. Prior Year Single Audit Report Finding Number: 2023-013 Recommendation: We recommend that the Department continues to review and update its internal controls to ensure that expenditures charged to their federal grants are incurred within the grant’s period of performance. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 133.

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Federal Agency: Department of Health and Human Services Federal Program Title: Block Grants for Prevention and Treatment of Substance Abuse Assistance Listing: 93.959 Federal Grant ID Number: B08TI083544 Pass-Through Entity: Not applicable Award Period: March 15, 2021, through March 14, 2024 Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: 2 CFR § 200.403(h) requires costs be incurred during the approved budget period. Condition: Expenditures were incurred and charged after the period of performance had ended. Cause: Department controls failed to prevent charging the grant for costs incurred outside the applicable period of performance. Effect: Costs charged outside the period of performance may not be allowable. Questioned Costs: $1,540 Context: One of the five transactions selected for testing costs for which the obligation had not been paid as of the end of period of performance had cost incurred after the ending period of performance. This is a repeat finding from the fiscal year 2023 Single Audit. The Department stated on its Summary Schedule of Prior Year Audit Findings that this issue was “Fully Corrected with Previously Reported Corrective Action Implemented”. Due to this issue repeating for fiscal year 2024, this issue has not been fully corrected. Prior Year Single Audit Report Finding Number: 2023-013 Recommendation: We recommend that the Department continues to review and update its internal controls to ensure that expenditures charged to their federal grants are incurred within the grant’s period of performance. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 133.

Corrective Action Plan

The South Carolina Department of Alcohol and Other Drug Abuse Services respectfully submits the following corrective action plan for the year ended June 30, 2024, on behalf of the State of South Carolina. The findings from the Schedule of Findings and Questioned Costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAM AUDIT U.S. Department of Health and Human Services 2024-005 Block Grants for Prevention and Treatment of Substance Abuse – Assistance Listing No. 93.959 Disposition of Audit Finding: The Department concurs with the audit finding. Corrective Action: The Department will establish additional policies and procedures to ensure all expenditures are processed within the period of performance of the award. The new policies and procedures will include, but are not limited to, the creation of a standardize award expenditure review checklist, additional training for programmatic and finance staff, pre-approval of expenditures incurring near the award’s obligation ending date, a secondary review of all expenditures and journal entries processed during and after the award’s liquidation period, and quarterly monitoring by the internal auditor group to ensure compliance with the award’s period of performance requirements. Anticipated Completion Date: June 1, 2025 Name of the contact person responsible for corrective action: Angela Outing, Administrative Manager, at 803-896-5547

Prior Finding References

2023-013

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2024-006
Special Tests & Provisions
SIGNIFICANT DEFICIENCYOTHER MATTERS

The Department of Health and Human Services (Department) was unable to provide documentation to verify that annual health and safety surveys were performed during the fiscal year. Cause: The Department did not maintain a record of completed annual health and safety surveys. Effect: We were unable to verify that the State ensured providers met the prescribed health and safety standards. Questioned Costs: None Context: The Department could not provide annual health and safety surveys in accordance with the State Plan. Therefore, we were unable to perform audit procedures. Prior Year Single Audit Finding Number: Not applicable. Recommendation: We recommend that the Department ensure that provider health and safety surveys are conducted in accordance with the State Plan and documentation is adequately maintained. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 134.

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Federal Agency: Department of Health and Human Services Federal Program Title: Medicaid Cluster Assistance Listing: 93.775, 93.777, and 93.778 Federal Grant ID Number: 05-2305-SC-5MAP and 05-2405-SC-5MAP Pass-Through Entity: Not Applicable Award Period: October 1, 2022, through September 30, 2024 Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: Per 2 CFR § 200.303 (a), non-Federal entities 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. Per Section 4 of the South Carolina Department of Health and Human Services State Plan (h) the State assures that each facility shall have a standard survey which includes (for a case-mix stratified sample of residents) a survey of the quality of care furnished, as measured by indicators of medical, nursing and rehabilitative care, dietary and nutritional services, activities and social participation, and sanitation, infection control, and the physical environment, written plans of care and audit of resident’s assessments, and a review of compliance with resident’s rights not later than 15 months after the date of the previous standard survey. Additionally, Section 4 (i) states that the State assures that the Statewide average interval between standard surveys of nursing facilities does not exceed 12 months. Condition: The Department of Health and Human Services (Department) was unable to provide documentation to verify that annual health and safety surveys were performed during the fiscal year. Cause: The Department did not maintain a record of completed annual health and safety surveys. Effect: We were unable to verify that the State ensured providers met the prescribed health and safety standards. Questioned Costs: None Context: The Department could not provide annual health and safety surveys in accordance with the State Plan. Therefore, we were unable to perform audit procedures. Prior Year Single Audit Finding Number: Not applicable. Recommendation: We recommend that the Department ensure that provider health and safety surveys are conducted in accordance with the State Plan and documentation is adequately maintained. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 134.

Corrective Action Plan

The Department of Health and Human Services respectfully submits the following corrective action plan for the year ended June 30, 2024, on behalf of the State of South Carolina. The finding from the schedule of findings and questioned costs are discussed below. The finding numbered consistently with the number assigned in the schedule. FINDING—FEDERAL AWARD PROGRAM AUDIT U.S. Department of Health and Human Services 2024-006 Medicaid Cluster – Assistance Listing No. 93.775, 93.777, and 93.778 Disposition of Audit Finding: The Department of Health and Human Services concurs with the audit finding. Corrective Action: In accordance with the current contract with the state survey and certification agency, the South Carolina Department of Public Health (SCDPH), SCDHHS will ensure SCDPH submits a quarterly summary report to SCDHHS which identifies nursing facilities surveyed, and F tags cited, including scope and severity measures. SCDHHS will also ensure that SCDPH submits a cumulative end-of-year report confirming that each facility has had a survey within an average interval not to exceed 12 months, and no later than 15 months after the date of the previous survey. SCDHHS will schedule on-going quarterly meetings with SCDPH to review the reports and discuss the findings. The first meeting will be scheduled during the second quarter 2025 (April – June 2025) to review reports for Third Quarter 2024 and First Quarter 2025. Subsequent quarterly reports will be due the month after the reporting period and ongoing quarterly meetings will be scheduled. SCDHHS’s Office of Waiver and Facility Services will maintain a copy of the quarterly reports, annual reports, meeting agendas and minutes on its internal SharePoint site. Anticipated Completion Date: October 31, 2025 Names of the contact persons responsible for corrective action: SCDHHS Agency contacts: Russell Morrison at (803) 898-3044 Lisa Ragland at (803) 898-1387

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2024-007
Special Tests & Provisions
SIGNIFICANT DEFICIENCYOTHER MATTERS

Documentation was not adequate to support compliance with oversight and monitoring responsibilities. Cause: The Department’s internal controls failed to ensure compliance with paid lunch equity requirements. Effect: Without a thorough annual review, subrecipients could receive incorrect funding. Questioned Costs: None Context: During a Department administrative review, one School Food Authority (SFA) had a negative balance as of June 30, 2022, and failed to provide sufficient documentation to support it. Department program personnel ended the paid lunch equity review without ensuring the SFA assessed the need to raise paid lunch prices for the current school year. Prior Year Single Audit Finding Number: Not applicable. Recommendation: We recommend the Department strengthen procedures to ensure proper documentation is maintained for the paid lunch equity requirement. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 135.

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Federal Agency: Department of Agriculture Federal Program Title: Child Nutrition Cluster Assistance Listings: 10.553, 10.555, 10.559, and 10.582 Federal Grant ID Number: None Pass-Through Entity: Not applicable Award Period: October 01, 2023, through September 30, 2024 Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: 2 CFR § 200.303 requires that the 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. Condition: Documentation was not adequate to support compliance with oversight and monitoring responsibilities. Cause: The Department’s internal controls failed to ensure compliance with paid lunch equity requirements. Effect: Without a thorough annual review, subrecipients could receive incorrect funding. Questioned Costs: None Context: During a Department administrative review, one School Food Authority (SFA) had a negative balance as of June 30, 2022, and failed to provide sufficient documentation to support it. Department program personnel ended the paid lunch equity review without ensuring the SFA assessed the need to raise paid lunch prices for the current school year. Prior Year Single Audit Finding Number: Not applicable. Recommendation: We recommend the Department strengthen procedures to ensure proper documentation is maintained for the paid lunch equity requirement. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 135.

Corrective Action Plan

The South Carolina Department of Education respectfully submits the following corrective action plan for the year ended June 30, 2024, on behalf of the State of South Carolina. The finding from the schedule of findings and questioned costs are discussed below. The finding is numbered consistently with the number assigned in the schedule. Finding—FEDERAL AWARD PROGRAM AUDIT Department of Education 2024 - 007 Child Nutrition – Assistance Listing No. 10.553, 10.555, 10.559, 10.582 Disposition of Audit Finding: The SC Department of Education concurs with the audit finding. Corrective Action: The Office of Health and Nutrition staff must note on financial reviews when the General Fund of an SFA contributes to the child nutrition account. Staff will include documentation or a statement from the SFA to certify that non-Federal funds were used to support the paid lunch price when the SFA does not complete the PLE tool or have a positive fund balance. . Anticipated Completion Date: Immediate implementation Names of the contact persons responsible for corrective action: • Ellen Mason at 803-734-8199 • Heather Snelgrove at 803-734-6034

About Special Tests and Provisions →
2024-008
Reporting
SIGNIFICANT DEFICIENCYOTHER MATTERS

Discrepancies were identified in the reported amounts on SF-425 reports. Cause: The Department’s review of semi-annual SF-425 reports submitted during fiscal year 2024 failed to detect discrepancies in reported amounts. Effect: Without proper supervisory review, there is an increased risk of inaccurate reporting. Questioned Costs: None Context: In four of eight SF-425 reports tested, reporting discrepancies in financial data were identified related to federal share of expenditures, and recipient share of expenditures. Prior Year Single Audit Finding Numbers: Not applicable. Recommendation: We recommend the Department strengthen procedures to ensure an adequate review is completed prior to report submission and records are maintained of adjustments made within the period. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 136.

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Federal Agency: Department of Health and Human Services Federal Program Title: Aging Cluster Assistance Listing: 93.044, 93.045, and 93.053 Federal Grant ID Number: None Pass-Through Entity: Not Applicable Award Period: July 1, 2023, through June 30, 2025 Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: 2 CFR § 200.303 requires that the 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. Condition: Discrepancies were identified in the reported amounts on SF-425 reports. Cause: The Department’s review of semi-annual SF-425 reports submitted during fiscal year 2024 failed to detect discrepancies in reported amounts. Effect: Without proper supervisory review, there is an increased risk of inaccurate reporting. Questioned Costs: None Context: In four of eight SF-425 reports tested, reporting discrepancies in financial data were identified related to federal share of expenditures, and recipient share of expenditures. Prior Year Single Audit Finding Numbers: Not applicable. Recommendation: We recommend the Department strengthen procedures to ensure an adequate review is completed prior to report submission and records are maintained of adjustments made within the period. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 136.

Corrective Action Plan

The South Carolina Department on Aging (SCDOA) respectfully submits the following corrective action plan for the year ended June 30, 2024, on behalf of the State of South Carolina. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS —FEDERAL AWARD PROGRAM AUDIT U.S. Department of Health and Human Services (HHS) – Administration for Community Living (ACL) 2024-008 Aging Cluster – Assistance Listing No. 93.044, 93.045, and 93.053 Disposition of Audit Finding: The SCDOA concurs with the audit finding. Corrective Action: SCDOA will implement a review process for SF-425 submission. The Finance Director will review SF-425 Reports completed by the Grant Administrator for accuracy before final submission. Anticipated Completion Date: 03.31.2025 Names of the contact persons responsible for corrective action: • Syeeda Gallman, Finance Director at 803.734.9917 • Towanda Prior, Grants Administrator at 803.734.9950

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2024-009
Reporting
SIGNIFICANT DEFICIENCYOTHER MATTERS

We identified noncompliance with FFATA reporting requirements. Cause: The Department’s internal controls failed to detect the lack of timely and accurate reporting, as well as the non-compliance with federal FFATA filing requirements. Effect: The Department failed to meet federal FFATA filing requirements. Questioned Costs: None Context: The Department did not submit any FFATA reports during FY24, although it had subawards of $30,000 or more. Prior Year Single Audit Finding Numbers: Not applicable. Recommendation: We recommend the Department strengthen procedures to ensure timely and accurate filing of FFATA reports. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 137.

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Federal Agency: Department of Health and Human Services Federal Program Title: Aging Cluster Assistance Listing: 93.044, 93.045, and 93.053 Federal Grant ID Number: None Pass-Through Entity: Not Applicable Award Period: July 1, 2023, through June 30, 2024 Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: 2 CFR § 170 Appendix A requires that recipients of grants or cooperative agreements report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act (FFATA) Subaward Reporting System (FSRS) no later than the end of the month following the month in which the obligation was made. Condition: We identified noncompliance with FFATA reporting requirements. Cause: The Department’s internal controls failed to detect the lack of timely and accurate reporting, as well as the non-compliance with federal FFATA filing requirements. Effect: The Department failed to meet federal FFATA filing requirements. Questioned Costs: None Context: The Department did not submit any FFATA reports during FY24, although it had subawards of $30,000 or more. Prior Year Single Audit Finding Numbers: Not applicable. Recommendation: We recommend the Department strengthen procedures to ensure timely and accurate filing of FFATA reports. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 137.

Corrective Action Plan

The South Carolina Department on Aging (SCDOA) respectfully submits the following corrective action plan for the year ended June 30, 2024, on behalf of the State of South Carolina. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS —FEDERAL AWARD PROGRAM AUDIT U.S. Department of Health and Human Services (HHS) – Administration for Community Living (ACL) 2024-009 Aging Cluster – Assistance Listing No. 93.044, 93.045, and 93.053 Disposition of Audit Finding: The SCDOA concurs with the audit finding. Corrective Action: Once SCDOA was made aware of FFATA reporting requirements, immediate action was taken for compliance. Research was conducted to understand the submission process, and necessary information was gathered to refine procedures to ensure accurate and timely submissions moving forward. Anticipated Completion Date: 06.30.2025 Names of the contact persons responsible for corrective action: • Loretta Dykes, Accounts Payable at 803.734.9877 • Towanda Prior, Grants Administrator at 803.734.9950

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2024-010
Period of Performance
SIGNIFICANT DEFICIENCYQUESTIONED COSTSOTHER MATTERS

Expenditures were incurred outside of the period of performance. Cause: Department controls failed to prevent charging the grant for costs incurred outside the applicable period of performance. Effect: Costs charged outside the period of performance may not be allowable. Questioned Costs: $26,975 Context: Two of the three transactions selected for testing from costs recorded during the beginning period of the grant were for costs incurred prior to the applicable period of performance. Prior Year Single Audit Finding Number: Not applicable Recommendation: We recommend that the Department review and update internal controls to ensure all expenditures charged to a federal award are incurred within the grant’s period of performance. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 138.

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Federal Agency: Department of Health and Human Services Federal Program Title: Block Grants for Community Mental Health Services Assistance Listing: 93.958 Federal Grant ID Number: B09SM089607 Pass-Through Entity: Not Applicable Award Period: October 1, 2023, through September 30, 2025 Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: 2 CFR § 200.303 requires that the non-federal entity 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. 2 CFR § 200.403(h) requires costs be incurred during the approved budget period. Condition: Expenditures were incurred outside of the period of performance. Cause: Department controls failed to prevent charging the grant for costs incurred outside the applicable period of performance. Effect: Costs charged outside the period of performance may not be allowable. Questioned Costs: $26,975 Context: Two of the three transactions selected for testing from costs recorded during the beginning period of the grant were for costs incurred prior to the applicable period of performance. Prior Year Single Audit Finding Number: Not applicable Recommendation: We recommend that the Department review and update internal controls to ensure all expenditures charged to a federal award are incurred within the grant’s period of performance. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 138.

Corrective Action Plan

The Department of Mental Health respectfully submits the following corrective action plan for the year ended June 30, 2024, on behalf of the State of South Carolina. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS-FEDERAL AWARD PROGRAM AUDIT U.S. Department of Health and Human Services 2024-010 Block Grants for Community Mental Services - Assistance Listing No. 93.958 Disposition of Audit Finding: The Department of Mental Health concurs with the audit finding. Corrective Action: Journal entries were completed to move unallowable costs to non-grant funds and correct expenditures and revenue prior to final grant reporting. Grants Administration will increase monitoring at the beginning of all grant periods of performance, and an additional staff member at the center level will review invoices prior to submission for payment. Anticipated Completion Date: 05/31/2025 Name of the contact person responsible for corrective action: • Liza Watson at (803) 898-8457

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2024-011
Matching, Level of Effort, Earmarking
SIGNIFICANT DEFICIENCYOTHER MATTERS

The Department did not comply with federal earmarking minimum spending requirements. Cause: Department controls failed to ensure that the earmarking requirements were met prior to the grant closing. Effect: The Department was not in compliance with the federal earmarking requirements. Questioned Costs: Not applicable Context: The Department did not meet the ten percent evidence-based expenditure threshold and five percent crisis care expenditure threshold mandated by earmarking requirements. Prior Year Single Audit Finding Number: Not applicable Recommendation: We recommend that the Department review its policies and procedures and update internal controls to ensure earmarking requirements are met. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 139.

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Federal Agency: Department of Health and Human Services Federal Program Title: Block Grants for Community Mental Health Services Assistance Listing: 93.958 Federal Grant ID Number: B09SM085991 Pass-Through Entity: Not Applicable Award Period: October 1, 2021, through September 30, 2023 Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: 2 CFR § 200.303 requires that the non-federal entity 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. 42 USC 300x-9(c) requires that a state shall expend not less than ten percent of grant funds for carrying out evidence-based programs that address the needs of individuals with early serious mental illness, including psychotic disorders, regardless of the age of the individual at onset. 42 USC 300x-9(d) requires that a state shall expend at least five percent of grant funds to support evidence-based programs that address the crisis care needs of individuals with serious mental illnesses (SMI) and children with serious emotional disturbances (SED), which may include individuals experiencing mental health crises demonstrating serious mental illness or serious emotional disturbance, as applicable. Condition: The Department did not comply with federal earmarking minimum spending requirements. Cause: Department controls failed to ensure that the earmarking requirements were met prior to the grant closing. Effect: The Department was not in compliance with the federal earmarking requirements. Questioned Costs: Not applicable Context: The Department did not meet the ten percent evidence-based expenditure threshold and five percent crisis care expenditure threshold mandated by earmarking requirements. Prior Year Single Audit Finding Number: Not applicable Recommendation: We recommend that the Department review its policies and procedures and update internal controls to ensure earmarking requirements are met. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 139.

Corrective Action Plan

The Department of Mental Health respectfully submits the following corrective action plan for the year ended June 30, 2024, on behalf of the State of South Carolina. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS-FEDERAL AWARD PROGRAM AUDIT U.S. Department of Health and Human Services 2024-011 93.958 Block Grants for Community Mental Services - Assistance Listing No. Disposition of Audit Finding: The Department of Mental Health concurs with the audit finding. Corrective Action: As of SFY25, the Department has successfully expanded its crisis programs and is meeting compliance requirements for evidence-based crisis services. The Department will continue to expand its evidencebased ESMI programs to meet compliance requirement expenditure amounts. We are on track to meeting compliance fully by SFY28 once the supplemental grants for ARPA and CARES have ended. Anticipated Completion Date: 12/31/2027 Name of the contact person responsible for corrective action: • Denise Morgan at (803) 898-7182

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2024-012
Reporting
SIGNIFICANT DEFICIENCY

FFATA report did not have documentation supporting a review by an employee other than the preparer prior to submission. Cause: The Department has a policy requiring a report reviewer; however, the policy did not require documentation of actual approval. Effect: Without a supervisory review, there is an increased risk of inaccurate reporting. Questioned Costs: None Context: For the FFATA report tested, no documentation supporting a supervisory review and approval was provided. Prior Year Single Audit Finding Number: Not applicable Recommendation: We recommend that the Department strengthen policies and procedure to require documentation of a report reviewer other than the preparer, prior to submission. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 140.

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Federal Agency: Department of Health and Human Services Federal Program Title: Low-Income Home Energy Assistance Program Assistance Listing: 93.568 Federal Grant ID Number: 2402SCLIEA Pass-Through Entity: Not applicable Award Period: October 1, 2023, through September 30, 2025 Type of Finding: Significant deficiency in internal control over compliance Criteria: 2 CFR § 200.303 requires that the 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. Condition: FFATA report did not have documentation supporting a review by an employee other than the preparer prior to submission. Cause: The Department has a policy requiring a report reviewer; however, the policy did not require documentation of actual approval. Effect: Without a supervisory review, there is an increased risk of inaccurate reporting. Questioned Costs: None Context: For the FFATA report tested, no documentation supporting a supervisory review and approval was provided. Prior Year Single Audit Finding Number: Not applicable Recommendation: We recommend that the Department strengthen policies and procedure to require documentation of a report reviewer other than the preparer, prior to submission. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 140.

Corrective Action Plan

The South Carolina Department of Administration respectfully submits the following corrective action plan for the year ended June 30, 2024, on behalf of the State of South Carolina. The finding from the Schedule of Findings and Questioned Costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAM AUDIT U. S. Department of Health and Human Services 2024 – 012 Federal Program Title: Low-Income Home Energy Assistance Program – Assistance Listing: 93.568 Disposition of Audit Finding: The South Carolina Department of Administration concurs with the audit finding. Corrective Action: The Office of Economic Opportunity, an office within the South Carolina Department of Administration, implemented a review process whereby a copy of the Federal Funding Accountability and Transparency Act (FFATA) report prepared in the FFATA Subaward Reporting System (FSRS), along with support documentation is attached to a routing sheet. This sheet is reviewed by the Fiscal Services Manager for accuracy. Once reviewed and approved, the Fiscal Services Manager will sign off on the routing sheet and the FFATA report will be submitted in FSRS. In the event that the Fiscal Services Manager is the preparer of the report, or the Fiscal Services Manager position is vacant, another OEO Fiscal staff member will review the report for accuracy and sign off on the routing sheet prior to submission. Anticipated Completion Date: December 2024 Name of the contact person responsible for corrective action: Kimberly Cosare, Chief Compliance Officer, at (803) 734-4063.

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2024-013
Subrecipient Monitoring
SIGNIFICANT DEFICIENCY

The Department failed to provide documentation to prove the existence of an internal control. Cause: Financial monitoring is completed virtually on an annual basis by the grants accountant and reviewed by the grants accounting manager; however, there is an absence of documented evidence to support the review process. Effect: Without adequate controls in place, the Department may not monitor the subrecipients in accordance with requirements. Questioned Costs: None Context: For three of the eight items tested, the Annual Financial Monitoring Form does not have the grants accounting manager’s approval signature. Prior Year Single Audit Finding Number: Not applicable. Recommendation: We recommend that the Department strengthen controls to ensure that documentation is maintained to support that the Financial Monitoring Form is reviewed and approved by the grants accounting manager. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 141.

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Federal Agency: Department of Transportation Federal Program Title: Highway Safety Cluster Assistance Listing: 20.600 and 20.616 Federal Grant ID Number: Various Pass-Through Entity: Not applicable Award Period: October 1, 2023, through September 30, 2024 Type of Finding: Significant deficiency in internal control over compliance Criteria: 2 CFR § 200.303 requires that the non-federal entity 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. Condition: The Department failed to provide documentation to prove the existence of an internal control. Cause: Financial monitoring is completed virtually on an annual basis by the grants accountant and reviewed by the grants accounting manager; however, there is an absence of documented evidence to support the review process. Effect: Without adequate controls in place, the Department may not monitor the subrecipients in accordance with requirements. Questioned Costs: None Context: For three of the eight items tested, the Annual Financial Monitoring Form does not have the grants accounting manager’s approval signature. Prior Year Single Audit Finding Number: Not applicable. Recommendation: We recommend that the Department strengthen controls to ensure that documentation is maintained to support that the Financial Monitoring Form is reviewed and approved by the grants accounting manager. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 141.

Corrective Action Plan

The South Carolina Department of Public Safety respectfully submits the following corrective action plan for the year ended June 30, 2024. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAM AUDIT U.S. Department of Transportation 2024-013 State and Community Highway Safety & National Priority Safety Programs -Assistance Listing No. 20.600 & 20.616 Disposition of Audit Finding: The South Carolina Department of Public Safety concurs with the audit finding. Corrective Action: The Department will update the Highway Safety Grant Program’s Financial Procedures Manual to include the Highway Safety Grants Accounting Manager’s signature on all monitoring reports. Anticipated Completion Date: 3/7/2025 Joyce McCarty, Business Manager, and Angela Campbell, Highway Safety Grants Accounting Manager, will be responsible for corrective action: • Joyce McCarty at 803-896-7732 • Angela Campbell at 803-896-7815

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2024-014
Reporting
SIGNIFICANT DEFICIENCY

The Department failed to provide documentation to prove the existence of an internal control. Cause: Management verbally approved the report once the review was complete. Effect: Without adequate controls in place the Department could inaccurately submit a report. Questioned Costs: None Context: For both of the reports tested, management did not properly document a review of the FFATA. Prior Year Single Audit Finding Number: Not applicable. Recommendation: We recommend the Department update their internal controls to include continuous monitoring and reviewing of project obligations to ensure that reports are submitted in compliance with FFATA reporting requirements. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 141.

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Federal Agency: Department of Transportation Federal Program Title: Highway Safety Cluster Assistance Listing: 20.600 and 20.616 Federal Grant ID Number: Various Pass-Through Entity: Not applicable Award Period: October 1, 2023, through September 30, 2026 Type of Finding: Significant deficiency in internal control over compliance Criteria: 2 CFR § 200.303 requires that the non-federal entity 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. Condition: The Department failed to provide documentation to prove the existence of an internal control. Cause: Management verbally approved the report once the review was complete. Effect: Without adequate controls in place the Department could inaccurately submit a report. Questioned Costs: None Context: For both of the reports tested, management did not properly document a review of the FFATA. Prior Year Single Audit Finding Number: Not applicable. Recommendation: We recommend the Department update their internal controls to include continuous monitoring and reviewing of project obligations to ensure that reports are submitted in compliance with FFATA reporting requirements. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 141.

Corrective Action Plan

The South Carolina Department of Public Safety respectfully submits the following corrective action plan for the year ended June 30, 2024. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAM AUDIT U.S. Department of Transportation 2024-014 State and Community Highway Safety & National Priority Safety Programs – Assistance Listing No. 20.600 & 20.616 Disposition of Audit Finding: The South Carolina Department of Public Safety concurs with the audit finding. Corrective Action: The Department will update the Highway Safety Grant Program’s Financial Procedures Manual to include a review and signature approval process by the Grants Administration Accountant and the Grants Accounting Manager prior to the FFATA report submission. Anticipated Completion Date: 3/7/2025 Joyce McCarty, Business Manager, and Angela Campbell, Highway Safety Grants Accounting Manager will be responsible for corrective action: • Joyce McCarty at 803-896-7732 • Angela Campbell at 803-896-7815

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2024-015
Activities Allowed or Unallowed / Cost Allowability
SIGNIFICANT DEFICIENCY

The Department failed to provide documentation to prove the existence of an internal control. Cause: The Chief Financial Officer verbally approved the transaction; however, there was an absence of documented evidence to support the internal control process. Effect: Without adequate controls in place, unallowable expenditures may be charged to the grant. Questioned Costs: None Context: For the one transaction tested, no documentation was available to prove the existence of an internal control. Prior Year Single Audit Finding Number: Not applicable. Recommendation: We recommend that the Academy strengthen controls to ensure that documentation is maintained to support that costs charged to the grant were properly reviewed and approved for allowability. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 143.

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Federal Agency: Department of Transportation Federal Program Title: Highway Safety Cluster Assistance Listing: 20.600 and 20.616 Federal Grant ID Number: M5TR-2024-HS-26-24 Pass-Through Entity: Not applicable Award Period: October 1, 2023, through September 30, 2024 Type of Finding: Significant deficiency in internal control over compliance Criteria: 2 CFR § 200.303 requires that the non-federal entity 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. Condition: The Department failed to provide documentation to prove the existence of an internal control. Cause: The Chief Financial Officer verbally approved the transaction; however, there was an absence of documented evidence to support the internal control process. Effect: Without adequate controls in place, unallowable expenditures may be charged to the grant. Questioned Costs: None Context: For the one transaction tested, no documentation was available to prove the existence of an internal control. Prior Year Single Audit Finding Number: Not applicable. Recommendation: We recommend that the Academy strengthen controls to ensure that documentation is maintained to support that costs charged to the grant were properly reviewed and approved for allowability. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 143.

Corrective Action Plan

Criminal Justice Academy respectfully submits the following corrective action plan for the year ended June 30, 2024, on behalf of the State of South Carolina. The findings from the schedule of findings and questioned costs are discussed below. The findings numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAM AUDIT Department of Transportation 2024-015 State and Community Highway Safety & National Priority Safety Programs - Assistance Listing No. 20.600 & 20.616 Disposition of Audit Finding: The South Carolina Criminal Justice Academy (SCCJA) concurs with the audit finding. Corrective Action: The SCCJA will update our desktop procedures to require that all grant expense paperwork will be signed by the CFO or an email indicating approval will be sent by the CFO and a copy of the signed document or email will be attached to the document in SCEIS. Anticipated Completion Date: 3/3/2025 The contact responsible for corrective action: • Lauren Parker Wright at (803) 468-5623

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2024-016
Period of Performance
SIGNIFICANT DEFICIENCY

The Academy failed to provide documentation to prove the existence of an internal control. Cause: The Chief Financial Officer verbally approved the transaction; however, there was an absence of documented evidence to support the internal control process Effect: The costs charged outside the period of performance may not be allowable. Questioned Costs: None Context: For three of eighteen expenditures tested, the CFO was unable to provide sufficient documentation of a review and approval. Prior Year Single Audit Report Finding Number: Not applicable. Recommendation: We recommend that the Academy strengthen controls to ensure that documentation is maintained to support that period of performance requirements are reviewed and approved. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 143.

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Full finding narrative

Federal Agency: Department of Transportation Federal Program Title: Highway Safety Cluster Assistance Listing: 20.600 and 20.616 Federal Grant ID Number: Various Pass-Through Entity: Not applicable Award Period: October 1, 2023, through September 30, 2024 Type of Finding: Significant deficiency in internal control over compliance Criteria: 2 CFR § 200.303 requires that the non-federal entity 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. Condition: The Academy failed to provide documentation to prove the existence of an internal control. Cause: The Chief Financial Officer verbally approved the transaction; however, there was an absence of documented evidence to support the internal control process Effect: The costs charged outside the period of performance may not be allowable. Questioned Costs: None Context: For three of eighteen expenditures tested, the CFO was unable to provide sufficient documentation of a review and approval. Prior Year Single Audit Report Finding Number: Not applicable. Recommendation: We recommend that the Academy strengthen controls to ensure that documentation is maintained to support that period of performance requirements are reviewed and approved. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 143.

Corrective Action Plan

Criminal Justice Academy respectfully submits the following corrective action plan for the year ended June 30, 2024, on behalf of the State of South Carolina. The findings from the schedule of findings and questioned costs are discussed below. The findings numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAM AUDIT Department of Transportation 2024-016 State and Community Highway Safety & National Priority Safety Programs – Assistance Listing No. 20.600 & 20.616 Disposition of Audit Finding: The SCCJA concurs with the audit finding. Corrective Action: The SCCJA will update our desktop procedures to require documented CFO approval via signature or email attached to SCEIS document for all grant expenses. This includes travel documents, IDTS, journal entries, and any documentation submitted for approval to our grantee organization. Anticipated Completion Date: 3/3/20 The contact person responsible for corrective action: • Lauren Wright at (803) 468-5622

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2024-017
Activities Allowed or Unallowed / Cost Allowability
MATERIAL WEAKNESSMODIFIED OPINIONQUESTIONED COSTS

Expenditures charged to the program were not adequately supported. Cause: The Department lacks sufficient controls to ensure that expenditures are allowable and properly supported with documentation. Effect: The potential for overcharging the grant exists when transactions charged to federal awards are not adequately supported. Questioned Costs: $1,580,113 Context: For four transactions tested, the Department was unable to provide documentation with sufficient details to support the specific services rendered. Prior year Single Audit Report Finding Number: Not applicable Recommendation: We recommend that the Department review and update its procedures to ensure all costs charged to the grant are allowable and properly allocated to the grant. Views of Responsible Officials and Corrective Actions Plan: Management agrees with the finding. See Corrective Action Plan at page 145.

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Federal Agency: Department of Health and Human Services Federal Program Title: Refugee and Entrant Assistance Assistance Listing: 93.566 Federal Grant ID Numbers: 2201SCRSSS and 2301SCRSSS Pass-Through Entity: Not applicable Award Period: October 1, 2021, through September 30, 2025 Type of Finding: Material weakness in internal control over compliance, material noncompliance Criteria: 45 CFR § 75.303(a) requires effective internal controls be established and maintained in order to provide reasonable assurance that the federal award is being managed in compliance with federal statutes, regulations, and the terms and conditions of the federal award. 45 CFR § 75.403 outlines factors affecting allowability of costs, including adequate documentation. Condition: Expenditures charged to the program were not adequately supported. Cause: The Department lacks sufficient controls to ensure that expenditures are allowable and properly supported with documentation. Effect: The potential for overcharging the grant exists when transactions charged to federal awards are not adequately supported. Questioned Costs: $1,580,113 Context: For four transactions tested, the Department was unable to provide documentation with sufficient details to support the specific services rendered. Prior year Single Audit Report Finding Number: Not applicable Recommendation: We recommend that the Department review and update its procedures to ensure all costs charged to the grant are allowable and properly allocated to the grant. Views of Responsible Officials and Corrective Actions Plan: Management agrees with the finding. See Corrective Action Plan at page 145.

Corrective Action Plan

The South Carolina Department of Social Services respectfully submits the following corrective action plan for the year ended June 30, 2024, on behalf of the State of South Carolina. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the number or numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAM AUDIT U. S. Department of Health and Human Services 2024 – 017 Federal Program Title: Refugee and Entrant Assistance Program – Assistance Listing: 93.566 Disposition of Audit Finding: The South Carolina Department of Social Services concurs with the audit finding. Corrective Action: The Department will ensure that all grant recipients and subrecipients are required to submit an itemized statement showing the breakdown of services rendered for each client, along with case management services with their monthly invoice for each program. This will ensure all costs are allowable, properly allocated, and supported with complete documentation. Anticipated Completion Date: June 30, 2025 Name of the contact person responsible for corrective action: Ambrea Jones, State Refugee Program Manager

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2024-018
Eligibility
SIGNIFICANT DEFICIENCYQUESTIONED COSTSOTHER MATTERS

The Department was not in compliance with several eligibility requirements. Cause: The Department did not have adequate internal controls in place to prevent the issues identified. Effect: The Department is not in compliance with eligibility requirements. Questioned Costs: $410 Context: Sixty case files were selected for testing and the following discrepancies were identified: (1) All case files tested lacked documentation to show that the Department verified that the individuals were not full-time students at institutions of higher education. (2) Benefit payments were not properly calculated for seven cases. (3) Benefit payments were expensed outside of the twelve-month eligibility period for two cases. (4) The Department was unable to provide an existing control set in place for eligibility. Prior year Single Audit Report Finding Number: Not applicable Recommendation: We recommend that the Department establish policies and procedures to ensure compliance with eligibility requirements. In addition, we recommend that the Department implement internal control procedures to ensure all elements of eligibility requirements are being met. Views of Responsible Officials and Corrective Actions Plan: Management agrees with the finding. See Corrective Action Plan at page 145.

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Full finding narrative

Federal Agency: Department of Health and Human Services Federal Program Title: Refugee and Entrant Assistance Assistance Listing: 93.566 Federal Grant ID Numbers: 2301SCRCMA and 2401SCRCMA Pass-Through Entity: Not applicable Award Period: October 1, 2022, through September 30, 2025 Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: 45 CFR § 75.303(a) requires effective internal controls be established and maintained in order to provide reasonable assurance that the federal award is being managed in compliance with federal statutes, regulations, and the terms and conditions of the federal award. 45 CFR § 400.53 (a)(4) requires eligibility for refugee cash assistance be limited to those who are not full-time students in institutions of higher education, as defined by the Director. 45 CFR § 400.66 states requirements for benefit payment calculations. 45 CFR § 400.211 provides the methodology of the time-eligibility period for refugees. Condition: The Department was not in compliance with several eligibility requirements. Cause: The Department did not have adequate internal controls in place to prevent the issues identified. Effect: The Department is not in compliance with eligibility requirements. Questioned Costs: $410 Context: Sixty case files were selected for testing and the following discrepancies were identified: (1) All case files tested lacked documentation to show that the Department verified that the individuals were not full-time students at institutions of higher education. (2) Benefit payments were not properly calculated for seven cases. (3) Benefit payments were expensed outside of the twelve-month eligibility period for two cases. (4) The Department was unable to provide an existing control set in place for eligibility. Prior year Single Audit Report Finding Number: Not applicable Recommendation: We recommend that the Department establish policies and procedures to ensure compliance with eligibility requirements. In addition, we recommend that the Department implement internal control procedures to ensure all elements of eligibility requirements are being met. Views of Responsible Officials and Corrective Actions Plan: Management agrees with the finding. See Corrective Action Plan at page 145.

Corrective Action Plan

The South Carolina Department of Social Services respectfully submits the following corrective action plan for the year ended June 30, 2024, on behalf of the State of South Carolina. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the number or numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAM AUDIT U. S. Department of Health and Human Services 2024 – 018 Federal Program Title: Refugee and Entrant Assistance Program – Assistance Listing: 93.566 Disposition of Audit Finding: The South Carolina Department of Social Services concurs with the audit finding. Corrective Action: The Department will implement monthly report requirements from case managers to update and verify whether individual Refugee Cash Assistance recipients/individuals are enrolled as full-time students at institutions of higher education. If attested for enrollment, follow-up documentation will be required to be completed by higher education officials for school enrollment verification. Also, the implementation of a data management system will ensure compliance with all eligibility requirements. The system will also produce properly calculated and timely payments. Anticipated Completion Date: June 30, 2025 Name of the contact person responsible for corrective action: Ambrea Jones, State Refugee Program Manager

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2024-019
Reporting
SIGNIFICANT DEFICIENCYOTHER MATTERS

The Department did not ensure one key line-item was accurately reported on the financial report. Cause: The Department's internal controls failed to prevent inaccurate reporting of expenditures. Effect: The accuracy of the financial report could not be validated. Questioned Costs: None Context: The reported federal share of expenditures did not agree to supporting documentation. Prior Year Single Audit Finding Number: Not applicable Recommendation: We recommend the Department strengthen its internal controls to ensure all reports are accurately prepared and submitted. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 146.

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Full finding narrative

Federal Agency: Department of Health and Human Services Federal Program Title: Refugee and Entrant Assistance Assistance Listing: 93.566 Federal Grant ID Number: 2101SCRSSS Pass-Through Entity: Not applicable Award Period: October 1, 2020, through September 30, 2023 Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: 2 CFR § 200.303 requires that the 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. Condition: The Department did not ensure one key line-item was accurately reported on the financial report. Cause: The Department's internal controls failed to prevent inaccurate reporting of expenditures. Effect: The accuracy of the financial report could not be validated. Questioned Costs: None Context: The reported federal share of expenditures did not agree to supporting documentation. Prior Year Single Audit Finding Number: Not applicable Recommendation: We recommend the Department strengthen its internal controls to ensure all reports are accurately prepared and submitted. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 146.

Corrective Action Plan

The South Carolina Department of Social Services respectfully submits the following corrective action plan for the year ended June 30, 2024, on behalf of the State of South Carolina. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the number or numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAM AUDIT U. S. Department of Health and Human Services 2024 – 019 Federal Program Title: Refugee and Entrant Assistance Program– Assistance Listing: 93.566 Disposition of Audit Finding: The South Carolina Department of Social Services concurs with the audit finding. Corrective Action: The Department will implement the role of a contract/grants manager for internal control and/or establish familiarity with Codes of Federal Regulation. The department also plans to implement a data management system to account, track, and validate the appropriate use of federal funds. This system and the review by the grants manager will ensure the accuracy of the report. Anticipated Completion Date: October 1, 2025 Name of the contact person responsible for corrective action: Ambrea Jones, State Refugee Program Manager

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2024-020
Reporting
SIGNIFICANT DEFICIENCYOTHER MATTERS

The Department did not submit a FFATA report for fiscal year 2024. Cause: The Department had two unique entity identifier (UEI) numbers. The FSRS wouldn’t allow the Department to submit a FFATA as it was unable to determine the appropriate UEI to assign to the report. Effect: We were unable to determine compliance with FFATA reporting requirements. Questioned Costs: None Context: The Department could not provide documentation that it submitted one of the two FFATA reports selected for testing, although it had subawards of $30,000 or more. Prior Year Single Audit Finding Number: Not applicable Recommendation: We recommend that the Department take steps to ensure FFATA submissions and retention of supporting documentation to demonstrate compliance with reporting requirements. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 146.

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Federal Agency: Department of Health and Human Services Federal Program Title: Refugee and Entrant Assistance Assistance Listing: 93.566 Federal Grant ID Number: 2301SCRSSS Pass-Through Entity: Not applicable Award Period: October 1, 2022, through September 30, 2025 Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: 2 CFR § 170 Appendix A requires that recipients of grants or cooperative agreements report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act (FFATA) Subaward Reporting System (FSRS). 2 CFR § 200.303 requires that the 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. Condition: The Department did not submit a FFATA report for fiscal year 2024. Cause: The Department had two unique entity identifier (UEI) numbers. The FSRS wouldn’t allow the Department to submit a FFATA as it was unable to determine the appropriate UEI to assign to the report. Effect: We were unable to determine compliance with FFATA reporting requirements. Questioned Costs: None Context: The Department could not provide documentation that it submitted one of the two FFATA reports selected for testing, although it had subawards of $30,000 or more. Prior Year Single Audit Finding Number: Not applicable Recommendation: We recommend that the Department take steps to ensure FFATA submissions and retention of supporting documentation to demonstrate compliance with reporting requirements. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 146.

Corrective Action Plan

The South Carolina Department of Social Services respectfully submits the following corrective action plan for the year ended June 30, 2024, on behalf of the State of South Carolina. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the number or numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAM AUDIT U. S. Department of Health and Human Services 2024 – 020 Federal Program Title: Refugee and Entrant Assistance Program – Assistance Listing: 93.566 Disposition of Audit Finding: The South Carolina Department of Social Services concurs with the audit finding. Corrective Action: The Department will implement a review process for unique entity identifier (UEI) numbers and complete training for submission of the FFATAreport. The Grants Department will implement a tracking log to document all FFATA submissions. Anticipated Completion Date: June 30, 2025. Name of the contact person responsible for corrective action: Betsy Cline, Controller

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2024-021
Subrecipient Monitoring
MATERIAL WEAKNESSMODIFIED OPINIONQUESTIONED COSTS

The Department did not comply with federal subrecipient monitoring requirements. Cause: Due to staffing turnover, the Department’s internal controls failed to ensure proper subrecipient monitoring, including the submission of subaward agreements for all subrecipients. Effect: The Department is not in compliance with federal subrecipient monitoring requirements. Questioned Costs: $1,125,412 Context: For the two subrecipients tested: • The Department did not provide the correct subaward for one. • The Department did not perform required monitoring procedures for either. Prior Year Single Audit Finding Number: Not applicable Recommendation: We recommend that the Department implement procedures to ensure all subawards are properly submitted and proper retention of those documents. Additionally, the Department should establish procedures to ensure all subrecipients are appropriately monitored and that single audit reports are reviewed. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 147.

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Federal Agency: Department of Health and Human Services Federal Program Title: Refugee and Entrant Assistance Assistance Listing: 93.566 Federal Grant ID Numbers: 2201SCRSSS and 2301SCRSSS Pass-Through Entity: Not applicable Award Period: October 1, 2021, through September 30, 2026 Type of Finding: Material weakness in internal control over compliance, material noncompliance Criteria: 2 CFR § 200.332(e) requires that all pass-through entities monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. 45 CFR § 75.352 requires that all pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes all of the information required by 45 CFR § 75.352(a)(1) (i-xiii) at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the federal award and subaward. Condition: The Department did not comply with federal subrecipient monitoring requirements. Cause: Due to staffing turnover, the Department’s internal controls failed to ensure proper subrecipient monitoring, including the submission of subaward agreements for all subrecipients. Effect: The Department is not in compliance with federal subrecipient monitoring requirements. Questioned Costs: $1,125,412 Context: For the two subrecipients tested: • The Department did not provide the correct subaward for one. • The Department did not perform required monitoring procedures for either. Prior Year Single Audit Finding Number: Not applicable Recommendation: We recommend that the Department implement procedures to ensure all subawards are properly submitted and proper retention of those documents. Additionally, the Department should establish procedures to ensure all subrecipients are appropriately monitored and that single audit reports are reviewed. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 147.

Corrective Action Plan

The South Carolina Department of Social Services respectfully submits the following corrective action plan for the year ended June 30, 2024, on behalf of the State of South Carolina. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the number or numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAM AUDIT U. S. Department of Health and Human Services 2024 – 021 Federal Program Title: Refugee and Entrant Assistance Program – Assistance Listing: 93.566 Disposition of Audit Finding: The South Carolina Department of Social Services concurs with the audit finding. Corrective Action: The Department will begin using a newly created contract monitoring position to ensure compliance with federal subrecipient monitoring requirements. Documents and templates obtained from other states Refugee Resettlement Programs will be used for subrecipient monitoring. Anticipated Completion Date: June 30, 2025. Name of the contact person responsible for corrective action: Ambrea Jones, State Refugee Coordinator

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2024-022
Activities Allowed or Unallowed / Cost Allowability
SIGNIFICANT DEFICIENCYREPEAT OF 2023-032QUESTIONED COSTSOTHER MATTERS

Costs charged to the program were not properly allocated. Cause: Department controls failed to ensure costs were properly allocated based upon proportional benefit or on a reasonable, documented basis. Effect: The potential for overcharging the grant exists when costs charged to federal awards are not properly allocated. Questioned Costs: $491 Context: For two of ten TANF non-payroll transactions tested, the costs were not properly allocated to match proportional benefit to each allowable funding source. This is a repeat finding from the fiscal year 2023 Single Audit. The Department stated on its Summary Schedule of Prior Year Audit Findings that this issue was “Fully Corrected with Previously Reported Corrective Action Implemented”. Due to this issue repeating for fiscal year 2024, this issue has not been fully corrected. Prior Year Single Audit Report Finding Number: 2023-032 Recommendation: We recommend that the Department strengthen its efforts to review and update its procedures to ensure that all costs charged to the grants are properly allocated to applicable grants and funding sources based upon proportional benefit. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 147.

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Federal Agencies: Department of Health and Human Services Federal Program Title: Temporary Assistance for Needy Families Assistance Listing: 93.558 Federal Grant ID Number: 2201SCTANF Pass-Through Entity: Not applicable Award Period: October 1, 2022, through September 30, 2024 Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: 45 CFR § 75.405(d) requires costs that benefit two or more projects or activities to be allocated among projects based on the proportional benefit or, if that cannot be determined feasibly, allocated on another reasonable, documented basis. Condition: Costs charged to the program were not properly allocated. Cause: Department controls failed to ensure costs were properly allocated based upon proportional benefit or on a reasonable, documented basis. Effect: The potential for overcharging the grant exists when costs charged to federal awards are not properly allocated. Questioned Costs: $491 Context: For two of ten TANF non-payroll transactions tested, the costs were not properly allocated to match proportional benefit to each allowable funding source. This is a repeat finding from the fiscal year 2023 Single Audit. The Department stated on its Summary Schedule of Prior Year Audit Findings that this issue was “Fully Corrected with Previously Reported Corrective Action Implemented”. Due to this issue repeating for fiscal year 2024, this issue has not been fully corrected. Prior Year Single Audit Report Finding Number: 2023-032 Recommendation: We recommend that the Department strengthen its efforts to review and update its procedures to ensure that all costs charged to the grants are properly allocated to applicable grants and funding sources based upon proportional benefit. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 147.

Corrective Action Plan

The South Carolina Department of Social Services respectfully submits the following corrective action plan for the year ended June 30, 2024, on behalf of the State of South Carolina. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the number or numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAM AUDIT U. S. Department of Health and Human Services 2024 – 022 Federal Program Title: Temporary Assistance for Needy Families Program – Assistance Listing: 93.558 Disposition of Audit Finding: The South Carolina Department of Social Services concurs with the audit finding. Corrective Action: Management believed all costs were properly allocated based upon proportional benefit; however, one transaction was entered incorrectly on the invoice by the provider and wasn’t caught by the Department. General Accounting staff will perform a secondary review to identify appropriate transaction allocation, documentation, and approval approaches that more fully, clearly, and consistently consider the extent to which these specific charges benefit the various programs and ensure the documentation and accounting for those charges reflect the relative benefits. Anticipated Completion Date: June 30, 2025 Name of the contact person responsible for corrective action: Betsy Cline, Controller

Prior Finding References

2023-032

About Activities Allowed or Unallowed, Allowable Costs / Cost Principles →
2024-023
Activities Allowed or Unallowed / Cost Allowability
SIGNIFICANT DEFICIENCYREPEAT OF 2023-034OTHER MATTERS

Personnel expenditures for one employee were charged to the federal award without documented approval as required by the Department’s internal control procedure. Cause: The Department failed to retain salary and approval documentation supporting the employee's personnel charges to the grant program. Effect: The Department could incorrectly charge the federal award for personnel costs. Questioned Costs: None Context: There were five employees tested that were paid out of TANF funds and not SNAP funds and five employees tested that were paid out of TANF and SNAP funds. One payroll transaction that was paid out of SNAP and TANF funds did not have an updated State Personnel Action Form applicable to the pay the employee received in the selected period. Therefore, we were not able to confirm that the employee's pay during the selected period was allowable, as it was not supported by adequate documentation. This is a repeat finding from the fiscal year 2023 Single Audit. The Department stated on its Summary Schedule of Prior Year Audit Findings that this issue was “Fully Corrected with Previously Reported Corrective Action Implemented”. Due to this issue repeating for fiscal year 2024, this issue has not been fully corrected. Prior Year Single Audit Report Finding Number: 2023-034 Recommendation: We recommend that the Department strengthen its efforts to consistently adhere to its procedures including maintaining the approved State Personnel Action Form to support the personnel charges and allocations to applicable funding sources. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 148.

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Federal Agencies: Department of Agriculture and Department of Health and Human Services Federal Program Titles: SNAP Cluster and Temporary Assistance for Needy Families Assistance Listings: 10.551, 10.561, and 93.558 Federal Grant ID Numbers: 5SC400407 and 2201SCTANF Pass-Through Entity: Not applicable Award Period: Various Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: 2 CFR § 200.430 states that (a) Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-federal entity consistently applied to both federal and non-federal activities; (2) Follows an appointment made in accordance with a non-federal entity’s laws and/or rules or written policies and meets the requirements of federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, Standards for Documentation of Personnel Expenses, when applicable. 2 CFR § 200.303 requires that the non-federal entity 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. Condition: Personnel expenditures for one employee were charged to the federal award without documented approval as required by the Department’s internal control procedure. Cause: The Department failed to retain salary and approval documentation supporting the employee's personnel charges to the grant program. Effect: The Department could incorrectly charge the federal award for personnel costs. Questioned Costs: None Context: There were five employees tested that were paid out of TANF funds and not SNAP funds and five employees tested that were paid out of TANF and SNAP funds. One payroll transaction that was paid out of SNAP and TANF funds did not have an updated State Personnel Action Form applicable to the pay the employee received in the selected period. Therefore, we were not able to confirm that the employee's pay during the selected period was allowable, as it was not supported by adequate documentation. This is a repeat finding from the fiscal year 2023 Single Audit. The Department stated on its Summary Schedule of Prior Year Audit Findings that this issue was “Fully Corrected with Previously Reported Corrective Action Implemented”. Due to this issue repeating for fiscal year 2024, this issue has not been fully corrected. Prior Year Single Audit Report Finding Number: 2023-034 Recommendation: We recommend that the Department strengthen its efforts to consistently adhere to its procedures including maintaining the approved State Personnel Action Form to support the personnel charges and allocations to applicable funding sources. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 148.

Corrective Action Plan

The South Carolina Department of Social Services respectfully submits the following corrective action plan for the year ended June 30, 2024, on behalf of the State of South Carolina. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the number or numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAM AUDIT U. S. Department of Health and Human Services 2024 – 023 Federal Program Title: SNAP Cluster and Temporary Assistance for Needy Families Program – Assistance Listing: 10.551, 10.561, and 93.588 Disposition of Audit Finding: The South Carolina Department of Social Services concurs with the audit finding. Corrective Action: The Department now has controls in place to include review of all forms for completeness and accuracy, and correction of missing signatures or other errors noted, prior to routing the forms to staff for input. After processing by input staff, the personnel actions now work-flow to other staff who complete quality assurance checks by comparing the changes processed to the Personnel Action Forms to ensure they agree. These added controls provide adequate assurance that only personnel actions supported by correct and complete documentation will be processed. Anticipated Completion Date: February 28, 2025 Name of the contact person responsible for corrective action: Shaquanda Gallman, Assistant Director of Human Resources

Prior Finding References

2023-034

About Activities Allowed or Unallowed, Allowable Costs / Cost Principles →
2024-024
Reporting
SIGNIFICANT DEFICIENCYREPEAT OF 2023-035OTHER MATTERS

Discrepancies existed between the ACF-199 (TANF Data Report) and the Department’s records. Documentation was not retained to determine that the report had been reviewed prior to submission as required by the Department’s policies and procedures. Cause: The incorrect source data was utilized when completing the referenced data element on the performance report. Effect: Some of the data fields reported on the ACF-199 report are inconsistent with the supporting case records. Questioned Costs: None Context: Key data elements for twenty-five families were tested from one quarterly ACF-199 report. A discrepancy was noted for one data element related to recording the number of months countable towards the federal time limit for assistance. This is a repeat finding from the fiscal year 2023 Single Audit. The Department stated on its Summary Schedule of Prior Year Audit Findings that this issue was “Fully Corrected with Previously Reported Correction Action Implemented”. Due to this issue repeating for fiscal year 2024, this issue has not been fully corrected. Prior Year Single Audit Finding Number: 2023-035 Recommendation: We recommend that the Department strengthen its processes to ensure that federal reports are free from error prior to submission. We also recommend that the Department update and review processes to ensure proper documentation of supervisory review is maintained. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 148.

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Federal Agency: Department of Health and Human Services Federal Program Title: Temporary Assistance for Needy Families Assistance Listing: 93.558 Federal Grant ID Numbers: 2201SCTANF and 2301SCTANF Pass-Through Entity: Not applicable Award Period: October 01, 2021, through September 30, 2024 Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: 45 CFR § 265.7(a) requires that each state's quarterly reports, including the TANF Data Report, be complete and accurate. 2 CFR § 200.303 requires that the 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. Condition: Discrepancies existed between the ACF-199 (TANF Data Report) and the Department’s records. Documentation was not retained to determine that the report had been reviewed prior to submission as required by the Department’s policies and procedures. Cause: The incorrect source data was utilized when completing the referenced data element on the performance report. Effect: Some of the data fields reported on the ACF-199 report are inconsistent with the supporting case records. Questioned Costs: None Context: Key data elements for twenty-five families were tested from one quarterly ACF-199 report. A discrepancy was noted for one data element related to recording the number of months countable towards the federal time limit for assistance. This is a repeat finding from the fiscal year 2023 Single Audit. The Department stated on its Summary Schedule of Prior Year Audit Findings that this issue was “Fully Corrected with Previously Reported Correction Action Implemented”. Due to this issue repeating for fiscal year 2024, this issue has not been fully corrected. Prior Year Single Audit Finding Number: 2023-035 Recommendation: We recommend that the Department strengthen its processes to ensure that federal reports are free from error prior to submission. We also recommend that the Department update and review processes to ensure proper documentation of supervisory review is maintained. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 148.

Corrective Action Plan

The South Carolina Department of Social Services respectfully submits the following corrective action plan for the year ended June 30, 2024, on behalf of the State of South Carolina. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the number or numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAM AUDIT U. S. Department of Health and Human Services 2024 – 024 Federal Program Title: Temporary Assistance for Needy Families Program – Assistance Listing: 93.558 Disposition of Audit Finding: The South Carolina Department of Social Services concurs with the audit finding. Corrective Action: Management will ensure the supervisor documents the review of each case file by recording in the file the results of the review including any errors and corrections that were made to the case. Each file will be digitally signed and dated at completion of the review by the reviewer and the supervisor. Furthermore, the ACF-199 TANF report will be reviewed and signed by the grants manager to ensure accurate reporting. Anticipated Completion Date: June 30, 2025 Name of the contact person responsible for corrective action: Kimberly Boyd, Program Coordinator II

Prior Finding References

2023-035

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2024-025
Activities Allowed or Unallowed / Cost Allowability
SIGNIFICANT DEFICIENCYQUESTIONED COSTSOTHER MATTERS

Costs charged to the program were not adequately allocated. Cause: The Authority failed to ensure costs were properly allocated based upon Rural Infrastructure Authority’s cost allocation plan for FY24. Effect: The potential for overcharging the grant exists when cost charged to the federal award are not adequately supported. Questioned Costs: $183 Context: Two of forty-seven expenditures tested had costs improperly charged to the federal award. The two transactions involved allowable charges that benefited multiple grant programs and activities but were not properly allocated to match Rural Infrastructure Authority’s cost allocation plan for FY24. Prior Year Single Audit Report Finding Number: Not applicable Recommendation: We recommend that the Authority review and update its procedures to ensure that all costs charged to the grant are properly allocated to applicable grants and funding sources based upon their yearly cost allocation plan. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 149.

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Federal Agency: Department of the Treasury Federal Program Title: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing: 21.027 Federal Grant ID Number: None Provided Pass-Through Entity: Not applicable Award Period: March 3, 2021, through December 31, 2026 Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: 2 CFR § 200.405(a) states that 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. Condition: Costs charged to the program were not adequately allocated. Cause: The Authority failed to ensure costs were properly allocated based upon Rural Infrastructure Authority’s cost allocation plan for FY24. Effect: The potential for overcharging the grant exists when cost charged to the federal award are not adequately supported. Questioned Costs: $183 Context: Two of forty-seven expenditures tested had costs improperly charged to the federal award. The two transactions involved allowable charges that benefited multiple grant programs and activities but were not properly allocated to match Rural Infrastructure Authority’s cost allocation plan for FY24. Prior Year Single Audit Report Finding Number: Not applicable Recommendation: We recommend that the Authority review and update its procedures to ensure that all costs charged to the grant are properly allocated to applicable grants and funding sources based upon their yearly cost allocation plan. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 149.

Corrective Action Plan

The Rural Infrastructure Authority respectfully submits the following corrective action plan for the year ended June 30, 2024. The finding from the schedule of findings and questioned costs are discussed below. The finding is numbered consistently with the number assigned in the schedule. FINDING-FEDERAL AWARD PROGRAM AUDIT Department of the Treasury 2024-025 Coronavirus State and Local Fiscal Recovery Funds - Assistance Listing No. 21.027 Disposition of Audit Finding: The Rural Infrastructure Authority concurs with the audit finding. Corrective Action: A journal entry has been posted to correct the allocation of legal shared services expense between agency programs. In the future, when processing shared services invoicing, staff will recalculate all individualized line items on the invoice, before payment, to ensure the allocation of expense agrees to the Agency's cost allocation memo. Anticipated Completion Date: November 21, 2024 Name of the contact person responsible for corrective action: • Noel Hebert at 803-737 -9873

About Activities Allowed or Unallowed, Allowable Costs / Cost Principles →
2024-026
Activities Allowed or Unallowed / Cost Allowability
SIGNIFICANT DEFICIENCYQUESTIONED COSTSOTHER MATTERS

Costs charged to the program were not necessary and reasonable to the purpose of the program, were not adequately supported, and were improperly charged. Cause: The Department’s review process and controls failed to prevent the identified issues. Effect: Expenditures were charged to the grant that were neither essential nor reasonable for the construction of the health laboratory, including charges lacking proper documentation. Questioned Costs: $9,090 Context: For two out of seven transactions tested, the Department reimbursed nonallowable costs to their construction contractor in the amount of $8,164. For one out of seven transactions tested, the Department was not able to produce adequate supporting documentation to determine that the transactions were an allowable cost. Consequently, this led to a questioned cost totaling $33. For five out of seven transactions tested, the supporting documentation did not agree to the amount charged. Consequently, this discrepancy led to a questioned cost totaling $893 due to miscalculations. Prior Year Single Audit Report Finding Number: Not applicable. Recommendation: We recommend that the Department strengthen controls to ensure the review process consists of the following: • Documentation is obtained and maintained to support that expenditures are allowable prior to reimbursement. • There is a segregation of duties between the individual preparing the reimbursement request and the approver, both of whom must be employed by the Department. • The preparer and approver should include recalculations and document a thorough inspection of supporting documentation in their review. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 150.

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Federal Agency: Department of the Treasury Federal Program Title: Coronavirus State and Local Fiscal Recovery Funds Assistance Listings: 21.027 Federal Grant ID Numbers: None Provided Pass-Through Entity: Not applicable Award Period: March 3, 2021, through December 31, 2026 Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: 45 CFR § 75.403 (a) costs must be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. 2 CFR § 200.302 (b) (3) states the financial management system of each non-federal entity must provide records that identify adequately the source and application of funds for federally funded activities. These records must contain information pertaining to Federal awards, authorizations, financial obligations, unobligated balances, assets, expenditures, income and interest and be supported by source documentation. 2 CFR § 200.303 requires that the 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 statues, regulations, and the terms and conditions of the federal award. Condition: Costs charged to the program were not necessary and reasonable to the purpose of the program, were not adequately supported, and were improperly charged. Cause: The Department’s review process and controls failed to prevent the identified issues. Effect: Expenditures were charged to the grant that were neither essential nor reasonable for the construction of the health laboratory, including charges lacking proper documentation. Questioned Costs: $9,090 Context: For two out of seven transactions tested, the Department reimbursed nonallowable costs to their construction contractor in the amount of $8,164. For one out of seven transactions tested, the Department was not able to produce adequate supporting documentation to determine that the transactions were an allowable cost. Consequently, this led to a questioned cost totaling $33. For five out of seven transactions tested, the supporting documentation did not agree to the amount charged. Consequently, this discrepancy led to a questioned cost totaling $893 due to miscalculations. Prior Year Single Audit Report Finding Number: Not applicable. Recommendation: We recommend that the Department strengthen controls to ensure the review process consists of the following: • Documentation is obtained and maintained to support that expenditures are allowable prior to reimbursement. • There is a segregation of duties between the individual preparing the reimbursement request and the approver, both of whom must be employed by the Department. • The preparer and approver should include recalculations and document a thorough inspection of supporting documentation in their review. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 150.

Corrective Action Plan

The SC Department of Public Health respectfully submits the following corrective action plan for the year ended June 30, 2024, on behalf of the State of South Carolina. The finding from the schedule of findings and questioned costs are discussed below. The finding is numbered consistently with the number assigned in the schedule. FINDING—FEDERAL AWARD PROGRAM AUDIT U.S. Department of the Treasury 2024-026 Coronavirus State and Local Fiscal Recovery Funds– Assistance Listing No. 21.027 Disposition of Audit Finding: The Department of Public Health concurs with the audit finding. Corrective Action: For perspective, this was an audit of a large construction contract that is partially funded by Federal funds. The total cost of the project is $118,122,747. Questioned costs of $9,090 is 0.00769% of the project cost. To address the finding, the Department will conduct a more thorough review of all third-party invoices from the contractor. We plan to have a separate person in Business Management complete a detailed review of the contractor invoices with a second person also reviewing the invoices. Both employees will sign and date the documents to verify their reviews. We will ensure that documentation is obtained from the contractor for all costs and the invoices are thoroughly reviewed and amounts are recalculated. The Department will follow the guidance on the allowable purchase of items as defined in the grant and request prior approval for purchases that require such approval. The contractor is providing the Department with a credit on a future invoice for the miscalculations and the other nonallowable items. Anticipated Completion Date: March 31, 2025 Name of the contact person responsible for corrective action: • Trey Reed, Director, Bureau of Business Management at 803-898- 3522

About Activities Allowed or Unallowed, Allowable Costs / Cost Principles →
2024-027
Activities Allowed or Unallowed / Cost Allowability
SIGNIFICANT DEFICIENCYREPEAT OF 2023-024OTHER MATTERS

The Department did not provide adequate support for its required quarterly reconciliations of the labor system to the payment system. Cause: The Department has not fully implemented the corrective action associated with this finding from the prior year. Effect: The Department can potentially allocate labor costs not associated with the grant program. Questioned Costs: None Context: The Department requires a quarterly reconciliation of the labor tracking system to the payment system to ensure that grants are billed for time and effort appropriately. As of the end of fiscal year 2024, the Department was still working on implementing the updated reconciliation process outlined in their corrective action plan from the prior year finding. Prior Year Single Audit Finding Number: 2023-024 for Public Health Emergency Preparedness, (Assistance Listing Number 93.069), Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response (Assistance Listing Number 93.354) and HIV Prevention Activities Health Department Based (Assistance Listing Number 93.940) only. Recommendation: We recommend the Department continue its efforts to strengthen their current policies and procedures to ensure that all charges to the grant are allowable. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 152.

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Federal Agencies: Department of Agriculture and Department of Health and Human Services Federal Program Titles: WIC Special Supplemental Nutrition Program for Women, Infants, and Children, HIV Care Formula Grants, Epidemiology and Laboratory Capacity for Infectious Disease (ELC), Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises, Public Health Emergency Preparedness, Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response, and HIV Prevention Activities Health Department Based Assistance Listings: 10.557, 93.917, 93.323, 93.391, 93.069, 93.354, and 93.940 Federal Grant ID Numbers: Various Pass-Through Entity: Not applicable Award Period: Various Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: 2 CFR § 200.303 requires that the non-federal entity 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. Condition: The Department did not provide adequate support for its required quarterly reconciliations of the labor system to the payment system. Cause: The Department has not fully implemented the corrective action associated with this finding from the prior year. Effect: The Department can potentially allocate labor costs not associated with the grant program. Questioned Costs: None Context: The Department requires a quarterly reconciliation of the labor tracking system to the payment system to ensure that grants are billed for time and effort appropriately. As of the end of fiscal year 2024, the Department was still working on implementing the updated reconciliation process outlined in their corrective action plan from the prior year finding. Prior Year Single Audit Finding Number: 2023-024 for Public Health Emergency Preparedness, (Assistance Listing Number 93.069), Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response (Assistance Listing Number 93.354) and HIV Prevention Activities Health Department Based (Assistance Listing Number 93.940) only. Recommendation: We recommend the Department continue its efforts to strengthen their current policies and procedures to ensure that all charges to the grant are allowable. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 152.

Corrective Action Plan

The S.C. Department of Public Health (DPH) respectfully submits the following corrective action plan for the year ended June 30, 2024, on behalf of the State of South Carolina. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAM AUDIT Department of Agriculture and Department of Health and Human Services 2024-027 Activities Allowed or Unallowed and Allowable Costs/Cost Principles Federal Program Titles: WIC Special Supplemental Nutrition Program for Women, Infants, and Children, HIV Care Formula Grants, Epidemiology and Laboratory Capacity for Infectious Disease (ELC), Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises, Public Health Emergency Preparedness, Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response, and HIV Prevention Activities Health Department Based Assistance Listings: 10.557, 93.917, 93.323, 93.391, 93.069, 93.354, and 93.940 Disposition of Audit Finding: S.C. DPH concurs with the audit finding. Corrective Action: This was a repeat finding from the FY2023 audit. In our response last year, we listed the anticipated completion date as December 31, 2024. We actually implemented a new process as of November 1, 2024. However, since this was outside of FY2024, the new process was not reviewed during this audit. We had numerous meetings with relevant staff during FY2024 which resulted in a standardized quarterly time and effort report that is saved in a database according to the grants reviewed and the Budget Analyst responsible. This database allows managers to easily identify the grants reviewed and discussed with the program and the results of these discussions. Budget analysts also ensure documentation of monthly report distribution to the relevant program areas. In addition, staff developed complementary guides to assist non-financial staff with review of reports and steps needed for proper reconciliation. Anticipated Completion Date: November 1, 2024 Name of the contact person responsible for corrective action: • Meredith Murphy (Director, Budget & Business Services) at 803-898-4222

Prior Finding References

2023-024

About Activities Allowed or Unallowed, Allowable Costs / Cost Principles →
2024-028
Cash Management
SIGNIFICANT DEFICIENCY

Supporting documentation was not adequate to determine if federal reimbursements were properly reviewed and approved by a supervisor as required by the Department’s policies and procedures. Cause: Documentation that was provided was inadequate to support that the employee who completed the drawdown request was a different individual than the employee who reviewed and approved the drawdown. Effect: The Department may request improper drawdowns due to a lack of segregation of duties. Questioned Costs: None Context: For one out of fourteen drawdown requests tested, supporting documentation was not adequate to demonstrate that a proper review and approval by a supervisor occurred. Prior Year Single Audit Finding Number: Not applicable Recommendation: We recommend that the Department follow its policies and procedures to ensure proper documentation of supervisory review is maintained supporting a supervisory review was performed and that there is a segregation of duties between the individual completing the drawdown request and the individual approving the drawdown request. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 153.

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Federal Agency: Department of Health and Human Services Federal Program Title: HIV Care Formula Grants Assistance Listing: 93.917 Federal Grant ID Number: 2 X08HA32379‐05‐00 Pass-Through Entity: Not applicable Award Period: September 30, 2022, through September 29, 2023 Type of Finding: Significant deficiency in internal control over compliance Criteria: 2 CFR § 200.303 requires that the 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. Condition: Supporting documentation was not adequate to determine if federal reimbursements were properly reviewed and approved by a supervisor as required by the Department’s policies and procedures. Cause: Documentation that was provided was inadequate to support that the employee who completed the drawdown request was a different individual than the employee who reviewed and approved the drawdown. Effect: The Department may request improper drawdowns due to a lack of segregation of duties. Questioned Costs: None Context: For one out of fourteen drawdown requests tested, supporting documentation was not adequate to demonstrate that a proper review and approval by a supervisor occurred. Prior Year Single Audit Finding Number: Not applicable Recommendation: We recommend that the Department follow its policies and procedures to ensure proper documentation of supervisory review is maintained supporting a supervisory review was performed and that there is a segregation of duties between the individual completing the drawdown request and the individual approving the drawdown request. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 153.

Corrective Action Plan

The S.C. Department of Public Health (DPH) respectfully submits the following corrective action plan for the year ended June 30, 2024, on behalf of the State of South Carolina. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAM AUDIT Department of Health and Human Services 2024-028 Cash Management Federal Program Title: HIV Care Formula Grants Assistance Listing: 93.917 Disposition of Audit Finding: S.C. DPH concurs with the audit finding. Corrective Action: We agree that draws should have proper documentation of supervisory review and segregation of duties exist between the individual completing the drawdown request and the individual approving the drawdown request. After the split of DHEC into two agencies, we have had turnover resulting in reduced staffing in this area. We will retrain staff on these procedures and controls to ensure that draws have the signature of both the person making the draw and the individual approving the draw. Anticipated Completion Date: June 30, 2025 Name of the contact person responsible for corrective action: • Kim Paradeses (Controller) at 803-898-3390

About Cash Management →
2024-029
Period of Performance
SIGNIFICANT DEFICIENCYQUESTIONED COSTSOTHER MATTERS

Expenditures, which did not meet the applicable requirements, were charged prior to and after the program’s period of performance. Cause: Department controls failed to prevent charging the grant for costs incurred outside the applicable period of performance. Effect: Costs charged outside the period of performance may not be allowable. Questioned Costs: $1,856 Context: Two of the forty transactions selected for testing from costs recorded during the beginning period of the grant were for costs incurred prior to the applicable period of performance. Additionally, two of the forty transactions selected for testing from costs recorded during the ending period of the grant were for costs incurred after the applicable period of performance. Prior Year Single Audit Finding Number: Not applicable Recommendation: We recommend that the Department strengthen internal controls to ensure all expenditures charged to federal awards are incurred within the grant’s period of performance. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 153.

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Federal Agency: Department of Agriculture Federal Program Title: WIC Special Supplemental Nutrition Program for Women, Infants, and Children Assistance Listing: 10.557 Federal Grant ID Number: 5SC700706 and 5SC700715 Pass-Through Entity: Not Applicable Award Period: October 1, 2022, through September 30, 2024 Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: 2 CFR § 200.303 requires that the non-federal entity 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. 2 CFR § 200.403(h) requires costs be incurred during the approved budget period. Condition: Expenditures, which did not meet the applicable requirements, were charged prior to and after the program’s period of performance. Cause: Department controls failed to prevent charging the grant for costs incurred outside the applicable period of performance. Effect: Costs charged outside the period of performance may not be allowable. Questioned Costs: $1,856 Context: Two of the forty transactions selected for testing from costs recorded during the beginning period of the grant were for costs incurred prior to the applicable period of performance. Additionally, two of the forty transactions selected for testing from costs recorded during the ending period of the grant were for costs incurred after the applicable period of performance. Prior Year Single Audit Finding Number: Not applicable Recommendation: We recommend that the Department strengthen internal controls to ensure all expenditures charged to federal awards are incurred within the grant’s period of performance. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 153.

Corrective Action Plan

The S.C. Department of Public Health (DPH) respectfully submits the following corrective action plan for the year ended June 30, 2024, on behalf of the State of South Carolina. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAM AUDIT U.S. Department of Agriculture 2024-029 Period of Performance Federal Program Title: WIC Special Supplemental Nutrition Program for Women, Infants, and Children Assistance Listing: 10.557 Disposition of Audit Finding: S.C. DPH concurs with this portion of the audit finding. Corrective Action: We agree that two of the forty invoices tested were for costs associated with the new grant period that were charged to the old grant period. The WIC Section Manager does send a grant closeout email to all WIC staff that reminds them of the Grant Closeout Process and verifying expenditures. The email notes that 2 CFR 200.403(h) requires that costs must be incurred during the approved budget period. This email will be sent again this year during grant closeout. We will also remind staff that transactions should be charged within the grant period of performance. Anticipated Completion Date: June 30, 2025 Name of the contact person responsible for corrective action: • Heather Price (WIC Section Manager) at 803-898-0894 Disposition of Audit Finding: S.C. DPH concurs with this portion of the audit finding. Corrective Action: We agree with the finding regarding the two of forty transactions tested during the ending period of the grant. The error occurred because of the way the SC Enterprise Information System (SCEIS) accounting system processes bonuses. It is difficult to catch these rare occurrences because SCEIS pays bonuses with the funds on the current payroll file, instead of pulling the funding based on the effective date. Even though the effective date of the bonuses was August 17, 2023, the system used the new grant year because the funds for these three employees automatically rolled to the new grant on September 2. In this case, the three bonuses along with any other off-cycle payroll actions were paid on September 19, 2023. The indirect cost always posts the same way as the expense, so the indirect cost journal entries were also posted to the new grant. We will evaluate procedures related to bonuses to determine a more effective way to catch or correct such issues in the future. Anticipated Completion Date: June 30, 2025 Name of the contact person responsible for corrective action: • Sharon T. Burke (Chief Human Resource Officer) at 803-898-3582 • Darbi MacPhail (Deputy Director, Finance & Operations) at 803-898-3331

About Period of Performance →
2024-030
Reporting
SIGNIFICANT DEFICIENCYREPEAT OF 2023-028OTHER MATTERS

The Department did not submit timely FFATA reports in accordance with FFATA reporting requirements. Cause: Department controls failed to ensure timely report submission. Effect: The Department was not in compliance with FFATA reporting requirements. Questioned Costs: None Context: FFATA reports for five Epidemiology and Laboratory Capacity for Infectious Disease (ELC) subawards selected for testing were not submitted timely. Additionally, this is a repeat finding from the fiscal year 2023 Single Audit for the Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response, and HIV Prevention Activities Health Department Based programs. Although we noted partial corrective action had taken place from the prior year, we encountered two untimely FFATA submissions and two FFATA reports not submitted while performing follow-up procedures in fiscal year 2024. Prior Year Single Audit Finding Number: 2023-028 for Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response (Assistance Listing Number 93.354) and HIV Prevention Activities Health Department Based (Assistance Listing Number 93.940) only. Recommendation: We recommend the Department continue its efforts to strengthen internal controls to ensure continuous monitoring and reviewing of project obligations results in reports that are submitted in compliance with FFATA reporting requirements. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 155.

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Federal Agency: Department of Health and Human Services Federal Program Titles: Epidemiology and Laboratory Capacity for Infectious Disease (ELC), Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response, and HIV Prevention Activities Health Department Based Assistance Listings: 93.323, 93.354, and 93.940 Federal Grant ID Number: Various Pass-Through Entity: Not applicable Award Period: Various Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: 2 CFR § 170 Appendix A requires that recipients of grants or cooperative agreements report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act (FFATA) Subaward Reporting System (FSRS) no later than the end of the month following the month in which the obligation was made. Condition: The Department did not submit timely FFATA reports in accordance with FFATA reporting requirements. Cause: Department controls failed to ensure timely report submission. Effect: The Department was not in compliance with FFATA reporting requirements. Questioned Costs: None Context: FFATA reports for five Epidemiology and Laboratory Capacity for Infectious Disease (ELC) subawards selected for testing were not submitted timely. Additionally, this is a repeat finding from the fiscal year 2023 Single Audit for the Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response, and HIV Prevention Activities Health Department Based programs. Although we noted partial corrective action had taken place from the prior year, we encountered two untimely FFATA submissions and two FFATA reports not submitted while performing follow-up procedures in fiscal year 2024. Prior Year Single Audit Finding Number: 2023-028 for Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response (Assistance Listing Number 93.354) and HIV Prevention Activities Health Department Based (Assistance Listing Number 93.940) only. Recommendation: We recommend the Department continue its efforts to strengthen internal controls to ensure continuous monitoring and reviewing of project obligations results in reports that are submitted in compliance with FFATA reporting requirements. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 155.

Corrective Action Plan

The S.C. Department of Public Health (DPH) respectfully submits the following corrective action plan for the year ended June 30, 2024, on behalf of the State of South Carolina. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAM AUDIT Department of Health and Human Services 2024-030 Reporting Federal Program Titles: Epidemiology and Laboratory Capacity for Infectious Disease (ELC), Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response, and HIV Prevention Activities Health Department Based Assistance Listings: 93.323, 93.354, and 93.940 Disposition of Audit Finding: S.C. DPH concurs with the audit finding. Corrective Action: This was a repeat finding from the FY2023 audit. After the FY2023 audit was completed, the S.C. Department of Health and Environmental Control (DHEC) began working on the logistics of splitting one large agency into two agencies. As a result of the split, some reorganization occurred that created a new Contract Development & Management Section. Under this new process, the Contract Specialist will send the Grant Compliance Director in the Bureau of Financial Management copies of all fully executed subawards, completed Source of Funds Forms, and FFATAs via email. As another measure for collecting the FFATA forms, the Contrax Management System (CMS) also notifies the Contract Specialist and Finance when there is a fully executed subaward in the system. This gives Finance the backup option to receive the FFATA forms firsthand and immediately for subawards that are executed in the CMS. For subawards that may be executed outside of CMS, the Contract Specialist is also responsible for uploading the FFATA to the CMS repository (agency filing system for contracts) in addition to emailing Finance the completed form. Anticipated Completion Date: Immediately, March 4, 2025, and ongoing Names of the contact persons responsible for corrective action: • Thomas Bowen (Director, Program Support) at 803-576-2770 • Trey Reed (Director, Business Management) at 803-898-3522

Prior Finding References

2023-028

About Reporting →
2024-031
Reporting
SIGNIFICANT DEFICIENCYOTHER MATTERS

Discrepancies existed between the federal financial reports and the accounting system. Additionally, Department did not document a supervisory review and approval for all submitted reports. Cause: The Department misclassified unliquidated obligations as expenditures. Also, the Department could not locate the documentation of the supervisory review. Effect: The accuracy of the reported federal share of expenditures could not be fully validated. Additionally, without a supervisory review, there is an increased risk of inaccurate reporting. Questioned Costs: None Context: For all five ELC reports selected for testing, the Department reported expenditures incurred after the reporting period end date. Additionally, for one of the ELC reports and for the sole STLT report tested, the Department failed to maintain evidence of review and approval. Prior Year Single Audit Finding Number: Not applicable Recommendation: We recommend that the Department strengthen procedures to ensure that federal reports are submitted in accordance with reporting requirements and that records are maintained to support that a segregation of duties exists between report preparers and reviewers. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 156.

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Federal Agency: Department of Health and Human Services Federal Program Titles: Epidemiology and Laboratory Capacity for Infectious Disease (ELC) and Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises Assistance Listing: 93.323 and 93.391 Federal Grant ID Number: Various Pass-Through Entity: Not applicable Award Period: August 1, 2019, through July 31, 2027 Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: 2 CFR § 200.303 requires that the non-federal entity 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. Condition: Discrepancies existed between the federal financial reports and the accounting system. Additionally, Department did not document a supervisory review and approval for all submitted reports. Cause: The Department misclassified unliquidated obligations as expenditures. Also, the Department could not locate the documentation of the supervisory review. Effect: The accuracy of the reported federal share of expenditures could not be fully validated. Additionally, without a supervisory review, there is an increased risk of inaccurate reporting. Questioned Costs: None Context: For all five ELC reports selected for testing, the Department reported expenditures incurred after the reporting period end date. Additionally, for one of the ELC reports and for the sole STLT report tested, the Department failed to maintain evidence of review and approval. Prior Year Single Audit Finding Number: Not applicable Recommendation: We recommend that the Department strengthen procedures to ensure that federal reports are submitted in accordance with reporting requirements and that records are maintained to support that a segregation of duties exists between report preparers and reviewers. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 156.

Corrective Action Plan

The S.C. Department of Public Health (DPH) respectfully submits the following corrective action plan for the year ended June 30, 2024, on behalf of the State of South Carolina. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAM AUDIT Department of Health and Human Services 2024-031 Reporting Federal Program Title: Epidemiology and Laboratory Capacity for Infectious Disease (ELC) and Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises Assistance Listing: 93.323 and 93.391 Disposition of Audit Finding: S.C. DPH concurs with the audit finding. Corrective Action: We had a similar finding last fiscal year. The findings from the Statewide Single Audit for FY2023 were received in March 2024. However, all of the Federal Financial Reports (FFR) tested in the FY2024 audit were for dates prior to March 2024. The STLT FFR was for the period ending May 31, 2023, and the ELC FFRs were all for the period ending July 31, 2023. The STLT FFR for the period ending May 31, 2024, did have the signatures and date of both the preparer and approver. Regarding the two FFRs that were missing two signatures, we will retrain our staff on these procedures and controls. Regarding unliquidated obligations, they were mistakenly included on the expenditures line on the FFR. In our response on March 4, 2024, from last year’s audit, we stated that we will strengthen our controls to ensure that all unliquidated obligations are included on the appropriate line in the Federal Financial Report and the required two signatures are on each FFR. We will retrain our staff on these procedures and controls. Anticipated Completion Date: June 30, 2025 Name of the contact person responsible for corrective action: • Kim Paradeses (Controller) at 803-898-3390

About Reporting →
2024-032
Procurement & Suspension/Debarment
SIGNIFICANT DEFICIENCYOTHER MATTERS

Compliance with suspension and debarment regulations could not be confirmed for one vendor contract. Cause: The Department could not locate the vendor’s signed contract agreement containing the suspension and debarment certification clause. Effect: The Department's compliance with federal suspension and debarment requirements was not supported by appropriate documentation. Questioned Costs: None Context: The Department verifies suspension and debarment through a certification clause embedded in the vendor contract. For one of eight vendors tested, the Department was unable to locate a signed vendor contract agreement with the required clause. Prior Year Single Audit Finding Number: Not applicable Recommendation: We recommend the Department consistently adhere to its procedures including maintaining the signed contract agreement containing the suspension and debarment terms and conditions for all applicable vendors. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 156.

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Federal Agency: Department of Health and Human Services Federal Program Title: Epidemiology and Laboratory Capacity for Infectious Disease (ELC) Assistance Listing: 93.323 Federal Grant ID Number: 6 NU50CK000542-05-08 Pass-Through Entity: Not applicable Award Period: August 1, 2019, through July 31, 2027 Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: 2 CFR § 180.300 requires that when a non-federal entity enters into a covered transaction (contracts for goods and services that are expected to equal or exceed $25,000, as well as all subawards to subrecipients, irrespective of award amount) with an entity of a lower tier, the non-federal entity must verify that the entity is not suspended or debarred or otherwise excluded from participating in the transaction. The regulation lists several permitted methods for verification, including the collection of a certification from the entity. Condition: Compliance with suspension and debarment regulations could not be confirmed for one vendor contract. Cause: The Department could not locate the vendor’s signed contract agreement containing the suspension and debarment certification clause. Effect: The Department's compliance with federal suspension and debarment requirements was not supported by appropriate documentation. Questioned Costs: None Context: The Department verifies suspension and debarment through a certification clause embedded in the vendor contract. For one of eight vendors tested, the Department was unable to locate a signed vendor contract agreement with the required clause. Prior Year Single Audit Finding Number: Not applicable Recommendation: We recommend the Department consistently adhere to its procedures including maintaining the signed contract agreement containing the suspension and debarment terms and conditions for all applicable vendors. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 156.

Corrective Action Plan

The S.C. Department of Public Health (DPH) respectfully submits the following corrective action plan for the year ended June 30, 2024, on behalf of the State of South Carolina. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAM AUDIT Department of Health and Human Services 2024-032 Suspension & Debarment Federal Program Title: Epidemiology and Laboratory Capacity for Infectious Disease (ELC) Assistance Listing: 93.323 Disposition of Audit Finding: S.C. DPH concurs with the audit finding. Corrective Action: Following the audit period and the split of the S.C. Department of Health and Environmental Control, DPH now has fewer staff authorized to create purchase orders, with a more centralized structure. This change is expected to enhance compliance with this requirement. While total compliance is always our goal, it’s important to note that although our team did fail to perform a SAM check for this vendor—and this purchase required no solicitation in which to include the standard debarment clause—this was the only noncompliant PO among the many which were tested. This indicates that while improvement is needed, the issue is not widespread. To strengthen compliance, the agency procurement director created an instructional video on March 15, 2024, guiding staff through the SAM check process, which is complex and lacks clear federal instructions, and distributed it to procurement staff. On January 27, 2025, this requirement was reinforced again in an email to all buyers, which included the video link and a detailed explanation of when SAM checks are necessary. Moving forward, we will continue reminding staff of this requirement and incorporate it as a checkpoint in our quality assurance review before issuing purchase orders. Anticipated Completion Date: March 14, 2025 Name of the contact persons responsible for corrective action: • Trey Reed (Director, Business Management) at 803-898-3522

About Procurement and Suspension and Debarment →

FY 2023-06-30

$13,516,531,331 federal awards expended

FAC accepted this audit on March 26, 2024 — management decision was due September 26, 2024.

2023-002
Matching, Level of Effort, Earmarking
SIGNIFICANT DEFICIENCYOTHER MATTERS

The Department's review of subrecipient maintenance of effort (MOE) failed to detect incorrect calculations. Cause: MOE is reviewed by program personnel during subrecipient monitoring which is every four years rather than every year. Effect: Without a thorough annual review, subrecipients could receive incorrect funding without meeting MOE requirements. Questioned Costs: None Context: For three out of twelve subrecipients tested, the incorrect fiscal years were used in the MOE calculations. Prior Year Single Audit Finding Number: Not applicable Recommendation: We recommend the Department strengthen procedures to ensure an adequate annual review of its subrecipients' MOE calculations. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 119.

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Federal Agency: Department of Education Federal Program Title: Title I Grants to Local Education Agencies Assistance Listing: 84.010 Federal Grant ID Number: S010A220040 Pass-Through Entity: Not applicable Award Period: July 1, 2022, through September 30, 2023 Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: 2 CFR § 200.303 requires that the 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. Condition: The Department's review of subrecipient maintenance of effort (MOE) failed to detect incorrect calculations. Cause: MOE is reviewed by program personnel during subrecipient monitoring which is every four years rather than every year. Effect: Without a thorough annual review, subrecipients could receive incorrect funding without meeting MOE requirements. Questioned Costs: None Context: For three out of twelve subrecipients tested, the incorrect fiscal years were used in the MOE calculations. Prior Year Single Audit Finding Number: Not applicable Recommendation: We recommend the Department strengthen procedures to ensure an adequate annual review of its subrecipients' MOE calculations. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 119.

Corrective Action Plan

The Department of Education respectfully submits the following corrective action plan for the year ending June 30, 2023, on behalf of the State of South Carolina. The findings from the Schedule of Findings and Questioned Costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAM AUDIT U.S. Department of Education 2023-002 Title I Grants to LEAs– Assistance Listing No. 84.010 Disposition of Audit Finding: The Department of Education concurs with the audit finding. Corrective Action: A checklist has been developed to provide verification that a district’s maintenance of effort will be reviewed. The checklist will be provided to the team leader for review and approval and retained with the monitoring documentation. The malfunction in the grants management system (GEMS) has been corrected and will prepopulate the dates to ensure that the correct years are used. Anticipated Completion Date: May 30, 2024 Greg King and Barret Leviner will be responsible for corrective action: • Greg King at 803-734-0025 • Barret Leviner at 803-734-3477

About Matching, Level of Effort, Earmarking →
2023-003
Reporting
SIGNIFICANT DEFICIENCYOTHER MATTERS

A FFATA reporting discrepancy was identified. Cause: Due to a clerical error, the subaward was entered incorrectly. Effect: The Department was not in compliance with FFATA reporting requirements. Questioned Costs: None Context: One of eight subawards tested from the FFATA report did not agree to supporting documentation. Prior Year Single Audit Finding Number: Not applicable Recommendation: We recommend the Department strengthen procedures to ensure an adequate review is completed prior to report submission. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 120.

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Federal Agency: Department of Education Federal Program Title: Title I Grants to Local Education Agencies Assistance Listing: 84.010 Federal Grant ID Number: S010A220040 Pass-Through Entity: Not applicable Award Period: July 1, 2022, through September 30, 2023 Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: 2 CFR § 170 Appendix A requires that recipients of grants or cooperative agreements report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act (FFATA) Subaward Reporting System (FSRS). Condition: A FFATA reporting discrepancy was identified. Cause: Due to a clerical error, the subaward was entered incorrectly. Effect: The Department was not in compliance with FFATA reporting requirements. Questioned Costs: None Context: One of eight subawards tested from the FFATA report did not agree to supporting documentation. Prior Year Single Audit Finding Number: Not applicable Recommendation: We recommend the Department strengthen procedures to ensure an adequate review is completed prior to report submission. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 120.

Corrective Action Plan

The Department of Education respectfully submits the following corrective action plan for the year ending June 30, 2023, on behalf of the State of South Carolina. The findings from the Schedule of Findings and Questioned Costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAM AUDIT U.S. Department of Education 2023-003 Title I Grants to LEAs– Assistance Listing No. 84.010 Disposition of Audit Finding: The Department of Education concurs with the audit finding. Corrective Action: The grant accountants are currently preparing and entering all the data for uploading and reporting. After completing this step, the Accounting/Fiscal Manager will be notified. Going forward, the grants accounting office will conduct primary reviews from the preparer, a secondary peer review, and a managerial review prior to the preparer uploading to the FFATA site. Anticipated Completion Date: Effective immediately as new awards are received. Sequoyah Burden and Melanie Cooper will be responsible for corrective action: • Sequoyah Burden at 803-734-8488 • Melanie Cooper at 803-734-8135

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2023-004
Special Tests & Provisions
SIGNIFICANT DEFICIENCYOTHER MATTERS

Documentation was not adequate to support compliance with oversight and monitoring responsibilities. Cause: The Department failed to retain documentation demonstrating performance of a supervisory review and approval. Effect: We were unable to determine compliance with the stated requirement. Questioned Costs: None Context: For one of two charter schools tested with charter management organization relationships, supervisor review and approval of compliance with oversight and monitoring was not documented. Prior Year Single Audit Finding Number: Not applicable Recommendation: We recommend the Department strengthen procedures to ensure proper documentation is maintained for each special test and provision. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 120.

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Federal Agency: Department of Education Federal Program Titles: Title I Grants to Local Education Agencies and Supporting Effective Instruction State Grants Assistance Listings: 84.010 and 84.367 Federal Grant ID Numbers: S010A220040 and S367A220038 Pass-Through Entity: Not applicable Award Period: July 1, 2022, through September 30, 2023 Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: 2 CFR § 200.303 requires that the 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. Condition: Documentation was not adequate to support compliance with oversight and monitoring responsibilities. Cause: The Department failed to retain documentation demonstrating performance of a supervisory review and approval. Effect: We were unable to determine compliance with the stated requirement. Questioned Costs: None Context: For one of two charter schools tested with charter management organization relationships, supervisor review and approval of compliance with oversight and monitoring was not documented. Prior Year Single Audit Finding Number: Not applicable Recommendation: We recommend the Department strengthen procedures to ensure proper documentation is maintained for each special test and provision. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 120.

Corrective Action Plan

The Department of Education respectfully submits the following corrective action plan for the year ending June 30, 2023, on behalf of the State of South Carolina. The findings from the Schedule of Findings and Questioned Costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAM AUDIT U.S. Department of Education 2023-004 Title I Grants to LEAs, and Supporting Effective Instruction State Grants Assistance Listing No. 84.010 and 84.367 Disposition of Audit Finding: The Department of Education concurs with the audit finding. Corrective Action: The Consolidated Oversight and Monitoring (COM) team lead will review all monitoring file folders monthly to verify file completion. The team lead will ensure each file is complete, including appropriate approvals, and resolve any issues at that time. The team lead will document the status of each file and note the completion date. These documents will be maintained on the office drive to ensure the data retention policy. Anticipated Completion Date: May 30, 2024 Barret Leviner is responsible for corrective action: • Barret Leviner at 803-734-3477

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2023-005
Reporting
SIGNIFICANT DEFICIENCYOTHER MATTERS

The Annual Performance Report did not agree to supporting documentation. Cause: Due to a clerical error, data in the Annual Performance Report was incorrect. Effect: The Department was not in compliance with the annual performance reporting requirements. Questioned Costs: None Context: For one of ten school districts tested, the ESSER II allocation amount on the Annual Performance Report did not agree to supporting documentation. Prior Year Single Audit Finding Number: Not applicable Recommendation: We recommend the Department strengthen procedures to ensure all calculations are correct prior to submitting the Annual Performance Report. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 121.

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Federal Agency: Department of Education Federal Program Title: Education Stabilization Fund Assistance Listing: 84.425 Federal Grant ID Number: S425D210019 Pass-Through Entity: Not applicable Award Period: January 05, 2021, through September 30, 2022 Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: The Office of Management and Budget (OMB) compliance supplement requires, in part, that Elementary and Secondary School Emergency Relief (ESSER) grantees submit an annual performance report (OMB No. 1810-0749 for ESSER) with data on actual expenditures, planned expenditures, subrecipients, and uses of funds, including mandatory reservations and verifying key line items. Condition: The Annual Performance Report did not agree to supporting documentation. Cause: Due to a clerical error, data in the Annual Performance Report was incorrect. Effect: The Department was not in compliance with the annual performance reporting requirements. Questioned Costs: None Context: For one of ten school districts tested, the ESSER II allocation amount on the Annual Performance Report did not agree to supporting documentation. Prior Year Single Audit Finding Number: Not applicable Recommendation: We recommend the Department strengthen procedures to ensure all calculations are correct prior to submitting the Annual Performance Report. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 121.

Corrective Action Plan

The Department of Education respectfully submits the following corrective action plan for the year ending June 30, 2023, on behalf of the State of South Carolina. The findings from the Schedule of Findings and Questioned Costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAM AUDIT U.S. Department of Education 2023-005 Education Stabilization – Assistance Listing No. 84.425 Disposition of Audit Finding: The Department of Education concurs with the audit finding. Corrective Action: In May 2024, the USDE will reopen the 2023 Annual Reporting Portal for SEAs to make corrections. When this portal opens, the SCDE will make the noted correction and send a copy of the submitted correction to the Office of the State Auditor. Anticipated Completion Date: June 30, 2024 Tonia Mallett Smith and Kristi Motley are responsible for corrective action: • Tonia Mallet Smith (803) 543-7900 • Kristi Motley (803) 497-7722

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2023-006
Reporting
SIGNIFICANT DEFICIENCYREPEAT OF 2022-006OTHER MATTERS

FFATA reporting and timing errors were identified. Cause: Administrative turnover increased workloads which led to delays in submission and retention of the FFATA reports. Effect: The Office was not in compliance with FFATA reporting requirements. Questioned Costs: None Context: Seven subawards were selected for testing and the following compliance errors were identified during the testing:  The FSRS could not be accessed for two of the subawards in order to test reporting compliance for the subawards.  For one of the subawards tested, the action was not reported in the FSRS by the last day of the month following the month that the subaward was made. This is a repeat finding from the fiscal year 2022 Single Audit. The Office stated on its Summary Schedule of Prior Year Audit Findings that this issue was “Fully Corrected with Previously Reported Corrective Action Implemented”. Due to this issue repeating for fiscal year 2023, this issue has not been fully corrected. Prior Year Single Audit Report Finding Number: 2022-006 Recommendation: We recommend the Office continue its efforts to strengthen internal controls to ensure continuous monitoring and reviewing of project obligations resulting in reports that are submitted in compliance with FFATA reporting requirements. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 122.

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Federal Agency: Department of Homeland Security Federal Program Title: Disaster Grants – Public Assistance (Presidentially Declared Disasters) Assistance Listing: 97.036 Federal Grant ID Number: Various Pass-Through Entity: Not applicable Award Period: Various Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: 2 CFR § 170 Appendix A requires that recipients of grants or cooperative agreements report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act (FFATA) Subaward Reporting System (FSRS) no later than the end of the month following the month in which the obligation was made. Condition: FFATA reporting and timing errors were identified. Cause: Administrative turnover increased workloads which led to delays in submission and retention of the FFATA reports. Effect: The Office was not in compliance with FFATA reporting requirements. Questioned Costs: None Context: Seven subawards were selected for testing and the following compliance errors were identified during the testing:  The FSRS could not be accessed for two of the subawards in order to test reporting compliance for the subawards.  For one of the subawards tested, the action was not reported in the FSRS by the last day of the month following the month that the subaward was made. This is a repeat finding from the fiscal year 2022 Single Audit. The Office stated on its Summary Schedule of Prior Year Audit Findings that this issue was “Fully Corrected with Previously Reported Corrective Action Implemented”. Due to this issue repeating for fiscal year 2023, this issue has not been fully corrected. Prior Year Single Audit Report Finding Number: 2022-006 Recommendation: We recommend the Office continue its efforts to strengthen internal controls to ensure continuous monitoring and reviewing of project obligations resulting in reports that are submitted in compliance with FFATA reporting requirements. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 122.

Corrective Action Plan

The South Carolina Adjutant General’s Office respectfully submits the following corrective action plan for the year ended June 30, 2023, on behalf of the State of South Carolina. The finding from the schedule of findings and questioned costs are discussed below. The finding is numbered consistently with the number assigned in the schedule. Finding — FEDERAL AWARD PROGRAM AUDIT United States Department of Homeland Security 2023-006 Public Assistance (Presidentially Declared Disasters) - Assistance Listing No. 97.036 Disposition of Audit Finding: The Office concurs with the audit finding. Corrective Action: 1. PA and Grants and Finance staff have reviewed the step 2 notification in SCEMD’s South Carolina Recovery Grants (SCRG) platform to ensure that notifications to the Finance/Admin staff include complete and clear information needed for FFATA reporting of obligations and project versions that change the dollar amount obligated. 2. The Grants and Finance team is initiating a monthly report of new obligations/awards, versions, and budget amendments that will be provided to the Finance/Admin team by the end of the second week each month. The Finance/Admin team will use the report to cross-check to ensure sure all obligations/awards and budget amendments are captured in FFATA reporting for the prior month. Implementation of the new report began in December 2023. 3. The PA team is revising PA standard operating procedures (SOPs) to clarify PA specialist responsibility for document uploads related to obligations and amendments to support timely notification of Finance/Admin staff. The PA SOP will be revised by March 29, 2024. Anticipated Completion Date: June 30, 2024 Name of the contact person responsible for corrective action: • Landry Phillips at LPhillips@emd.sc.gov or 803-737-8559

Prior Finding References

2022-006

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2023-007
Activities Allowed or Unallowed / Cost Allowability
SIGNIFICANT DEFICIENCYQUESTIONED COSTSOTHER MATTERS

The Department did not record fourth quarter indirect cost adjustments within the correct fiscal year. Cause: Due to turnover of key personnel at the end of the fiscal year, the Department’s ability to calculate and create the journal entries was constrained. Effect: As of June 30, 2023, the Schedule of Expenditures of Federal Awards was overstated by $378,960 because the Department failed to redistribute costs to other funding sources for the fourth quarter. Questioned Costs: $378,960 Context: The Department utilizes a cost allocation plan and at the end of each quarter a journal entry is created to adjust directly recorded administrative costs within the indirect cost pool to the various federal programs based upon the approved cost allocation plan bases. Administrative costs that were charged to the grant program should have been redistributed to other federal grant programs by the end of the fiscal year based on the fourth quarter cost allocation plan calculations. Prior Year Single Audit Report Finding Number: Not applicable Recommendation: We recommend the Department review and update its policies and procedures to ensure that indirect cost entries are recorded within the correct fiscal year. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 124.

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Federal Agency: Department of Education Federal Program Title: Rehabilitation Services Vocational Rehabilitation Grants to States Assistance Listing: 84.126 Federal Grant ID Number: H126A220060 Pass-Through Entity: Not applicable Award Period: October 1, 2021, through September 30, 2023 Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: 2 CFR § 200.303 requires that the 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. Condition: The Department did not record fourth quarter indirect cost adjustments within the correct fiscal year. Cause: Due to turnover of key personnel at the end of the fiscal year, the Department’s ability to calculate and create the journal entries was constrained. Effect: As of June 30, 2023, the Schedule of Expenditures of Federal Awards was overstated by $378,960 because the Department failed to redistribute costs to other funding sources for the fourth quarter. Questioned Costs: $378,960 Context: The Department utilizes a cost allocation plan and at the end of each quarter a journal entry is created to adjust directly recorded administrative costs within the indirect cost pool to the various federal programs based upon the approved cost allocation plan bases. Administrative costs that were charged to the grant program should have been redistributed to other federal grant programs by the end of the fiscal year based on the fourth quarter cost allocation plan calculations. Prior Year Single Audit Report Finding Number: Not applicable Recommendation: We recommend the Department review and update its policies and procedures to ensure that indirect cost entries are recorded within the correct fiscal year. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 124.

Corrective Action Plan

Vocational Rehabilitation respectfully submits the following corrective action plan for the year ended June 30, 2023, on behalf of the State of South Carolina. The findings from the Schedule of Findings and Questioned Costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAM AUDIT U.S. Department of Education 2023-007 Rehabilitation Services Vocational Rehabilitation Grants to States – Assistance Listing No. 84.126 Disposition of Audit Finding: The SC Department of Vocational Rehabilitation concurs with the audit finding. Corrective Action: Staff will be trained in that the allocation should be completed by the 20th of the month following the calendar quarter end. For the fourth quarter CAP, all allocations and journal entries should be entered before the Comptroller General’s Journal Entry year-end cutoff date to ensure proper accounting for the State Fiscal Year. Anticipated Completion Date: June 30, 2024 Name of the contact Person responsible for corrective action: • Sabrina Walker at (803) 896-6604

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2023-008
Period of Performance
SIGNIFICANT DEFICIENCYQUESTIONED COSTSOTHER MATTERS

Expenditures were incurred and liquidated after the grant’s period of performance. Cause: The Department’s internal controls failed to prevent expenditures from being charged outside the grant’s period of performance. Effect: Costs charged outside the period of performance may not be allowable. Questioned Costs: $251 Context: For four of twenty transactions tested, program expenditures were not incurred and liquidated in accordance with program regulations. The Department detected the errors, but correcting journal entries were not made until the subsequent fiscal year. Prior Year Single Audit Report Finding Number: Not applicable Recommendation: We recommend that the Department review and update internal controls to ensure that expenditures are incurred and liquidated within the grant’s period of performance. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 125.

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Federal Agency: Department of Education Federal Program Title: Rehabilitation Services Vocational Rehabilitation Grants to States Assistance Listing: 84.126 Federal Grant ID Number: H126A210060 Pass-Through Entity: Not applicable Award Period: October 1, 2021, through September 30, 2023 Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: 2 CFR § 200.403(h) requires costs be incurred during the approved budget period. 2 CFR § 200.344(b) requires that all financial obligations incurred under the federal award be liquidated no later than 120 calendar days after the end date of the period of performance. Condition: Expenditures were incurred and liquidated after the grant’s period of performance. Cause: The Department’s internal controls failed to prevent expenditures from being charged outside the grant’s period of performance. Effect: Costs charged outside the period of performance may not be allowable. Questioned Costs: $251 Context: For four of twenty transactions tested, program expenditures were not incurred and liquidated in accordance with program regulations. The Department detected the errors, but correcting journal entries were not made until the subsequent fiscal year. Prior Year Single Audit Report Finding Number: Not applicable Recommendation: We recommend that the Department review and update internal controls to ensure that expenditures are incurred and liquidated within the grant’s period of performance. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 125.

Corrective Action Plan

Vocational Rehabilitation respectfully submits the following corrective action plan for the year ended June 30, 2023, on behalf of the State of South Carolina. The findings from the Schedule of Findings and Questioned Costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAM AUDIT Department of Education 2023-008 Rehabilitation Services Vocational Rehabilitation Grants to States – Assistance Listing No. 84.126 Disposition of Audit Finding: The SC Department of Vocational Rehabilitation concurs with the audit finding. Corrective Action: These transactions were payroll related and required the validity date on a closed grant to be extended in SCEIS in order for payroll to post. When the Agency is notified by the Comptroller General’s Office of a payroll error related to a closed grant, Human Resources will supply Grants and Funds Management with documentation for the payroll activity and why the extension of the validity date in SCEIS should be allowed. When the grant is extended for payroll postings, fiscal staff would run reports to identify if any expenditures were posted to the closed grant. If necessary, journal entries will be entered to remove the expenditures from the closed grant to the proper funding source. Human Resources will also remind supervisors of the importance of submitting HR Action Forms in a timely manner and that Time Administrators need to monitor missing time weekly. Human Resources will also run weekly reports and advise supervisors of missing time if needed. A final review of all closed grants will be performed by fiscal staff before the end of each State Fiscal Year. Anticipated Completion Date: June 30, 2024 Names of the contact persons responsible for corrective action: • Kim Jones at (803) 896-6551 • Sabrina Walker at (803) 896-6604

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2023-009
Activities Allowed or Unallowed / Cost Allowability
SIGNIFICANT DEFICIENCYQUESTIONED COSTSOTHER MATTERS

Costs charged to the program were not adequately supported. Cause: Department controls failed to ensure costs were properly allocated or that proper supporting documentation was retained. Effect: The potential for overcharging the grant exists when costs charged to federal awards are not adequately supported, including documentation of the proportional benefit to the grant award. Questioned Costs: Unknown Context: Three of sixty expenditure transactions tested had costs improperly charged to the federal award. One transaction had insufficient documentation to support the expenditure was related to the federal award. The other two transactions involved allowable charges that benefited multiple grant programs and activities but were not properly allocated to match proportional benefit to each allowable funding source. Prior Year Single Audit Finding Number: Not applicable Recommendation: We recommend that the Department review and update its procedures to ensure that all costs charged to the grant are allowable and properly allocated to applicable grants and funding sources based on benefit. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 126.

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Federal Agency: Department of Health and Human Services Federal Program Title: Block Grants for Prevention and Treatment of Substance Abuse Assistance Listing: 93.959 Federal Grant ID Number: B08TI083544, B08TI084670, and B08TI085832 Pass-Through Entity: Not applicable Award Period: March 15, 2021, through September 30, 2024 Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: 2 CFR § 200.405(a) states that 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. 2 CFR § 200.303 requires that the 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. Condition: Costs charged to the program were not adequately supported. Cause: Department controls failed to ensure costs were properly allocated or that proper supporting documentation was retained. Effect: The potential for overcharging the grant exists when costs charged to federal awards are not adequately supported, including documentation of the proportional benefit to the grant award. Questioned Costs: Unknown Context: Three of sixty expenditure transactions tested had costs improperly charged to the federal award. One transaction had insufficient documentation to support the expenditure was related to the federal award. The other two transactions involved allowable charges that benefited multiple grant programs and activities but were not properly allocated to match proportional benefit to each allowable funding source. Prior Year Single Audit Finding Number: Not applicable Recommendation: We recommend that the Department review and update its procedures to ensure that all costs charged to the grant are allowable and properly allocated to applicable grants and funding sources based on benefit. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 126.

Corrective Action Plan

The South Carolina Department of Alcohol and Other Drug Abuse Services respectfully submits the following corrective action plan for the year ended June 30, 2023, on behalf of the State of South Carolina. The findings from the Schedule of Findings and Questioned Costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAM AUDIT U.S. Department of Health and Human Services 2023-009 Block Grants for Prevention and Treatment of Substance Abuse – Assistance Listing No. 93.959 Disposition of Audit Finding: DAODAS concurs with the audit finding. Corrective Action: DAODAS will update its Block Grant Policy to ensure that all expenditures follow a methodology to allocate costs to applicable grants. This method will be reviewed at the beginning of each state fiscal year by the Finance Manager to ensure that all costs are allocated correctly. Policies for travel documentation have been updated in our Procurement Card procedures. Anticipated Completion Date: 03/01/2024 Names of the contact persons responsible for corrective action: • Anita Anderson at 803.896.1145 • Chance Murray at 803.896.5576

About Activities Allowed or Unallowed, Allowable Costs / Cost Principles →
2023-010
Activities Allowed or Unallowed / Cost Allowability
SIGNIFICANT DEFICIENCYQUESTIONED COSTSOTHER MATTERS

The Department did not have adequate controls in place to ensure timesheets were properly completed and reviewed by a supervisor, maintained by the agency, and that the time and effort documentation agreed to salary allocations in the accounting system. Cause: Department controls failed to prevent the identified issues. Effect: The Department is not in compliance with applicable allowable activities/cost requirements. Questioned Costs: Unknown Context: For fourteen out of sixty payroll transactions, time and effort documentation was either missing or did not agree to the funding percentages per the accounting system. Prior Year Single Audit Finding Number: Not applicable Recommendation: We recommend the Department implement policies and procedures to ensure time and effort reports are properly completed, reviewed, and maintained. We also recommend the Department ensure the accounting system accurately reports actual time worked. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 127.

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Federal Agency: Department of Health and Human Services Federal Program Title: Block Grants for Prevention and Treatment of Substance Abuse Assistance Listing: 93.959 Federal Grant ID Number: B08TI084670 and B08TI085832 Pass-Through Entity: Not applicable Award Period: October 1, 2021, through September 30, 2024 Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: 2 CFR § 200.430 states that (a) costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-federal entity consistently applied to both federal and non-federal activities; (2) Follows an appointment made in accordance with a non-federal entity’s laws and/or rules or written policies and meets the requirements of federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, Standards for Documentation of Personnel Expenses, when applicable. 2 CFR § 200.303 requires that the 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. Condition: The Department did not have adequate controls in place to ensure timesheets were properly completed and reviewed by a supervisor, maintained by the agency, and that the time and effort documentation agreed to salary allocations in the accounting system. Cause: Department controls failed to prevent the identified issues. Effect: The Department is not in compliance with applicable allowable activities/cost requirements. Questioned Costs: Unknown Context: For fourteen out of sixty payroll transactions, time and effort documentation was either missing or did not agree to the funding percentages per the accounting system. Prior Year Single Audit Finding Number: Not applicable Recommendation: We recommend the Department implement policies and procedures to ensure time and effort reports are properly completed, reviewed, and maintained. We also recommend the Department ensure the accounting system accurately reports actual time worked. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 127.

Corrective Action Plan

The South Carolina Department of Alcohol and Other Drug Abuse Services respectfully submits the following corrective action plan for the year ended June 30, 2023, on behalf of the State of South Carolina. The findings from the Schedule of Findings and Questioned Costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAM AUDIT U.S. Department of Health and Human Services 2023-010 Block Grants for Prevention and Treatment of Substance Abuse – Assistance Listing No. 93.959 Disposition of Audit Finding: DAODAS concurs with the audit finding. Corrective Action: DAODAS will ensure compliance with our current Time & Effort policy and will have management properly review time & effort sheets for their direct reports. Anticipated Completion Date: 04/01/2024 Names of the contact persons responsible for corrective action: • Anita Anderson at 803.896.1145 • Angela Outing at 803.896.5547

About Activities Allowed or Unallowed, Allowable Costs / Cost Principles →
2023-011
Cash Management
SIGNIFICANT DEFICIENCY

Supporting documentation was not adequate to determine if federal reimbursements were properly reviewed and approved by a supervisor prior to requesting a drawdown as required by the Department’s policies and procedures. Cause: Documentation that was provided was inadequate to support that the employee who completed the drawdown request was a different individual than the employee who reviewed and approved the drawdown prior to the reimbursement request. Effect: The Department may request improper drawdowns due to a lack of segregation of duties. Questioned Costs: None Context: For six out of eight drawdown requests tested, supporting documentation was not adequate to demonstrate that a proper review and approval by a supervisor occurred prior to the federal reimbursement request. Prior Year Single Audit Finding Number: Not applicable Recommendation: We recommend that the Department follow its policies and procedures to ensure proper documentation of supervisory review is maintained supporting a supervisory was performed and that there is a segregation of duties between the individual completing the drawdown request and the individual approving the drawdown request. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 127.

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Federal Agency: Department of Health and Human Services Federal Program Title: Block Grants for Prevention and Treatment of Substance Abuse Assistance Listing: 93.959 Federal Grant ID Number: Various Pass-Through Entity: Not applicable Award Period: October 1, 2020, through September 30, 2024 Type of Finding: Significant deficiency in internal control over compliance Criteria: 2 CFR § 200.303 requires that the 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. Condition: Supporting documentation was not adequate to determine if federal reimbursements were properly reviewed and approved by a supervisor prior to requesting a drawdown as required by the Department’s policies and procedures. Cause: Documentation that was provided was inadequate to support that the employee who completed the drawdown request was a different individual than the employee who reviewed and approved the drawdown prior to the reimbursement request. Effect: The Department may request improper drawdowns due to a lack of segregation of duties. Questioned Costs: None Context: For six out of eight drawdown requests tested, supporting documentation was not adequate to demonstrate that a proper review and approval by a supervisor occurred prior to the federal reimbursement request. Prior Year Single Audit Finding Number: Not applicable Recommendation: We recommend that the Department follow its policies and procedures to ensure proper documentation of supervisory review is maintained supporting a supervisory was performed and that there is a segregation of duties between the individual completing the drawdown request and the individual approving the drawdown request. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 127.

Corrective Action Plan

The South Carolina Department of Alcohol and Other Drug Abuse Services respectfully submits the following corrective action plan for the year ended June 30, 2023, on behalf of the State of South Carolina. The findings from the Schedule of Findings and Questioned Costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAM AUDIT U.S. Department of Health and Human Services 2023-011 Block Grants for Prevention and Treatment of Substance Abuse – Assistance Listing No. 93.959 Disposition of Audit Finding: DAODAS concurs with the audit finding. Corrective Action: DAODAS has strongly enforced its current Cash Management policy to ensure that each drawdown is prepared by a Senior Accountant and approved by the Finance Manager. Anticipated Completion Date: 03/01/2024 Names of the contact persons responsible for corrective action: • Anita Anderson at 803.896.1145 • Chance Murray at 803.896.5576

About Cash Management →
2023-012
Matching, Level of Effort, Earmarking
SIGNIFICANT DEFICIENCY

The Department failed to retain documentation demonstrating proper internal controls over level of effort and earmarking requirements. Cause: The Department failed to retain documentation demonstrating performance and approval of the monthly Internal Update Budget workbooks. Effect: The Department may not meet level of effort or earmarking requirements without proper reviews. Questioned Costs: None Context: For one grant that closed during the audit period, the Department was unable to provide documentation of tracking and monitoring requirements using monthly Internal Update Budget workbooks as required by the Department’s procedures. Prior Year Single Audit Finding Number: Not applicable Recommendation: We recommend that the Department review and update policies and procedures to ensure proper documentation is maintained to support amounts as well as the review of level of effort and earmarking requirements. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 128.

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Federal Agency: Department of Health and Human Services Federal Program Title: Block Grants for Prevention and Treatment of Substance Abuse Assistance Listing: 93.959 Federal Grant ID Number: B08TI083475 Pass-Through Entity: Not applicable Award Period: October 1, 2020, through September 30, 2022 Type of Finding: Significant deficiency in internal control over compliance Criteria: 2 CFR § 200.303 requires that the 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. Condition: The Department failed to retain documentation demonstrating proper internal controls over level of effort and earmarking requirements. Cause: The Department failed to retain documentation demonstrating performance and approval of the monthly Internal Update Budget workbooks. Effect: The Department may not meet level of effort or earmarking requirements without proper reviews. Questioned Costs: None Context: For one grant that closed during the audit period, the Department was unable to provide documentation of tracking and monitoring requirements using monthly Internal Update Budget workbooks as required by the Department’s procedures. Prior Year Single Audit Finding Number: Not applicable Recommendation: We recommend that the Department review and update policies and procedures to ensure proper documentation is maintained to support amounts as well as the review of level of effort and earmarking requirements. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 128.

Corrective Action Plan

The South Carolina Department of Alcohol and Other Drug Abuse Services respectfully submits the following corrective action plan for the year ended June 30, 2023, on behalf of the State of South Carolina. The findings from the Schedule of Findings and Questioned Costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAM AUDIT U.S. Department of Health and Human Services 2023-012 Block Grants for Prevention and Treatment of Substance Abuse – Assistance Listing No. 93.959 Disposition of Audit Finding: DAODAS concurs with the audit finding. Corrective Action: DAODAS has updated its Block Grant Policy to include both a monthly financial review with programmatic staff and an Internal Budget Report. The Internal Budget Report will be prepared by a Senior Accountant and approved by the Finance Manager. Anticipated Completion Date: 03/01/2024 Names of the contact persons responsible for corrective action: • Anita Anderson at 803.896.1145 • Chance Murray at 803.896.5576

About Matching, Level of Effort, Earmarking →
2023-013
Period of Performance
SIGNIFICANT DEFICIENCYQUESTIONED COSTSOTHER MATTERS

Expenditures were incurred and charged outside of the period of performance. Cause: Department controls failed to prevent charging the grant for costs incurred outside the applicable period of performance. Effect: Costs charged outside the period of performance may not be allowable. Questioned Costs: $1,090 Context: One of five transactions selected for testing from costs recorded during the first period of the grant was for a cost incurred prior to the applicable period of performance. One of eight transactions selected for testing costs for which the obligation had not been paid as of the end of performance had costs incurred after the ending period of performance. One of nine transactions selected for testing journal entries that occurred during the fiscal year incurred charges after the period of performance end date. Prior Year Single Audit Finding Number: Not applicable Recommendation: We recommend that the Department review and update its internal controls to ensure that all expenditures charged to Federal awards are incurred within the grant’s period of performance. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 128.

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Federal Agency: Department of Health and Human Services Federal Program Title: Block Grants for Prevention and Treatment of Substance Abuse Assistance Listing: 93.959 Federal Grant ID Number: B08TI085832 and B08TI083475 Pass-Through Entity: Not applicable Award Period: October 1, 2020, through September 30, 2024 Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: 2 CFR § 200.403(h) requires costs be incurred during the approved budget period. Condition: Expenditures were incurred and charged outside of the period of performance. Cause: Department controls failed to prevent charging the grant for costs incurred outside the applicable period of performance. Effect: Costs charged outside the period of performance may not be allowable. Questioned Costs: $1,090 Context: One of five transactions selected for testing from costs recorded during the first period of the grant was for a cost incurred prior to the applicable period of performance. One of eight transactions selected for testing costs for which the obligation had not been paid as of the end of performance had costs incurred after the ending period of performance. One of nine transactions selected for testing journal entries that occurred during the fiscal year incurred charges after the period of performance end date. Prior Year Single Audit Finding Number: Not applicable Recommendation: We recommend that the Department review and update its internal controls to ensure that all expenditures charged to Federal awards are incurred within the grant’s period of performance. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 128.

Corrective Action Plan

The South Carolina Department of Alcohol and Other Drug Abuse Services respectfully submits the following corrective action plan for the year ended June 30, 2023, on behalf of the State of South Carolina. The findings from the Schedule of Findings and Questioned Costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAM AUDIT U.S. Department of Health and Human Services 2023-013 Block Grants for Prevention and Treatment of Substance Abuse – Assistance Listing No. 93.959 Disposition of Audit Finding: DAODAS concurs with the audit finding. Corrective Action: All invoices will be reviewed by the Finance Manager before approval to ensure that no expenditures are paid if they are outside the period of performance for that funding source. All Accounts Payable staff will be trained on the relevant period of performance for each grant. Anticipated Completion Date: 03/01/2024 Names of the contact persons responsible for corrective action: • Anita Anderson at 803.896.1145 • Latisha Jones at 803.896.8201

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2023-014
Reporting
SIGNIFICANT DEFICIENCY

We tested the sole SF-425 report submitted during fiscal year 2023 and noted the Department did not document a supervisory review and approval. Cause: The Department does not have a policy requiring a reviewer separate from the preparer. Effect: Without a supervisory review, there is an increased risk of inaccurate reporting. Questioned Costs: None Context: The report was not reviewed by an employee other than the report preparer prior to submission. Prior Year Single Audit Finding Number: Not applicable Recommendation: We recommend that the Department strengthen policies and procedures to require a report reviewer other than the preparer. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 129.

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Federal Agency: Department of Health and Human Services Federal Program Title: Block Grants for Prevention and Treatment of Substance Abuse Assistance Listing: 93.959 Federal Grant ID Number: B08TI083475 Pass-Through Entity: Not applicable Award Period: October 1, 2020, through September 30, 2022 Type of Finding: Significant deficiency in internal control over compliance Criteria: 2 CFR § 200.303 requires that the 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. Condition: We tested the sole SF-425 report submitted during fiscal year 2023 and noted the Department did not document a supervisory review and approval. Cause: The Department does not have a policy requiring a reviewer separate from the preparer. Effect: Without a supervisory review, there is an increased risk of inaccurate reporting. Questioned Costs: None Context: The report was not reviewed by an employee other than the report preparer prior to submission. Prior Year Single Audit Finding Number: Not applicable Recommendation: We recommend that the Department strengthen policies and procedures to require a report reviewer other than the preparer. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 129.

Corrective Action Plan

The South Carolina Department of Alcohol and Other Drug Abuse Services respectfully submits the following corrective action plan for the year ended June 30, 2023, on behalf of the State of South Carolina. The findings from the Schedule of Findings and Questioned Costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAM AUDIT U.S. Department of Health and Human Services 2023-014 Block Grants for Prevention and Treatment of Substance Abuse – Assistance Listing No. 93.959 Disposition of Audit Finding: DAODAS concurs with the audit finding. Corrective Action: Once all relevant staff obtain access to the HHS Payment Management System, a Senior Accountant will prepare the SF-425 report for certification by the Finance Manager. Anticipated Completion Date: 04/01/2024 Names of the contact persons responsible for corrective action: • Anita Anderson at 803.896.1145 • Chance Murray at 803.896.5576

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2023-015
Reporting
SIGNIFICANT DEFICIENCYOTHER MATTERS

Federal Agency: Department of Health and Human Services Federal Program Title: Block Grants for Prevention and Treatment of Substance Abuse Assistance Listing: 93.959 Federal Grant ID Number: Various Pass-Through Entity: Not applicable Award Period: Various Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: 2 CFR § 170 Appendix A requires that recipients of grants or cooperative agreements report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act (FFATA) Subaward Reporting System (FSRS). Condition : We identified noncompliance with FFATA reporting requirements. Cause: Due to staffing turnover, the FSRS could not be accessed to provide the FFATA reports that were submitted during fiscal year 2023. Effect: We were unable to determine compliance with FFATA reporting requirements. Questioned Costs: None Context: The Department could not provide documentation that it had submitted FFATA reports although it had subawards of $30,000 or more. Prior Year Single Audit Finding Number: Not applicable Recommendation: We recommend that the Department take steps to assure access to FFATA submissions and retention of supporting documentation to demonstrate compliance with reporting requirements. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 129.

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Federal Agency: Department of Health and Human Services Federal Program Title: Block Grants for Prevention and Treatment of Substance Abuse Assistance Listing: 93.959 Federal Grant ID Number: Various Pass-Through Entity: Not applicable Award Period: Various Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: 2 CFR § 170 Appendix A requires that recipients of grants or cooperative agreements report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act (FFATA) Subaward Reporting System (FSRS). Condition : We identified noncompliance with FFATA reporting requirements. Cause: Due to staffing turnover, the FSRS could not be accessed to provide the FFATA reports that were submitted during fiscal year 2023. Effect: We were unable to determine compliance with FFATA reporting requirements. Questioned Costs: None Context: The Department could not provide documentation that it had submitted FFATA reports although it had subawards of $30,000 or more. Prior Year Single Audit Finding Number: Not applicable Recommendation: We recommend that the Department take steps to assure access to FFATA submissions and retention of supporting documentation to demonstrate compliance with reporting requirements. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 129.

Corrective Action Plan

The South Carolina Department of Alcohol and Other Drug Abuse Services respectfully submits the following corrective action plan for the year ended June 30, 2023, on behalf of the State of South Carolina. The findings from the Schedule of Findings and Questioned Costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAM AUDIT U.S. Department of Health and Human Services 2023-015 Block Grants for Prevention and Treatment of Substance Abuse – Assistance Listing No. 93.959 Disposition of Audit Finding: DAODAS concurs with the audit finding. Corrective Action: Once all relevant staff obtain access to the FSRS system and all subrecipients provide their UEI number, a Senior Accountant will prepare the FFATA reports for review and approval by the Finance Manager. Anticipated Completion Date: 04/01/2024 Names of the contact persons responsible for corrective action: • Anita Anderson at 803.896.1145 • Chance Murray at 803.896.5576

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2023-016
Subrecipient Monitoring
SIGNIFICANT DEFICIENCYOTHER MATTERS

The Department was not in compliance with several subrecipient monitoring requirements. Cause: The Department’s internal controls failed to ensure adequate communication to the subrecipients through the annual subaward process as required by federal regulations. Additionally, the Department’s internal controls failed to include a review and approval process to ensure proper subrecipient monitoring occurred. The Department’s subrecipient monitoring policy states that miscellaneous subrecipients receiving $50,000 or greater are randomly selected for an annual review. However, after inquiry with the Department, no miscellaneous subrecipients had an annual review in FY2023. Effect: The Department is not in compliance with federal subrecipient monitoring requirements. Questioned Costs: None Context: The following discrepancies were encountered during testing of eight subrecipients selected for testing: • All forty-four subawards provided by the Department did not contain all of the information required by 45 CFR § 75.352(a). • For seven of the eight subrecipients tested, the Department did not have adequate documentation showing a proper review and approval of subrecipient monitoring reports. • One of the eight subrecipients selected for testing was not monitored as required by the Department’s policy. Prior Year Single Audit Finding Number: Not applicable Recommendation: We recommend the Department update its subrecipient agreements to incorporate all required information to ensure adequate communication to subrecipients and to ensure compliance with federal requirements. Additionally, the Department should update and implement policies to ensure all subrecipients are being appropriately monitored and subrecipient monitoring reports are properly reviewed and approved. We recommend that the Department follow its policies and procedures to ensure that miscellaneous subrecipients receiving $50,000 or greater have an annual review. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 130.

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Federal Agency: Department of Health and Human Services Federal Program Title: Block Grants for Prevention and Treatment of Substance Abuse Assistance Listing: 93.959 Federal Grant ID Number: Various Pass-Through Entity: Not applicable Award Period: October 1, 2020, through September 30, 2025 Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: 45 CFR § 75.352 requires that all pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes all of the information required by 45 CFR § 75.352(a)(1)(i-xiii) at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the federal award and subaward. 2 CFR § 200.303 requires that the 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. Condition: The Department was not in compliance with several subrecipient monitoring requirements. Cause: The Department’s internal controls failed to ensure adequate communication to the subrecipients through the annual subaward process as required by federal regulations. Additionally, the Department’s internal controls failed to include a review and approval process to ensure proper subrecipient monitoring occurred. The Department’s subrecipient monitoring policy states that miscellaneous subrecipients receiving $50,000 or greater are randomly selected for an annual review. However, after inquiry with the Department, no miscellaneous subrecipients had an annual review in FY2023. Effect: The Department is not in compliance with federal subrecipient monitoring requirements. Questioned Costs: None Context: The following discrepancies were encountered during testing of eight subrecipients selected for testing: • All forty-four subawards provided by the Department did not contain all of the information required by 45 CFR § 75.352(a). • For seven of the eight subrecipients tested, the Department did not have adequate documentation showing a proper review and approval of subrecipient monitoring reports. • One of the eight subrecipients selected for testing was not monitored as required by the Department’s policy. Prior Year Single Audit Finding Number: Not applicable Recommendation: We recommend the Department update its subrecipient agreements to incorporate all required information to ensure adequate communication to subrecipients and to ensure compliance with federal requirements. Additionally, the Department should update and implement policies to ensure all subrecipients are being appropriately monitored and subrecipient monitoring reports are properly reviewed and approved. We recommend that the Department follow its policies and procedures to ensure that miscellaneous subrecipients receiving $50,000 or greater have an annual review. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 130.

Corrective Action Plan

The South Carolina Department of Alcohol and Other Drug Abuse Services respectfully submits the following corrective action plan for the year ended June 30, 2023, on behalf of the State of South Carolina. The findings from the Schedule of Findings and Questioned Costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAM AUDIT U.S. Department of Health and Human Services 2023-016 Block Grants for Prevention and Treatment of Substance Abuse – Assistance Listing No. 93.959 Disposition of Audit Finding: DAODAS concurs with the audit finding. Corrective Action: DAODAS will revise and update our policy on Subrecipient Monitoring to include the following procedures: 1. Documentation, review, and approval for Subrecipient Monitoring 2. Annual compliance review process for miscellaneous subrecipients. 3. Communication to subrecipients. 4. Compliance assurance. Anticipated Completion Date: 04/01/2024 Name of the contact person responsible for corrective action: • Yihong Wu at 803.896.2837

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2023-017
Reporting
SIGNIFICANT DEFICIENCYOTHER MATTERS

The Department’s review of key line-item amounts on quarterly Project and Expenditure Reports did not ensure the accuracy of reported amounts. Cause: The Department did not ensure State agencies utilized the same procedures when calculating and reporting key line-item amounts. Effect: Treasury will not be able to accurately track key line item amounts. Questioned Costs: None Context: For the following quarterly reports, we noted: July – September 2022:  Current period expenditure amount was understated by $750.97 thousand.  Cumulative expenditure amount was understated by $215.19 thousand. April – June 2023:  Current period expenditure amount was understated by $3.16 million.  Cumulative expenditure amount was understated by $3.18 million. Prior Year Single Audit Report Finding Number: Not applicable Recommendation: We recommend the Department strengthen procedures to ensure review responsibilities include requiring all State agencies to report expenditures posted to the accounting system as of the tenth day of the month following the period covered by each quarterly report. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 131.

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Federal Agency: Department of Treasury Federal Program Title: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing: 21.027 Federal Grant ID Number: None Provided Pass-Through Entity: Not applicable Award Period: March 3, 2021, through December 31, 2024 Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: 2 CFR § 200.303 requires that the 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. Condition: The Department’s review of key line-item amounts on quarterly Project and Expenditure Reports did not ensure the accuracy of reported amounts. Cause: The Department did not ensure State agencies utilized the same procedures when calculating and reporting key line-item amounts. Effect: Treasury will not be able to accurately track key line item amounts. Questioned Costs: None Context: For the following quarterly reports, we noted: July – September 2022:  Current period expenditure amount was understated by $750.97 thousand.  Cumulative expenditure amount was understated by $215.19 thousand. April – June 2023:  Current period expenditure amount was understated by $3.16 million.  Cumulative expenditure amount was understated by $3.18 million. Prior Year Single Audit Report Finding Number: Not applicable Recommendation: We recommend the Department strengthen procedures to ensure review responsibilities include requiring all State agencies to report expenditures posted to the accounting system as of the tenth day of the month following the period covered by each quarterly report. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 131.

Corrective Action Plan

The Department of Administration respectfully submits the following corrective action plan for the year ended June 30, 2023, on behalf of the State of South Carolina. The findings from the Schedule of Findings and Questioned Costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAM AUDIT U.S. Department of Treasury 2023-017 Coronavirus State and Local Fiscal Recovery Funds – Assistance Listing No. 21.027 Disposition of Audit Finding: The Department of Administration concurs with the audit finding. Corrective Action: The Department will strengthen the reporting procedures utilized by Guidehouse and state agencies to ensure all agencies report their expenditures posted in the state’s accounting system as of the tenth day of the month following the period covered by the quarterly report. In addition, Guidehouse will reconcile state agencies’ reported expenditures to the state’s accounting system prior to finalizing the quarterly reporting process. Anticipated Completion Date: April 30, 2024 Name of the contact person responsible for corrective action: • Mike Shealy, Acting Executive Budget Office Director at (803) 734- 8120

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2023-018
Eligibility
SIGNIFICANT DEFICIENCYREPEAT OF 2022-004OTHER MATTERS

The Department’s monitoring process and eligibility systems do not ensure recipients’ eligibility determinations are renewed annually as required by 42 CFR § 435.916(a)(1) and 42 CFR § 435.916(b). Cause: The Department did not comply with the annual review requirement due to a backlog in eligibility determination processing. Effect: Without an annual review, the Department could provide Medicaid and CHIP benefits to ineligible recipients because all recipients are not being recertified as required by 42 CFR § 435.916(a)(1) and 42 CFR § 435.916(b). Questioned Costs: None Context: The Department did not complete annual reviews during the Public Health Emergency (PHE) (beginning January 27, 2020) based on guidance from Centers for Medicare & Medicaid Services (CMS). However, we determined that eight Medicaid and seven CHIP recipients did not have an annual renewal completed during the twelve months prior to the PHE being instituted. Prior Year Single Audit Report Finding Number: 2022-004 Recommendation: We recommend the Department ensure staffing is adequate to confirm only eligible recipients receive benefits by completing periodic eligibility determination renewals. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 132.

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Federal Agency: Department of Health and Human Services Federal Program Title: Medicaid Cluster and Children’s Health Insurance Program Assistance Listing: 93.775, 93.777, 93.778, and 93.767 Federal Grant ID Number: 05-2105-SC-5001, 05-1005-SC-5MAP, and 05-2305-SC-5021 Pass-Through Entity: Not applicable Award Period: October 1, 2021, through September 30, 2023 Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: 2 CFR § 200.303 requires that the 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. 42 CFR § 435.916(a)(1) requires the Department renew MAGI-based determinations of eligibility once every twelve months and no more frequently than once every twelve months. 42 CFR § 435.916(b) requires the Department renew non-MAGI-based determinations of eligibility at least once every twelve months.. Condition: The Department’s monitoring process and eligibility systems do not ensure recipients’ eligibility determinations are renewed annually as required by 42 CFR § 435.916(a)(1) and 42 CFR § 435.916(b). Cause: The Department did not comply with the annual review requirement due to a backlog in eligibility determination processing. Effect: Without an annual review, the Department could provide Medicaid and CHIP benefits to ineligible recipients because all recipients are not being recertified as required by 42 CFR § 435.916(a)(1) and 42 CFR § 435.916(b). Questioned Costs: None Context: The Department did not complete annual reviews during the Public Health Emergency (PHE) (beginning January 27, 2020) based on guidance from Centers for Medicare & Medicaid Services (CMS). However, we determined that eight Medicaid and seven CHIP recipients did not have an annual renewal completed during the twelve months prior to the PHE being instituted. Prior Year Single Audit Report Finding Number: 2022-004 Recommendation: We recommend the Department ensure staffing is adequate to confirm only eligible recipients receive benefits by completing periodic eligibility determination renewals. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 132.

Corrective Action Plan

The Department of Health and Human Services respectfully submits the following corrective action plan for the year ended June 30, 2023, on behalf of the State of South Carolina. The findings from the Schedule of Findings and Questioned Costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAM AUDIT U.S. Department of Health and Human Services 2023-018 Medicaid Cluster and Children’s Health Insurance Program – Assistance Listing No. 93.775, 93.777, 93.778, and 93.767 Disposition of Audit Finding: The Department concurs with the audit finding. Corrective Action: Beginning in April 2023, the Department began implementation of its Public Health Emergency (PHE) Unwinding Plan for the completion of annual reviews. This includes: 1) Distribution of review across unwinding period; 2) Updated policies and procedures for review processing; 3) Refresher training provided to all eligibility staff on processing annual reviews; 4) Hired additional staff to process annual reviews; 5) Contracted with 3rd party to hire additional 400 staff to assist with annual reviews and other PHE Unwinding related activities; 6) System enhancements to improve ex parte renewals; 7) Adoption of 13 (thirteen) e(14) Waiver flexibilities to improve ex parte rates and efficiencies with processing reviews; 8) Workload Management to monitor work assignments, assess daily progress, and to address issues; 9) Performance Management to maximize staff productivity and accuracy. The Department provides monthly data to Centers for Medicare & Medicaid Services (CMS) to show that work is on track to be completed by the end of the PHE Unwinding period, as well as to continue standard annual review processing beyond the Unwinding period. Anticipated Completion Date: August 2024 • Lori Risk at 803-898-4562

Prior Finding References

2022-004

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2023-019
Eligibility
SIGNIFICANT DEFICIENCYQUESTIONED COSTSOTHER MATTERS

The Department’s monitoring process and eligibility systems did not ensure recipients nineteen or older who are deemed ineligible no longer receive CHIP benefits. Cause: The Department did not complete the close out process to remove the recipients from the list of eligible beneficiaries. Effect: The Department could be providing CHIP benefits to ineligible recipients. Questioned Costs: $6,396 Context: The Department provided a closure notice to one recipient detailing that the recipient will no longer be eligible for CHIP benefits. The recipient continued to receive benefits due to the Department not completing the close out process. Prior Year Single Audit Report Finding Number: Not applicable Recommendation: We recommend the Department ensure staffing is adequate to ensure that only eligible recipients receive benefits by completion of the eligibility determination close out processes. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 133.

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Federal Agency: Department of Health and Human Services Federal Program Title: Children’s Health Insurance Program Assistance Listing: 93.767 Federal Grant ID Number: 05-2305-SC-5021 Pass-Through Entity: Not applicable Award Period: October 1, 2021, through September 30, 2023 Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: 2 CFR § 200.303 requires that the 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. 42 CFR § 435.926(b)(1) requires enrolled recipients under age nineteen or under a younger age specified by the Department in its State plan are eligible for CHIP benefits. Section 2.1(d) of the State plan sets the eligibility age for CHIP benefits at under age 19. Condition: The Department’s monitoring process and eligibility systems did not ensure recipients nineteen or older who are deemed ineligible no longer receive CHIP benefits. Cause: The Department did not complete the close out process to remove the recipients from the list of eligible beneficiaries. Effect: The Department could be providing CHIP benefits to ineligible recipients. Questioned Costs: $6,396 Context: The Department provided a closure notice to one recipient detailing that the recipient will no longer be eligible for CHIP benefits. The recipient continued to receive benefits due to the Department not completing the close out process. Prior Year Single Audit Report Finding Number: Not applicable Recommendation: We recommend the Department ensure staffing is adequate to ensure that only eligible recipients receive benefits by completion of the eligibility determination close out processes. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 133.

Corrective Action Plan

The Department of Health and Human Services respectfully submits the following corrective action plan for the year ended June 30, 2023, on behalf of the State of South Carolina. The findings from the Schedule of Findings and Questioned Costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAM AUDIT U.S. Department of Health and Human Services 2023-019 Children’s Health Insurance Program – Assistance Listing No. 93.767 Disposition of Audit Finding: The Department concurs with the audit finding. Corrective Action: 1) Conduct 3rd party and internal quality reviews and analysis with focus on end dating coverage to identify statewide error trends, opportunities for policy clarification, training material updates and staff coaching; 2) Review findings and recommendations made by 3rd party reviewer and internal Eligibility Quality Assurance team; 3) Implement any needed policy clarifications and training material updates; 4) Provide recommendations to supervisors with staff who may benefit from refresher training on how to end date coverage correctly in the eligibility system; 5) Work with supervisors and lead workers to ensure they understand how to end date coverage correctly and can support staff to prevent errors. The impact of these activities will be assessed by monitoring ongoing quality findings from both 3rd party and internal quality reviews. Adjustments will be made to corrective actions based on these results. Anticipated Completion Date: April 30, 2024 • Lori Risk at 803-898-4562

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2023-020
Special Tests & Provisions
SIGNIFICANT DEFICIENCYOTHER MATTERS

The Department’s review of reporting templates did not ensure the thirteen required elements were included in reports submitted by MCOs. Cause: The Department stated that it would not be cost effective for the MCOs to include a comparison between audited financial information and other financial information in reports submitted to the Department as required by 42 CFR §438.8 (k)(1)(xi). Effect: MCOs could potentially misstate financial information reported to the Department. Questioned Costs: None Context: We noted that a comparison of other financial information and audited basic financial statements was not included in all five MCO reports tested. Prior Year Single Audit Report Finding Number: Not applicable Recommendation: We recommend the Department strengthen report review procedures to ensure the MCO’s provide a comparison between other financial information and audited basic financial statements. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 133.

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Federal Agency: Department of Health and Human Services Federal Program Title: Medicaid Cluster and Children’s Health Insurance Program Assistance Listing No.: 93.775, 93.777, 93.778, and 93.767 Federal Grant ID Number: 05-2105-SC-5001, 05-1005-SC-5MAP, and 05-2305-SC-5021 Pass-Through Entity: Not applicable Award Period: October 1, 2021, through September 30, 2023 Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: 2 CFR § 200.303 requires that the 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. 42 CFR § 438.8(k)(1) requires the Department, through its contracts, must require each Managed Care Organization (MCO), Prepaid Inpatient Health Plan (PIHP), or Prepaid Ambulatory Health Plan (PAHP) to submit a report to the Department that includes the information required by 42 CFR § 438.8(k)(1)(i) through 42 CFR § 438.8(k)(1)(xiii) each year. Condition: The Department’s review of reporting templates did not ensure the thirteen required elements were included in reports submitted by MCOs. Cause: The Department stated that it would not be cost effective for the MCOs to include a comparison between audited financial information and other financial information in reports submitted to the Department as required by 42 CFR §438.8 (k)(1)(xi). Effect: MCOs could potentially misstate financial information reported to the Department. Questioned Costs: None Context: We noted that a comparison of other financial information and audited basic financial statements was not included in all five MCO reports tested. Prior Year Single Audit Report Finding Number: Not applicable Recommendation: We recommend the Department strengthen report review procedures to ensure the MCO’s provide a comparison between other financial information and audited basic financial statements. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 133.

Corrective Action Plan

The Department of Health and Human Services respectfully submits the following corrective action plan for the year ended June 30, 2023, on behalf of the State of South Carolina. The findings from the Schedule of Findings and Questioned Costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAM AUDIT U.S. Department of Health and Human Services 2023-020 Medicaid Cluster and Children’s Health Insurance Program (CHIP) – Assistance Listing No. 93.775, 93.777, 93.778, and 93.767 Disposition of Audit Finding: The Department concurs with the audit finding. Corrective Action: A contract amendment effective 7/01/24 will be made to include the following requirements: • A separate independent audit report to be provided on a contract year/state fiscal year basis. • The independent audit report will be specific to the Medicaid program but not include other programs such as Prime, Medicare Advantage, DSNP, or Direct Pay. • The independent audit report will have to conform to Generally Accepted Accounting Principles. • SC DHHS will consider the costs of the independent audit report in the administrative component of the capitation rates paid to the Managed Care Organizations (MCO). Anticipated Completion Date: July 1, 2024, and December 31, 2025 • Clark Phillip at (803) 898-1017

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2023-021
Special Tests & Provisions
SIGNIFICANT DEFICIENCYOTHER MATTERS

The Department’s review of quarterly CMS-64 reports did not ensure the federal share of overpayments recovered by the Medicaid RAC were included on each report. Cause: Due to a coding error in the accounting system the Department was not aware of overpayments recovered by the Medicaid RAC that needed to be reported on each CMS-64 report. Effect: CMS is unable to monitor and evaluate the performance of the State’s Medicaid RAC program. Questioned Costs: None Context: The Department’s RAC program recoveries are not being reported to CMS. Prior Year Single Audit Report Finding Number: Not applicable Recommendation: We recommend the Department strengthen procedures by correcting the coding error in the accounting system to ensure that the federal share of overpayments recovered by the Medicaid RAC are reported on the quarterly CMS-64 report submitted by the Department. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 134.

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Federal Agency: Department of Health and Human Services Federal Program Title: Medicaid Cluster Assistance Listings: 93.775, 93.777, and 93.778 Federal Grant ID Number: 05-2105-SC-5001 and 05-1005-SC-5MAP Pass-Through Entity: Not applicable Award Period: October 1, 2021, through September 30, 2023 Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: 2 CFR § 200.303 requires that the 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. 42 CFR § 455.502(c) requires that the Department complies with reporting requirements describing the effectiveness of the Medicaid Recovery Audit Contractor (RAC) programs as specified by Centers for Medicare & Medicaid Services (CMS). Condition: The Department’s review of quarterly CMS-64 reports did not ensure the federal share of overpayments recovered by the Medicaid RAC were included on each report. Cause: Due to a coding error in the accounting system the Department was not aware of overpayments recovered by the Medicaid RAC that needed to be reported on each CMS-64 report. Effect: CMS is unable to monitor and evaluate the performance of the State’s Medicaid RAC program. Questioned Costs: None Context: The Department’s RAC program recoveries are not being reported to CMS. Prior Year Single Audit Report Finding Number: Not applicable Recommendation: We recommend the Department strengthen procedures by correcting the coding error in the accounting system to ensure that the federal share of overpayments recovered by the Medicaid RAC are reported on the quarterly CMS-64 report submitted by the Department. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 134.

Corrective Action Plan

The Department of Health and Human Services respectfully submits the following corrective action plan for the year ended June 30, 2023, on behalf of the State of South Carolina. The findings from the Schedule of Findings and Questioned Costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAM AUDIT U.S. Department of Health and Human Services 2023-021 Medicaid Cluster – Assistance Listing No. 93.775, 93.777, and 93.778 Disposition of Audit Finding: The Department concurs with the audit finding. Corrective Action: In FY2023 payments for Medicaid Recovery Audit Contractor (RAC) revenues were coded incorrectly in our accounting system. The coding error resulted in the RAC revenues not being reported correctly on the CMS-64. The system coding (functional area and g/l code) will be corrected, and reporting staff trained to confirm all RAC revenues and expenditures are reported to CMS correctly. The department will also create a monthly RAC expenditure and revenue report. Anticipated Completion Date: March 15, 2024 • Cynthia Moore at 803-898-1880 • Brian Paeth at 803-898-1268

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2023-022
Activities Allowed or Unallowed / Cost Allowability
SIGNIFICANT DEFICIENCYQUESTIONED COSTSOTHER MATTERS

Costs were improperly charged to the federal award. Cause: The Department failed to ensure that all costs charged to the grant were allowable. Effect: An amount of $295 was improperly allocated and recorded to the grant program. Questioned Costs: $295 Context: One of sixty non-payroll disbursements included two purchases that were incorrectly charged to the grant due to an allocation error. Prior Year Single Audit Finding Number: Not applicable Recommendation: We recommend the Department strengthen its current policies and procedures to ensure that all charges to the grant are allowable. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 135.

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Federal Agency: Department of Health and Human Services Federal Program Title: Public Health Emergency Preparedness Assistance Listing: 93.069 Federal Grant ID Number: NU90TP922053 Pass-Through Entity: Not applicable Award Period: July 1, 2022, through June 30, 2023 Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: 2 CFR § 200.303 requires that the 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. 2 CFR § 200.403 requires expenditures be necessary and reasonable for the performance of the Federal award and be allocable. Condition: Costs were improperly charged to the federal award. Cause: The Department failed to ensure that all costs charged to the grant were allowable. Effect: An amount of $295 was improperly allocated and recorded to the grant program. Questioned Costs: $295 Context: One of sixty non-payroll disbursements included two purchases that were incorrectly charged to the grant due to an allocation error. Prior Year Single Audit Finding Number: Not applicable Recommendation: We recommend the Department strengthen its current policies and procedures to ensure that all charges to the grant are allowable. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 135.

Corrective Action Plan

The South Carolina Department of Health and Environmental Control respectfully submits the following corrective action plan for the year ended June 30, 2023, on behalf of the State of South Carolina. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAM AUDIT U.S. Department of Health and Human Services 2023 – 022. Public Health Emergency Preparedness – Assistance Listing No. 93.069 Disposition of Audit Finding: SC DHEC concurs with the audit finding. Corrective Action: This appears to be a case where a person mistakenly charged this registration to the wrong grant and the manager approving the transaction did not catch it. We will continue to emphasize the importance of using the correct grant and to make sure that staff involved in funding transactions are well versed in the requirements and stipulations. Anticipated Completion Date: Immediately (February 29, 2024) Names of Contact Person Responsible for Corrective Action:  Kim Paradeses –-803-898-3390

About Activities Allowed or Unallowed, Allowable Costs / Cost Principles →
2023-023
Activities Allowed or Unallowed / Cost Allowability
SIGNIFICANT DEFICIENCYQUESTIONED COSTSOTHER MATTERS

An individual with programmatic knowledge did not review and approve certain costs as allowable to the grant. Cause: The Department did not have adequate internal controls in place to ensure that costs were properly reviewed and approved for allowability before being charged to the grant. Effect: Without adequate controls in place, unallowable expenditures may be charged to the grant. Questioned Costs: Unknown Context: Two of sixty transactions tested for Public Health Emergency Preparedness, two of sixty transactions tested for Public Health Emergency Response, and two of sixty transactions tested for HIV Prevention Activities Health Department Based, had invoiced expenditures that were not approved by programmatic staff prior to payment. Prior Year Single Audit Finding Number: Not applicable Recommendation: We recommend that the Department strengthen controls to ensure that documentation is maintained to support that costs charged to the grant were reviewed and approved for allowability. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 135.

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Federal Agency: Department of Health and Human Services Federal Program Titles: Public Health Emergency Preparedness, Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response, and HIV Prevention Activities Health Department Based Assistance Listings: 93.069, 93.354, and 93.940 Federal Grant ID Number: Various Pass-Through Entity: Not applicable Award Period: July 1, 2022, through June 30, 2023 Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: 2 CFR § 200.303 requires that the 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. Condition: An individual with programmatic knowledge did not review and approve certain costs as allowable to the grant. Cause: The Department did not have adequate internal controls in place to ensure that costs were properly reviewed and approved for allowability before being charged to the grant. Effect: Without adequate controls in place, unallowable expenditures may be charged to the grant. Questioned Costs: Unknown Context: Two of sixty transactions tested for Public Health Emergency Preparedness, two of sixty transactions tested for Public Health Emergency Response, and two of sixty transactions tested for HIV Prevention Activities Health Department Based, had invoiced expenditures that were not approved by programmatic staff prior to payment. Prior Year Single Audit Finding Number: Not applicable Recommendation: We recommend that the Department strengthen controls to ensure that documentation is maintained to support that costs charged to the grant were reviewed and approved for allowability. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 135.

Corrective Action Plan

The South Carolina Department of Health and Environmental Control respectfully submits the following corrective action plan for the year ended June 30, 2023, on behalf of the State of South Carolina. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAM AUDIT U.S. Department of Health and Human Services 2023 – 023. Public Health Emergency Preparedness, Public Health Emergency Response, and HIV Prevention Activities Health Department Based – Assistance Listing No. 93.069, 93.354, and 93.940 Disposition of Audit Finding: SC DHEC concurs with the audit finding. Corrective Actions: 93.940 HIV Prevention Activities- The program area will continue to communicate the importance of documenting and retaining the approval process for expenses charged to the grant. The program now has a better understanding of how the invoice gets finalized through various areas and with specific program approval. Anticipated Completion Date: Immediately during FY2024 93.354 Public Health Emergency Response & 93.069 Public Health Emergency Preparedness The program area will continue to emphasize the importance of documenting and retaining the approval process for costs charged to the grants. Anticipated Completion Date: Immediately during FY2024 Name of the contact person responsible for corrective actions:  Kim Paradeses –-803-898-3390

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2023-024
Activities Allowed or Unallowed / Cost Allowability
SIGNIFICANT DEFICIENCYQUESTIONED COSTSOTHER MATTERS

The Department failed to provide adequate support for the required quarterly reconciliations of the labor system to the payment system. Cause: Documentation of the reconciliations was not retained by program staff. Effect: One grant was charged for labor not associated with the grant program. Questioned Costs: $115,479 Context: The Department requires a quarterly reconciliation of the labor tracking system to the payment system to ensure that grants are billed for time and effort appropriately. The Department was not able to produce adequate support for the completion of this quarterly reconciliation for the three grants. Prior Year Single Audit Finding Number: Not applicable Recommendation: We recommend the Department strengthen its procedures to ensure performance of the quarterly labor reconciliation process. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 136.

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Federal Agency: Department of Health and Human Services Federal Program Titles: Public Health Emergency Preparedness, Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response, and HIV Prevention Activities Health Department Based Assistance Listings: 93.069, 93.354, and 93.940 Federal Grant ID Number: Various Pass-Through Entity: Not applicable Award Period: July 1, 2022, through June 30, 2023 Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: 2 CFR § 200.303 requires that the 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. Condition: The Department failed to provide adequate support for the required quarterly reconciliations of the labor system to the payment system. Cause: Documentation of the reconciliations was not retained by program staff. Effect: One grant was charged for labor not associated with the grant program. Questioned Costs: $115,479 Context: The Department requires a quarterly reconciliation of the labor tracking system to the payment system to ensure that grants are billed for time and effort appropriately. The Department was not able to produce adequate support for the completion of this quarterly reconciliation for the three grants. Prior Year Single Audit Finding Number: Not applicable Recommendation: We recommend the Department strengthen its procedures to ensure performance of the quarterly labor reconciliation process. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 136.

Corrective Action Plan

The South Carolina Department of Health and Environmental Control respectfully submits the following corrective action plan for the year ended June 30, 2023, on behalf of the State of South Carolina. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAM AUDIT U.S. Department of Health and Human Services 2023 – 024. Public Health Emergency Preparedness, Public Health Emergency Response, and HIV Prevention Activities Health Department Based – Assistance Listing No. 93.069, 93.354, and 93.940 Disposition of Audit Finding: SC DHEC concurs with the audit finding. Corrective Actions: Budget staff will create standardized quarterly time and effort reports and ensure distribution to grant managers and leadership in program areas. Budget staff will also develop complementary guides to assist non-financial program staff with review of reports and steps needed for proper reconciliation. Budget analysts will ensure documentation of monthly report distribution, review with program areas and items needed for reconciliation. Anticipated Completion Date: December 31, 2024 Name of the contact person responsible for corrective action:  Meredith Murphy--803-898-4222

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2023-025
Equipment & Real Property
SIGNIFICANT DEFICIENCYQUESTIONED COSTSOTHER MATTERS

Federal regulations require that recipients request disposition instructions from the Federal awarding agency prior to disposal. Cause: The Department was not in compliance with federal regulations and applicable property and equipment requirements. Effect: The Department failed to prevent the retirement of an asset without guidance from the Federal awarding agency. Questioned Costs: Unknown Context: For the only asset disposal tested, the Department failed to comply with the requirements for proper disposal. Prior Year Single Audit Finding Number: Not applicable Recommendation: We recommend the Department strengthen its processes to ensure assets are disposed of in compliance with federal guidelines. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 136.

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Federal Agency: Department of Health and Human Services Federal Program Title: Public Health Emergency Preparedness Assistance Listing No: 93.069 Federal Grant ID Number: NU90TP922053 Pass-Through Entity: Not applicable Award Period: July 1, 2022, through June 30, 2023 Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: 2 CFR 200.313(e) states when original or replacement equipment acquired under a Federal award is no longer needed for the original project or program, the non- Federal entity must request disposition instructions from the Federal awarding agency. Condition: Federal regulations require that recipients request disposition instructions from the Federal awarding agency prior to disposal. Cause: The Department was not in compliance with federal regulations and applicable property and equipment requirements. Effect: The Department failed to prevent the retirement of an asset without guidance from the Federal awarding agency. Questioned Costs: Unknown Context: For the only asset disposal tested, the Department failed to comply with the requirements for proper disposal. Prior Year Single Audit Finding Number: Not applicable Recommendation: We recommend the Department strengthen its processes to ensure assets are disposed of in compliance with federal guidelines. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 136.

Corrective Action Plan

The South Carolina Department of Health and Environmental Control respectfully submits the following corrective action plan for the year ended June 30, 2023, on behalf of the State of South Carolina. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAM AUDIT U.S. Department of Health and Human Services 2023 – 025. Public Health Emergency Preparedness – Assistance Listing No. 93.069 Disposition of Audit Finding: SC DHEC concurs with the audit finding. Corrective Action: There are policies in place and staff are adequately trained to identify assets purchased with federal funds. Furthermore, staff are aware of the process to surplus an asset with a fair market value that may require a reimbursement to the federal government. This isolated incident was due to human error. To prevent such errors from happening in the future, the Fixed Asset Manager has asked that the Property Custodian(s) first check whether an asset has been purchased with federal funds when initiating the surplus process. That way, there is more than one individual confirming the source funding for the asset (first the property custodian and then the Asset Manager). We would also take the necessary steps and request asset disposition instructions from the grantor for any disposal of federally-funded assets. This should be an easy fix to the issue going forward. Implementation will begin immediately. Anticipated Completion Date: February 29, 2024 Names of Contact Person Responsible for Corrective Action:  Kim Paradeses –-803-898-3390

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2023-026
Equipment & Real Property
SIGNIFICANT DEFICIENCYOTHER MATTERS

The Department was not in compliance with several equipment and real property requirements. Cause: The Department's processes failed to prevent the issues identified. Effect: The Department was not in compliance with federal regulations and applicable property and equipment requirements. Questioned Costs: None Context: The following discrepancies were encountered during the testing of equipment:  Nine of sixteen tested equipment purchases were not tracked according to Department procedures.  Three of ten purchased equipment tested were not included on the Department’s annual physical inventory of property. Prior Year Single Audit Finding Number: Not applicable Recommendation: We recommend the Department strengthen procedures to ensure that accurate property records are maintained. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 137.

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Federal Agency: Department of Health and Human Services Federal Program Title: Public Health Emergency Preparedness and Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response Assistance Listing: 93.069 and 93.354 Federal Grant ID Number: Various Pass-Through Entity: Not applicable Award Period: Various Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: 2 CFR § 200.303 requires that the 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. 2 CFR § 200.313(d)(1) requires property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the FAIN), who holds title, the acquisition date, and cost of the property, percentage of Federal participation in the project costs for the federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sale price of the property. Condition: The Department was not in compliance with several equipment and real property requirements. Cause: The Department's processes failed to prevent the issues identified. Effect: The Department was not in compliance with federal regulations and applicable property and equipment requirements. Questioned Costs: None Context: The following discrepancies were encountered during the testing of equipment:  Nine of sixteen tested equipment purchases were not tracked according to Department procedures.  Three of ten purchased equipment tested were not included on the Department’s annual physical inventory of property. Prior Year Single Audit Finding Number: Not applicable Recommendation: We recommend the Department strengthen procedures to ensure that accurate property records are maintained. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 137.

Corrective Action Plan

The South Carolina Department of Health and Environmental Control respectfully submits the following corrective action plan for the year ended June 30, 2023, on behalf of the State of South Carolina. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAM AUDIT U.S. Department of Health and Human Services 2023 – 026. Public Health Emergency Preparedness and Public Health Emergency Response – Assistance Listing No. 93.069 and 93.354 Disposition of Audit Finding: SC DHEC concurs with the audit finding. Corrective Action: Due to retirements over the past year, DHEC Business Management has hired new employees in both the Fixed Asset Accounting Manager and the Support Services Director positions. The current Fixed Asset Accounting Manager, with assistance from the Support Services Division Director, completed an internal assessment of the asset inventory process. The asset management process will be updated to reflect a more modern approach to tracking incoming assets during the procurement process. We will do a comprehensive overhaul of the Fixed Asset Accounting Office as well as creating more responsibility for Property Custodians within the agency. This will require updating agency procedures for Property Custodians as well as coordinating a date and time to train and give instruction. We are also looking to modernize and digitize files to create a better filing system for the Fixed Asset Accounting Office. Anticipated Completion Date: Due to the current restructuring of DHEC starting July 1, 2024, we will begin instructing Property Custodians on what new policies will be enforced regarding the asset/procurement process. To ensure a timely transition, all Property Custodians should be adhering to new policies by August 31, 2024. Names of Contact Persons Responsible for Corrective Action:  Kim Paradeses –-803-898-3390

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2023-027
Procurement & Suspension/Debarment
SIGNIFICANT DEFICIENCYOTHER MATTERS

Compliance with suspension and debarment regulations could not be confirmed for one vendor contract. Cause: The Department could not locate the vendor's signed contract agreement containing the suspension and debarment certification clause. Effect: The Department's compliance with federal suspension and debarment requirements was not supported by appropriate documentation. Questioned Costs: None Context: The Department verifies suspension and debarment through a certification clause embedded in the vendor contract. For one of eight vendors tested, the Department was unable to locate a signed vendor contract agreement with the required clause. Prior Year Single Audit Report Finding Number: Not applicable Recommendation: We recommend the Department consistently adhere to its procedures including maintaining the signed contract agreement containing the suspension and debarment terms and conditions for all applicable vendors. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 137.

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Federal Agency: Department of Health and Human Services Federal Program Title: HIV Prevention Activities Health Department Based Assistance Listing: 93.940 Federal Grant ID Number: NU62PS92641 Pass-Through Entity: Not applicable Award Period: July 1, 2022, through June 30, 2023 Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: 2 CFR § 180.300 requires that when a non-federal entity enters into a covered transaction (contracts for goods and services that are expected to equal or exceed $25,000, as well as all subawards to subrecipients, irrespective of award amount) with an entity at a lower tier, the non-federal entity must verify that the entity is not suspended or debarred or otherwise excluded from participating in the transaction. The regulation lists several permitted methods for verification, including the collection of a certification from subrecipients. Condition: Compliance with suspension and debarment regulations could not be confirmed for one vendor contract. Cause: The Department could not locate the vendor's signed contract agreement containing the suspension and debarment certification clause. Effect: The Department's compliance with federal suspension and debarment requirements was not supported by appropriate documentation. Questioned Costs: None Context: The Department verifies suspension and debarment through a certification clause embedded in the vendor contract. For one of eight vendors tested, the Department was unable to locate a signed vendor contract agreement with the required clause. Prior Year Single Audit Report Finding Number: Not applicable Recommendation: We recommend the Department consistently adhere to its procedures including maintaining the signed contract agreement containing the suspension and debarment terms and conditions for all applicable vendors. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 137.

Corrective Action Plan

The South Carolina Department of Health and Environmental Control respectfully submits the following corrective action plan for the year ended June 30, 2023, on behalf of the State of South Carolina. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAM AUDIT U.S. Department of Health and Human Services 2023 – 027. HIV Prevention Activities Health Department Based – Assistance Listing No. 93.940 Disposition of Audit Finding: SC DHEC concurs with the audit finding. Corrective Action: This was simply a mistake caused by human error. The procedure is in place and in writing and all staff are aware of the requirement. In this instance, one of eight tested, the file did not contain the proper documentation of either or both a SAM check showing no exclusions or a solicitation with the debarment and suspension clause. In this case, since a formal written solicitation was not needed or used, the buyer should have performed a SAM check, printed documentation to substantiate this, and retain the documentation in the file. Since there is no such documentation in the file, either the buyer failed to perform the check or performed the check but failed to properly retain the written documentation in the file. Normally we would address such matters at our twice annual Direct Purchase Order (DPO) Update meetings that are required to be attended or viewed by all staff with procurement responsibilities. However, DHEC is currently preparing for legislatively required restructuring which will dissolve DHEC on June 30, 2024, and establish two new successor agencies effective July 1, 2024. There are no DPO Update meetings scheduled before DHEC ceases to exist, and there is no clear certainty that the DPO Update, as we know it at DHEC, will exist for both successor agencies. Therefore, we will first address this matter by email to all staff who issue purchase orders subject to this requirement, reminding them of the Suspension and Debarment requirements and that they need to retain documentation in the file. Further, we will advise the Procurement Directors of the two successor agencies to reinforce this requirement with the appropriate staff of the new agencies at the first appropriate opportunity after the two new agencies are operational. Anticipated Completion Date: March 2024 Persons responsible for corrective action:  Kim Paradeses –-803-898-3390

About Procurement and Suspension and Debarment →
2023-028
Reporting
SIGNIFICANT DEFICIENCYOTHER MATTERS

We identified noncompliance with FFATA reporting requirements. Cause: Due to staffing turnover, the FSRS could not be accessed to provide the FFATA reports that were submitted during fiscal year 2023. Effect: We were unable to determine compliance with FFATA reporting requirements. Questioned Costs: None Context: The Department could not provide documentation that they had submitted FFATA reports for subawards of $30,000 or more. Prior Year Single Audit Finding Number: Not applicable. Recommendation: We recommend that the Department take steps to ensure access to FFATA submissions and retention of supporting documentation to demonstrate compliance with reporting requirements. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 138.

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Federal Agency: Department of Health and Human Services Federal Program Titles: Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response and HIV Prevention Activities Health Department Based Assistance Listings: 93.354 and 93.940 Federal Grant ID Number: Various Pass-Through Entity: Not applicable Award Period: Various Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: 2 CFR § 170 Appendix A requires that recipients of grants or cooperative agreements report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act (FFATA) Subaward Reporting System (FSRS). Condition: We identified noncompliance with FFATA reporting requirements. Cause: Due to staffing turnover, the FSRS could not be accessed to provide the FFATA reports that were submitted during fiscal year 2023. Effect: We were unable to determine compliance with FFATA reporting requirements. Questioned Costs: None Context: The Department could not provide documentation that they had submitted FFATA reports for subawards of $30,000 or more. Prior Year Single Audit Finding Number: Not applicable. Recommendation: We recommend that the Department take steps to ensure access to FFATA submissions and retention of supporting documentation to demonstrate compliance with reporting requirements. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 138.

Corrective Action Plan

The South Carolina Department of Health and Environmental Control respectfully submits the following corrective action plan for the year ended June 30, 2023, on behalf of the State of South Carolina. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAM AUDIT U.S. Department of Health and Human Services 2023 – 028. Public Health Emergency Response and HIV Prevention Activities Health Department Based – Assistance Listing No. 93.354 and 93.940 Disposition of Audit Finding: SC DHEC concurs with the audit finding. Corrective Action: We are currently saving the FFATA reports on the shared drive each month when they are entered. This has been the process since October 2022. This finding was from the subawards in the audit where the FFATA information was entered prior to these dates, and prior to the current employee entering them. The system does not show FFATA reports submitted from a different login, and the previous log-in/person is no longer with the agency. We will contact the Federal agency to see if it is possible to get the reports submitted from the old log-in. Our current process of saving these reports gives us access to all the reports entered for the agency. Anticipated Completion Date: March 2024 Name of the contact person responsible for corrective action:  Kim Paradeses –-803-898-3390

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2023-029
Reporting
SIGNIFICANT DEFICIENCYOTHER MATTERS

Discrepancies existed between the federal financial reports and the accounting system. Cause: The Department misclassified unliquidated obligations as expenditures. Effect: The accuracy of the reported federal share of expenditures could not be fully validated. Questioned Costs: None Context: For the two annual reports submitted for Public Health Preparedness and HIV Prevention Activities Health Department Based, the Department reported expenditures incurred after the reporting period end date. Prior Year Single Audit Finding Number: Not applicable. Recommendation: We recommend that the Department review its procedures to ensure that federal reports are submitted in accordance with the reporting requirements. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 138.

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Federal Agency: Department of Health and Human Services Federal Program Titles: Public Health Emergency Preparedness and HIV Prevention Activities Health Department Based Assistance Listings: 93.069 and 93.940 Federal Grant ID Number: Various Pass-Through Entity: Not applicable Award Period: Various Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: 45 CFR § 75.303 requires effective internal controls be established and maintained to provide reasonable assurance that the federal award is being managed in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: Discrepancies existed between the federal financial reports and the accounting system. Cause: The Department misclassified unliquidated obligations as expenditures. Effect: The accuracy of the reported federal share of expenditures could not be fully validated. Questioned Costs: None Context: For the two annual reports submitted for Public Health Preparedness and HIV Prevention Activities Health Department Based, the Department reported expenditures incurred after the reporting period end date. Prior Year Single Audit Finding Number: Not applicable. Recommendation: We recommend that the Department review its procedures to ensure that federal reports are submitted in accordance with the reporting requirements. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 138.

Corrective Action Plan

The South Carolina Department of Health and Environmental Control respectfully submits the following corrective action plan for the year ended June 30, 2023, on behalf of the State of South Carolina. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAM AUDIT U.S. Department of Health and Human Services2023 – 029. Public Health Emergency Preparedness and HIV Prevention Activities Health Department Based – Assistance Listing No. 93.069 and 93.940 Disposition of Audit Finding: SC DHEC concurs with the audit finding. Corrective Action: This was an oversight in filing the Federal Financial Reports (FFR) noted above. The unliquidated obligations were mistakenly included on the expenditures line on the FFR. In the future, we will strengthen our controls to ensure that all unliquidated obligations are included on the appropriate line in the Federal Financial Report. Anticipated Completion Date: March 31, 2024 Name of the contact person responsible for corrective action:  Kim Paradeses –-803-898-3390

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2023-030
Period of Performance
SIGNIFICANT DEFICIENCYOTHER MATTERS

Expenditures were charged to the program after the end of the period of performance. Cause: The Department's internal controls failed to prevent expenditures from being charged to the grant after close of the period of performance. Effect: Costs charged outside of the period of performance may not be allowable. Questioned Costs: None Context: During our testing of the final report for Public Health Emergency Response, we noted expenditures were recorded in the accounting system after grant closure. Prior Year Single Audit Finding Number: Not applicable Recommendation: We recommend that the Department review its internal controls to ensure all expenditures charged to a federal award are incurred within the grant’s period of performance. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 139.

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Full finding narrative

Federal Agency: Department of Health and Human Services Federal Program Titles: Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response Assistance Listings: 93.354 Federal Grant ID Number: NU90TP922116 Pass-Through Entity: Not applicable Award Period: Various Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: 2 CFR § 200.403(h) requires costs to be incurred during the approved budget period. Condition: Expenditures were charged to the program after the end of the period of performance. Cause: The Department's internal controls failed to prevent expenditures from being charged to the grant after close of the period of performance. Effect: Costs charged outside of the period of performance may not be allowable. Questioned Costs: None Context: During our testing of the final report for Public Health Emergency Response, we noted expenditures were recorded in the accounting system after grant closure. Prior Year Single Audit Finding Number: Not applicable Recommendation: We recommend that the Department review its internal controls to ensure all expenditures charged to a federal award are incurred within the grant’s period of performance. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 139.

Corrective Action Plan

The South Carolina Department of Health and Environmental Control respectfully submits the following corrective action plan for the year ended June 30, 2023, on behalf of the State of South Carolina. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAM AUDIT U.S. Department of Health and Human Services 2023 – 030. Public Health Emergency Response – Assistance Listing No. 93.354 Disposition of Audit Finding: SC DHEC concurs with the audit finding. Corrective Action: This was an error, and it was caught through the Statement of Changes Report and the expenditure was covered with a cash transfer. We will review our internal controls to determine what other steps can be taken to prevent this from occurring in the future. Anticipated Completion Date: March 31, 2024 Name of the contact person responsible for corrective action:  Kim Paradeses –-803-898-3390

About Period of Performance →
2023-031
Activities Allowed or Unallowed / Cost Allowability / Eligibility
SIGNIFICANT DEFICIENCYQUESTIONED COSTSOTHER MATTERS

Eligibility and allowable costs/cost principles related discrepancies were encountered for some payments. Cause: Department controls failed to ensure eligibility requirements were being met by retaining records for the required amount of time, and that all costs charged to the grant were allowable. Effect: The Department did not comply with eligibility and allowable costs/cost principles requirements. Questioned Costs: $7,560 Context: Sixty payments were selected for testing eligibility compliance. The following discrepancies were identified: (1) For ten payments tested, the related case files lacked some or all of the documents needed to verify that all the required criminal background checks had been completed prior to the dates covered by the payment. These include Federal Bureau of Investigation fingerprint background checks, South Carolina Law Enforcement Division checks, and the South Carolina Central Registry of Child Abuse and Neglect checks. (2) For five payments tested, adoption subsidies were being improperly charged to the federal award. Prior year Single Audit Report Finding Number: Not applicable Recommendation: We recommend that the Department strengthen their current policies and procedures to ensure compliance with eligibility and allowable costs/cost principles requirements. In addition, we recommend that the Department implement procedures to ensure all required foster home records are properly retained. Views of Responsible Officials and Corrective Actions Plan: Management agrees with the finding. See Corrective Action Plan at page 140.

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Full finding narrative

Federal Agency: Department of Health and Human Services Federal Program Title: Foster Care Title IV-E Assistance Listing: 93.658 Federal Grant ID Numbers: 2101SCFOST, 2201SCFOST, and 2303SCFOST Pass-Through Entity: Not applicable Award Period: October 1, 2021, through September 30, 2023 Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: 45 CFR § 75.303 requires effective internal controls be established and maintained in order to provide reasonable assurance that the federal award is being managed in compliance with federal statutes, regulations, and the terms and conditions of the federal award. 42 USC § 672 describes the general eligibility requirements for foster care maintenance payments. 42 USC § 671(a)(20) outlines requirements for criminal background checks of foster care providers, including those for child care institutions. 45 CFR § 75.361 states record retention requirements of the non-federal entity pertinent to the federal award. Condition: Eligibility and allowable costs/cost principles related discrepancies were encountered for some payments. Cause: Department controls failed to ensure eligibility requirements were being met by retaining records for the required amount of time, and that all costs charged to the grant were allowable. Effect: The Department did not comply with eligibility and allowable costs/cost principles requirements. Questioned Costs: $7,560 Context: Sixty payments were selected for testing eligibility compliance. The following discrepancies were identified: (1) For ten payments tested, the related case files lacked some or all of the documents needed to verify that all the required criminal background checks had been completed prior to the dates covered by the payment. These include Federal Bureau of Investigation fingerprint background checks, South Carolina Law Enforcement Division checks, and the South Carolina Central Registry of Child Abuse and Neglect checks. (2) For five payments tested, adoption subsidies were being improperly charged to the federal award. Prior year Single Audit Report Finding Number: Not applicable Recommendation: We recommend that the Department strengthen their current policies and procedures to ensure compliance with eligibility and allowable costs/cost principles requirements. In addition, we recommend that the Department implement procedures to ensure all required foster home records are properly retained. Views of Responsible Officials and Corrective Actions Plan: Management agrees with the finding. See Corrective Action Plan at page 140.

Corrective Action Plan

The South Carolina Department of Social Services respectfully submits the following corrective action plan for the year ended June 30, 2023, on behalf of the State of South Carolina. The findings from the Schedule of Findings and Questioned Costs are discussed below. The findings are numbered consistently with the number or numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAM AUDIT U. S. Department of Health and Human Services 2023 – 031 Federal Program Title: Foster Care Title IV-E – Assistance Listing: 93.658 Disposition of Audit Finding: The South Carolina Department of Social Services concurs with the audit finding. Corrective Action: The timely completion of all required background checks is a vital program requirement, and we have taken several steps in recent years to better assure that they occur when they should. Among those is the inclusion in all child placement agency contracts of a provision stating that, if the Department determines the provider has failed to complete required background checks, any federal IV-E Foster Care funding received that relied on the correct completion of those checks must be returned to the Department so that it can return the funds to ACF. The Department also has modified its contracts with group homes to include this same requirement with respect to some but not all required background checks, and management has initiated the process to modify these agreements again to apply that provision to all required background checks. Management also will review the case files for the exceptions noted to determine the circumstances in which the exceptions occurred and identify measures that can be added to our processes and controls to eliminate those exceptions, to the fullest extent possible, going forward. One possibility is to modify the provider contracts to require them to provide more information to DSS about changes in their employee populations and their completion of background checks for both new employees and on an annual basis for existing employees, so that the Department can more readily monitor their background check compliance. Management will also review its monitoring practices to identify any changes needed to make better use of available information and increase the likelihood that the Department will timely detect background check failures, promptly initiate the calculation of the associated federal funds paid, demand return of federal funds to the Department, and follow up to ensure the Department receives and returns them. We believe that stronger and more prompt enforcement of the requirement to return federal funding will substantially reduce the number of exceptions that occur. Management will also consider whether additional enforcement measures are needed to prevent or detect failure to complete background checks associated with individual foster homes when new household members enter a home after initial licensing. Regarding the case for which five adoption subsidy payments were miscoded to Foster Care, the coding of the subject case has been corrected in CCWIS. This miscoding was caused by selection of an invalid funding source code during case set-up in our CCWIS system. The Department’s IT staff have since removed the ability to choose the invalid option, making it impossible to repeat this error. The Department is moving the incorrectly posted expenditures from IV-E Foster Care to IV-E Adoption Assistance funding. Name(s) of the contact person(s) responsible for corrective action: Dawn Barton, Permanency Manager Planned completion date for corrective action plan: For background check documentation exceptions, initial review of case files and exploration of additional measures needed: May 31, 2024. Implementation of additional measures determined to be needed: August 31, 2024. For the miscoded payments: February 29, 2024.

About Activities Allowed or Unallowed, Allowable Costs / Cost Principles, Eligibility →
2023-032
Activities Allowed or Unallowed / Cost Allowability
SIGNIFICANT DEFICIENCYREPEAT OF 2020-032QUESTIONED COSTSOTHER MATTERS

Costs charged to the program were not adequately supported. Cause: Documentation and system issues caused the discrepancies noted. Effect: The potential for overcharging the grant exists when costs charged to federal awards are not adequately supported, including documentation of the proportional benefit to the grant award. Questioned Costs: Unknown Context: For eight of sixty Foster Care and three of sixty TANF non-payroll transactions tested, the costs included allowable charges that benefited multiple programs and activities but were not properly allocated to match proportional benefit to each allowable funding source. For the Foster Care program, this is a repeat finding from the fiscal year 2022 Single Audit. The Department stated on its Summary Schedule of Prior Year Audit Findings that this issue was “Fully Corrected with Previously Reported Corrective Action Implemented”. Due to this issue repeating for fiscal year 2023, not all issues have been fully corrected. Prior year Single Audit Report Finding Number: 2020-032 for Foster Care (Assistance Listing Number 93.658) only. Recommendation: We recommend that the Department review and update its procedures to ensure all costs charged to the grant are allowable and properly allocated to applicable grants and funding sources based on benefit. Views of Responsible Officials and Corrective Actions Plan: Management agrees with the finding. See Corrective Action Plan at page 141.

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Federal Agency: Department of Health and Human Services Federal Program Titles: Foster Care Title IV-E and Temporary Assistance for Needy Families Assistance Listings: 93.658 and 93.558 Federal Grant ID Numbers: Various Pass-Through Entity: Not applicable Award Period: October 1, 2021, through September 30, 2023 Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: 45 CFR § 75.403 outlines factors affecting allowability of costs, including adequate documentation. 45 CFR § 75.405(d) requires costs that benefit two or more projects or activities to be allocated among projects based on the proportional benefit or, if that cannot be determined feasibly, allocated on another reasonable, documented basis. Condition: Costs charged to the program were not adequately supported. Cause: Documentation and system issues caused the discrepancies noted. Effect: The potential for overcharging the grant exists when costs charged to federal awards are not adequately supported, including documentation of the proportional benefit to the grant award. Questioned Costs: Unknown Context: For eight of sixty Foster Care and three of sixty TANF non-payroll transactions tested, the costs included allowable charges that benefited multiple programs and activities but were not properly allocated to match proportional benefit to each allowable funding source. For the Foster Care program, this is a repeat finding from the fiscal year 2022 Single Audit. The Department stated on its Summary Schedule of Prior Year Audit Findings that this issue was “Fully Corrected with Previously Reported Corrective Action Implemented”. Due to this issue repeating for fiscal year 2023, not all issues have been fully corrected. Prior year Single Audit Report Finding Number: 2020-032 for Foster Care (Assistance Listing Number 93.658) only. Recommendation: We recommend that the Department review and update its procedures to ensure all costs charged to the grant are allowable and properly allocated to applicable grants and funding sources based on benefit. Views of Responsible Officials and Corrective Actions Plan: Management agrees with the finding. See Corrective Action Plan at page 141.

Corrective Action Plan

The South Carolina Department of Social Services respectfully submits the following corrective action plan for the year ended June 30, 2023, on behalf of the State of South Carolina. The findings from the Schedule of Findings and Questioned Costs are discussed below. The findings are numbered consistently with the number or numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAM AUDIT U. S. Department of Health and Human Services 2023 – 032 Foster Care Title IV-E and Temporary Assistance for Needy Families – Assistance Listings: 93.658 and 93.558 Disposition of Audit Finding: The South Carolina Department of Social Services concurs with the audit finding. Corrective Action: Management believed all the necessary corrective action had been taken to address this issue when we evaluated the status of prior-year findings. Now that new examples of this issue have emerged, we understand that charges to one PCA in particular still needs further attention. Management will review these charges to identify appropriate transaction allocation, documentation, and approval approaches that more fully, clearly, and consistently consider the extent to which these specific charges benefit the various programs, and we will ensure the documentation and accounting for those charges reflect the relative benefits thus determined. Name(s) of the contact person(s) responsible for corrective action: David O’Kelly, Fiscal/Accounting Manager Planned completion date for corrective action plan: June 30, 2024

Prior Finding References

2020-032

About Activities Allowed or Unallowed, Allowable Costs / Cost Principles →
2023-033
Reporting
SIGNIFICANT DEFICIENCYOTHER MATTERS

We identified noncompliance with FFATA reporting requirements. Cause: The Department has two unique entity identifier (UEI) numbers. The FSRS wouldn’t allow the Department to submit a FFATA as it was unable to determine the appropriate UEI to assign to the report. Effect: The Department was not in compliance with FFATA reporting requirements. Questioned Costs: None Context: The Department did not submit FFATA reports, although it had subawards of $30,000 or more. Prior Year Single Audit Report Finding Number: Not applicable Recommendation: We recommend that the Department contact its federal awarding agency (Department of Health and Human Services) to resolve the issue of having two UEIs and confirm which UEI should be utilized to submit FFATA reports. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 142.

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Federal Agency: Department of Health and Human Services Federal Program Title: Temporary Assistance for Needy Families Assistance Listing: 93.558 Federal Grant ID Numbers: 2201SCTANF and 2301SCTANF Pass-Through Entity: Not applicable Award Period: October 01, 2021, through September 30, 2024 Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: 2 CFR § 170 Appendix A requires that recipients of grants or cooperative agreements report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act (FFATA) Subaward Reporting System (FSRS). Condition: We identified noncompliance with FFATA reporting requirements. Cause: The Department has two unique entity identifier (UEI) numbers. The FSRS wouldn’t allow the Department to submit a FFATA as it was unable to determine the appropriate UEI to assign to the report. Effect: The Department was not in compliance with FFATA reporting requirements. Questioned Costs: None Context: The Department did not submit FFATA reports, although it had subawards of $30,000 or more. Prior Year Single Audit Report Finding Number: Not applicable Recommendation: We recommend that the Department contact its federal awarding agency (Department of Health and Human Services) to resolve the issue of having two UEIs and confirm which UEI should be utilized to submit FFATA reports. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 142.

Corrective Action Plan

The South Carolina Department of Social Services respectfully submits the following corrective action plan for the year ended June 30, 2023, on behalf of the State of South Carolina. The findings from the Schedule of Findings and Questioned Costs are discussed below. The findings are numbered consistently with the number or numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAM AUDIT U. S. Department of Health and Human Services 2023 – 033 Temporary Assistance for Needy Families – Assistance Listing No. 93.558 Disposition of Audit Finding: The South Carolina Department of Social Services concurs with the audit finding. Corrective Action: One of the two UEI numbers is no longer active, and this should make it easier to address this problem. The Department’s Grants Accounting and Reporting staff will work with the Department of Health and Human Services to resolve the issues precluding entry of FFATA reports, and they will catch-up on the reporting as quickly as possible. Name(s) of the contact person(s) responsible for corrective action: Susan Roben, Chief Financial Officer Planned completion date for corrective action plan: June 30, 2024

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2023-034
Activities Allowed or Unallowed / Cost Allowability
SIGNIFICANT DEFICIENCYOTHER MATTERS

Personnel expenditures for two employees were charged to the federal award without documented approval as required by the Department’s internal control procedure. Cause: The Department failed to retain salary and approval documentation supporting the two employee's personnel charges to the grant program. Effect: The Department could incorrectly charge the federal award for personnel costs. Questioned Costs: None Context: There were 60 employees tested that were only paid out of TANF funds and 60 employees tested that were paid out of TANF and SNAP funds. The following discrepancies were identified: 1) One payroll transaction that was only paid out of TANF funds was missing an approval by an appointed manager on their State Personnel Action Form that documents their salary and the percentage of their salary covered by the grant program. 2) One payroll transaction that was paid out of SNAP and TANF funds did not have an updated State Personnel Action Form applicable to the pay the employee received in the selected period. Therefore, we were not able to confirm that the employee's pay during the selected period was allowable, as it was not supported by adequate documentation. Prior Year Single Audit Report Finding Number: Not applicable Recommendation: We recommend the Department consistently adhere to its internal controls including maintaining the approved State Personnel Action Form to support the personnel charges and allocations to applicable funding sources. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 142.

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Full finding narrative

Federal Agencies: Department of Agriculture and Department of Health and Human Services Federal Program Titles: SNAP Cluster and Temporary Assistance for Needy Families Assistance Listings: 10.551, 10.561, and 93.558 Federal Grant ID Numbers: 5SC400407 and 2201SCTANF Pass-Through Entity: Not applicable Award Period: October 01, 2021, through September 30, 2023 Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: 2 CFR § 200.303 requires that the 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. Condition: Personnel expenditures for two employees were charged to the federal award without documented approval as required by the Department’s internal control procedure. Cause: The Department failed to retain salary and approval documentation supporting the two employee's personnel charges to the grant program. Effect: The Department could incorrectly charge the federal award for personnel costs. Questioned Costs: None Context: There were 60 employees tested that were only paid out of TANF funds and 60 employees tested that were paid out of TANF and SNAP funds. The following discrepancies were identified: 1) One payroll transaction that was only paid out of TANF funds was missing an approval by an appointed manager on their State Personnel Action Form that documents their salary and the percentage of their salary covered by the grant program. 2) One payroll transaction that was paid out of SNAP and TANF funds did not have an updated State Personnel Action Form applicable to the pay the employee received in the selected period. Therefore, we were not able to confirm that the employee's pay during the selected period was allowable, as it was not supported by adequate documentation. Prior Year Single Audit Report Finding Number: Not applicable Recommendation: We recommend the Department consistently adhere to its internal controls including maintaining the approved State Personnel Action Form to support the personnel charges and allocations to applicable funding sources. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 142.

Corrective Action Plan

The South Carolina Department of Social Services respectfully submits the following corrective action plan for the year ended June 30, 2023, on behalf of the State of South Carolina. The findings from the Schedule of Findings and Questioned Costs are discussed below. The findings are numbered consistently with the number or numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAM AUDIT U. S. Department of Health and Human Services 2023 – 034 SNAP Cluster and Temporary Assistance for Needy Families – Assistance Listing No. 10.551, 10.561, and 93.558 Disposition of Audit Finding: The South Carolina Department of Social Services concurs with the audit finding. Corrective Action: In the case of the missing approval signature, the Personnel Action Form did contain the employee’s data and the salary that was put into effect. Management believes that this occurred due to an oversight by clerical staff when this October 2019 payroll change form was processed. Regarding the exception involving a missing State Personnel Action Form, which occurred March 2021, management believes this was an isolated occurrence. Since the time in which the noted exceptions occurred, the Department’s Human Resources staff have strengthened the controls over the processing of State Personnel Action Forms. These controls now include review of all forms for completeness and accuracy, and correction of missing signatures or other errors noted, prior to routing the forms to staff for input. After processing by input staff, the personnel actions now work-flow to other staff who complete quality assurance checks by comparing the changes processed to the Personnel Action Forms to ensure they agree. We believe these added controls provide adequate assurance that only personnel actions supported by correct and complete documentation will be processed. Name(s) of the contact person(s) responsible for corrective action: Shaquanda Gallman, Assistant Director of Human Resources Planned completion date for corrective action plan: January 2024

About Activities Allowed or Unallowed, Allowable Costs / Cost Principles →
2023-035
Reporting
SIGNIFICANT DEFICIENCYOTHER MATTERS

Discrepancies existed between the ACF-199 (TANF Data Report) and the Department’s records. Documentation was not retained to determine that the report had been reviewed prior to submission as required by the Department’s policies and procedures. Cause: The incorrect source data was utilized when completing the referenced data element on the performance report. Effect: Some of the data fields reported on the ACF-199 report are inconsistent with the supporting case records. Questioned Costs: None Context: Key data elements for twenty-five families were tested from one quarterly ACF- 199 report. Two discrepancies were noted for one data element related to recording the number of months countable towards the federal time limit for assistance. Prior year Single Audit Report Finding Number: Not applicable Recommendation: We recommend that the Department strengthen its processes to ensure that federal reports are free from error prior to submission. We also recommend that the Department update and review processes to ensure proper documentation of supervisory review is maintained. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 143.

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Federal Agency: Department of Health and Human Services Federal Program Title: Temporary Assistance for Needy Families Assistance Listing: 93.558 Federal Grant ID Numbers: 2201SCTANF and 2301SCTANF Pass-Through Entity: Not applicable Award Period: October 01, 2021, through September 30, 2024 Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: 45 CFR § 265.7(a) requires that each state's quarterly reports, including the TANF Data Report, be complete and accurate. 2 CFR § 200.303 requires that the 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. Condition: Discrepancies existed between the ACF-199 (TANF Data Report) and the Department’s records. Documentation was not retained to determine that the report had been reviewed prior to submission as required by the Department’s policies and procedures. Cause: The incorrect source data was utilized when completing the referenced data element on the performance report. Effect: Some of the data fields reported on the ACF-199 report are inconsistent with the supporting case records. Questioned Costs: None Context: Key data elements for twenty-five families were tested from one quarterly ACF- 199 report. Two discrepancies were noted for one data element related to recording the number of months countable towards the federal time limit for assistance. Prior year Single Audit Report Finding Number: Not applicable Recommendation: We recommend that the Department strengthen its processes to ensure that federal reports are free from error prior to submission. We also recommend that the Department update and review processes to ensure proper documentation of supervisory review is maintained. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 143.

Corrective Action Plan

The South Carolina Department of Social Services respectfully submits the following corrective action plan for the year ended June 30, 2023, on behalf of the State of South Carolina. The findings from the Schedule of Findings and Questioned Costs are discussed below. The findings are numbered consistently with the number or numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAM AUDIT U. S. Department of Health and Human Services 2023– 035 Temporary Assistance for Needy Families – Assistance Listing No. 93.558 Disposition of Audit Finding: The South Carolina Department of Social Services concurs with the audit finding. Corrective Action: Management believes these errors resulted from staff pulling the dates from the wrong system screen. Management has already met with staff to discuss the errors and agree on corrective action, and the Department has already submitted the needed data corrections to The Administration for Children and Families (ACF). Going forward, as staff pull these dates, they will save an image of the screen accessed as backup. In addition, the program supervisor will increase the quality reviews of these data inputs from the current level of 10 to 15 % of the total cases processed, to at least 25%. The files to be reviewed will be pulled and saved in a designated file review folder. The supervisor will document their review of each case file by recording in the file the results of the review (whether found to be correct, or recording any exceptions noted and corrections made) and then digitally sign and date the file. We believe these measures will greatly reduce the risk of undetected and uncorrected errors. Name(s) of the contact person(s) responsible for corrective action: Kimberly Boyd, Accountability, Data and Research Program Coordinator II Planned completion date for corrective action plan: April 30, 2024

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FY 2022-06-30

$12,910,515,918 federal awards expended

FAC accepted this audit on March 30, 2023 — management decision was due September 30, 2023.

2022-001
Eligibility
MATERIAL WEAKNESSMODIFIED OPINIONREPEAT OF 2021-001QUESTIONED COSTS

In March 2020, the President signed the CARES Act that authorized additional funding under the Unemployment Insurance (UI) program. This was followed by additional federal and state funding programs that increased grants available and modified eligibility requirements to support changes in employment status caused by the COVID-19 pandemic. Certain benefits under these programs extended into fiscal year 2022. There was a priority on distributing funds under self-attestation strategy with limited income verification to expedite disbursement of funds and support individuals in greatest need. As a result of this, many states saw a significant increase in fraudulent claims to historical highs. The U.S. Department of Labor and the Agency have partnered to investigate the extent and methods used to perpetrate fraud. For the Agency, eligibility determinations made by the management followed existing policies and procedures for this pandemic funding; however, to meet federal and state expectations regarding the quick payment of federal pandemic benefits, the policies and procedures in place were not the usual policies and procedures and so they were not adequate to completely prevent fraudulent claims. The Agency’s detective controls did identify abnormal claim activity; however, it was after the claims had already been paid. During our testing of a sample of 60 benefit payments we identified 3 payments that were fraudulent, total value of payments tested was $16,776 and total amount of fraud was $835. The extrapolated fraud amount over the total benefit payments of $179.4 million would be $9 million. Criteria: Per 2 CFR §200 Appendix XI, state responsibilities include: (1) establishing specific, detailed policies and operating procedures which comply with the requirements of federal laws and regulations; (2) determining the state unemployment insurance tax structure; (3) collecting state unemployment insurance contributions from employers (commonly called “unemployment taxes”); (4) determining claimant eligibility and disqualification provisions; (5) making payment of UI benefits to claimants; (6) managing the program’s revenue and benefit administrative functions; (7) administering the programs in accordance with established policies and procedures; and (8) enacting state UC law that conforms with federal UC law and that state law and operations substantially comply with federal law. Effect: A lack of adequate internal controls over eligibility determinations may increase the likelihood of fraudulent claims being submitted and incorrectly paid. Known Questioned Costs: During our testing of a sample of 60 benefit payments we identified 3 payments that were fraudulent, the total value of payments tested was $16,776 and total amount of known fraud was $835. Likely Questioned Costs: Based upon the extrapolated fraud amount over the total benefit payment of $179.4 thousand the total amount of fraud would likely be $10 million. Cause: The Agency experienced unprecedented claims volume starting in fiscal 2021 and continuing into fiscal year 2022 with increased funding and additional program requirements with a priority for efficient distribution from both the U.S. Department of Labor and state officials. Recommendation: We recommend that the Agency continue to review, monitor, and enhance eligibility procedures to detect and/or prevent fraudulent claimants from receiving benefits. The Agency should work to enhance and update its assessment of risks related to the eligibility process and implement internal controls to help mitigate future fraudulent claims.

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Finding 2022-001: Unemployment Insurance Benefit Payments (Material Weakness in Internal Controls) Condition: In March 2020, the President signed the CARES Act that authorized additional funding under the Unemployment Insurance (UI) program. This was followed by additional federal and state funding programs that increased grants available and modified eligibility requirements to support changes in employment status caused by the COVID-19 pandemic. Certain benefits under these programs extended into fiscal year 2022. There was a priority on distributing funds under self-attestation strategy with limited income verification to expedite disbursement of funds and support individuals in greatest need. As a result of this, many states saw a significant increase in fraudulent claims to historical highs. The U.S. Department of Labor and the Agency have partnered to investigate the extent and methods used to perpetrate fraud. For the Agency, eligibility determinations made by the management followed existing policies and procedures for this pandemic funding; however, to meet federal and state expectations regarding the quick payment of federal pandemic benefits, the policies and procedures in place were not the usual policies and procedures and so they were not adequate to completely prevent fraudulent claims. The Agency’s detective controls did identify abnormal claim activity; however, it was after the claims had already been paid. During our testing of a sample of 60 benefit payments we identified 3 payments that were fraudulent, total value of payments tested was $16,776 and total amount of fraud was $835. The extrapolated fraud amount over the total benefit payments of $179.4 million would be $9 million. Criteria: Per 2 CFR §200 Appendix XI, state responsibilities include: (1) establishing specific, detailed policies and operating procedures which comply with the requirements of federal laws and regulations; (2) determining the state unemployment insurance tax structure; (3) collecting state unemployment insurance contributions from employers (commonly called “unemployment taxes”); (4) determining claimant eligibility and disqualification provisions; (5) making payment of UI benefits to claimants; (6) managing the program’s revenue and benefit administrative functions; (7) administering the programs in accordance with established policies and procedures; and (8) enacting state UC law that conforms with federal UC law and that state law and operations substantially comply with federal law. Effect: A lack of adequate internal controls over eligibility determinations may increase the likelihood of fraudulent claims being submitted and incorrectly paid. Known Questioned Costs: During our testing of a sample of 60 benefit payments we identified 3 payments that were fraudulent, the total value of payments tested was $16,776 and total amount of known fraud was $835. Likely Questioned Costs: Based upon the extrapolated fraud amount over the total benefit payment of $179.4 thousand the total amount of fraud would likely be $10 million. Cause: The Agency experienced unprecedented claims volume starting in fiscal 2021 and continuing into fiscal year 2022 with increased funding and additional program requirements with a priority for efficient distribution from both the U.S. Department of Labor and state officials. Recommendation: We recommend that the Agency continue to review, monitor, and enhance eligibility procedures to detect and/or prevent fraudulent claimants from receiving benefits. The Agency should work to enhance and update its assessment of risks related to the eligibility process and implement internal controls to help mitigate future fraudulent claims.

Corrective Action Plan

The South Carolina Department of Employment and Workforce (SCDEW) immediately recognized the increased fraud risk presented by the federal pandemic programs. In an effort to deter this obvious fraud threat, SCDEW initially informed every applicant for federal pandemic benefits that they might be required to provide proof of their employment or self-employment at a future time. The USDOL, however, ordered SCDEW to remove this notification because, in the words of one USDOL representative, such a warning might deter a claimant from applying for federal pandemic benefits. USDOL subsequently issued guidance prohibiting states from requiring proof of employment or self-employment as an eligibility requirement to receive federal pandemic benefits. Therefore, all a fraudster had to do to receive federal benefits was simply tell a state they were unemployed as a result of the COVID-19 pandemic. SCDEW was prohibited from requiring that fraudster to prove that they were even employed, let alone that they were unemployed because of the pandemic. Many of the items identified as paid fraudulent claims were caused by SCDEW’s compliance with the USDOL guidelines. SCDEW complied with this guidance, even though it disagreed with USDOL’s highly technical parsing of federal law, and SCDEW advocated for Congress to amend the law to clearly establish commonsense fraud protections. While awaiting Congressional action, SCDEW implemented numerous fraud detection and prevention tools and strategies to minimize the potential fraud exacerbated by lax federal requirements. Unfortunately, Congress did not amend the law until late December 2020. As a result, eligibility determinations made by SCDEW prior to the law change followed the federal guidance for this pandemic funding; however, to meet federal and state expectations regarding the quick payment of federal pandemic benefits, the federal policies and procedures SCDEW was forced to adopt were not adequate to completely prevent fraudulent claims. SCDEW continues to review, monitor, and enhance eligibility processes and procedures to prevent and detect fraudulent claims. We also updated our internal controls to help mitigate future fraudulent claims. The COVID pandemic created unprecedented challenges for every state workforce agency due to the combination of historic claim volume, the availability of a staggering amount of federal money, and new programs with lax eligibility and verification requirements that had to be implemented quickly, despite often changing federal guidance. These factors created a perfect storm for sophisticated fraudsters to exploit. In response, SCDEW took numerous aggressive steps. In mid-2020, SCDEW required applicants to provide copies of their driver’s license or passport to prove their identity before receiving benefits. SCDEW also implemented identity verification questions through Lexis Nexis that every claimant had to pass before processing a claim. This was further enhanced in March 2021, when South Carolina was one of the first states to implement digital identity verification through ID.me. SCDEW also implemented reCAPTCHA to prevent against bot attacks, implemented new data sharing agreements, and increased the number of staff dedicated to investigating fraudulent claim activity to over fifty at the peak of the pandemic programs. SCDEW continuously reviews its fraud detection and prevention activities to stay ahead of emerging fraud schemes. Since the height of the pandemic, SCDEW has increased its data crossmatching, partnered with the State Law Enforcement Division to have a financial fraud investigator dedicated to unemployment insurance fraud, and made numerous enhancements to its computer systems to combat fraud and preserve the integrity of the unemployment insurance system. Per USDOL data, the agency had the twelfth lowest improper payment rate out of fifty-three programs during the year ending September 30, 2024. For more comprehensive explanation and response, please see August 26, 2024, letter attached from Paul Famolari, Assistant Executive Director of Unemployment Insurance. The Agency’s contact person responsible for the corrective action plan is Jacquelyn Carlen, CFO. The completion date of the corrective action plan was June 20, 2021, and is ongoing.

Prior Finding References

2021-001

About Eligibility →
2022-002
Other
MATERIAL WEAKNESSOTHER MATTERS

The Agency did not prepare and submit its Data Collection Form and Reporting Package for the year ended June 30, 2022 to the Federal Audit Clearinghouse by the due date of March 31, 2023. Criteria: Per §200.512 of the Uniform Guidance, Report Submission, the audit shall be completed and the Data Collection Form and Reporting Package shall be electronically transmitted within the earlier of thirty (30) days after receipt of the auditor’s reports, or nine (9) months after the end of the audit period. If the due date falls on a Saturday, Sunday, or federal holiday, the Data Collection Form and Reporting Package are due the next business day. The Uniform Guidance does not permit the recipient to extend the due date. Cause: Management did not submit their Data Collection Form and Reporting Package by the due date due to an OIG review of the June 30, 2022 year end. Management delayed their reporting due to the completion of the OIG review and key accounting/finance personnel turnover. Effect: The Agency’s Data Collection Form and Reporting Package for the year ended June 30, 2022 was not prepared and submitted to the Federal Audit Clearinghouse by the due date. Recommendation: We recommend that management during times of unexpected increase activity ensure that all appropriate controls are in place to allow timely completion of audit procedures as well as submission of Data Collection Form and Reporting Package to the Federal Audit Clearinghouse.

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Item 2022-002: Report Submission to the Federal Audit Clearinghouse (Other Matter Required to be Reported Under the Uniform Guidance) (Material Weakness) Condition: The Agency did not prepare and submit its Data Collection Form and Reporting Package for the year ended June 30, 2022 to the Federal Audit Clearinghouse by the due date of March 31, 2023. Criteria: Per §200.512 of the Uniform Guidance, Report Submission, the audit shall be completed and the Data Collection Form and Reporting Package shall be electronically transmitted within the earlier of thirty (30) days after receipt of the auditor’s reports, or nine (9) months after the end of the audit period. If the due date falls on a Saturday, Sunday, or federal holiday, the Data Collection Form and Reporting Package are due the next business day. The Uniform Guidance does not permit the recipient to extend the due date. Cause: Management did not submit their Data Collection Form and Reporting Package by the due date due to an OIG review of the June 30, 2022 year end. Management delayed their reporting due to the completion of the OIG review and key accounting/finance personnel turnover. Effect: The Agency’s Data Collection Form and Reporting Package for the year ended June 30, 2022 was not prepared and submitted to the Federal Audit Clearinghouse by the due date. Recommendation: We recommend that management during times of unexpected increase activity ensure that all appropriate controls are in place to allow timely completion of audit procedures as well as submission of Data Collection Form and Reporting Package to the Federal Audit Clearinghouse.

Corrective Action Plan

SCDEW was unable to successfully complete and submit this audit on time to submit it to the Federal Audit Clearinghouse by March 31, 2023. This occurred as the completion of the FY21 audit was delayed due to additional auditing program requirements requested by the DOL OIG. SCDEW fully understands the failure to submit audits on time could negatively impact our federal funds or termination of federal grants with DOL. We continuously communicate with the DOL on the status of this audit and other audits to keep them informed on our progress. SCDEW has missed the March 31st submission deadlines for the 2023 and 2024 agency financial audits. The agency has begun working on the 2023 agency audit and has done some work on the 2024 agency audit. SCDEW will miss the March 31st submission deadline for the 2025 agency financial audit as work on this audit has not commenced. Although these specific reporting deadlines have been missed, SCDEW constantly monitors and consistently adheres to agency wide reporting deadlines on the master reporting database. This is explained more in the paragraph below. The Agency’s contact person responsible for the corrective action plan is Jacquelyn Carlen, CFO. The completion date of the corrective action plan was August 28, 2025.

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2022-003
Reporting
MATERIAL WEAKNESSREPEAT OF 2021-002

The Agency did not submit certain quarterly reports to the United States Department of Labor (“National Office”) by the required due dates. Accordingly, the Agency did not comply with the Reporting compliance requirements related to the Unemployment Insurance program. Criteria: Per Part 4 of the OMB Compliance Supplement: The ETA 191 Report is required to be submitted on a quarterly basis to the National Office by the 25th day of the month following the close of the quarter. The ETA 2208A Report is required to be submitted on a quarterly basis to the National Office by the 45th day of the month following the close of the quarter. The ETA 2112 Report is required to be submitted on a monthly basis to the National Office by the first day of the second month following the close of the month of reference. The ETA 9052 Report is required to be submitted on a monthly basis to the National Office by the 30th day of the month following the month of reference. Cause: Internal controls are not in place to ensure that all required reports are being submitted in accordance with the United States Department of Labor’s timelines. The reports were delayed due to program and system resources focused on claims processing as well as personnel shortages. Effect: As a result, the Agency becomes more susceptible to having its level of federal award funding reduced by the United States Department of Labor when it violates its Reporting compliance requirements applicable to the Unemployment Insurance program. Context: We inspected a sample of quarterly reports and noted the following exceptions: Unemployment Insurance – One (1) ETA 191 quarterly report; Unemployment Insurance – Two (2) ETA 2208A quarterly reports; Unemployment Insurance – One (1) ETA 2112 monthly report; Unemployment Insurance – One (1) ETA 9052 monthly report. Recommendation: We recommend that management carefully review the terms and conditions included in the supporting grant agreements and the Reporting requirements included in the OMB Compliance Supplement applicable to the Unemployment Insurance and the Employment Services Cluster programs and implement controls to ensure that all reports are filed on a timely basis.

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Item 2022-003: Reporting (Material Weakness over Reporting and Non-Material Noncompliance) Condition: The Agency did not submit certain quarterly reports to the United States Department of Labor (“National Office”) by the required due dates. Accordingly, the Agency did not comply with the Reporting compliance requirements related to the Unemployment Insurance program. Criteria: Per Part 4 of the OMB Compliance Supplement: The ETA 191 Report is required to be submitted on a quarterly basis to the National Office by the 25th day of the month following the close of the quarter. The ETA 2208A Report is required to be submitted on a quarterly basis to the National Office by the 45th day of the month following the close of the quarter. The ETA 2112 Report is required to be submitted on a monthly basis to the National Office by the first day of the second month following the close of the month of reference. The ETA 9052 Report is required to be submitted on a monthly basis to the National Office by the 30th day of the month following the month of reference. Cause: Internal controls are not in place to ensure that all required reports are being submitted in accordance with the United States Department of Labor’s timelines. The reports were delayed due to program and system resources focused on claims processing as well as personnel shortages. Effect: As a result, the Agency becomes more susceptible to having its level of federal award funding reduced by the United States Department of Labor when it violates its Reporting compliance requirements applicable to the Unemployment Insurance program. Context: We inspected a sample of quarterly reports and noted the following exceptions: Unemployment Insurance – One (1) ETA 191 quarterly report; Unemployment Insurance – Two (2) ETA 2208A quarterly reports; Unemployment Insurance – One (1) ETA 2112 monthly report; Unemployment Insurance – One (1) ETA 9052 monthly report. Recommendation: We recommend that management carefully review the terms and conditions included in the supporting grant agreements and the Reporting requirements included in the OMB Compliance Supplement applicable to the Unemployment Insurance and the Employment Services Cluster programs and implement controls to ensure that all reports are filed on a timely basis.

Corrective Action Plan

SCDEW implemented a corrective action plan in response to this funding for the year ended June 30,2021, in response to similar findings in prior year audits. The SCDEW Enterprise and Project Management Office (EPMO) was originally tasked with monitoring agency wide reporting deadlines and was transferred to Executive Director’s Office. SCDEW continues to utilize the master reporting database developed by EPMO that includes relevant identifying information including report name, agency, SCDEW contact, reporting frequency and due dates. Individual reporters at SCDEW submit data to the Executive Director’s Office on the status of the required filings. The Executive Director’s Office routine reports the status of filings to executive leadership. The Agency’s contact person for the corrective action plan is Jacquelyn Carlen, CFO. The corrective action plan was implemented on June 20, 2021, and is ongoing.

Prior Finding References

2021-002

About Reporting →
2022-004
Eligibility
MATERIAL WEAKNESSMODIFIED OPINIONREPEAT OF 2021-004

The Department did not consistently perform timely annual eligibility reviews for Medicaid and CHIP recipients in accordance with Section 101.10 of the South Carolina Medicaid Policies and Procedures Manual. Questioned Costs: Unknown Context: We tested 120 individual recipients (60 each for Medicaid and CHIP) to ensure the Department complied with applicable eligibility requirements. We determined the Department did not comply with the annual review requirement for 42 Medicaid recipients and 58 CHIP recipients. Cause: Department personnel stated they did not comply with the annual review requirement for these recipients due to a backlog in case processing. Effect: In the absence of an annual review, Medicaid and CHIP recipients may continue to receive benefits without meeting eligibility requirements. Recommendation: We recommend eligibility reviews be performed annually in accordance with the South Carolina Medicaid Policies and Procedures Manual. Prior Year Single Audit Finding Number: 2021-004 Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 102.

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Federal Agency: Department of Health and Human Services Federal Program Title: Medicaid Cluster and Children?s Health Insurance Program (CHIP) Assistance Listings: 93.775, 93.777, 93.778, and 93.767 Federal Grant ID Numbers: 05-2105SC5MAP, 05-2205SC5MAP, 05-2105SC5ADM, 05-2205SC5ADM, 05-2105SC5021, and 05-2205SC5021 Pass-Through Entity: Not applicable Award Period: October 01, 2020, through September 30, 2023 Type of Finding: Material weakness in internal control over compliance, material noncompliance Criteria: Section 2.1 of the Department?s Title XIX (Medicaid) State Plan (Application, Determination of Eligibility and Furnishing Medicaid) affirms that it meets the requirements outlined in 42 CFR Part 435.916, which states in part, that the agency must promptly determine eligibility between regular renewals of eligibility. In addition, Section 101.10 of the South Carolina Medicaid Policies and Procedures Manual states that the Department must complete an annual review for certain payment categories. Furthermore, the Department?s Title XXI (CHIP) State Plan attests that CHIP will operate as a Medicaid expansion program. Therefore, the aforementioned regulation and policies apply to both programs. Condition: The Department did not consistently perform timely annual eligibility reviews for Medicaid and CHIP recipients in accordance with Section 101.10 of the South Carolina Medicaid Policies and Procedures Manual. Questioned Costs: Unknown Context: We tested 120 individual recipients (60 each for Medicaid and CHIP) to ensure the Department complied with applicable eligibility requirements. We determined the Department did not comply with the annual review requirement for 42 Medicaid recipients and 58 CHIP recipients. Cause: Department personnel stated they did not comply with the annual review requirement for these recipients due to a backlog in case processing. Effect: In the absence of an annual review, Medicaid and CHIP recipients may continue to receive benefits without meeting eligibility requirements. Recommendation: We recommend eligibility reviews be performed annually in accordance with the South Carolina Medicaid Policies and Procedures Manual. Prior Year Single Audit Finding Number: 2021-004 Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 102.

Corrective Action Plan

Department of Health & Human Services Centers for Medicare & Medicaid Services 31 Forsyth Street, SW, Room 4T20 Atlanta, Georgia 30303-8909 The South Carolina Department of Health and Human Services respectfully submits the following corrective action plan for the year ended June 30, 2022. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS ? FEDERAL AWARD PROGRAM AUDIT DEPARTMENT OF HEALTH AND HUMAN SERVICES 2022-004 Medicaid Cluster; Children?s Health Insurance Program (CHIP) ? Assistance Listing No. 93.775, 93.777, 93.778; 93.767 Recommendation: We recommend eligibility reviews be performed annually in accordance with the South Carolina Medicaid Policies and Procedures Manual. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The agency will resume standard review processing in April 2023 in response to requirements outlined in the Consolidated Appropriations Act 2023. The state has developed a comprehensive operational plan for completing this work including: ? Policy and procedure updates ? Hiring additional staff in response to attrition during the public health emergency (PHE) and staffing levels needed to complete the anticipated work ? Additional staff augmentation through a third party vendor to assist with specific data entry tasks associated with review processing ? Staff refresher training on eligibility review policies and procedures ? A comprehensive Communication Plan for sharing relevant information regarding unwinding activities with stakeholders such as beneficiaries, agency staff, call centers, providers, managed care plans and community organizations ? Outreach to inform beneficiaries about the review process and how to contact the agency with changes to contact information and questions they may have ? Distribution of reviews. The state has 12 months during the unwinding period to initiate reviews and 14 months to complete the work. ? Workload management plan to react to staffing needed for both application and review processing. Name(s) of the contact person(s) responsible for corrective action: Lori Risk Planned completion date for corrective action plan: June 2024 (End of Unwinding Period)

Prior Finding References

2021-004

About Eligibility →
2022-005
Eligibility
SIGNIFICANT DEFICIENCYREPEAT OF 2021-005OTHER MATTERS

Eligibility files did not contain adequate documentation to support the Medicaid and CHIP recipient eligibility status. Questioned Costs: Unknown Context: We tested 120 individual recipients (60 each for Medicaid and CHIP) to ensure the Department complied with applicable eligibility requirements. We determined the Department did not maintain adequate documentation of eligibility for 3 Medicaid recipients and 3 CHIP recipients. Cause: According to Department personnel, some documentation was not scanned into the electronic case files and maintained in accordance with its State plan. Effect: The Department could not support eligibility determinations in accordance with its State plan. Recommendation: We recommend the Department strengthen controls over eligibility determinations to ensure documentation is maintained and reviewed in accordance with its State plan and federal regulations. Prior Year Single Audit Finding Number: 2021-005 Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 103.

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Federal Agency: Department of Health and Human Services Federal Program Title: Medicaid Cluster and Children?s Health Insurance Program (CHIP) Assistance Listings: 93.775, 93.777, 93.778, and 93.767 Federal Grant ID Numbers: 05-2205SC5MAP, 05-2205SC5ADM, 05-2105SC5021, and 05-2205SC5021 Pass-Through Entity: Not applicable Award Period: October 01, 2020, through September 30, 2023 Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: Per 42 CFR 435.914 (a), the agency must include in each applicant?s case record facts to support the agency?s decision on his or her application. In addition, Section 4.7 of the Department?s Title XIX (Medicaid) State Plan (Maintenance of Records) affirms that it meets the requirements outlined in 42 CFR 431.17 (b), that a State plan must provide that the Medicaid agency will maintain or supervise the maintenance of records necessary for the proper and efficient operation of the plan. Furthermore, the Department?s Title XXI (CHIP) State Plan attests that CHIP will operate as a Medicaid expansion program. Therefore, the aforementioned regulations apply to both programs. Condition: Eligibility files did not contain adequate documentation to support the Medicaid and CHIP recipient eligibility status. Questioned Costs: Unknown Context: We tested 120 individual recipients (60 each for Medicaid and CHIP) to ensure the Department complied with applicable eligibility requirements. We determined the Department did not maintain adequate documentation of eligibility for 3 Medicaid recipients and 3 CHIP recipients. Cause: According to Department personnel, some documentation was not scanned into the electronic case files and maintained in accordance with its State plan. Effect: The Department could not support eligibility determinations in accordance with its State plan. Recommendation: We recommend the Department strengthen controls over eligibility determinations to ensure documentation is maintained and reviewed in accordance with its State plan and federal regulations. Prior Year Single Audit Finding Number: 2021-005 Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 103.

Corrective Action Plan

Department of Health & Human Services Centers for Medicare & Medicaid Services 31 Forsyth Street, SW, Room 4T20 Atlanta, Georgia 30303-8909 The South Carolina Department of Health and Human Services respectfully submits the following corrective action plan for the year ended June 30, 2022. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS ? FEDERAL AWARD PROGRAM AUDIT DEPARTMENT OF HEALTH AND HUMAN SERVICES 2022-005 Medicaid Cluster; Children?s Health Insurance Program (CHIP) ? Assistance Listing No. 93.775, 93.777, 93.778; 93.767 Recommendation: We recommend the Department strengthen controls over eligibility determinations to ensure documentation is maintained and reviewed in accordance with its State plan and federal regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The agency continues to implement an Eligibility Performance and Remediation process, which includes internal Eligibility Quality Assurance (EQA) monthly case reviews, as well as third party case reviews conducted by the University of South Carolina Core for Applied Research and Evaluation (USC CARE). Eligibility Policies and Procedures provide instructions for a worker to ensure the case file is complete for all eligibility criteria based on policy, prior to making a determination. The policy is included in staff training and is evaluated as part of quality assurance activities. Supervisors are responsible for monitoring staff daily by using data available via system of record, the electronic document management system (OnBase), workload management software, as well as through case spot reviews. Supervisors meet monthly with each staff member to review Eligibility Quality Assurance (EQA) findings to identify and address issues that impact performance, as well as to facilitate corrections to incorrect determinations identified through the EQA process. Errors are identified via error codes and descriptions. EQA reviews are conducted and housed in a state-developed tool to allow for creation of reports that can be generated based on supervisor, worker, work type, error code or overall accuracy. The state compares errors identified through audits and federal reviews such as payment error rate measurement with internal and third party EQA error trends and use this monitoring method to identify trends, develop mitigation strategies and to determine impact of those strategies on these errors. During the 4th quarter of calendar year 2022, 15,716 cases were reviewed by EQA with the following results pertaining to missing documentation: Error Description, Q1 CY2022 % Cases Reviewed, Q2 CY2022 % Cases Reviewed, Q3 CY2022 % Cases Reviewed, Q4 CY2022 % Cases Reviewed: The application was not signed, 0.03%, 0.01%, 0.02%, 0.30%; The application could not be located in the case file, 0.02%, 0.03%, 0.01%, 0.03%; Level of care was not in the case file or in Phoenix, 0.02%, 0.01%, 0.01%, 0.01%; The case record was missing SSN or proof of application for SSN, 0.25% 0.36%, 0.26%, 0.00%; In response to these findings, the Eligibility department will conduct email and face-to-face communication with managers, supervisors and staff regarding these findings and a reminder of documentation requirements in policy, as well as to ensure supervisors are assessing for this requirement in casefile spot checks. This will also be discussed on an upcoming Eligibility Supervisor call and shared in the Eligibility, Enrollment, and Member Services Newsletter. These requirements will also continue to be emphasized in new worker and staff refresher training. Name(s) of the contact person(s) responsible for corrective action: Lori Risk Planned completion date for corrective action plan: Email, face-to-face and newsletter communications: June 2023; EQA Procedures, staff training ? Ongoing.

Prior Finding References

2021-005

About Eligibility →
2022-006
Reporting
SIGNIFICANT DEFICIENCYOTHER MATTERS

FFATA reporting and timing errors were identified. Questioned Costs: None Context: Fourteen subawards were selected for testing and the following compliance errors were identified during the testing: ? The reported subaward obligation/action date did not agree to the subaward agreement date for one of the subawards tested. ? For seven of the subawards tested, the action was not reported in the FSRS by the last day of the month following the month that the subaward was made. ? The FSRS could not be accessed for four of the subawards in order to test reporting compliance for that subaward. Cause: Data entry errors and administrative delays led to the compliance errors identified in the testing. Effect: The Office was not in compliance with FFATA reporting requirements. Recommendation: We recommend the Office update their current internal control to include continuous monitoring and reviewing of project obligations to ensure that reports are submitted in compliance with FFATA reporting requirements. Prior Year Single Audit Finding Number: Not applicable Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 105.

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Federal Agency: Department of Homeland Security Federal Program Title: Disaster Grants ? Public Assistance (Presidentially Declared Disasters) Assistance Listing: 97.036 Federal Grant ID Numbers: Various Pass-Through Entity: Not applicable Award Period: Various Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: 2 CFR 170 Appendix A requires that recipients of grants or cooperative agreements report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act (FFATA) Subaward Reporting System (FSRS) no later than the end of the month following the month in which the obligation was made. Condition: FFATA reporting and timing errors were identified. Questioned Costs: None Context: Fourteen subawards were selected for testing and the following compliance errors were identified during the testing: ? The reported subaward obligation/action date did not agree to the subaward agreement date for one of the subawards tested. ? For seven of the subawards tested, the action was not reported in the FSRS by the last day of the month following the month that the subaward was made. ? The FSRS could not be accessed for four of the subawards in order to test reporting compliance for that subaward. Cause: Data entry errors and administrative delays led to the compliance errors identified in the testing. Effect: The Office was not in compliance with FFATA reporting requirements. Recommendation: We recommend the Office update their current internal control to include continuous monitoring and reviewing of project obligations to ensure that reports are submitted in compliance with FFATA reporting requirements. Prior Year Single Audit Finding Number: Not applicable Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 105.

Corrective Action Plan

The South Carolina Adjutant General?s Office respectfully submits the following Corrective Action Plan for the year ended June 30, 2022. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the number assigned in the schedule. FINDINGS ? FEDERAL AWARD PROGRAM AUDIT United States Department of Homeland Security 2022-006 Public Assistance (Presidentially Declared Disasters) - Assistance Listing No. 97.036 Recommendation: We recommend the Office update their current internal control to include continuous monitoring and reviewing of project obligations to ensure that reports are submitted in compliance with FFATA reporting requirements. Explanation of disagreement with audit finding: The Office concurs with the audit finding. Action taken in response to finding: A. The Public Assistance team has updated the project version workflow in SCEMD?s South Carolina Recovery Grants (SCRecoveryGrants.org; known as SCRG) system to make sure the obligation information is received timely by the Finance and Administration team. The Fiscal Analyst responsible for reporting is now notified via SCRG automated email when a new obligation is made and when an existing obligation is modified. B. The Finance and Administration team began pulling records for FFATA reporting by obligation date instead of pulling records of reimbursements processed in April 2022 in response to a finding in a different Federal Grant program. This corrective action was implemented in all our Federal Grant Programs. FFATA reporting after May 2022 has been reported by the last day of the month following the month that the subaward was made for awards greater than $30,000. C. The Finance and Administration team will continue to save a pdf record of the monthly FFATA reports made. D. The Finance and Administration Team and the Fiscal Analyst responsible for reporting will continue to make efforts to update reporting that was not reported prior to April 2022. We will complete additional reviews of required FFATA reporting through June 30, 2023. Names of the contact persons responsible for correction action: Ms. Jessica Jones, State Public Assistance Officer; Ms. Brittany Hammond, Chief of Finance and Administration Planned completion date for corrective action plan: June 30, 2023

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2022-007
Activities Allowed or Unallowed / Cost Allowability
SIGNIFICANT DEFICIENCY

Personnel expenditures for three employees were charged to the federal award without documented approval as required by the Office?s internal control procedure. Questioned Costs: None Context: Three of forty payroll transactions tested did not have a corresponding approved State Personnel Action form that documented each employee?s salary and the percentage of their salary covered by the grant program. Cause: Management did not document approval of payroll changes for grant employees to avoid errors in payroll processing. Effect: The Office could incorrectly charge the federal award for personnel costs. Recommendation: We recommend the Office consistently adhere to its internal controls including maintaining the approved State Personnel Action form to support the personnel charges and allocations to applicable funding sources. Prior Year Single Audit Finding Number: Not applicable. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 106.

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Federal Agency: Department of Defense Federal Program Title: National Guard Military Operations and Maintenance (O&M) Projects Assistance Listing: 12.401 Federal Grant ID Numbers: Various Pass-Through Entity: Not applicable Award Period: Various Type of Finding: Significant deficiency in internal control Criteria: 2 CFR ? 200.303 states that the 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. Condition: Personnel expenditures for three employees were charged to the federal award without documented approval as required by the Office?s internal control procedure. Questioned Costs: None Context: Three of forty payroll transactions tested did not have a corresponding approved State Personnel Action form that documented each employee?s salary and the percentage of their salary covered by the grant program. Cause: Management did not document approval of payroll changes for grant employees to avoid errors in payroll processing. Effect: The Office could incorrectly charge the federal award for personnel costs. Recommendation: We recommend the Office consistently adhere to its internal controls including maintaining the approved State Personnel Action form to support the personnel charges and allocations to applicable funding sources. Prior Year Single Audit Finding Number: Not applicable. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 106.

Corrective Action Plan

The South Carolina Adjutant General?s Office respectfully submits the following Corrective Action Plan for the year ended June 30, 2022. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the number assigned in the schedule. FINDINGS ? FEDERAL AWARD PROGRAM AUDIT United States Department of Defense 2022-007 National Guard Military Operations and Maintenance (O&M) Projects Assistance Listing No. 12.401 Recommendation: We recommend the Office consistently adhere to its internal controls including maintaining the approved State Personnel Action form to support the personnel charges and allocations to applicable funding sources. Explanation of disagreement with audit finding: The Office concurs with the audit finding. Action taken in response to finding: A. The missing forms in the personnel files identified in the audit were corrected. Completed as of March 03, 2023. B. The Office is conducting a complete audit of all personnel files to ensure internal control were implemented and files are accurately and adequately documented. The estimated date of completion is March 31, 2023. C. The Office will ensure that established policies and procedures are followed, and all documentation is completed prior to entering actions into SCEIS. Name of the contact person responsible for correction action: Mr. Robert Faulk, State Human Resources Director Planned completion date for corrective action plan: March 31, 2023

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2022-008
Reporting
SIGNIFICANT DEFICIENCY

Supervisory personnel did not review certain reports prior to submission. Questioned Costs: None Context: We tested the Department?s Consolidated Annual Performance and Evaluation Report (CAPER), which includes the annual Section 3 report, and five Federal Funding Accountability and Transparency Act (FFATA) reports submitted by the Department. None of the FFATA reports were reviewed by supervisory personnel prior to submission. Cause: Department controls failed to ensure that supervisory personnel reviewed the reports prior to submission. Effect: Without supervisory review, there is an increased risk of inaccurate reporting. Recommendation: We recommend that Department personnel consistently follow policies in place to ensure reports are properly reviewed by supervisory personnel prior to submission. Prior Year Single Audit Finding Number: Not applicable Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 108.

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Federal Agency: Department of Housing and Urban Development Federal Program Title: Community Development Block Grant Assistance Listing: 14.228 Federal Grant ID Numbers: B20DW450001, B21DC450001, B20DC450001, B19DC450001, and B18DC450001 Pass-Through Entity: Not applicable Award Period: July 24, 2018, through September 1, 2028 Type of Finding: Significant deficiency in internal control over compliance Criteria: Per 2 CFR ? 200.303, the 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 be in compliance with guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States and the "Internal Control Integrated Framework", issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: Supervisory personnel did not review certain reports prior to submission. Questioned Costs: None Context: We tested the Department?s Consolidated Annual Performance and Evaluation Report (CAPER), which includes the annual Section 3 report, and five Federal Funding Accountability and Transparency Act (FFATA) reports submitted by the Department. None of the FFATA reports were reviewed by supervisory personnel prior to submission. Cause: Department controls failed to ensure that supervisory personnel reviewed the reports prior to submission. Effect: Without supervisory review, there is an increased risk of inaccurate reporting. Recommendation: We recommend that Department personnel consistently follow policies in place to ensure reports are properly reviewed by supervisory personnel prior to submission. Prior Year Single Audit Finding Number: Not applicable Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 108.

Corrective Action Plan

The South Carolina Department of Commerce respectfully submits the following corrective action plan for the year ended June 30, 2022. The finding from the schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. FINDINGS ? FEDERAL AWARD PROGRAM AUDIT U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT 2022-008 Community Development Block Grant (CDBG) ? Assistance Listing No. 14.228 Recommendation: We recommend that Department personnel consistently follow policies in place to ensure reports are properly reviewed by supervisory personnel prior to submission. Explanation of disagreement with audit finding: The South Carolina Department of Commerce agrees with the audit finding. Action taken in response to finding: All reports and documents to be submitted on behalf of the State?s Community Development Block Grant Program to the U.S. Department of Housing, Urban and Development (HUD), U.S. Department of Labor and FSRS.gov will follow a formal review process to include using track changes for documents and a final review by a CDBG staff member in a supervisory position. The designee for the final review will be the Deputy Director of Community Development or the CDBG Program Administrator. An acknowledgement of the final review will be documented to ensure the appropriate review has taken place. Name(s) of the contact person(s) responsible for corrective action: Caroline Griffin ? Deputy Director for Community Development Keely McMahan ? CDBG Program Administrator Planned completion date for corrective action plan: As of March 1, 2023, CDBG program management has adopted this corrective action plan to ensure a comprehensive review of reports by supervisory personnel prior to submission to the appropriate Federal agency.

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2022-009
Reporting
SIGNIFICANT DEFICIENCYOTHER MATTERS

We determined expenditure transactions were incorrectly classified in the general ledger. Questioned Costs: None Context: For two of twenty-two transactions tested, the Office classified subrecipient payments as contractual services. Cause: Office controls failed to ensure transactions were recorded properly in the general ledger. Effect: Subrecipient expenditures of $51,853 were omitted from the Office?s Schedule of Federal Awards (SEFA). Recommendation: We recommend that the Office ensure staff preparing and entering transactions into the accounting system have a good working knowledge of account codes as defined by the South Carolina Comptroller General?s Office (CG). In addition, supervisory personnel should closely review transactions to ensure proper classification in the general ledger. Further, the Office should seek guidance from the CG if questions regarding coding of transactions arises. Prior Year Single Audit Finding Number: Not applicable Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 109.

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Federal Agency: Department of Housing and Urban Development Federal Program Title: Community Development Block Grant Assistance Listing: 14.228 Federal Grant ID Number: B-18-DP-06-0002 Pass-Through Entity: Not applicable Award Period: August 20, 2020, through November 19, 2032 Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: 2 CFR ? 200.303 requires effective internal controls be established and maintained in order to provide reasonable assurance that the federal award is being managed in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: We determined expenditure transactions were incorrectly classified in the general ledger. Questioned Costs: None Context: For two of twenty-two transactions tested, the Office classified subrecipient payments as contractual services. Cause: Office controls failed to ensure transactions were recorded properly in the general ledger. Effect: Subrecipient expenditures of $51,853 were omitted from the Office?s Schedule of Federal Awards (SEFA). Recommendation: We recommend that the Office ensure staff preparing and entering transactions into the accounting system have a good working knowledge of account codes as defined by the South Carolina Comptroller General?s Office (CG). In addition, supervisory personnel should closely review transactions to ensure proper classification in the general ledger. Further, the Office should seek guidance from the CG if questions regarding coding of transactions arises. Prior Year Single Audit Finding Number: Not applicable Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 109.

Corrective Action Plan

The South Carolina Office of Resilience (SCOR) respectfully submits the following corrective action plan for the year ended June 30, 2022. The finding from the schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. FINDINGS - FEDERAL AWARD PROGRAM AUDIT U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT 2022-009 Community Development Block Grant - Assistance Listing No. 14.228 Recommendation: We recommend that the Office ensure staff preparing and entering transactions into the accounting system have a good working knowledge of account codes as defined by the South Carolina Comptroller General's Office (CG). In addition, supervisory personnel should closely review transactions to ensure proper classification in the general ledger. Further, the Office should seek guidance from the CG if questions regarding coding of transactions arises. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: SCOR has developed and implemented the use of a Purchase Order Cover Sheet (POCS) (See example #1) to better identify subrecipient projects/vendors requiring the correct use 517 General Ledger Categories. The POCS is a check list of all required information needed to create a shopping cart / purchase order. A recent POCS form update added a field that requires the requester to identify the Project Management team, either State or Subrecipient. This selection will determine the General Ledger Category used by Finance. Since this issue was identified, SCOR Finance has completed a review of FY23 general ledger coding and will post corrective journal entries prior to year end to ensure compliance in future audits. Name(s) of the contact person(s) responsible for corrective action: Andrew DeRienzo, SCOR Finance Director Planned completion date for corrective action plan: June 30, 2023

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2022-010
Reporting
SIGNIFICANT DEFICIENCYOTHER MATTERS

We identified noncompliance with FFATA reporting requirements. Questioned Costs: None Context: The Office did not submit FFATA reports although it had subawards of $30,000 or more. Cause: Office personnel were unaware of FFATA reporting requirements. Effect: The Office was not in compliance with FFATA reporting requirements. Recommendation: We recommend that the Office implement procedures to ensure reports are submitted in compliance with FFATA reporting requirements. Prior Year Single Audit Finding Number: Not applicable Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 111.

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Federal Agency: Department of Housing and Urban Development Federal Program Title: Community Development Block Grant Assistance Listing: 14.228 Federal Grant ID Numbers: P-19-SC-45-0DD2 and P-18-SC-45-MIT1 Pass-Through Entity: Not applicable Award Period: December 14, 2020, through August 19, 2032 Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: 2 CFR 170 Appendix A requires that recipients of grants or cooperative agreements report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act (FFATA) Subaward Reporting System (FSRS). Condition: We identified noncompliance with FFATA reporting requirements. Questioned Costs: None Context: The Office did not submit FFATA reports although it had subawards of $30,000 or more. Cause: Office personnel were unaware of FFATA reporting requirements. Effect: The Office was not in compliance with FFATA reporting requirements. Recommendation: We recommend that the Office implement procedures to ensure reports are submitted in compliance with FFATA reporting requirements. Prior Year Single Audit Finding Number: Not applicable Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 111.

Corrective Action Plan

The South Carolina Office of Resilience (SCOR) respectfully submits the following corrective action plan for the year ended June 30, 2022. The finding from the schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. FINDINGS - FEDERAL AWARD PROGRAM AUDIT U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT 2022-010 Community Development Block Grant - Assistance Listing No. 14.228 Recommendation: We recommend that the Office implement procedures to ensure reports are submitted in compliance with FFATA reporting requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: SCOR has already designated an employee (SCOR Reporting Manager) to gain knowledge of FFATA and become the FFATA Reporting point of contact. SCOR is currently unable to report grants in the FFATA Subaward Reporting System (FSRS) because FSRS identifies the 2018 CDBG-DR and CDBG-MIT grants reporting entity under a different state agency. Because the information within FSRS is based off data entries within SAM.GOV, only HUD, as the Federal entity that issued the grant, can make changes within the system. SCOR is working with its assigned representative at HUD to identify and make the appropriate changes in SAM.GOV and FSRS. Once SCOR has control of the two grants in FSRS, SCOR will retroactively report on all subrecipient subawards in the CDBG-MIT program. In the future, SCOR will also report in FSRS any other subrecipient awards for CDBG-DR and CDBG-MIT. Name(s) of the contact person(s) responsible for corrective action: Ran Reinhard, Director of Operations Planned completion date for corrective action plan: June 30, 2023

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2022-011
Special Tests & Provisions
SIGNIFICANT DEFICIENCYOTHER MATTERS

The Department did not consistently perform reviews of compliance visits of vaccine providers in accordance with its policy. Questioned Costs: None Context: We tested 37 compliance visits of providers to ensure the Department complied with applicable Special Tests and Provisions requirements. We determined the Department had not reviewed four of the compliance visits as of the end of our fieldwork. Cause: Due to the prioritization of annual VFC and other vaccine program enrollments, the Department was unable to review the site visits for these providers. Effect: In the absence of a compliance visit review, providers could have unresolved issues that could affect the quality and quantity of vaccines provided to VFC recipients. Recommendation: We recommend the Department ensure compliance visits are reviewed in accordance with Department policy. Prior Year Single Audit Finding Number: Not applicable Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 112.

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Federal Agency: Department of Health and Human Services Federal Program Title: Immunization Cooperative Agreements Assistance Listing: 93.268 Federal Grant ID Numbers: 5 NH23IP922601-03-00, 1 N23IP922601-01-00, and 6 NH23IP922601-02-00 Pass-Through Entity: Not applicable Award Period: October 01, 2019, through September 30, 2024 Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: The Office of Management and Budget?s (OMB) 2022 Compliance Supplement states that effective control and accountability must be maintained for all vaccines under the Vaccines for Children (VFC) program. Vaccines must be adequately safeguarded and used solely for authorized purposes in accordance with guidance set forth in 42 USC 1396s. To comply with this requirement, the Department?s Vaccines for Children Operation Guide requires that all completed VFC compliance site visits be reviewed by the VFC coordinator, immunization program manager, or a designee. Condition: The Department did not consistently perform reviews of compliance visits of vaccine providers in accordance with its policy. Questioned Costs: None Context: We tested 37 compliance visits of providers to ensure the Department complied with applicable Special Tests and Provisions requirements. We determined the Department had not reviewed four of the compliance visits as of the end of our fieldwork. Cause: Due to the prioritization of annual VFC and other vaccine program enrollments, the Department was unable to review the site visits for these providers. Effect: In the absence of a compliance visit review, providers could have unresolved issues that could affect the quality and quantity of vaccines provided to VFC recipients. Recommendation: We recommend the Department ensure compliance visits are reviewed in accordance with Department policy. Prior Year Single Audit Finding Number: Not applicable Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 112.

Corrective Action Plan

US Department of Health and Human Services The South Carolina Department of Health and Environmental Control respectfully submits the following corrective action plan for the year ended 6/30/22. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS?FEDERAL AWARD PROGRAM AUDIT U.S. DEPARTMENT OF Health and Human Services 2022-011 Immunization Cooperative Agreements ? Assistance Listing No. 93.268 Recommendation: We recommend the Department ensure compliance visits are reviewed in accordance with Department policy. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: To strengthen internal controls, the Department has discussed the finding with staff and stressed the importance of ensuring Centers for Disease Control guidelines are followed. Each person assigned to a site visit will complete the task within a six month signoff time frame. The Vaccines for Children Operations Director will ensure that the regions are up to speed and responsive to complete these tasks within the required timeframe. In addition, the corrective action plan will be communicated to staff at the next in-person regional meeting. Name(s) of the contact person(s) responsible for corrective action: Kim Paradeses Planned completion date for corrective action plan: June 30, 2023

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2022-012
Cash Management
SIGNIFICANT DEFICIENCYOTHER MATTERS

Supporting documentation was not adequate to determine if federal reimbursements were properly reviewed and approved by a supervisor prior to requesting a drawdown as required by the Department?s policies and procedures. Questioned Costs: None Context: For two of five Adoption Assistance drawdowns and one of the five Child and Adult Care Food Program drawdowns selected for testing, supporting documentation was not adequate to demonstrate proper review and approval by a supervisor prior to the federal reimbursement request. Cause: The Department failed to retain documentation demonstrating performance of a supervisory review and approval. Effect: The Department may request improper drawdowns due to a lack of proper approval. Recommendation: We recommend that the Department follow their policies and procedures to ensure that proper documentation is maintained to support the review and approval of a drawdown of funds. Prior Year Single Audit Finding Number: Not applicable Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 113.

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Federal Agency: Department of Health and Human Services and Department of Agriculture Federal Program Titles: Adoption Assistance and Child and Adult Care Food Program Assistance Listings: 93.659 and 10.558 Federal Grant ID Numbers: 2001SCADPT, 2101SCADPT, and 5SC300329 Pass-Through Entity: Not applicable Award Period: October 1, 2019, through September 30, 2021 Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: 2 CFR ? 200.303 requires that the non-federal entity establish and maintain effective internal controls over the federal award that provide 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. Condition: Supporting documentation was not adequate to determine if federal reimbursements were properly reviewed and approved by a supervisor prior to requesting a drawdown as required by the Department?s policies and procedures. Questioned Costs: None Context: For two of five Adoption Assistance drawdowns and one of the five Child and Adult Care Food Program drawdowns selected for testing, supporting documentation was not adequate to demonstrate proper review and approval by a supervisor prior to the federal reimbursement request. Cause: The Department failed to retain documentation demonstrating performance of a supervisory review and approval. Effect: The Department may request improper drawdowns due to a lack of proper approval. Recommendation: We recommend that the Department follow their policies and procedures to ensure that proper documentation is maintained to support the review and approval of a drawdown of funds. Prior Year Single Audit Finding Number: Not applicable Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 113.

Corrective Action Plan

The South Carolina Department of Social Services respectfully submits the following corrective action plan for the year ended June 30, 2022. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS?FEDERAL AWARD PROGRAM AUDIT U. S. Department of Health and Human Services 2022 ? 012 Adoption Assistance, Child and Adult Care Food Program ? Assistance Listing: 93.659, 10.558 Recommendation: We recommend that the Department follow their policies and procedures to ensure that proper documentation is maintained to support the review and approval of a drawdown of funds. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Department?s Grants Accounting and Reporting staff are following the established policies and procedures to ensure proper documentation is maintained to support the review and approval of draws prior to their execution. In every case the exceptions noted were draws that were done following group discussions that included the Department?s regional federal grant program representatives. Discussions were had to confirm the appropriate support and amounts of draws, and the conclusions of those discussions were that the Department should draw the amounts ultimately drawn. The Grants Accounting and Reporting Manager did approve the draws in advance but did not provide specific written approval. In one case the Grants Accounting Reporting Manager emailed the Department?s federal contact confirming the amount of funds we would draw, and the staff interpreted the email as authorization to proceed. Grants Accounting and Reporting staff have been instructed not to draw funds without express written approval, and they are complying with that requirement. Name(s) of the contact person(s) responsible for corrective action: Reshma Parikh, Grants Accounting and Reporting Manager Planned completion date for corrective action plan: Effective immediately

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2022-013
Subrecipient Monitoring
SIGNIFICANT DEFICIENCYOTHER MATTERS

The Department did not perform its subrecipient monitoring reviews in accordance with its policies and procedures and federal regulations. Questioned Costs: None Context: For fourteen of the sixty subrecipients tested, subrecipient monitoring reviews were not conducted within the three-year timeframe as set out in federal regulations. Cause: Due to staffing turnover, the Department did not comply with federal subrecipient monitoring requirements. Effect: The Department is not in compliance with federal requirements related to subrecipient monitoring requirements. Recommendation: We recommend that the Department follow its established policies and procedures for the program to ensure compliance with federal subrecipient monitoring requirements. Prior Year Single Audit Finding Number: Not applicable Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 114.

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Federal Agency: Department of Agriculture Federal Program Title: Child and Adult Care Food Program Assistance Listing: 10.558 Federal Grant ID Numbers: 5SC300329 and 5SC308329 Pass-Through Entity: Not applicable Award Period: October 1, 2019, through September 30, 2022 Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: 2 CFR ? 200.332(d) requires that all pass-through entities monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Additionally, 7 CFR ? 226.6(m)(6) outlines the frequency and number of required institution reviews. Condition: The Department did not perform its subrecipient monitoring reviews in accordance with its policies and procedures and federal regulations. Questioned Costs: None Context: For fourteen of the sixty subrecipients tested, subrecipient monitoring reviews were not conducted within the three-year timeframe as set out in federal regulations. Cause: Due to staffing turnover, the Department did not comply with federal subrecipient monitoring requirements. Effect: The Department is not in compliance with federal requirements related to subrecipient monitoring requirements. Recommendation: We recommend that the Department follow its established policies and procedures for the program to ensure compliance with federal subrecipient monitoring requirements. Prior Year Single Audit Finding Number: Not applicable Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 114.

Corrective Action Plan

The South Carolina Department of Social Services respectfully submits the following corrective action plan for the year ended June 30, 2022. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS?FEDERAL AWARD PROGRAM AUDIT U. S. Department of Agriculture 2022-013 Child and Adult Care Food Program ? Assistance Listing: 10.558 Recommendation: We recommend that the Department follow its established policies and procedures for the program to ensure compliance with federal subrecipient monitoring requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The three-year time frame in which these monitoring reviews were to have occurred included the peak months of the Coronavirus pandemic, when Department staff were working remotely for an extended period and many provider facilities were closed or operating sporadically due to staffing shortages. A significant number of program staff also left the agency during that time. These factors made timely monitoring much more difficult and extended the time required to complete it. The program maintains a worksheet designed to track compliance with this monitoring requirement and reviews, updates and acts upon it monthly. All monitoring reviews are now being conducted within the required time-frame. DSS also has an active project in progress to automate its compliance monitoring processes, and management plans to include a dashboard that displays the detailed status of each provider?s review, from start to completion. It will also report statistics showing the progress toward meeting the required yearly reviews. Management expects to have these system controls in place by December 2023. In the meantime, program staff will maintain the manual monitoring controls now in place to assure compliance. Name(s) of the contact person(s) responsible for corrective action: Mary Abney-Young, Early Care and Education Program Manager Planned completion date for corrective action plan: December 31, 2023

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2022-014
Eligibility
SIGNIFICANT DEFICIENCYOTHER MATTERS

Documentation was not adequate to verify that applicants were notified in writing of approval or disapproval by the Department within 30 days of receiving a completed application. Questioned Costs: None Context: For eleven of sixty institutions tested, we could not verify if the Department sent an approval or disapproval notification within 30 days of receiving the completed applications. Cause: The Department?s internal controls failed to ensure timely notifications to applicants according to federal regulations. Effect: We could not confirm compliance with federal regulations requiring written notifications of application approval or disapproval within 30 days of receiving a completed application. Recommendation: We recommend that the Department review its internal controls to ensure timely notifications of application approvals and disapprovals. Prior Year Single Audit Finding Number: Not applicable Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 115.

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Federal Agency: Department of Agriculture Federal Program Title: Child and Adult Care Food Program Assistance Listing: 10.558 Federal Grant ID Numbers: 5SC300329 and 5SC308329 Pass-Through Entity: Not applicable Award Period: October 1, 2019, through September 30, 2022 Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: 7 CFR ? 226.6(b)(3) requires that any new or renewing institution applying for participation in the Program be notified in writing of approval or disapproval by the State agency within 30 calendar days of the State agency's receipt of a completed application. Whenever possible, State agencies should provide assistance to institutions that have submitted an incomplete application. Any disapproved applicant institution or family day care home must be notified of the reasons for its disapproval and its right to appeal under paragraph (k) or (l), respectively, of this section. Condition: Documentation was not adequate to verify that applicants were notified in writing of approval or disapproval by the Department within 30 days of receiving a completed application. Questioned Costs: None Context: For eleven of sixty institutions tested, we could not verify if the Department sent an approval or disapproval notification within 30 days of receiving the completed applications. Cause: The Department?s internal controls failed to ensure timely notifications to applicants according to federal regulations. Effect: We could not confirm compliance with federal regulations requiring written notifications of application approval or disapproval within 30 days of receiving a completed application. Recommendation: We recommend that the Department review its internal controls to ensure timely notifications of application approvals and disapprovals. Prior Year Single Audit Finding Number: Not applicable Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 115.

Corrective Action Plan

The South Carolina Department of Social Services respectfully submits the following corrective action plan for the year ended June 30, 2022. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS?FEDERAL AWARD PROGRAM AUDIT U. S. Department of Agriculture 2022-014 Child and Adult Care Food Program ? Assistance Listing: 10.558 Recommendation: We recommend that the Department review its internal controls to ensure timely notifications of application approvals and disapprovals. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management agrees with the finding. The Department has sound controls in place for tracking notification compliance. These normally function well to assure that all application decisions are made and communicated timely. During the period in which these exceptions occurred, the program manager was away from work for an extended time. Also, during that time two experienced program staff left the Department. The remaining program staff were then temporarily unable to keep up with the volume of required application reviews, determinations and notifications. In the future, if these situations arise additional resources will be directed to keeping up with the timely processing of application reviews and notifications. In addition, program management has requested that Information Systems staff add to the system dashboard metrics a field displaying pending file approval dates. This will further assure that all upcoming deadlines are met. Management expects these dashboard enhancements to be completed by May 31, 2023. Name(s) of the contact person(s) responsible for corrective action: Mary Abney-Young, Early Care and Education Program Manager Planned completion date for corrective action plan: May 31, 2023

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2022-015
Procurement & Suspension/Debarment
SIGNIFICANT DEFICIENCYOTHER MATTERS

Compliance with suspension and debarment regulations could not be confirmed for one subrecipient. Questioned Costs: None Context: The Department verifies suspension and debarment through a certification clause embedded in the subrecipient contract. For one of sixty subrecipients tested, the Department was unable to locate the subrecipient's signed contract agreement. Cause: The Department could not locate the subrecipient's signed contract agreement containing the suspension and debarment certification clause. Effect: The Department's compliance with federal suspension and debarment requirements could not be confirmed. Recommendation: We recommend that the Department review and update its internal controls to ensure a signed contract agreement containing suspension and debarment terms and conditions is on file for all subrecipients. Prior Year Single Audit Finding Number: Not applicable Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 115.

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Federal Agency: Department of Agriculture Federal Program Title: Child and Adult Care Food Program Assistance Listing: 10.558 Federal Grant ID Numbers: 5SC300329 and 5SC308329 Pass-Through Entity: Not applicable Award Period: October 1, 2019, through September 30, 2022 Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: 2 CFR ? 180.300 requires that when a non-federal entity enters into a covered transaction (contracts for goods and services that are expected to equal or exceed $25,000, as well as all subawards to subrecipients, irrespective of award amount) with an entity at a lower tier, the non-Federal entity must verify that the entity is not suspended or debarred or otherwise excluded from participating in the transaction. The regulation lists several permitted methods for verification, including the collection of a certification from subrecipients. Condition: Compliance with suspension and debarment regulations could not be confirmed for one subrecipient. Questioned Costs: None Context: The Department verifies suspension and debarment through a certification clause embedded in the subrecipient contract. For one of sixty subrecipients tested, the Department was unable to locate the subrecipient's signed contract agreement. Cause: The Department could not locate the subrecipient's signed contract agreement containing the suspension and debarment certification clause. Effect: The Department's compliance with federal suspension and debarment requirements could not be confirmed. Recommendation: We recommend that the Department review and update its internal controls to ensure a signed contract agreement containing suspension and debarment terms and conditions is on file for all subrecipients. Prior Year Single Audit Finding Number: Not applicable Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 115.

Corrective Action Plan

The South Carolina Department of Social Services respectfully submits the following corrective action plan for the year ended June 30, 2022. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS?FEDERAL AWARD PROGRAM AUDIT U. S. Department of Agriculture 2022-015 Child and Adult Care Food Program - Assistance Listing: 10.558 Recommendation: We recommend that the Department review and update its internal controls to ensure a signed contract agreement containing suspension and debarment terms and conditions is on file for all subrecipients. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Program manager did retain the email and attachments that were sent to the provider with an explanation that their signature and return of the documents was required prior to their program participation, and management believes the document was executed. However, because the document could not be located, the Department and the provider executed a new agreement to correct the documentation deficiency in February 2023. Program staff are now conducting a 100% review of all active providers to ensure their program participation is supported by signed agreements on file. This review and any corrective measures found to be needed will be completed by April 30, 2023. In addition, management will explore with Information Systems staff the possibility of adding new system controls to confirm the uploading of required documents prior to enabling provider access to the system?s claims module. Management expects to complete any enhancements that can be made in this regard by December 31, 2023. Name(s) of the contact person(s) responsible for corrective action: Mary Abney-Young, Early Care and Education Program Manager Planned completion date for corrective action plan: December 31, 2023

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2022-016
Reporting
SIGNIFICANT DEFICIENCYREPEAT OF 2021-014OTHER MATTERS

Discrepancies existed between federal financial reports and the Department?s supporting records. Questioned Costs: None Context: For both CB-496 reports selected for testing, discrepancies were noted between supporting documentation and the report. For the quarter ending September 30, 2021, some activity was improperly reported as prior quarter adjustments. Additionally, for the quarter ending June 30, 2022, a prior quarter amount was improperly reported as current quarter claims. Cause: The Department did not fully implement the corrective action associated with this finding from the prior year. Effect: The accuracy of the CB-496 reports could not be fully validated. Recommendation: We recommend that the Department continue to review its internal controls to ensure that federal reports are free from error and clearly supported prior to submission. Prior Year Single Audit Finding Number: 2021-014 Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 116.

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Federal Agency: Department of Health and Human Services Federal Program Title: Adoption Assistance Assistance Listing: 93.659 Federal Grant ID Number: 2001SCADPT and 2101SCADPT Pass-Through Entity: Not applicable Award Period: October 1, 2019, through September 30, 2021 Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: 45 CFR ? 75.303 requires effective internal controls be established and maintained in order to provide reasonable assurance that the Federal award is being managed in compliance with Federal statutes, regulations, and the terms and conditions of the federal award. Condition: Discrepancies existed between federal financial reports and the Department?s supporting records. Questioned Costs: None Context: For both CB-496 reports selected for testing, discrepancies were noted between supporting documentation and the report. For the quarter ending September 30, 2021, some activity was improperly reported as prior quarter adjustments. Additionally, for the quarter ending June 30, 2022, a prior quarter amount was improperly reported as current quarter claims. Cause: The Department did not fully implement the corrective action associated with this finding from the prior year. Effect: The accuracy of the CB-496 reports could not be fully validated. Recommendation: We recommend that the Department continue to review its internal controls to ensure that federal reports are free from error and clearly supported prior to submission. Prior Year Single Audit Finding Number: 2021-014 Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 116.

Corrective Action Plan

The South Carolina Department of Social Services respectfully submits the following corrective action plan for the year ended June 30, 2022. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS?FEDERAL AWARD PROGRAM AUDIT U. S. Department of Health and Human Services 2022-016 Adoption Assistance - Assistance Listing: 93.659 Recommendation: We recommend that the Department continue to review its internal controls to ensure that federal reports are free from error and clearly supported prior to submission. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management agrees with the finding. Most of the discrepancies found involved current-period activity correctly posted to prior year grants which should have been reported as current quarter activity but was mistakenly reported as prior-quarter adjustments. Through discussions with the Department?s regional IV-E fiscal reporting contact, the Grants Accounting and Reporting staff have further clarified their understanding of when it is appropriate to report activity as a prior-quarter adjustment versus current-period activity, and they now have a clear understanding of the rules. The Department will correct the CB-496 reports for the quarter ending September 30, 2021, for the activity improperly reported as prior quarter adjustments and the amounts improperly reported as current quarter claims on the June 30, 2022, quarter ending report as soon the reports are made available to update in the reporting system by federal authorities. Going forward, as part of the established review process, the Grants Accounting and Reporting manager will specifically review the transactions and supporting documentation to ensure the correct treatment of prior-quarter adjustments and current-quarter activity. Name(s) of the contact person(s) responsible for corrective action: Reshma Parikh, Grants Accounting and Reporting Manager Planned completion date for corrective action plan: March 31, 2023

Prior Finding References

2021-014

About Reporting →
2022-017
Period of Performance
SIGNIFICANT DEFICIENCYQUESTIONED COSTSOTHER MATTERS

Expenditures were incurred after the end of the grant?s period of performance. Questioned Costs: $246,284 Context: For seven of forty expenditure transactions tested, program expenditures were not obligated and expended in accordance with program requirements. Cause: The Department?s internal controls failed to identify and prevent charging costs incurred outside the applicable period of performance. Effect: Costs charged outside the period of performance may not be allowable. Recommendation: We recommend that the Department review and update internal controls to ensure all expenditures charged to federal awards are incurred within the grant's period of performance. Prior Year Single Audit Finding Number: Not applicable Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 117.

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Federal Agency: Department of Health and Human Services Federal Program Title: Child Care and Development Fund (CCDF) Cluster Assistance Listings: 93.575 and 93.596 Federal Grant ID Number: 2001SCCCDD Pass-Through Entity: Not applicable Award Period: October 1, 2019, through September 30, 2022 Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: 45 CFR ? 98.60(d)(1) requires that discretionary funds (Assistance Listing 93.575) be obligated by the end of the succeeding fiscal year after the award and expended by the end of the third fiscal year after the award. Condition: Expenditures were incurred after the end of the grant?s period of performance. Questioned Costs: $246,284 Context: For seven of forty expenditure transactions tested, program expenditures were not obligated and expended in accordance with program requirements. Cause: The Department?s internal controls failed to identify and prevent charging costs incurred outside the applicable period of performance. Effect: Costs charged outside the period of performance may not be allowable. Recommendation: We recommend that the Department review and update internal controls to ensure all expenditures charged to federal awards are incurred within the grant's period of performance. Prior Year Single Audit Finding Number: Not applicable Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 117.

Corrective Action Plan

The South Carolina Department of Social Services respectfully submits the following corrective action plan for the year ended June 30, 2022. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS?FEDERAL AWARD PROGRAM AUDIT U. S. Department of Health and Human Services 2022-017 CCDF Cluster - Assistance Listing: 93.575 and 93.596 Recommendation: We recommend that the Department review and update internal controls to ensure all expenditures charged to federal awards are incurred within the grant's period of performance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Additional controls have been implemented to ensure the Department?s Grants Accounting and Reporting manager and staff review and research all transactions posted in the liquidation period of a given grant year to ensure they include only those legally obligated as of the obligation date. The transactions incorrectly posted to the 2020 Discretionary Grant have now been correctly moved to the 2021 Discretionary Grant and are being replaced with qualified voucher expenditures previously moved from the 2020 Discretionary grant to the 2020 Mandatory Grant. Name(s) of the contact person(s) responsible for corrective action: Reshma Parikh, Grants Accounting and Reporting Manager Planned completion date for corrective action plan: June 30, 2023

About Period of Performance →
2022-018
Activities Allowed or Unallowed / Cost Allowability
SIGNIFICANT DEFICIENCYOTHER MATTERS

Indirect cost allocations were not appropriately supported. Questioned Costs: Unknown Context: For one quarter tested, a substantial change was noted to one of the six allocation plan bases tested. The change was inconsistent with the public assistance cost allocation plan. Additionally, the journal entry for one quarter tested was incorrect due to a clerical error. Cause: For one of the six bases tested, the Department started using a new method to allocate costs; however, approval was not received before implementing the basis change. Additionally, a clerical error resulted in an incorrect allocation percentage for one of two tested quarterly journal entries. Effect: Indirect costs were not claimed in accordance with the approved cost allocation plan. Recommendation: We recommend that the Department regularly review their public assistance cost allocation plan and submit amendments for approval as necessary. Additionally, we recommend consolidating the support documentation for bases with multiple percentages. Prior Year Single Audit Finding Number: Not applicable Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 117.

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Federal Agency: Department of Health and Human Services Federal Program Titles: Adoption Assistance and Child Care and Development Fund (CCDF) Cluster Assistance Listings: 93.659, 93.575, and 93.596 Federal Grant ID Numbers: Various Pass-Through Entity: Not applicable Award Period: Various Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: 45 CFR ? 95.509(a) requires that a state promptly submit an amended public assistance cost allocation plan for approval if the procedures shown in the existing cost allocation plan become outdated. Additionally, 2 CFR ? 200.303 requires that the entity establish and maintain effective internal controls over the federal award that provide 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. Condition: Indirect cost allocations were not appropriately supported. Questioned Costs: Unknown Context: For one quarter tested, a substantial change was noted to one of the six allocation plan bases tested. The change was inconsistent with the public assistance cost allocation plan. Additionally, the journal entry for one quarter tested was incorrect due to a clerical error. Cause: For one of the six bases tested, the Department started using a new method to allocate costs; however, approval was not received before implementing the basis change. Additionally, a clerical error resulted in an incorrect allocation percentage for one of two tested quarterly journal entries. Effect: Indirect costs were not claimed in accordance with the approved cost allocation plan. Recommendation: We recommend that the Department regularly review their public assistance cost allocation plan and submit amendments for approval as necessary. Additionally, we recommend consolidating the support documentation for bases with multiple percentages. Prior Year Single Audit Finding Number: Not applicable Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 117.

Corrective Action Plan

The South Carolina Department of Social Services respectfully submits the following corrective action plan for the year ended June 30, 2022. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS?FEDERAL AWARD PROGRAM AUDIT U. S. Department of Health and Human Services 2022-018 Adoption Assistance, CCDF Cluster - Assistance Listing Nos.: 93.659, 93.575, and 93.596 Recommendation: We recommend that the Department regularly review their public assistance cost allocation plan and submit amendments for approval as necessary. Additionally, we recommend consolidating the support documentation for bases with multiple percentages. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management agrees with the finding. The change involved allocation based on newly-tracked case management time statistics instead of benefit payment statistics. The new time statistics were available for the first time in the quarter tested, and management considers the new method to be preferable to that previously used. Per CFR 45, Part 95, Subpart E, Section 95.515, the Department can implement changes to its cost allocation beginning with the effective date of its request for approval to do so; it is not required to receive the approval first. Management did submit a request for approval of this change with Cost Allocation Services, but the request was effective as of the beginning of the following quarter, thus did not include the quarter in question. The department will recompute the cost allocation for the quarter in which the exception occurred using the previous allocation method and will record an adjustment to correct the amounts allocated. The clerical error referenced would not have occurred had the various base calculation worksheets been integrated with one another as appropriate and with the allocation calculation worksheets. We will link these worksheets beginning with those used in the allocation for the quarter ending March 31, 2023. Name(s) of the contact person(s) responsible for corrective action: David O?Kelly, Controller Planned completion date for corrective action plan: June 30, 2023

About Activities Allowed or Unallowed, Allowable Costs / Cost Principles →

FY 2022-06-30

MATERIAL NONCOMPLIANCE DISCLOSED$194,505,206 federal awards expended

FAC accepted this audit on December 11, 2025 — management decision was due June 11, 2026.

2022-001
Eligibility
MATERIAL WEAKNESSMODIFIED OPINIONREPEAT OF 2021-001QUESTIONED COSTS

In March 2020, the President signed the CARES Act that authorized additional funding under the Unemployment Insurance (UI) program. This was followed by additional federal and state funding programs that increased grants available and modified eligibility requirements to support changes in employment status caused by the COVID-19 pandemic. Certain benefits under these programs extended into fiscal year 2022. There was a priority on distributing funds under self-attestation strategy with limited income verification to expedite disbursement of funds and support individuals in greatest need. As a result of this, many states saw a significant increase in fraudulent claims to historical highs. The U.S. Department of Labor and the Agency have partnered to investigate the extent and methods used to perpetrate fraud. For the Agency, eligibility determinations made by the management followed existing policies and procedures for this pandemic funding; however, to meet federal and state expectations regarding the quick payment of federal pandemic benefits, the policies and procedures in place were not the usual policies and procedures and so they were not adequate to completely prevent fraudulent claims. The Agency’s detective controls did identify abnormal claim activity; however, it was after the claims had already been paid. During our testing of a sample of 60 benefit payments we identified 3 payments that were fraudulent, total value of payments tested was $16,776 and total amount of fraud was $835. The extrapolated fraud amount over the total benefit payments of $179.4 million would be $9 million. Criteria: Per 2 CFR §200 Appendix XI, state responsibilities include: (1) establishing specific, detailed policies and operating procedures which comply with the requirements of federal laws and regulations; (2) determining the state unemployment insurance tax structure; (3) collecting state unemployment insurance contributions from employers (commonly called “unemployment taxes”); (4) determining claimant eligibility and disqualification provisions; (5) making payment of UI benefits to claimants; (6) managing the program’s revenue and benefit administrative functions; (7) administering the programs in accordance with established policies and procedures; and (8) enacting state UC law that conforms with federal UC law and that state law and operations substantially comply with federal law. Effect: A lack of adequate internal controls over eligibility determinations may increase the likelihood of fraudulent claims being submitted and incorrectly paid. Known Questioned Costs: During our testing of a sample of 60 benefit payments we identified 3 payments that were fraudulent, the total value of payments tested was $16,776 and total amount of known fraud was $835. Likely Questioned Costs: Based upon the extrapolated fraud amount over the total benefit payment of $179.4 thousand the total amount of fraud would likely be $10 million. Cause: The Agency experienced unprecedented claims volume starting in fiscal 2021 and continuing into fiscal year 2022 with increased funding and additional program requirements with a priority for efficient distribution from both the U.S. Department of Labor and state officials. Recommendation: We recommend that the Agency continue to review, monitor, and enhance eligibility procedures to detect and/or prevent fraudulent claimants from receiving benefits. The Agency should work to enhance and update its assessment of risks related to the eligibility process and implement internal controls to help mitigate future fraudulent claims.

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Finding 2022-001: Unemployment Insurance Benefit Payments (Material Weakness in Internal Controls) Condition: In March 2020, the President signed the CARES Act that authorized additional funding under the Unemployment Insurance (UI) program. This was followed by additional federal and state funding programs that increased grants available and modified eligibility requirements to support changes in employment status caused by the COVID-19 pandemic. Certain benefits under these programs extended into fiscal year 2022. There was a priority on distributing funds under self-attestation strategy with limited income verification to expedite disbursement of funds and support individuals in greatest need. As a result of this, many states saw a significant increase in fraudulent claims to historical highs. The U.S. Department of Labor and the Agency have partnered to investigate the extent and methods used to perpetrate fraud. For the Agency, eligibility determinations made by the management followed existing policies and procedures for this pandemic funding; however, to meet federal and state expectations regarding the quick payment of federal pandemic benefits, the policies and procedures in place were not the usual policies and procedures and so they were not adequate to completely prevent fraudulent claims. The Agency’s detective controls did identify abnormal claim activity; however, it was after the claims had already been paid. During our testing of a sample of 60 benefit payments we identified 3 payments that were fraudulent, total value of payments tested was $16,776 and total amount of fraud was $835. The extrapolated fraud amount over the total benefit payments of $179.4 million would be $9 million. Criteria: Per 2 CFR §200 Appendix XI, state responsibilities include: (1) establishing specific, detailed policies and operating procedures which comply with the requirements of federal laws and regulations; (2) determining the state unemployment insurance tax structure; (3) collecting state unemployment insurance contributions from employers (commonly called “unemployment taxes”); (4) determining claimant eligibility and disqualification provisions; (5) making payment of UI benefits to claimants; (6) managing the program’s revenue and benefit administrative functions; (7) administering the programs in accordance with established policies and procedures; and (8) enacting state UC law that conforms with federal UC law and that state law and operations substantially comply with federal law. Effect: A lack of adequate internal controls over eligibility determinations may increase the likelihood of fraudulent claims being submitted and incorrectly paid. Known Questioned Costs: During our testing of a sample of 60 benefit payments we identified 3 payments that were fraudulent, the total value of payments tested was $16,776 and total amount of known fraud was $835. Likely Questioned Costs: Based upon the extrapolated fraud amount over the total benefit payment of $179.4 thousand the total amount of fraud would likely be $10 million. Cause: The Agency experienced unprecedented claims volume starting in fiscal 2021 and continuing into fiscal year 2022 with increased funding and additional program requirements with a priority for efficient distribution from both the U.S. Department of Labor and state officials. Recommendation: We recommend that the Agency continue to review, monitor, and enhance eligibility procedures to detect and/or prevent fraudulent claimants from receiving benefits. The Agency should work to enhance and update its assessment of risks related to the eligibility process and implement internal controls to help mitigate future fraudulent claims.

Corrective Action Plan

The South Carolina Department of Employment and Workforce (SCDEW) immediately recognized the increased fraud risk presented by the federal pandemic programs. In an effort to deter this obvious fraud threat, SCDEW initially informed every applicant for federal pandemic benefits that they might be required to provide proof of their employment or self-employment at a future time. The USDOL, however, ordered SCDEW to remove this notification because, in the words of one USDOL representative, such a warning might deter a claimant from applying for federal pandemic benefits. USDOL subsequently issued guidance prohibiting states from requiring proof of employment or self-employment as an eligibility requirement to receive federal pandemic benefits. Therefore, all a fraudster had to do to receive federal benefits was simply tell a state they were unemployed as a result of the COVID-19 pandemic. SCDEW was prohibited from requiring that fraudster to prove that they were even employed, let alone that they were unemployed because of the pandemic. Many of the items identified as paid fraudulent claims were caused by SCDEW’s compliance with the USDOL guidelines. SCDEW complied with this guidance, even though it disagreed with USDOL’s highly technical parsing of federal law, and SCDEW advocated for Congress to amend the law to clearly establish commonsense fraud protections. While awaiting Congressional action, SCDEW implemented numerous fraud detection and prevention tools and strategies to minimize the potential fraud exacerbated by lax federal requirements. Unfortunately, Congress did not amend the law until late December 2020. As a result, eligibility determinations made by SCDEW prior to the law change followed the federal guidance for this pandemic funding; however, to meet federal and state expectations regarding the quick payment of federal pandemic benefits, the federal policies and procedures SCDEW was forced to adopt were not adequate to completely prevent fraudulent claims. SCDEW continues to review, monitor, and enhance eligibility processes and procedures to prevent and detect fraudulent claims. We also updated our internal controls to help mitigate future fraudulent claims. The COVID pandemic created unprecedented challenges for every state workforce agency due to the combination of historic claim volume, the availability of a staggering amount of federal money, and new programs with lax eligibility and verification requirements that had to be implemented quickly, despite often changing federal guidance. These factors created a perfect storm for sophisticated fraudsters to exploit. In response, SCDEW took numerous aggressive steps. In mid-2020, SCDEW required applicants to provide copies of their driver’s license or passport to prove their identity before receiving benefits. SCDEW also implemented identity verification questions through Lexis Nexis that every claimant had to pass before processing a claim. This was further enhanced in March 2021, when South Carolina was one of the first states to implement digital identity verification through ID.me. SCDEW also implemented reCAPTCHA to prevent against bot attacks, implemented new data sharing agreements, and increased the number of staff dedicated to investigating fraudulent claim activity to over fifty at the peak of the pandemic programs. SCDEW continuously reviews its fraud detection and prevention activities to stay ahead of emerging fraud schemes. Since the height of the pandemic, SCDEW has increased its data crossmatching, partnered with the State Law Enforcement Division to have a financial fraud investigator dedicated to unemployment insurance fraud, and made numerous enhancements to its computer systems to combat fraud and preserve the integrity of the unemployment insurance system. Per USDOL data, the agency had the twelfth lowest improper payment rate out of fifty-three programs during the year ending September 30, 2024. For more comprehensive explanation and response, please see August 26, 2024, letter attached from Paul Famolari, Assistant Executive Director of Unemployment Insurance. The Agency’s contact person responsible for the corrective action plan is Jacquelyn Carlen, CFO. The completion date of the corrective action plan was June 20, 2021, and is ongoing.

Prior Finding References

2021-001

About Eligibility →
2022-002
Other
MATERIAL WEAKNESSOTHER MATTERS

The Agency did not prepare and submit its Data Collection Form and Reporting Package for the year ended June 30, 2022 to the Federal Audit Clearinghouse by the due date of March 31, 2023. Criteria: Per §200.512 of the Uniform Guidance, Report Submission, the audit shall be completed and the Data Collection Form and Reporting Package shall be electronically transmitted within the earlier of thirty (30) days after receipt of the auditor’s reports, or nine (9) months after the end of the audit period. If the due date falls on a Saturday, Sunday, or federal holiday, the Data Collection Form and Reporting Package are due the next business day. The Uniform Guidance does not permit the recipient to extend the due date. Cause: Management did not submit their Data Collection Form and Reporting Package by the due date due to an OIG review of the June 30, 2022 year end. Management delayed their reporting due to the completion of the OIG review and key accounting/finance personnel turnover. Effect: The Agency’s Data Collection Form and Reporting Package for the year ended June 30, 2022 was not prepared and submitted to the Federal Audit Clearinghouse by the due date. Recommendation: We recommend that management during times of unexpected increase activity ensure that all appropriate controls are in place to allow timely completion of audit procedures as well as submission of Data Collection Form and Reporting Package to the Federal Audit Clearinghouse.

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Item 2022-002: Report Submission to the Federal Audit Clearinghouse (Other Matter Required to be Reported Under the Uniform Guidance) (Material Weakness) Condition: The Agency did not prepare and submit its Data Collection Form and Reporting Package for the year ended June 30, 2022 to the Federal Audit Clearinghouse by the due date of March 31, 2023. Criteria: Per §200.512 of the Uniform Guidance, Report Submission, the audit shall be completed and the Data Collection Form and Reporting Package shall be electronically transmitted within the earlier of thirty (30) days after receipt of the auditor’s reports, or nine (9) months after the end of the audit period. If the due date falls on a Saturday, Sunday, or federal holiday, the Data Collection Form and Reporting Package are due the next business day. The Uniform Guidance does not permit the recipient to extend the due date. Cause: Management did not submit their Data Collection Form and Reporting Package by the due date due to an OIG review of the June 30, 2022 year end. Management delayed their reporting due to the completion of the OIG review and key accounting/finance personnel turnover. Effect: The Agency’s Data Collection Form and Reporting Package for the year ended June 30, 2022 was not prepared and submitted to the Federal Audit Clearinghouse by the due date. Recommendation: We recommend that management during times of unexpected increase activity ensure that all appropriate controls are in place to allow timely completion of audit procedures as well as submission of Data Collection Form and Reporting Package to the Federal Audit Clearinghouse.

Corrective Action Plan

SCDEW was unable to successfully complete and submit this audit on time to submit it to the Federal Audit Clearinghouse by March 31, 2023. This occurred as the completion of the FY21 audit was delayed due to additional auditing program requirements requested by the DOL OIG. SCDEW fully understands the failure to submit audits on time could negatively impact our federal funds or termination of federal grants with DOL. We continuously communicate with the DOL on the status of this audit and other audits to keep them informed on our progress. SCDEW has missed the March 31st submission deadlines for the 2023 and 2024 agency financial audits. The agency has begun working on the 2023 agency audit and has done some work on the 2024 agency audit. SCDEW will miss the March 31st submission deadline for the 2025 agency financial audit as work on this audit has not commenced. Although these specific reporting deadlines have been missed, SCDEW constantly monitors and consistently adheres to agency wide reporting deadlines on the master reporting database. This is explained more in the paragraph below. The Agency’s contact person responsible for the corrective action plan is Jacquelyn Carlen, CFO. The completion date of the corrective action plan was August 28, 2025.

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2022-003
Reporting
MATERIAL WEAKNESSREPEAT OF 2021-002

The Agency did not submit certain quarterly reports to the United States Department of Labor (“National Office”) by the required due dates. Accordingly, the Agency did not comply with the Reporting compliance requirements related to the Unemployment Insurance program. Criteria: Per Part 4 of the OMB Compliance Supplement: The ETA 191 Report is required to be submitted on a quarterly basis to the National Office by the 25th day of the month following the close of the quarter. The ETA 2208A Report is required to be submitted on a quarterly basis to the National Office by the 45th day of the month following the close of the quarter. The ETA 2112 Report is required to be submitted on a monthly basis to the National Office by the first day of the second month following the close of the month of reference. The ETA 9052 Report is required to be submitted on a monthly basis to the National Office by the 30th day of the month following the month of reference. Cause: Internal controls are not in place to ensure that all required reports are being submitted in accordance with the United States Department of Labor’s timelines. The reports were delayed due to program and system resources focused on claims processing as well as personnel shortages. Effect: As a result, the Agency becomes more susceptible to having its level of federal award funding reduced by the United States Department of Labor when it violates its Reporting compliance requirements applicable to the Unemployment Insurance program. Context: We inspected a sample of quarterly reports and noted the following exceptions: Unemployment Insurance – One (1) ETA 191 quarterly report; Unemployment Insurance – Two (2) ETA 2208A quarterly reports; Unemployment Insurance – One (1) ETA 2112 monthly report; Unemployment Insurance – One (1) ETA 9052 monthly report. Recommendation: We recommend that management carefully review the terms and conditions included in the supporting grant agreements and the Reporting requirements included in the OMB Compliance Supplement applicable to the Unemployment Insurance and the Employment Services Cluster programs and implement controls to ensure that all reports are filed on a timely basis.

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Item 2022-003: Reporting (Material Weakness over Reporting and Non-Material Noncompliance) Condition: The Agency did not submit certain quarterly reports to the United States Department of Labor (“National Office”) by the required due dates. Accordingly, the Agency did not comply with the Reporting compliance requirements related to the Unemployment Insurance program. Criteria: Per Part 4 of the OMB Compliance Supplement: The ETA 191 Report is required to be submitted on a quarterly basis to the National Office by the 25th day of the month following the close of the quarter. The ETA 2208A Report is required to be submitted on a quarterly basis to the National Office by the 45th day of the month following the close of the quarter. The ETA 2112 Report is required to be submitted on a monthly basis to the National Office by the first day of the second month following the close of the month of reference. The ETA 9052 Report is required to be submitted on a monthly basis to the National Office by the 30th day of the month following the month of reference. Cause: Internal controls are not in place to ensure that all required reports are being submitted in accordance with the United States Department of Labor’s timelines. The reports were delayed due to program and system resources focused on claims processing as well as personnel shortages. Effect: As a result, the Agency becomes more susceptible to having its level of federal award funding reduced by the United States Department of Labor when it violates its Reporting compliance requirements applicable to the Unemployment Insurance program. Context: We inspected a sample of quarterly reports and noted the following exceptions: Unemployment Insurance – One (1) ETA 191 quarterly report; Unemployment Insurance – Two (2) ETA 2208A quarterly reports; Unemployment Insurance – One (1) ETA 2112 monthly report; Unemployment Insurance – One (1) ETA 9052 monthly report. Recommendation: We recommend that management carefully review the terms and conditions included in the supporting grant agreements and the Reporting requirements included in the OMB Compliance Supplement applicable to the Unemployment Insurance and the Employment Services Cluster programs and implement controls to ensure that all reports are filed on a timely basis.

Corrective Action Plan

SCDEW implemented a corrective action plan in response to this funding for the year ended June 30,2021, in response to similar findings in prior year audits. The SCDEW Enterprise and Project Management Office (EPMO) was originally tasked with monitoring agency wide reporting deadlines and was transferred to Executive Director’s Office. SCDEW continues to utilize the master reporting database developed by EPMO that includes relevant identifying information including report name, agency, SCDEW contact, reporting frequency and due dates. Individual reporters at SCDEW submit data to the Executive Director’s Office on the status of the required filings. The Executive Director’s Office routine reports the status of filings to executive leadership. The Agency’s contact person for the corrective action plan is Jacquelyn Carlen, CFO. The corrective action plan was implemented on June 20, 2021, and is ongoing.

Prior Finding References

2021-002

About Reporting →
2022-004
Eligibility
MATERIAL WEAKNESSMODIFIED OPINIONREPEAT OF 2021-004

The Department did not consistently perform timely annual eligibility reviews for Medicaid and CHIP recipients in accordance with Section 101.10 of the South Carolina Medicaid Policies and Procedures Manual. Questioned Costs: Unknown Context: We tested 120 individual recipients (60 each for Medicaid and CHIP) to ensure the Department complied with applicable eligibility requirements. We determined the Department did not comply with the annual review requirement for 42 Medicaid recipients and 58 CHIP recipients. Cause: Department personnel stated they did not comply with the annual review requirement for these recipients due to a backlog in case processing. Effect: In the absence of an annual review, Medicaid and CHIP recipients may continue to receive benefits without meeting eligibility requirements. Recommendation: We recommend eligibility reviews be performed annually in accordance with the South Carolina Medicaid Policies and Procedures Manual. Prior Year Single Audit Finding Number: 2021-004 Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 102.

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Federal Agency: Department of Health and Human Services Federal Program Title: Medicaid Cluster and Children?s Health Insurance Program (CHIP) Assistance Listings: 93.775, 93.777, 93.778, and 93.767 Federal Grant ID Numbers: 05-2105SC5MAP, 05-2205SC5MAP, 05-2105SC5ADM, 05-2205SC5ADM, 05-2105SC5021, and 05-2205SC5021 Pass-Through Entity: Not applicable Award Period: October 01, 2020, through September 30, 2023 Type of Finding: Material weakness in internal control over compliance, material noncompliance Criteria: Section 2.1 of the Department?s Title XIX (Medicaid) State Plan (Application, Determination of Eligibility and Furnishing Medicaid) affirms that it meets the requirements outlined in 42 CFR Part 435.916, which states in part, that the agency must promptly determine eligibility between regular renewals of eligibility. In addition, Section 101.10 of the South Carolina Medicaid Policies and Procedures Manual states that the Department must complete an annual review for certain payment categories. Furthermore, the Department?s Title XXI (CHIP) State Plan attests that CHIP will operate as a Medicaid expansion program. Therefore, the aforementioned regulation and policies apply to both programs. Condition: The Department did not consistently perform timely annual eligibility reviews for Medicaid and CHIP recipients in accordance with Section 101.10 of the South Carolina Medicaid Policies and Procedures Manual. Questioned Costs: Unknown Context: We tested 120 individual recipients (60 each for Medicaid and CHIP) to ensure the Department complied with applicable eligibility requirements. We determined the Department did not comply with the annual review requirement for 42 Medicaid recipients and 58 CHIP recipients. Cause: Department personnel stated they did not comply with the annual review requirement for these recipients due to a backlog in case processing. Effect: In the absence of an annual review, Medicaid and CHIP recipients may continue to receive benefits without meeting eligibility requirements. Recommendation: We recommend eligibility reviews be performed annually in accordance with the South Carolina Medicaid Policies and Procedures Manual. Prior Year Single Audit Finding Number: 2021-004 Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 102.

Corrective Action Plan

Department of Health & Human Services Centers for Medicare & Medicaid Services 31 Forsyth Street, SW, Room 4T20 Atlanta, Georgia 30303-8909 The South Carolina Department of Health and Human Services respectfully submits the following corrective action plan for the year ended June 30, 2022. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS ? FEDERAL AWARD PROGRAM AUDIT DEPARTMENT OF HEALTH AND HUMAN SERVICES 2022-004 Medicaid Cluster; Children?s Health Insurance Program (CHIP) ? Assistance Listing No. 93.775, 93.777, 93.778; 93.767 Recommendation: We recommend eligibility reviews be performed annually in accordance with the South Carolina Medicaid Policies and Procedures Manual. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The agency will resume standard review processing in April 2023 in response to requirements outlined in the Consolidated Appropriations Act 2023. The state has developed a comprehensive operational plan for completing this work including: ? Policy and procedure updates ? Hiring additional staff in response to attrition during the public health emergency (PHE) and staffing levels needed to complete the anticipated work ? Additional staff augmentation through a third party vendor to assist with specific data entry tasks associated with review processing ? Staff refresher training on eligibility review policies and procedures ? A comprehensive Communication Plan for sharing relevant information regarding unwinding activities with stakeholders such as beneficiaries, agency staff, call centers, providers, managed care plans and community organizations ? Outreach to inform beneficiaries about the review process and how to contact the agency with changes to contact information and questions they may have ? Distribution of reviews. The state has 12 months during the unwinding period to initiate reviews and 14 months to complete the work. ? Workload management plan to react to staffing needed for both application and review processing. Name(s) of the contact person(s) responsible for corrective action: Lori Risk Planned completion date for corrective action plan: June 2024 (End of Unwinding Period)

Prior Finding References

2021-004

About Eligibility →
2022-005
Eligibility
SIGNIFICANT DEFICIENCYREPEAT OF 2021-005OTHER MATTERS

Eligibility files did not contain adequate documentation to support the Medicaid and CHIP recipient eligibility status. Questioned Costs: Unknown Context: We tested 120 individual recipients (60 each for Medicaid and CHIP) to ensure the Department complied with applicable eligibility requirements. We determined the Department did not maintain adequate documentation of eligibility for 3 Medicaid recipients and 3 CHIP recipients. Cause: According to Department personnel, some documentation was not scanned into the electronic case files and maintained in accordance with its State plan. Effect: The Department could not support eligibility determinations in accordance with its State plan. Recommendation: We recommend the Department strengthen controls over eligibility determinations to ensure documentation is maintained and reviewed in accordance with its State plan and federal regulations. Prior Year Single Audit Finding Number: 2021-005 Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 103.

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Federal Agency: Department of Health and Human Services Federal Program Title: Medicaid Cluster and Children?s Health Insurance Program (CHIP) Assistance Listings: 93.775, 93.777, 93.778, and 93.767 Federal Grant ID Numbers: 05-2205SC5MAP, 05-2205SC5ADM, 05-2105SC5021, and 05-2205SC5021 Pass-Through Entity: Not applicable Award Period: October 01, 2020, through September 30, 2023 Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: Per 42 CFR 435.914 (a), the agency must include in each applicant?s case record facts to support the agency?s decision on his or her application. In addition, Section 4.7 of the Department?s Title XIX (Medicaid) State Plan (Maintenance of Records) affirms that it meets the requirements outlined in 42 CFR 431.17 (b), that a State plan must provide that the Medicaid agency will maintain or supervise the maintenance of records necessary for the proper and efficient operation of the plan. Furthermore, the Department?s Title XXI (CHIP) State Plan attests that CHIP will operate as a Medicaid expansion program. Therefore, the aforementioned regulations apply to both programs. Condition: Eligibility files did not contain adequate documentation to support the Medicaid and CHIP recipient eligibility status. Questioned Costs: Unknown Context: We tested 120 individual recipients (60 each for Medicaid and CHIP) to ensure the Department complied with applicable eligibility requirements. We determined the Department did not maintain adequate documentation of eligibility for 3 Medicaid recipients and 3 CHIP recipients. Cause: According to Department personnel, some documentation was not scanned into the electronic case files and maintained in accordance with its State plan. Effect: The Department could not support eligibility determinations in accordance with its State plan. Recommendation: We recommend the Department strengthen controls over eligibility determinations to ensure documentation is maintained and reviewed in accordance with its State plan and federal regulations. Prior Year Single Audit Finding Number: 2021-005 Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 103.

Corrective Action Plan

Department of Health & Human Services Centers for Medicare & Medicaid Services 31 Forsyth Street, SW, Room 4T20 Atlanta, Georgia 30303-8909 The South Carolina Department of Health and Human Services respectfully submits the following corrective action plan for the year ended June 30, 2022. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS ? FEDERAL AWARD PROGRAM AUDIT DEPARTMENT OF HEALTH AND HUMAN SERVICES 2022-005 Medicaid Cluster; Children?s Health Insurance Program (CHIP) ? Assistance Listing No. 93.775, 93.777, 93.778; 93.767 Recommendation: We recommend the Department strengthen controls over eligibility determinations to ensure documentation is maintained and reviewed in accordance with its State plan and federal regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The agency continues to implement an Eligibility Performance and Remediation process, which includes internal Eligibility Quality Assurance (EQA) monthly case reviews, as well as third party case reviews conducted by the University of South Carolina Core for Applied Research and Evaluation (USC CARE). Eligibility Policies and Procedures provide instructions for a worker to ensure the case file is complete for all eligibility criteria based on policy, prior to making a determination. The policy is included in staff training and is evaluated as part of quality assurance activities. Supervisors are responsible for monitoring staff daily by using data available via system of record, the electronic document management system (OnBase), workload management software, as well as through case spot reviews. Supervisors meet monthly with each staff member to review Eligibility Quality Assurance (EQA) findings to identify and address issues that impact performance, as well as to facilitate corrections to incorrect determinations identified through the EQA process. Errors are identified via error codes and descriptions. EQA reviews are conducted and housed in a state-developed tool to allow for creation of reports that can be generated based on supervisor, worker, work type, error code or overall accuracy. The state compares errors identified through audits and federal reviews such as payment error rate measurement with internal and third party EQA error trends and use this monitoring method to identify trends, develop mitigation strategies and to determine impact of those strategies on these errors. During the 4th quarter of calendar year 2022, 15,716 cases were reviewed by EQA with the following results pertaining to missing documentation: Error Description, Q1 CY2022 % Cases Reviewed, Q2 CY2022 % Cases Reviewed, Q3 CY2022 % Cases Reviewed, Q4 CY2022 % Cases Reviewed: The application was not signed, 0.03%, 0.01%, 0.02%, 0.30%; The application could not be located in the case file, 0.02%, 0.03%, 0.01%, 0.03%; Level of care was not in the case file or in Phoenix, 0.02%, 0.01%, 0.01%, 0.01%; The case record was missing SSN or proof of application for SSN, 0.25% 0.36%, 0.26%, 0.00%; In response to these findings, the Eligibility department will conduct email and face-to-face communication with managers, supervisors and staff regarding these findings and a reminder of documentation requirements in policy, as well as to ensure supervisors are assessing for this requirement in casefile spot checks. This will also be discussed on an upcoming Eligibility Supervisor call and shared in the Eligibility, Enrollment, and Member Services Newsletter. These requirements will also continue to be emphasized in new worker and staff refresher training. Name(s) of the contact person(s) responsible for corrective action: Lori Risk Planned completion date for corrective action plan: Email, face-to-face and newsletter communications: June 2023; EQA Procedures, staff training ? Ongoing.

Prior Finding References

2021-005

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2022-006
Reporting
SIGNIFICANT DEFICIENCYOTHER MATTERS

FFATA reporting and timing errors were identified. Questioned Costs: None Context: Fourteen subawards were selected for testing and the following compliance errors were identified during the testing: ? The reported subaward obligation/action date did not agree to the subaward agreement date for one of the subawards tested. ? For seven of the subawards tested, the action was not reported in the FSRS by the last day of the month following the month that the subaward was made. ? The FSRS could not be accessed for four of the subawards in order to test reporting compliance for that subaward. Cause: Data entry errors and administrative delays led to the compliance errors identified in the testing. Effect: The Office was not in compliance with FFATA reporting requirements. Recommendation: We recommend the Office update their current internal control to include continuous monitoring and reviewing of project obligations to ensure that reports are submitted in compliance with FFATA reporting requirements. Prior Year Single Audit Finding Number: Not applicable Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 105.

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Federal Agency: Department of Homeland Security Federal Program Title: Disaster Grants ? Public Assistance (Presidentially Declared Disasters) Assistance Listing: 97.036 Federal Grant ID Numbers: Various Pass-Through Entity: Not applicable Award Period: Various Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: 2 CFR 170 Appendix A requires that recipients of grants or cooperative agreements report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act (FFATA) Subaward Reporting System (FSRS) no later than the end of the month following the month in which the obligation was made. Condition: FFATA reporting and timing errors were identified. Questioned Costs: None Context: Fourteen subawards were selected for testing and the following compliance errors were identified during the testing: ? The reported subaward obligation/action date did not agree to the subaward agreement date for one of the subawards tested. ? For seven of the subawards tested, the action was not reported in the FSRS by the last day of the month following the month that the subaward was made. ? The FSRS could not be accessed for four of the subawards in order to test reporting compliance for that subaward. Cause: Data entry errors and administrative delays led to the compliance errors identified in the testing. Effect: The Office was not in compliance with FFATA reporting requirements. Recommendation: We recommend the Office update their current internal control to include continuous monitoring and reviewing of project obligations to ensure that reports are submitted in compliance with FFATA reporting requirements. Prior Year Single Audit Finding Number: Not applicable Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 105.

Corrective Action Plan

The South Carolina Adjutant General?s Office respectfully submits the following Corrective Action Plan for the year ended June 30, 2022. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the number assigned in the schedule. FINDINGS ? FEDERAL AWARD PROGRAM AUDIT United States Department of Homeland Security 2022-006 Public Assistance (Presidentially Declared Disasters) - Assistance Listing No. 97.036 Recommendation: We recommend the Office update their current internal control to include continuous monitoring and reviewing of project obligations to ensure that reports are submitted in compliance with FFATA reporting requirements. Explanation of disagreement with audit finding: The Office concurs with the audit finding. Action taken in response to finding: A. The Public Assistance team has updated the project version workflow in SCEMD?s South Carolina Recovery Grants (SCRecoveryGrants.org; known as SCRG) system to make sure the obligation information is received timely by the Finance and Administration team. The Fiscal Analyst responsible for reporting is now notified via SCRG automated email when a new obligation is made and when an existing obligation is modified. B. The Finance and Administration team began pulling records for FFATA reporting by obligation date instead of pulling records of reimbursements processed in April 2022 in response to a finding in a different Federal Grant program. This corrective action was implemented in all our Federal Grant Programs. FFATA reporting after May 2022 has been reported by the last day of the month following the month that the subaward was made for awards greater than $30,000. C. The Finance and Administration team will continue to save a pdf record of the monthly FFATA reports made. D. The Finance and Administration Team and the Fiscal Analyst responsible for reporting will continue to make efforts to update reporting that was not reported prior to April 2022. We will complete additional reviews of required FFATA reporting through June 30, 2023. Names of the contact persons responsible for correction action: Ms. Jessica Jones, State Public Assistance Officer; Ms. Brittany Hammond, Chief of Finance and Administration Planned completion date for corrective action plan: June 30, 2023

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2022-007
Activities Allowed or Unallowed / Cost Allowability
SIGNIFICANT DEFICIENCY

Personnel expenditures for three employees were charged to the federal award without documented approval as required by the Office?s internal control procedure. Questioned Costs: None Context: Three of forty payroll transactions tested did not have a corresponding approved State Personnel Action form that documented each employee?s salary and the percentage of their salary covered by the grant program. Cause: Management did not document approval of payroll changes for grant employees to avoid errors in payroll processing. Effect: The Office could incorrectly charge the federal award for personnel costs. Recommendation: We recommend the Office consistently adhere to its internal controls including maintaining the approved State Personnel Action form to support the personnel charges and allocations to applicable funding sources. Prior Year Single Audit Finding Number: Not applicable. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 106.

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Federal Agency: Department of Defense Federal Program Title: National Guard Military Operations and Maintenance (O&M) Projects Assistance Listing: 12.401 Federal Grant ID Numbers: Various Pass-Through Entity: Not applicable Award Period: Various Type of Finding: Significant deficiency in internal control Criteria: 2 CFR ? 200.303 states that the 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. Condition: Personnel expenditures for three employees were charged to the federal award without documented approval as required by the Office?s internal control procedure. Questioned Costs: None Context: Three of forty payroll transactions tested did not have a corresponding approved State Personnel Action form that documented each employee?s salary and the percentage of their salary covered by the grant program. Cause: Management did not document approval of payroll changes for grant employees to avoid errors in payroll processing. Effect: The Office could incorrectly charge the federal award for personnel costs. Recommendation: We recommend the Office consistently adhere to its internal controls including maintaining the approved State Personnel Action form to support the personnel charges and allocations to applicable funding sources. Prior Year Single Audit Finding Number: Not applicable. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 106.

Corrective Action Plan

The South Carolina Adjutant General?s Office respectfully submits the following Corrective Action Plan for the year ended June 30, 2022. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the number assigned in the schedule. FINDINGS ? FEDERAL AWARD PROGRAM AUDIT United States Department of Defense 2022-007 National Guard Military Operations and Maintenance (O&M) Projects Assistance Listing No. 12.401 Recommendation: We recommend the Office consistently adhere to its internal controls including maintaining the approved State Personnel Action form to support the personnel charges and allocations to applicable funding sources. Explanation of disagreement with audit finding: The Office concurs with the audit finding. Action taken in response to finding: A. The missing forms in the personnel files identified in the audit were corrected. Completed as of March 03, 2023. B. The Office is conducting a complete audit of all personnel files to ensure internal control were implemented and files are accurately and adequately documented. The estimated date of completion is March 31, 2023. C. The Office will ensure that established policies and procedures are followed, and all documentation is completed prior to entering actions into SCEIS. Name of the contact person responsible for correction action: Mr. Robert Faulk, State Human Resources Director Planned completion date for corrective action plan: March 31, 2023

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2022-008
Reporting
SIGNIFICANT DEFICIENCY

Supervisory personnel did not review certain reports prior to submission. Questioned Costs: None Context: We tested the Department?s Consolidated Annual Performance and Evaluation Report (CAPER), which includes the annual Section 3 report, and five Federal Funding Accountability and Transparency Act (FFATA) reports submitted by the Department. None of the FFATA reports were reviewed by supervisory personnel prior to submission. Cause: Department controls failed to ensure that supervisory personnel reviewed the reports prior to submission. Effect: Without supervisory review, there is an increased risk of inaccurate reporting. Recommendation: We recommend that Department personnel consistently follow policies in place to ensure reports are properly reviewed by supervisory personnel prior to submission. Prior Year Single Audit Finding Number: Not applicable Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 108.

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Federal Agency: Department of Housing and Urban Development Federal Program Title: Community Development Block Grant Assistance Listing: 14.228 Federal Grant ID Numbers: B20DW450001, B21DC450001, B20DC450001, B19DC450001, and B18DC450001 Pass-Through Entity: Not applicable Award Period: July 24, 2018, through September 1, 2028 Type of Finding: Significant deficiency in internal control over compliance Criteria: Per 2 CFR ? 200.303, the 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 be in compliance with guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States and the "Internal Control Integrated Framework", issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: Supervisory personnel did not review certain reports prior to submission. Questioned Costs: None Context: We tested the Department?s Consolidated Annual Performance and Evaluation Report (CAPER), which includes the annual Section 3 report, and five Federal Funding Accountability and Transparency Act (FFATA) reports submitted by the Department. None of the FFATA reports were reviewed by supervisory personnel prior to submission. Cause: Department controls failed to ensure that supervisory personnel reviewed the reports prior to submission. Effect: Without supervisory review, there is an increased risk of inaccurate reporting. Recommendation: We recommend that Department personnel consistently follow policies in place to ensure reports are properly reviewed by supervisory personnel prior to submission. Prior Year Single Audit Finding Number: Not applicable Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 108.

Corrective Action Plan

The South Carolina Department of Commerce respectfully submits the following corrective action plan for the year ended June 30, 2022. The finding from the schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. FINDINGS ? FEDERAL AWARD PROGRAM AUDIT U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT 2022-008 Community Development Block Grant (CDBG) ? Assistance Listing No. 14.228 Recommendation: We recommend that Department personnel consistently follow policies in place to ensure reports are properly reviewed by supervisory personnel prior to submission. Explanation of disagreement with audit finding: The South Carolina Department of Commerce agrees with the audit finding. Action taken in response to finding: All reports and documents to be submitted on behalf of the State?s Community Development Block Grant Program to the U.S. Department of Housing, Urban and Development (HUD), U.S. Department of Labor and FSRS.gov will follow a formal review process to include using track changes for documents and a final review by a CDBG staff member in a supervisory position. The designee for the final review will be the Deputy Director of Community Development or the CDBG Program Administrator. An acknowledgement of the final review will be documented to ensure the appropriate review has taken place. Name(s) of the contact person(s) responsible for corrective action: Caroline Griffin ? Deputy Director for Community Development Keely McMahan ? CDBG Program Administrator Planned completion date for corrective action plan: As of March 1, 2023, CDBG program management has adopted this corrective action plan to ensure a comprehensive review of reports by supervisory personnel prior to submission to the appropriate Federal agency.

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2022-009
Reporting
SIGNIFICANT DEFICIENCYOTHER MATTERS

We determined expenditure transactions were incorrectly classified in the general ledger. Questioned Costs: None Context: For two of twenty-two transactions tested, the Office classified subrecipient payments as contractual services. Cause: Office controls failed to ensure transactions were recorded properly in the general ledger. Effect: Subrecipient expenditures of $51,853 were omitted from the Office?s Schedule of Federal Awards (SEFA). Recommendation: We recommend that the Office ensure staff preparing and entering transactions into the accounting system have a good working knowledge of account codes as defined by the South Carolina Comptroller General?s Office (CG). In addition, supervisory personnel should closely review transactions to ensure proper classification in the general ledger. Further, the Office should seek guidance from the CG if questions regarding coding of transactions arises. Prior Year Single Audit Finding Number: Not applicable Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 109.

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Federal Agency: Department of Housing and Urban Development Federal Program Title: Community Development Block Grant Assistance Listing: 14.228 Federal Grant ID Number: B-18-DP-06-0002 Pass-Through Entity: Not applicable Award Period: August 20, 2020, through November 19, 2032 Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: 2 CFR ? 200.303 requires effective internal controls be established and maintained in order to provide reasonable assurance that the federal award is being managed in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: We determined expenditure transactions were incorrectly classified in the general ledger. Questioned Costs: None Context: For two of twenty-two transactions tested, the Office classified subrecipient payments as contractual services. Cause: Office controls failed to ensure transactions were recorded properly in the general ledger. Effect: Subrecipient expenditures of $51,853 were omitted from the Office?s Schedule of Federal Awards (SEFA). Recommendation: We recommend that the Office ensure staff preparing and entering transactions into the accounting system have a good working knowledge of account codes as defined by the South Carolina Comptroller General?s Office (CG). In addition, supervisory personnel should closely review transactions to ensure proper classification in the general ledger. Further, the Office should seek guidance from the CG if questions regarding coding of transactions arises. Prior Year Single Audit Finding Number: Not applicable Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 109.

Corrective Action Plan

The South Carolina Office of Resilience (SCOR) respectfully submits the following corrective action plan for the year ended June 30, 2022. The finding from the schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. FINDINGS - FEDERAL AWARD PROGRAM AUDIT U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT 2022-009 Community Development Block Grant - Assistance Listing No. 14.228 Recommendation: We recommend that the Office ensure staff preparing and entering transactions into the accounting system have a good working knowledge of account codes as defined by the South Carolina Comptroller General's Office (CG). In addition, supervisory personnel should closely review transactions to ensure proper classification in the general ledger. Further, the Office should seek guidance from the CG if questions regarding coding of transactions arises. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: SCOR has developed and implemented the use of a Purchase Order Cover Sheet (POCS) (See example #1) to better identify subrecipient projects/vendors requiring the correct use 517 General Ledger Categories. The POCS is a check list of all required information needed to create a shopping cart / purchase order. A recent POCS form update added a field that requires the requester to identify the Project Management team, either State or Subrecipient. This selection will determine the General Ledger Category used by Finance. Since this issue was identified, SCOR Finance has completed a review of FY23 general ledger coding and will post corrective journal entries prior to year end to ensure compliance in future audits. Name(s) of the contact person(s) responsible for corrective action: Andrew DeRienzo, SCOR Finance Director Planned completion date for corrective action plan: June 30, 2023

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2022-010
Reporting
SIGNIFICANT DEFICIENCYOTHER MATTERS

We identified noncompliance with FFATA reporting requirements. Questioned Costs: None Context: The Office did not submit FFATA reports although it had subawards of $30,000 or more. Cause: Office personnel were unaware of FFATA reporting requirements. Effect: The Office was not in compliance with FFATA reporting requirements. Recommendation: We recommend that the Office implement procedures to ensure reports are submitted in compliance with FFATA reporting requirements. Prior Year Single Audit Finding Number: Not applicable Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 111.

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Federal Agency: Department of Housing and Urban Development Federal Program Title: Community Development Block Grant Assistance Listing: 14.228 Federal Grant ID Numbers: P-19-SC-45-0DD2 and P-18-SC-45-MIT1 Pass-Through Entity: Not applicable Award Period: December 14, 2020, through August 19, 2032 Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: 2 CFR 170 Appendix A requires that recipients of grants or cooperative agreements report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act (FFATA) Subaward Reporting System (FSRS). Condition: We identified noncompliance with FFATA reporting requirements. Questioned Costs: None Context: The Office did not submit FFATA reports although it had subawards of $30,000 or more. Cause: Office personnel were unaware of FFATA reporting requirements. Effect: The Office was not in compliance with FFATA reporting requirements. Recommendation: We recommend that the Office implement procedures to ensure reports are submitted in compliance with FFATA reporting requirements. Prior Year Single Audit Finding Number: Not applicable Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 111.

Corrective Action Plan

The South Carolina Office of Resilience (SCOR) respectfully submits the following corrective action plan for the year ended June 30, 2022. The finding from the schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. FINDINGS - FEDERAL AWARD PROGRAM AUDIT U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT 2022-010 Community Development Block Grant - Assistance Listing No. 14.228 Recommendation: We recommend that the Office implement procedures to ensure reports are submitted in compliance with FFATA reporting requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: SCOR has already designated an employee (SCOR Reporting Manager) to gain knowledge of FFATA and become the FFATA Reporting point of contact. SCOR is currently unable to report grants in the FFATA Subaward Reporting System (FSRS) because FSRS identifies the 2018 CDBG-DR and CDBG-MIT grants reporting entity under a different state agency. Because the information within FSRS is based off data entries within SAM.GOV, only HUD, as the Federal entity that issued the grant, can make changes within the system. SCOR is working with its assigned representative at HUD to identify and make the appropriate changes in SAM.GOV and FSRS. Once SCOR has control of the two grants in FSRS, SCOR will retroactively report on all subrecipient subawards in the CDBG-MIT program. In the future, SCOR will also report in FSRS any other subrecipient awards for CDBG-DR and CDBG-MIT. Name(s) of the contact person(s) responsible for corrective action: Ran Reinhard, Director of Operations Planned completion date for corrective action plan: June 30, 2023

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2022-011
Special Tests & Provisions
SIGNIFICANT DEFICIENCYOTHER MATTERS

The Department did not consistently perform reviews of compliance visits of vaccine providers in accordance with its policy. Questioned Costs: None Context: We tested 37 compliance visits of providers to ensure the Department complied with applicable Special Tests and Provisions requirements. We determined the Department had not reviewed four of the compliance visits as of the end of our fieldwork. Cause: Due to the prioritization of annual VFC and other vaccine program enrollments, the Department was unable to review the site visits for these providers. Effect: In the absence of a compliance visit review, providers could have unresolved issues that could affect the quality and quantity of vaccines provided to VFC recipients. Recommendation: We recommend the Department ensure compliance visits are reviewed in accordance with Department policy. Prior Year Single Audit Finding Number: Not applicable Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 112.

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Federal Agency: Department of Health and Human Services Federal Program Title: Immunization Cooperative Agreements Assistance Listing: 93.268 Federal Grant ID Numbers: 5 NH23IP922601-03-00, 1 N23IP922601-01-00, and 6 NH23IP922601-02-00 Pass-Through Entity: Not applicable Award Period: October 01, 2019, through September 30, 2024 Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: The Office of Management and Budget?s (OMB) 2022 Compliance Supplement states that effective control and accountability must be maintained for all vaccines under the Vaccines for Children (VFC) program. Vaccines must be adequately safeguarded and used solely for authorized purposes in accordance with guidance set forth in 42 USC 1396s. To comply with this requirement, the Department?s Vaccines for Children Operation Guide requires that all completed VFC compliance site visits be reviewed by the VFC coordinator, immunization program manager, or a designee. Condition: The Department did not consistently perform reviews of compliance visits of vaccine providers in accordance with its policy. Questioned Costs: None Context: We tested 37 compliance visits of providers to ensure the Department complied with applicable Special Tests and Provisions requirements. We determined the Department had not reviewed four of the compliance visits as of the end of our fieldwork. Cause: Due to the prioritization of annual VFC and other vaccine program enrollments, the Department was unable to review the site visits for these providers. Effect: In the absence of a compliance visit review, providers could have unresolved issues that could affect the quality and quantity of vaccines provided to VFC recipients. Recommendation: We recommend the Department ensure compliance visits are reviewed in accordance with Department policy. Prior Year Single Audit Finding Number: Not applicable Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 112.

Corrective Action Plan

US Department of Health and Human Services The South Carolina Department of Health and Environmental Control respectfully submits the following corrective action plan for the year ended 6/30/22. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS?FEDERAL AWARD PROGRAM AUDIT U.S. DEPARTMENT OF Health and Human Services 2022-011 Immunization Cooperative Agreements ? Assistance Listing No. 93.268 Recommendation: We recommend the Department ensure compliance visits are reviewed in accordance with Department policy. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: To strengthen internal controls, the Department has discussed the finding with staff and stressed the importance of ensuring Centers for Disease Control guidelines are followed. Each person assigned to a site visit will complete the task within a six month signoff time frame. The Vaccines for Children Operations Director will ensure that the regions are up to speed and responsive to complete these tasks within the required timeframe. In addition, the corrective action plan will be communicated to staff at the next in-person regional meeting. Name(s) of the contact person(s) responsible for corrective action: Kim Paradeses Planned completion date for corrective action plan: June 30, 2023

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2022-012
Cash Management
SIGNIFICANT DEFICIENCYOTHER MATTERS

Supporting documentation was not adequate to determine if federal reimbursements were properly reviewed and approved by a supervisor prior to requesting a drawdown as required by the Department?s policies and procedures. Questioned Costs: None Context: For two of five Adoption Assistance drawdowns and one of the five Child and Adult Care Food Program drawdowns selected for testing, supporting documentation was not adequate to demonstrate proper review and approval by a supervisor prior to the federal reimbursement request. Cause: The Department failed to retain documentation demonstrating performance of a supervisory review and approval. Effect: The Department may request improper drawdowns due to a lack of proper approval. Recommendation: We recommend that the Department follow their policies and procedures to ensure that proper documentation is maintained to support the review and approval of a drawdown of funds. Prior Year Single Audit Finding Number: Not applicable Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 113.

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Federal Agency: Department of Health and Human Services and Department of Agriculture Federal Program Titles: Adoption Assistance and Child and Adult Care Food Program Assistance Listings: 93.659 and 10.558 Federal Grant ID Numbers: 2001SCADPT, 2101SCADPT, and 5SC300329 Pass-Through Entity: Not applicable Award Period: October 1, 2019, through September 30, 2021 Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: 2 CFR ? 200.303 requires that the non-federal entity establish and maintain effective internal controls over the federal award that provide 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. Condition: Supporting documentation was not adequate to determine if federal reimbursements were properly reviewed and approved by a supervisor prior to requesting a drawdown as required by the Department?s policies and procedures. Questioned Costs: None Context: For two of five Adoption Assistance drawdowns and one of the five Child and Adult Care Food Program drawdowns selected for testing, supporting documentation was not adequate to demonstrate proper review and approval by a supervisor prior to the federal reimbursement request. Cause: The Department failed to retain documentation demonstrating performance of a supervisory review and approval. Effect: The Department may request improper drawdowns due to a lack of proper approval. Recommendation: We recommend that the Department follow their policies and procedures to ensure that proper documentation is maintained to support the review and approval of a drawdown of funds. Prior Year Single Audit Finding Number: Not applicable Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 113.

Corrective Action Plan

The South Carolina Department of Social Services respectfully submits the following corrective action plan for the year ended June 30, 2022. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS?FEDERAL AWARD PROGRAM AUDIT U. S. Department of Health and Human Services 2022 ? 012 Adoption Assistance, Child and Adult Care Food Program ? Assistance Listing: 93.659, 10.558 Recommendation: We recommend that the Department follow their policies and procedures to ensure that proper documentation is maintained to support the review and approval of a drawdown of funds. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Department?s Grants Accounting and Reporting staff are following the established policies and procedures to ensure proper documentation is maintained to support the review and approval of draws prior to their execution. In every case the exceptions noted were draws that were done following group discussions that included the Department?s regional federal grant program representatives. Discussions were had to confirm the appropriate support and amounts of draws, and the conclusions of those discussions were that the Department should draw the amounts ultimately drawn. The Grants Accounting and Reporting Manager did approve the draws in advance but did not provide specific written approval. In one case the Grants Accounting Reporting Manager emailed the Department?s federal contact confirming the amount of funds we would draw, and the staff interpreted the email as authorization to proceed. Grants Accounting and Reporting staff have been instructed not to draw funds without express written approval, and they are complying with that requirement. Name(s) of the contact person(s) responsible for corrective action: Reshma Parikh, Grants Accounting and Reporting Manager Planned completion date for corrective action plan: Effective immediately

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2022-013
Subrecipient Monitoring
SIGNIFICANT DEFICIENCYOTHER MATTERS

The Department did not perform its subrecipient monitoring reviews in accordance with its policies and procedures and federal regulations. Questioned Costs: None Context: For fourteen of the sixty subrecipients tested, subrecipient monitoring reviews were not conducted within the three-year timeframe as set out in federal regulations. Cause: Due to staffing turnover, the Department did not comply with federal subrecipient monitoring requirements. Effect: The Department is not in compliance with federal requirements related to subrecipient monitoring requirements. Recommendation: We recommend that the Department follow its established policies and procedures for the program to ensure compliance with federal subrecipient monitoring requirements. Prior Year Single Audit Finding Number: Not applicable Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 114.

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Federal Agency: Department of Agriculture Federal Program Title: Child and Adult Care Food Program Assistance Listing: 10.558 Federal Grant ID Numbers: 5SC300329 and 5SC308329 Pass-Through Entity: Not applicable Award Period: October 1, 2019, through September 30, 2022 Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: 2 CFR ? 200.332(d) requires that all pass-through entities monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Additionally, 7 CFR ? 226.6(m)(6) outlines the frequency and number of required institution reviews. Condition: The Department did not perform its subrecipient monitoring reviews in accordance with its policies and procedures and federal regulations. Questioned Costs: None Context: For fourteen of the sixty subrecipients tested, subrecipient monitoring reviews were not conducted within the three-year timeframe as set out in federal regulations. Cause: Due to staffing turnover, the Department did not comply with federal subrecipient monitoring requirements. Effect: The Department is not in compliance with federal requirements related to subrecipient monitoring requirements. Recommendation: We recommend that the Department follow its established policies and procedures for the program to ensure compliance with federal subrecipient monitoring requirements. Prior Year Single Audit Finding Number: Not applicable Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 114.

Corrective Action Plan

The South Carolina Department of Social Services respectfully submits the following corrective action plan for the year ended June 30, 2022. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS?FEDERAL AWARD PROGRAM AUDIT U. S. Department of Agriculture 2022-013 Child and Adult Care Food Program ? Assistance Listing: 10.558 Recommendation: We recommend that the Department follow its established policies and procedures for the program to ensure compliance with federal subrecipient monitoring requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The three-year time frame in which these monitoring reviews were to have occurred included the peak months of the Coronavirus pandemic, when Department staff were working remotely for an extended period and many provider facilities were closed or operating sporadically due to staffing shortages. A significant number of program staff also left the agency during that time. These factors made timely monitoring much more difficult and extended the time required to complete it. The program maintains a worksheet designed to track compliance with this monitoring requirement and reviews, updates and acts upon it monthly. All monitoring reviews are now being conducted within the required time-frame. DSS also has an active project in progress to automate its compliance monitoring processes, and management plans to include a dashboard that displays the detailed status of each provider?s review, from start to completion. It will also report statistics showing the progress toward meeting the required yearly reviews. Management expects to have these system controls in place by December 2023. In the meantime, program staff will maintain the manual monitoring controls now in place to assure compliance. Name(s) of the contact person(s) responsible for corrective action: Mary Abney-Young, Early Care and Education Program Manager Planned completion date for corrective action plan: December 31, 2023

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2022-014
Eligibility
SIGNIFICANT DEFICIENCYOTHER MATTERS

Documentation was not adequate to verify that applicants were notified in writing of approval or disapproval by the Department within 30 days of receiving a completed application. Questioned Costs: None Context: For eleven of sixty institutions tested, we could not verify if the Department sent an approval or disapproval notification within 30 days of receiving the completed applications. Cause: The Department?s internal controls failed to ensure timely notifications to applicants according to federal regulations. Effect: We could not confirm compliance with federal regulations requiring written notifications of application approval or disapproval within 30 days of receiving a completed application. Recommendation: We recommend that the Department review its internal controls to ensure timely notifications of application approvals and disapprovals. Prior Year Single Audit Finding Number: Not applicable Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 115.

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Federal Agency: Department of Agriculture Federal Program Title: Child and Adult Care Food Program Assistance Listing: 10.558 Federal Grant ID Numbers: 5SC300329 and 5SC308329 Pass-Through Entity: Not applicable Award Period: October 1, 2019, through September 30, 2022 Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: 7 CFR ? 226.6(b)(3) requires that any new or renewing institution applying for participation in the Program be notified in writing of approval or disapproval by the State agency within 30 calendar days of the State agency's receipt of a completed application. Whenever possible, State agencies should provide assistance to institutions that have submitted an incomplete application. Any disapproved applicant institution or family day care home must be notified of the reasons for its disapproval and its right to appeal under paragraph (k) or (l), respectively, of this section. Condition: Documentation was not adequate to verify that applicants were notified in writing of approval or disapproval by the Department within 30 days of receiving a completed application. Questioned Costs: None Context: For eleven of sixty institutions tested, we could not verify if the Department sent an approval or disapproval notification within 30 days of receiving the completed applications. Cause: The Department?s internal controls failed to ensure timely notifications to applicants according to federal regulations. Effect: We could not confirm compliance with federal regulations requiring written notifications of application approval or disapproval within 30 days of receiving a completed application. Recommendation: We recommend that the Department review its internal controls to ensure timely notifications of application approvals and disapprovals. Prior Year Single Audit Finding Number: Not applicable Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 115.

Corrective Action Plan

The South Carolina Department of Social Services respectfully submits the following corrective action plan for the year ended June 30, 2022. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS?FEDERAL AWARD PROGRAM AUDIT U. S. Department of Agriculture 2022-014 Child and Adult Care Food Program ? Assistance Listing: 10.558 Recommendation: We recommend that the Department review its internal controls to ensure timely notifications of application approvals and disapprovals. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management agrees with the finding. The Department has sound controls in place for tracking notification compliance. These normally function well to assure that all application decisions are made and communicated timely. During the period in which these exceptions occurred, the program manager was away from work for an extended time. Also, during that time two experienced program staff left the Department. The remaining program staff were then temporarily unable to keep up with the volume of required application reviews, determinations and notifications. In the future, if these situations arise additional resources will be directed to keeping up with the timely processing of application reviews and notifications. In addition, program management has requested that Information Systems staff add to the system dashboard metrics a field displaying pending file approval dates. This will further assure that all upcoming deadlines are met. Management expects these dashboard enhancements to be completed by May 31, 2023. Name(s) of the contact person(s) responsible for corrective action: Mary Abney-Young, Early Care and Education Program Manager Planned completion date for corrective action plan: May 31, 2023

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2022-015
Procurement & Suspension/Debarment
SIGNIFICANT DEFICIENCYOTHER MATTERS

Compliance with suspension and debarment regulations could not be confirmed for one subrecipient. Questioned Costs: None Context: The Department verifies suspension and debarment through a certification clause embedded in the subrecipient contract. For one of sixty subrecipients tested, the Department was unable to locate the subrecipient's signed contract agreement. Cause: The Department could not locate the subrecipient's signed contract agreement containing the suspension and debarment certification clause. Effect: The Department's compliance with federal suspension and debarment requirements could not be confirmed. Recommendation: We recommend that the Department review and update its internal controls to ensure a signed contract agreement containing suspension and debarment terms and conditions is on file for all subrecipients. Prior Year Single Audit Finding Number: Not applicable Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 115.

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Federal Agency: Department of Agriculture Federal Program Title: Child and Adult Care Food Program Assistance Listing: 10.558 Federal Grant ID Numbers: 5SC300329 and 5SC308329 Pass-Through Entity: Not applicable Award Period: October 1, 2019, through September 30, 2022 Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: 2 CFR ? 180.300 requires that when a non-federal entity enters into a covered transaction (contracts for goods and services that are expected to equal or exceed $25,000, as well as all subawards to subrecipients, irrespective of award amount) with an entity at a lower tier, the non-Federal entity must verify that the entity is not suspended or debarred or otherwise excluded from participating in the transaction. The regulation lists several permitted methods for verification, including the collection of a certification from subrecipients. Condition: Compliance with suspension and debarment regulations could not be confirmed for one subrecipient. Questioned Costs: None Context: The Department verifies suspension and debarment through a certification clause embedded in the subrecipient contract. For one of sixty subrecipients tested, the Department was unable to locate the subrecipient's signed contract agreement. Cause: The Department could not locate the subrecipient's signed contract agreement containing the suspension and debarment certification clause. Effect: The Department's compliance with federal suspension and debarment requirements could not be confirmed. Recommendation: We recommend that the Department review and update its internal controls to ensure a signed contract agreement containing suspension and debarment terms and conditions is on file for all subrecipients. Prior Year Single Audit Finding Number: Not applicable Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 115.

Corrective Action Plan

The South Carolina Department of Social Services respectfully submits the following corrective action plan for the year ended June 30, 2022. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS?FEDERAL AWARD PROGRAM AUDIT U. S. Department of Agriculture 2022-015 Child and Adult Care Food Program - Assistance Listing: 10.558 Recommendation: We recommend that the Department review and update its internal controls to ensure a signed contract agreement containing suspension and debarment terms and conditions is on file for all subrecipients. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Program manager did retain the email and attachments that were sent to the provider with an explanation that their signature and return of the documents was required prior to their program participation, and management believes the document was executed. However, because the document could not be located, the Department and the provider executed a new agreement to correct the documentation deficiency in February 2023. Program staff are now conducting a 100% review of all active providers to ensure their program participation is supported by signed agreements on file. This review and any corrective measures found to be needed will be completed by April 30, 2023. In addition, management will explore with Information Systems staff the possibility of adding new system controls to confirm the uploading of required documents prior to enabling provider access to the system?s claims module. Management expects to complete any enhancements that can be made in this regard by December 31, 2023. Name(s) of the contact person(s) responsible for corrective action: Mary Abney-Young, Early Care and Education Program Manager Planned completion date for corrective action plan: December 31, 2023

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2022-016
Reporting
SIGNIFICANT DEFICIENCYREPEAT OF 2021-014OTHER MATTERS

Discrepancies existed between federal financial reports and the Department?s supporting records. Questioned Costs: None Context: For both CB-496 reports selected for testing, discrepancies were noted between supporting documentation and the report. For the quarter ending September 30, 2021, some activity was improperly reported as prior quarter adjustments. Additionally, for the quarter ending June 30, 2022, a prior quarter amount was improperly reported as current quarter claims. Cause: The Department did not fully implement the corrective action associated with this finding from the prior year. Effect: The accuracy of the CB-496 reports could not be fully validated. Recommendation: We recommend that the Department continue to review its internal controls to ensure that federal reports are free from error and clearly supported prior to submission. Prior Year Single Audit Finding Number: 2021-014 Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 116.

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Federal Agency: Department of Health and Human Services Federal Program Title: Adoption Assistance Assistance Listing: 93.659 Federal Grant ID Number: 2001SCADPT and 2101SCADPT Pass-Through Entity: Not applicable Award Period: October 1, 2019, through September 30, 2021 Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: 45 CFR ? 75.303 requires effective internal controls be established and maintained in order to provide reasonable assurance that the Federal award is being managed in compliance with Federal statutes, regulations, and the terms and conditions of the federal award. Condition: Discrepancies existed between federal financial reports and the Department?s supporting records. Questioned Costs: None Context: For both CB-496 reports selected for testing, discrepancies were noted between supporting documentation and the report. For the quarter ending September 30, 2021, some activity was improperly reported as prior quarter adjustments. Additionally, for the quarter ending June 30, 2022, a prior quarter amount was improperly reported as current quarter claims. Cause: The Department did not fully implement the corrective action associated with this finding from the prior year. Effect: The accuracy of the CB-496 reports could not be fully validated. Recommendation: We recommend that the Department continue to review its internal controls to ensure that federal reports are free from error and clearly supported prior to submission. Prior Year Single Audit Finding Number: 2021-014 Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 116.

Corrective Action Plan

The South Carolina Department of Social Services respectfully submits the following corrective action plan for the year ended June 30, 2022. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS?FEDERAL AWARD PROGRAM AUDIT U. S. Department of Health and Human Services 2022-016 Adoption Assistance - Assistance Listing: 93.659 Recommendation: We recommend that the Department continue to review its internal controls to ensure that federal reports are free from error and clearly supported prior to submission. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management agrees with the finding. Most of the discrepancies found involved current-period activity correctly posted to prior year grants which should have been reported as current quarter activity but was mistakenly reported as prior-quarter adjustments. Through discussions with the Department?s regional IV-E fiscal reporting contact, the Grants Accounting and Reporting staff have further clarified their understanding of when it is appropriate to report activity as a prior-quarter adjustment versus current-period activity, and they now have a clear understanding of the rules. The Department will correct the CB-496 reports for the quarter ending September 30, 2021, for the activity improperly reported as prior quarter adjustments and the amounts improperly reported as current quarter claims on the June 30, 2022, quarter ending report as soon the reports are made available to update in the reporting system by federal authorities. Going forward, as part of the established review process, the Grants Accounting and Reporting manager will specifically review the transactions and supporting documentation to ensure the correct treatment of prior-quarter adjustments and current-quarter activity. Name(s) of the contact person(s) responsible for corrective action: Reshma Parikh, Grants Accounting and Reporting Manager Planned completion date for corrective action plan: March 31, 2023

Prior Finding References

2021-014

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2022-017
Period of Performance
SIGNIFICANT DEFICIENCYQUESTIONED COSTSOTHER MATTERS

Expenditures were incurred after the end of the grant?s period of performance. Questioned Costs: $246,284 Context: For seven of forty expenditure transactions tested, program expenditures were not obligated and expended in accordance with program requirements. Cause: The Department?s internal controls failed to identify and prevent charging costs incurred outside the applicable period of performance. Effect: Costs charged outside the period of performance may not be allowable. Recommendation: We recommend that the Department review and update internal controls to ensure all expenditures charged to federal awards are incurred within the grant's period of performance. Prior Year Single Audit Finding Number: Not applicable Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 117.

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Federal Agency: Department of Health and Human Services Federal Program Title: Child Care and Development Fund (CCDF) Cluster Assistance Listings: 93.575 and 93.596 Federal Grant ID Number: 2001SCCCDD Pass-Through Entity: Not applicable Award Period: October 1, 2019, through September 30, 2022 Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: 45 CFR ? 98.60(d)(1) requires that discretionary funds (Assistance Listing 93.575) be obligated by the end of the succeeding fiscal year after the award and expended by the end of the third fiscal year after the award. Condition: Expenditures were incurred after the end of the grant?s period of performance. Questioned Costs: $246,284 Context: For seven of forty expenditure transactions tested, program expenditures were not obligated and expended in accordance with program requirements. Cause: The Department?s internal controls failed to identify and prevent charging costs incurred outside the applicable period of performance. Effect: Costs charged outside the period of performance may not be allowable. Recommendation: We recommend that the Department review and update internal controls to ensure all expenditures charged to federal awards are incurred within the grant's period of performance. Prior Year Single Audit Finding Number: Not applicable Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 117.

Corrective Action Plan

The South Carolina Department of Social Services respectfully submits the following corrective action plan for the year ended June 30, 2022. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS?FEDERAL AWARD PROGRAM AUDIT U. S. Department of Health and Human Services 2022-017 CCDF Cluster - Assistance Listing: 93.575 and 93.596 Recommendation: We recommend that the Department review and update internal controls to ensure all expenditures charged to federal awards are incurred within the grant's period of performance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Additional controls have been implemented to ensure the Department?s Grants Accounting and Reporting manager and staff review and research all transactions posted in the liquidation period of a given grant year to ensure they include only those legally obligated as of the obligation date. The transactions incorrectly posted to the 2020 Discretionary Grant have now been correctly moved to the 2021 Discretionary Grant and are being replaced with qualified voucher expenditures previously moved from the 2020 Discretionary grant to the 2020 Mandatory Grant. Name(s) of the contact person(s) responsible for corrective action: Reshma Parikh, Grants Accounting and Reporting Manager Planned completion date for corrective action plan: June 30, 2023

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2022-018
Activities Allowed or Unallowed / Cost Allowability
SIGNIFICANT DEFICIENCYOTHER MATTERS

Indirect cost allocations were not appropriately supported. Questioned Costs: Unknown Context: For one quarter tested, a substantial change was noted to one of the six allocation plan bases tested. The change was inconsistent with the public assistance cost allocation plan. Additionally, the journal entry for one quarter tested was incorrect due to a clerical error. Cause: For one of the six bases tested, the Department started using a new method to allocate costs; however, approval was not received before implementing the basis change. Additionally, a clerical error resulted in an incorrect allocation percentage for one of two tested quarterly journal entries. Effect: Indirect costs were not claimed in accordance with the approved cost allocation plan. Recommendation: We recommend that the Department regularly review their public assistance cost allocation plan and submit amendments for approval as necessary. Additionally, we recommend consolidating the support documentation for bases with multiple percentages. Prior Year Single Audit Finding Number: Not applicable Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 117.

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Federal Agency: Department of Health and Human Services Federal Program Titles: Adoption Assistance and Child Care and Development Fund (CCDF) Cluster Assistance Listings: 93.659, 93.575, and 93.596 Federal Grant ID Numbers: Various Pass-Through Entity: Not applicable Award Period: Various Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: 45 CFR ? 95.509(a) requires that a state promptly submit an amended public assistance cost allocation plan for approval if the procedures shown in the existing cost allocation plan become outdated. Additionally, 2 CFR ? 200.303 requires that the entity establish and maintain effective internal controls over the federal award that provide 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. Condition: Indirect cost allocations were not appropriately supported. Questioned Costs: Unknown Context: For one quarter tested, a substantial change was noted to one of the six allocation plan bases tested. The change was inconsistent with the public assistance cost allocation plan. Additionally, the journal entry for one quarter tested was incorrect due to a clerical error. Cause: For one of the six bases tested, the Department started using a new method to allocate costs; however, approval was not received before implementing the basis change. Additionally, a clerical error resulted in an incorrect allocation percentage for one of two tested quarterly journal entries. Effect: Indirect costs were not claimed in accordance with the approved cost allocation plan. Recommendation: We recommend that the Department regularly review their public assistance cost allocation plan and submit amendments for approval as necessary. Additionally, we recommend consolidating the support documentation for bases with multiple percentages. Prior Year Single Audit Finding Number: Not applicable Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 117.

Corrective Action Plan

The South Carolina Department of Social Services respectfully submits the following corrective action plan for the year ended June 30, 2022. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS?FEDERAL AWARD PROGRAM AUDIT U. S. Department of Health and Human Services 2022-018 Adoption Assistance, CCDF Cluster - Assistance Listing Nos.: 93.659, 93.575, and 93.596 Recommendation: We recommend that the Department regularly review their public assistance cost allocation plan and submit amendments for approval as necessary. Additionally, we recommend consolidating the support documentation for bases with multiple percentages. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management agrees with the finding. The change involved allocation based on newly-tracked case management time statistics instead of benefit payment statistics. The new time statistics were available for the first time in the quarter tested, and management considers the new method to be preferable to that previously used. Per CFR 45, Part 95, Subpart E, Section 95.515, the Department can implement changes to its cost allocation beginning with the effective date of its request for approval to do so; it is not required to receive the approval first. Management did submit a request for approval of this change with Cost Allocation Services, but the request was effective as of the beginning of the following quarter, thus did not include the quarter in question. The department will recompute the cost allocation for the quarter in which the exception occurred using the previous allocation method and will record an adjustment to correct the amounts allocated. The clerical error referenced would not have occurred had the various base calculation worksheets been integrated with one another as appropriate and with the allocation calculation worksheets. We will link these worksheets beginning with those used in the allocation for the quarter ending March 31, 2023. Name(s) of the contact person(s) responsible for corrective action: David O?Kelly, Controller Planned completion date for corrective action plan: June 30, 2023

About Activities Allowed or Unallowed, Allowable Costs / Cost Principles →

FY 2021-06-30

$3,757,488,499 federal awards expended

FAC accepted this audit on October 23, 2022 — management decision was due April 23, 2023.

2021-001
Reporting
MATERIAL WEAKNESSREPEAT OF 2020-002

The Agency did not submit certain quarterly reports to the United States Department of Labor ("National Office") by the required due dates. Accordingly, the Agency did not comply with the Reporting compliance requirements related to the Unemployment Insurance program. Criteria: Per Part 4 of the OMB Compliance Supplement: The ETA 191 Report is required to be submitted on a quarterly basis to the National Office by the 25th of the month following the close of the quarter. Cause: Internal controls are not in place to ensure that all required reports are being submitted in accordance with the United States Department of Labor's timelines. The reports were affected by the unprecedented COVID-19 pandemic, which required all program resources to focus on pandemic claims processing. Some of the data needed for these reports was delayed due to program and system resources focused on claims processing as well as the difficulty experienced due to the requirement of staff to shelter at home beginning April 2020 under the South Carolina Governor's Executive Order and restricted access to records located in the office. Effect: As a result, the Agency becomes more susceptible to having its level of federal award funding reduced by the United States Department of Labor when it violates its Reporting compliance requirements applicable to the Unemployment Insurance program. Context: We inspected a sample of quarterly reports and noted the following exceptions: Unemployment Insurance - Three (3) ETA 191 quarterly reports of the four (4) reports tested. Recommendation: We recommend that management carefully review the terms and conditions included in the supporting grant agreements and the Reporting requirements included in the OMB Compliance Supplement applicable to the Unemployment Insurance and the Employment Services Cluster programs and implement controls to ensure that all reports are filed on a timely basis.

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Item 2021-001: Reporting (Material Weakness over Reporting and Non-Material Noncompliance) Condition: The Agency did not submit certain quarterly reports to the United States Department of Labor ("National Office") by the required due dates. Accordingly, the Agency did not comply with the Reporting compliance requirements related to the Unemployment Insurance program. Criteria: Per Part 4 of the OMB Compliance Supplement: The ETA 191 Report is required to be submitted on a quarterly basis to the National Office by the 25th of the month following the close of the quarter. Cause: Internal controls are not in place to ensure that all required reports are being submitted in accordance with the United States Department of Labor's timelines. The reports were affected by the unprecedented COVID-19 pandemic, which required all program resources to focus on pandemic claims processing. Some of the data needed for these reports was delayed due to program and system resources focused on claims processing as well as the difficulty experienced due to the requirement of staff to shelter at home beginning April 2020 under the South Carolina Governor's Executive Order and restricted access to records located in the office. Effect: As a result, the Agency becomes more susceptible to having its level of federal award funding reduced by the United States Department of Labor when it violates its Reporting compliance requirements applicable to the Unemployment Insurance program. Context: We inspected a sample of quarterly reports and noted the following exceptions: Unemployment Insurance - Three (3) ETA 191 quarterly reports of the four (4) reports tested. Recommendation: We recommend that management carefully review the terms and conditions included in the supporting grant agreements and the Reporting requirements included in the OMB Compliance Supplement applicable to the Unemployment Insurance and the Employment Services Cluster programs and implement controls to ensure that all reports are filed on a timely basis.

Corrective Action Plan

Item 2021-001 Reporting (Material Weakness over reporting and Non-Material Noncompliance) SCDEW implemented a corrective action plan in response to this finding during the year ended June 30, 2021 in response to similar finding for audits of prior periods a brief summary follows: The SCDEW Enterprise and Project Management Office (EPMO) is tasked with monitoring agency wide reporting deadlines. The EPMO developed a master reporting database that includes relevant identifying information including report names, Agency, SCDEW contact, reporting frequency and due dates. Individual reporters at SCDEW submit data to EPMO on the status of the required filings. EPMO routinely reports the status of filings to executive leadership.

Prior Finding References

2020-002

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2021-001
Eligibility
MATERIAL WEAKNESSMODIFIED OPINIONQUESTIONED COSTS

In March 2020, the President signed the CARES Act that authorized additional funding under the Unemployment Insurance (UI) program. This was followed by additional federal and state funding programs that increased grants available and modified eligibility requirements to support changes in employment status caused by the COVID-19 pandemic. Certain benefits under these programs extended into fiscal year 2022. Subsequent to June 30, 2020, supplemental assistance provided by the CARES Act and other federal legislation supported elevated sustained benefit payments through June 2021 in excess of $3.6 billion. South Carolina ended its participation in the supplementary federal programs in June 2021 and has seen benefit payments drop significantly returning to pre-pandemic levels by October 2021. There was a priority on distributing funds under self-attestation strategy with limited income verification to expedite disbursement of funds and support individuals in greatest need. As a result of this, many states saw a significant increase in fraudulent claims to historical highs. The U.S. Department of Labor and the Agency have partnered to investigate the extent and methods used to perpetrate fraud. For the Agency, eligibility determinations made by the management followed existing policies and procedures for this pandemic funding; however, to meet federal and state expectations regarding the quick payment of federal pandemic benefits, the policies and procedures in place were not the usual policies and procedures and so they were not adequate to completely prevent fraudulent claims. The Agency’s detective controls did identify abnormal claim activity; however, it was after the claims had already been paid. During our testing of a sample of 360 benefit payments we identified 23 payments that were fraudulent, total value of payments tested was $109,375 and total amount of fraud was $7,230. The extrapolated fraud amount over the total benefit payment of $3.757 billion would be $252.9 million. Criteria: Per 2 CFR §200 Appendix XI, state responsibilities include: (1) establishing specific, detailed policies and operating procedures which comply with the requirements of federal laws and regulations; (2) determining the state unemployment insurance tax structure; (3) collecting state unemployment insurance contributions from employers (commonly called “unemployment taxes”); (4) determining claimant eligibility and disqualification provisions; (5) making payment of UI benefits to claimants; (6) managing the program’s revenue and benefit administrative functions; (7) administering the programs in accordance with established policies and procedures; and (8) enacting state UC law that conforms with federal UC law and that state law and operations substantially comply with federal law. Effect: A lack of adequate internal controls over eligibility determinations may increase the likelihood of fraudulent claims being submitted and incorrectly paid. Known Questioned Costs: During our testing of a sample of 360 benefit payments we identified 23 payments that were fraudulent, the total value of payments tested was $109,375 and total amount of known fraud was $7,230. Likely Questioned Costs: Based upon the extrapolated fraud amount over the total benefit payment of $3.757 billion the total amount of fraud would likely be $252.9 million. Cause: The Agency experienced unprecedented claims volume during fiscal 2021 with increased funding and additional program requirements with a priority for efficient distribution from both the U.S. Department of Labor and state officials. Recommendation: We recommend that the Agency continue to review, monitor, and enhance eligibility procedures to detect and/or prevent fraudulent claimants from receiving benefits. The Agency should work to enhance and update its assessment of risks related to the eligibility process and implement internal controls to help mitigate future fraudulent claims.

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Condition: In March 2020, the President signed the CARES Act that authorized additional funding under the Unemployment Insurance (UI) program. This was followed by additional federal and state funding programs that increased grants available and modified eligibility requirements to support changes in employment status caused by the COVID-19 pandemic. Certain benefits under these programs extended into fiscal year 2022. Subsequent to June 30, 2020, supplemental assistance provided by the CARES Act and other federal legislation supported elevated sustained benefit payments through June 2021 in excess of $3.6 billion. South Carolina ended its participation in the supplementary federal programs in June 2021 and has seen benefit payments drop significantly returning to pre-pandemic levels by October 2021. There was a priority on distributing funds under self-attestation strategy with limited income verification to expedite disbursement of funds and support individuals in greatest need. As a result of this, many states saw a significant increase in fraudulent claims to historical highs. The U.S. Department of Labor and the Agency have partnered to investigate the extent and methods used to perpetrate fraud. For the Agency, eligibility determinations made by the management followed existing policies and procedures for this pandemic funding; however, to meet federal and state expectations regarding the quick payment of federal pandemic benefits, the policies and procedures in place were not the usual policies and procedures and so they were not adequate to completely prevent fraudulent claims. The Agency’s detective controls did identify abnormal claim activity; however, it was after the claims had already been paid. During our testing of a sample of 360 benefit payments we identified 23 payments that were fraudulent, total value of payments tested was $109,375 and total amount of fraud was $7,230. The extrapolated fraud amount over the total benefit payment of $3.757 billion would be $252.9 million. Criteria: Per 2 CFR §200 Appendix XI, state responsibilities include: (1) establishing specific, detailed policies and operating procedures which comply with the requirements of federal laws and regulations; (2) determining the state unemployment insurance tax structure; (3) collecting state unemployment insurance contributions from employers (commonly called “unemployment taxes”); (4) determining claimant eligibility and disqualification provisions; (5) making payment of UI benefits to claimants; (6) managing the program’s revenue and benefit administrative functions; (7) administering the programs in accordance with established policies and procedures; and (8) enacting state UC law that conforms with federal UC law and that state law and operations substantially comply with federal law. Effect: A lack of adequate internal controls over eligibility determinations may increase the likelihood of fraudulent claims being submitted and incorrectly paid. Known Questioned Costs: During our testing of a sample of 360 benefit payments we identified 23 payments that were fraudulent, the total value of payments tested was $109,375 and total amount of known fraud was $7,230. Likely Questioned Costs: Based upon the extrapolated fraud amount over the total benefit payment of $3.757 billion the total amount of fraud would likely be $252.9 million. Cause: The Agency experienced unprecedented claims volume during fiscal 2021 with increased funding and additional program requirements with a priority for efficient distribution from both the U.S. Department of Labor and state officials. Recommendation: We recommend that the Agency continue to review, monitor, and enhance eligibility procedures to detect and/or prevent fraudulent claimants from receiving benefits. The Agency should work to enhance and update its assessment of risks related to the eligibility process and implement internal controls to help mitigate future fraudulent claims.

Corrective Action Plan

The South Carolina Department of Employment and Workforce (SCDEW) immediately recognized the increased fraud risk presented by the federal pandemic programs. ln an effort to deter this obvious fraud threat, SCDEW initially informed every applicant for federal pandemic benefits that they might be required to provide proof of their employment or self-employment at a future time. The USDOL, however, ordered SCDEW to remove this notification because, in the words of one USDOL representative, such a warning might deter a claimant from applying for federal pandemic benefits. USDOL subsequently issued guidance prohibiting states from requiring proof of employment or self-employment as an eligibility requirement to receive federal pandemic benefits. Therefore, all a fraudster had to do to receive federal benefits was simply tell a state they were unemployed as a result of the COVID-19 pandemic. SCDEW was prohibited from requiring that fraudster to prove that they were even employed, let alone that they were unemployed because of the pandemic. Many of the items identified as paid fraudulent claims were caused by SCDEW's compliance with the USDOL guidelines. SCDEW complied with this guidance, even though it disagreed with USDOL's highly technical parsing of federal law, and SCDEW advocated for Congress to amend the law to clearly establish commonsense fraud protections. While awaiting Congressional action, SCDEW implemented numerous fraud detection and prevention tools and strategies to minimize the potential fraud exacerbated by lax federal requirements. Unfortunately, Congress did not amend the law until late December 2020. As a result, eligibility determinations made by SCDEW prior to the law change followed the federal guidance for this pandemic funding; however, to meet federal and state expectations regarding the quick payment of federal pandemic benefits, the federal policies and procedures SCDEW was forced to adopt were not adequate to completely prevent fraudulent claims. SCDEW continues to review, monitor, and enhance eligibility processes and procedures to prevent and detect fraudulent claims. We also updated our internal controls to help mitigate future fraudulent claims. The COVID pandemic created unprecedented challenges for eve1y state workforce agency due to the combination of historic claim volume, the availability of a staggering amount of federal money, and new programs with lax eligibility and verification requirements that had to be implemented quickly, despite often changing federal guidance. These factors created a perfect storm for sophisticated fraudsters 10 exploit. In response, SCDEW took numerous aggressive steps. In mid-2020, SCDEW required applicants to provide copies of their driver's license or passport to prove their identity before receiving benefits. SCDEW also implemented identity verification questions through Lexis Nexis that every claimant had to pass before processing a claim. This was further enhanced in March 2021, when South Carolina was one of the first states to implement digital identity verification through ID.me. SCDEW also implemented reCAPTCHA to prevent against bot attacks, implemented new data sharing agreements, and increased the number of staff dedicated to investigating fraudulent claim activity to over fifty at the peak of the pandemic programs. SCDEW continuously reviews its fraud detection and prevention activities to stay ahead of emerging fraud schemes. Since the height of the pandemic, SCDEW has increased its data crossmatching, partnered with the State Law Enforcement Division to have a financial fraud investigator dedicated to unemployment insurance fraud, and made numerous enhancements to its computer systems to combat fraud and preserve the integrity of the unemployment insurance system. For more comprehensive explanation and response, please sec August 26, 2024 letter attached from Paul Famolari, Assistant Executive Director of Unemployment Insurance. The Agency's contact person responsible for the corrective action plan is Jacquelyn Carlen, CFO. The completion date of the corrective action plan was June 20, 2021.

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2021-002
Reporting
SIGNIFICANT DEFICIENCYOTHER MATTERS

A reporting discrepancy was identified on a federal financial report filed by the Office. Questioned Costs: None Context: On one of five SF-425 reports selected for testing, reported recipient share of expenditures did not agree to applicable Office supporting documentation. The Office submitted an amended report to correct the discrepancy identified during the audit. Cause: A portion of recipient share activity was mistakenly excluded from the report and the discrepancy was not detected during the Office?s review and approval process. Effect: Recipient share of expenditures was misstated on a federal financial report. Recommendation: We recommend that the Office strengthen its internal controls and processes to ensure that federal reports are free from error prior to submission. Prior Year Single Audit Report Finding Number: Not applicable Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 96.

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Federal Agency: Department of Justice Federal Program Title: Crime Victim Assistance Assistance Listing: 16.575 Federal Grant ID Number: 2017-VA-GX-4040 Pass-Through Entity: Not applicable Award Period: October 1, 2016 through September 30, 2020 Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: Per 2 CFR 200.303 Internal controls, 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. Condition: A reporting discrepancy was identified on a federal financial report filed by the Office. Questioned Costs: None Context: On one of five SF-425 reports selected for testing, reported recipient share of expenditures did not agree to applicable Office supporting documentation. The Office submitted an amended report to correct the discrepancy identified during the audit. Cause: A portion of recipient share activity was mistakenly excluded from the report and the discrepancy was not detected during the Office?s review and approval process. Effect: Recipient share of expenditures was misstated on a federal financial report. Recommendation: We recommend that the Office strengthen its internal controls and processes to ensure that federal reports are free from error prior to submission. Prior Year Single Audit Report Finding Number: Not applicable Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 96.

Corrective Action Plan

U. S. Department of Justice The South Carolina Attorney General?s Office respectfully submits the following corrective action plan for the year ended June 30, 2021. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS?FEDERAL AWARD PROGRAM AUDIT 2021-002 Crime Victim Assistance ? Assistance Listing No. 16.575 Recommendation: We recommend that the Office strengthen is internal controls and processes to ensure that federal reports are free from error prior to submission. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: When generating reports for quarterly FFR, a BW (Business Warehouse) or SCEIS cumulative report will be generated from inception to-date to ensure all federal data is captured accurately. A FFR tracking log will be maintained to reflect quarterly and cumulative match amounts to ensure total effort is reported. Any adjustments will be noted in the tracking log noting the reason for the adjustment. These procedures will be implemented immediately. The agency is currently working to implement a new grants management system that will track federal and match expenditures that will assist with federal reporting to ensure amounts are reported accurately. The projected implementation start date for the new grants accounting system is October 1, 2022. Full implementation will be completed within twelve months. Name(s) of the contact person(s) responsible for corrective action: Kelley Anderson Planned completion date for corrective action plan: Tracking log adjustments will be implemented immediately. If the Federal Cognizant Agency of Oversight or Audit has questions regarding this plan, please call Kelley Anderson at 803-734-0779.

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2021-002
Reporting
MATERIAL WEAKNESSMODIFIED OPINIONREPEAT OF 2020-002

The Agency did not submit certain quarterly reports to the United States Department of Labor (“National Office”) by the required due dates. Accordingly, the Agency did not comply with the Reporting compliance requirements related to the Unemployment Insurance program. Criteria: Per Part 4 of the OMB Compliance Supplement: • The ETA 191 Report is required to be submitted on a quarterly basis to the National Office by the 25th of the month following the close of the quarter. Cause: Internal controls are not in place to ensure that all required reports are being submitted in accordance with the United States Department of Labor’s timelines. The reports were affected by the unprecedented COVID-19 pandemic, which required all program resources to focus on pandemic claims processing. Some of the data needed for these reports was delayed due to program and system resources focused on claims processing. Effect: As a result, the Agency becomes more susceptible to having its level of federal award funding reduced by the United States Department of Labor when it violates its Reporting compliance requirements applicable to the Unemployment Insurance program. Context: We inspected a sample of quarterly reports and noted the following exceptions: • Unemployment Insurance – Three (3) ETA 191 quarterly reports of four (4) reports tested Recommendation: We recommend that management carefully review the terms and conditions included in the supporting grant agreements and the Reporting requirements included in the OMB Compliance Supplement applicable to the Unemployment Insurance and the Employment Services Cluster programs and implement controls to ensure that all reports are filed on a timely basis.

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Condition: The Agency did not submit certain quarterly reports to the United States Department of Labor (“National Office”) by the required due dates. Accordingly, the Agency did not comply with the Reporting compliance requirements related to the Unemployment Insurance program. Criteria: Per Part 4 of the OMB Compliance Supplement: • The ETA 191 Report is required to be submitted on a quarterly basis to the National Office by the 25th of the month following the close of the quarter. Cause: Internal controls are not in place to ensure that all required reports are being submitted in accordance with the United States Department of Labor’s timelines. The reports were affected by the unprecedented COVID-19 pandemic, which required all program resources to focus on pandemic claims processing. Some of the data needed for these reports was delayed due to program and system resources focused on claims processing. Effect: As a result, the Agency becomes more susceptible to having its level of federal award funding reduced by the United States Department of Labor when it violates its Reporting compliance requirements applicable to the Unemployment Insurance program. Context: We inspected a sample of quarterly reports and noted the following exceptions: • Unemployment Insurance – Three (3) ETA 191 quarterly reports of four (4) reports tested Recommendation: We recommend that management carefully review the terms and conditions included in the supporting grant agreements and the Reporting requirements included in the OMB Compliance Supplement applicable to the Unemployment Insurance and the Employment Services Cluster programs and implement controls to ensure that all reports are filed on a timely basis.

Corrective Action Plan

SCDEW implemented a corrective action plan in response to this finding during the year ended June 30, 2021 in response to similar findings in prior year audits. The SCDEW Enterprise and Project Management Office (EPMO) is tasked with monitoring agency wide reporting deadlines. The EPMO developed a master reporting database that includes relevant identifying infom1ation including report name, agency, SCDEW contact, reporting frequency and due dates. Individual reporters at SCDEW submit data to EPMO on the status of the required filings. EPMO routinely reports the status of filings to executive leadership. The Agency's contact person responsible for the corrective action plan is Jacquelyn Carlen, CFO. The completion date of the corrective action plan was September 30, 2022.

Prior Finding References

2020-002

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2021-003
Subrecipient Monitoring
SIGNIFICANT DEFICIENCYOTHER MATTERS

The Office was not in compliance with several subrecipient monitoring requirements. Questioned Costs: None Context: The following discrepancies were encountered during testing of twelve subrecipients selected for testing: Two subrecipient single audit reports were not obtained for review in accordance with federal monitoring requirements. Three subrecipients had single audit findings where documentation was not adequate to demonstrate appropriate follow-up or management decision on the findings. Nine subrecipients did not receive site visits within the timeframe set out in the monitoring plan. Cause: The global pandemic?s impact on staffing and equipment contributed to the Office?s inability to fully comply with certain monitoring requirements. Effect: The Office was not in compliance with certain federal subrecipient monitoring requirements. Recommendation: We recommend that the Office review and strengthen subrecipient monitoring controls and procedures to ensure compliance with all federal subrecipient monitoring requirements. Prior Year Single Audit Report Finding Number: Not applicable Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 96.

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Federal Agency: Department of Justice Federal Program Title: Crime Victim Assistance Assistance Listing: 16.575 Federal Grant ID Number: Various Pass-Through Entity: Not applicable Award Period: Various Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: 2 CFR 200.332 (d) describes pass-through entity requirements for reviewing single audit reports of subrecipients, including requirements for follow-up and management decisions on applicable audit findings. 28 CFR 94.106 (b) specifies the pass-through entity frequency requirements for on-site monitoring of subrecipients. Condition: The Office was not in compliance with several subrecipient monitoring requirements. Questioned Costs: None Context: The following discrepancies were encountered during testing of twelve subrecipients selected for testing: Two subrecipient single audit reports were not obtained for review in accordance with federal monitoring requirements. Three subrecipients had single audit findings where documentation was not adequate to demonstrate appropriate follow-up or management decision on the findings. Nine subrecipients did not receive site visits within the timeframe set out in the monitoring plan. Cause: The global pandemic?s impact on staffing and equipment contributed to the Office?s inability to fully comply with certain monitoring requirements. Effect: The Office was not in compliance with certain federal subrecipient monitoring requirements. Recommendation: We recommend that the Office review and strengthen subrecipient monitoring controls and procedures to ensure compliance with all federal subrecipient monitoring requirements. Prior Year Single Audit Report Finding Number: Not applicable Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 96.

Corrective Action Plan

U. S. Department of Justice The South Carolina Attorney General?s Office respectfully submits the following corrective action plan for the year ended June 30, 2021. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS?FEDERAL AWARD PROGRAM AUDIT 2021-003 Crime Victim Assistance ? Assistance Listing No. 16.575 Recommendation: We recommend that the Office review and strengthen subrecipient monitoring controls and procedures to ensure that it is in compliance with all federal subrecipient monitoring requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Procedures were written to strengthen internal controls to ensure all subrecipients submit single or program specific audits in a timely manner. A step-by-step process of notification, action requirements and follow-up will be implemented immediately. A tracking log will capture the necessary data, such as, date report received, completed review sheet, review of corrective action plan and necessary follow-up to ensure monitoring is complete and compliant with monitoring requirements. Furthermore, the agency is updating its process and tracking system to ensure all site-monitoring is conducted once every three years as stated in procedures for all subgrantees and will be reviewed and approved by the Division Director. Name(s) of the contact person(s) responsible for corrective action: Kelley Anderson and Billy House Planned completion date for corrective action plan: Immediately If the Federal Cognizant Agency of Oversight or Audit has questions regarding this plan, please call Kelley Anderson at 803-734-0779.

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2021-004
Eligibility
MATERIAL WEAKNESSMODIFIED OPINIONREPEAT OF 2020-006

The Department did not consistently perform timely annual eligibility reviews for Medicaid and CHIP recipients in accordance with Section 101.10 of the South Carolina Medicaid Policies and Procedures Manual. Questioned Costs: Unknown Context: We tested 120 individual recipients (60 each for Medicaid and CHIP) to ensure the Department complied with applicable eligibility requirements. We determined the Department did not comply with the annual review requirement for 37 Medicaid recipients and 43 CHIP recipients. Cause: Department personnel stated they did not comply with the annual review requirement for these recipients due to a backlog in case processing. Effect: In the absence of an annual review, Medicaid and CHIP recipients may continue to receive benefits without meeting eligibility requirements. Recommendation: We recommend eligibility reviews be performed annually in accordance with the South Carolina Medicaid Policies and Procedures Manual. Prior Year Single Audit Finding Number: 2020-006 Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 98.

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Federal Agency: Department of Health and Human Services Federal Program Title: Medicaid Cluster; Children?s Health Insurance Program (CHIP) Assistance Listing No.: 93.775, 93.777, 93.778; 93.767 Federal Grant ID Number: 05-2005SC5MAP, 05-1905SC5021 Pass-Through Entity: Not applicable Award Period: October 1, 2018 through September 30, 2021 Type of Finding: Material weakness in internal control over compliance, material noncompliance Criteria: Section 2.1 of the Department?s Title XIX (Medicaid) State Plan (Application, Determination of Eligibility and Furnishing Medicaid) affirms that it meets the requirements outlined in 42 CFR Part 435.916, which states in part, that the agency must promptly determine eligibility between regular renewals of eligibility. In addition, Section 101.10 of the South Carolina Medicaid Policies and Procedures Manual states that the Department must complete an annual review for certain payment categories. Furthermore, the Department?s Title XXI (CHIP) State Plan attests that CHIP will operate as a Medicaid expansion program. Therefore, the aforementioned regulation and policies apply to both programs. Condition: The Department did not consistently perform timely annual eligibility reviews for Medicaid and CHIP recipients in accordance with Section 101.10 of the South Carolina Medicaid Policies and Procedures Manual. Questioned Costs: Unknown Context: We tested 120 individual recipients (60 each for Medicaid and CHIP) to ensure the Department complied with applicable eligibility requirements. We determined the Department did not comply with the annual review requirement for 37 Medicaid recipients and 43 CHIP recipients. Cause: Department personnel stated they did not comply with the annual review requirement for these recipients due to a backlog in case processing. Effect: In the absence of an annual review, Medicaid and CHIP recipients may continue to receive benefits without meeting eligibility requirements. Recommendation: We recommend eligibility reviews be performed annually in accordance with the South Carolina Medicaid Policies and Procedures Manual. Prior Year Single Audit Finding Number: 2020-006 Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 98.

Corrective Action Plan

Department of Health & Human Services Centers for Medicare & Medicaid Services (CMS) 31 Forsyth Street, SW, Room 4T20 Atlanta, Georgia 30303-8909 The South Carolina Department of Health and Human Services respectfully submits the following corrective action plan for the year ended 6/30/21. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS ? FEDERAL AWARD PROGRAM AUDIT DEPARTMENT OF HEALTH AND HUMAN SERVICES 2021-004 Medicaid Cluster; Children?s Health Insurance Program (CHIP) ? Assistance Listing No. 93.775, 93.777, 93.778; 93.767 Recommendation: We recommend eligibility reviews be performed annually in accordance with the South Carolina Medicaid Policies and Procedures Manual. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: In 2021, SCDHHS (the agency) developed a tentative unwinding operational plan for completing pending eligibility and enrollment actions at the conclusion of the public health emergency (PHE). The state is in the process of updating the plan, based on CMS guidance and tools issued on 3/4/22. However, the basic components of the plan are still relevant. Current Activities in Progress ? Policy and procedure updates for unwinding from PHE requirements ? System updates required for unwinding from PHE policies and procedures ? Development of communication plan for sharing relevant information regarding unwinding activities with stakeholders such as beneficiaries, agency staff, call centers, providers, managed care plans and community organizations ? Preparation for outreach strategies to inform beneficiaries about the review process and encourage them to report changes in contact information. Current efforts include texting and outbound calling initiatives. ? Planning for handling increased agency contacts regarding reviews or address changes ? Planning for handling increased appeals that are possible once continuous enrollment period has ended Prioritization of Reviews The agency will use a hybrid approach for the distribution of redeterminations at the end of the PHE. Redeterminations will be prioritized to promote accurate coverage, as well as continuity of coverage. Attention will be given to prevent incorrect decisions that will then likely result in a new application being submitted, unnecessarily adding to the volume of work that must be completed. Continuity of coverage applies to both beneficiaries eligible for Medicaid, as well as those who may be eligible for Marketplace coverage and subsidies. Updated data reporting is in progress to compare to volumes identified earlier in the PHE so that decisions can be made for distribution of prioritized reviews, based on CMS guidelines and the desire to achieve a manageable distribution of reviews for subsequent years. Priority groups include: ? Pregnant Women category greater than 12 months post-partum ? Infants over 1 year old ? Individuals Over 19 in Children?s category ? Parent Caretaker Relatives who no longer have dependent children in the home ? Individuals who have aged out of Foster Care ? Individuals in the Refugee category greater than 8 months from Entry date ? Individuals receiving Medicaid because of Supplemental Security Income (SSI) benefits who will need to provide additional information to assess for eligibility in other categories The agency reached out once to individuals no longer eligible for SSI and are receiving long term care services during the PHE so that they would have the opportunity to provide the needed information and undergo the ex parte process prior to the end of the PHE. Any beneficiaries who did not respond or were found not eligible during the PHE remained in their current payment category and will receive another opportunity after the PHE ends. The remainder of reviews will be distributed across the 12-month period following the end of the PHE to allow for a relatively equal distribution, with consideration for periods of anticipated higher application volume such as open enrollment. Staffing Attrition during the PHE and an increase in workload and anticipation of work to be completed at the end of the PHE has resulted in a significant hiring of MAGI, Non-MAGI and Long-Term Care Eligibility Specialists which will continue at least through the end of federal fiscal year (FFY) 2022, depending on impacts of any additional attrition. Forty-seven (47) Non-MAGI workers have been hired and trained to date and 96 additional Non-MAGI workers are expected to be hired by the end of FFY 2022. Forty-three (43) Long-Term-Care workers have been hired and trained, with an additional 27 to be hired by the end of FFY2022. Approximately 100 additional MAGI staff will be hired as well. The additional staff is intended to build capacity for current work, as well as in preparation for resumption of normal review processing at the end of the continuous enrollment period. Staff are trained to assist with current work upon hiring and all staff will undergo training on redetermination processing in time for reinstatement of the redetermination process at the end of the PHE. Workload Management Workload management is an important component of current operations and will be critical as the state unwinds after the PHE ends. Workload management allows the agency to predict and react to staffing needs and better plan for timely decisions. Eligibility's Workload Management team monitors work queues daily and collaborates with eligibility supervisors and leadership to address timeliness of case processing and distribution of work. This may include shifting work assignments, reprioritization of work, referral to additional training, or other mechanisms to increase efficiency. Name(s) of the contact person(s) responsible for corrective action: Lori Risk Planned completion date for corrective action plan: 14 months from end of PHE or end of continuous enrollment requirement.

Prior Finding References

2020-006

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2021-005
Eligibility
SIGNIFICANT DEFICIENCYREPEAT OF 2020-004OTHER MATTERS

Eligibility files did not contain adequate documentation to support the Medicaid and CHIP recipients? eligibility statuses. Questioned Costs: Unknown Context: We tested 120 individual recipients (60 each for Medicaid and CHIP) to ensure the Department complied with applicable eligibility requirements. We determined the Department did not maintain adequate documentation of eligibility for ten Medicaid recipients and five CHIP recipients. Cause: The Department transitioned to an online eligibility system, the Medicaid Eligibility Determination System (MEDS), in July 2013. According to Department personnel, documentation in some of the paper files may not have been scanned into the system since the transition. For cases opened after the transition, the omissions were due to worker error. Effect: The Department could not support eligibility determinations in accordance with its State plan. Recommendation: We recommend the Department continue its efforts to maintain documentation to support eligibility determinations in accordance with its State plan and federal regulations. Prior Year Single Audit Finding Number: 2020-004 Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 100.

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Federal Agency: Department of Health and Human Services Federal Program Title: Medicaid Cluster; Children?s Health Insurance Program (CHIP) Assistance Listing No.: 93.775, 93.777, 93.778; 93.767 Federal Grant ID Number: 05-2005SC5MAP; 05-1905SC5021 Pass-Through Entity: Not applicable Award Period: October 1, 2018 through September 30, 2021 Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: Per 42 CFR 435.914 (a), the agency must include in each applicant?s case record facts to support the agency?s decision on his or her application. In addition, Section 4.7 of the Department?s Title XIX (Medicaid) State Plan (Maintenance of Records) affirms that it meets the requirements outlined in 42 CFR 431.17 (b), that a State plan must provide that the Medicaid agency will maintain or supervise the maintenance of records necessary for the proper and efficient operation of the plan. Furthermore, the Department?s Title XXI (CHIP) State Plan attests that CHIP will operate as a Medicaid expansion program. Therefore, the aforementioned regulations apply to both programs. Condition: Eligibility files did not contain adequate documentation to support the Medicaid and CHIP recipients? eligibility statuses. Questioned Costs: Unknown Context: We tested 120 individual recipients (60 each for Medicaid and CHIP) to ensure the Department complied with applicable eligibility requirements. We determined the Department did not maintain adequate documentation of eligibility for ten Medicaid recipients and five CHIP recipients. Cause: The Department transitioned to an online eligibility system, the Medicaid Eligibility Determination System (MEDS), in July 2013. According to Department personnel, documentation in some of the paper files may not have been scanned into the system since the transition. For cases opened after the transition, the omissions were due to worker error. Effect: The Department could not support eligibility determinations in accordance with its State plan. Recommendation: We recommend the Department continue its efforts to maintain documentation to support eligibility determinations in accordance with its State plan and federal regulations. Prior Year Single Audit Finding Number: 2020-004 Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 100.

Corrective Action Plan

Department of Health & Human Services Centers for Medicare & Medicaid Services (CMS) 31 Forsyth Street, SW, Room 4T20 Atlanta, Georgia 30303-8909 The South Carolina Department of Health and Human Services respectfully submits the following corrective action plan for the year ended 6/30/21. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS ? FEDERAL AWARD PROGRAM AUDIT DEPARTMENT OF HEALTH AND HUMAN SERVICES 2021-005 Medicaid Cluster; Children?s Health Insurance Program (CHIP) ? Assistance Listing No. 93.775, 93.777, 93.778; 93.767 Recommendation: We recommend the Department continue its efforts to maintain documentation to support eligibility determinations in accordance with its State plan and federal regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Staff Performance Evaluation and Remediation: The eligibility performance and remediation process continue to include key elements for review which lead to a correct or incorrect eligibility determination, including the presence of required documentation. Eligibility policies and procedures from March 1, 2020, provide instructions for a worker to ensure the case file is complete for all eligibility criteria based on policy, prior to making an eligibility determination. This policy is included in staff training and is evaluated as part of quality assurance activities. The Eligibility Quality Assurance Team (EQAT) members are trained to evaluate MAGI, Non-MAGI or Long-Term Care determinations for accuracy of those determinations, as well as vital procedural errors that are most likely to impact eligibility. On the first business day of each month, supervisors receive employee performance results for their staff. Supervisors are responsible for monitoring staff daily by using data available via system of record, the electronic document management system (OnBase), workload management software, as well as through case spot reviews. Supervisors meet monthly with each staff member to review Eligibility Quality Assurance (EQA) findings to identify and address issues that impact performance, as well as to facilitate corrections to incorrect determinations identified through the EQA process. Errors are identified via error codes and descriptions. EQA reviews are conducted and housed in a state-developed tool to allow for creation of reports that can be generated based on supervisor, worker, work type, error code or overall accuracy. The agency compares errors identified through audits and federal reviews such as payment error rate measurement with EQA error trends and use this monitoring method to identify trends, develop mitigation strategies and to determine impact of those strategies on these errors. In addition, the agency collaborates with our third-party quality review entity, the University of South Carolina Core for Applied Research and Evaluation (USC CARE) to conduct focused reviews to assist with monitoring trends, providing recommendations for mitigation (e.g., policy clarifications, training, or supervisor intervention) and impact of mitigation strategies. During the 4th quarter of calendar year 2021, 10,767 quality reviews were conducted by the EQA team. The agency monitors the following errors and will continue to do so on a quarterly basis: Internal EQA findings: Error Description, Q1 CY2021 % Cases Reviewed, Q2 CY2021 % Cases Reviewed, Q3 CY2021 % Cases Reviewed, Q4 CY2021 % Cases Reviewed: The application was not signed, .03%, .03%, .05%, .04%; The application could not be located in the case file, .05%, .04%, .04%, .02%; Level of care was not in the case file or in Phoenix, .01%, .02%, .01%, .02%; The case record was missing SSN or proof of application for SSN, .49%, .57%, .19%, .20% Policy Update: Currently, Medicaid Policy and Procedure Manual (MPPM) review requirements (MPPM 101.10) include a requirement to review and upload State Data Exchange (SDX) interface data into the casefile for Payment Categories 54 (Supplemental Security Income (SSI) Nursing Home) and 86 (Optional State Supplementation with SSI) each year, to confirm continued SSI eligibility although an annual review itself is not required. As the agency has transitioned to a rules-based system that reacts to SDX interface data updates, stores information in the case record and takes appropriate action in response to updates, this policy will be updated to remove this requirement. Staff Reminders: In response to these findings, the Eligibility department will send email communication to managers, supervisors and staff regarding these findings and a reminder of documentation requirements in policy, as well as to ensure supervisors are assessing for this requirement in casefile spot checks. This will also be discussed on an upcoming Eligibility Supervisor call. Name(s) of the contact person(s) responsible for corrective action: Lori Risk Planned completion date for corrective action plan: Policy update and Staff communication - June 2022; EQA Procedures - Ongoing

Prior Finding References

2020-004

About Eligibility →
2021-006
Matching, Level of Effort, Earmarking
SIGNIFICANT DEFICIENCYOTHER MATTERS

The Department did not comply with the federal matching requirement for family planning services, family planning related services, or Part B assistance premium payments. Questioned Costs: None Context: We tested 60 individual claims to ensure the Department complied with matching requirements. We determined the Department did not use the proper Federal Medical Assistance Percentage (FMAP) for all (two) of the family planning related services selected for testing as well as one of the Part B assistance premium payments selected for testing. Cause: Department personnel stated that an improper modifier was used causing sexually transmitted infection testing and treatment services to map to the incorrect internal fund code and FMAP. Also, Department personnel stated, regarding the Part B assistance premium payment, that an incorrect functional area was assigned to the report?s translation table, resulting in the incorrect FMAP being used. Staff realized the error and corrected the translation table to the correct functional area. However, staff failed to follow through to ensure the entry was posted correctly or to process a journal entry in the accounting system to correct the posting. Effect: The Department?s controls did not consistently detect errors identified which could lead to improper payments. Recommendation: We recommend the Department correct the errors in MMIS and strengthen its controls to ensure errors are corrected when identified. Prior Year Single Audit Finding Number: Not applicable Views of Responsible Offices and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 102.

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Federal Agency: Department of Health and Human Services Federal Program Title: Medicaid Cluster Assistance Listing No.: 93.775, 93.777, 93.778 Federal Grant ID Number: 05-2005SC5MAP Pass-Through Entity: Not applicable Award Period: October 1, 2020 through September 30, 2021 Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: Per 42 CFR 433.10 (c) (1), under Section 1905 (a) (5) of the Act, the federal share of state expenditures for family planning services is 90 percent. In addition, per the Centers for Medicare & Medicaid Services (CMS) State Medicaid Director Letter 14-003, family planning related services are matched at the states? regular federal medical assistance percentage. Also, per 42 CFR 433.10 (c) (5) (i), under section 1933(d) of the Act, the federal share of state expenditures for Medicare Part B premiums described in section 1905(p)(3)(A)(ii) of the Act on behalf of Qualifying Individuals described in section 1902(a)(10)(E)(iv) of the Act, is 100 percent, to the extent that the assistance does not exceed the state's allocation under paragraph (c)(5)(ii) of this section. To the extent that the assistance exceeds that allocation, the federal share is 0 percent. Condition: The Department did not comply with the federal matching requirement for family planning services, family planning related services, or Part B assistance premium payments. Questioned Costs: None Context: We tested 60 individual claims to ensure the Department complied with matching requirements. We determined the Department did not use the proper Federal Medical Assistance Percentage (FMAP) for all (two) of the family planning related services selected for testing as well as one of the Part B assistance premium payments selected for testing. Cause: Department personnel stated that an improper modifier was used causing sexually transmitted infection testing and treatment services to map to the incorrect internal fund code and FMAP. Also, Department personnel stated, regarding the Part B assistance premium payment, that an incorrect functional area was assigned to the report?s translation table, resulting in the incorrect FMAP being used. Staff realized the error and corrected the translation table to the correct functional area. However, staff failed to follow through to ensure the entry was posted correctly or to process a journal entry in the accounting system to correct the posting. Effect: The Department?s controls did not consistently detect errors identified which could lead to improper payments. Recommendation: We recommend the Department correct the errors in MMIS and strengthen its controls to ensure errors are corrected when identified. Prior Year Single Audit Finding Number: Not applicable Views of Responsible Offices and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 102.

Corrective Action Plan

Department of Health & Human Services Centers for Medicare & Medicaid Services (CMS) 31 Forsyth Street, SW, Room 4T20 Atlanta, Georgia 30303-8909 The South Carolina Department of Health and Human Services respectfully submits the following corrective action plan for the year ended 6/30/21. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS ? FEDERAL AWARD PROGRAM AUDIT DEPARTMENT OF HEALTH AND HUMAN SERVICES 2021-006 Medicaid Cluster ? Assistance Listing No. 93.775, 93.777, 93.778 Recommendation: We recommend the Department correct the errors in MMIS and strengthen its controls to ensure errors are corrected when identified. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Root Cause: Medicaid Management Information System (MMIS) does not include pointer logic for diagnosis codes to indicate the specific line(s) that each apply to. This results in all diagnosis codes being assigned to all procedure codes submitted on a claim. In cases where diagnosis codes with a program indicator of `Family Planning? are included on the claim, the MMIS is incorrectly treating each line as if it were a family planning service. In some cases, this is resulting in the incorrect FMAP being applied to services that may not have been true Family Planning codes. The Department has made numerous corrections to the Family Planning logic, including removing aspects such as the FP modifier from assignment to FMAP assignment, but agrees that further remediation is needed. Corrective Action: The agency is developing an action plan, in collaboration with its MMIS vendor, Clemson University, to evaluate the complete adjudication logic of the Family Planning limited benefit plan. This evaluation includes a review of all aspects of plan administration, including: ? Review/update procedure/Diagnosis Code program indicators ? Review/update the dedicated Family Planning MMIS tables ? Review/update the adjudication logic, including the continued use of the FP modifier for billing purposes ? Update the Fund Code assignment to remediate the auto-assignment of Family Planning FMAP rates based on diagnosis code alone ? Update the policy manuals to give clear guidance to providers on how to bill for Family Planning beneficiaries ? Finally, a review will be completed of all claims that may have been processed under the former logic and decisions will be made on whether to reprocess claims to assign the proper FMAP or if a ledger adjustment will be performed to correct FMAP draw downs. The development, testing, and implementation of the revised Family Planning logic is scheduled to be completely by December 31, 2022. Corrective Action Plan for Part B Assistance Premium Payment issue: Fiscal staff have created a training document for identifying and assigning the correct functional areas to report types in the Medicaid Claims Payment Processing module in SCEIS. The training emphasizes the need to follow through the process to ensure errors are corrected when identified. Name(s) of the contact person(s) responsible for corrective action: Jeremy Faulkenburg, Brian Paeth, and Jenny Shealy Planned completion date for corrective action plan: December 31, 2022

About Matching, Level of Effort, Earmarking →
2021-007
Special Tests & Provisions
SIGNIFICANT DEFICIENCYOTHER MATTERS

The Department did not conduct, or contract, for an independent audit of the accuracy, truthfulness, and completeness of the encounter and financial data submitted by, or on behalf of, each MCO. Questioned Costs: None Context: We selected all (5) MCOs to ensure the Department complied with Managed Care Financial Audit requirements, but the Department could not provide us with the required periodic audit reports. Cause: Department personnel stated the periodic audits have not been conducted because they, along with the Department?s contracted third-party actuary, analyze the encounter and financial data of the MCO on a quarterly and annual basis at the aggregate level. Effect: The Department did not comply with the Special Tests and Provisions-Managed Care Financial Audit requirement. Recommendation: We recommend the Department ensure required periodic audits are performed. The required reports and documents should then be posted to the Department?s publicly accessible website. Prior Year Single Audit Finding Number: Not applicable Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 103.

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Federal Agency: Department of Health and Human Services Federal Program Title: Medicaid Cluster; Children?s Health Insurance Program Assistance Listing No.: 93.775, 93.777, 93.778, 93.767 Federal Grant ID Number: 05-2005SC5MAP, 05-1905SC5021 Pass-Through Entity: Not applicable Award Period: October 1, 2020 through September 30, 2021 Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: Per 42 CFR 438.602 (e), the state must periodically, but no less frequently than once every 3 years, conduct, or contract for the conduct of, an independent audit of the accuracy, truthfulness, and completeness of the encounter and financial data submitted by, or on behalf of, each Managed Care Organization (MCO), Prepaid Inpatient Health Plan (PIHP) or Prepaid Ambulatory Health Plan (PAHP). In addition, per 42 CFR 438.602 (g), the state must post on its Web site, as required in 438.10(c)(3), the following documents and reports: (1) The MCO, PIHP, PAHP, or Primary Care Case Management (PCCM) entity contract. (2) The data at 438.604(a)(5). (3) The name and title of individuals included in 438.604(a)(6). (4) The results of any audits under paragraph (e) of this section. Condition: The Department did not conduct, or contract, for an independent audit of the accuracy, truthfulness, and completeness of the encounter and financial data submitted by, or on behalf of, each MCO. Questioned Costs: None Context: We selected all (5) MCOs to ensure the Department complied with Managed Care Financial Audit requirements, but the Department could not provide us with the required periodic audit reports. Cause: Department personnel stated the periodic audits have not been conducted because they, along with the Department?s contracted third-party actuary, analyze the encounter and financial data of the MCO on a quarterly and annual basis at the aggregate level. Effect: The Department did not comply with the Special Tests and Provisions-Managed Care Financial Audit requirement. Recommendation: We recommend the Department ensure required periodic audits are performed. The required reports and documents should then be posted to the Department?s publicly accessible website. Prior Year Single Audit Finding Number: Not applicable Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 103.

Corrective Action Plan

Department of Health & Human Services Centers for Medicare & Medicaid Services (CMS) 31 Forsyth Street, SW, Room 4T20 Atlanta, Georgia 30303-8909 The South Carolina Department of Health and Human Services respectfully submits the following corrective action plan for the year ended 6/30/21. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS ? FEDERAL AWARD PROGRAM AUDIT DEPARTMENT OF HEALTH AND HUMAN SERVICES Medicaid Cluster; Children?s Health Insurance Program (CHIP) ? Assistance Listing No. 93.775, 93.777, 93.778; 93.767 Recommendation: We recommend the Department ensure required periodic audits are performed. The required reports and documents should then be posted to the Department?s publicly accessible website. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The agency will update its managed care contract to include the following language: 7.9.1. The CONTRACTOR must submit an annual audited financial report by July 1st of each year. 7.9.2.1 The annual audited financial report must include an independent audit of the accuracy, truthfulness and completeness of the Encounter and financial data submitted by the CONTRACTOR. 7.9.2.2 Detailed instructions for completion of the audited financial report are available in the Managed Care Policy and Procedure Guide. Name(s) of the contact person(s) responsible for corrective action: Jonathan Tapley, Thomas Clark Phillip Planned completion date for corrective action plan: July 1, 2022. First report submitted with the independent audit to occur after contract execution. MCO annual reports submitted in 2023 to include the audited financial and encounter data.

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2021-008
Special Tests & Provisions
MATERIAL WEAKNESSMODIFIED OPINION

The Department could not provide support that it complied with the implementation of the required six NCCI methodologies and the NCCI program requirements in accordance with the NCCI Medicaid Policy Manual and the NCCI Medicaid Technical Guidance Manual. Questioned Costs: None Context: We were unable to process test claims to determine if the Department complied with the NCCI Medicaid Policy Manual and the NCCI Medicaid Technical Guidance Manual. Cause: The Department contracts with a third party to implement the required six NCCI methodologies and program requirements. The Department's only monitoring tool over the responsibilities performed by the third party is to review cost savings reports provided by them; the Department does not monitor or perform a test of claims throughout the year. The Department did not provide access to necessary systems or documentation to allow us to test claims to determine compliance. Effect: In the absence of internal controls over the implementation of the Medicaid NCCI methodologies, the Department is unable to ensure that only proper payments of procedures are reimbursed. Recommendation: We recommend the Department implement controls to ensure its third-party contractor has implemented the required six NCCI methodologies and NCCI program requirements. Prior Year Single Audit Finding Number: Not applicable Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 104.

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Federal Agency: Department of Health and Human Services Federal Program Title: Medicaid Cluster Assistance Listing No.: 93.775, 93.777, 93.778 Federal Grant ID Number: 05-2005SC5MAP Pass-Through Entity: Not applicable Award Period: October 1, 2020 through September 30, 2021 Type of Finding: Material weakness in internal control over compliance, material noncompliance Criteria: The NCCI Policy Manual for Medicaid Services and the Medicaid NCCI Technical Guidance Manual require states to implement the required six NCCI methodologies and NCCI program requirements. Condition: The Department could not provide support that it complied with the implementation of the required six NCCI methodologies and the NCCI program requirements in accordance with the NCCI Medicaid Policy Manual and the NCCI Medicaid Technical Guidance Manual. Questioned Costs: None Context: We were unable to process test claims to determine if the Department complied with the NCCI Medicaid Policy Manual and the NCCI Medicaid Technical Guidance Manual. Cause: The Department contracts with a third party to implement the required six NCCI methodologies and program requirements. The Department's only monitoring tool over the responsibilities performed by the third party is to review cost savings reports provided by them; the Department does not monitor or perform a test of claims throughout the year. The Department did not provide access to necessary systems or documentation to allow us to test claims to determine compliance. Effect: In the absence of internal controls over the implementation of the Medicaid NCCI methodologies, the Department is unable to ensure that only proper payments of procedures are reimbursed. Recommendation: We recommend the Department implement controls to ensure its third-party contractor has implemented the required six NCCI methodologies and NCCI program requirements. Prior Year Single Audit Finding Number: Not applicable Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 104.

Corrective Action Plan

Department of Health & Human Services Centers for Medicare & Medicaid Services (CMS) 31 Forsyth Street, SW, Room 4T20 Atlanta, Georgia 30303-8909 The South Carolina Department of Health and Human Services respectfully submits the following corrective action plan for the year ended 6/30/21. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS ? FEDERAL AWARD PROGRAM AUDIT DEPARTMENT OF HEALTH AND HUMAN SERVICES 2021-008 Medicaid Cluster ? Assistance Listing No. 93.775, 93.777, 93.778 Recommendation: We recommend the Department implement controls to ensure its third-party contractor has implemented the required six NCCI methodologies and NCCI program requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Root Cause: MMIS does not have native editing of methodologies within the National Correct Coding Initiative. As such, it has contracted with a third party to perform NCCI analysis against claim extracts and provide the agency with a Pass/Fail report. This report is then ingested into the MMIS system and corresponding claim edits are applied to any submission that fails NCCI compliance. In response to this edit, the third party has provided evidence that they are up to date on all CMS edit criteria, that claim submissions and response reports are being transmitted, and a savings report showing the total costs saved by the agency via implementation of the NCCI edits is provided on a monthly basis. However, the agency agrees that it has not performed test claims of the NCCI system. Corrective Action: The agency is developing a plan to engage the third party with test scenarios on a quarterly basis. These test files will be generated via collaboration between the agency?s Bureau of Provider Services and Support, the area responsible for fee-for-service claims processing, and the Bureau of Medicaid Systems, the area of Information Technology who oversees file transmissions between the MMIS and the third party. The quarterly test file will include scenarios that cover both types of NCCI edits- procedure to procedure (PTP) and medically unlikely edits (MUEs). The scenarios will include claim types expected to validate the proper execution of all six methodologies, including: ? PTP edits for practitioner and ambulatory surgical center (ASC) services ? PTP edits for outpatient services in hospitals (including services offered in emergency and radiology departments, observation units, clinics, and laboratories) ? PTP edits for durable medical equipment (DME) ? MUE edits for practitioner and ASC services ? MUE edits for outpatient services in hospitals ? MUE edits for DME The quarterly testing files will coincide with the quarterly updates released by CMS. Special attention will be given to codes/scenarios that are included in the preceding quarter?s update. This development of the test scenarios, methodology creation, proprietary file development and transmission protocols to the third party are scheduled to be completed by the close of calendar year 2022. The first test file submission will take place in Q1 2023. Name(s) of the contact person(s) responsible for corrective action: Jeremy Faulkenburg Planned completion date for corrective action plan: December 2022

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2021-009
Special Tests & Provisions
SIGNIFICANT DEFICIENCYOTHER MATTERS

The Department did not ensure reports submitted by managed care organizations (MCO) included all MLR report elements as required by federal regulations. Questioned Costs: None Context: The Department contracts with 5 MCOs. We tested all reports submitted by the MCOs to ensure they contained the required 13 elements and determined the reports did not contain any line item or note regarding fraud prevention activities. Cause: Department personnel stated fraud prevention activities were excluded from the MLR reports due to the private market not yet incorporating fraud prevention activities in the MLR calculation. Effect: The Department did not comply with the Special Tests and Provisions-Medical Loss Ratio requirement. Recommendation: We recommend the Department ensure MLR reports submitted by MCOs comply with federal regulations. Prior Year Single Audit Finding Number: Not applicable Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 105.

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Federal Agency: Department of Health and Human Services Federal Program Title: Medicaid Cluster; Children?s Health Insurance Program Assistance Listing No.: 93.775, 93.777, 93.778, 93.767 Federal Grant ID Number: 05-2005SC5MAP, 05-1905SC5021 Pass-Through Entity: Not applicable Award Period: October 1, 2020 through September 30, 2021 Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: Per 42 CFR 438.8(k)(1), the state, through its contracts, must require each MCO, PIHP, or PAHP to submit a report to the state that includes at least the following information for each MLR reporting year: (iii) Fraud prevention activities as defined in paragraph (e)(4) of this section. Condition: The Department did not ensure reports submitted by managed care organizations (MCO) included all MLR report elements as required by federal regulations. Questioned Costs: None Context: The Department contracts with 5 MCOs. We tested all reports submitted by the MCOs to ensure they contained the required 13 elements and determined the reports did not contain any line item or note regarding fraud prevention activities. Cause: Department personnel stated fraud prevention activities were excluded from the MLR reports due to the private market not yet incorporating fraud prevention activities in the MLR calculation. Effect: The Department did not comply with the Special Tests and Provisions-Medical Loss Ratio requirement. Recommendation: We recommend the Department ensure MLR reports submitted by MCOs comply with federal regulations. Prior Year Single Audit Finding Number: Not applicable Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 105.

Corrective Action Plan

Department of Health & Human Services Centers for Medicare & Medicaid Services (CMS) 31 Forsyth Street, SW, Room 4T20 Atlanta, Georgia 30303-8909 The South Carolina Department of Health and Human Services respectfully submits the following corrective action plan for the year ended 6/30/21. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS ? FEDERAL AWARD PROGRAM AUDIT DEPARTMENT OF HEALTH AND HUMAN SERVICES 2021-009 Medicaid Cluster; Children?s Health Insurance Program (CHIP) ? Assistance Listing No. 93.775, 93.777, 93.778; 93.767 Recommendation: We recommend the Department ensure MLR reports submitted by MCOs comply with federal regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Our actuaries will be required to change their annual MLR reporting template to include Fraud Prevention Activities expenditures as defined in 42 CFR 438.8(e)(4) and required under 42 CFR 438.8(k)(1)(iii). Name(s) of the contact person(s) responsible for corrective action: T. Clark Phillip Planned completion date for corrective action plan: April 30, 2022.

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2021-010
Activities Allowed or Unallowed / Cost Allowability
SIGNIFICANT DEFICIENCYQUESTIONED COSTSOTHER MATTERS

Non-allowable costs were charged to the grant. Questioned Costs: $6,272 Context: Federal regulations state that non-federal entities may only use payments from the Fund to cover previously unbudgeted costs of necessary expenditures incurred as a result of the COVID-19 public health emergency. One of 71 non-payroll disbursements tested was for the costs of carpet cleaning services. These costs were neither previously unbudgeted nor necessary due to the public health emergency. Cause: The Office's internal controls failed to prevent non allowable activities and costs from being charged to the grant. Effect: The Office was not in compliance with certain federal regulations and applicable allowable costs/activities requirements. Recommendation: We recommend the Office strengthen its internal controls and processes to ensure that all charges to the grant are allowable. Prior Year Single Audit Finding Number: Not applicable Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 106.

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Federal Agency: Department of the Treasury Federal Program Title: Coronavirus Relief Fund ? COVID-19 Assistance Listing No.: 21.019 Federal Grant ID Number: None provided Pass-Through Entity: State of South Carolina Award Period: March 1, 2020 through December 31, 2021 Type of Finding: Significant Deficiency in internal control over compliance, other matters Criteria: Per 2 CFR 200.303 Internal controls, 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. Condition: Non-allowable costs were charged to the grant. Questioned Costs: $6,272 Context: Federal regulations state that non-federal entities may only use payments from the Fund to cover previously unbudgeted costs of necessary expenditures incurred as a result of the COVID-19 public health emergency. One of 71 non-payroll disbursements tested was for the costs of carpet cleaning services. These costs were neither previously unbudgeted nor necessary due to the public health emergency. Cause: The Office's internal controls failed to prevent non allowable activities and costs from being charged to the grant. Effect: The Office was not in compliance with certain federal regulations and applicable allowable costs/activities requirements. Recommendation: We recommend the Office strengthen its internal controls and processes to ensure that all charges to the grant are allowable. Prior Year Single Audit Finding Number: Not applicable Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 106.

Corrective Action Plan

United States Department of the Treasury The South Carolina Office of Regulatory Staff respectfully submits the following corrective action plan for the year ended 6/30/21. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS?FEDERAL AWARD PROGRAM AUDIT 2021-010 Coronavirus Relief Fund? Assistance Listing No. 21.019 Recommendation: We recommend the Office strengthen its internal controls and processes to ensure that all charges to the grant are allowable. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: ORS will strengthen its review procedures to ensure all expenditures charged to grants are allowable. The condition noted was related to the operation of an existing control and not control design; therefore, ORS will implement a plan whereby it periodically takes action to increase staff awareness of their responsibility to exercise due professional care in their duties. Name(s) of the contact person(s) responsible for corrective action: Mark Rhoden, CFO. Planned completion date for corrective action plan: June 30, 2022.

About Activities Allowed or Unallowed, Allowable Costs / Cost Principles →
2021-011
Activities Allowed or Unallowed / Cost Allowability
MATERIAL WEAKNESSQUESTIONED COSTSOTHER MATTERS

Fraud was committed by a school district employee. Each school district in the State was a beneficiary of the program and had expenditures funded by the South Carolina Department of Education (the Department). Questioned Costs: $548,391 Context: The procurement office of a beneficiary school district discovered misuse of funds by a school employee who steered the district to contract with companies he created and controlled for the purchase of equipment. The equipment was sold to the school district at a substantial markup. The now former school district employee pled guilty on January 27, 2022, to defrauding the school district. The questioned costs related to the fraud include $130,000 overcharged for cameras, $60,000 related to invoicing for sales tax and $358,391 retained by the former employee failing to pay the camera vendor for the items delivered to the school district. Cause: Department controls failed to prevent the identified misappropriation of funds. Effect: $548,391 of Coronavirus Relief Funds were misappropriated. Recommendation: We recommend the Department strengthen controls to ensure that all costs charged to the grant are allowable. Prior Year Single Audit Finding Number: Not applicable Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 107.

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Federal Agency: Department of the Treasury Federal Program Title: Coronavirus Relief Fund ? COVID-19 Assistance Listing No.: 21.019 Federal Grant ID Number: None provided Pass-Through Entity: South Carolina Department of Administration Award Period: March 1, 2020 through December 31, 2021 Type of Finding: Material Weakness in internal control over compliance, other matters Criteria: Per 2 CFR 200.303 Internal controls, 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. Condition: Fraud was committed by a school district employee. Each school district in the State was a beneficiary of the program and had expenditures funded by the South Carolina Department of Education (the Department). Questioned Costs: $548,391 Context: The procurement office of a beneficiary school district discovered misuse of funds by a school employee who steered the district to contract with companies he created and controlled for the purchase of equipment. The equipment was sold to the school district at a substantial markup. The now former school district employee pled guilty on January 27, 2022, to defrauding the school district. The questioned costs related to the fraud include $130,000 overcharged for cameras, $60,000 related to invoicing for sales tax and $358,391 retained by the former employee failing to pay the camera vendor for the items delivered to the school district. Cause: Department controls failed to prevent the identified misappropriation of funds. Effect: $548,391 of Coronavirus Relief Funds were misappropriated. Recommendation: We recommend the Department strengthen controls to ensure that all costs charged to the grant are allowable. Prior Year Single Audit Finding Number: Not applicable Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 107.

Corrective Action Plan

South Carolina Department of Education 1429 Senate Steet Columbia, South Carolina 29201 The South Carolina Department of Education respectfully submits the following corrective action plan for the year ended June 30, 2021. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS?FEDERAL AWARD PROGRAM AUDIT DEPARTMENT OF EDUCATION 2021-011 Coronavirus Relief Fund ? Assistance Listing No. 21.019 Recommendation: We recommend the Department strengthen controls to ensure that all costs charged to the grant are allowable. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The SC Department of Education will continue to educate school districts and other subrecipients on the appropriate use of federal awards. The Department will continue to work with the Executive Budget Office and the US Department of Treasury to determine the appropriate corrective actions. Name(s) of the contact person(s) responsible for corrective action: Nancy Williams, Chief Financial Officer Planned completion date for corrective action plan: June 30, 2022

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2021-012
Reporting
SIGNIFICANT DEFICIENCYOTHER MATTERS

The report was filed after the due date. Questioned Costs: None Context: The action was reported in FSRS on April 14, 2021, but was due no later than the last day of the month following the month in which the obligation was made (February 28, 2021). Cause: Department controls failed to ensure timely report submission. Effect: Noncompliance was noted with FSRS requirements. Recommendation: We recommend the Department strengthen controls to ensure the FFATA report is submitted in FSRS in a timely manner. Prior Year Single Audit Finding Number: Not applicable Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 108.

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Full finding narrative

Federal Agency: Department of Education Federal Program Title: Education Stabilization Fund ? COVID-19 Assistance Listing No.: 84.425D Federal Grant ID Number: S425D210019 Pass-Through Entity: None Award Period: January 5, 2021 through September 30, 2022 Type of Finding: Significant Deficiency in internal control over compliance, other matters Criteria: Per 2 CFR 170 Appendix A, the action should be reported in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS) no later than the last day of the month following the month in which the obligation was made. Condition: The report was filed after the due date. Questioned Costs: None Context: The action was reported in FSRS on April 14, 2021, but was due no later than the last day of the month following the month in which the obligation was made (February 28, 2021). Cause: Department controls failed to ensure timely report submission. Effect: Noncompliance was noted with FSRS requirements. Recommendation: We recommend the Department strengthen controls to ensure the FFATA report is submitted in FSRS in a timely manner. Prior Year Single Audit Finding Number: Not applicable Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 108.

Corrective Action Plan

South Carolina Department of Education 1429 Senate Steet Columbia, South Carolina 29201 The South Carolina Department of Education respectfully submits the following corrective action plan for the year ended June 30, 2021. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS?FEDERAL AWARD PROGRAM AUDIT DEPARTMENT OF EDUCATION 2021-012 Education Stabilization Fund ? Assistance Listing No. 84.425D Recommendation: We recommend the Department strengthen controls to ensure the FFATA report is submitted in FSRS in a timely manner. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Procedures were written to assure timely reporting of federal awards in the FSRS System. A review of these procedures will be scheduled for early April with Grants Accounting and Mid-April with the Program Offices. Due to these dates, we recommend a completion date of May 1, 2022, for the Corrective Action. Name(s) of the contact person(s) responsible for corrective action: Steven Strother, Finance Director Planned completion date for corrective action plan: May 1, 2022

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2021-013
Cost Allowability / Eligibility
MATERIAL WEAKNESSMODIFIED OPINIONREPEAT OF 2020-027QUESTIONED COSTS

Eligibility related discrepancies were encountered for some subsidy payments. Questioned Costs: $3,321 Context: Sixty payments charged to the program were selected for testing eligibility compliance. Seven of the payments tested contained eligibility discrepancies as follows: Documentation properly supported that the case was ineligible for program subsidy payments (two). Documentation contained information that was not consistent with meeting eligibility requirements (three). Documentation was insufficient to determine eligibility (two). Additionally, three other subsidy payments tested were for children no longer eligible for payment. Cause: Department controls failed to ensure eligibility was properly determined or applied, benefits were terminated timely, and records were appropriately retained. The ongoing global pandemic also limited the Department?s ability to implement corrective action. Effect: The Department did not comply with and/or could not demonstrate compliance with eligibility and allowable costs/cost principles requirements. Recommendation: We recommend that the Department continue to implement corrective action for eligibility file controls. Prior Year Single Audit Report Finding Number: 2020-027 Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 109.

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Full finding narrative

Federal Agency: Department of Health and Human Services Federal Program Title: Adoption Assistance Assistance Listing: 93.659 Federal Grant ID Number: 2001SCADPT, 2101SCADPT Pass-Through Entity: Not applicable Award Period: October 1, 2019 through September 30, 2021 Type of Finding: Material weakness in internal control over compliance, material noncompliance Criteria: 45 CFR 75.361 outlines record retention requirements of the non-federal entity pertinent to the federal award. 45 CFR 1356.40(b)(1) requires the adoption assistance agreement be signed and in effect at the time of or prior to the final decree of adoption. 42 U.S.C. 673(c) explains the children with special needs criteria. 42 U.S.C. 675(8)(b) expands eligibility requirements for children over the age of eighteen. Condition: Eligibility related discrepancies were encountered for some subsidy payments. Questioned Costs: $3,321 Context: Sixty payments charged to the program were selected for testing eligibility compliance. Seven of the payments tested contained eligibility discrepancies as follows: Documentation properly supported that the case was ineligible for program subsidy payments (two). Documentation contained information that was not consistent with meeting eligibility requirements (three). Documentation was insufficient to determine eligibility (two). Additionally, three other subsidy payments tested were for children no longer eligible for payment. Cause: Department controls failed to ensure eligibility was properly determined or applied, benefits were terminated timely, and records were appropriately retained. The ongoing global pandemic also limited the Department?s ability to implement corrective action. Effect: The Department did not comply with and/or could not demonstrate compliance with eligibility and allowable costs/cost principles requirements. Recommendation: We recommend that the Department continue to implement corrective action for eligibility file controls. Prior Year Single Audit Report Finding Number: 2020-027 Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 109.

Corrective Action Plan

The South Carolina Department of Social Services respectfully submits the following corrective action plan for the year ended June 30, 2021. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS?FEDERAL AWARD PROGRAM AUDIT U. S. Department of Health and Human Services 2021-013 Adoption Assistance ? Assistance Listing No. 93.659 Recommendation: We recommend that the Department continue to implement corrective action for eligibility file controls. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: All adoption subsidy agreements (ASAs) are nowreviewed for completeness, accuracy and agreement with appropriate supportingdocumentation by two State Office Adoptions administrative employees specifically assigned to ensure the agreements have been completed correctly. Only after they haveconfirmed an ASA is properly supported, complete and accurate, they submit it to the State Office Adoptions Manager for signature. When signing the ASAs, the State Office Adoptions Manager now conducts their own compliance review and verifies the subsidy payment amounts are correct and agree with the signed adoption subsidy negotiation approval form. If discrepancies are found, the manager contacts the region for clarification or corrective action. Then, when key information from the ASAs is entered into the Child Welfare Information System (CAPSS), staff verify that each ASA includes the State Adoption Office Manager?s signature. In addition, State Adoptions staff, working with the Department?s Information Technology team, are implementing a process whereby Adoptions staff will be required to upload all ASAs and supporting documents into Sharepoint for work-flowed approval. Management believes that, collectively, the above controls will greatly reduce the possibility that adoption subsidies will commence without the proper support of an ASA that has been correctly completed, appropriately supported by other required documentation, properly signed by an authorized manager, and can easily be retrieved from Department files. Some of the payments tested and identified as exceptions this year were made pursuant to subsidy agreements executed in prior years. The Department has already begun reviewing older files to ensure the subsidy agreements include the proper signatures, and the Department will continue this practice. The Department also has begun implementation of an eligibility review process whereby staff pull sample cases quarterly for internal review to confirm compliance with various requirements and ensure all subsidy payments were adequately supported. Finally, in August 2021 State Adoptions staff, working with the Department?s Information Technology team, implemented system controls and reports to ensure timely termination of payments and maintenance of documentary support for payments to children who are 18 years and older. The Department?s CAPSS system now discontinues subsidy payments at the end of the month in which a child reaches age 21. In addition, monthly reports are provided to Adoptions staff that facilitate the generation and mailing of advance requests for required updates to educational and medical information to assure timely receipt of support for continuing payments for children who are 18 and over. Each month staff track the documentation requested to ensure the required updates have been received, and they terminate payments that lack the required support. Management believes these new processes substantially reduce the possibility that payments will continue without appropriate support for youth who are 18 years of age or older. Name(s) of the contact person(s) responsible for corrective action: Dawn Barton, Permanency Manager Planned completion date for corrective action plan: August 1, 2022

Prior Finding References

2020-027

About Allowable Costs / Cost Principles, Eligibility →
2021-014
Reporting
SIGNIFICANT DEFICIENCYREPEAT OF 2020-028OTHER MATTERS

Discrepancies existed between federal financial reports and the Department?s supporting records. Questioned Costs: None Context: Two CB-496 reports were selected for testing. Discrepancies were noted between supporting documentation and the reports. In Part 1, Section B of both reports, some activity was improperly reported as prior quarter adjustments. Errors were also identified in the Adoption Savings Calculation used in determining the amounts reported in Part 4 of the report. Cause: The Department had not completely implemented the corrective action associated with this finding from the prior year. Effect: The accuracy of the CB-496 reports could not be fully validated. Recommendation: We recommend that the Department continue to strengthen its internal controls to ensure that federal reports are free from error and clearly supported prior to submission. Prior Year Single Audit Report Finding Number: 2020-028 Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 110.

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Full finding narrative

Federal Agency: Department of Health and Human Services Federal Program Title: Adoption Assistance Assistance Listing: 93.659 Federal Grant ID Number: 2001SCADPT, 2101SCADPT Pass-Through Entity: Not applicable Award Period: October 1, 2019 through September 30, 2021 Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: 45 CFR 75.303 requires effective internal controls be established and maintained in order to provide reasonable assurance that the federal award is being managed in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: Discrepancies existed between federal financial reports and the Department?s supporting records. Questioned Costs: None Context: Two CB-496 reports were selected for testing. Discrepancies were noted between supporting documentation and the reports. In Part 1, Section B of both reports, some activity was improperly reported as prior quarter adjustments. Errors were also identified in the Adoption Savings Calculation used in determining the amounts reported in Part 4 of the report. Cause: The Department had not completely implemented the corrective action associated with this finding from the prior year. Effect: The accuracy of the CB-496 reports could not be fully validated. Recommendation: We recommend that the Department continue to strengthen its internal controls to ensure that federal reports are free from error and clearly supported prior to submission. Prior Year Single Audit Report Finding Number: 2020-028 Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 110.

Corrective Action Plan

The South Carolina Department of Social Services respectfully submits the following corrective action plan for the year ended June 30, 2021. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS?FEDERAL AWARD PROGRAM AUDIT U. S. Department of Health and Human Services 2021-014 Adoption Assistance ? Assistance Listing No. 93.659 Recommendation: We recommend that the Department continue to strengthen its internal controls to ensure that federal reports are free from error and clearly supported prior to submission. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Department?s Grants Accounting and Reporting Manager now has completed the first year of work at the Department and has also added staff to allow more time for review of reports. The entire team has greatly increased its understanding of the reporting rules and the measures required to ensure proper completion of the Federal Financial Reports, with appropriate tie-in and retention of relevant supporting documentation. Management has specifically reviewed with staff the discrepancies noted between supporting documentation and the reports, as well as the incorrect treatment of report corrections as prior quarter adjustments. Management does not expect these errors to recur. If they do, management expects them to be detected and corrected during management review. Errors noted in the Adoption Savings calculation were related to specific calculation and reporting mechanics that are simple to check and now well understood. The Department will specifically review the calculations and supporting documentation to ensure they are free of these errors and will continue the management review process now in place. Name(s) of the contact person(s) responsible for corrective action: Reshma Parikh, Grants Accounting and Reporting Manager Planned completion date for corrective action plan: March 31, 2022

Prior Finding References

2020-028

About Reporting →
2021-015
Reporting
MATERIAL WEAKNESSMODIFIED OPINION

The total awards expended for the program could not be determined or identified on the Department?s SEFA. Questioned Costs: None Context: The expenditure activity of the new program was not tracked in the Department?s accounting system in a manner consistent with other grant programs and therefore was not included on the Department?s SEFA. Cause: Department controls failed to ensure consistent tracking of the program?s expenditure activity in its accounting system and reporting controls did not detect and correct the resulting reporting error on the SEFA submitted for audit. Effect: An audit adjustment was required to correct the Department?s SEFA and some federal reports of the program required revision. Recommendation: We recommend that the Department implement procedures to ensure that all new grant program activity is consistently accounted for in the Department?s accounting system and that SEFA reporting does not exclude any expenditures required by federal reporting requirements. Prior Year Single Audit Report Finding Number: None Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 111.

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Federal Agency: Department of Agriculture Federal Program Title: Pandemic EBT Food Benefits ? COVID-19 Assistance Listing: 10.542 Federal Grant ID Number: None Pass-Through Entity: Not applicable Award Period: March 16, 2020 through June 11, 2021 Type of Finding: Material weakness in internal control over compliance, material noncompliance Criteria: 2 CFR 200.303 requires effective internal controls be established and maintained in order to provide reasonable assurance that the federal award is being managed in compliance with federal statutes, regulations, and the terms and conditions of the federal award. 2 CFR 200.510(b) specifies the reporting requirements for the schedule of expenditures of federal awards (SEFA). Condition: The total awards expended for the program could not be determined or identified on the Department?s SEFA. Questioned Costs: None Context: The expenditure activity of the new program was not tracked in the Department?s accounting system in a manner consistent with other grant programs and therefore was not included on the Department?s SEFA. Cause: Department controls failed to ensure consistent tracking of the program?s expenditure activity in its accounting system and reporting controls did not detect and correct the resulting reporting error on the SEFA submitted for audit. Effect: An audit adjustment was required to correct the Department?s SEFA and some federal reports of the program required revision. Recommendation: We recommend that the Department implement procedures to ensure that all new grant program activity is consistently accounted for in the Department?s accounting system and that SEFA reporting does not exclude any expenditures required by federal reporting requirements. Prior Year Single Audit Report Finding Number: None Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 111.

Corrective Action Plan

The South Carolina Department of Social Services respectfully submits the following corrective action plan for the year ended June 30, 2021. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS?FEDERAL AWARD PROGRAM AUDIT U. S. Department of Health and Human Services 2021-015 Pandemic EBT Food Benefits ? Assistance Listing No. 10.542 Recommendation: We recommend that the Department implement procedures to ensure that all new grant program activity is consistently accounted for in the Department?s accounting system and that SEFA reporting does not exclude any expenditures required by federal reporting requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The transmission and delivery of most PEBT benefits were executed in separate and distinct processes developed solely for that purpose on an emergency basis. Most of these benefits therefore were excluded from the normal SNAP benefits accounting reports and processes. Management will modify the accounting process to specifically capture PEBT benefits, and the Grants Accounting and Reporting staff will reconcile total SNAP benefits issued to postings in the accounting system to ensure all have been recorded and reported. PEBT expenditures, as well as those of any other new grant programs enacted in the future, will be reported separately, rather than combined with those of similar programs. Name(s) of the contact person(s) responsible for corrective action: Reshma Parikh, Grants Accounting and Reporting Manager Planned completion date for corrective action plan: April 30, 2022

About Reporting →
2021-016
Cost Allowability
SIGNIFICANT DEFICIENCYQUESTIONED COSTSOTHER MATTERS

Non-allowable costs were identified in charges to the grant. Questioned Costs: $4,691 Context: Three of the sixty-six expenditure transactions selected for inspection were recorded to the grant twice through two separate accounting transactions. Cause: The Department identified allowable charges and recorded those charges to the grant through adjusting journal entries. The same transaction was mistakenly included in two separate journal entries and the duplication was not detected and corrected through the review and approval of the Department?s journal entries. Effect: The grant could be overcharged for some specific costs. Recommendation: We recommend that the Department review the supporting documentation for the amounts charged to the grant to determine if the grant was overcharged and determine any necessary appropriate resolution for the closed grant program. Prior Year Single Audit Report Finding Number: None Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 111.

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Federal Agency: Department of the Treasury Federal Program Title: Coronavirus Relief Fund ? COVID-19 Assistance Listing: 21.019 Federal Grant ID Number: None Pass-Through Entity: South Carolina Department of Administration Award Period: March 1, 2020 through December 31, 2021 Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: 2 CFR 200.303 requires effective internal controls be established and maintained in order to provide reasonable assurance that the federal award is being managed in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: Non-allowable costs were identified in charges to the grant. Questioned Costs: $4,691 Context: Three of the sixty-six expenditure transactions selected for inspection were recorded to the grant twice through two separate accounting transactions. Cause: The Department identified allowable charges and recorded those charges to the grant through adjusting journal entries. The same transaction was mistakenly included in two separate journal entries and the duplication was not detected and corrected through the review and approval of the Department?s journal entries. Effect: The grant could be overcharged for some specific costs. Recommendation: We recommend that the Department review the supporting documentation for the amounts charged to the grant to determine if the grant was overcharged and determine any necessary appropriate resolution for the closed grant program. Prior Year Single Audit Report Finding Number: None Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 111.

Corrective Action Plan

The South Carolina Department of Social Services respectfully submits the following corrective action plan for the year ended June 30, 2021. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS?FEDERAL AWARD PROGRAM AUDIT U. S. Department of Health and Human Services 2021-016 Coronavirus Relief Fund? Assistance Listing No. 21.019 Recommendation: We recommend that the Department review the supporting documentation for the amounts charged to the grant to determine if the grant wasovercharged and determine any necessary appropriate resolution for the closed grant program. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Of the approximate $16 million in total Coronavirus Relief Fund expenditures reported, which included thousands of individual expenditure documents, three duplicate expenditure documents totaling $4,691 have been found to have escaped detection by staff, Department management, and by the firm engaged to review and approve all program reimbursements. The Department will conduct a thorough search for additional duplicate document numbers in the entire population of expenditure documents reimbursed. Management does not expect the total thus returned to be material. Name(s) of the contact person(s) responsible for corrective action: Ashley Harris, Assistant Controller Planned completion date for corrective action plan: April 30, 2022

About Allowable Costs / Cost Principles →
2021-017
Reporting
SIGNIFICANT DEFICIENCYOTHER MATTERS

FFATA reporting and timing discrepancies were identified. Questioned Costs: None Context: Seven subawards were selected for testing and the following compliance discrepancies were identified during the testing: The reported subaward obligation/action date did not agree to the subaward agreement date for five subawards tested. The reported subaward Data Universal Numbering System (DUNS) number did not agree to the DUNS number on the subaward for one subaward tested. For the subawards tested, the action was not reported in the Federal Subaward Reporting System (FSRS) by the last day of the month following the month that the subaward was made. The Office was not able to access FSRS for one of the subawards selected in order to test reporting compliance for that subaward. Cause: Data entry errors and administrative delays led to the compliance errors identified in the testing. Effect: Some information was not reported timely or accurately in accordance with the federal requirements. Recommendation: We recommend that the Office strengthen its internal controls over FFATA reporting to ensure that all reporting is timely and accurate in accordance with the federal requirements. Prior Year Single Audit Report Finding Number: Not applicable Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 113.

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Federal Agency: Department of Homeland Security Federal Program Title: Hazard Mitigation Grant Program Assistance Listing: 97.039 Federal Grant ID Number: Various Pass-Through Entity: Not applicable Award Period: Various Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: 2 CFR 170 Appendix A specifies the reporting and timing requirements for Federal Funding Accountability and Transparency Act (FFATA) reporting. Condition: FFATA reporting and timing discrepancies were identified. Questioned Costs: None Context: Seven subawards were selected for testing and the following compliance discrepancies were identified during the testing: The reported subaward obligation/action date did not agree to the subaward agreement date for five subawards tested. The reported subaward Data Universal Numbering System (DUNS) number did not agree to the DUNS number on the subaward for one subaward tested. For the subawards tested, the action was not reported in the Federal Subaward Reporting System (FSRS) by the last day of the month following the month that the subaward was made. The Office was not able to access FSRS for one of the subawards selected in order to test reporting compliance for that subaward. Cause: Data entry errors and administrative delays led to the compliance errors identified in the testing. Effect: Some information was not reported timely or accurately in accordance with the federal requirements. Recommendation: We recommend that the Office strengthen its internal controls over FFATA reporting to ensure that all reporting is timely and accurate in accordance with the federal requirements. Prior Year Single Audit Report Finding Number: Not applicable Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 113.

Corrective Action Plan

The South Carolina Adjutant General?s Office respectfully submits the following Corrective Action Plan for the year ended 6/30/21. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS?FEDERAL AWARD PROGRAM AUDIT U.S. Department of Homeland Security 2021-017 Hazard Mitigation Grant Program ? Assistance Listing No. 97.039 Recommendation: We recommend that the Office strengthen its internal controls over FFATA reporting to ensure that all reporting is timely and accurate in accordance with the federal requirements. Explanation of disagreement with audit finding: The Agency concurs with the audit finding. Action taken in response to finding: The Hazard Mitigation team has assigned staff to check and correct all project award dates in SCEMD?s South Carolina Recovery Grants (SCRecoveryGrants.org; known as SCRG) system to ensure the date in SCRG matches the award date on FEMA?s award letter for the respective project. The Hazard Mitigation team is reinforcing in staff training the requirement that when entering HMGP award information in SCRG, the enterer must select the award date from the drop-down menu rather than allow the system to default to the entry date. The above two steps will provide the correct award date in SCRG for Finance and Administration staff to pull the award date matching the award letter for FFATA reporting purposes (will avoid discrepancies). The Finance and Administration team will pull records for FFATA reporting by obligation date instead of pulling records of reimbursements processed; this action will correct the reporting dates in FSRS. The Finance and Administration team will continue to save a pdf record of the monthly reports. Name(s) of the contact person(s) responsible for corrective action: Candice Shealey, SCEMD State Hazard Mitigation Officer: Brittany Hammond, SCEMD Chief of Finance and Administration. Planned completion date for corrective action plan: April 15, 2022

About Reporting →
2021-018
Cash Management
MATERIAL WEAKNESSMODIFIED OPINIONREPEAT OF 2020-019

Advanced funds were not expended within the required timeframe to minimize the time elapsing between drawdown and disbursement. Questioned Costs: None Context: From forty drawdown transactions selected for testing, nineteen grants were identified as having unspent advance funds after forty-five days from the date the funds were advanced. Cause: The timeframe for determining and returning excess advance funding exceeded forty-five days. Effect: Advance funding was not spent or returned within forty-five days of receipt as required by federal regulation. Recommendation: We recommend that the Office continue the implementation of corrective action to strengthen its internal controls over advance payments in order to demonstrate compliance with the federal requirements. Prior Year Single Audit Report Finding Number: 2020-19 Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 114.

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Federal Agency: Department of Defense Federal Program Title: National Guard Military Operations and Maintenance (O&M) Projects Assistance Listing: 12.401 Federal Grant ID Number: Various Pass-Through Entity: Not applicable Award Period: October 1, 2019 through September 30, 2021 Type of Finding: Material weakness in internal control over compliance, material noncompliance Criteria: National Guard Regulation (NGR) 5-1, Chapter 11-5 requires advance payments be disbursed by the state within forty-five days. Condition: Advanced funds were not expended within the required timeframe to minimize the time elapsing between drawdown and disbursement. Questioned Costs: None Context: From forty drawdown transactions selected for testing, nineteen grants were identified as having unspent advance funds after forty-five days from the date the funds were advanced. Cause: The timeframe for determining and returning excess advance funding exceeded forty-five days. Effect: Advance funding was not spent or returned within forty-five days of receipt as required by federal regulation. Recommendation: We recommend that the Office continue the implementation of corrective action to strengthen its internal controls over advance payments in order to demonstrate compliance with the federal requirements. Prior Year Single Audit Report Finding Number: 2020-19 Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 114.

Corrective Action Plan

The South Carolina Adjutant General?s Office respectfully submits the following Corrective Action Plan for the year ended 6/30/21. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS?FEDERAL AWARD PROGRAM AUDIT U.S. Department of Defense 2021-018 National Guard Military Operations and Maintenance (O&M) Projects ? Assistance Listing No. 12.401 Recommendation: We recommend that the Office continue the implementation of corrective action to strengthen its internal controls over advance payments in order to demonstrate compliance with the federal requirements. Explanation of disagreement with audit finding: The Agency concurs with the audit finding. Action taken in response to finding: The Grants and Agreements Section will implement additional procedures to strengthen internal controls over advance payments in order to demonstrate compliance with the Federal requirements. The Grants and Agreements Section will provide additional information to Program Managers and/or State and Federal Budget Analysts concerning the details of the amounts of the advance funds requested for each appendix. This information will include the dollar amounts of expenditure categories needed for the advance funding amount requested for the applicable time period. The Program Manager and/or Federal and State Budget Analysts for each appendix will develop a spreadsheet to track expenditures that have occurred period to date, by expenditure categories, used in the Federal Army and Air Guard Accounting Systems for processing of expenditures and payments for the Cooperative Agreements. This spreadsheet will also track the amounts of the remaining Federal budgets for each appendix and the amounts of the advance funding available for use for each appendix. Each Program Manager and/or Federal and State Budget Analysts for each appendix will submit a copy of all spreadsheets to the Grants and Agreements Section on a monthly basis. The Grants and Agreements Section will maintain a copy of the spreadsheet. No later than the fifth working day of the first month of the new Federal Fiscal Year (October), the Grants and Agreements Section will complete a final reconciliation of State and Federal Accounting data for each appendix for the previous Federal Fiscal Year. The Grants Administrator will make a determination, based on reconciliation of account balances, of the amount of advance funding for each appendices that the Agency should return to the Federal Government. The Grants and Agreements Section will ensure all remaining advance funding is returned to the Federal Government within forty-five (45) days after the end of the Federal Fiscal Year. Name(s) of the contact person(s) responsible for corrective action: Alex Counts Planned completion date for corrective action plan: May 31, 2022

Prior Finding References

2020-019

About Cash Management →
2021-019
Period of Performance
SIGNIFICANT DEFICIENCYREPEAT OF 2020-020QUESTIONED COSTSOTHER MATTERS

Expenditures, which did not meet the applicable requirements, were charged prior to and after the program?s period of performance. Questioned Costs: $521 Context: Forty expenditure transactions were selected for testing from costs recorded during the first period of the program grants. One of the forty transactions tested was for a cost incurred prior to the applicable period of performance. In addition, nine transactions were selected for testing from costs recorded to program grants beyond ninety days after the close of the federal fiscal year. One of the nine transactions tested was not included on the detailed listing of unliquidated claims and undisbursed obligations. Cause: Office controls failed to prevent charging the grant for a cost incurred outside the applicable period of performance. Effect: Costs charged outside the period of performance may not be allowable. Recommendation: We recommend that the Office continue the implementation of corrective action to strengthen its internal controls to ensure documented compliance with all federal period of performance requirements. Prior Year Single Audit Report Finding Number: 2020-20 Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 115.

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Federal Agency: Department of Defense Federal Program Title: National Guard Military Operations and Maintenance (O&M) Projects Assistance Listing: 12.401 Federal Grant ID Number: W912QG-20-2-1001, W912QG-21-2-1001 Pass-Through Entity: Not applicable Award Period: October 1, 2019 through September 30, 2021 Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: 2 CFR 200.403(h) requires costs be incurred during the approved budget period. NGR 5-1, Chapter 11-2 requires the obligation of funds within the federal fiscal year or period of federal availability. Per NGR 5-1, Chapter 11-10, if unliquidated claims and undisbursed obligations remain ninety days after the close of the federal fiscal year, the recipient shall provide a detailed listing of uncleared obligations no later than December 31. Condition: Expenditures, which did not meet the applicable requirements, were charged prior to and after the program?s period of performance. Questioned Costs: $521 Context: Forty expenditure transactions were selected for testing from costs recorded during the first period of the program grants. One of the forty transactions tested was for a cost incurred prior to the applicable period of performance. In addition, nine transactions were selected for testing from costs recorded to program grants beyond ninety days after the close of the federal fiscal year. One of the nine transactions tested was not included on the detailed listing of unliquidated claims and undisbursed obligations. Cause: Office controls failed to prevent charging the grant for a cost incurred outside the applicable period of performance. Effect: Costs charged outside the period of performance may not be allowable. Recommendation: We recommend that the Office continue the implementation of corrective action to strengthen its internal controls to ensure documented compliance with all federal period of performance requirements. Prior Year Single Audit Report Finding Number: 2020-20 Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 115.

Corrective Action Plan

The South Carolina Adjutant General?s Office respectfully submits the following Corrective Action Plan for the year ended 6/30/21. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS?FEDERAL AWARD PROGRAM AUDIT U.S. Department of Defense 2021-019 National Guard Military Operations and Maintenance (O&M) Projects ? Assistance Listing No. 12.401 Recommendation: We recommend that the Office continue the implementation of corrective action to strengthen its internal controls to ensure documented compliance with all federal period of performance requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Grants and Agreements Section will implement additional procedures to strengthen internal controls to ensure documented compliance with all federal period of performance requirements. The Grants and Agreements Section will send each Program Manager and/or their Federal and State Budget Analysts a detailed listing of the remaining balances of purchase orders and funds reservations to on a monthly basis to ensure accuracy and compliance for each appendix. Each Program Manager and/or their Federal and State Budget Analysts will provide a mandatory response to ensure accuracy or needed changes. The Grants and Agreements Section will maintain a copy of the listing and responses. The Grants and Agreements Section will submit a monthly detailed listing of expenditures for all appendices to each Program Manager and/or their Federal and State Budget Analysts for all open Federal Fiscal Years to ensure accuracy and compliance. Program Managers and/or their Federal and State Budget Analysts will provide a mandatory response to ensure accuracy or needed changes. The Grants and Agreements Section will maintain a copy of responses. The Grants and Agreements Section will review all expenditures for each appendix for accuracy and compliance. The Grants and Agreements Section will maintain documentation for accuracy and changes. Program Managers and/or Federal and State Budget Analysts for each appendix will develop and maintain a spreadsheet for tracking invoices for each open Federal Fiscal Year. Program Managers and/or Federal and State Budget Analysts will submit a copy of the spreadsheet to Grants and Agreements on a monthly basis. The Grants and Agreements Section will maintain a copy of the spreadsheet. Name(s) of the contact person(s) responsible for corrective action: Alex Counts Planned completion date for corrective action plan: May 31, 2022

Prior Finding References

2020-020

About Period of Performance →
2021-020
Activities Allowed or Unallowed / Cost Allowability
MATERIAL WEAKNESSQUESTIONED COSTSOTHER MATTERS

Indirect costs were improperly charged to the CRF. Questioned Costs: $4,590,544 Context: While examining expenditure populations to evaluate which costs were direct and material to the CRF, we noted activity charged to general ledger accounts designated for indirect costs. Cause: Department controls failed to prevent the identified noncompliance issue noted above. Effect: The identified indirect costs resulted in noncompliance with federal regulations and applicable allowable activities/costs requirements. Recommendation: We recommend the Department strengthen controls to ensure that all costs charged to the CRF are for allowable grant activities and costs. Prior Year Single Audit Finding Number: Not applicable Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 117.

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Federal Agency: Department of the Treasury Federal Program Title: Coronavirus Relief Fund ? COVID-19 Assistance Listing No.: 21.019 Federal Grant ID Number: None provided Pass-Through Entity: South Carolina Department of Administration Award Period: March 1, 2020 through December 31, 2021 Type of Finding: Material weakness in internal control over compliance, other matters Criteria: Per Federal Register Notice Volume 86, Number 10, payments from the Coronavirus Relief Fund (CRF) are not administered as part of a traditional grant program. The provisions of the Uniform Guidance, 2 CFR 200, that are applicable to indirect costs do not apply. Recipients do not apply their indirect cost rates to payments received from the CRF. Additionally, per 2 CFR 200.303, the 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. Condition: Indirect costs were improperly charged to the CRF. Questioned Costs: $4,590,544 Context: While examining expenditure populations to evaluate which costs were direct and material to the CRF, we noted activity charged to general ledger accounts designated for indirect costs. Cause: Department controls failed to prevent the identified noncompliance issue noted above. Effect: The identified indirect costs resulted in noncompliance with federal regulations and applicable allowable activities/costs requirements. Recommendation: We recommend the Department strengthen controls to ensure that all costs charged to the CRF are for allowable grant activities and costs. Prior Year Single Audit Finding Number: Not applicable Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 117.

Corrective Action Plan

US Department of Health and Human Services The South Carolina Department of Health and Environmental Control respectfully submits the following corrective action plan for the year ended 6/30/21. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS?FEDERAL AWARD PROGRAM AUDIT DEPARTMENT OF THE TREASURY 2021-020 Coronavirus Relief Fund (CRF) ? Assistance Listing No. 21.019 Recommendation: We recommend that the Department strengthen controls to ensure that all costs charged to the CRF are for allowable grant activities and costs. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: To strengthen internal controls, the Department discussed the finding with staff to reiterate the importance of ensuring grant awards are thoroughly reviewed and appropriate staff are aware of the terms and conditions related to activities that are deemed allowable, as well as activities that would be deemed unallowable. In addition, the unallowed costs will be returned to the grantor. Name(s) of the contact person(s) responsible for corrective action: Kim Paradeses Planned completion date for corrective action plan: June 30, 2022

About Activities Allowed or Unallowed, Allowable Costs / Cost Principles →
2021-021
Reporting
SIGNIFICANT DEFICIENCYOTHER MATTERS

Discrepancies existed between the federal financial report (FFR) and the Department?s supporting records. Additionally, not all information reported on the FFR was reviewed by an employee other than the report preparer prior to submission. Questioned Costs: None Context: We tested information reported for all four FFR Payment Management System (PMS) document numbers that were required to be submitted for the reporting period ending July 31, 2020, for federal grant number 6 NU50CK000542-01-08. We noted two discrepancies between the FFR associated with PMS document number 19NU50CK000542 (nonprevention and public health funds) and the Department?s supporting records. The federal share of indirect costs was understated by $54,195 because the incorrect indirect cost base amount was transferred from the supporting worksheets to the FFR. Moreover, the federal share of expenditures did not agree to the supporting worksheets by approximately $2,450. Additionally, the FFR component for PMS document number 19NU50CK000542C4 (COVID-19 paycheck protection and Health Care Enhancement Act response activities) was prepared and submitted by the same individual. Cause: Department controls failed to identify and correct discrepancies noted in the federal reports prior to submission. Effect: The FFR amounts did not agree to supporting documentation. Additionally, without a supervisory review, there is an increased risk of inaccurate reporting. Recommendation: We recommend that the Department strengthen policies and procedures to ensure that all information reported on federal reports is accurate and that a segregation of duties exists between report preparers and reviewers. Prior Year Single Audit Finding Number: Not applicable Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 118.

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Federal Agency: Department of Health and Human Services Federal Program Title: Epidemiology and Laboratory Capacity for Infectious Diseases ? COVID 19 Assistance Listing No.: 93.323 Federal Grant ID Number: 6 NU50CK000542-01-08 Pass-Through Entity: Not applicable Award Period: August 1, 2019 through July 31, 2024 Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: Per 2 CFR 200.303, the 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 be in compliance with guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States and the "Internal Control Integrated Framework", issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: Discrepancies existed between the federal financial report (FFR) and the Department?s supporting records. Additionally, not all information reported on the FFR was reviewed by an employee other than the report preparer prior to submission. Questioned Costs: None Context: We tested information reported for all four FFR Payment Management System (PMS) document numbers that were required to be submitted for the reporting period ending July 31, 2020, for federal grant number 6 NU50CK000542-01-08. We noted two discrepancies between the FFR associated with PMS document number 19NU50CK000542 (nonprevention and public health funds) and the Department?s supporting records. The federal share of indirect costs was understated by $54,195 because the incorrect indirect cost base amount was transferred from the supporting worksheets to the FFR. Moreover, the federal share of expenditures did not agree to the supporting worksheets by approximately $2,450. Additionally, the FFR component for PMS document number 19NU50CK000542C4 (COVID-19 paycheck protection and Health Care Enhancement Act response activities) was prepared and submitted by the same individual. Cause: Department controls failed to identify and correct discrepancies noted in the federal reports prior to submission. Effect: The FFR amounts did not agree to supporting documentation. Additionally, without a supervisory review, there is an increased risk of inaccurate reporting. Recommendation: We recommend that the Department strengthen policies and procedures to ensure that all information reported on federal reports is accurate and that a segregation of duties exists between report preparers and reviewers. Prior Year Single Audit Finding Number: Not applicable Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 118.

Corrective Action Plan

US Department of Health and Human Services The South Carolina Department of Health and Environmental Control respectfully submits the following corrective action plan for the year ended 6/30/21. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS?FEDERAL AWARD PROGRAM AUDIT DEPARTMENT OF HEALTH AND HUMAN SERVICES 2021-021 Epidemiology and Laboratory Capacity for Infectious Diseases ? Covid 19 ? Assistance Listing No. 93.323 Recommendation: We recommend that the Department strengthen policies and procedures to ensure that all information reported on federal reports is accurate and that a segregation of duties exists between report preparers and reviewers. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: To strengthen internal controls, the Department will develop and implement specific policies and standard operating procedures defining the Federal Financial Report (FFR) process and documenting the review and approval roles. All workpapers will be reviewed by staff other than the preparer of the FFR. Approvals will be documented. Name(s) of the contact person(s) responsible for corrective action: Kim Paradeses Planned completion date for corrective action plan: June 30, 2022

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2021-022
Period of Performance
SIGNIFICANT DEFICIENCYOTHER MATTERS

An expenditure was incurred after the end of the grant?s period of performance. Questioned Costs: Undetermined Context: For 1 of 40 expenditure transactions tested, program expenditures were incurred subsequent to the end of the grant?s period of performance (September 30, 2020). Cause: The Department?s internal controls failed to identify and prevent expenditures from being charged outside the grant?s period of performance. Effect: The Department may request reimbursement for expenses not incurred within the period of performance. Recommendation: We recommend that the Department strengthen internal controls to ensure all expenditures charged to federal awards are incurred during the grant's period of performance. Prior Year Single Audit Finding Number: Not applicable Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 118.

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Federal Agency: Department of Agriculture Federal Program Title: Special Supplemental Nutrition Program for Women, Infants, and Children (WIC) Assistance Listing No.: 10.557 Federal Grant ID Number: 5SC700715 Pass-Through Entity: Not applicable Award Period: October 1, 2019 through September 30, 2020 Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: 2 CFR 200.403(h) states that costs must be incurred during the approved budget period. Condition: An expenditure was incurred after the end of the grant?s period of performance. Questioned Costs: Undetermined Context: For 1 of 40 expenditure transactions tested, program expenditures were incurred subsequent to the end of the grant?s period of performance (September 30, 2020). Cause: The Department?s internal controls failed to identify and prevent expenditures from being charged outside the grant?s period of performance. Effect: The Department may request reimbursement for expenses not incurred within the period of performance. Recommendation: We recommend that the Department strengthen internal controls to ensure all expenditures charged to federal awards are incurred during the grant's period of performance. Prior Year Single Audit Finding Number: Not applicable Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 118.

Corrective Action Plan

US Department of Health and Human Services The South Carolina Department of Health and Environmental Control respectfully submits the following corrective action plan for the year ended 6/30/21. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS?FEDERAL AWARD PROGRAM AUDIT DEPARTMENT OF AGRICULTURE 2021-022 Special Supplemental Nutrition Program for Women, Infants, and Children (WIC) Assistance Listing No. 10.557 Recommendation: We recommend that the Department strengthen internal controls to ensure all expenditures charged to federal awards are incurred during the grant's period of performance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: To strengthen internal controls, the Department?s Program/Region staff will provide periodic reminders to appropriate staff regarding the selection of grants and the associated period of performance when processing payments. In addition, the Department?s Program/Region staff will perform post-closing reviews of expenditures to ensure the proper grant funding was used. Budget staff will monitor post-closing budget balances to assure only the balance of the unliquidated obligations remain on the books until the final FFR has been submitted. Name(s) of the contact person(s) responsible for corrective action: Kim Paradeses Planned completion date for corrective action plan: June 30, 2022

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FY 2021-06-30

$12,501,392,696 federal awards expended

FAC accepted this audit on April 26, 2022 — management decision was due October 26, 2022.

2021-001
Reporting
MATERIAL WEAKNESSREPEAT OF 2020-002

The Agency did not submit certain quarterly reports to the United States Department of Labor ("National Office") by the required due dates. Accordingly, the Agency did not comply with the Reporting compliance requirements related to the Unemployment Insurance program. Criteria: Per Part 4 of the OMB Compliance Supplement: The ETA 191 Report is required to be submitted on a quarterly basis to the National Office by the 25th of the month following the close of the quarter. Cause: Internal controls are not in place to ensure that all required reports are being submitted in accordance with the United States Department of Labor's timelines. The reports were affected by the unprecedented COVID-19 pandemic, which required all program resources to focus on pandemic claims processing. Some of the data needed for these reports was delayed due to program and system resources focused on claims processing as well as the difficulty experienced due to the requirement of staff to shelter at home beginning April 2020 under the South Carolina Governor's Executive Order and restricted access to records located in the office. Effect: As a result, the Agency becomes more susceptible to having its level of federal award funding reduced by the United States Department of Labor when it violates its Reporting compliance requirements applicable to the Unemployment Insurance program. Context: We inspected a sample of quarterly reports and noted the following exceptions: Unemployment Insurance - Three (3) ETA 191 quarterly reports of the four (4) reports tested. Recommendation: We recommend that management carefully review the terms and conditions included in the supporting grant agreements and the Reporting requirements included in the OMB Compliance Supplement applicable to the Unemployment Insurance and the Employment Services Cluster programs and implement controls to ensure that all reports are filed on a timely basis.

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Item 2021-001: Reporting (Material Weakness over Reporting and Non-Material Noncompliance) Condition: The Agency did not submit certain quarterly reports to the United States Department of Labor ("National Office") by the required due dates. Accordingly, the Agency did not comply with the Reporting compliance requirements related to the Unemployment Insurance program. Criteria: Per Part 4 of the OMB Compliance Supplement: The ETA 191 Report is required to be submitted on a quarterly basis to the National Office by the 25th of the month following the close of the quarter. Cause: Internal controls are not in place to ensure that all required reports are being submitted in accordance with the United States Department of Labor's timelines. The reports were affected by the unprecedented COVID-19 pandemic, which required all program resources to focus on pandemic claims processing. Some of the data needed for these reports was delayed due to program and system resources focused on claims processing as well as the difficulty experienced due to the requirement of staff to shelter at home beginning April 2020 under the South Carolina Governor's Executive Order and restricted access to records located in the office. Effect: As a result, the Agency becomes more susceptible to having its level of federal award funding reduced by the United States Department of Labor when it violates its Reporting compliance requirements applicable to the Unemployment Insurance program. Context: We inspected a sample of quarterly reports and noted the following exceptions: Unemployment Insurance - Three (3) ETA 191 quarterly reports of the four (4) reports tested. Recommendation: We recommend that management carefully review the terms and conditions included in the supporting grant agreements and the Reporting requirements included in the OMB Compliance Supplement applicable to the Unemployment Insurance and the Employment Services Cluster programs and implement controls to ensure that all reports are filed on a timely basis.

Corrective Action Plan

Item 2021-001 Reporting (Material Weakness over reporting and Non-Material Noncompliance) SCDEW implemented a corrective action plan in response to this finding during the year ended June 30, 2021 in response to similar finding for audits of prior periods a brief summary follows: The SCDEW Enterprise and Project Management Office (EPMO) is tasked with monitoring agency wide reporting deadlines. The EPMO developed a master reporting database that includes relevant identifying information including report names, Agency, SCDEW contact, reporting frequency and due dates. Individual reporters at SCDEW submit data to EPMO on the status of the required filings. EPMO routinely reports the status of filings to executive leadership.

Prior Finding References

2020-002

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2021-001
Eligibility
MATERIAL WEAKNESSMODIFIED OPINIONQUESTIONED COSTS

In March 2020, the President signed the CARES Act that authorized additional funding under the Unemployment Insurance (UI) program. This was followed by additional federal and state funding programs that increased grants available and modified eligibility requirements to support changes in employment status caused by the COVID-19 pandemic. Certain benefits under these programs extended into fiscal year 2022. Subsequent to June 30, 2020, supplemental assistance provided by the CARES Act and other federal legislation supported elevated sustained benefit payments through June 2021 in excess of $3.6 billion. South Carolina ended its participation in the supplementary federal programs in June 2021 and has seen benefit payments drop significantly returning to pre-pandemic levels by October 2021. There was a priority on distributing funds under self-attestation strategy with limited income verification to expedite disbursement of funds and support individuals in greatest need. As a result of this, many states saw a significant increase in fraudulent claims to historical highs. The U.S. Department of Labor and the Agency have partnered to investigate the extent and methods used to perpetrate fraud. For the Agency, eligibility determinations made by the management followed existing policies and procedures for this pandemic funding; however, to meet federal and state expectations regarding the quick payment of federal pandemic benefits, the policies and procedures in place were not the usual policies and procedures and so they were not adequate to completely prevent fraudulent claims. The Agency’s detective controls did identify abnormal claim activity; however, it was after the claims had already been paid. During our testing of a sample of 360 benefit payments we identified 23 payments that were fraudulent, total value of payments tested was $109,375 and total amount of fraud was $7,230. The extrapolated fraud amount over the total benefit payment of $3.757 billion would be $252.9 million. Criteria: Per 2 CFR §200 Appendix XI, state responsibilities include: (1) establishing specific, detailed policies and operating procedures which comply with the requirements of federal laws and regulations; (2) determining the state unemployment insurance tax structure; (3) collecting state unemployment insurance contributions from employers (commonly called “unemployment taxes”); (4) determining claimant eligibility and disqualification provisions; (5) making payment of UI benefits to claimants; (6) managing the program’s revenue and benefit administrative functions; (7) administering the programs in accordance with established policies and procedures; and (8) enacting state UC law that conforms with federal UC law and that state law and operations substantially comply with federal law. Effect: A lack of adequate internal controls over eligibility determinations may increase the likelihood of fraudulent claims being submitted and incorrectly paid. Known Questioned Costs: During our testing of a sample of 360 benefit payments we identified 23 payments that were fraudulent, the total value of payments tested was $109,375 and total amount of known fraud was $7,230. Likely Questioned Costs: Based upon the extrapolated fraud amount over the total benefit payment of $3.757 billion the total amount of fraud would likely be $252.9 million. Cause: The Agency experienced unprecedented claims volume during fiscal 2021 with increased funding and additional program requirements with a priority for efficient distribution from both the U.S. Department of Labor and state officials. Recommendation: We recommend that the Agency continue to review, monitor, and enhance eligibility procedures to detect and/or prevent fraudulent claimants from receiving benefits. The Agency should work to enhance and update its assessment of risks related to the eligibility process and implement internal controls to help mitigate future fraudulent claims.

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Condition: In March 2020, the President signed the CARES Act that authorized additional funding under the Unemployment Insurance (UI) program. This was followed by additional federal and state funding programs that increased grants available and modified eligibility requirements to support changes in employment status caused by the COVID-19 pandemic. Certain benefits under these programs extended into fiscal year 2022. Subsequent to June 30, 2020, supplemental assistance provided by the CARES Act and other federal legislation supported elevated sustained benefit payments through June 2021 in excess of $3.6 billion. South Carolina ended its participation in the supplementary federal programs in June 2021 and has seen benefit payments drop significantly returning to pre-pandemic levels by October 2021. There was a priority on distributing funds under self-attestation strategy with limited income verification to expedite disbursement of funds and support individuals in greatest need. As a result of this, many states saw a significant increase in fraudulent claims to historical highs. The U.S. Department of Labor and the Agency have partnered to investigate the extent and methods used to perpetrate fraud. For the Agency, eligibility determinations made by the management followed existing policies and procedures for this pandemic funding; however, to meet federal and state expectations regarding the quick payment of federal pandemic benefits, the policies and procedures in place were not the usual policies and procedures and so they were not adequate to completely prevent fraudulent claims. The Agency’s detective controls did identify abnormal claim activity; however, it was after the claims had already been paid. During our testing of a sample of 360 benefit payments we identified 23 payments that were fraudulent, total value of payments tested was $109,375 and total amount of fraud was $7,230. The extrapolated fraud amount over the total benefit payment of $3.757 billion would be $252.9 million. Criteria: Per 2 CFR §200 Appendix XI, state responsibilities include: (1) establishing specific, detailed policies and operating procedures which comply with the requirements of federal laws and regulations; (2) determining the state unemployment insurance tax structure; (3) collecting state unemployment insurance contributions from employers (commonly called “unemployment taxes”); (4) determining claimant eligibility and disqualification provisions; (5) making payment of UI benefits to claimants; (6) managing the program’s revenue and benefit administrative functions; (7) administering the programs in accordance with established policies and procedures; and (8) enacting state UC law that conforms with federal UC law and that state law and operations substantially comply with federal law. Effect: A lack of adequate internal controls over eligibility determinations may increase the likelihood of fraudulent claims being submitted and incorrectly paid. Known Questioned Costs: During our testing of a sample of 360 benefit payments we identified 23 payments that were fraudulent, the total value of payments tested was $109,375 and total amount of known fraud was $7,230. Likely Questioned Costs: Based upon the extrapolated fraud amount over the total benefit payment of $3.757 billion the total amount of fraud would likely be $252.9 million. Cause: The Agency experienced unprecedented claims volume during fiscal 2021 with increased funding and additional program requirements with a priority for efficient distribution from both the U.S. Department of Labor and state officials. Recommendation: We recommend that the Agency continue to review, monitor, and enhance eligibility procedures to detect and/or prevent fraudulent claimants from receiving benefits. The Agency should work to enhance and update its assessment of risks related to the eligibility process and implement internal controls to help mitigate future fraudulent claims.

Corrective Action Plan

The South Carolina Department of Employment and Workforce (SCDEW) immediately recognized the increased fraud risk presented by the federal pandemic programs. ln an effort to deter this obvious fraud threat, SCDEW initially informed every applicant for federal pandemic benefits that they might be required to provide proof of their employment or self-employment at a future time. The USDOL, however, ordered SCDEW to remove this notification because, in the words of one USDOL representative, such a warning might deter a claimant from applying for federal pandemic benefits. USDOL subsequently issued guidance prohibiting states from requiring proof of employment or self-employment as an eligibility requirement to receive federal pandemic benefits. Therefore, all a fraudster had to do to receive federal benefits was simply tell a state they were unemployed as a result of the COVID-19 pandemic. SCDEW was prohibited from requiring that fraudster to prove that they were even employed, let alone that they were unemployed because of the pandemic. Many of the items identified as paid fraudulent claims were caused by SCDEW's compliance with the USDOL guidelines. SCDEW complied with this guidance, even though it disagreed with USDOL's highly technical parsing of federal law, and SCDEW advocated for Congress to amend the law to clearly establish commonsense fraud protections. While awaiting Congressional action, SCDEW implemented numerous fraud detection and prevention tools and strategies to minimize the potential fraud exacerbated by lax federal requirements. Unfortunately, Congress did not amend the law until late December 2020. As a result, eligibility determinations made by SCDEW prior to the law change followed the federal guidance for this pandemic funding; however, to meet federal and state expectations regarding the quick payment of federal pandemic benefits, the federal policies and procedures SCDEW was forced to adopt were not adequate to completely prevent fraudulent claims. SCDEW continues to review, monitor, and enhance eligibility processes and procedures to prevent and detect fraudulent claims. We also updated our internal controls to help mitigate future fraudulent claims. The COVID pandemic created unprecedented challenges for eve1y state workforce agency due to the combination of historic claim volume, the availability of a staggering amount of federal money, and new programs with lax eligibility and verification requirements that had to be implemented quickly, despite often changing federal guidance. These factors created a perfect storm for sophisticated fraudsters 10 exploit. In response, SCDEW took numerous aggressive steps. In mid-2020, SCDEW required applicants to provide copies of their driver's license or passport to prove their identity before receiving benefits. SCDEW also implemented identity verification questions through Lexis Nexis that every claimant had to pass before processing a claim. This was further enhanced in March 2021, when South Carolina was one of the first states to implement digital identity verification through ID.me. SCDEW also implemented reCAPTCHA to prevent against bot attacks, implemented new data sharing agreements, and increased the number of staff dedicated to investigating fraudulent claim activity to over fifty at the peak of the pandemic programs. SCDEW continuously reviews its fraud detection and prevention activities to stay ahead of emerging fraud schemes. Since the height of the pandemic, SCDEW has increased its data crossmatching, partnered with the State Law Enforcement Division to have a financial fraud investigator dedicated to unemployment insurance fraud, and made numerous enhancements to its computer systems to combat fraud and preserve the integrity of the unemployment insurance system. For more comprehensive explanation and response, please sec August 26, 2024 letter attached from Paul Famolari, Assistant Executive Director of Unemployment Insurance. The Agency's contact person responsible for the corrective action plan is Jacquelyn Carlen, CFO. The completion date of the corrective action plan was June 20, 2021.

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2021-002
Reporting
SIGNIFICANT DEFICIENCYOTHER MATTERS

A reporting discrepancy was identified on a federal financial report filed by the Office. Questioned Costs: None Context: On one of five SF-425 reports selected for testing, reported recipient share of expenditures did not agree to applicable Office supporting documentation. The Office submitted an amended report to correct the discrepancy identified during the audit. Cause: A portion of recipient share activity was mistakenly excluded from the report and the discrepancy was not detected during the Office?s review and approval process. Effect: Recipient share of expenditures was misstated on a federal financial report. Recommendation: We recommend that the Office strengthen its internal controls and processes to ensure that federal reports are free from error prior to submission. Prior Year Single Audit Report Finding Number: Not applicable Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 96.

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Federal Agency: Department of Justice Federal Program Title: Crime Victim Assistance Assistance Listing: 16.575 Federal Grant ID Number: 2017-VA-GX-4040 Pass-Through Entity: Not applicable Award Period: October 1, 2016 through September 30, 2020 Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: Per 2 CFR 200.303 Internal controls, 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. Condition: A reporting discrepancy was identified on a federal financial report filed by the Office. Questioned Costs: None Context: On one of five SF-425 reports selected for testing, reported recipient share of expenditures did not agree to applicable Office supporting documentation. The Office submitted an amended report to correct the discrepancy identified during the audit. Cause: A portion of recipient share activity was mistakenly excluded from the report and the discrepancy was not detected during the Office?s review and approval process. Effect: Recipient share of expenditures was misstated on a federal financial report. Recommendation: We recommend that the Office strengthen its internal controls and processes to ensure that federal reports are free from error prior to submission. Prior Year Single Audit Report Finding Number: Not applicable Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 96.

Corrective Action Plan

U. S. Department of Justice The South Carolina Attorney General?s Office respectfully submits the following corrective action plan for the year ended June 30, 2021. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS?FEDERAL AWARD PROGRAM AUDIT 2021-002 Crime Victim Assistance ? Assistance Listing No. 16.575 Recommendation: We recommend that the Office strengthen is internal controls and processes to ensure that federal reports are free from error prior to submission. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: When generating reports for quarterly FFR, a BW (Business Warehouse) or SCEIS cumulative report will be generated from inception to-date to ensure all federal data is captured accurately. A FFR tracking log will be maintained to reflect quarterly and cumulative match amounts to ensure total effort is reported. Any adjustments will be noted in the tracking log noting the reason for the adjustment. These procedures will be implemented immediately. The agency is currently working to implement a new grants management system that will track federal and match expenditures that will assist with federal reporting to ensure amounts are reported accurately. The projected implementation start date for the new grants accounting system is October 1, 2022. Full implementation will be completed within twelve months. Name(s) of the contact person(s) responsible for corrective action: Kelley Anderson Planned completion date for corrective action plan: Tracking log adjustments will be implemented immediately. If the Federal Cognizant Agency of Oversight or Audit has questions regarding this plan, please call Kelley Anderson at 803-734-0779.

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2021-002
Reporting
MATERIAL WEAKNESSMODIFIED OPINIONREPEAT OF 2020-002

The Agency did not submit certain quarterly reports to the United States Department of Labor (“National Office”) by the required due dates. Accordingly, the Agency did not comply with the Reporting compliance requirements related to the Unemployment Insurance program. Criteria: Per Part 4 of the OMB Compliance Supplement: • The ETA 191 Report is required to be submitted on a quarterly basis to the National Office by the 25th of the month following the close of the quarter. Cause: Internal controls are not in place to ensure that all required reports are being submitted in accordance with the United States Department of Labor’s timelines. The reports were affected by the unprecedented COVID-19 pandemic, which required all program resources to focus on pandemic claims processing. Some of the data needed for these reports was delayed due to program and system resources focused on claims processing. Effect: As a result, the Agency becomes more susceptible to having its level of federal award funding reduced by the United States Department of Labor when it violates its Reporting compliance requirements applicable to the Unemployment Insurance program. Context: We inspected a sample of quarterly reports and noted the following exceptions: • Unemployment Insurance – Three (3) ETA 191 quarterly reports of four (4) reports tested Recommendation: We recommend that management carefully review the terms and conditions included in the supporting grant agreements and the Reporting requirements included in the OMB Compliance Supplement applicable to the Unemployment Insurance and the Employment Services Cluster programs and implement controls to ensure that all reports are filed on a timely basis.

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Condition: The Agency did not submit certain quarterly reports to the United States Department of Labor (“National Office”) by the required due dates. Accordingly, the Agency did not comply with the Reporting compliance requirements related to the Unemployment Insurance program. Criteria: Per Part 4 of the OMB Compliance Supplement: • The ETA 191 Report is required to be submitted on a quarterly basis to the National Office by the 25th of the month following the close of the quarter. Cause: Internal controls are not in place to ensure that all required reports are being submitted in accordance with the United States Department of Labor’s timelines. The reports were affected by the unprecedented COVID-19 pandemic, which required all program resources to focus on pandemic claims processing. Some of the data needed for these reports was delayed due to program and system resources focused on claims processing. Effect: As a result, the Agency becomes more susceptible to having its level of federal award funding reduced by the United States Department of Labor when it violates its Reporting compliance requirements applicable to the Unemployment Insurance program. Context: We inspected a sample of quarterly reports and noted the following exceptions: • Unemployment Insurance – Three (3) ETA 191 quarterly reports of four (4) reports tested Recommendation: We recommend that management carefully review the terms and conditions included in the supporting grant agreements and the Reporting requirements included in the OMB Compliance Supplement applicable to the Unemployment Insurance and the Employment Services Cluster programs and implement controls to ensure that all reports are filed on a timely basis.

Corrective Action Plan

SCDEW implemented a corrective action plan in response to this finding during the year ended June 30, 2021 in response to similar findings in prior year audits. The SCDEW Enterprise and Project Management Office (EPMO) is tasked with monitoring agency wide reporting deadlines. The EPMO developed a master reporting database that includes relevant identifying infom1ation including report name, agency, SCDEW contact, reporting frequency and due dates. Individual reporters at SCDEW submit data to EPMO on the status of the required filings. EPMO routinely reports the status of filings to executive leadership. The Agency's contact person responsible for the corrective action plan is Jacquelyn Carlen, CFO. The completion date of the corrective action plan was September 30, 2022.

Prior Finding References

2020-002

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2021-003
Subrecipient Monitoring
SIGNIFICANT DEFICIENCYOTHER MATTERS

The Office was not in compliance with several subrecipient monitoring requirements. Questioned Costs: None Context: The following discrepancies were encountered during testing of twelve subrecipients selected for testing: Two subrecipient single audit reports were not obtained for review in accordance with federal monitoring requirements. Three subrecipients had single audit findings where documentation was not adequate to demonstrate appropriate follow-up or management decision on the findings. Nine subrecipients did not receive site visits within the timeframe set out in the monitoring plan. Cause: The global pandemic?s impact on staffing and equipment contributed to the Office?s inability to fully comply with certain monitoring requirements. Effect: The Office was not in compliance with certain federal subrecipient monitoring requirements. Recommendation: We recommend that the Office review and strengthen subrecipient monitoring controls and procedures to ensure compliance with all federal subrecipient monitoring requirements. Prior Year Single Audit Report Finding Number: Not applicable Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 96.

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Federal Agency: Department of Justice Federal Program Title: Crime Victim Assistance Assistance Listing: 16.575 Federal Grant ID Number: Various Pass-Through Entity: Not applicable Award Period: Various Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: 2 CFR 200.332 (d) describes pass-through entity requirements for reviewing single audit reports of subrecipients, including requirements for follow-up and management decisions on applicable audit findings. 28 CFR 94.106 (b) specifies the pass-through entity frequency requirements for on-site monitoring of subrecipients. Condition: The Office was not in compliance with several subrecipient monitoring requirements. Questioned Costs: None Context: The following discrepancies were encountered during testing of twelve subrecipients selected for testing: Two subrecipient single audit reports were not obtained for review in accordance with federal monitoring requirements. Three subrecipients had single audit findings where documentation was not adequate to demonstrate appropriate follow-up or management decision on the findings. Nine subrecipients did not receive site visits within the timeframe set out in the monitoring plan. Cause: The global pandemic?s impact on staffing and equipment contributed to the Office?s inability to fully comply with certain monitoring requirements. Effect: The Office was not in compliance with certain federal subrecipient monitoring requirements. Recommendation: We recommend that the Office review and strengthen subrecipient monitoring controls and procedures to ensure compliance with all federal subrecipient monitoring requirements. Prior Year Single Audit Report Finding Number: Not applicable Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 96.

Corrective Action Plan

U. S. Department of Justice The South Carolina Attorney General?s Office respectfully submits the following corrective action plan for the year ended June 30, 2021. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS?FEDERAL AWARD PROGRAM AUDIT 2021-003 Crime Victim Assistance ? Assistance Listing No. 16.575 Recommendation: We recommend that the Office review and strengthen subrecipient monitoring controls and procedures to ensure that it is in compliance with all federal subrecipient monitoring requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Procedures were written to strengthen internal controls to ensure all subrecipients submit single or program specific audits in a timely manner. A step-by-step process of notification, action requirements and follow-up will be implemented immediately. A tracking log will capture the necessary data, such as, date report received, completed review sheet, review of corrective action plan and necessary follow-up to ensure monitoring is complete and compliant with monitoring requirements. Furthermore, the agency is updating its process and tracking system to ensure all site-monitoring is conducted once every three years as stated in procedures for all subgrantees and will be reviewed and approved by the Division Director. Name(s) of the contact person(s) responsible for corrective action: Kelley Anderson and Billy House Planned completion date for corrective action plan: Immediately If the Federal Cognizant Agency of Oversight or Audit has questions regarding this plan, please call Kelley Anderson at 803-734-0779.

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2021-004
Eligibility
MATERIAL WEAKNESSMODIFIED OPINIONREPEAT OF 2020-006

The Department did not consistently perform timely annual eligibility reviews for Medicaid and CHIP recipients in accordance with Section 101.10 of the South Carolina Medicaid Policies and Procedures Manual. Questioned Costs: Unknown Context: We tested 120 individual recipients (60 each for Medicaid and CHIP) to ensure the Department complied with applicable eligibility requirements. We determined the Department did not comply with the annual review requirement for 37 Medicaid recipients and 43 CHIP recipients. Cause: Department personnel stated they did not comply with the annual review requirement for these recipients due to a backlog in case processing. Effect: In the absence of an annual review, Medicaid and CHIP recipients may continue to receive benefits without meeting eligibility requirements. Recommendation: We recommend eligibility reviews be performed annually in accordance with the South Carolina Medicaid Policies and Procedures Manual. Prior Year Single Audit Finding Number: 2020-006 Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 98.

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Federal Agency: Department of Health and Human Services Federal Program Title: Medicaid Cluster; Children?s Health Insurance Program (CHIP) Assistance Listing No.: 93.775, 93.777, 93.778; 93.767 Federal Grant ID Number: 05-2005SC5MAP, 05-1905SC5021 Pass-Through Entity: Not applicable Award Period: October 1, 2018 through September 30, 2021 Type of Finding: Material weakness in internal control over compliance, material noncompliance Criteria: Section 2.1 of the Department?s Title XIX (Medicaid) State Plan (Application, Determination of Eligibility and Furnishing Medicaid) affirms that it meets the requirements outlined in 42 CFR Part 435.916, which states in part, that the agency must promptly determine eligibility between regular renewals of eligibility. In addition, Section 101.10 of the South Carolina Medicaid Policies and Procedures Manual states that the Department must complete an annual review for certain payment categories. Furthermore, the Department?s Title XXI (CHIP) State Plan attests that CHIP will operate as a Medicaid expansion program. Therefore, the aforementioned regulation and policies apply to both programs. Condition: The Department did not consistently perform timely annual eligibility reviews for Medicaid and CHIP recipients in accordance with Section 101.10 of the South Carolina Medicaid Policies and Procedures Manual. Questioned Costs: Unknown Context: We tested 120 individual recipients (60 each for Medicaid and CHIP) to ensure the Department complied with applicable eligibility requirements. We determined the Department did not comply with the annual review requirement for 37 Medicaid recipients and 43 CHIP recipients. Cause: Department personnel stated they did not comply with the annual review requirement for these recipients due to a backlog in case processing. Effect: In the absence of an annual review, Medicaid and CHIP recipients may continue to receive benefits without meeting eligibility requirements. Recommendation: We recommend eligibility reviews be performed annually in accordance with the South Carolina Medicaid Policies and Procedures Manual. Prior Year Single Audit Finding Number: 2020-006 Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 98.

Corrective Action Plan

Department of Health & Human Services Centers for Medicare & Medicaid Services (CMS) 31 Forsyth Street, SW, Room 4T20 Atlanta, Georgia 30303-8909 The South Carolina Department of Health and Human Services respectfully submits the following corrective action plan for the year ended 6/30/21. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS ? FEDERAL AWARD PROGRAM AUDIT DEPARTMENT OF HEALTH AND HUMAN SERVICES 2021-004 Medicaid Cluster; Children?s Health Insurance Program (CHIP) ? Assistance Listing No. 93.775, 93.777, 93.778; 93.767 Recommendation: We recommend eligibility reviews be performed annually in accordance with the South Carolina Medicaid Policies and Procedures Manual. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: In 2021, SCDHHS (the agency) developed a tentative unwinding operational plan for completing pending eligibility and enrollment actions at the conclusion of the public health emergency (PHE). The state is in the process of updating the plan, based on CMS guidance and tools issued on 3/4/22. However, the basic components of the plan are still relevant. Current Activities in Progress ? Policy and procedure updates for unwinding from PHE requirements ? System updates required for unwinding from PHE policies and procedures ? Development of communication plan for sharing relevant information regarding unwinding activities with stakeholders such as beneficiaries, agency staff, call centers, providers, managed care plans and community organizations ? Preparation for outreach strategies to inform beneficiaries about the review process and encourage them to report changes in contact information. Current efforts include texting and outbound calling initiatives. ? Planning for handling increased agency contacts regarding reviews or address changes ? Planning for handling increased appeals that are possible once continuous enrollment period has ended Prioritization of Reviews The agency will use a hybrid approach for the distribution of redeterminations at the end of the PHE. Redeterminations will be prioritized to promote accurate coverage, as well as continuity of coverage. Attention will be given to prevent incorrect decisions that will then likely result in a new application being submitted, unnecessarily adding to the volume of work that must be completed. Continuity of coverage applies to both beneficiaries eligible for Medicaid, as well as those who may be eligible for Marketplace coverage and subsidies. Updated data reporting is in progress to compare to volumes identified earlier in the PHE so that decisions can be made for distribution of prioritized reviews, based on CMS guidelines and the desire to achieve a manageable distribution of reviews for subsequent years. Priority groups include: ? Pregnant Women category greater than 12 months post-partum ? Infants over 1 year old ? Individuals Over 19 in Children?s category ? Parent Caretaker Relatives who no longer have dependent children in the home ? Individuals who have aged out of Foster Care ? Individuals in the Refugee category greater than 8 months from Entry date ? Individuals receiving Medicaid because of Supplemental Security Income (SSI) benefits who will need to provide additional information to assess for eligibility in other categories The agency reached out once to individuals no longer eligible for SSI and are receiving long term care services during the PHE so that they would have the opportunity to provide the needed information and undergo the ex parte process prior to the end of the PHE. Any beneficiaries who did not respond or were found not eligible during the PHE remained in their current payment category and will receive another opportunity after the PHE ends. The remainder of reviews will be distributed across the 12-month period following the end of the PHE to allow for a relatively equal distribution, with consideration for periods of anticipated higher application volume such as open enrollment. Staffing Attrition during the PHE and an increase in workload and anticipation of work to be completed at the end of the PHE has resulted in a significant hiring of MAGI, Non-MAGI and Long-Term Care Eligibility Specialists which will continue at least through the end of federal fiscal year (FFY) 2022, depending on impacts of any additional attrition. Forty-seven (47) Non-MAGI workers have been hired and trained to date and 96 additional Non-MAGI workers are expected to be hired by the end of FFY 2022. Forty-three (43) Long-Term-Care workers have been hired and trained, with an additional 27 to be hired by the end of FFY2022. Approximately 100 additional MAGI staff will be hired as well. The additional staff is intended to build capacity for current work, as well as in preparation for resumption of normal review processing at the end of the continuous enrollment period. Staff are trained to assist with current work upon hiring and all staff will undergo training on redetermination processing in time for reinstatement of the redetermination process at the end of the PHE. Workload Management Workload management is an important component of current operations and will be critical as the state unwinds after the PHE ends. Workload management allows the agency to predict and react to staffing needs and better plan for timely decisions. Eligibility's Workload Management team monitors work queues daily and collaborates with eligibility supervisors and leadership to address timeliness of case processing and distribution of work. This may include shifting work assignments, reprioritization of work, referral to additional training, or other mechanisms to increase efficiency. Name(s) of the contact person(s) responsible for corrective action: Lori Risk Planned completion date for corrective action plan: 14 months from end of PHE or end of continuous enrollment requirement.

Prior Finding References

2020-006

About Eligibility →
2021-005
Eligibility
SIGNIFICANT DEFICIENCYREPEAT OF 2020-004OTHER MATTERS

Eligibility files did not contain adequate documentation to support the Medicaid and CHIP recipients? eligibility statuses. Questioned Costs: Unknown Context: We tested 120 individual recipients (60 each for Medicaid and CHIP) to ensure the Department complied with applicable eligibility requirements. We determined the Department did not maintain adequate documentation of eligibility for ten Medicaid recipients and five CHIP recipients. Cause: The Department transitioned to an online eligibility system, the Medicaid Eligibility Determination System (MEDS), in July 2013. According to Department personnel, documentation in some of the paper files may not have been scanned into the system since the transition. For cases opened after the transition, the omissions were due to worker error. Effect: The Department could not support eligibility determinations in accordance with its State plan. Recommendation: We recommend the Department continue its efforts to maintain documentation to support eligibility determinations in accordance with its State plan and federal regulations. Prior Year Single Audit Finding Number: 2020-004 Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 100.

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Federal Agency: Department of Health and Human Services Federal Program Title: Medicaid Cluster; Children?s Health Insurance Program (CHIP) Assistance Listing No.: 93.775, 93.777, 93.778; 93.767 Federal Grant ID Number: 05-2005SC5MAP; 05-1905SC5021 Pass-Through Entity: Not applicable Award Period: October 1, 2018 through September 30, 2021 Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: Per 42 CFR 435.914 (a), the agency must include in each applicant?s case record facts to support the agency?s decision on his or her application. In addition, Section 4.7 of the Department?s Title XIX (Medicaid) State Plan (Maintenance of Records) affirms that it meets the requirements outlined in 42 CFR 431.17 (b), that a State plan must provide that the Medicaid agency will maintain or supervise the maintenance of records necessary for the proper and efficient operation of the plan. Furthermore, the Department?s Title XXI (CHIP) State Plan attests that CHIP will operate as a Medicaid expansion program. Therefore, the aforementioned regulations apply to both programs. Condition: Eligibility files did not contain adequate documentation to support the Medicaid and CHIP recipients? eligibility statuses. Questioned Costs: Unknown Context: We tested 120 individual recipients (60 each for Medicaid and CHIP) to ensure the Department complied with applicable eligibility requirements. We determined the Department did not maintain adequate documentation of eligibility for ten Medicaid recipients and five CHIP recipients. Cause: The Department transitioned to an online eligibility system, the Medicaid Eligibility Determination System (MEDS), in July 2013. According to Department personnel, documentation in some of the paper files may not have been scanned into the system since the transition. For cases opened after the transition, the omissions were due to worker error. Effect: The Department could not support eligibility determinations in accordance with its State plan. Recommendation: We recommend the Department continue its efforts to maintain documentation to support eligibility determinations in accordance with its State plan and federal regulations. Prior Year Single Audit Finding Number: 2020-004 Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 100.

Corrective Action Plan

Department of Health & Human Services Centers for Medicare & Medicaid Services (CMS) 31 Forsyth Street, SW, Room 4T20 Atlanta, Georgia 30303-8909 The South Carolina Department of Health and Human Services respectfully submits the following corrective action plan for the year ended 6/30/21. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS ? FEDERAL AWARD PROGRAM AUDIT DEPARTMENT OF HEALTH AND HUMAN SERVICES 2021-005 Medicaid Cluster; Children?s Health Insurance Program (CHIP) ? Assistance Listing No. 93.775, 93.777, 93.778; 93.767 Recommendation: We recommend the Department continue its efforts to maintain documentation to support eligibility determinations in accordance with its State plan and federal regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Staff Performance Evaluation and Remediation: The eligibility performance and remediation process continue to include key elements for review which lead to a correct or incorrect eligibility determination, including the presence of required documentation. Eligibility policies and procedures from March 1, 2020, provide instructions for a worker to ensure the case file is complete for all eligibility criteria based on policy, prior to making an eligibility determination. This policy is included in staff training and is evaluated as part of quality assurance activities. The Eligibility Quality Assurance Team (EQAT) members are trained to evaluate MAGI, Non-MAGI or Long-Term Care determinations for accuracy of those determinations, as well as vital procedural errors that are most likely to impact eligibility. On the first business day of each month, supervisors receive employee performance results for their staff. Supervisors are responsible for monitoring staff daily by using data available via system of record, the electronic document management system (OnBase), workload management software, as well as through case spot reviews. Supervisors meet monthly with each staff member to review Eligibility Quality Assurance (EQA) findings to identify and address issues that impact performance, as well as to facilitate corrections to incorrect determinations identified through the EQA process. Errors are identified via error codes and descriptions. EQA reviews are conducted and housed in a state-developed tool to allow for creation of reports that can be generated based on supervisor, worker, work type, error code or overall accuracy. The agency compares errors identified through audits and federal reviews such as payment error rate measurement with EQA error trends and use this monitoring method to identify trends, develop mitigation strategies and to determine impact of those strategies on these errors. In addition, the agency collaborates with our third-party quality review entity, the University of South Carolina Core for Applied Research and Evaluation (USC CARE) to conduct focused reviews to assist with monitoring trends, providing recommendations for mitigation (e.g., policy clarifications, training, or supervisor intervention) and impact of mitigation strategies. During the 4th quarter of calendar year 2021, 10,767 quality reviews were conducted by the EQA team. The agency monitors the following errors and will continue to do so on a quarterly basis: Internal EQA findings: Error Description, Q1 CY2021 % Cases Reviewed, Q2 CY2021 % Cases Reviewed, Q3 CY2021 % Cases Reviewed, Q4 CY2021 % Cases Reviewed: The application was not signed, .03%, .03%, .05%, .04%; The application could not be located in the case file, .05%, .04%, .04%, .02%; Level of care was not in the case file or in Phoenix, .01%, .02%, .01%, .02%; The case record was missing SSN or proof of application for SSN, .49%, .57%, .19%, .20% Policy Update: Currently, Medicaid Policy and Procedure Manual (MPPM) review requirements (MPPM 101.10) include a requirement to review and upload State Data Exchange (SDX) interface data into the casefile for Payment Categories 54 (Supplemental Security Income (SSI) Nursing Home) and 86 (Optional State Supplementation with SSI) each year, to confirm continued SSI eligibility although an annual review itself is not required. As the agency has transitioned to a rules-based system that reacts to SDX interface data updates, stores information in the case record and takes appropriate action in response to updates, this policy will be updated to remove this requirement. Staff Reminders: In response to these findings, the Eligibility department will send email communication to managers, supervisors and staff regarding these findings and a reminder of documentation requirements in policy, as well as to ensure supervisors are assessing for this requirement in casefile spot checks. This will also be discussed on an upcoming Eligibility Supervisor call. Name(s) of the contact person(s) responsible for corrective action: Lori Risk Planned completion date for corrective action plan: Policy update and Staff communication - June 2022; EQA Procedures - Ongoing

Prior Finding References

2020-004

About Eligibility →
2021-006
Matching, Level of Effort, Earmarking
SIGNIFICANT DEFICIENCYOTHER MATTERS

The Department did not comply with the federal matching requirement for family planning services, family planning related services, or Part B assistance premium payments. Questioned Costs: None Context: We tested 60 individual claims to ensure the Department complied with matching requirements. We determined the Department did not use the proper Federal Medical Assistance Percentage (FMAP) for all (two) of the family planning related services selected for testing as well as one of the Part B assistance premium payments selected for testing. Cause: Department personnel stated that an improper modifier was used causing sexually transmitted infection testing and treatment services to map to the incorrect internal fund code and FMAP. Also, Department personnel stated, regarding the Part B assistance premium payment, that an incorrect functional area was assigned to the report?s translation table, resulting in the incorrect FMAP being used. Staff realized the error and corrected the translation table to the correct functional area. However, staff failed to follow through to ensure the entry was posted correctly or to process a journal entry in the accounting system to correct the posting. Effect: The Department?s controls did not consistently detect errors identified which could lead to improper payments. Recommendation: We recommend the Department correct the errors in MMIS and strengthen its controls to ensure errors are corrected when identified. Prior Year Single Audit Finding Number: Not applicable Views of Responsible Offices and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 102.

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Federal Agency: Department of Health and Human Services Federal Program Title: Medicaid Cluster Assistance Listing No.: 93.775, 93.777, 93.778 Federal Grant ID Number: 05-2005SC5MAP Pass-Through Entity: Not applicable Award Period: October 1, 2020 through September 30, 2021 Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: Per 42 CFR 433.10 (c) (1), under Section 1905 (a) (5) of the Act, the federal share of state expenditures for family planning services is 90 percent. In addition, per the Centers for Medicare & Medicaid Services (CMS) State Medicaid Director Letter 14-003, family planning related services are matched at the states? regular federal medical assistance percentage. Also, per 42 CFR 433.10 (c) (5) (i), under section 1933(d) of the Act, the federal share of state expenditures for Medicare Part B premiums described in section 1905(p)(3)(A)(ii) of the Act on behalf of Qualifying Individuals described in section 1902(a)(10)(E)(iv) of the Act, is 100 percent, to the extent that the assistance does not exceed the state's allocation under paragraph (c)(5)(ii) of this section. To the extent that the assistance exceeds that allocation, the federal share is 0 percent. Condition: The Department did not comply with the federal matching requirement for family planning services, family planning related services, or Part B assistance premium payments. Questioned Costs: None Context: We tested 60 individual claims to ensure the Department complied with matching requirements. We determined the Department did not use the proper Federal Medical Assistance Percentage (FMAP) for all (two) of the family planning related services selected for testing as well as one of the Part B assistance premium payments selected for testing. Cause: Department personnel stated that an improper modifier was used causing sexually transmitted infection testing and treatment services to map to the incorrect internal fund code and FMAP. Also, Department personnel stated, regarding the Part B assistance premium payment, that an incorrect functional area was assigned to the report?s translation table, resulting in the incorrect FMAP being used. Staff realized the error and corrected the translation table to the correct functional area. However, staff failed to follow through to ensure the entry was posted correctly or to process a journal entry in the accounting system to correct the posting. Effect: The Department?s controls did not consistently detect errors identified which could lead to improper payments. Recommendation: We recommend the Department correct the errors in MMIS and strengthen its controls to ensure errors are corrected when identified. Prior Year Single Audit Finding Number: Not applicable Views of Responsible Offices and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 102.

Corrective Action Plan

Department of Health & Human Services Centers for Medicare & Medicaid Services (CMS) 31 Forsyth Street, SW, Room 4T20 Atlanta, Georgia 30303-8909 The South Carolina Department of Health and Human Services respectfully submits the following corrective action plan for the year ended 6/30/21. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS ? FEDERAL AWARD PROGRAM AUDIT DEPARTMENT OF HEALTH AND HUMAN SERVICES 2021-006 Medicaid Cluster ? Assistance Listing No. 93.775, 93.777, 93.778 Recommendation: We recommend the Department correct the errors in MMIS and strengthen its controls to ensure errors are corrected when identified. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Root Cause: Medicaid Management Information System (MMIS) does not include pointer logic for diagnosis codes to indicate the specific line(s) that each apply to. This results in all diagnosis codes being assigned to all procedure codes submitted on a claim. In cases where diagnosis codes with a program indicator of `Family Planning? are included on the claim, the MMIS is incorrectly treating each line as if it were a family planning service. In some cases, this is resulting in the incorrect FMAP being applied to services that may not have been true Family Planning codes. The Department has made numerous corrections to the Family Planning logic, including removing aspects such as the FP modifier from assignment to FMAP assignment, but agrees that further remediation is needed. Corrective Action: The agency is developing an action plan, in collaboration with its MMIS vendor, Clemson University, to evaluate the complete adjudication logic of the Family Planning limited benefit plan. This evaluation includes a review of all aspects of plan administration, including: ? Review/update procedure/Diagnosis Code program indicators ? Review/update the dedicated Family Planning MMIS tables ? Review/update the adjudication logic, including the continued use of the FP modifier for billing purposes ? Update the Fund Code assignment to remediate the auto-assignment of Family Planning FMAP rates based on diagnosis code alone ? Update the policy manuals to give clear guidance to providers on how to bill for Family Planning beneficiaries ? Finally, a review will be completed of all claims that may have been processed under the former logic and decisions will be made on whether to reprocess claims to assign the proper FMAP or if a ledger adjustment will be performed to correct FMAP draw downs. The development, testing, and implementation of the revised Family Planning logic is scheduled to be completely by December 31, 2022. Corrective Action Plan for Part B Assistance Premium Payment issue: Fiscal staff have created a training document for identifying and assigning the correct functional areas to report types in the Medicaid Claims Payment Processing module in SCEIS. The training emphasizes the need to follow through the process to ensure errors are corrected when identified. Name(s) of the contact person(s) responsible for corrective action: Jeremy Faulkenburg, Brian Paeth, and Jenny Shealy Planned completion date for corrective action plan: December 31, 2022

About Matching, Level of Effort, Earmarking →
2021-007
Special Tests & Provisions
SIGNIFICANT DEFICIENCYOTHER MATTERS

The Department did not conduct, or contract, for an independent audit of the accuracy, truthfulness, and completeness of the encounter and financial data submitted by, or on behalf of, each MCO. Questioned Costs: None Context: We selected all (5) MCOs to ensure the Department complied with Managed Care Financial Audit requirements, but the Department could not provide us with the required periodic audit reports. Cause: Department personnel stated the periodic audits have not been conducted because they, along with the Department?s contracted third-party actuary, analyze the encounter and financial data of the MCO on a quarterly and annual basis at the aggregate level. Effect: The Department did not comply with the Special Tests and Provisions-Managed Care Financial Audit requirement. Recommendation: We recommend the Department ensure required periodic audits are performed. The required reports and documents should then be posted to the Department?s publicly accessible website. Prior Year Single Audit Finding Number: Not applicable Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 103.

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Federal Agency: Department of Health and Human Services Federal Program Title: Medicaid Cluster; Children?s Health Insurance Program Assistance Listing No.: 93.775, 93.777, 93.778, 93.767 Federal Grant ID Number: 05-2005SC5MAP, 05-1905SC5021 Pass-Through Entity: Not applicable Award Period: October 1, 2020 through September 30, 2021 Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: Per 42 CFR 438.602 (e), the state must periodically, but no less frequently than once every 3 years, conduct, or contract for the conduct of, an independent audit of the accuracy, truthfulness, and completeness of the encounter and financial data submitted by, or on behalf of, each Managed Care Organization (MCO), Prepaid Inpatient Health Plan (PIHP) or Prepaid Ambulatory Health Plan (PAHP). In addition, per 42 CFR 438.602 (g), the state must post on its Web site, as required in 438.10(c)(3), the following documents and reports: (1) The MCO, PIHP, PAHP, or Primary Care Case Management (PCCM) entity contract. (2) The data at 438.604(a)(5). (3) The name and title of individuals included in 438.604(a)(6). (4) The results of any audits under paragraph (e) of this section. Condition: The Department did not conduct, or contract, for an independent audit of the accuracy, truthfulness, and completeness of the encounter and financial data submitted by, or on behalf of, each MCO. Questioned Costs: None Context: We selected all (5) MCOs to ensure the Department complied with Managed Care Financial Audit requirements, but the Department could not provide us with the required periodic audit reports. Cause: Department personnel stated the periodic audits have not been conducted because they, along with the Department?s contracted third-party actuary, analyze the encounter and financial data of the MCO on a quarterly and annual basis at the aggregate level. Effect: The Department did not comply with the Special Tests and Provisions-Managed Care Financial Audit requirement. Recommendation: We recommend the Department ensure required periodic audits are performed. The required reports and documents should then be posted to the Department?s publicly accessible website. Prior Year Single Audit Finding Number: Not applicable Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 103.

Corrective Action Plan

Department of Health & Human Services Centers for Medicare & Medicaid Services (CMS) 31 Forsyth Street, SW, Room 4T20 Atlanta, Georgia 30303-8909 The South Carolina Department of Health and Human Services respectfully submits the following corrective action plan for the year ended 6/30/21. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS ? FEDERAL AWARD PROGRAM AUDIT DEPARTMENT OF HEALTH AND HUMAN SERVICES Medicaid Cluster; Children?s Health Insurance Program (CHIP) ? Assistance Listing No. 93.775, 93.777, 93.778; 93.767 Recommendation: We recommend the Department ensure required periodic audits are performed. The required reports and documents should then be posted to the Department?s publicly accessible website. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The agency will update its managed care contract to include the following language: 7.9.1. The CONTRACTOR must submit an annual audited financial report by July 1st of each year. 7.9.2.1 The annual audited financial report must include an independent audit of the accuracy, truthfulness and completeness of the Encounter and financial data submitted by the CONTRACTOR. 7.9.2.2 Detailed instructions for completion of the audited financial report are available in the Managed Care Policy and Procedure Guide. Name(s) of the contact person(s) responsible for corrective action: Jonathan Tapley, Thomas Clark Phillip Planned completion date for corrective action plan: July 1, 2022. First report submitted with the independent audit to occur after contract execution. MCO annual reports submitted in 2023 to include the audited financial and encounter data.

About Special Tests and Provisions →
2021-008
Special Tests & Provisions
MATERIAL WEAKNESSMODIFIED OPINION

The Department could not provide support that it complied with the implementation of the required six NCCI methodologies and the NCCI program requirements in accordance with the NCCI Medicaid Policy Manual and the NCCI Medicaid Technical Guidance Manual. Questioned Costs: None Context: We were unable to process test claims to determine if the Department complied with the NCCI Medicaid Policy Manual and the NCCI Medicaid Technical Guidance Manual. Cause: The Department contracts with a third party to implement the required six NCCI methodologies and program requirements. The Department's only monitoring tool over the responsibilities performed by the third party is to review cost savings reports provided by them; the Department does not monitor or perform a test of claims throughout the year. The Department did not provide access to necessary systems or documentation to allow us to test claims to determine compliance. Effect: In the absence of internal controls over the implementation of the Medicaid NCCI methodologies, the Department is unable to ensure that only proper payments of procedures are reimbursed. Recommendation: We recommend the Department implement controls to ensure its third-party contractor has implemented the required six NCCI methodologies and NCCI program requirements. Prior Year Single Audit Finding Number: Not applicable Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 104.

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Federal Agency: Department of Health and Human Services Federal Program Title: Medicaid Cluster Assistance Listing No.: 93.775, 93.777, 93.778 Federal Grant ID Number: 05-2005SC5MAP Pass-Through Entity: Not applicable Award Period: October 1, 2020 through September 30, 2021 Type of Finding: Material weakness in internal control over compliance, material noncompliance Criteria: The NCCI Policy Manual for Medicaid Services and the Medicaid NCCI Technical Guidance Manual require states to implement the required six NCCI methodologies and NCCI program requirements. Condition: The Department could not provide support that it complied with the implementation of the required six NCCI methodologies and the NCCI program requirements in accordance with the NCCI Medicaid Policy Manual and the NCCI Medicaid Technical Guidance Manual. Questioned Costs: None Context: We were unable to process test claims to determine if the Department complied with the NCCI Medicaid Policy Manual and the NCCI Medicaid Technical Guidance Manual. Cause: The Department contracts with a third party to implement the required six NCCI methodologies and program requirements. The Department's only monitoring tool over the responsibilities performed by the third party is to review cost savings reports provided by them; the Department does not monitor or perform a test of claims throughout the year. The Department did not provide access to necessary systems or documentation to allow us to test claims to determine compliance. Effect: In the absence of internal controls over the implementation of the Medicaid NCCI methodologies, the Department is unable to ensure that only proper payments of procedures are reimbursed. Recommendation: We recommend the Department implement controls to ensure its third-party contractor has implemented the required six NCCI methodologies and NCCI program requirements. Prior Year Single Audit Finding Number: Not applicable Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 104.

Corrective Action Plan

Department of Health & Human Services Centers for Medicare & Medicaid Services (CMS) 31 Forsyth Street, SW, Room 4T20 Atlanta, Georgia 30303-8909 The South Carolina Department of Health and Human Services respectfully submits the following corrective action plan for the year ended 6/30/21. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS ? FEDERAL AWARD PROGRAM AUDIT DEPARTMENT OF HEALTH AND HUMAN SERVICES 2021-008 Medicaid Cluster ? Assistance Listing No. 93.775, 93.777, 93.778 Recommendation: We recommend the Department implement controls to ensure its third-party contractor has implemented the required six NCCI methodologies and NCCI program requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Root Cause: MMIS does not have native editing of methodologies within the National Correct Coding Initiative. As such, it has contracted with a third party to perform NCCI analysis against claim extracts and provide the agency with a Pass/Fail report. This report is then ingested into the MMIS system and corresponding claim edits are applied to any submission that fails NCCI compliance. In response to this edit, the third party has provided evidence that they are up to date on all CMS edit criteria, that claim submissions and response reports are being transmitted, and a savings report showing the total costs saved by the agency via implementation of the NCCI edits is provided on a monthly basis. However, the agency agrees that it has not performed test claims of the NCCI system. Corrective Action: The agency is developing a plan to engage the third party with test scenarios on a quarterly basis. These test files will be generated via collaboration between the agency?s Bureau of Provider Services and Support, the area responsible for fee-for-service claims processing, and the Bureau of Medicaid Systems, the area of Information Technology who oversees file transmissions between the MMIS and the third party. The quarterly test file will include scenarios that cover both types of NCCI edits- procedure to procedure (PTP) and medically unlikely edits (MUEs). The scenarios will include claim types expected to validate the proper execution of all six methodologies, including: ? PTP edits for practitioner and ambulatory surgical center (ASC) services ? PTP edits for outpatient services in hospitals (including services offered in emergency and radiology departments, observation units, clinics, and laboratories) ? PTP edits for durable medical equipment (DME) ? MUE edits for practitioner and ASC services ? MUE edits for outpatient services in hospitals ? MUE edits for DME The quarterly testing files will coincide with the quarterly updates released by CMS. Special attention will be given to codes/scenarios that are included in the preceding quarter?s update. This development of the test scenarios, methodology creation, proprietary file development and transmission protocols to the third party are scheduled to be completed by the close of calendar year 2022. The first test file submission will take place in Q1 2023. Name(s) of the contact person(s) responsible for corrective action: Jeremy Faulkenburg Planned completion date for corrective action plan: December 2022

About Special Tests and Provisions →
2021-009
Special Tests & Provisions
SIGNIFICANT DEFICIENCYOTHER MATTERS

The Department did not ensure reports submitted by managed care organizations (MCO) included all MLR report elements as required by federal regulations. Questioned Costs: None Context: The Department contracts with 5 MCOs. We tested all reports submitted by the MCOs to ensure they contained the required 13 elements and determined the reports did not contain any line item or note regarding fraud prevention activities. Cause: Department personnel stated fraud prevention activities were excluded from the MLR reports due to the private market not yet incorporating fraud prevention activities in the MLR calculation. Effect: The Department did not comply with the Special Tests and Provisions-Medical Loss Ratio requirement. Recommendation: We recommend the Department ensure MLR reports submitted by MCOs comply with federal regulations. Prior Year Single Audit Finding Number: Not applicable Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 105.

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Federal Agency: Department of Health and Human Services Federal Program Title: Medicaid Cluster; Children?s Health Insurance Program Assistance Listing No.: 93.775, 93.777, 93.778, 93.767 Federal Grant ID Number: 05-2005SC5MAP, 05-1905SC5021 Pass-Through Entity: Not applicable Award Period: October 1, 2020 through September 30, 2021 Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: Per 42 CFR 438.8(k)(1), the state, through its contracts, must require each MCO, PIHP, or PAHP to submit a report to the state that includes at least the following information for each MLR reporting year: (iii) Fraud prevention activities as defined in paragraph (e)(4) of this section. Condition: The Department did not ensure reports submitted by managed care organizations (MCO) included all MLR report elements as required by federal regulations. Questioned Costs: None Context: The Department contracts with 5 MCOs. We tested all reports submitted by the MCOs to ensure they contained the required 13 elements and determined the reports did not contain any line item or note regarding fraud prevention activities. Cause: Department personnel stated fraud prevention activities were excluded from the MLR reports due to the private market not yet incorporating fraud prevention activities in the MLR calculation. Effect: The Department did not comply with the Special Tests and Provisions-Medical Loss Ratio requirement. Recommendation: We recommend the Department ensure MLR reports submitted by MCOs comply with federal regulations. Prior Year Single Audit Finding Number: Not applicable Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 105.

Corrective Action Plan

Department of Health & Human Services Centers for Medicare & Medicaid Services (CMS) 31 Forsyth Street, SW, Room 4T20 Atlanta, Georgia 30303-8909 The South Carolina Department of Health and Human Services respectfully submits the following corrective action plan for the year ended 6/30/21. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS ? FEDERAL AWARD PROGRAM AUDIT DEPARTMENT OF HEALTH AND HUMAN SERVICES 2021-009 Medicaid Cluster; Children?s Health Insurance Program (CHIP) ? Assistance Listing No. 93.775, 93.777, 93.778; 93.767 Recommendation: We recommend the Department ensure MLR reports submitted by MCOs comply with federal regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Our actuaries will be required to change their annual MLR reporting template to include Fraud Prevention Activities expenditures as defined in 42 CFR 438.8(e)(4) and required under 42 CFR 438.8(k)(1)(iii). Name(s) of the contact person(s) responsible for corrective action: T. Clark Phillip Planned completion date for corrective action plan: April 30, 2022.

About Special Tests and Provisions →
2021-010
Activities Allowed or Unallowed / Cost Allowability
SIGNIFICANT DEFICIENCYQUESTIONED COSTSOTHER MATTERS

Non-allowable costs were charged to the grant. Questioned Costs: $6,272 Context: Federal regulations state that non-federal entities may only use payments from the Fund to cover previously unbudgeted costs of necessary expenditures incurred as a result of the COVID-19 public health emergency. One of 71 non-payroll disbursements tested was for the costs of carpet cleaning services. These costs were neither previously unbudgeted nor necessary due to the public health emergency. Cause: The Office's internal controls failed to prevent non allowable activities and costs from being charged to the grant. Effect: The Office was not in compliance with certain federal regulations and applicable allowable costs/activities requirements. Recommendation: We recommend the Office strengthen its internal controls and processes to ensure that all charges to the grant are allowable. Prior Year Single Audit Finding Number: Not applicable Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 106.

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Federal Agency: Department of the Treasury Federal Program Title: Coronavirus Relief Fund ? COVID-19 Assistance Listing No.: 21.019 Federal Grant ID Number: None provided Pass-Through Entity: State of South Carolina Award Period: March 1, 2020 through December 31, 2021 Type of Finding: Significant Deficiency in internal control over compliance, other matters Criteria: Per 2 CFR 200.303 Internal controls, 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. Condition: Non-allowable costs were charged to the grant. Questioned Costs: $6,272 Context: Federal regulations state that non-federal entities may only use payments from the Fund to cover previously unbudgeted costs of necessary expenditures incurred as a result of the COVID-19 public health emergency. One of 71 non-payroll disbursements tested was for the costs of carpet cleaning services. These costs were neither previously unbudgeted nor necessary due to the public health emergency. Cause: The Office's internal controls failed to prevent non allowable activities and costs from being charged to the grant. Effect: The Office was not in compliance with certain federal regulations and applicable allowable costs/activities requirements. Recommendation: We recommend the Office strengthen its internal controls and processes to ensure that all charges to the grant are allowable. Prior Year Single Audit Finding Number: Not applicable Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 106.

Corrective Action Plan

United States Department of the Treasury The South Carolina Office of Regulatory Staff respectfully submits the following corrective action plan for the year ended 6/30/21. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS?FEDERAL AWARD PROGRAM AUDIT 2021-010 Coronavirus Relief Fund? Assistance Listing No. 21.019 Recommendation: We recommend the Office strengthen its internal controls and processes to ensure that all charges to the grant are allowable. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: ORS will strengthen its review procedures to ensure all expenditures charged to grants are allowable. The condition noted was related to the operation of an existing control and not control design; therefore, ORS will implement a plan whereby it periodically takes action to increase staff awareness of their responsibility to exercise due professional care in their duties. Name(s) of the contact person(s) responsible for corrective action: Mark Rhoden, CFO. Planned completion date for corrective action plan: June 30, 2022.

About Activities Allowed or Unallowed, Allowable Costs / Cost Principles →
2021-011
Activities Allowed or Unallowed / Cost Allowability
MATERIAL WEAKNESSQUESTIONED COSTSOTHER MATTERS

Fraud was committed by a school district employee. Each school district in the State was a beneficiary of the program and had expenditures funded by the South Carolina Department of Education (the Department). Questioned Costs: $548,391 Context: The procurement office of a beneficiary school district discovered misuse of funds by a school employee who steered the district to contract with companies he created and controlled for the purchase of equipment. The equipment was sold to the school district at a substantial markup. The now former school district employee pled guilty on January 27, 2022, to defrauding the school district. The questioned costs related to the fraud include $130,000 overcharged for cameras, $60,000 related to invoicing for sales tax and $358,391 retained by the former employee failing to pay the camera vendor for the items delivered to the school district. Cause: Department controls failed to prevent the identified misappropriation of funds. Effect: $548,391 of Coronavirus Relief Funds were misappropriated. Recommendation: We recommend the Department strengthen controls to ensure that all costs charged to the grant are allowable. Prior Year Single Audit Finding Number: Not applicable Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 107.

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Federal Agency: Department of the Treasury Federal Program Title: Coronavirus Relief Fund ? COVID-19 Assistance Listing No.: 21.019 Federal Grant ID Number: None provided Pass-Through Entity: South Carolina Department of Administration Award Period: March 1, 2020 through December 31, 2021 Type of Finding: Material Weakness in internal control over compliance, other matters Criteria: Per 2 CFR 200.303 Internal controls, 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. Condition: Fraud was committed by a school district employee. Each school district in the State was a beneficiary of the program and had expenditures funded by the South Carolina Department of Education (the Department). Questioned Costs: $548,391 Context: The procurement office of a beneficiary school district discovered misuse of funds by a school employee who steered the district to contract with companies he created and controlled for the purchase of equipment. The equipment was sold to the school district at a substantial markup. The now former school district employee pled guilty on January 27, 2022, to defrauding the school district. The questioned costs related to the fraud include $130,000 overcharged for cameras, $60,000 related to invoicing for sales tax and $358,391 retained by the former employee failing to pay the camera vendor for the items delivered to the school district. Cause: Department controls failed to prevent the identified misappropriation of funds. Effect: $548,391 of Coronavirus Relief Funds were misappropriated. Recommendation: We recommend the Department strengthen controls to ensure that all costs charged to the grant are allowable. Prior Year Single Audit Finding Number: Not applicable Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 107.

Corrective Action Plan

South Carolina Department of Education 1429 Senate Steet Columbia, South Carolina 29201 The South Carolina Department of Education respectfully submits the following corrective action plan for the year ended June 30, 2021. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS?FEDERAL AWARD PROGRAM AUDIT DEPARTMENT OF EDUCATION 2021-011 Coronavirus Relief Fund ? Assistance Listing No. 21.019 Recommendation: We recommend the Department strengthen controls to ensure that all costs charged to the grant are allowable. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The SC Department of Education will continue to educate school districts and other subrecipients on the appropriate use of federal awards. The Department will continue to work with the Executive Budget Office and the US Department of Treasury to determine the appropriate corrective actions. Name(s) of the contact person(s) responsible for corrective action: Nancy Williams, Chief Financial Officer Planned completion date for corrective action plan: June 30, 2022

About Activities Allowed or Unallowed, Allowable Costs / Cost Principles →
2021-012
Reporting
SIGNIFICANT DEFICIENCYOTHER MATTERS

The report was filed after the due date. Questioned Costs: None Context: The action was reported in FSRS on April 14, 2021, but was due no later than the last day of the month following the month in which the obligation was made (February 28, 2021). Cause: Department controls failed to ensure timely report submission. Effect: Noncompliance was noted with FSRS requirements. Recommendation: We recommend the Department strengthen controls to ensure the FFATA report is submitted in FSRS in a timely manner. Prior Year Single Audit Finding Number: Not applicable Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 108.

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Federal Agency: Department of Education Federal Program Title: Education Stabilization Fund ? COVID-19 Assistance Listing No.: 84.425D Federal Grant ID Number: S425D210019 Pass-Through Entity: None Award Period: January 5, 2021 through September 30, 2022 Type of Finding: Significant Deficiency in internal control over compliance, other matters Criteria: Per 2 CFR 170 Appendix A, the action should be reported in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS) no later than the last day of the month following the month in which the obligation was made. Condition: The report was filed after the due date. Questioned Costs: None Context: The action was reported in FSRS on April 14, 2021, but was due no later than the last day of the month following the month in which the obligation was made (February 28, 2021). Cause: Department controls failed to ensure timely report submission. Effect: Noncompliance was noted with FSRS requirements. Recommendation: We recommend the Department strengthen controls to ensure the FFATA report is submitted in FSRS in a timely manner. Prior Year Single Audit Finding Number: Not applicable Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 108.

Corrective Action Plan

South Carolina Department of Education 1429 Senate Steet Columbia, South Carolina 29201 The South Carolina Department of Education respectfully submits the following corrective action plan for the year ended June 30, 2021. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS?FEDERAL AWARD PROGRAM AUDIT DEPARTMENT OF EDUCATION 2021-012 Education Stabilization Fund ? Assistance Listing No. 84.425D Recommendation: We recommend the Department strengthen controls to ensure the FFATA report is submitted in FSRS in a timely manner. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Procedures were written to assure timely reporting of federal awards in the FSRS System. A review of these procedures will be scheduled for early April with Grants Accounting and Mid-April with the Program Offices. Due to these dates, we recommend a completion date of May 1, 2022, for the Corrective Action. Name(s) of the contact person(s) responsible for corrective action: Steven Strother, Finance Director Planned completion date for corrective action plan: May 1, 2022

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2021-013
Cost Allowability / Eligibility
MATERIAL WEAKNESSMODIFIED OPINIONREPEAT OF 2020-027QUESTIONED COSTS

Eligibility related discrepancies were encountered for some subsidy payments. Questioned Costs: $3,321 Context: Sixty payments charged to the program were selected for testing eligibility compliance. Seven of the payments tested contained eligibility discrepancies as follows: Documentation properly supported that the case was ineligible for program subsidy payments (two). Documentation contained information that was not consistent with meeting eligibility requirements (three). Documentation was insufficient to determine eligibility (two). Additionally, three other subsidy payments tested were for children no longer eligible for payment. Cause: Department controls failed to ensure eligibility was properly determined or applied, benefits were terminated timely, and records were appropriately retained. The ongoing global pandemic also limited the Department?s ability to implement corrective action. Effect: The Department did not comply with and/or could not demonstrate compliance with eligibility and allowable costs/cost principles requirements. Recommendation: We recommend that the Department continue to implement corrective action for eligibility file controls. Prior Year Single Audit Report Finding Number: 2020-027 Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 109.

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Federal Agency: Department of Health and Human Services Federal Program Title: Adoption Assistance Assistance Listing: 93.659 Federal Grant ID Number: 2001SCADPT, 2101SCADPT Pass-Through Entity: Not applicable Award Period: October 1, 2019 through September 30, 2021 Type of Finding: Material weakness in internal control over compliance, material noncompliance Criteria: 45 CFR 75.361 outlines record retention requirements of the non-federal entity pertinent to the federal award. 45 CFR 1356.40(b)(1) requires the adoption assistance agreement be signed and in effect at the time of or prior to the final decree of adoption. 42 U.S.C. 673(c) explains the children with special needs criteria. 42 U.S.C. 675(8)(b) expands eligibility requirements for children over the age of eighteen. Condition: Eligibility related discrepancies were encountered for some subsidy payments. Questioned Costs: $3,321 Context: Sixty payments charged to the program were selected for testing eligibility compliance. Seven of the payments tested contained eligibility discrepancies as follows: Documentation properly supported that the case was ineligible for program subsidy payments (two). Documentation contained information that was not consistent with meeting eligibility requirements (three). Documentation was insufficient to determine eligibility (two). Additionally, three other subsidy payments tested were for children no longer eligible for payment. Cause: Department controls failed to ensure eligibility was properly determined or applied, benefits were terminated timely, and records were appropriately retained. The ongoing global pandemic also limited the Department?s ability to implement corrective action. Effect: The Department did not comply with and/or could not demonstrate compliance with eligibility and allowable costs/cost principles requirements. Recommendation: We recommend that the Department continue to implement corrective action for eligibility file controls. Prior Year Single Audit Report Finding Number: 2020-027 Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 109.

Corrective Action Plan

The South Carolina Department of Social Services respectfully submits the following corrective action plan for the year ended June 30, 2021. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS?FEDERAL AWARD PROGRAM AUDIT U. S. Department of Health and Human Services 2021-013 Adoption Assistance ? Assistance Listing No. 93.659 Recommendation: We recommend that the Department continue to implement corrective action for eligibility file controls. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: All adoption subsidy agreements (ASAs) are nowreviewed for completeness, accuracy and agreement with appropriate supportingdocumentation by two State Office Adoptions administrative employees specifically assigned to ensure the agreements have been completed correctly. Only after they haveconfirmed an ASA is properly supported, complete and accurate, they submit it to the State Office Adoptions Manager for signature. When signing the ASAs, the State Office Adoptions Manager now conducts their own compliance review and verifies the subsidy payment amounts are correct and agree with the signed adoption subsidy negotiation approval form. If discrepancies are found, the manager contacts the region for clarification or corrective action. Then, when key information from the ASAs is entered into the Child Welfare Information System (CAPSS), staff verify that each ASA includes the State Adoption Office Manager?s signature. In addition, State Adoptions staff, working with the Department?s Information Technology team, are implementing a process whereby Adoptions staff will be required to upload all ASAs and supporting documents into Sharepoint for work-flowed approval. Management believes that, collectively, the above controls will greatly reduce the possibility that adoption subsidies will commence without the proper support of an ASA that has been correctly completed, appropriately supported by other required documentation, properly signed by an authorized manager, and can easily be retrieved from Department files. Some of the payments tested and identified as exceptions this year were made pursuant to subsidy agreements executed in prior years. The Department has already begun reviewing older files to ensure the subsidy agreements include the proper signatures, and the Department will continue this practice. The Department also has begun implementation of an eligibility review process whereby staff pull sample cases quarterly for internal review to confirm compliance with various requirements and ensure all subsidy payments were adequately supported. Finally, in August 2021 State Adoptions staff, working with the Department?s Information Technology team, implemented system controls and reports to ensure timely termination of payments and maintenance of documentary support for payments to children who are 18 years and older. The Department?s CAPSS system now discontinues subsidy payments at the end of the month in which a child reaches age 21. In addition, monthly reports are provided to Adoptions staff that facilitate the generation and mailing of advance requests for required updates to educational and medical information to assure timely receipt of support for continuing payments for children who are 18 and over. Each month staff track the documentation requested to ensure the required updates have been received, and they terminate payments that lack the required support. Management believes these new processes substantially reduce the possibility that payments will continue without appropriate support for youth who are 18 years of age or older. Name(s) of the contact person(s) responsible for corrective action: Dawn Barton, Permanency Manager Planned completion date for corrective action plan: August 1, 2022

Prior Finding References

2020-027

About Allowable Costs / Cost Principles, Eligibility →
2021-014
Reporting
SIGNIFICANT DEFICIENCYREPEAT OF 2020-028OTHER MATTERS

Discrepancies existed between federal financial reports and the Department?s supporting records. Questioned Costs: None Context: Two CB-496 reports were selected for testing. Discrepancies were noted between supporting documentation and the reports. In Part 1, Section B of both reports, some activity was improperly reported as prior quarter adjustments. Errors were also identified in the Adoption Savings Calculation used in determining the amounts reported in Part 4 of the report. Cause: The Department had not completely implemented the corrective action associated with this finding from the prior year. Effect: The accuracy of the CB-496 reports could not be fully validated. Recommendation: We recommend that the Department continue to strengthen its internal controls to ensure that federal reports are free from error and clearly supported prior to submission. Prior Year Single Audit Report Finding Number: 2020-028 Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 110.

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Federal Agency: Department of Health and Human Services Federal Program Title: Adoption Assistance Assistance Listing: 93.659 Federal Grant ID Number: 2001SCADPT, 2101SCADPT Pass-Through Entity: Not applicable Award Period: October 1, 2019 through September 30, 2021 Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: 45 CFR 75.303 requires effective internal controls be established and maintained in order to provide reasonable assurance that the federal award is being managed in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: Discrepancies existed between federal financial reports and the Department?s supporting records. Questioned Costs: None Context: Two CB-496 reports were selected for testing. Discrepancies were noted between supporting documentation and the reports. In Part 1, Section B of both reports, some activity was improperly reported as prior quarter adjustments. Errors were also identified in the Adoption Savings Calculation used in determining the amounts reported in Part 4 of the report. Cause: The Department had not completely implemented the corrective action associated with this finding from the prior year. Effect: The accuracy of the CB-496 reports could not be fully validated. Recommendation: We recommend that the Department continue to strengthen its internal controls to ensure that federal reports are free from error and clearly supported prior to submission. Prior Year Single Audit Report Finding Number: 2020-028 Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 110.

Corrective Action Plan

The South Carolina Department of Social Services respectfully submits the following corrective action plan for the year ended June 30, 2021. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS?FEDERAL AWARD PROGRAM AUDIT U. S. Department of Health and Human Services 2021-014 Adoption Assistance ? Assistance Listing No. 93.659 Recommendation: We recommend that the Department continue to strengthen its internal controls to ensure that federal reports are free from error and clearly supported prior to submission. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Department?s Grants Accounting and Reporting Manager now has completed the first year of work at the Department and has also added staff to allow more time for review of reports. The entire team has greatly increased its understanding of the reporting rules and the measures required to ensure proper completion of the Federal Financial Reports, with appropriate tie-in and retention of relevant supporting documentation. Management has specifically reviewed with staff the discrepancies noted between supporting documentation and the reports, as well as the incorrect treatment of report corrections as prior quarter adjustments. Management does not expect these errors to recur. If they do, management expects them to be detected and corrected during management review. Errors noted in the Adoption Savings calculation were related to specific calculation and reporting mechanics that are simple to check and now well understood. The Department will specifically review the calculations and supporting documentation to ensure they are free of these errors and will continue the management review process now in place. Name(s) of the contact person(s) responsible for corrective action: Reshma Parikh, Grants Accounting and Reporting Manager Planned completion date for corrective action plan: March 31, 2022

Prior Finding References

2020-028

About Reporting →
2021-015
Reporting
MATERIAL WEAKNESSMODIFIED OPINION

The total awards expended for the program could not be determined or identified on the Department?s SEFA. Questioned Costs: None Context: The expenditure activity of the new program was not tracked in the Department?s accounting system in a manner consistent with other grant programs and therefore was not included on the Department?s SEFA. Cause: Department controls failed to ensure consistent tracking of the program?s expenditure activity in its accounting system and reporting controls did not detect and correct the resulting reporting error on the SEFA submitted for audit. Effect: An audit adjustment was required to correct the Department?s SEFA and some federal reports of the program required revision. Recommendation: We recommend that the Department implement procedures to ensure that all new grant program activity is consistently accounted for in the Department?s accounting system and that SEFA reporting does not exclude any expenditures required by federal reporting requirements. Prior Year Single Audit Report Finding Number: None Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 111.

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Federal Agency: Department of Agriculture Federal Program Title: Pandemic EBT Food Benefits ? COVID-19 Assistance Listing: 10.542 Federal Grant ID Number: None Pass-Through Entity: Not applicable Award Period: March 16, 2020 through June 11, 2021 Type of Finding: Material weakness in internal control over compliance, material noncompliance Criteria: 2 CFR 200.303 requires effective internal controls be established and maintained in order to provide reasonable assurance that the federal award is being managed in compliance with federal statutes, regulations, and the terms and conditions of the federal award. 2 CFR 200.510(b) specifies the reporting requirements for the schedule of expenditures of federal awards (SEFA). Condition: The total awards expended for the program could not be determined or identified on the Department?s SEFA. Questioned Costs: None Context: The expenditure activity of the new program was not tracked in the Department?s accounting system in a manner consistent with other grant programs and therefore was not included on the Department?s SEFA. Cause: Department controls failed to ensure consistent tracking of the program?s expenditure activity in its accounting system and reporting controls did not detect and correct the resulting reporting error on the SEFA submitted for audit. Effect: An audit adjustment was required to correct the Department?s SEFA and some federal reports of the program required revision. Recommendation: We recommend that the Department implement procedures to ensure that all new grant program activity is consistently accounted for in the Department?s accounting system and that SEFA reporting does not exclude any expenditures required by federal reporting requirements. Prior Year Single Audit Report Finding Number: None Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 111.

Corrective Action Plan

The South Carolina Department of Social Services respectfully submits the following corrective action plan for the year ended June 30, 2021. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS?FEDERAL AWARD PROGRAM AUDIT U. S. Department of Health and Human Services 2021-015 Pandemic EBT Food Benefits ? Assistance Listing No. 10.542 Recommendation: We recommend that the Department implement procedures to ensure that all new grant program activity is consistently accounted for in the Department?s accounting system and that SEFA reporting does not exclude any expenditures required by federal reporting requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The transmission and delivery of most PEBT benefits were executed in separate and distinct processes developed solely for that purpose on an emergency basis. Most of these benefits therefore were excluded from the normal SNAP benefits accounting reports and processes. Management will modify the accounting process to specifically capture PEBT benefits, and the Grants Accounting and Reporting staff will reconcile total SNAP benefits issued to postings in the accounting system to ensure all have been recorded and reported. PEBT expenditures, as well as those of any other new grant programs enacted in the future, will be reported separately, rather than combined with those of similar programs. Name(s) of the contact person(s) responsible for corrective action: Reshma Parikh, Grants Accounting and Reporting Manager Planned completion date for corrective action plan: April 30, 2022

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2021-016
Cost Allowability
SIGNIFICANT DEFICIENCYQUESTIONED COSTSOTHER MATTERS

Non-allowable costs were identified in charges to the grant. Questioned Costs: $4,691 Context: Three of the sixty-six expenditure transactions selected for inspection were recorded to the grant twice through two separate accounting transactions. Cause: The Department identified allowable charges and recorded those charges to the grant through adjusting journal entries. The same transaction was mistakenly included in two separate journal entries and the duplication was not detected and corrected through the review and approval of the Department?s journal entries. Effect: The grant could be overcharged for some specific costs. Recommendation: We recommend that the Department review the supporting documentation for the amounts charged to the grant to determine if the grant was overcharged and determine any necessary appropriate resolution for the closed grant program. Prior Year Single Audit Report Finding Number: None Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 111.

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Federal Agency: Department of the Treasury Federal Program Title: Coronavirus Relief Fund ? COVID-19 Assistance Listing: 21.019 Federal Grant ID Number: None Pass-Through Entity: South Carolina Department of Administration Award Period: March 1, 2020 through December 31, 2021 Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: 2 CFR 200.303 requires effective internal controls be established and maintained in order to provide reasonable assurance that the federal award is being managed in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: Non-allowable costs were identified in charges to the grant. Questioned Costs: $4,691 Context: Three of the sixty-six expenditure transactions selected for inspection were recorded to the grant twice through two separate accounting transactions. Cause: The Department identified allowable charges and recorded those charges to the grant through adjusting journal entries. The same transaction was mistakenly included in two separate journal entries and the duplication was not detected and corrected through the review and approval of the Department?s journal entries. Effect: The grant could be overcharged for some specific costs. Recommendation: We recommend that the Department review the supporting documentation for the amounts charged to the grant to determine if the grant was overcharged and determine any necessary appropriate resolution for the closed grant program. Prior Year Single Audit Report Finding Number: None Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 111.

Corrective Action Plan

The South Carolina Department of Social Services respectfully submits the following corrective action plan for the year ended June 30, 2021. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS?FEDERAL AWARD PROGRAM AUDIT U. S. Department of Health and Human Services 2021-016 Coronavirus Relief Fund? Assistance Listing No. 21.019 Recommendation: We recommend that the Department review the supporting documentation for the amounts charged to the grant to determine if the grant wasovercharged and determine any necessary appropriate resolution for the closed grant program. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Of the approximate $16 million in total Coronavirus Relief Fund expenditures reported, which included thousands of individual expenditure documents, three duplicate expenditure documents totaling $4,691 have been found to have escaped detection by staff, Department management, and by the firm engaged to review and approve all program reimbursements. The Department will conduct a thorough search for additional duplicate document numbers in the entire population of expenditure documents reimbursed. Management does not expect the total thus returned to be material. Name(s) of the contact person(s) responsible for corrective action: Ashley Harris, Assistant Controller Planned completion date for corrective action plan: April 30, 2022

About Allowable Costs / Cost Principles →
2021-017
Reporting
SIGNIFICANT DEFICIENCYOTHER MATTERS

FFATA reporting and timing discrepancies were identified. Questioned Costs: None Context: Seven subawards were selected for testing and the following compliance discrepancies were identified during the testing: The reported subaward obligation/action date did not agree to the subaward agreement date for five subawards tested. The reported subaward Data Universal Numbering System (DUNS) number did not agree to the DUNS number on the subaward for one subaward tested. For the subawards tested, the action was not reported in the Federal Subaward Reporting System (FSRS) by the last day of the month following the month that the subaward was made. The Office was not able to access FSRS for one of the subawards selected in order to test reporting compliance for that subaward. Cause: Data entry errors and administrative delays led to the compliance errors identified in the testing. Effect: Some information was not reported timely or accurately in accordance with the federal requirements. Recommendation: We recommend that the Office strengthen its internal controls over FFATA reporting to ensure that all reporting is timely and accurate in accordance with the federal requirements. Prior Year Single Audit Report Finding Number: Not applicable Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 113.

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Federal Agency: Department of Homeland Security Federal Program Title: Hazard Mitigation Grant Program Assistance Listing: 97.039 Federal Grant ID Number: Various Pass-Through Entity: Not applicable Award Period: Various Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: 2 CFR 170 Appendix A specifies the reporting and timing requirements for Federal Funding Accountability and Transparency Act (FFATA) reporting. Condition: FFATA reporting and timing discrepancies were identified. Questioned Costs: None Context: Seven subawards were selected for testing and the following compliance discrepancies were identified during the testing: The reported subaward obligation/action date did not agree to the subaward agreement date for five subawards tested. The reported subaward Data Universal Numbering System (DUNS) number did not agree to the DUNS number on the subaward for one subaward tested. For the subawards tested, the action was not reported in the Federal Subaward Reporting System (FSRS) by the last day of the month following the month that the subaward was made. The Office was not able to access FSRS for one of the subawards selected in order to test reporting compliance for that subaward. Cause: Data entry errors and administrative delays led to the compliance errors identified in the testing. Effect: Some information was not reported timely or accurately in accordance with the federal requirements. Recommendation: We recommend that the Office strengthen its internal controls over FFATA reporting to ensure that all reporting is timely and accurate in accordance with the federal requirements. Prior Year Single Audit Report Finding Number: Not applicable Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 113.

Corrective Action Plan

The South Carolina Adjutant General?s Office respectfully submits the following Corrective Action Plan for the year ended 6/30/21. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS?FEDERAL AWARD PROGRAM AUDIT U.S. Department of Homeland Security 2021-017 Hazard Mitigation Grant Program ? Assistance Listing No. 97.039 Recommendation: We recommend that the Office strengthen its internal controls over FFATA reporting to ensure that all reporting is timely and accurate in accordance with the federal requirements. Explanation of disagreement with audit finding: The Agency concurs with the audit finding. Action taken in response to finding: The Hazard Mitigation team has assigned staff to check and correct all project award dates in SCEMD?s South Carolina Recovery Grants (SCRecoveryGrants.org; known as SCRG) system to ensure the date in SCRG matches the award date on FEMA?s award letter for the respective project. The Hazard Mitigation team is reinforcing in staff training the requirement that when entering HMGP award information in SCRG, the enterer must select the award date from the drop-down menu rather than allow the system to default to the entry date. The above two steps will provide the correct award date in SCRG for Finance and Administration staff to pull the award date matching the award letter for FFATA reporting purposes (will avoid discrepancies). The Finance and Administration team will pull records for FFATA reporting by obligation date instead of pulling records of reimbursements processed; this action will correct the reporting dates in FSRS. The Finance and Administration team will continue to save a pdf record of the monthly reports. Name(s) of the contact person(s) responsible for corrective action: Candice Shealey, SCEMD State Hazard Mitigation Officer: Brittany Hammond, SCEMD Chief of Finance and Administration. Planned completion date for corrective action plan: April 15, 2022

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2021-018
Cash Management
MATERIAL WEAKNESSMODIFIED OPINIONREPEAT OF 2020-019

Advanced funds were not expended within the required timeframe to minimize the time elapsing between drawdown and disbursement. Questioned Costs: None Context: From forty drawdown transactions selected for testing, nineteen grants were identified as having unspent advance funds after forty-five days from the date the funds were advanced. Cause: The timeframe for determining and returning excess advance funding exceeded forty-five days. Effect: Advance funding was not spent or returned within forty-five days of receipt as required by federal regulation. Recommendation: We recommend that the Office continue the implementation of corrective action to strengthen its internal controls over advance payments in order to demonstrate compliance with the federal requirements. Prior Year Single Audit Report Finding Number: 2020-19 Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 114.

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Federal Agency: Department of Defense Federal Program Title: National Guard Military Operations and Maintenance (O&M) Projects Assistance Listing: 12.401 Federal Grant ID Number: Various Pass-Through Entity: Not applicable Award Period: October 1, 2019 through September 30, 2021 Type of Finding: Material weakness in internal control over compliance, material noncompliance Criteria: National Guard Regulation (NGR) 5-1, Chapter 11-5 requires advance payments be disbursed by the state within forty-five days. Condition: Advanced funds were not expended within the required timeframe to minimize the time elapsing between drawdown and disbursement. Questioned Costs: None Context: From forty drawdown transactions selected for testing, nineteen grants were identified as having unspent advance funds after forty-five days from the date the funds were advanced. Cause: The timeframe for determining and returning excess advance funding exceeded forty-five days. Effect: Advance funding was not spent or returned within forty-five days of receipt as required by federal regulation. Recommendation: We recommend that the Office continue the implementation of corrective action to strengthen its internal controls over advance payments in order to demonstrate compliance with the federal requirements. Prior Year Single Audit Report Finding Number: 2020-19 Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 114.

Corrective Action Plan

The South Carolina Adjutant General?s Office respectfully submits the following Corrective Action Plan for the year ended 6/30/21. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS?FEDERAL AWARD PROGRAM AUDIT U.S. Department of Defense 2021-018 National Guard Military Operations and Maintenance (O&M) Projects ? Assistance Listing No. 12.401 Recommendation: We recommend that the Office continue the implementation of corrective action to strengthen its internal controls over advance payments in order to demonstrate compliance with the federal requirements. Explanation of disagreement with audit finding: The Agency concurs with the audit finding. Action taken in response to finding: The Grants and Agreements Section will implement additional procedures to strengthen internal controls over advance payments in order to demonstrate compliance with the Federal requirements. The Grants and Agreements Section will provide additional information to Program Managers and/or State and Federal Budget Analysts concerning the details of the amounts of the advance funds requested for each appendix. This information will include the dollar amounts of expenditure categories needed for the advance funding amount requested for the applicable time period. The Program Manager and/or Federal and State Budget Analysts for each appendix will develop a spreadsheet to track expenditures that have occurred period to date, by expenditure categories, used in the Federal Army and Air Guard Accounting Systems for processing of expenditures and payments for the Cooperative Agreements. This spreadsheet will also track the amounts of the remaining Federal budgets for each appendix and the amounts of the advance funding available for use for each appendix. Each Program Manager and/or Federal and State Budget Analysts for each appendix will submit a copy of all spreadsheets to the Grants and Agreements Section on a monthly basis. The Grants and Agreements Section will maintain a copy of the spreadsheet. No later than the fifth working day of the first month of the new Federal Fiscal Year (October), the Grants and Agreements Section will complete a final reconciliation of State and Federal Accounting data for each appendix for the previous Federal Fiscal Year. The Grants Administrator will make a determination, based on reconciliation of account balances, of the amount of advance funding for each appendices that the Agency should return to the Federal Government. The Grants and Agreements Section will ensure all remaining advance funding is returned to the Federal Government within forty-five (45) days after the end of the Federal Fiscal Year. Name(s) of the contact person(s) responsible for corrective action: Alex Counts Planned completion date for corrective action plan: May 31, 2022

Prior Finding References

2020-019

About Cash Management →
2021-019
Period of Performance
SIGNIFICANT DEFICIENCYREPEAT OF 2020-020QUESTIONED COSTSOTHER MATTERS

Expenditures, which did not meet the applicable requirements, were charged prior to and after the program?s period of performance. Questioned Costs: $521 Context: Forty expenditure transactions were selected for testing from costs recorded during the first period of the program grants. One of the forty transactions tested was for a cost incurred prior to the applicable period of performance. In addition, nine transactions were selected for testing from costs recorded to program grants beyond ninety days after the close of the federal fiscal year. One of the nine transactions tested was not included on the detailed listing of unliquidated claims and undisbursed obligations. Cause: Office controls failed to prevent charging the grant for a cost incurred outside the applicable period of performance. Effect: Costs charged outside the period of performance may not be allowable. Recommendation: We recommend that the Office continue the implementation of corrective action to strengthen its internal controls to ensure documented compliance with all federal period of performance requirements. Prior Year Single Audit Report Finding Number: 2020-20 Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 115.

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Federal Agency: Department of Defense Federal Program Title: National Guard Military Operations and Maintenance (O&M) Projects Assistance Listing: 12.401 Federal Grant ID Number: W912QG-20-2-1001, W912QG-21-2-1001 Pass-Through Entity: Not applicable Award Period: October 1, 2019 through September 30, 2021 Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: 2 CFR 200.403(h) requires costs be incurred during the approved budget period. NGR 5-1, Chapter 11-2 requires the obligation of funds within the federal fiscal year or period of federal availability. Per NGR 5-1, Chapter 11-10, if unliquidated claims and undisbursed obligations remain ninety days after the close of the federal fiscal year, the recipient shall provide a detailed listing of uncleared obligations no later than December 31. Condition: Expenditures, which did not meet the applicable requirements, were charged prior to and after the program?s period of performance. Questioned Costs: $521 Context: Forty expenditure transactions were selected for testing from costs recorded during the first period of the program grants. One of the forty transactions tested was for a cost incurred prior to the applicable period of performance. In addition, nine transactions were selected for testing from costs recorded to program grants beyond ninety days after the close of the federal fiscal year. One of the nine transactions tested was not included on the detailed listing of unliquidated claims and undisbursed obligations. Cause: Office controls failed to prevent charging the grant for a cost incurred outside the applicable period of performance. Effect: Costs charged outside the period of performance may not be allowable. Recommendation: We recommend that the Office continue the implementation of corrective action to strengthen its internal controls to ensure documented compliance with all federal period of performance requirements. Prior Year Single Audit Report Finding Number: 2020-20 Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 115.

Corrective Action Plan

The South Carolina Adjutant General?s Office respectfully submits the following Corrective Action Plan for the year ended 6/30/21. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS?FEDERAL AWARD PROGRAM AUDIT U.S. Department of Defense 2021-019 National Guard Military Operations and Maintenance (O&M) Projects ? Assistance Listing No. 12.401 Recommendation: We recommend that the Office continue the implementation of corrective action to strengthen its internal controls to ensure documented compliance with all federal period of performance requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Grants and Agreements Section will implement additional procedures to strengthen internal controls to ensure documented compliance with all federal period of performance requirements. The Grants and Agreements Section will send each Program Manager and/or their Federal and State Budget Analysts a detailed listing of the remaining balances of purchase orders and funds reservations to on a monthly basis to ensure accuracy and compliance for each appendix. Each Program Manager and/or their Federal and State Budget Analysts will provide a mandatory response to ensure accuracy or needed changes. The Grants and Agreements Section will maintain a copy of the listing and responses. The Grants and Agreements Section will submit a monthly detailed listing of expenditures for all appendices to each Program Manager and/or their Federal and State Budget Analysts for all open Federal Fiscal Years to ensure accuracy and compliance. Program Managers and/or their Federal and State Budget Analysts will provide a mandatory response to ensure accuracy or needed changes. The Grants and Agreements Section will maintain a copy of responses. The Grants and Agreements Section will review all expenditures for each appendix for accuracy and compliance. The Grants and Agreements Section will maintain documentation for accuracy and changes. Program Managers and/or Federal and State Budget Analysts for each appendix will develop and maintain a spreadsheet for tracking invoices for each open Federal Fiscal Year. Program Managers and/or Federal and State Budget Analysts will submit a copy of the spreadsheet to Grants and Agreements on a monthly basis. The Grants and Agreements Section will maintain a copy of the spreadsheet. Name(s) of the contact person(s) responsible for corrective action: Alex Counts Planned completion date for corrective action plan: May 31, 2022

Prior Finding References

2020-020

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2021-020
Activities Allowed or Unallowed / Cost Allowability
MATERIAL WEAKNESSQUESTIONED COSTSOTHER MATTERS

Indirect costs were improperly charged to the CRF. Questioned Costs: $4,590,544 Context: While examining expenditure populations to evaluate which costs were direct and material to the CRF, we noted activity charged to general ledger accounts designated for indirect costs. Cause: Department controls failed to prevent the identified noncompliance issue noted above. Effect: The identified indirect costs resulted in noncompliance with federal regulations and applicable allowable activities/costs requirements. Recommendation: We recommend the Department strengthen controls to ensure that all costs charged to the CRF are for allowable grant activities and costs. Prior Year Single Audit Finding Number: Not applicable Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 117.

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Federal Agency: Department of the Treasury Federal Program Title: Coronavirus Relief Fund ? COVID-19 Assistance Listing No.: 21.019 Federal Grant ID Number: None provided Pass-Through Entity: South Carolina Department of Administration Award Period: March 1, 2020 through December 31, 2021 Type of Finding: Material weakness in internal control over compliance, other matters Criteria: Per Federal Register Notice Volume 86, Number 10, payments from the Coronavirus Relief Fund (CRF) are not administered as part of a traditional grant program. The provisions of the Uniform Guidance, 2 CFR 200, that are applicable to indirect costs do not apply. Recipients do not apply their indirect cost rates to payments received from the CRF. Additionally, per 2 CFR 200.303, the 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. Condition: Indirect costs were improperly charged to the CRF. Questioned Costs: $4,590,544 Context: While examining expenditure populations to evaluate which costs were direct and material to the CRF, we noted activity charged to general ledger accounts designated for indirect costs. Cause: Department controls failed to prevent the identified noncompliance issue noted above. Effect: The identified indirect costs resulted in noncompliance with federal regulations and applicable allowable activities/costs requirements. Recommendation: We recommend the Department strengthen controls to ensure that all costs charged to the CRF are for allowable grant activities and costs. Prior Year Single Audit Finding Number: Not applicable Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 117.

Corrective Action Plan

US Department of Health and Human Services The South Carolina Department of Health and Environmental Control respectfully submits the following corrective action plan for the year ended 6/30/21. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS?FEDERAL AWARD PROGRAM AUDIT DEPARTMENT OF THE TREASURY 2021-020 Coronavirus Relief Fund (CRF) ? Assistance Listing No. 21.019 Recommendation: We recommend that the Department strengthen controls to ensure that all costs charged to the CRF are for allowable grant activities and costs. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: To strengthen internal controls, the Department discussed the finding with staff to reiterate the importance of ensuring grant awards are thoroughly reviewed and appropriate staff are aware of the terms and conditions related to activities that are deemed allowable, as well as activities that would be deemed unallowable. In addition, the unallowed costs will be returned to the grantor. Name(s) of the contact person(s) responsible for corrective action: Kim Paradeses Planned completion date for corrective action plan: June 30, 2022

About Activities Allowed or Unallowed, Allowable Costs / Cost Principles →
2021-021
Reporting
SIGNIFICANT DEFICIENCYOTHER MATTERS

Discrepancies existed between the federal financial report (FFR) and the Department?s supporting records. Additionally, not all information reported on the FFR was reviewed by an employee other than the report preparer prior to submission. Questioned Costs: None Context: We tested information reported for all four FFR Payment Management System (PMS) document numbers that were required to be submitted for the reporting period ending July 31, 2020, for federal grant number 6 NU50CK000542-01-08. We noted two discrepancies between the FFR associated with PMS document number 19NU50CK000542 (nonprevention and public health funds) and the Department?s supporting records. The federal share of indirect costs was understated by $54,195 because the incorrect indirect cost base amount was transferred from the supporting worksheets to the FFR. Moreover, the federal share of expenditures did not agree to the supporting worksheets by approximately $2,450. Additionally, the FFR component for PMS document number 19NU50CK000542C4 (COVID-19 paycheck protection and Health Care Enhancement Act response activities) was prepared and submitted by the same individual. Cause: Department controls failed to identify and correct discrepancies noted in the federal reports prior to submission. Effect: The FFR amounts did not agree to supporting documentation. Additionally, without a supervisory review, there is an increased risk of inaccurate reporting. Recommendation: We recommend that the Department strengthen policies and procedures to ensure that all information reported on federal reports is accurate and that a segregation of duties exists between report preparers and reviewers. Prior Year Single Audit Finding Number: Not applicable Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 118.

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Federal Agency: Department of Health and Human Services Federal Program Title: Epidemiology and Laboratory Capacity for Infectious Diseases ? COVID 19 Assistance Listing No.: 93.323 Federal Grant ID Number: 6 NU50CK000542-01-08 Pass-Through Entity: Not applicable Award Period: August 1, 2019 through July 31, 2024 Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: Per 2 CFR 200.303, the 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 be in compliance with guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States and the "Internal Control Integrated Framework", issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: Discrepancies existed between the federal financial report (FFR) and the Department?s supporting records. Additionally, not all information reported on the FFR was reviewed by an employee other than the report preparer prior to submission. Questioned Costs: None Context: We tested information reported for all four FFR Payment Management System (PMS) document numbers that were required to be submitted for the reporting period ending July 31, 2020, for federal grant number 6 NU50CK000542-01-08. We noted two discrepancies between the FFR associated with PMS document number 19NU50CK000542 (nonprevention and public health funds) and the Department?s supporting records. The federal share of indirect costs was understated by $54,195 because the incorrect indirect cost base amount was transferred from the supporting worksheets to the FFR. Moreover, the federal share of expenditures did not agree to the supporting worksheets by approximately $2,450. Additionally, the FFR component for PMS document number 19NU50CK000542C4 (COVID-19 paycheck protection and Health Care Enhancement Act response activities) was prepared and submitted by the same individual. Cause: Department controls failed to identify and correct discrepancies noted in the federal reports prior to submission. Effect: The FFR amounts did not agree to supporting documentation. Additionally, without a supervisory review, there is an increased risk of inaccurate reporting. Recommendation: We recommend that the Department strengthen policies and procedures to ensure that all information reported on federal reports is accurate and that a segregation of duties exists between report preparers and reviewers. Prior Year Single Audit Finding Number: Not applicable Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 118.

Corrective Action Plan

US Department of Health and Human Services The South Carolina Department of Health and Environmental Control respectfully submits the following corrective action plan for the year ended 6/30/21. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS?FEDERAL AWARD PROGRAM AUDIT DEPARTMENT OF HEALTH AND HUMAN SERVICES 2021-021 Epidemiology and Laboratory Capacity for Infectious Diseases ? Covid 19 ? Assistance Listing No. 93.323 Recommendation: We recommend that the Department strengthen policies and procedures to ensure that all information reported on federal reports is accurate and that a segregation of duties exists between report preparers and reviewers. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: To strengthen internal controls, the Department will develop and implement specific policies and standard operating procedures defining the Federal Financial Report (FFR) process and documenting the review and approval roles. All workpapers will be reviewed by staff other than the preparer of the FFR. Approvals will be documented. Name(s) of the contact person(s) responsible for corrective action: Kim Paradeses Planned completion date for corrective action plan: June 30, 2022

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2021-022
Period of Performance
SIGNIFICANT DEFICIENCYOTHER MATTERS

An expenditure was incurred after the end of the grant?s period of performance. Questioned Costs: Undetermined Context: For 1 of 40 expenditure transactions tested, program expenditures were incurred subsequent to the end of the grant?s period of performance (September 30, 2020). Cause: The Department?s internal controls failed to identify and prevent expenditures from being charged outside the grant?s period of performance. Effect: The Department may request reimbursement for expenses not incurred within the period of performance. Recommendation: We recommend that the Department strengthen internal controls to ensure all expenditures charged to federal awards are incurred during the grant's period of performance. Prior Year Single Audit Finding Number: Not applicable Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 118.

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Federal Agency: Department of Agriculture Federal Program Title: Special Supplemental Nutrition Program for Women, Infants, and Children (WIC) Assistance Listing No.: 10.557 Federal Grant ID Number: 5SC700715 Pass-Through Entity: Not applicable Award Period: October 1, 2019 through September 30, 2020 Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: 2 CFR 200.403(h) states that costs must be incurred during the approved budget period. Condition: An expenditure was incurred after the end of the grant?s period of performance. Questioned Costs: Undetermined Context: For 1 of 40 expenditure transactions tested, program expenditures were incurred subsequent to the end of the grant?s period of performance (September 30, 2020). Cause: The Department?s internal controls failed to identify and prevent expenditures from being charged outside the grant?s period of performance. Effect: The Department may request reimbursement for expenses not incurred within the period of performance. Recommendation: We recommend that the Department strengthen internal controls to ensure all expenditures charged to federal awards are incurred during the grant's period of performance. Prior Year Single Audit Finding Number: Not applicable Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 118.

Corrective Action Plan

US Department of Health and Human Services The South Carolina Department of Health and Environmental Control respectfully submits the following corrective action plan for the year ended 6/30/21. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS?FEDERAL AWARD PROGRAM AUDIT DEPARTMENT OF AGRICULTURE 2021-022 Special Supplemental Nutrition Program for Women, Infants, and Children (WIC) Assistance Listing No. 10.557 Recommendation: We recommend that the Department strengthen internal controls to ensure all expenditures charged to federal awards are incurred during the grant's period of performance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: To strengthen internal controls, the Department?s Program/Region staff will provide periodic reminders to appropriate staff regarding the selection of grants and the associated period of performance when processing payments. In addition, the Department?s Program/Region staff will perform post-closing reviews of expenditures to ensure the proper grant funding was used. Budget staff will monitor post-closing budget balances to assure only the balance of the unliquidated obligations remain on the books until the final FFR has been submitted. Name(s) of the contact person(s) responsible for corrective action: Kim Paradeses Planned completion date for corrective action plan: June 30, 2022

About Period of Performance →

FY 2021-06-30

MATERIAL NONCOMPLIANCE DISCLOSED$3,757,488,499 federal awards expended

FAC accepted this audit on January 27, 2025 — management decision was due July 27, 2025.

2021-001
Reporting
MATERIAL WEAKNESSREPEAT OF 2020-002

The Agency did not submit certain quarterly reports to the United States Department of Labor ("National Office") by the required due dates. Accordingly, the Agency did not comply with the Reporting compliance requirements related to the Unemployment Insurance program. Criteria: Per Part 4 of the OMB Compliance Supplement: The ETA 191 Report is required to be submitted on a quarterly basis to the National Office by the 25th of the month following the close of the quarter. Cause: Internal controls are not in place to ensure that all required reports are being submitted in accordance with the United States Department of Labor's timelines. The reports were affected by the unprecedented COVID-19 pandemic, which required all program resources to focus on pandemic claims processing. Some of the data needed for these reports was delayed due to program and system resources focused on claims processing as well as the difficulty experienced due to the requirement of staff to shelter at home beginning April 2020 under the South Carolina Governor's Executive Order and restricted access to records located in the office. Effect: As a result, the Agency becomes more susceptible to having its level of federal award funding reduced by the United States Department of Labor when it violates its Reporting compliance requirements applicable to the Unemployment Insurance program. Context: We inspected a sample of quarterly reports and noted the following exceptions: Unemployment Insurance - Three (3) ETA 191 quarterly reports of the four (4) reports tested. Recommendation: We recommend that management carefully review the terms and conditions included in the supporting grant agreements and the Reporting requirements included in the OMB Compliance Supplement applicable to the Unemployment Insurance and the Employment Services Cluster programs and implement controls to ensure that all reports are filed on a timely basis.

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Item 2021-001: Reporting (Material Weakness over Reporting and Non-Material Noncompliance) Condition: The Agency did not submit certain quarterly reports to the United States Department of Labor ("National Office") by the required due dates. Accordingly, the Agency did not comply with the Reporting compliance requirements related to the Unemployment Insurance program. Criteria: Per Part 4 of the OMB Compliance Supplement: The ETA 191 Report is required to be submitted on a quarterly basis to the National Office by the 25th of the month following the close of the quarter. Cause: Internal controls are not in place to ensure that all required reports are being submitted in accordance with the United States Department of Labor's timelines. The reports were affected by the unprecedented COVID-19 pandemic, which required all program resources to focus on pandemic claims processing. Some of the data needed for these reports was delayed due to program and system resources focused on claims processing as well as the difficulty experienced due to the requirement of staff to shelter at home beginning April 2020 under the South Carolina Governor's Executive Order and restricted access to records located in the office. Effect: As a result, the Agency becomes more susceptible to having its level of federal award funding reduced by the United States Department of Labor when it violates its Reporting compliance requirements applicable to the Unemployment Insurance program. Context: We inspected a sample of quarterly reports and noted the following exceptions: Unemployment Insurance - Three (3) ETA 191 quarterly reports of the four (4) reports tested. Recommendation: We recommend that management carefully review the terms and conditions included in the supporting grant agreements and the Reporting requirements included in the OMB Compliance Supplement applicable to the Unemployment Insurance and the Employment Services Cluster programs and implement controls to ensure that all reports are filed on a timely basis.

Corrective Action Plan

Item 2021-001 Reporting (Material Weakness over reporting and Non-Material Noncompliance) SCDEW implemented a corrective action plan in response to this finding during the year ended June 30, 2021 in response to similar finding for audits of prior periods a brief summary follows: The SCDEW Enterprise and Project Management Office (EPMO) is tasked with monitoring agency wide reporting deadlines. The EPMO developed a master reporting database that includes relevant identifying information including report names, Agency, SCDEW contact, reporting frequency and due dates. Individual reporters at SCDEW submit data to EPMO on the status of the required filings. EPMO routinely reports the status of filings to executive leadership.

Prior Finding References

2020-002

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2021-001
Eligibility
MATERIAL WEAKNESSMODIFIED OPINIONQUESTIONED COSTS

In March 2020, the President signed the CARES Act that authorized additional funding under the Unemployment Insurance (UI) program. This was followed by additional federal and state funding programs that increased grants available and modified eligibility requirements to support changes in employment status caused by the COVID-19 pandemic. Certain benefits under these programs extended into fiscal year 2022. Subsequent to June 30, 2020, supplemental assistance provided by the CARES Act and other federal legislation supported elevated sustained benefit payments through June 2021 in excess of $3.6 billion. South Carolina ended its participation in the supplementary federal programs in June 2021 and has seen benefit payments drop significantly returning to pre-pandemic levels by October 2021. There was a priority on distributing funds under self-attestation strategy with limited income verification to expedite disbursement of funds and support individuals in greatest need. As a result of this, many states saw a significant increase in fraudulent claims to historical highs. The U.S. Department of Labor and the Agency have partnered to investigate the extent and methods used to perpetrate fraud. For the Agency, eligibility determinations made by the management followed existing policies and procedures for this pandemic funding; however, to meet federal and state expectations regarding the quick payment of federal pandemic benefits, the policies and procedures in place were not the usual policies and procedures and so they were not adequate to completely prevent fraudulent claims. The Agency’s detective controls did identify abnormal claim activity; however, it was after the claims had already been paid. During our testing of a sample of 360 benefit payments we identified 23 payments that were fraudulent, total value of payments tested was $109,375 and total amount of fraud was $7,230. The extrapolated fraud amount over the total benefit payment of $3.757 billion would be $252.9 million. Criteria: Per 2 CFR §200 Appendix XI, state responsibilities include: (1) establishing specific, detailed policies and operating procedures which comply with the requirements of federal laws and regulations; (2) determining the state unemployment insurance tax structure; (3) collecting state unemployment insurance contributions from employers (commonly called “unemployment taxes”); (4) determining claimant eligibility and disqualification provisions; (5) making payment of UI benefits to claimants; (6) managing the program’s revenue and benefit administrative functions; (7) administering the programs in accordance with established policies and procedures; and (8) enacting state UC law that conforms with federal UC law and that state law and operations substantially comply with federal law. Effect: A lack of adequate internal controls over eligibility determinations may increase the likelihood of fraudulent claims being submitted and incorrectly paid. Known Questioned Costs: During our testing of a sample of 360 benefit payments we identified 23 payments that were fraudulent, the total value of payments tested was $109,375 and total amount of known fraud was $7,230. Likely Questioned Costs: Based upon the extrapolated fraud amount over the total benefit payment of $3.757 billion the total amount of fraud would likely be $252.9 million. Cause: The Agency experienced unprecedented claims volume during fiscal 2021 with increased funding and additional program requirements with a priority for efficient distribution from both the U.S. Department of Labor and state officials. Recommendation: We recommend that the Agency continue to review, monitor, and enhance eligibility procedures to detect and/or prevent fraudulent claimants from receiving benefits. The Agency should work to enhance and update its assessment of risks related to the eligibility process and implement internal controls to help mitigate future fraudulent claims.

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Condition: In March 2020, the President signed the CARES Act that authorized additional funding under the Unemployment Insurance (UI) program. This was followed by additional federal and state funding programs that increased grants available and modified eligibility requirements to support changes in employment status caused by the COVID-19 pandemic. Certain benefits under these programs extended into fiscal year 2022. Subsequent to June 30, 2020, supplemental assistance provided by the CARES Act and other federal legislation supported elevated sustained benefit payments through June 2021 in excess of $3.6 billion. South Carolina ended its participation in the supplementary federal programs in June 2021 and has seen benefit payments drop significantly returning to pre-pandemic levels by October 2021. There was a priority on distributing funds under self-attestation strategy with limited income verification to expedite disbursement of funds and support individuals in greatest need. As a result of this, many states saw a significant increase in fraudulent claims to historical highs. The U.S. Department of Labor and the Agency have partnered to investigate the extent and methods used to perpetrate fraud. For the Agency, eligibility determinations made by the management followed existing policies and procedures for this pandemic funding; however, to meet federal and state expectations regarding the quick payment of federal pandemic benefits, the policies and procedures in place were not the usual policies and procedures and so they were not adequate to completely prevent fraudulent claims. The Agency’s detective controls did identify abnormal claim activity; however, it was after the claims had already been paid. During our testing of a sample of 360 benefit payments we identified 23 payments that were fraudulent, total value of payments tested was $109,375 and total amount of fraud was $7,230. The extrapolated fraud amount over the total benefit payment of $3.757 billion would be $252.9 million. Criteria: Per 2 CFR §200 Appendix XI, state responsibilities include: (1) establishing specific, detailed policies and operating procedures which comply with the requirements of federal laws and regulations; (2) determining the state unemployment insurance tax structure; (3) collecting state unemployment insurance contributions from employers (commonly called “unemployment taxes”); (4) determining claimant eligibility and disqualification provisions; (5) making payment of UI benefits to claimants; (6) managing the program’s revenue and benefit administrative functions; (7) administering the programs in accordance with established policies and procedures; and (8) enacting state UC law that conforms with federal UC law and that state law and operations substantially comply with federal law. Effect: A lack of adequate internal controls over eligibility determinations may increase the likelihood of fraudulent claims being submitted and incorrectly paid. Known Questioned Costs: During our testing of a sample of 360 benefit payments we identified 23 payments that were fraudulent, the total value of payments tested was $109,375 and total amount of known fraud was $7,230. Likely Questioned Costs: Based upon the extrapolated fraud amount over the total benefit payment of $3.757 billion the total amount of fraud would likely be $252.9 million. Cause: The Agency experienced unprecedented claims volume during fiscal 2021 with increased funding and additional program requirements with a priority for efficient distribution from both the U.S. Department of Labor and state officials. Recommendation: We recommend that the Agency continue to review, monitor, and enhance eligibility procedures to detect and/or prevent fraudulent claimants from receiving benefits. The Agency should work to enhance and update its assessment of risks related to the eligibility process and implement internal controls to help mitigate future fraudulent claims.

Corrective Action Plan

The South Carolina Department of Employment and Workforce (SCDEW) immediately recognized the increased fraud risk presented by the federal pandemic programs. ln an effort to deter this obvious fraud threat, SCDEW initially informed every applicant for federal pandemic benefits that they might be required to provide proof of their employment or self-employment at a future time. The USDOL, however, ordered SCDEW to remove this notification because, in the words of one USDOL representative, such a warning might deter a claimant from applying for federal pandemic benefits. USDOL subsequently issued guidance prohibiting states from requiring proof of employment or self-employment as an eligibility requirement to receive federal pandemic benefits. Therefore, all a fraudster had to do to receive federal benefits was simply tell a state they were unemployed as a result of the COVID-19 pandemic. SCDEW was prohibited from requiring that fraudster to prove that they were even employed, let alone that they were unemployed because of the pandemic. Many of the items identified as paid fraudulent claims were caused by SCDEW's compliance with the USDOL guidelines. SCDEW complied with this guidance, even though it disagreed with USDOL's highly technical parsing of federal law, and SCDEW advocated for Congress to amend the law to clearly establish commonsense fraud protections. While awaiting Congressional action, SCDEW implemented numerous fraud detection and prevention tools and strategies to minimize the potential fraud exacerbated by lax federal requirements. Unfortunately, Congress did not amend the law until late December 2020. As a result, eligibility determinations made by SCDEW prior to the law change followed the federal guidance for this pandemic funding; however, to meet federal and state expectations regarding the quick payment of federal pandemic benefits, the federal policies and procedures SCDEW was forced to adopt were not adequate to completely prevent fraudulent claims. SCDEW continues to review, monitor, and enhance eligibility processes and procedures to prevent and detect fraudulent claims. We also updated our internal controls to help mitigate future fraudulent claims. The COVID pandemic created unprecedented challenges for eve1y state workforce agency due to the combination of historic claim volume, the availability of a staggering amount of federal money, and new programs with lax eligibility and verification requirements that had to be implemented quickly, despite often changing federal guidance. These factors created a perfect storm for sophisticated fraudsters 10 exploit. In response, SCDEW took numerous aggressive steps. In mid-2020, SCDEW required applicants to provide copies of their driver's license or passport to prove their identity before receiving benefits. SCDEW also implemented identity verification questions through Lexis Nexis that every claimant had to pass before processing a claim. This was further enhanced in March 2021, when South Carolina was one of the first states to implement digital identity verification through ID.me. SCDEW also implemented reCAPTCHA to prevent against bot attacks, implemented new data sharing agreements, and increased the number of staff dedicated to investigating fraudulent claim activity to over fifty at the peak of the pandemic programs. SCDEW continuously reviews its fraud detection and prevention activities to stay ahead of emerging fraud schemes. Since the height of the pandemic, SCDEW has increased its data crossmatching, partnered with the State Law Enforcement Division to have a financial fraud investigator dedicated to unemployment insurance fraud, and made numerous enhancements to its computer systems to combat fraud and preserve the integrity of the unemployment insurance system. For more comprehensive explanation and response, please sec August 26, 2024 letter attached from Paul Famolari, Assistant Executive Director of Unemployment Insurance. The Agency's contact person responsible for the corrective action plan is Jacquelyn Carlen, CFO. The completion date of the corrective action plan was June 20, 2021.

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2021-002
Reporting
SIGNIFICANT DEFICIENCYOTHER MATTERS

A reporting discrepancy was identified on a federal financial report filed by the Office. Questioned Costs: None Context: On one of five SF-425 reports selected for testing, reported recipient share of expenditures did not agree to applicable Office supporting documentation. The Office submitted an amended report to correct the discrepancy identified during the audit. Cause: A portion of recipient share activity was mistakenly excluded from the report and the discrepancy was not detected during the Office?s review and approval process. Effect: Recipient share of expenditures was misstated on a federal financial report. Recommendation: We recommend that the Office strengthen its internal controls and processes to ensure that federal reports are free from error prior to submission. Prior Year Single Audit Report Finding Number: Not applicable Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 96.

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Federal Agency: Department of Justice Federal Program Title: Crime Victim Assistance Assistance Listing: 16.575 Federal Grant ID Number: 2017-VA-GX-4040 Pass-Through Entity: Not applicable Award Period: October 1, 2016 through September 30, 2020 Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: Per 2 CFR 200.303 Internal controls, 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. Condition: A reporting discrepancy was identified on a federal financial report filed by the Office. Questioned Costs: None Context: On one of five SF-425 reports selected for testing, reported recipient share of expenditures did not agree to applicable Office supporting documentation. The Office submitted an amended report to correct the discrepancy identified during the audit. Cause: A portion of recipient share activity was mistakenly excluded from the report and the discrepancy was not detected during the Office?s review and approval process. Effect: Recipient share of expenditures was misstated on a federal financial report. Recommendation: We recommend that the Office strengthen its internal controls and processes to ensure that federal reports are free from error prior to submission. Prior Year Single Audit Report Finding Number: Not applicable Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 96.

Corrective Action Plan

U. S. Department of Justice The South Carolina Attorney General?s Office respectfully submits the following corrective action plan for the year ended June 30, 2021. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS?FEDERAL AWARD PROGRAM AUDIT 2021-002 Crime Victim Assistance ? Assistance Listing No. 16.575 Recommendation: We recommend that the Office strengthen is internal controls and processes to ensure that federal reports are free from error prior to submission. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: When generating reports for quarterly FFR, a BW (Business Warehouse) or SCEIS cumulative report will be generated from inception to-date to ensure all federal data is captured accurately. A FFR tracking log will be maintained to reflect quarterly and cumulative match amounts to ensure total effort is reported. Any adjustments will be noted in the tracking log noting the reason for the adjustment. These procedures will be implemented immediately. The agency is currently working to implement a new grants management system that will track federal and match expenditures that will assist with federal reporting to ensure amounts are reported accurately. The projected implementation start date for the new grants accounting system is October 1, 2022. Full implementation will be completed within twelve months. Name(s) of the contact person(s) responsible for corrective action: Kelley Anderson Planned completion date for corrective action plan: Tracking log adjustments will be implemented immediately. If the Federal Cognizant Agency of Oversight or Audit has questions regarding this plan, please call Kelley Anderson at 803-734-0779.

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2021-002
Reporting
MATERIAL WEAKNESSMODIFIED OPINIONREPEAT OF 2020-002

The Agency did not submit certain quarterly reports to the United States Department of Labor (“National Office”) by the required due dates. Accordingly, the Agency did not comply with the Reporting compliance requirements related to the Unemployment Insurance program. Criteria: Per Part 4 of the OMB Compliance Supplement: • The ETA 191 Report is required to be submitted on a quarterly basis to the National Office by the 25th of the month following the close of the quarter. Cause: Internal controls are not in place to ensure that all required reports are being submitted in accordance with the United States Department of Labor’s timelines. The reports were affected by the unprecedented COVID-19 pandemic, which required all program resources to focus on pandemic claims processing. Some of the data needed for these reports was delayed due to program and system resources focused on claims processing. Effect: As a result, the Agency becomes more susceptible to having its level of federal award funding reduced by the United States Department of Labor when it violates its Reporting compliance requirements applicable to the Unemployment Insurance program. Context: We inspected a sample of quarterly reports and noted the following exceptions: • Unemployment Insurance – Three (3) ETA 191 quarterly reports of four (4) reports tested Recommendation: We recommend that management carefully review the terms and conditions included in the supporting grant agreements and the Reporting requirements included in the OMB Compliance Supplement applicable to the Unemployment Insurance and the Employment Services Cluster programs and implement controls to ensure that all reports are filed on a timely basis.

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Condition: The Agency did not submit certain quarterly reports to the United States Department of Labor (“National Office”) by the required due dates. Accordingly, the Agency did not comply with the Reporting compliance requirements related to the Unemployment Insurance program. Criteria: Per Part 4 of the OMB Compliance Supplement: • The ETA 191 Report is required to be submitted on a quarterly basis to the National Office by the 25th of the month following the close of the quarter. Cause: Internal controls are not in place to ensure that all required reports are being submitted in accordance with the United States Department of Labor’s timelines. The reports were affected by the unprecedented COVID-19 pandemic, which required all program resources to focus on pandemic claims processing. Some of the data needed for these reports was delayed due to program and system resources focused on claims processing. Effect: As a result, the Agency becomes more susceptible to having its level of federal award funding reduced by the United States Department of Labor when it violates its Reporting compliance requirements applicable to the Unemployment Insurance program. Context: We inspected a sample of quarterly reports and noted the following exceptions: • Unemployment Insurance – Three (3) ETA 191 quarterly reports of four (4) reports tested Recommendation: We recommend that management carefully review the terms and conditions included in the supporting grant agreements and the Reporting requirements included in the OMB Compliance Supplement applicable to the Unemployment Insurance and the Employment Services Cluster programs and implement controls to ensure that all reports are filed on a timely basis.

Corrective Action Plan

SCDEW implemented a corrective action plan in response to this finding during the year ended June 30, 2021 in response to similar findings in prior year audits. The SCDEW Enterprise and Project Management Office (EPMO) is tasked with monitoring agency wide reporting deadlines. The EPMO developed a master reporting database that includes relevant identifying infom1ation including report name, agency, SCDEW contact, reporting frequency and due dates. Individual reporters at SCDEW submit data to EPMO on the status of the required filings. EPMO routinely reports the status of filings to executive leadership. The Agency's contact person responsible for the corrective action plan is Jacquelyn Carlen, CFO. The completion date of the corrective action plan was September 30, 2022.

Prior Finding References

2020-002

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2021-003
Subrecipient Monitoring
SIGNIFICANT DEFICIENCYOTHER MATTERS

The Office was not in compliance with several subrecipient monitoring requirements. Questioned Costs: None Context: The following discrepancies were encountered during testing of twelve subrecipients selected for testing: Two subrecipient single audit reports were not obtained for review in accordance with federal monitoring requirements. Three subrecipients had single audit findings where documentation was not adequate to demonstrate appropriate follow-up or management decision on the findings. Nine subrecipients did not receive site visits within the timeframe set out in the monitoring plan. Cause: The global pandemic?s impact on staffing and equipment contributed to the Office?s inability to fully comply with certain monitoring requirements. Effect: The Office was not in compliance with certain federal subrecipient monitoring requirements. Recommendation: We recommend that the Office review and strengthen subrecipient monitoring controls and procedures to ensure compliance with all federal subrecipient monitoring requirements. Prior Year Single Audit Report Finding Number: Not applicable Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 96.

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Federal Agency: Department of Justice Federal Program Title: Crime Victim Assistance Assistance Listing: 16.575 Federal Grant ID Number: Various Pass-Through Entity: Not applicable Award Period: Various Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: 2 CFR 200.332 (d) describes pass-through entity requirements for reviewing single audit reports of subrecipients, including requirements for follow-up and management decisions on applicable audit findings. 28 CFR 94.106 (b) specifies the pass-through entity frequency requirements for on-site monitoring of subrecipients. Condition: The Office was not in compliance with several subrecipient monitoring requirements. Questioned Costs: None Context: The following discrepancies were encountered during testing of twelve subrecipients selected for testing: Two subrecipient single audit reports were not obtained for review in accordance with federal monitoring requirements. Three subrecipients had single audit findings where documentation was not adequate to demonstrate appropriate follow-up or management decision on the findings. Nine subrecipients did not receive site visits within the timeframe set out in the monitoring plan. Cause: The global pandemic?s impact on staffing and equipment contributed to the Office?s inability to fully comply with certain monitoring requirements. Effect: The Office was not in compliance with certain federal subrecipient monitoring requirements. Recommendation: We recommend that the Office review and strengthen subrecipient monitoring controls and procedures to ensure compliance with all federal subrecipient monitoring requirements. Prior Year Single Audit Report Finding Number: Not applicable Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 96.

Corrective Action Plan

U. S. Department of Justice The South Carolina Attorney General?s Office respectfully submits the following corrective action plan for the year ended June 30, 2021. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS?FEDERAL AWARD PROGRAM AUDIT 2021-003 Crime Victim Assistance ? Assistance Listing No. 16.575 Recommendation: We recommend that the Office review and strengthen subrecipient monitoring controls and procedures to ensure that it is in compliance with all federal subrecipient monitoring requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Procedures were written to strengthen internal controls to ensure all subrecipients submit single or program specific audits in a timely manner. A step-by-step process of notification, action requirements and follow-up will be implemented immediately. A tracking log will capture the necessary data, such as, date report received, completed review sheet, review of corrective action plan and necessary follow-up to ensure monitoring is complete and compliant with monitoring requirements. Furthermore, the agency is updating its process and tracking system to ensure all site-monitoring is conducted once every three years as stated in procedures for all subgrantees and will be reviewed and approved by the Division Director. Name(s) of the contact person(s) responsible for corrective action: Kelley Anderson and Billy House Planned completion date for corrective action plan: Immediately If the Federal Cognizant Agency of Oversight or Audit has questions regarding this plan, please call Kelley Anderson at 803-734-0779.

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2021-004
Eligibility
MATERIAL WEAKNESSMODIFIED OPINIONREPEAT OF 2020-006

The Department did not consistently perform timely annual eligibility reviews for Medicaid and CHIP recipients in accordance with Section 101.10 of the South Carolina Medicaid Policies and Procedures Manual. Questioned Costs: Unknown Context: We tested 120 individual recipients (60 each for Medicaid and CHIP) to ensure the Department complied with applicable eligibility requirements. We determined the Department did not comply with the annual review requirement for 37 Medicaid recipients and 43 CHIP recipients. Cause: Department personnel stated they did not comply with the annual review requirement for these recipients due to a backlog in case processing. Effect: In the absence of an annual review, Medicaid and CHIP recipients may continue to receive benefits without meeting eligibility requirements. Recommendation: We recommend eligibility reviews be performed annually in accordance with the South Carolina Medicaid Policies and Procedures Manual. Prior Year Single Audit Finding Number: 2020-006 Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 98.

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Federal Agency: Department of Health and Human Services Federal Program Title: Medicaid Cluster; Children?s Health Insurance Program (CHIP) Assistance Listing No.: 93.775, 93.777, 93.778; 93.767 Federal Grant ID Number: 05-2005SC5MAP, 05-1905SC5021 Pass-Through Entity: Not applicable Award Period: October 1, 2018 through September 30, 2021 Type of Finding: Material weakness in internal control over compliance, material noncompliance Criteria: Section 2.1 of the Department?s Title XIX (Medicaid) State Plan (Application, Determination of Eligibility and Furnishing Medicaid) affirms that it meets the requirements outlined in 42 CFR Part 435.916, which states in part, that the agency must promptly determine eligibility between regular renewals of eligibility. In addition, Section 101.10 of the South Carolina Medicaid Policies and Procedures Manual states that the Department must complete an annual review for certain payment categories. Furthermore, the Department?s Title XXI (CHIP) State Plan attests that CHIP will operate as a Medicaid expansion program. Therefore, the aforementioned regulation and policies apply to both programs. Condition: The Department did not consistently perform timely annual eligibility reviews for Medicaid and CHIP recipients in accordance with Section 101.10 of the South Carolina Medicaid Policies and Procedures Manual. Questioned Costs: Unknown Context: We tested 120 individual recipients (60 each for Medicaid and CHIP) to ensure the Department complied with applicable eligibility requirements. We determined the Department did not comply with the annual review requirement for 37 Medicaid recipients and 43 CHIP recipients. Cause: Department personnel stated they did not comply with the annual review requirement for these recipients due to a backlog in case processing. Effect: In the absence of an annual review, Medicaid and CHIP recipients may continue to receive benefits without meeting eligibility requirements. Recommendation: We recommend eligibility reviews be performed annually in accordance with the South Carolina Medicaid Policies and Procedures Manual. Prior Year Single Audit Finding Number: 2020-006 Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 98.

Corrective Action Plan

Department of Health & Human Services Centers for Medicare & Medicaid Services (CMS) 31 Forsyth Street, SW, Room 4T20 Atlanta, Georgia 30303-8909 The South Carolina Department of Health and Human Services respectfully submits the following corrective action plan for the year ended 6/30/21. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS ? FEDERAL AWARD PROGRAM AUDIT DEPARTMENT OF HEALTH AND HUMAN SERVICES 2021-004 Medicaid Cluster; Children?s Health Insurance Program (CHIP) ? Assistance Listing No. 93.775, 93.777, 93.778; 93.767 Recommendation: We recommend eligibility reviews be performed annually in accordance with the South Carolina Medicaid Policies and Procedures Manual. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: In 2021, SCDHHS (the agency) developed a tentative unwinding operational plan for completing pending eligibility and enrollment actions at the conclusion of the public health emergency (PHE). The state is in the process of updating the plan, based on CMS guidance and tools issued on 3/4/22. However, the basic components of the plan are still relevant. Current Activities in Progress ? Policy and procedure updates for unwinding from PHE requirements ? System updates required for unwinding from PHE policies and procedures ? Development of communication plan for sharing relevant information regarding unwinding activities with stakeholders such as beneficiaries, agency staff, call centers, providers, managed care plans and community organizations ? Preparation for outreach strategies to inform beneficiaries about the review process and encourage them to report changes in contact information. Current efforts include texting and outbound calling initiatives. ? Planning for handling increased agency contacts regarding reviews or address changes ? Planning for handling increased appeals that are possible once continuous enrollment period has ended Prioritization of Reviews The agency will use a hybrid approach for the distribution of redeterminations at the end of the PHE. Redeterminations will be prioritized to promote accurate coverage, as well as continuity of coverage. Attention will be given to prevent incorrect decisions that will then likely result in a new application being submitted, unnecessarily adding to the volume of work that must be completed. Continuity of coverage applies to both beneficiaries eligible for Medicaid, as well as those who may be eligible for Marketplace coverage and subsidies. Updated data reporting is in progress to compare to volumes identified earlier in the PHE so that decisions can be made for distribution of prioritized reviews, based on CMS guidelines and the desire to achieve a manageable distribution of reviews for subsequent years. Priority groups include: ? Pregnant Women category greater than 12 months post-partum ? Infants over 1 year old ? Individuals Over 19 in Children?s category ? Parent Caretaker Relatives who no longer have dependent children in the home ? Individuals who have aged out of Foster Care ? Individuals in the Refugee category greater than 8 months from Entry date ? Individuals receiving Medicaid because of Supplemental Security Income (SSI) benefits who will need to provide additional information to assess for eligibility in other categories The agency reached out once to individuals no longer eligible for SSI and are receiving long term care services during the PHE so that they would have the opportunity to provide the needed information and undergo the ex parte process prior to the end of the PHE. Any beneficiaries who did not respond or were found not eligible during the PHE remained in their current payment category and will receive another opportunity after the PHE ends. The remainder of reviews will be distributed across the 12-month period following the end of the PHE to allow for a relatively equal distribution, with consideration for periods of anticipated higher application volume such as open enrollment. Staffing Attrition during the PHE and an increase in workload and anticipation of work to be completed at the end of the PHE has resulted in a significant hiring of MAGI, Non-MAGI and Long-Term Care Eligibility Specialists which will continue at least through the end of federal fiscal year (FFY) 2022, depending on impacts of any additional attrition. Forty-seven (47) Non-MAGI workers have been hired and trained to date and 96 additional Non-MAGI workers are expected to be hired by the end of FFY 2022. Forty-three (43) Long-Term-Care workers have been hired and trained, with an additional 27 to be hired by the end of FFY2022. Approximately 100 additional MAGI staff will be hired as well. The additional staff is intended to build capacity for current work, as well as in preparation for resumption of normal review processing at the end of the continuous enrollment period. Staff are trained to assist with current work upon hiring and all staff will undergo training on redetermination processing in time for reinstatement of the redetermination process at the end of the PHE. Workload Management Workload management is an important component of current operations and will be critical as the state unwinds after the PHE ends. Workload management allows the agency to predict and react to staffing needs and better plan for timely decisions. Eligibility's Workload Management team monitors work queues daily and collaborates with eligibility supervisors and leadership to address timeliness of case processing and distribution of work. This may include shifting work assignments, reprioritization of work, referral to additional training, or other mechanisms to increase efficiency. Name(s) of the contact person(s) responsible for corrective action: Lori Risk Planned completion date for corrective action plan: 14 months from end of PHE or end of continuous enrollment requirement.

Prior Finding References

2020-006

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2021-005
Eligibility
SIGNIFICANT DEFICIENCYREPEAT OF 2020-004OTHER MATTERS

Eligibility files did not contain adequate documentation to support the Medicaid and CHIP recipients? eligibility statuses. Questioned Costs: Unknown Context: We tested 120 individual recipients (60 each for Medicaid and CHIP) to ensure the Department complied with applicable eligibility requirements. We determined the Department did not maintain adequate documentation of eligibility for ten Medicaid recipients and five CHIP recipients. Cause: The Department transitioned to an online eligibility system, the Medicaid Eligibility Determination System (MEDS), in July 2013. According to Department personnel, documentation in some of the paper files may not have been scanned into the system since the transition. For cases opened after the transition, the omissions were due to worker error. Effect: The Department could not support eligibility determinations in accordance with its State plan. Recommendation: We recommend the Department continue its efforts to maintain documentation to support eligibility determinations in accordance with its State plan and federal regulations. Prior Year Single Audit Finding Number: 2020-004 Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 100.

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Federal Agency: Department of Health and Human Services Federal Program Title: Medicaid Cluster; Children?s Health Insurance Program (CHIP) Assistance Listing No.: 93.775, 93.777, 93.778; 93.767 Federal Grant ID Number: 05-2005SC5MAP; 05-1905SC5021 Pass-Through Entity: Not applicable Award Period: October 1, 2018 through September 30, 2021 Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: Per 42 CFR 435.914 (a), the agency must include in each applicant?s case record facts to support the agency?s decision on his or her application. In addition, Section 4.7 of the Department?s Title XIX (Medicaid) State Plan (Maintenance of Records) affirms that it meets the requirements outlined in 42 CFR 431.17 (b), that a State plan must provide that the Medicaid agency will maintain or supervise the maintenance of records necessary for the proper and efficient operation of the plan. Furthermore, the Department?s Title XXI (CHIP) State Plan attests that CHIP will operate as a Medicaid expansion program. Therefore, the aforementioned regulations apply to both programs. Condition: Eligibility files did not contain adequate documentation to support the Medicaid and CHIP recipients? eligibility statuses. Questioned Costs: Unknown Context: We tested 120 individual recipients (60 each for Medicaid and CHIP) to ensure the Department complied with applicable eligibility requirements. We determined the Department did not maintain adequate documentation of eligibility for ten Medicaid recipients and five CHIP recipients. Cause: The Department transitioned to an online eligibility system, the Medicaid Eligibility Determination System (MEDS), in July 2013. According to Department personnel, documentation in some of the paper files may not have been scanned into the system since the transition. For cases opened after the transition, the omissions were due to worker error. Effect: The Department could not support eligibility determinations in accordance with its State plan. Recommendation: We recommend the Department continue its efforts to maintain documentation to support eligibility determinations in accordance with its State plan and federal regulations. Prior Year Single Audit Finding Number: 2020-004 Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 100.

Corrective Action Plan

Department of Health & Human Services Centers for Medicare & Medicaid Services (CMS) 31 Forsyth Street, SW, Room 4T20 Atlanta, Georgia 30303-8909 The South Carolina Department of Health and Human Services respectfully submits the following corrective action plan for the year ended 6/30/21. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS ? FEDERAL AWARD PROGRAM AUDIT DEPARTMENT OF HEALTH AND HUMAN SERVICES 2021-005 Medicaid Cluster; Children?s Health Insurance Program (CHIP) ? Assistance Listing No. 93.775, 93.777, 93.778; 93.767 Recommendation: We recommend the Department continue its efforts to maintain documentation to support eligibility determinations in accordance with its State plan and federal regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Staff Performance Evaluation and Remediation: The eligibility performance and remediation process continue to include key elements for review which lead to a correct or incorrect eligibility determination, including the presence of required documentation. Eligibility policies and procedures from March 1, 2020, provide instructions for a worker to ensure the case file is complete for all eligibility criteria based on policy, prior to making an eligibility determination. This policy is included in staff training and is evaluated as part of quality assurance activities. The Eligibility Quality Assurance Team (EQAT) members are trained to evaluate MAGI, Non-MAGI or Long-Term Care determinations for accuracy of those determinations, as well as vital procedural errors that are most likely to impact eligibility. On the first business day of each month, supervisors receive employee performance results for their staff. Supervisors are responsible for monitoring staff daily by using data available via system of record, the electronic document management system (OnBase), workload management software, as well as through case spot reviews. Supervisors meet monthly with each staff member to review Eligibility Quality Assurance (EQA) findings to identify and address issues that impact performance, as well as to facilitate corrections to incorrect determinations identified through the EQA process. Errors are identified via error codes and descriptions. EQA reviews are conducted and housed in a state-developed tool to allow for creation of reports that can be generated based on supervisor, worker, work type, error code or overall accuracy. The agency compares errors identified through audits and federal reviews such as payment error rate measurement with EQA error trends and use this monitoring method to identify trends, develop mitigation strategies and to determine impact of those strategies on these errors. In addition, the agency collaborates with our third-party quality review entity, the University of South Carolina Core for Applied Research and Evaluation (USC CARE) to conduct focused reviews to assist with monitoring trends, providing recommendations for mitigation (e.g., policy clarifications, training, or supervisor intervention) and impact of mitigation strategies. During the 4th quarter of calendar year 2021, 10,767 quality reviews were conducted by the EQA team. The agency monitors the following errors and will continue to do so on a quarterly basis: Internal EQA findings: Error Description, Q1 CY2021 % Cases Reviewed, Q2 CY2021 % Cases Reviewed, Q3 CY2021 % Cases Reviewed, Q4 CY2021 % Cases Reviewed: The application was not signed, .03%, .03%, .05%, .04%; The application could not be located in the case file, .05%, .04%, .04%, .02%; Level of care was not in the case file or in Phoenix, .01%, .02%, .01%, .02%; The case record was missing SSN or proof of application for SSN, .49%, .57%, .19%, .20% Policy Update: Currently, Medicaid Policy and Procedure Manual (MPPM) review requirements (MPPM 101.10) include a requirement to review and upload State Data Exchange (SDX) interface data into the casefile for Payment Categories 54 (Supplemental Security Income (SSI) Nursing Home) and 86 (Optional State Supplementation with SSI) each year, to confirm continued SSI eligibility although an annual review itself is not required. As the agency has transitioned to a rules-based system that reacts to SDX interface data updates, stores information in the case record and takes appropriate action in response to updates, this policy will be updated to remove this requirement. Staff Reminders: In response to these findings, the Eligibility department will send email communication to managers, supervisors and staff regarding these findings and a reminder of documentation requirements in policy, as well as to ensure supervisors are assessing for this requirement in casefile spot checks. This will also be discussed on an upcoming Eligibility Supervisor call. Name(s) of the contact person(s) responsible for corrective action: Lori Risk Planned completion date for corrective action plan: Policy update and Staff communication - June 2022; EQA Procedures - Ongoing

Prior Finding References

2020-004

About Eligibility →
2021-006
Matching, Level of Effort, Earmarking
SIGNIFICANT DEFICIENCYOTHER MATTERS

The Department did not comply with the federal matching requirement for family planning services, family planning related services, or Part B assistance premium payments. Questioned Costs: None Context: We tested 60 individual claims to ensure the Department complied with matching requirements. We determined the Department did not use the proper Federal Medical Assistance Percentage (FMAP) for all (two) of the family planning related services selected for testing as well as one of the Part B assistance premium payments selected for testing. Cause: Department personnel stated that an improper modifier was used causing sexually transmitted infection testing and treatment services to map to the incorrect internal fund code and FMAP. Also, Department personnel stated, regarding the Part B assistance premium payment, that an incorrect functional area was assigned to the report?s translation table, resulting in the incorrect FMAP being used. Staff realized the error and corrected the translation table to the correct functional area. However, staff failed to follow through to ensure the entry was posted correctly or to process a journal entry in the accounting system to correct the posting. Effect: The Department?s controls did not consistently detect errors identified which could lead to improper payments. Recommendation: We recommend the Department correct the errors in MMIS and strengthen its controls to ensure errors are corrected when identified. Prior Year Single Audit Finding Number: Not applicable Views of Responsible Offices and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 102.

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Federal Agency: Department of Health and Human Services Federal Program Title: Medicaid Cluster Assistance Listing No.: 93.775, 93.777, 93.778 Federal Grant ID Number: 05-2005SC5MAP Pass-Through Entity: Not applicable Award Period: October 1, 2020 through September 30, 2021 Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: Per 42 CFR 433.10 (c) (1), under Section 1905 (a) (5) of the Act, the federal share of state expenditures for family planning services is 90 percent. In addition, per the Centers for Medicare & Medicaid Services (CMS) State Medicaid Director Letter 14-003, family planning related services are matched at the states? regular federal medical assistance percentage. Also, per 42 CFR 433.10 (c) (5) (i), under section 1933(d) of the Act, the federal share of state expenditures for Medicare Part B premiums described in section 1905(p)(3)(A)(ii) of the Act on behalf of Qualifying Individuals described in section 1902(a)(10)(E)(iv) of the Act, is 100 percent, to the extent that the assistance does not exceed the state's allocation under paragraph (c)(5)(ii) of this section. To the extent that the assistance exceeds that allocation, the federal share is 0 percent. Condition: The Department did not comply with the federal matching requirement for family planning services, family planning related services, or Part B assistance premium payments. Questioned Costs: None Context: We tested 60 individual claims to ensure the Department complied with matching requirements. We determined the Department did not use the proper Federal Medical Assistance Percentage (FMAP) for all (two) of the family planning related services selected for testing as well as one of the Part B assistance premium payments selected for testing. Cause: Department personnel stated that an improper modifier was used causing sexually transmitted infection testing and treatment services to map to the incorrect internal fund code and FMAP. Also, Department personnel stated, regarding the Part B assistance premium payment, that an incorrect functional area was assigned to the report?s translation table, resulting in the incorrect FMAP being used. Staff realized the error and corrected the translation table to the correct functional area. However, staff failed to follow through to ensure the entry was posted correctly or to process a journal entry in the accounting system to correct the posting. Effect: The Department?s controls did not consistently detect errors identified which could lead to improper payments. Recommendation: We recommend the Department correct the errors in MMIS and strengthen its controls to ensure errors are corrected when identified. Prior Year Single Audit Finding Number: Not applicable Views of Responsible Offices and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 102.

Corrective Action Plan

Department of Health & Human Services Centers for Medicare & Medicaid Services (CMS) 31 Forsyth Street, SW, Room 4T20 Atlanta, Georgia 30303-8909 The South Carolina Department of Health and Human Services respectfully submits the following corrective action plan for the year ended 6/30/21. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS ? FEDERAL AWARD PROGRAM AUDIT DEPARTMENT OF HEALTH AND HUMAN SERVICES 2021-006 Medicaid Cluster ? Assistance Listing No. 93.775, 93.777, 93.778 Recommendation: We recommend the Department correct the errors in MMIS and strengthen its controls to ensure errors are corrected when identified. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Root Cause: Medicaid Management Information System (MMIS) does not include pointer logic for diagnosis codes to indicate the specific line(s) that each apply to. This results in all diagnosis codes being assigned to all procedure codes submitted on a claim. In cases where diagnosis codes with a program indicator of `Family Planning? are included on the claim, the MMIS is incorrectly treating each line as if it were a family planning service. In some cases, this is resulting in the incorrect FMAP being applied to services that may not have been true Family Planning codes. The Department has made numerous corrections to the Family Planning logic, including removing aspects such as the FP modifier from assignment to FMAP assignment, but agrees that further remediation is needed. Corrective Action: The agency is developing an action plan, in collaboration with its MMIS vendor, Clemson University, to evaluate the complete adjudication logic of the Family Planning limited benefit plan. This evaluation includes a review of all aspects of plan administration, including: ? Review/update procedure/Diagnosis Code program indicators ? Review/update the dedicated Family Planning MMIS tables ? Review/update the adjudication logic, including the continued use of the FP modifier for billing purposes ? Update the Fund Code assignment to remediate the auto-assignment of Family Planning FMAP rates based on diagnosis code alone ? Update the policy manuals to give clear guidance to providers on how to bill for Family Planning beneficiaries ? Finally, a review will be completed of all claims that may have been processed under the former logic and decisions will be made on whether to reprocess claims to assign the proper FMAP or if a ledger adjustment will be performed to correct FMAP draw downs. The development, testing, and implementation of the revised Family Planning logic is scheduled to be completely by December 31, 2022. Corrective Action Plan for Part B Assistance Premium Payment issue: Fiscal staff have created a training document for identifying and assigning the correct functional areas to report types in the Medicaid Claims Payment Processing module in SCEIS. The training emphasizes the need to follow through the process to ensure errors are corrected when identified. Name(s) of the contact person(s) responsible for corrective action: Jeremy Faulkenburg, Brian Paeth, and Jenny Shealy Planned completion date for corrective action plan: December 31, 2022

About Matching, Level of Effort, Earmarking →
2021-007
Special Tests & Provisions
SIGNIFICANT DEFICIENCYOTHER MATTERS

The Department did not conduct, or contract, for an independent audit of the accuracy, truthfulness, and completeness of the encounter and financial data submitted by, or on behalf of, each MCO. Questioned Costs: None Context: We selected all (5) MCOs to ensure the Department complied with Managed Care Financial Audit requirements, but the Department could not provide us with the required periodic audit reports. Cause: Department personnel stated the periodic audits have not been conducted because they, along with the Department?s contracted third-party actuary, analyze the encounter and financial data of the MCO on a quarterly and annual basis at the aggregate level. Effect: The Department did not comply with the Special Tests and Provisions-Managed Care Financial Audit requirement. Recommendation: We recommend the Department ensure required periodic audits are performed. The required reports and documents should then be posted to the Department?s publicly accessible website. Prior Year Single Audit Finding Number: Not applicable Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 103.

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Federal Agency: Department of Health and Human Services Federal Program Title: Medicaid Cluster; Children?s Health Insurance Program Assistance Listing No.: 93.775, 93.777, 93.778, 93.767 Federal Grant ID Number: 05-2005SC5MAP, 05-1905SC5021 Pass-Through Entity: Not applicable Award Period: October 1, 2020 through September 30, 2021 Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: Per 42 CFR 438.602 (e), the state must periodically, but no less frequently than once every 3 years, conduct, or contract for the conduct of, an independent audit of the accuracy, truthfulness, and completeness of the encounter and financial data submitted by, or on behalf of, each Managed Care Organization (MCO), Prepaid Inpatient Health Plan (PIHP) or Prepaid Ambulatory Health Plan (PAHP). In addition, per 42 CFR 438.602 (g), the state must post on its Web site, as required in 438.10(c)(3), the following documents and reports: (1) The MCO, PIHP, PAHP, or Primary Care Case Management (PCCM) entity contract. (2) The data at 438.604(a)(5). (3) The name and title of individuals included in 438.604(a)(6). (4) The results of any audits under paragraph (e) of this section. Condition: The Department did not conduct, or contract, for an independent audit of the accuracy, truthfulness, and completeness of the encounter and financial data submitted by, or on behalf of, each MCO. Questioned Costs: None Context: We selected all (5) MCOs to ensure the Department complied with Managed Care Financial Audit requirements, but the Department could not provide us with the required periodic audit reports. Cause: Department personnel stated the periodic audits have not been conducted because they, along with the Department?s contracted third-party actuary, analyze the encounter and financial data of the MCO on a quarterly and annual basis at the aggregate level. Effect: The Department did not comply with the Special Tests and Provisions-Managed Care Financial Audit requirement. Recommendation: We recommend the Department ensure required periodic audits are performed. The required reports and documents should then be posted to the Department?s publicly accessible website. Prior Year Single Audit Finding Number: Not applicable Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 103.

Corrective Action Plan

Department of Health & Human Services Centers for Medicare & Medicaid Services (CMS) 31 Forsyth Street, SW, Room 4T20 Atlanta, Georgia 30303-8909 The South Carolina Department of Health and Human Services respectfully submits the following corrective action plan for the year ended 6/30/21. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS ? FEDERAL AWARD PROGRAM AUDIT DEPARTMENT OF HEALTH AND HUMAN SERVICES Medicaid Cluster; Children?s Health Insurance Program (CHIP) ? Assistance Listing No. 93.775, 93.777, 93.778; 93.767 Recommendation: We recommend the Department ensure required periodic audits are performed. The required reports and documents should then be posted to the Department?s publicly accessible website. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The agency will update its managed care contract to include the following language: 7.9.1. The CONTRACTOR must submit an annual audited financial report by July 1st of each year. 7.9.2.1 The annual audited financial report must include an independent audit of the accuracy, truthfulness and completeness of the Encounter and financial data submitted by the CONTRACTOR. 7.9.2.2 Detailed instructions for completion of the audited financial report are available in the Managed Care Policy and Procedure Guide. Name(s) of the contact person(s) responsible for corrective action: Jonathan Tapley, Thomas Clark Phillip Planned completion date for corrective action plan: July 1, 2022. First report submitted with the independent audit to occur after contract execution. MCO annual reports submitted in 2023 to include the audited financial and encounter data.

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2021-008
Special Tests & Provisions
MATERIAL WEAKNESSMODIFIED OPINION

The Department could not provide support that it complied with the implementation of the required six NCCI methodologies and the NCCI program requirements in accordance with the NCCI Medicaid Policy Manual and the NCCI Medicaid Technical Guidance Manual. Questioned Costs: None Context: We were unable to process test claims to determine if the Department complied with the NCCI Medicaid Policy Manual and the NCCI Medicaid Technical Guidance Manual. Cause: The Department contracts with a third party to implement the required six NCCI methodologies and program requirements. The Department's only monitoring tool over the responsibilities performed by the third party is to review cost savings reports provided by them; the Department does not monitor or perform a test of claims throughout the year. The Department did not provide access to necessary systems or documentation to allow us to test claims to determine compliance. Effect: In the absence of internal controls over the implementation of the Medicaid NCCI methodologies, the Department is unable to ensure that only proper payments of procedures are reimbursed. Recommendation: We recommend the Department implement controls to ensure its third-party contractor has implemented the required six NCCI methodologies and NCCI program requirements. Prior Year Single Audit Finding Number: Not applicable Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 104.

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Federal Agency: Department of Health and Human Services Federal Program Title: Medicaid Cluster Assistance Listing No.: 93.775, 93.777, 93.778 Federal Grant ID Number: 05-2005SC5MAP Pass-Through Entity: Not applicable Award Period: October 1, 2020 through September 30, 2021 Type of Finding: Material weakness in internal control over compliance, material noncompliance Criteria: The NCCI Policy Manual for Medicaid Services and the Medicaid NCCI Technical Guidance Manual require states to implement the required six NCCI methodologies and NCCI program requirements. Condition: The Department could not provide support that it complied with the implementation of the required six NCCI methodologies and the NCCI program requirements in accordance with the NCCI Medicaid Policy Manual and the NCCI Medicaid Technical Guidance Manual. Questioned Costs: None Context: We were unable to process test claims to determine if the Department complied with the NCCI Medicaid Policy Manual and the NCCI Medicaid Technical Guidance Manual. Cause: The Department contracts with a third party to implement the required six NCCI methodologies and program requirements. The Department's only monitoring tool over the responsibilities performed by the third party is to review cost savings reports provided by them; the Department does not monitor or perform a test of claims throughout the year. The Department did not provide access to necessary systems or documentation to allow us to test claims to determine compliance. Effect: In the absence of internal controls over the implementation of the Medicaid NCCI methodologies, the Department is unable to ensure that only proper payments of procedures are reimbursed. Recommendation: We recommend the Department implement controls to ensure its third-party contractor has implemented the required six NCCI methodologies and NCCI program requirements. Prior Year Single Audit Finding Number: Not applicable Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 104.

Corrective Action Plan

Department of Health & Human Services Centers for Medicare & Medicaid Services (CMS) 31 Forsyth Street, SW, Room 4T20 Atlanta, Georgia 30303-8909 The South Carolina Department of Health and Human Services respectfully submits the following corrective action plan for the year ended 6/30/21. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS ? FEDERAL AWARD PROGRAM AUDIT DEPARTMENT OF HEALTH AND HUMAN SERVICES 2021-008 Medicaid Cluster ? Assistance Listing No. 93.775, 93.777, 93.778 Recommendation: We recommend the Department implement controls to ensure its third-party contractor has implemented the required six NCCI methodologies and NCCI program requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Root Cause: MMIS does not have native editing of methodologies within the National Correct Coding Initiative. As such, it has contracted with a third party to perform NCCI analysis against claim extracts and provide the agency with a Pass/Fail report. This report is then ingested into the MMIS system and corresponding claim edits are applied to any submission that fails NCCI compliance. In response to this edit, the third party has provided evidence that they are up to date on all CMS edit criteria, that claim submissions and response reports are being transmitted, and a savings report showing the total costs saved by the agency via implementation of the NCCI edits is provided on a monthly basis. However, the agency agrees that it has not performed test claims of the NCCI system. Corrective Action: The agency is developing a plan to engage the third party with test scenarios on a quarterly basis. These test files will be generated via collaboration between the agency?s Bureau of Provider Services and Support, the area responsible for fee-for-service claims processing, and the Bureau of Medicaid Systems, the area of Information Technology who oversees file transmissions between the MMIS and the third party. The quarterly test file will include scenarios that cover both types of NCCI edits- procedure to procedure (PTP) and medically unlikely edits (MUEs). The scenarios will include claim types expected to validate the proper execution of all six methodologies, including: ? PTP edits for practitioner and ambulatory surgical center (ASC) services ? PTP edits for outpatient services in hospitals (including services offered in emergency and radiology departments, observation units, clinics, and laboratories) ? PTP edits for durable medical equipment (DME) ? MUE edits for practitioner and ASC services ? MUE edits for outpatient services in hospitals ? MUE edits for DME The quarterly testing files will coincide with the quarterly updates released by CMS. Special attention will be given to codes/scenarios that are included in the preceding quarter?s update. This development of the test scenarios, methodology creation, proprietary file development and transmission protocols to the third party are scheduled to be completed by the close of calendar year 2022. The first test file submission will take place in Q1 2023. Name(s) of the contact person(s) responsible for corrective action: Jeremy Faulkenburg Planned completion date for corrective action plan: December 2022

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2021-009
Special Tests & Provisions
SIGNIFICANT DEFICIENCYOTHER MATTERS

The Department did not ensure reports submitted by managed care organizations (MCO) included all MLR report elements as required by federal regulations. Questioned Costs: None Context: The Department contracts with 5 MCOs. We tested all reports submitted by the MCOs to ensure they contained the required 13 elements and determined the reports did not contain any line item or note regarding fraud prevention activities. Cause: Department personnel stated fraud prevention activities were excluded from the MLR reports due to the private market not yet incorporating fraud prevention activities in the MLR calculation. Effect: The Department did not comply with the Special Tests and Provisions-Medical Loss Ratio requirement. Recommendation: We recommend the Department ensure MLR reports submitted by MCOs comply with federal regulations. Prior Year Single Audit Finding Number: Not applicable Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 105.

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Federal Agency: Department of Health and Human Services Federal Program Title: Medicaid Cluster; Children?s Health Insurance Program Assistance Listing No.: 93.775, 93.777, 93.778, 93.767 Federal Grant ID Number: 05-2005SC5MAP, 05-1905SC5021 Pass-Through Entity: Not applicable Award Period: October 1, 2020 through September 30, 2021 Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: Per 42 CFR 438.8(k)(1), the state, through its contracts, must require each MCO, PIHP, or PAHP to submit a report to the state that includes at least the following information for each MLR reporting year: (iii) Fraud prevention activities as defined in paragraph (e)(4) of this section. Condition: The Department did not ensure reports submitted by managed care organizations (MCO) included all MLR report elements as required by federal regulations. Questioned Costs: None Context: The Department contracts with 5 MCOs. We tested all reports submitted by the MCOs to ensure they contained the required 13 elements and determined the reports did not contain any line item or note regarding fraud prevention activities. Cause: Department personnel stated fraud prevention activities were excluded from the MLR reports due to the private market not yet incorporating fraud prevention activities in the MLR calculation. Effect: The Department did not comply with the Special Tests and Provisions-Medical Loss Ratio requirement. Recommendation: We recommend the Department ensure MLR reports submitted by MCOs comply with federal regulations. Prior Year Single Audit Finding Number: Not applicable Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 105.

Corrective Action Plan

Department of Health & Human Services Centers for Medicare & Medicaid Services (CMS) 31 Forsyth Street, SW, Room 4T20 Atlanta, Georgia 30303-8909 The South Carolina Department of Health and Human Services respectfully submits the following corrective action plan for the year ended 6/30/21. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS ? FEDERAL AWARD PROGRAM AUDIT DEPARTMENT OF HEALTH AND HUMAN SERVICES 2021-009 Medicaid Cluster; Children?s Health Insurance Program (CHIP) ? Assistance Listing No. 93.775, 93.777, 93.778; 93.767 Recommendation: We recommend the Department ensure MLR reports submitted by MCOs comply with federal regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Our actuaries will be required to change their annual MLR reporting template to include Fraud Prevention Activities expenditures as defined in 42 CFR 438.8(e)(4) and required under 42 CFR 438.8(k)(1)(iii). Name(s) of the contact person(s) responsible for corrective action: T. Clark Phillip Planned completion date for corrective action plan: April 30, 2022.

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2021-010
Activities Allowed or Unallowed / Cost Allowability
SIGNIFICANT DEFICIENCYQUESTIONED COSTSOTHER MATTERS

Non-allowable costs were charged to the grant. Questioned Costs: $6,272 Context: Federal regulations state that non-federal entities may only use payments from the Fund to cover previously unbudgeted costs of necessary expenditures incurred as a result of the COVID-19 public health emergency. One of 71 non-payroll disbursements tested was for the costs of carpet cleaning services. These costs were neither previously unbudgeted nor necessary due to the public health emergency. Cause: The Office's internal controls failed to prevent non allowable activities and costs from being charged to the grant. Effect: The Office was not in compliance with certain federal regulations and applicable allowable costs/activities requirements. Recommendation: We recommend the Office strengthen its internal controls and processes to ensure that all charges to the grant are allowable. Prior Year Single Audit Finding Number: Not applicable Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 106.

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Federal Agency: Department of the Treasury Federal Program Title: Coronavirus Relief Fund ? COVID-19 Assistance Listing No.: 21.019 Federal Grant ID Number: None provided Pass-Through Entity: State of South Carolina Award Period: March 1, 2020 through December 31, 2021 Type of Finding: Significant Deficiency in internal control over compliance, other matters Criteria: Per 2 CFR 200.303 Internal controls, 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. Condition: Non-allowable costs were charged to the grant. Questioned Costs: $6,272 Context: Federal regulations state that non-federal entities may only use payments from the Fund to cover previously unbudgeted costs of necessary expenditures incurred as a result of the COVID-19 public health emergency. One of 71 non-payroll disbursements tested was for the costs of carpet cleaning services. These costs were neither previously unbudgeted nor necessary due to the public health emergency. Cause: The Office's internal controls failed to prevent non allowable activities and costs from being charged to the grant. Effect: The Office was not in compliance with certain federal regulations and applicable allowable costs/activities requirements. Recommendation: We recommend the Office strengthen its internal controls and processes to ensure that all charges to the grant are allowable. Prior Year Single Audit Finding Number: Not applicable Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 106.

Corrective Action Plan

United States Department of the Treasury The South Carolina Office of Regulatory Staff respectfully submits the following corrective action plan for the year ended 6/30/21. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS?FEDERAL AWARD PROGRAM AUDIT 2021-010 Coronavirus Relief Fund? Assistance Listing No. 21.019 Recommendation: We recommend the Office strengthen its internal controls and processes to ensure that all charges to the grant are allowable. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: ORS will strengthen its review procedures to ensure all expenditures charged to grants are allowable. The condition noted was related to the operation of an existing control and not control design; therefore, ORS will implement a plan whereby it periodically takes action to increase staff awareness of their responsibility to exercise due professional care in their duties. Name(s) of the contact person(s) responsible for corrective action: Mark Rhoden, CFO. Planned completion date for corrective action plan: June 30, 2022.

About Activities Allowed or Unallowed, Allowable Costs / Cost Principles →
2021-011
Activities Allowed or Unallowed / Cost Allowability
MATERIAL WEAKNESSQUESTIONED COSTSOTHER MATTERS

Fraud was committed by a school district employee. Each school district in the State was a beneficiary of the program and had expenditures funded by the South Carolina Department of Education (the Department). Questioned Costs: $548,391 Context: The procurement office of a beneficiary school district discovered misuse of funds by a school employee who steered the district to contract with companies he created and controlled for the purchase of equipment. The equipment was sold to the school district at a substantial markup. The now former school district employee pled guilty on January 27, 2022, to defrauding the school district. The questioned costs related to the fraud include $130,000 overcharged for cameras, $60,000 related to invoicing for sales tax and $358,391 retained by the former employee failing to pay the camera vendor for the items delivered to the school district. Cause: Department controls failed to prevent the identified misappropriation of funds. Effect: $548,391 of Coronavirus Relief Funds were misappropriated. Recommendation: We recommend the Department strengthen controls to ensure that all costs charged to the grant are allowable. Prior Year Single Audit Finding Number: Not applicable Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 107.

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Federal Agency: Department of the Treasury Federal Program Title: Coronavirus Relief Fund ? COVID-19 Assistance Listing No.: 21.019 Federal Grant ID Number: None provided Pass-Through Entity: South Carolina Department of Administration Award Period: March 1, 2020 through December 31, 2021 Type of Finding: Material Weakness in internal control over compliance, other matters Criteria: Per 2 CFR 200.303 Internal controls, 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. Condition: Fraud was committed by a school district employee. Each school district in the State was a beneficiary of the program and had expenditures funded by the South Carolina Department of Education (the Department). Questioned Costs: $548,391 Context: The procurement office of a beneficiary school district discovered misuse of funds by a school employee who steered the district to contract with companies he created and controlled for the purchase of equipment. The equipment was sold to the school district at a substantial markup. The now former school district employee pled guilty on January 27, 2022, to defrauding the school district. The questioned costs related to the fraud include $130,000 overcharged for cameras, $60,000 related to invoicing for sales tax and $358,391 retained by the former employee failing to pay the camera vendor for the items delivered to the school district. Cause: Department controls failed to prevent the identified misappropriation of funds. Effect: $548,391 of Coronavirus Relief Funds were misappropriated. Recommendation: We recommend the Department strengthen controls to ensure that all costs charged to the grant are allowable. Prior Year Single Audit Finding Number: Not applicable Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 107.

Corrective Action Plan

South Carolina Department of Education 1429 Senate Steet Columbia, South Carolina 29201 The South Carolina Department of Education respectfully submits the following corrective action plan for the year ended June 30, 2021. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS?FEDERAL AWARD PROGRAM AUDIT DEPARTMENT OF EDUCATION 2021-011 Coronavirus Relief Fund ? Assistance Listing No. 21.019 Recommendation: We recommend the Department strengthen controls to ensure that all costs charged to the grant are allowable. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The SC Department of Education will continue to educate school districts and other subrecipients on the appropriate use of federal awards. The Department will continue to work with the Executive Budget Office and the US Department of Treasury to determine the appropriate corrective actions. Name(s) of the contact person(s) responsible for corrective action: Nancy Williams, Chief Financial Officer Planned completion date for corrective action plan: June 30, 2022

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2021-012
Reporting
SIGNIFICANT DEFICIENCYOTHER MATTERS

The report was filed after the due date. Questioned Costs: None Context: The action was reported in FSRS on April 14, 2021, but was due no later than the last day of the month following the month in which the obligation was made (February 28, 2021). Cause: Department controls failed to ensure timely report submission. Effect: Noncompliance was noted with FSRS requirements. Recommendation: We recommend the Department strengthen controls to ensure the FFATA report is submitted in FSRS in a timely manner. Prior Year Single Audit Finding Number: Not applicable Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 108.

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Full finding narrative

Federal Agency: Department of Education Federal Program Title: Education Stabilization Fund ? COVID-19 Assistance Listing No.: 84.425D Federal Grant ID Number: S425D210019 Pass-Through Entity: None Award Period: January 5, 2021 through September 30, 2022 Type of Finding: Significant Deficiency in internal control over compliance, other matters Criteria: Per 2 CFR 170 Appendix A, the action should be reported in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS) no later than the last day of the month following the month in which the obligation was made. Condition: The report was filed after the due date. Questioned Costs: None Context: The action was reported in FSRS on April 14, 2021, but was due no later than the last day of the month following the month in which the obligation was made (February 28, 2021). Cause: Department controls failed to ensure timely report submission. Effect: Noncompliance was noted with FSRS requirements. Recommendation: We recommend the Department strengthen controls to ensure the FFATA report is submitted in FSRS in a timely manner. Prior Year Single Audit Finding Number: Not applicable Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 108.

Corrective Action Plan

South Carolina Department of Education 1429 Senate Steet Columbia, South Carolina 29201 The South Carolina Department of Education respectfully submits the following corrective action plan for the year ended June 30, 2021. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS?FEDERAL AWARD PROGRAM AUDIT DEPARTMENT OF EDUCATION 2021-012 Education Stabilization Fund ? Assistance Listing No. 84.425D Recommendation: We recommend the Department strengthen controls to ensure the FFATA report is submitted in FSRS in a timely manner. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Procedures were written to assure timely reporting of federal awards in the FSRS System. A review of these procedures will be scheduled for early April with Grants Accounting and Mid-April with the Program Offices. Due to these dates, we recommend a completion date of May 1, 2022, for the Corrective Action. Name(s) of the contact person(s) responsible for corrective action: Steven Strother, Finance Director Planned completion date for corrective action plan: May 1, 2022

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2021-013
Cost Allowability / Eligibility
MATERIAL WEAKNESSMODIFIED OPINIONREPEAT OF 2020-027QUESTIONED COSTS

Eligibility related discrepancies were encountered for some subsidy payments. Questioned Costs: $3,321 Context: Sixty payments charged to the program were selected for testing eligibility compliance. Seven of the payments tested contained eligibility discrepancies as follows: Documentation properly supported that the case was ineligible for program subsidy payments (two). Documentation contained information that was not consistent with meeting eligibility requirements (three). Documentation was insufficient to determine eligibility (two). Additionally, three other subsidy payments tested were for children no longer eligible for payment. Cause: Department controls failed to ensure eligibility was properly determined or applied, benefits were terminated timely, and records were appropriately retained. The ongoing global pandemic also limited the Department?s ability to implement corrective action. Effect: The Department did not comply with and/or could not demonstrate compliance with eligibility and allowable costs/cost principles requirements. Recommendation: We recommend that the Department continue to implement corrective action for eligibility file controls. Prior Year Single Audit Report Finding Number: 2020-027 Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 109.

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Full finding narrative

Federal Agency: Department of Health and Human Services Federal Program Title: Adoption Assistance Assistance Listing: 93.659 Federal Grant ID Number: 2001SCADPT, 2101SCADPT Pass-Through Entity: Not applicable Award Period: October 1, 2019 through September 30, 2021 Type of Finding: Material weakness in internal control over compliance, material noncompliance Criteria: 45 CFR 75.361 outlines record retention requirements of the non-federal entity pertinent to the federal award. 45 CFR 1356.40(b)(1) requires the adoption assistance agreement be signed and in effect at the time of or prior to the final decree of adoption. 42 U.S.C. 673(c) explains the children with special needs criteria. 42 U.S.C. 675(8)(b) expands eligibility requirements for children over the age of eighteen. Condition: Eligibility related discrepancies were encountered for some subsidy payments. Questioned Costs: $3,321 Context: Sixty payments charged to the program were selected for testing eligibility compliance. Seven of the payments tested contained eligibility discrepancies as follows: Documentation properly supported that the case was ineligible for program subsidy payments (two). Documentation contained information that was not consistent with meeting eligibility requirements (three). Documentation was insufficient to determine eligibility (two). Additionally, three other subsidy payments tested were for children no longer eligible for payment. Cause: Department controls failed to ensure eligibility was properly determined or applied, benefits were terminated timely, and records were appropriately retained. The ongoing global pandemic also limited the Department?s ability to implement corrective action. Effect: The Department did not comply with and/or could not demonstrate compliance with eligibility and allowable costs/cost principles requirements. Recommendation: We recommend that the Department continue to implement corrective action for eligibility file controls. Prior Year Single Audit Report Finding Number: 2020-027 Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 109.

Corrective Action Plan

The South Carolina Department of Social Services respectfully submits the following corrective action plan for the year ended June 30, 2021. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS?FEDERAL AWARD PROGRAM AUDIT U. S. Department of Health and Human Services 2021-013 Adoption Assistance ? Assistance Listing No. 93.659 Recommendation: We recommend that the Department continue to implement corrective action for eligibility file controls. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: All adoption subsidy agreements (ASAs) are nowreviewed for completeness, accuracy and agreement with appropriate supportingdocumentation by two State Office Adoptions administrative employees specifically assigned to ensure the agreements have been completed correctly. Only after they haveconfirmed an ASA is properly supported, complete and accurate, they submit it to the State Office Adoptions Manager for signature. When signing the ASAs, the State Office Adoptions Manager now conducts their own compliance review and verifies the subsidy payment amounts are correct and agree with the signed adoption subsidy negotiation approval form. If discrepancies are found, the manager contacts the region for clarification or corrective action. Then, when key information from the ASAs is entered into the Child Welfare Information System (CAPSS), staff verify that each ASA includes the State Adoption Office Manager?s signature. In addition, State Adoptions staff, working with the Department?s Information Technology team, are implementing a process whereby Adoptions staff will be required to upload all ASAs and supporting documents into Sharepoint for work-flowed approval. Management believes that, collectively, the above controls will greatly reduce the possibility that adoption subsidies will commence without the proper support of an ASA that has been correctly completed, appropriately supported by other required documentation, properly signed by an authorized manager, and can easily be retrieved from Department files. Some of the payments tested and identified as exceptions this year were made pursuant to subsidy agreements executed in prior years. The Department has already begun reviewing older files to ensure the subsidy agreements include the proper signatures, and the Department will continue this practice. The Department also has begun implementation of an eligibility review process whereby staff pull sample cases quarterly for internal review to confirm compliance with various requirements and ensure all subsidy payments were adequately supported. Finally, in August 2021 State Adoptions staff, working with the Department?s Information Technology team, implemented system controls and reports to ensure timely termination of payments and maintenance of documentary support for payments to children who are 18 years and older. The Department?s CAPSS system now discontinues subsidy payments at the end of the month in which a child reaches age 21. In addition, monthly reports are provided to Adoptions staff that facilitate the generation and mailing of advance requests for required updates to educational and medical information to assure timely receipt of support for continuing payments for children who are 18 and over. Each month staff track the documentation requested to ensure the required updates have been received, and they terminate payments that lack the required support. Management believes these new processes substantially reduce the possibility that payments will continue without appropriate support for youth who are 18 years of age or older. Name(s) of the contact person(s) responsible for corrective action: Dawn Barton, Permanency Manager Planned completion date for corrective action plan: August 1, 2022

Prior Finding References

2020-027

About Allowable Costs / Cost Principles, Eligibility →
2021-014
Reporting
SIGNIFICANT DEFICIENCYREPEAT OF 2020-028OTHER MATTERS

Discrepancies existed between federal financial reports and the Department?s supporting records. Questioned Costs: None Context: Two CB-496 reports were selected for testing. Discrepancies were noted between supporting documentation and the reports. In Part 1, Section B of both reports, some activity was improperly reported as prior quarter adjustments. Errors were also identified in the Adoption Savings Calculation used in determining the amounts reported in Part 4 of the report. Cause: The Department had not completely implemented the corrective action associated with this finding from the prior year. Effect: The accuracy of the CB-496 reports could not be fully validated. Recommendation: We recommend that the Department continue to strengthen its internal controls to ensure that federal reports are free from error and clearly supported prior to submission. Prior Year Single Audit Report Finding Number: 2020-028 Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 110.

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Full finding narrative

Federal Agency: Department of Health and Human Services Federal Program Title: Adoption Assistance Assistance Listing: 93.659 Federal Grant ID Number: 2001SCADPT, 2101SCADPT Pass-Through Entity: Not applicable Award Period: October 1, 2019 through September 30, 2021 Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: 45 CFR 75.303 requires effective internal controls be established and maintained in order to provide reasonable assurance that the federal award is being managed in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: Discrepancies existed between federal financial reports and the Department?s supporting records. Questioned Costs: None Context: Two CB-496 reports were selected for testing. Discrepancies were noted between supporting documentation and the reports. In Part 1, Section B of both reports, some activity was improperly reported as prior quarter adjustments. Errors were also identified in the Adoption Savings Calculation used in determining the amounts reported in Part 4 of the report. Cause: The Department had not completely implemented the corrective action associated with this finding from the prior year. Effect: The accuracy of the CB-496 reports could not be fully validated. Recommendation: We recommend that the Department continue to strengthen its internal controls to ensure that federal reports are free from error and clearly supported prior to submission. Prior Year Single Audit Report Finding Number: 2020-028 Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 110.

Corrective Action Plan

The South Carolina Department of Social Services respectfully submits the following corrective action plan for the year ended June 30, 2021. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS?FEDERAL AWARD PROGRAM AUDIT U. S. Department of Health and Human Services 2021-014 Adoption Assistance ? Assistance Listing No. 93.659 Recommendation: We recommend that the Department continue to strengthen its internal controls to ensure that federal reports are free from error and clearly supported prior to submission. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Department?s Grants Accounting and Reporting Manager now has completed the first year of work at the Department and has also added staff to allow more time for review of reports. The entire team has greatly increased its understanding of the reporting rules and the measures required to ensure proper completion of the Federal Financial Reports, with appropriate tie-in and retention of relevant supporting documentation. Management has specifically reviewed with staff the discrepancies noted between supporting documentation and the reports, as well as the incorrect treatment of report corrections as prior quarter adjustments. Management does not expect these errors to recur. If they do, management expects them to be detected and corrected during management review. Errors noted in the Adoption Savings calculation were related to specific calculation and reporting mechanics that are simple to check and now well understood. The Department will specifically review the calculations and supporting documentation to ensure they are free of these errors and will continue the management review process now in place. Name(s) of the contact person(s) responsible for corrective action: Reshma Parikh, Grants Accounting and Reporting Manager Planned completion date for corrective action plan: March 31, 2022

Prior Finding References

2020-028

About Reporting →
2021-015
Reporting
MATERIAL WEAKNESSMODIFIED OPINION

The total awards expended for the program could not be determined or identified on the Department?s SEFA. Questioned Costs: None Context: The expenditure activity of the new program was not tracked in the Department?s accounting system in a manner consistent with other grant programs and therefore was not included on the Department?s SEFA. Cause: Department controls failed to ensure consistent tracking of the program?s expenditure activity in its accounting system and reporting controls did not detect and correct the resulting reporting error on the SEFA submitted for audit. Effect: An audit adjustment was required to correct the Department?s SEFA and some federal reports of the program required revision. Recommendation: We recommend that the Department implement procedures to ensure that all new grant program activity is consistently accounted for in the Department?s accounting system and that SEFA reporting does not exclude any expenditures required by federal reporting requirements. Prior Year Single Audit Report Finding Number: None Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 111.

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Federal Agency: Department of Agriculture Federal Program Title: Pandemic EBT Food Benefits ? COVID-19 Assistance Listing: 10.542 Federal Grant ID Number: None Pass-Through Entity: Not applicable Award Period: March 16, 2020 through June 11, 2021 Type of Finding: Material weakness in internal control over compliance, material noncompliance Criteria: 2 CFR 200.303 requires effective internal controls be established and maintained in order to provide reasonable assurance that the federal award is being managed in compliance with federal statutes, regulations, and the terms and conditions of the federal award. 2 CFR 200.510(b) specifies the reporting requirements for the schedule of expenditures of federal awards (SEFA). Condition: The total awards expended for the program could not be determined or identified on the Department?s SEFA. Questioned Costs: None Context: The expenditure activity of the new program was not tracked in the Department?s accounting system in a manner consistent with other grant programs and therefore was not included on the Department?s SEFA. Cause: Department controls failed to ensure consistent tracking of the program?s expenditure activity in its accounting system and reporting controls did not detect and correct the resulting reporting error on the SEFA submitted for audit. Effect: An audit adjustment was required to correct the Department?s SEFA and some federal reports of the program required revision. Recommendation: We recommend that the Department implement procedures to ensure that all new grant program activity is consistently accounted for in the Department?s accounting system and that SEFA reporting does not exclude any expenditures required by federal reporting requirements. Prior Year Single Audit Report Finding Number: None Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 111.

Corrective Action Plan

The South Carolina Department of Social Services respectfully submits the following corrective action plan for the year ended June 30, 2021. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS?FEDERAL AWARD PROGRAM AUDIT U. S. Department of Health and Human Services 2021-015 Pandemic EBT Food Benefits ? Assistance Listing No. 10.542 Recommendation: We recommend that the Department implement procedures to ensure that all new grant program activity is consistently accounted for in the Department?s accounting system and that SEFA reporting does not exclude any expenditures required by federal reporting requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The transmission and delivery of most PEBT benefits were executed in separate and distinct processes developed solely for that purpose on an emergency basis. Most of these benefits therefore were excluded from the normal SNAP benefits accounting reports and processes. Management will modify the accounting process to specifically capture PEBT benefits, and the Grants Accounting and Reporting staff will reconcile total SNAP benefits issued to postings in the accounting system to ensure all have been recorded and reported. PEBT expenditures, as well as those of any other new grant programs enacted in the future, will be reported separately, rather than combined with those of similar programs. Name(s) of the contact person(s) responsible for corrective action: Reshma Parikh, Grants Accounting and Reporting Manager Planned completion date for corrective action plan: April 30, 2022

About Reporting →
2021-016
Cost Allowability
SIGNIFICANT DEFICIENCYQUESTIONED COSTSOTHER MATTERS

Non-allowable costs were identified in charges to the grant. Questioned Costs: $4,691 Context: Three of the sixty-six expenditure transactions selected for inspection were recorded to the grant twice through two separate accounting transactions. Cause: The Department identified allowable charges and recorded those charges to the grant through adjusting journal entries. The same transaction was mistakenly included in two separate journal entries and the duplication was not detected and corrected through the review and approval of the Department?s journal entries. Effect: The grant could be overcharged for some specific costs. Recommendation: We recommend that the Department review the supporting documentation for the amounts charged to the grant to determine if the grant was overcharged and determine any necessary appropriate resolution for the closed grant program. Prior Year Single Audit Report Finding Number: None Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 111.

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Federal Agency: Department of the Treasury Federal Program Title: Coronavirus Relief Fund ? COVID-19 Assistance Listing: 21.019 Federal Grant ID Number: None Pass-Through Entity: South Carolina Department of Administration Award Period: March 1, 2020 through December 31, 2021 Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: 2 CFR 200.303 requires effective internal controls be established and maintained in order to provide reasonable assurance that the federal award is being managed in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: Non-allowable costs were identified in charges to the grant. Questioned Costs: $4,691 Context: Three of the sixty-six expenditure transactions selected for inspection were recorded to the grant twice through two separate accounting transactions. Cause: The Department identified allowable charges and recorded those charges to the grant through adjusting journal entries. The same transaction was mistakenly included in two separate journal entries and the duplication was not detected and corrected through the review and approval of the Department?s journal entries. Effect: The grant could be overcharged for some specific costs. Recommendation: We recommend that the Department review the supporting documentation for the amounts charged to the grant to determine if the grant was overcharged and determine any necessary appropriate resolution for the closed grant program. Prior Year Single Audit Report Finding Number: None Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 111.

Corrective Action Plan

The South Carolina Department of Social Services respectfully submits the following corrective action plan for the year ended June 30, 2021. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS?FEDERAL AWARD PROGRAM AUDIT U. S. Department of Health and Human Services 2021-016 Coronavirus Relief Fund? Assistance Listing No. 21.019 Recommendation: We recommend that the Department review the supporting documentation for the amounts charged to the grant to determine if the grant wasovercharged and determine any necessary appropriate resolution for the closed grant program. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Of the approximate $16 million in total Coronavirus Relief Fund expenditures reported, which included thousands of individual expenditure documents, three duplicate expenditure documents totaling $4,691 have been found to have escaped detection by staff, Department management, and by the firm engaged to review and approve all program reimbursements. The Department will conduct a thorough search for additional duplicate document numbers in the entire population of expenditure documents reimbursed. Management does not expect the total thus returned to be material. Name(s) of the contact person(s) responsible for corrective action: Ashley Harris, Assistant Controller Planned completion date for corrective action plan: April 30, 2022

About Allowable Costs / Cost Principles →
2021-017
Reporting
SIGNIFICANT DEFICIENCYOTHER MATTERS

FFATA reporting and timing discrepancies were identified. Questioned Costs: None Context: Seven subawards were selected for testing and the following compliance discrepancies were identified during the testing: The reported subaward obligation/action date did not agree to the subaward agreement date for five subawards tested. The reported subaward Data Universal Numbering System (DUNS) number did not agree to the DUNS number on the subaward for one subaward tested. For the subawards tested, the action was not reported in the Federal Subaward Reporting System (FSRS) by the last day of the month following the month that the subaward was made. The Office was not able to access FSRS for one of the subawards selected in order to test reporting compliance for that subaward. Cause: Data entry errors and administrative delays led to the compliance errors identified in the testing. Effect: Some information was not reported timely or accurately in accordance with the federal requirements. Recommendation: We recommend that the Office strengthen its internal controls over FFATA reporting to ensure that all reporting is timely and accurate in accordance with the federal requirements. Prior Year Single Audit Report Finding Number: Not applicable Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 113.

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Federal Agency: Department of Homeland Security Federal Program Title: Hazard Mitigation Grant Program Assistance Listing: 97.039 Federal Grant ID Number: Various Pass-Through Entity: Not applicable Award Period: Various Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: 2 CFR 170 Appendix A specifies the reporting and timing requirements for Federal Funding Accountability and Transparency Act (FFATA) reporting. Condition: FFATA reporting and timing discrepancies were identified. Questioned Costs: None Context: Seven subawards were selected for testing and the following compliance discrepancies were identified during the testing: The reported subaward obligation/action date did not agree to the subaward agreement date for five subawards tested. The reported subaward Data Universal Numbering System (DUNS) number did not agree to the DUNS number on the subaward for one subaward tested. For the subawards tested, the action was not reported in the Federal Subaward Reporting System (FSRS) by the last day of the month following the month that the subaward was made. The Office was not able to access FSRS for one of the subawards selected in order to test reporting compliance for that subaward. Cause: Data entry errors and administrative delays led to the compliance errors identified in the testing. Effect: Some information was not reported timely or accurately in accordance with the federal requirements. Recommendation: We recommend that the Office strengthen its internal controls over FFATA reporting to ensure that all reporting is timely and accurate in accordance with the federal requirements. Prior Year Single Audit Report Finding Number: Not applicable Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 113.

Corrective Action Plan

The South Carolina Adjutant General?s Office respectfully submits the following Corrective Action Plan for the year ended 6/30/21. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS?FEDERAL AWARD PROGRAM AUDIT U.S. Department of Homeland Security 2021-017 Hazard Mitigation Grant Program ? Assistance Listing No. 97.039 Recommendation: We recommend that the Office strengthen its internal controls over FFATA reporting to ensure that all reporting is timely and accurate in accordance with the federal requirements. Explanation of disagreement with audit finding: The Agency concurs with the audit finding. Action taken in response to finding: The Hazard Mitigation team has assigned staff to check and correct all project award dates in SCEMD?s South Carolina Recovery Grants (SCRecoveryGrants.org; known as SCRG) system to ensure the date in SCRG matches the award date on FEMA?s award letter for the respective project. The Hazard Mitigation team is reinforcing in staff training the requirement that when entering HMGP award information in SCRG, the enterer must select the award date from the drop-down menu rather than allow the system to default to the entry date. The above two steps will provide the correct award date in SCRG for Finance and Administration staff to pull the award date matching the award letter for FFATA reporting purposes (will avoid discrepancies). The Finance and Administration team will pull records for FFATA reporting by obligation date instead of pulling records of reimbursements processed; this action will correct the reporting dates in FSRS. The Finance and Administration team will continue to save a pdf record of the monthly reports. Name(s) of the contact person(s) responsible for corrective action: Candice Shealey, SCEMD State Hazard Mitigation Officer: Brittany Hammond, SCEMD Chief of Finance and Administration. Planned completion date for corrective action plan: April 15, 2022

About Reporting →
2021-018
Cash Management
MATERIAL WEAKNESSMODIFIED OPINIONREPEAT OF 2020-019

Advanced funds were not expended within the required timeframe to minimize the time elapsing between drawdown and disbursement. Questioned Costs: None Context: From forty drawdown transactions selected for testing, nineteen grants were identified as having unspent advance funds after forty-five days from the date the funds were advanced. Cause: The timeframe for determining and returning excess advance funding exceeded forty-five days. Effect: Advance funding was not spent or returned within forty-five days of receipt as required by federal regulation. Recommendation: We recommend that the Office continue the implementation of corrective action to strengthen its internal controls over advance payments in order to demonstrate compliance with the federal requirements. Prior Year Single Audit Report Finding Number: 2020-19 Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 114.

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Federal Agency: Department of Defense Federal Program Title: National Guard Military Operations and Maintenance (O&M) Projects Assistance Listing: 12.401 Federal Grant ID Number: Various Pass-Through Entity: Not applicable Award Period: October 1, 2019 through September 30, 2021 Type of Finding: Material weakness in internal control over compliance, material noncompliance Criteria: National Guard Regulation (NGR) 5-1, Chapter 11-5 requires advance payments be disbursed by the state within forty-five days. Condition: Advanced funds were not expended within the required timeframe to minimize the time elapsing between drawdown and disbursement. Questioned Costs: None Context: From forty drawdown transactions selected for testing, nineteen grants were identified as having unspent advance funds after forty-five days from the date the funds were advanced. Cause: The timeframe for determining and returning excess advance funding exceeded forty-five days. Effect: Advance funding was not spent or returned within forty-five days of receipt as required by federal regulation. Recommendation: We recommend that the Office continue the implementation of corrective action to strengthen its internal controls over advance payments in order to demonstrate compliance with the federal requirements. Prior Year Single Audit Report Finding Number: 2020-19 Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 114.

Corrective Action Plan

The South Carolina Adjutant General?s Office respectfully submits the following Corrective Action Plan for the year ended 6/30/21. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS?FEDERAL AWARD PROGRAM AUDIT U.S. Department of Defense 2021-018 National Guard Military Operations and Maintenance (O&M) Projects ? Assistance Listing No. 12.401 Recommendation: We recommend that the Office continue the implementation of corrective action to strengthen its internal controls over advance payments in order to demonstrate compliance with the federal requirements. Explanation of disagreement with audit finding: The Agency concurs with the audit finding. Action taken in response to finding: The Grants and Agreements Section will implement additional procedures to strengthen internal controls over advance payments in order to demonstrate compliance with the Federal requirements. The Grants and Agreements Section will provide additional information to Program Managers and/or State and Federal Budget Analysts concerning the details of the amounts of the advance funds requested for each appendix. This information will include the dollar amounts of expenditure categories needed for the advance funding amount requested for the applicable time period. The Program Manager and/or Federal and State Budget Analysts for each appendix will develop a spreadsheet to track expenditures that have occurred period to date, by expenditure categories, used in the Federal Army and Air Guard Accounting Systems for processing of expenditures and payments for the Cooperative Agreements. This spreadsheet will also track the amounts of the remaining Federal budgets for each appendix and the amounts of the advance funding available for use for each appendix. Each Program Manager and/or Federal and State Budget Analysts for each appendix will submit a copy of all spreadsheets to the Grants and Agreements Section on a monthly basis. The Grants and Agreements Section will maintain a copy of the spreadsheet. No later than the fifth working day of the first month of the new Federal Fiscal Year (October), the Grants and Agreements Section will complete a final reconciliation of State and Federal Accounting data for each appendix for the previous Federal Fiscal Year. The Grants Administrator will make a determination, based on reconciliation of account balances, of the amount of advance funding for each appendices that the Agency should return to the Federal Government. The Grants and Agreements Section will ensure all remaining advance funding is returned to the Federal Government within forty-five (45) days after the end of the Federal Fiscal Year. Name(s) of the contact person(s) responsible for corrective action: Alex Counts Planned completion date for corrective action plan: May 31, 2022

Prior Finding References

2020-019

About Cash Management →
2021-019
Period of Performance
SIGNIFICANT DEFICIENCYREPEAT OF 2020-020QUESTIONED COSTSOTHER MATTERS

Expenditures, which did not meet the applicable requirements, were charged prior to and after the program?s period of performance. Questioned Costs: $521 Context: Forty expenditure transactions were selected for testing from costs recorded during the first period of the program grants. One of the forty transactions tested was for a cost incurred prior to the applicable period of performance. In addition, nine transactions were selected for testing from costs recorded to program grants beyond ninety days after the close of the federal fiscal year. One of the nine transactions tested was not included on the detailed listing of unliquidated claims and undisbursed obligations. Cause: Office controls failed to prevent charging the grant for a cost incurred outside the applicable period of performance. Effect: Costs charged outside the period of performance may not be allowable. Recommendation: We recommend that the Office continue the implementation of corrective action to strengthen its internal controls to ensure documented compliance with all federal period of performance requirements. Prior Year Single Audit Report Finding Number: 2020-20 Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 115.

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Federal Agency: Department of Defense Federal Program Title: National Guard Military Operations and Maintenance (O&M) Projects Assistance Listing: 12.401 Federal Grant ID Number: W912QG-20-2-1001, W912QG-21-2-1001 Pass-Through Entity: Not applicable Award Period: October 1, 2019 through September 30, 2021 Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: 2 CFR 200.403(h) requires costs be incurred during the approved budget period. NGR 5-1, Chapter 11-2 requires the obligation of funds within the federal fiscal year or period of federal availability. Per NGR 5-1, Chapter 11-10, if unliquidated claims and undisbursed obligations remain ninety days after the close of the federal fiscal year, the recipient shall provide a detailed listing of uncleared obligations no later than December 31. Condition: Expenditures, which did not meet the applicable requirements, were charged prior to and after the program?s period of performance. Questioned Costs: $521 Context: Forty expenditure transactions were selected for testing from costs recorded during the first period of the program grants. One of the forty transactions tested was for a cost incurred prior to the applicable period of performance. In addition, nine transactions were selected for testing from costs recorded to program grants beyond ninety days after the close of the federal fiscal year. One of the nine transactions tested was not included on the detailed listing of unliquidated claims and undisbursed obligations. Cause: Office controls failed to prevent charging the grant for a cost incurred outside the applicable period of performance. Effect: Costs charged outside the period of performance may not be allowable. Recommendation: We recommend that the Office continue the implementation of corrective action to strengthen its internal controls to ensure documented compliance with all federal period of performance requirements. Prior Year Single Audit Report Finding Number: 2020-20 Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 115.

Corrective Action Plan

The South Carolina Adjutant General?s Office respectfully submits the following Corrective Action Plan for the year ended 6/30/21. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS?FEDERAL AWARD PROGRAM AUDIT U.S. Department of Defense 2021-019 National Guard Military Operations and Maintenance (O&M) Projects ? Assistance Listing No. 12.401 Recommendation: We recommend that the Office continue the implementation of corrective action to strengthen its internal controls to ensure documented compliance with all federal period of performance requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Grants and Agreements Section will implement additional procedures to strengthen internal controls to ensure documented compliance with all federal period of performance requirements. The Grants and Agreements Section will send each Program Manager and/or their Federal and State Budget Analysts a detailed listing of the remaining balances of purchase orders and funds reservations to on a monthly basis to ensure accuracy and compliance for each appendix. Each Program Manager and/or their Federal and State Budget Analysts will provide a mandatory response to ensure accuracy or needed changes. The Grants and Agreements Section will maintain a copy of the listing and responses. The Grants and Agreements Section will submit a monthly detailed listing of expenditures for all appendices to each Program Manager and/or their Federal and State Budget Analysts for all open Federal Fiscal Years to ensure accuracy and compliance. Program Managers and/or their Federal and State Budget Analysts will provide a mandatory response to ensure accuracy or needed changes. The Grants and Agreements Section will maintain a copy of responses. The Grants and Agreements Section will review all expenditures for each appendix for accuracy and compliance. The Grants and Agreements Section will maintain documentation for accuracy and changes. Program Managers and/or Federal and State Budget Analysts for each appendix will develop and maintain a spreadsheet for tracking invoices for each open Federal Fiscal Year. Program Managers and/or Federal and State Budget Analysts will submit a copy of the spreadsheet to Grants and Agreements on a monthly basis. The Grants and Agreements Section will maintain a copy of the spreadsheet. Name(s) of the contact person(s) responsible for corrective action: Alex Counts Planned completion date for corrective action plan: May 31, 2022

Prior Finding References

2020-020

About Period of Performance →
2021-020
Activities Allowed or Unallowed / Cost Allowability
MATERIAL WEAKNESSQUESTIONED COSTSOTHER MATTERS

Indirect costs were improperly charged to the CRF. Questioned Costs: $4,590,544 Context: While examining expenditure populations to evaluate which costs were direct and material to the CRF, we noted activity charged to general ledger accounts designated for indirect costs. Cause: Department controls failed to prevent the identified noncompliance issue noted above. Effect: The identified indirect costs resulted in noncompliance with federal regulations and applicable allowable activities/costs requirements. Recommendation: We recommend the Department strengthen controls to ensure that all costs charged to the CRF are for allowable grant activities and costs. Prior Year Single Audit Finding Number: Not applicable Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 117.

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Federal Agency: Department of the Treasury Federal Program Title: Coronavirus Relief Fund ? COVID-19 Assistance Listing No.: 21.019 Federal Grant ID Number: None provided Pass-Through Entity: South Carolina Department of Administration Award Period: March 1, 2020 through December 31, 2021 Type of Finding: Material weakness in internal control over compliance, other matters Criteria: Per Federal Register Notice Volume 86, Number 10, payments from the Coronavirus Relief Fund (CRF) are not administered as part of a traditional grant program. The provisions of the Uniform Guidance, 2 CFR 200, that are applicable to indirect costs do not apply. Recipients do not apply their indirect cost rates to payments received from the CRF. Additionally, per 2 CFR 200.303, the 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. Condition: Indirect costs were improperly charged to the CRF. Questioned Costs: $4,590,544 Context: While examining expenditure populations to evaluate which costs were direct and material to the CRF, we noted activity charged to general ledger accounts designated for indirect costs. Cause: Department controls failed to prevent the identified noncompliance issue noted above. Effect: The identified indirect costs resulted in noncompliance with federal regulations and applicable allowable activities/costs requirements. Recommendation: We recommend the Department strengthen controls to ensure that all costs charged to the CRF are for allowable grant activities and costs. Prior Year Single Audit Finding Number: Not applicable Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 117.

Corrective Action Plan

US Department of Health and Human Services The South Carolina Department of Health and Environmental Control respectfully submits the following corrective action plan for the year ended 6/30/21. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS?FEDERAL AWARD PROGRAM AUDIT DEPARTMENT OF THE TREASURY 2021-020 Coronavirus Relief Fund (CRF) ? Assistance Listing No. 21.019 Recommendation: We recommend that the Department strengthen controls to ensure that all costs charged to the CRF are for allowable grant activities and costs. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: To strengthen internal controls, the Department discussed the finding with staff to reiterate the importance of ensuring grant awards are thoroughly reviewed and appropriate staff are aware of the terms and conditions related to activities that are deemed allowable, as well as activities that would be deemed unallowable. In addition, the unallowed costs will be returned to the grantor. Name(s) of the contact person(s) responsible for corrective action: Kim Paradeses Planned completion date for corrective action plan: June 30, 2022

About Activities Allowed or Unallowed, Allowable Costs / Cost Principles →
2021-021
Reporting
SIGNIFICANT DEFICIENCYOTHER MATTERS

Discrepancies existed between the federal financial report (FFR) and the Department?s supporting records. Additionally, not all information reported on the FFR was reviewed by an employee other than the report preparer prior to submission. Questioned Costs: None Context: We tested information reported for all four FFR Payment Management System (PMS) document numbers that were required to be submitted for the reporting period ending July 31, 2020, for federal grant number 6 NU50CK000542-01-08. We noted two discrepancies between the FFR associated with PMS document number 19NU50CK000542 (nonprevention and public health funds) and the Department?s supporting records. The federal share of indirect costs was understated by $54,195 because the incorrect indirect cost base amount was transferred from the supporting worksheets to the FFR. Moreover, the federal share of expenditures did not agree to the supporting worksheets by approximately $2,450. Additionally, the FFR component for PMS document number 19NU50CK000542C4 (COVID-19 paycheck protection and Health Care Enhancement Act response activities) was prepared and submitted by the same individual. Cause: Department controls failed to identify and correct discrepancies noted in the federal reports prior to submission. Effect: The FFR amounts did not agree to supporting documentation. Additionally, without a supervisory review, there is an increased risk of inaccurate reporting. Recommendation: We recommend that the Department strengthen policies and procedures to ensure that all information reported on federal reports is accurate and that a segregation of duties exists between report preparers and reviewers. Prior Year Single Audit Finding Number: Not applicable Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 118.

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Federal Agency: Department of Health and Human Services Federal Program Title: Epidemiology and Laboratory Capacity for Infectious Diseases ? COVID 19 Assistance Listing No.: 93.323 Federal Grant ID Number: 6 NU50CK000542-01-08 Pass-Through Entity: Not applicable Award Period: August 1, 2019 through July 31, 2024 Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: Per 2 CFR 200.303, the 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 be in compliance with guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States and the "Internal Control Integrated Framework", issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: Discrepancies existed between the federal financial report (FFR) and the Department?s supporting records. Additionally, not all information reported on the FFR was reviewed by an employee other than the report preparer prior to submission. Questioned Costs: None Context: We tested information reported for all four FFR Payment Management System (PMS) document numbers that were required to be submitted for the reporting period ending July 31, 2020, for federal grant number 6 NU50CK000542-01-08. We noted two discrepancies between the FFR associated with PMS document number 19NU50CK000542 (nonprevention and public health funds) and the Department?s supporting records. The federal share of indirect costs was understated by $54,195 because the incorrect indirect cost base amount was transferred from the supporting worksheets to the FFR. Moreover, the federal share of expenditures did not agree to the supporting worksheets by approximately $2,450. Additionally, the FFR component for PMS document number 19NU50CK000542C4 (COVID-19 paycheck protection and Health Care Enhancement Act response activities) was prepared and submitted by the same individual. Cause: Department controls failed to identify and correct discrepancies noted in the federal reports prior to submission. Effect: The FFR amounts did not agree to supporting documentation. Additionally, without a supervisory review, there is an increased risk of inaccurate reporting. Recommendation: We recommend that the Department strengthen policies and procedures to ensure that all information reported on federal reports is accurate and that a segregation of duties exists between report preparers and reviewers. Prior Year Single Audit Finding Number: Not applicable Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 118.

Corrective Action Plan

US Department of Health and Human Services The South Carolina Department of Health and Environmental Control respectfully submits the following corrective action plan for the year ended 6/30/21. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS?FEDERAL AWARD PROGRAM AUDIT DEPARTMENT OF HEALTH AND HUMAN SERVICES 2021-021 Epidemiology and Laboratory Capacity for Infectious Diseases ? Covid 19 ? Assistance Listing No. 93.323 Recommendation: We recommend that the Department strengthen policies and procedures to ensure that all information reported on federal reports is accurate and that a segregation of duties exists between report preparers and reviewers. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: To strengthen internal controls, the Department will develop and implement specific policies and standard operating procedures defining the Federal Financial Report (FFR) process and documenting the review and approval roles. All workpapers will be reviewed by staff other than the preparer of the FFR. Approvals will be documented. Name(s) of the contact person(s) responsible for corrective action: Kim Paradeses Planned completion date for corrective action plan: June 30, 2022

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2021-022
Period of Performance
SIGNIFICANT DEFICIENCYOTHER MATTERS

An expenditure was incurred after the end of the grant?s period of performance. Questioned Costs: Undetermined Context: For 1 of 40 expenditure transactions tested, program expenditures were incurred subsequent to the end of the grant?s period of performance (September 30, 2020). Cause: The Department?s internal controls failed to identify and prevent expenditures from being charged outside the grant?s period of performance. Effect: The Department may request reimbursement for expenses not incurred within the period of performance. Recommendation: We recommend that the Department strengthen internal controls to ensure all expenditures charged to federal awards are incurred during the grant's period of performance. Prior Year Single Audit Finding Number: Not applicable Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 118.

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Federal Agency: Department of Agriculture Federal Program Title: Special Supplemental Nutrition Program for Women, Infants, and Children (WIC) Assistance Listing No.: 10.557 Federal Grant ID Number: 5SC700715 Pass-Through Entity: Not applicable Award Period: October 1, 2019 through September 30, 2020 Type of Finding: Significant deficiency in internal control over compliance, other matters Criteria: 2 CFR 200.403(h) states that costs must be incurred during the approved budget period. Condition: An expenditure was incurred after the end of the grant?s period of performance. Questioned Costs: Undetermined Context: For 1 of 40 expenditure transactions tested, program expenditures were incurred subsequent to the end of the grant?s period of performance (September 30, 2020). Cause: The Department?s internal controls failed to identify and prevent expenditures from being charged outside the grant?s period of performance. Effect: The Department may request reimbursement for expenses not incurred within the period of performance. Recommendation: We recommend that the Department strengthen internal controls to ensure all expenditures charged to federal awards are incurred during the grant's period of performance. Prior Year Single Audit Finding Number: Not applicable Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 118.

Corrective Action Plan

US Department of Health and Human Services The South Carolina Department of Health and Environmental Control respectfully submits the following corrective action plan for the year ended 6/30/21. The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS?FEDERAL AWARD PROGRAM AUDIT DEPARTMENT OF AGRICULTURE 2021-022 Special Supplemental Nutrition Program for Women, Infants, and Children (WIC) Assistance Listing No. 10.557 Recommendation: We recommend that the Department strengthen internal controls to ensure all expenditures charged to federal awards are incurred during the grant's period of performance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: To strengthen internal controls, the Department?s Program/Region staff will provide periodic reminders to appropriate staff regarding the selection of grants and the associated period of performance when processing payments. In addition, the Department?s Program/Region staff will perform post-closing reviews of expenditures to ensure the proper grant funding was used. Budget staff will monitor post-closing budget balances to assure only the balance of the unliquidated obligations remain on the books until the final FFR has been submitted. Name(s) of the contact person(s) responsible for corrective action: Kim Paradeses Planned completion date for corrective action plan: June 30, 2022

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FY 2020-06-30

$3,163,534,116 federal awards expended

FAC accepted this audit on April 21, 2022 — management decision was due October 21, 2022.

2020-001
Reporting
MATERIAL WEAKNESSREPEAT OF 2019-001

The agency did not prepare and submit its Data Collection Form and Reporting Package for the year ended June 30, 2020 to the Federal Audit Clearinghouse by the extended due date of September 30, 2021. Criteria: Per 200.512 of the Uniform Guidance, Report Submission, the audit shall be completed and the Data Collection Form and Reporting Package shall be electronically transmitted within the earlier of thirty (30) days after receipt of the auditor's reports, or nine (9) months after the end of the audit period. If the due date falls on a Saturday, Sunday, or federal holiday, the Data Collection Form and Reporting Package are due the next business day. The Uniform Guidance does not permit the recipient to extend the due date. Cause: Management did not review subsidiary ledgers for accuracy and reconcile them to the general ledger on a timely basis. Accordingly, the Agency's general ledger for the year ended June 30, 2019 was not closed out in a timely manner. Effect: The Agency's Data Collection Form and Reporting Package for the year ended June 30, 2020 was not prepared and submitted to the Federal Audit Clearinghouse by the due date. Recommendation: We recommend that management implement monthly financial reporting and closeout processes so that the financial closeout process can be performed timely.

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Item 2020-001: Report Submission to the Federal Audit Clearinghouse (Other Matter Required to be Reported Under the Uniform Guidance) (Material Weakness) Condition: The agency did not prepare and submit its Data Collection Form and Reporting Package for the year ended June 30, 2020 to the Federal Audit Clearinghouse by the extended due date of September 30, 2021. Criteria: Per 200.512 of the Uniform Guidance, Report Submission, the audit shall be completed and the Data Collection Form and Reporting Package shall be electronically transmitted within the earlier of thirty (30) days after receipt of the auditor's reports, or nine (9) months after the end of the audit period. If the due date falls on a Saturday, Sunday, or federal holiday, the Data Collection Form and Reporting Package are due the next business day. The Uniform Guidance does not permit the recipient to extend the due date. Cause: Management did not review subsidiary ledgers for accuracy and reconcile them to the general ledger on a timely basis. Accordingly, the Agency's general ledger for the year ended June 30, 2019 was not closed out in a timely manner. Effect: The Agency's Data Collection Form and Reporting Package for the year ended June 30, 2020 was not prepared and submitted to the Federal Audit Clearinghouse by the due date. Recommendation: We recommend that management implement monthly financial reporting and closeout processes so that the financial closeout process can be performed timely.

Corrective Action Plan

Item 2020-001 Report Submission to the Federal Audit Clearinghouse (Other Matter Required to be Reported Under the Uniform Guidance) (Material Weakness) The South Carolina Department of Employment and Workforce (SCDEW) is reviewing staffing needs and workflows to improve operations so that timely financial reports can be generated to meet SCDEW's reporting requirements. During the fiscal year July 1, 2019 to June 30, 2020 SCDEW replaced two key management positions in the finance department and began a significant project to replace its financial reporting system and update the related workflows. That project and other staffing matters were impacted by the disruptions in the workplace as a result of the Agency's response to the COVID 19 Pandemic. Staffing will continue to be evaluated as the transition to the new financial reporting system progresses. The financial reporting system replacement project was completed September 30, 2021.

Prior Finding References

2019-001

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2020-002
Reporting
MATERIAL WEAKNESSREPEAT OF 2019-002

The Agency did not submit certain quarterly reports to the United States Department of Labor ("National Office") by the required due dates. Accordingly, the Agency did not comply with the Reporting compliance requirements related to the Unemployment Insurance program. Criteria: Per Part 4 of the OMB compliance Supplement: The ETA 191 Report is required to be submitted on a quarterly basis to the National Office by the 25th of the month following the close of the quarter. Cause: Internal controls are not in place to ensure that all required reports are being submitted in the accordance with the United States Department of Labor's timelines. The reports were affected by the unprecedented COVID-19 pandemic, which required all program resources to focus on pandemic claims processing. Some of the data needed for these reports was delayed due to the program and system resources focused on claims processing as well as the difficulty experienced due to the requirement of staff to shelter at home beginning April 2020 under the South Carolina Governor's Executive Order and restricted access to records located in the office. Effect: As a result, the Agency becomes more susceptible to having its level of federal award funding reduced by the United States Department of Labor when it violates its Reporting compliance requirements applicable to the Unemployment Insurance program. Context: We inspected a sample of quarterly reports and noted the following exception: Unemployment Insurance - One(1) ETA 191 quarterly report. Recommendation: We recommend that management carefully review the terms and conditions included in the supporting grant agreements and the Reporting requirements included in the OMB Compliance Supplement applicable to the Unemployment Insurance and the Employment Services Cluster programs and implement controls to ensure that all reports are filed on a timely basis.

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Item 2020-002: Reporting (Material Weakness over Reporting and Non-Material Noncompliance). Condition: The Agency did not submit certain quarterly reports to the United States Department of Labor ("National Office") by the required due dates. Accordingly, the Agency did not comply with the Reporting compliance requirements related to the Unemployment Insurance program. Criteria: Per Part 4 of the OMB compliance Supplement: The ETA 191 Report is required to be submitted on a quarterly basis to the National Office by the 25th of the month following the close of the quarter. Cause: Internal controls are not in place to ensure that all required reports are being submitted in the accordance with the United States Department of Labor's timelines. The reports were affected by the unprecedented COVID-19 pandemic, which required all program resources to focus on pandemic claims processing. Some of the data needed for these reports was delayed due to the program and system resources focused on claims processing as well as the difficulty experienced due to the requirement of staff to shelter at home beginning April 2020 under the South Carolina Governor's Executive Order and restricted access to records located in the office. Effect: As a result, the Agency becomes more susceptible to having its level of federal award funding reduced by the United States Department of Labor when it violates its Reporting compliance requirements applicable to the Unemployment Insurance program. Context: We inspected a sample of quarterly reports and noted the following exception: Unemployment Insurance - One(1) ETA 191 quarterly report. Recommendation: We recommend that management carefully review the terms and conditions included in the supporting grant agreements and the Reporting requirements included in the OMB Compliance Supplement applicable to the Unemployment Insurance and the Employment Services Cluster programs and implement controls to ensure that all reports are filed on a timely basis.

Corrective Action Plan

Item 2020-002 Reporting (Material Weakness over Reporting and Non-Material Noncompliance) SCDEW implemented a corrective action plan in response to this finding during the year ended June 30, 2020 in response to similar finding for audits of prior periods a brief summary follows: The SCDEW Enterprise and Project Management Office (EPMO) is tasked with monitoring agency wide reporting deadlines. The EPMO developed a master reporting database that includes relevant identifying information including report name, Agency, SCDEW contact, reporting frequency and due dates. Individual reporters at SCDEW submit data to EPMO on the status of the required filings. EPMO routinely reports the status of filings to executive leadership. This finding for the year ended June 30, 2020 is a significant improvement with only one late report detected for the period under audit.

Prior Finding References

2019-002

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2020-003
Cost Allowability / Special Tests & Provisions
SIGNIFICANT DEFICIENCYREPEAT OF 2019-003OTHER MATTERS

The Department did not remit the federal share of recoveries and collections to the Medicaid program in accordance with federal regulations and the State Medicaid Manual.Questioned Costs: UnknownContext: We tested 60 receivables to ensure the Department properly credited the Medicaid program for the federal share of identified overpayments. For three receivables tested, the Department used the incorrect federal medical assistance percentage to calculate the federal share which resulted in an underpayment of $288 to the federal grantor.This is a repeat finding from the FY19 Single Audit. The Department stated on its Summary Schedule of Prior Year Audit Findings that this issue was ?Fully Corrected with Previously Reported Corrective Action Implemented?. Due to this issue repeating for FY20, this issue has not been fully corrected.Cause: Department personnel used the incorrect period of overpayment calculating and remitting the refunds due to human error.Effect: The Department?s control procedures did not detect the errors identified in our testing which could lead to further improper remittances.Recommendation: We recommend the Department continue its efforts to strengthen controls to ensure the federal share of recoveries and collections are remitted in accordance with applicable federal and State requirements.Prior Year Single Audit Finding Number: 2019-003Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 132.

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Federal Agency: Department of Health and Human ServicesFederal Program Title: Medicaid ClusterAssistance Listing: 93.775, 93.777, 93.778Federal Grant ID Number: 05-1905SC5MAP, 05-2005SC5MAPPass-Through Entity: Not applicableAward Period: October 1, 2018 through September 30, 2020Type of Finding: Significant deficiency in internal control over compliance, other mattersCriteria: Per 42 CFR 433.12 (c), the State is required to credit the Medicaid program for ??overpayments made to Medicaid providers?? In addition, Title 45 Section 2500.6 B of the Centers for Medicare & Medicaid Services? (CMS) State Medicaid Manual states to ??determine the date or period of the expenditure for which the refund is made to establish the [Federal Medical Assistance Percentage] at which the original expenditure was matched by the federal government. Make refunds of the federal share at the FMAP for which you were reimbursed.?Condition: The Department did not remit the federal share of recoveries and collections to the Medicaid program in accordance with federal regulations and the State Medicaid Manual.Questioned Costs: UnknownContext: We tested 60 receivables to ensure the Department properly credited the Medicaid program for the federal share of identified overpayments. For three receivables tested, the Department used the incorrect federal medical assistance percentage to calculate the federal share which resulted in an underpayment of $288 to the federal grantor.This is a repeat finding from the FY19 Single Audit. The Department stated on its Summary Schedule of Prior Year Audit Findings that this issue was ?Fully Corrected with Previously Reported Corrective Action Implemented?. Due to this issue repeating for FY20, this issue has not been fully corrected.Cause: Department personnel used the incorrect period of overpayment calculating and remitting the refunds due to human error.Effect: The Department?s control procedures did not detect the errors identified in our testing which could lead to further improper remittances.Recommendation: We recommend the Department continue its efforts to strengthen controls to ensure the federal share of recoveries and collections are remitted in accordance with applicable federal and State requirements.Prior Year Single Audit Finding Number: 2019-003Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 132.

Corrective Action Plan

Department of Health & Human ServicesCenters for Medicare & Medicaid Services31 Forsyth Street, SW, Room 4T20Atlanta, Georgia 30303-8909The South Carolina Department of Health and Human Services respectfully submits the following corrective action plan for the year ended 6/30/20.The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule.FINDINGS?FEDERAL AWARD PROGRAM AUDITDEPARTMENT OF HEALTH AND HUMAN SERVICES2020-003 Medicaid Cluster ? Assistance Listing No. 93.775, 93.777, 93.778Recommendation: We recommend the Department continue its efforts to strengthen controls to ensure the federal share of recoveries and collections are remitted in accordance with applicable federal and state requirements.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding:To continue to eliminate federal share miscalculation, the accounts receivable manager will continue to review 50% of each month?s receivables in FY2021 and the program director will increase the quarterly review to 20%. Management has submitted a South Carolina Enterprise Information System (SCEIS) Enhancement Request Form to create an accounts receivable workflow that will require management to approve all newly established and adjusted receivables. Furthermore, management will continue researching best practices for minimizing and eliminating manual error and miscalculation within the Accounts Receivable department.Name(s) of the contact person(s) responsible for corrective action: Lynette Wilson, Nika SimmonsPlanned completion date for corrective action plan: Ongoing

Prior Finding References

2019-003

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2020-004
Eligibility
SIGNIFICANT DEFICIENCYREPEAT OF 2019-005OTHER MATTERS

Eligibility files did not contain adequate documentation to support the Medicaid and CHIP recipients? eligibility statuses.Questioned Costs: UnknownContext: We tested 120 individual recipients (60 each for Medicaid and CHIP) to ensure the Department was in compliance with applicable eligibility requirements. We determined the Department did not maintain adequate documentation of eligibility for six Medicaid recipients and three CHIP recipients.Cause: The Department transitioned to an online eligibility system, the Medicaid Eligibility Determination System (MEDS), in July 2013. According to Department personnel, documentation in some of the paper files may not have been scanned into the system since the transition. For cases opened after the transition, the omissions were due to worker error.Effect: The Department could not support eligibility determinations in accordance with its State plan.Recommendation: We recommend the Department continue its efforts to maintain documentation to support eligibility determinations in accordance with its State plan and federal regulations.Prior Year Single Audit Finding Number: 2019-005Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 133.

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Federal Agency: Department of Health and Human ServicesFederal Program Title: Medicaid Cluster; Children?s Health Insurance Program (CHIP)Assistance Listing: 93.775, 93.777, 93.778; 93.767Federal Grant ID Number: 05-1905SC5MAP, 05-2005SC5MAP; 05-1805SC5021Pass-Through Entity: Not applicableAward Period: October 1, 2017 through September 30, 2020Type of Finding: Significant deficiency in internal control over compliance, other mattersCriteria: 42 CFR 435.914 (a) states, ?The agency must include in each applicant?s case record facts to support the agency?s decision on his application.? In addition, Section 4.7 of the Department?s Title XIX (Medicaid) State Plan (Maintenance of Records) affirms that it meets the requirements outlined in 42 CFR 431.17 (b), which states, ?A State plan must provide that the Medicaid agency will maintain or supervise the maintenance of records necessary for the proper and efficient operation of the plan.? Furthermore, the Department?s Title XXI (CHIP) State Plan attests that CHIP will operate as a Medicaid expansion program; therefore, the aforementioned regulations apply to both programs.Condition: Eligibility files did not contain adequate documentation to support the Medicaid and CHIP recipients? eligibility statuses.Questioned Costs: UnknownContext: We tested 120 individual recipients (60 each for Medicaid and CHIP) to ensure the Department was in compliance with applicable eligibility requirements. We determined the Department did not maintain adequate documentation of eligibility for six Medicaid recipients and three CHIP recipients.Cause: The Department transitioned to an online eligibility system, the Medicaid Eligibility Determination System (MEDS), in July 2013. According to Department personnel, documentation in some of the paper files may not have been scanned into the system since the transition. For cases opened after the transition, the omissions were due to worker error.Effect: The Department could not support eligibility determinations in accordance with its State plan.Recommendation: We recommend the Department continue its efforts to maintain documentation to support eligibility determinations in accordance with its State plan and federal regulations.Prior Year Single Audit Finding Number: 2019-005Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 133.

Corrective Action Plan

Department of Health & Human ServicesCenters for Medicare & Medicaid Services31 Forsyth Street, SW, Room 4T20Atlanta, Georgia 30303-8909The South Carolina Department of Health and Human Services respectfully submits the following corrective action plan for the year ended 6/30/20.The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule.DEPARTMENT OF HEALTH AND HUMAN SERVICES2020-004 Medicaid Cluster; Children?s Health Insurance Program (CHIP) ? Assistance Listing No. 93.775, 93.777, 93.778; 93.767Recommendation: We recommend the Department continue its efforts to maintain documentation to support eligibility determinations in accordance with its State plan and Federal regulations.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding:Staff Performance Evaluation and Remediation: The Eligibility Performance Evaluation and Remediation process rolled out to staff in July 2019. This process includes key elements for review which lead to a correct or incorrect eligibility determination. This includes the presence of a signed application (where appropriate) and presence of other documentation required for the eligibility decision (e.g. Level of Care), correct application of financial and non-financial eligibility criteria, as well as timeliness metrics to assist the agency with meeting federally defined standards.The Eligibility Quality Assurance Team (EQAT) consists of 52 team members. Team members are trained to evaluate MAGI, Non-MAGI or Long-Term Care determinations for accuracy of those determinations, as well as vital procedural errors that are most likely to impact eligibility. On the first business day of each month, supervisors receive Employee Performance results for their staff and review these results during one on one meetings. Action plans are established, implemented, and reviewed for any needed corrective measures.Eligibility Policy and Procedures were updated March 1, 2020, providing instructions to workers to ensure the case file is complete for all eligibility criteria based on policy, prior to making an eligibility determination. This includes reviewing the case file for the following:? Required documents are in the case file (e.g. signed application, review form, adoption decrees)? Information from the application and other documents is correctly entered into the System of Record? Required verification documents for financial, non-financial and categorical eligibility criteria are in OnBase and recorded on the Documentation Template and/or System of Record where appropriate (such as SSN if not system verified, MAO99, Level of Care)? Documentation template has been completed, including details of verified information such as for income or resources? The determination reflects reported changes found on application, review forms or other reported changes received in person, by mail, fax, or phone? Information requested via FM 1233: Was requested information needed to make a determination? The worker should not deny/close a case for failure to return information if the requested information is not needed. (for instance, information is already in the case file)? Completed budget workbook where appropriateThe updated policy has been incorporated into training and delivered to staff as part of new worker and refresher courses. Application of this policy is evaluated as part of the EQA process.Implementation and Monitoring Plan:Implementation and Monitoring is a shared responsibility among eligibility staff, supervisors, and managers, as well as key program areas within eligibility.Supervisors are responsible for monitoring staff daily by using data available via system of record and workload management software, as well as through case spot reviews. Supervisors meet monthly with each staff member to review EQA findings and timeliness metrics to identify and address issues that impact performance, as well as to facilitate corrections to incorrect determinations identified through the EQA processErrors are identified via error codes and descriptions. EQA reviews are conducted and housed in a state-developed tool to allow for creation of reports that can be generated based on supervisor, worker, work type, error code or overall accuracy. Beginning in October 2020, a monthly report of the top error codes identified for each work type (e.g. MAGI, Non-MAGI, Long Term Care) is generated. A sampling of incorrect cases is analyzed by EQA, Policy and Training for trends and root causes. From this analysis, mitigation strategies are developed and implemented. This may be a combination of supervisor intervention recommendations, policy clarifications or training to be improved, developed, and/or delivered. Data regarding these errors are tracked monthly to identify impact of these mitigation strategies.Starting in the First Quarter (Q1) of CY 2021, the state will compare errors identified through audits and federal reviews such as PERM with EQA error trends and use this monitoring method to determine impact of mitigation strategies on these errors. In addition, the agency will collaborate with our third-party quality review entity, the University of South Carolina Core for Applied Research and Evaluation (USC CARE) to conduct focused reviews to assist with monitoring trends and impact of mitigation strategies. Baseline error rates will be established, based on error codes. This reporting is in development and will be available by the end of Q1 CY 2021. Error codes have been further modified to better identify and monitor specific error trends as prioritized by the agency. System work to incorporate these updated codes in the EQA tool is in development with the agency?s information technology team. An implementation date has not been established.Summary of Eligibility Quality Assurance Process:A. Monthly EQA Reviews (10/worker) ?Monthly Feedback Reports reviewed with worker by supervisor?Corrections made by worker/training needs identified and addressed?Monthly monitoring for progress and corrective actionsB. Top errors identified through EQA process from previous quarter?Root cause analysis completed by training and policy team members?Mitigation strategies identified and implemented?Quarterly monitoring for progress and need for additional/alternative strategies?Continued monitoring and implementationC. Top errors identified through EQA process, PERM, MEQC, audits captured on a quarterly basis?USC CARE conducts third party reviews for additional analysis of root cause and makes recommendations for mitigation?SCDHHS and USC CARE review recommendations, compare with current strategies and implement as appropriate?Quarterly monitoring of findings and progressName(s) of the contact person(s) responsible for corrective action: Lori RiskPlanned completion date for corrective action plan: Ongoing

Prior Finding References

2019-005

About Eligibility →
2020-005
Eligibility
SIGNIFICANT DEFICIENCYREPEAT OF 2019-006QUESTIONED COSTSOTHER MATTERS

The Department did not consistently discontinue the benefits of ineligible recipients.Questioned Costs: $5,851Context: We tested 60 individual recipients to ensure the Department was in compliance with applicable eligibility requirements. We determined the Department did not discontinue the benefits of three recipients on the dates they became ineligible.Cause: Department personnel stated the closure process for these recipients ultimately was not completed due to their interpretation of the Families First Coronavirus Response Act.Effect: The Department was not in compliance with applicable eligibility requirements. In addition, payments were made on behalf of ineligible recipients.Recommendation: We recommend the Department discontinue the benefits of ineligible recipients in accordance with its State plan and federal regulations.Prior Year Single Audit Finding Number: 2019-006Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 135.

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Federal Agency: Department of Health and Human ServicesFederal Program Title: Children?s Health Insurance Program (CHIP)Assistance Listing: 93.767Federal Grant ID Number: 05-1805SC5021Pass-Through Entity: Not applicableAward Period: October 1, 2017 through September 30, 2019Type of Finding: Significant deficiency in internal control over compliance, other mattersCriteria: Section 4.32 of the Department?s Title XIX (Medicaid) State Plan (Income and Eligibility Verification System) affirms that it meets the requirements outlined in 42 CFR 435.930 (b), which states in part, ?The agency must?continue to furnish Medicaid regularly to all eligible individuals until they are found to be ineligible.? In addition, the Department?s Title XXI (CHIP) State Plan attests that CHIP will operate as a Medicaid expansion program; therefore, the aforementioned regulation applies to both programs.Condition: The Department did not consistently discontinue the benefits of ineligible recipients.Questioned Costs: $5,851Context: We tested 60 individual recipients to ensure the Department was in compliance with applicable eligibility requirements. We determined the Department did not discontinue the benefits of three recipients on the dates they became ineligible.Cause: Department personnel stated the closure process for these recipients ultimately was not completed due to their interpretation of the Families First Coronavirus Response Act.Effect: The Department was not in compliance with applicable eligibility requirements. In addition, payments were made on behalf of ineligible recipients.Recommendation: We recommend the Department discontinue the benefits of ineligible recipients in accordance with its State plan and federal regulations.Prior Year Single Audit Finding Number: 2019-006Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 135.

Corrective Action Plan

Department of Health & Human ServicesCenters for Medicare & Medicaid Services31 Forsyth Street, SW, Room 4T20Atlanta, Georgia 30303-8909DEPARTMENT OF HEALTH AND HUMAN SERVICES2020-005 Children?s Health Insurance Program (CHIP) ? Assistance Listing No. 93.767Recommendation: We recommend the Department discontinue the benefits of ineligible recipients in accordance with its State plan and Federal regulations.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding:Root Cause: Case Reviews were not processed within the standard of promptness due to the large backlog of annual reviews and previously, a large backlog of applications.Corrective Action: SCDHHS has implemented a plan to reduce and manage the eligibility processing backlog, while also protecting the integrity of eligibility decisions. The agency?s approach has been to build staff capacity through the creation of processing centers and to maximize accuracy and timeliness of eligibility decisions via implementation of a Staff Performance Evaluation and Remediation process.Staff Capacity and Processing Centers: The agency has created and staffed five (5) processing centers in Richland (2), Aiken (1), Spartanburg (1) and Florence (1) counties. Prior to the COVID-19 Public Health Emergency, staff webinars for processing reviews were conducted for MAGI and Non-MAGI review processing, as well as updates to job aids, based on updated policies and procedures.Staff Performance Evaluation and Remediation: The Eligibility Performance Evaluation and Remediation process rolled out to staff in July 2019. This process includes key elements for review which lead to a correct or incorrect eligibility determination. This includes the presence of a signed application (where appropriate) and presence of other documentation required for the eligibility decision (e.g. Level of Care), correct application of financial and non-financial eligibility criteria, as well as timeliness metrics to assist the agency with meeting federally defined standards.The Eligibility Quality Assurance Team (EQAT) consists of 52 team members. Team members are trained to evaluate MAGI, Non-MAGI or Long-Term Care determinations for accuracy of those determinations, as well as vital procedural errors that are most likely to impact eligibility. On the first business day of each month, supervisors receive Employee Performance results for their staff and review these results during one on one meetings. Action plans are established, implemented, and reviewed for any needed corrective measures.Implementation and Monitoring Plan: Implementation and Monitoring is a shared responsibility among eligibility staff, supervisors, and managers, as well as key program areas within eligibility.Supervisors are responsible for monitoring staff daily by using data available via system of record and workload management software, as well as though case spot reviews. Supervisors meet monthly with each staff member to review EQA findings and timeliness metrics to identify and address issues that impact performance, as well as to facilitate corrections to incorrect determinations identified through the EQA process.Errors are identified via error codes and descriptions. EQA reviews are conducted and housed in a state-developed tool to allow for creation of reports that can be generated based on supervisor, worker, work type, error code or overall accuracy. Beginning in October 2020, a monthly report of the top error codes identified for each work type (e.g. MAGI, Non-MAGI, Long Term Care) is generated. A sampling of incorrect cases is analyzed by EQA, Policy and Training for trends and root causes. From this analysis, mitigation strategies are developed and implemented. This may be a combination of supervisor intervention recommendations, policy clarifications or training to be improved, developed, and/or delivered. Data regarding these errors are tracked monthly to identify impact of these mitigation strategies.Starting in the First Quarter (Q1) of CY 2021, the state will compare errors identified in audits and federal reviews with EQA error trends and use this monitoring method to determine impact of mitigation strategies on these errors. In addition, the agency will collaborate with our third-party quality review entity, the University of South Carolina Core for Applied Research and Evaluation (USC CARE) to conduct focused reviews to assist with monitoring trends and impact of mitigation strategies. Baseline error rates will be established, based on error codes. This reporting is in development and will be available by the end of Q1, CY 2021. Error codes have been further modified to better identify and monitor specific error trends as prioritized by the agency. System work to incorporate these updated codes in the EQA tool is in development with the agency?s information technology team. An implementation date has not been established.Summary of Eligibility Quality Assurance Process:A. Monthly EQA Reviews (10/worker) ?Monthly Feedback Reports reviewed with worker by supervisor?Corrections made by worker/training needs identified and addressed?Monthly monitoring for progress and corrective actionsB. Top errors identified through EQA process from previous quarter?Root cause analysis completed by training and policy team members?Mitigation strategies identified and implemented?Quarterly monitoring for progress and need for additional/alternative strategies?Continued monitoring and implementationC. Top errors identified through EQA process, PERM, MEQC, audits captured on a quarterly basis?USC CARE conducts third party reviews for additional analysis of root cause and makes recommendations for mitigation?SCDHHS and USC CARE review recommendations, compare with current strategies and implement as appropriate?Quarterly monitoring of findings and progressDelays in review processing were due to the public health emergency. The agency is developing its plan to return to normal operations for review processing at the end of the public health emergency, based on guidance provided by CMS.Name(s) of the contact person(s) responsible for corrective action: Lori RiskPlanned completion date for corrective action plan: December 2022

Prior Finding References

2019-006

About Eligibility →
2020-006
Eligibility
MATERIAL WEAKNESSMODIFIED OPINIONREPEAT OF 2019-007

The Department did not consistently perform timely annual eligibility reviews for Medicaid and CHIP recipients in accordance with Section 101.10 of the South Carolina Medicaid Policies and Procedures Manual.Questioned Costs: UnknownContext: We tested 120 individual recipients (60 each for Medicaid and CHIP) to ensure the Department was in compliance with applicable eligibility requirements. We determined the Department did not comply with the annual review requirement for 22 Medicaid recipients and 21 CHIP recipients.Cause: Department personnel stated they did not comply with the annual review requirement for these recipients due to backlog in case processing.Effect: In the absence of an annual review, Medicaid and CHIP recipients may continue to receive benefits without meeting eligibility requirements.Recommendation: We recommend eligibility reviews be performed annually in accordance with the South Carolina Medicaid Policies and Procedures Manual.Prior Year Single Audit Finding Number: 2019-007Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 138.

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Federal Agency: Department of Health and Human ServicesFederal Program Title: Medicaid Cluster; Children?s Health Insurance Program (CHIP)Assistance Listing: 93.775, 93.777, 93.778; 93.767Federal Grant ID Number: 05-1905SC5MAP, 05-2005SC5MAP, 05-1805SC5021, 05-1905SC5022Pass-Through Entity: Not applicableAward Period: October 1, 2017 through September 30, 2020Type of Finding: Material weakness in internal control over compliance, material noncomplianceCriteria: Section 2.1 of the Department?s Title XIX (Medicaid) State Plan (Application, Determination of Eligibility and Furnishing Medicaid) affirms that it meets the requirements outlined in 42 CFR Part 435.916, which states in part, ?the agency must promptly determine eligibility between regular renewals of eligibility.? In addition, Section 101.10 of the South Carolina Medicaid Policies and Procedures Manual states that the Department must complete an annual review for certain payment categories. Furthermore, the Department?s Title XXI (CHIP) State Plan attests that CHIP will operate as a Medicaid expansion program; therefore, the aforementioned regulation and polices apply to both programs.Condition: The Department did not consistently perform timely annual eligibility reviews for Medicaid and CHIP recipients in accordance with Section 101.10 of the South Carolina Medicaid Policies and Procedures Manual.Questioned Costs: UnknownContext: We tested 120 individual recipients (60 each for Medicaid and CHIP) to ensure the Department was in compliance with applicable eligibility requirements. We determined the Department did not comply with the annual review requirement for 22 Medicaid recipients and 21 CHIP recipients.Cause: Department personnel stated they did not comply with the annual review requirement for these recipients due to backlog in case processing.Effect: In the absence of an annual review, Medicaid and CHIP recipients may continue to receive benefits without meeting eligibility requirements.Recommendation: We recommend eligibility reviews be performed annually in accordance with the South Carolina Medicaid Policies and Procedures Manual.Prior Year Single Audit Finding Number: 2019-007Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 138.

Corrective Action Plan

Department of Health & Human ServicesCenters for Medicare & Medicaid Services31 Forsyth Street, SW, Room 4T20Atlanta, Georgia 30303-8909DEPARTMENT OF HEALTH AND HUMAN SERVICES2020-006 Medicaid Cluster; Children?s Health Insurance Program (CHIP) ? Assistance Listing No. 93.775, 93.777, 93.778; 93.767Recommendation: We recommend eligibility reviews be performed annually in accordance with the South Carolina Medicaid Policies and Procedures Manual.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding:Root Cause: Case Reviews were not processed within the standard of promptness due to the large backlog of annual reviews and previously, a large backlog of applications.Corrective Action: SCDHHS has implemented a plan to reduce and manage the eligibility processing backlog, while also protecting the integrity of eligibility decisions. The agency?s approach has been to build staff capacity through the creation of processing centers and to maximize accuracy and timeliness of eligibility decisions via implementation of a Staff Performance Evaluation and Remediation process.Staff Capacity and Processing Centers: The agency has created and staffed five (5) processing centers in Richland (2), Aiken (1), Spartanburg (1) and Florence (1) counties. Prior to the COVID-19 Public Health Emergency, staff webinars for processing reviews were conducted for MAGI and Non-MAGI review processing, as well as updates to job aids, based on updated policies and procedures.Staff Performance Evaluation and Remediation: The Eligibility Performance Evaluation and Remediation process rolled out to staff in July 2019. This process includes key elements for review which lead to a correct or incorrect eligibility determination. This includes the presence of a signed application (where appropriate) and presence of other documentation required for the eligibility decision (e.g. Level of Care), correct application of financial and non-financial eligibility criteria, as well as timeliness metrics to assist the agency with meeting federally defined standards.The Eligibility Quality Assurance Team (EQAT) consists of 52 team members. Team members are trained to evaluate MAGI, Non-MAGI or Long-Term Care determinations for accuracy of those determinations, as well as vital procedural errors that are most likely to impact eligibility. On the first business day of each month, supervisors receive Employee Performance results for their staff and review these results during one on one meetings. Action plans are established, implemented, and reviewed for any needed corrective measures.Implementation and Monitoring Plan: Implementation and Monitoring is a shared responsibility among eligibility staff, supervisors, and managers, as well as key program areas within eligibility.Supervisors are responsible for monitoring staff daily by using data available via system of record and workload management software, as well as though case spot reviews. Supervisors meet monthly with each staff member to review EQA findings and timeliness metrics to identify and address issues that impact performance, as well as to facilitate corrections to incorrect determinations identified through the EQA process.Errors are identified via error codes and descriptions. EQA reviews are conducted and housed in a state-developed tool to allow for creation of reports that can be generated based on supervisor, worker, work type, error code or overall accuracy. Beginning in October 2020, a monthly report of the top error codes identified for each work type (e.g. MAGI, Non-MAGI, Long Term Care) is generated. A sampling of incorrect cases is analyzed by EQA, Policy and Training for trends and root causes. From this analysis, mitigation strategies are developed and implemented. This may be a combination of supervisor intervention recommendations, policy clarifications or training to be improved, developed, and/or delivered. Data regarding these errors are tracked monthly to identify impact of these mitigation strategies.Starting in the First Quarter (Q1) of CY 2021, the state will compare errors identified by audits and federal reviews with EQA error trends and use this monitoring method to determine impact of mitigation strategies on these errors. In addition, the agency will collaborate with our third-party quality review entity, the University of South Carolina Core for Applied Research and Evaluation (USC CARE) to conduct focused reviews to assist with monitoring trends and impact of mitigation strategies. Baseline error rates will be established, based on error codes. This reporting is in development and will be available by the end of Q1 CY 2021. Error codes have been further modified to better identify and monitor specific error trends as prioritized by the agency. System work to incorporate these updated codes in the EQA tool is in development with the agency?s information technology team. An implementation date has not been established.Summary of Eligibility Quality Assurance Process:A. Monthly EQA Reviews (10/worker) ?Monthly Feedback Reports reviewed with worker by supervisor?Corrections made by worker/training needs identified and addressed?Monthly monitoring for progress and corrective actionsB. Top errors identified through EQA process from previous quarter?Root cause analysis completed by training and policy team members?Mitigation strategies identified and implemented?Quarterly monitoring for progress and need for additional/alternative strategies?Continued monitoring and implementationC. Top errors identified through EQA process, PERM, MEQC, audits captured on a quarterly basis?USC CARE conducts third party reviews for additional analysis of root cause and makes recommendations for mitigation?SCDHHS and USC CARE review recommendations, compare with current strategies and implement as appropriate?Quarterly monitoring of findings and progressDelays in review processing due to Public Health Emergency: The agency is developing its plan to return to normal operations for review processing at the end of the Public Health Emergency, based on guidance provided by CMS.Name(s) of the contact person(s) responsible for corrective action: Lori RiskPlanned completion date for corrective action plan: December 2022If the U.S. Department of Health and Human Services has questions regarding this plan, please call Cynthia Moore, Controller at 803-898-1880.

Prior Finding References

2019-007

About Eligibility →
2020-008
Subrecipient Monitoring
SIGNIFICANT DEFICIENCYREPEAT OF 2019-025OTHER MATTERS

The Department failed to comply with its policies for monitoring the programs and activities of its subrecipients.Questioned Costs: UnknownContext: Our test of subrecipients indicated progress had been made with the implementation of corrective action to address this finding reported in the prior year. However, the annual onsite visits and monitoring required by Department policy were not fully completed for the five subrecipients selected for testing.Cause: The Department?s ability to perform onsite visits and monitoring of subrecipients was constrained significantly by the global pandemic.Effect: Subrecipient programs and activities were not monitored in accordance with Department policies and federal requirements.Recommendation: We recommend that the Department continue to implement policies and procedures to facilitate compliance with Department and federal monitoring requirements.Prior Year Single Audit Report Finding Number: 2019-025Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 142.

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Federal Agency: Department of Health and Human ServicesFederal Program Title: Aging ClusterAssistance Listing: 93.044, 93.045, 93.053Federal Grant ID Number: VariousPass-Through Entity: Not applicableAward Period: VariousType of Finding: Significant deficiency in internal control over compliance, other mattersCriteria: 45 CFR ? 1321.11 directs the State agency to develop policies to address the manner in which it will monitor the performance of all programs and activities for quality and effectiveness.Condition: The Department failed to comply with its policies for monitoring the programs and activities of its subrecipients.Questioned Costs: UnknownContext: Our test of subrecipients indicated progress had been made with the implementation of corrective action to address this finding reported in the prior year. However, the annual onsite visits and monitoring required by Department policy were not fully completed for the five subrecipients selected for testing.Cause: The Department?s ability to perform onsite visits and monitoring of subrecipients was constrained significantly by the global pandemic.Effect: Subrecipient programs and activities were not monitored in accordance with Department policies and federal requirements.Recommendation: We recommend that the Department continue to implement policies and procedures to facilitate compliance with Department and federal monitoring requirements.Prior Year Single Audit Report Finding Number: 2019-025Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 142.

Corrective Action Plan

U.S. Department of Health and Human ServicesThe South Carolina Department on Aging respectfully submits the following corrective action plan for the year ended June 30, 2020.The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule.FINDINGS?FEDERAL AWARD PROGRAM AUDITU.S. Department of Health and Human Services2020-008 Aging Cluster ? Assistance Listing No. 93.044, 93.045, 93.053Recommendation: We recommend that the Department continue to implement policies and procedures to facilitate compliance with Department and Federal monitoring requirements.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding: SCDOA has hired an additional staff member in the finance department to monitor subrecipients. As of the end of March 2021, six AAA have been monitored by the finance department despite the challenges of COVID, and the four remaining agencies will be monitored by June 30, 2021.Name(s) of the contact person(s) responsible for corrective action: Rhonda Walker and Andrew Walsh.Planned completion date for corrective action plan: June 30, 2021If the U.S. Department of Health and Human Services has questions regarding this plan, please call Connie D. Munn at (803) 734-9910.

Prior Finding References

2019-025

About Subrecipient Monitoring →
2020-009
Matching, Level of Effort, Earmarking
SIGNIFICANT DEFICIENCYOTHER MATTERS

Discrepancies existed between non-federal share amounts reported to meet matching requirements and the supporting accounting records.Questioned Costs: UnknownContext: The 2017 Title III-B and C grants, which closed during the audit period, were selected for detailed testing. While the total recipient share of expenditures reported for each grant met or exceeded the total share required, in comparison to the accounting system, the non-federal share amounts reported were overstated for administration and understated for services. These classification discrepancies totaled several hundred thousand dollars across all three Title III-B and C grants.Cause: The Department chose to reclassify some non-federal services expenditures recorded in the accounting system as non-federal administration expenditures on the federal report.Effect: The Department?s accounting system does not support the amounts reported for non-federal administration and services expenditures. The risk of noncompliance is greater when classification discrepancies exist between amounts reported and the Department?s accounting system.Recommendation: We recommend that policies and procedures are put in place to ensure that non-federal share reported for each matching requirement is supported by and agrees to the Department?s accounting system.Prior Year Single Audit Report Finding Number: Not applicableViews of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 142.

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Federal Agency: Department of Health and Human ServicesFederal Program Title: Aging ClusterAssistance Listing: 93.044, 93.045, 93.053Federal Grant ID: 17AASCT3SS, 17AASCT3CM, 17AASCT3HDPass-Through Entity: Not applicableAward Period: October 1, 2016 through September 30, 2019Type of Finding: Significant deficiency in internal control over compliance, other mattersCriteria: Matching requirements of the program are mandated by 45 CFR ? 1321.47 as follows: The statewide non-federal share for State or area plan administration must not be less than 25 percent of the funds used under this part. All services statewide, including ombudsman services and services funded under Title III-B, C, D, E and F, must be funded on a statewide basis with a non-federal share of not less than 15 percent. Matching requirements for individual area agencies are determined by the State agency.Condition: Discrepancies existed between non-federal share amounts reported to meet matching requirements and the supporting accounting records.Questioned Costs: UnknownContext: The 2017 Title III-B and C grants, which closed during the audit period, were selected for detailed testing. While the total recipient share of expenditures reported for each grant met or exceeded the total share required, in comparison to the accounting system, the non-federal share amounts reported were overstated for administration and understated for services. These classification discrepancies totaled several hundred thousand dollars across all three Title III-B and C grants.Cause: The Department chose to reclassify some non-federal services expenditures recorded in the accounting system as non-federal administration expenditures on the federal report.Effect: The Department?s accounting system does not support the amounts reported for non-federal administration and services expenditures. The risk of noncompliance is greater when classification discrepancies exist between amounts reported and the Department?s accounting system.Recommendation: We recommend that policies and procedures are put in place to ensure that non-federal share reported for each matching requirement is supported by and agrees to the Department?s accounting system.Prior Year Single Audit Report Finding Number: Not applicableViews of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 142.

Corrective Action Plan

U.S. Department of Health and Human ServicesThe South Carolina Department on Aging respectfully submits the following corrective action plan for the year ended June 30, 2020.The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule.FINDINGS?FEDERAL AWARD PROGRAM AUDITU.S. Department of Health and Human Services2020-009 Aging Cluster ? Assistance Listing No. 93.044, 93.045, 93.053Recommendation: We recommend that policies and procedures are put in place to ensure that non-Federal share reported for each matching requirement is supported by and agrees to the Department?s accounting system.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding: Policies have been created that require all match funds recorded into the statewide accounting system have the grant number included for the transaction when recorded by SCDOA. Policy and procedures also require that the match funds reported to the federal reports be confirmed in the SCEIS system prior to filing the federal report.Name(s) of the contact person(s) responsible for corrective action: Lisa Crosby and Rhonda Walker.Planned completion date for corrective action plan: March 31, 2021If the U.S. Department of Health and Human Services has questions regarding this plan, please call Connie D. Munn at (803) 734-9910.

About Matching, Level of Effort, Earmarking →
2020-010
Activities Allowed or Unallowed / Cost Allowability
SIGNIFICANT DEFICIENCYOTHER MATTERS

An expenditure was posted to the incorrect fiscal year.Questioned Costs: NoneContext: One of thirty-two expenditures was posted to the incorrect fiscal year without being marked as a prior period expenditure.Cause: The Department's internal controls failed to detect an expenditure posted to the incorrect fiscal year.Effect: Expenditure reported incorrectly.Recommendation: We recommend that the Department strengthen internal controls regarding expenditure approval to ensure that expenditures are posted to the correct fiscal year.Prior Year Single Audit Finding Number: Not ApplicableViews of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 144.

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Federal Agency: US Department of EducationFederal Program Title: Special Education Cluster (IDEA)Assistance Listing: 84.027 and 84.173Federal Grant ID Number: H027A170081Pass-Through Entity: Not applicableAward Period: July 01, 2017 through September 30, 2019Type of Finding: Significant deficiency in internal control over compliance, other mattersCriteria: Per 2 CFR ? 200.303 Internal controls, 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 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 and the ``Internal Control Integrated Framework??, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).Condition: An expenditure was posted to the incorrect fiscal year.Questioned Costs: NoneContext: One of thirty-two expenditures was posted to the incorrect fiscal year without being marked as a prior period expenditure.Cause: The Department's internal controls failed to detect an expenditure posted to the incorrect fiscal year.Effect: Expenditure reported incorrectly.Recommendation: We recommend that the Department strengthen internal controls regarding expenditure approval to ensure that expenditures are posted to the correct fiscal year.Prior Year Single Audit Finding Number: Not ApplicableViews of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 144.

Corrective Action Plan

U.S. Department of EducationS.C. Department of Education respectfully submits the following corrective action plan for the year ended 6/30/20.The finding from the schedule of findings and questioned costs are discussed below. The finding is numbered consistently with the numbers assigned in the schedule.FINDING?FEDERAL AWARD PROGRAM AUDITDEPARTMENT OF EDUCATION2020-010 Activities Allowed or Unallowed and Allowable Costs/Cost PrinciplesSpecial Education Cluster (IDEA) ? Assistance Listing No. 84.027 and 84.173Recommendation: We recommend that the Department strengthen internal controls regarding review and approval to ensure that expenditures are recorded in the correct fiscal year.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding: The steps below should be followed all fiscal year. However, these steps are especially important as a fiscal year closes and another begins to ensure documents are classified correctly.The agency will strengthen its review of transactions to ensure all expenditures are recorded in the correct fiscal year. Each analyst will exercise greater caution when coding invoices determined to be prior year payables (PYP) (with appropriate amount indicated) as payments are entered into SCEIS. If the payments are processed via an interface, PYP should be added to the document?s text field (with appropriate amount indicated) as soon as a document number is established. Additionally, agency approvers (AP Lead and/or Managers) will review documents closely to determine if any portion (or the entire payment) should be classified as PYP prior to approval. If a document is not classified as a PYP, it will be returned to the analyst for correction prior to approval.Name(s) of the contact person(s) responsible for corrective action: Lori Dean, Fiscal Accounting ManagerPlanned completion date for corrective action plan: ImmediatelyIf the U.S. Department of Education has questions regarding this plan, please call Nancy W. Williams, CFO at 803-734-8108.

About Activities Allowed or Unallowed, Allowable Costs / Cost Principles →
2020-011
Cost Allowability
SIGNIFICANT DEFICIENCYOTHER MATTERS

Equipment was purchased and not managed in accordance with certain State procedures.Questioned Costs: UndeterminedContext: One of the disbursement transactions selected for testing included a preapproved purchase of numerous equipment items, some of which were not tracked by the Department in accordance with State policy. The amount of the equipment purchase that should have been tracked was not determined in our testing.Cause: Department controls failed to identify the purchase as equipment.Effect: Federally funded equipment was not tracked in accordance with State policy.Recommendation: We recommend that the Department implement procedures to ensure any equipment purchased with federal funding is managed in accordance with State requirements.Prior Year Single Audit Finding Number: Not applicableViews of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 146.

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Federal Agency: Department of EducationFederal Program Title: Rehabilitation Services-Vocational Rehabilitation Grants to StatesAssistance Listing No.: 84.126Federal Grant ID Number: H126A180060Pass-Through Entity: Not applicableAward Period: October 1, 2017 through September 30, 2019Type of Finding: Significant deficiency in internal control over compliance, other mattersCriteria: For costs to be allowable under federal awards, 2 CFR 200.403(c) requires that applicable policies and procedures must be applied uniformly to both federally-financed and other activities of the non-federal entity.Additionally, 2 CFR 200.313(b) requires a State to use, manage and dispose of equipment acquired under a federal award in accordance with State laws and procedures.Finally, the State of South Carolina Comptroller General?s Reporting Policies and Procedures Manual describes how equipment should be tracked for the purpose of ensuring compliance with the annual inventory requirements mandated by Section 10-1-140 of the South Carolina Code of Laws.Condition: Equipment was purchased and not managed in accordance with certain State procedures.Questioned Costs: UndeterminedContext: One of the disbursement transactions selected for testing included a preapproved purchase of numerous equipment items, some of which were not tracked by the Department in accordance with State policy. The amount of the equipment purchase that should have been tracked was not determined in our testing.Cause: Department controls failed to identify the purchase as equipment.Effect: Federally funded equipment was not tracked in accordance with State policy.Recommendation: We recommend that the Department implement procedures to ensure any equipment purchased with federal funding is managed in accordance with State requirements.Prior Year Single Audit Finding Number: Not applicableViews of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 146.

Corrective Action Plan

U.S. Department of EducationThe South Carolina Vocational Rehabilitation Department respectfully submits the following corrective action plan for the year ended June 30, 2020.The finding from the schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the numbers assigned in the schedule.FINDINGS?FEDERAL AWARD PROGRAM AUDITU.S. Department of Education2020-011 Vocational Services-Vocational Rehabilitation Grants to States ? Assistance Listing No. 84.126Recommendation: We recommend that the Department implement procedures to ensure any equipment purchased with Federal funding is managed in accordance with state requirements.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding: The Agency will review and update (as needed) existing procedures to correct this deficiency. Appropriate staff will receive additional training on the purchasing of equipment to ensure understanding of the requirement that capital assets are tagged and recorded appropriately within the system in order to meet both state and federal requirements.Appropriate staff will review shopping carts on a weekly basis to verify that all equipment purchases are recorded as defined by state and federal requirements. Adjustments will be made as necessary for those shopping carts/purchase orders that will need to be corrected. Procurement card purchases will continue to be reviewed on a monthly basis and appropriate action will take place to ensure those assets are tagged and recorded appropriately.Name of the contact person responsible for corrective action: Ryan FutralPlanned completion date for corrective action plan: 06/30/2021If the US Department of Education has questions regarding this plan, please call Breta Rheney at (803) 896-6602.

About Allowable Costs / Cost Principles →
2020-012
Matching, Level of Effort, Earmarking
SIGNIFICANT DEFICIENCYOTHER MATTERS

The Commission was not in compliance with the pre-employment transition services earmarking requirement.Questioned Costs: NoneContext: Testing of the one grant that closed during the audit period revealed that the amount charged to the grant for pre-employment transition services did not meet the fifteen percent requirement.Cause: Commission controls failed to ensure that the earmarking requirement was met prior to finalizing the grant.Effect: The Commission was not in compliance with the federal earmarking requirement.Recommendation: We recommend that the Commission implement procedures to ensure that spending requirements for pre-employment transition services are met before the grant is closed.Prior Year Single Audit Finding Number: Not applicableViews of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 147.

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Federal Agency: Department of EducationFederal Program Title: Rehabilitation Services-Vocational Rehabilitation Grants to StatesAssistance Listing No.: 84.126Federal Grant ID Number: H126A180061Pass-Through Entity: Not applicableAward Period: October 1, 2017 through September 30, 2019Type of Finding: Significant deficiency in internal control over compliance, other mattersCriteria: 29 USC 730(d)(1) requires States to reserve no less than fifteen percent of the allotted funds to be spent for the provision of pre-employment transition services.Condition: The Commission was not in compliance with the pre-employment transition services earmarking requirement.Questioned Costs: NoneContext: Testing of the one grant that closed during the audit period revealed that the amount charged to the grant for pre-employment transition services did not meet the fifteen percent requirement.Cause: Commission controls failed to ensure that the earmarking requirement was met prior to finalizing the grant.Effect: The Commission was not in compliance with the federal earmarking requirement.Recommendation: We recommend that the Commission implement procedures to ensure that spending requirements for pre-employment transition services are met before the grant is closed.Prior Year Single Audit Finding Number: Not applicableViews of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 147.

Corrective Action Plan

U.S. Department of EducationThe South Carolina Commission for the Blind respectfully submits the following corrective action plan for the year ended June 30, 2020.The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule.FINDINGS?FEDERAL AWARD PROGRAM AUDITU.S. Department of Education2020-012 Rehabilitation Services-Vocational Rehabilitation Grants to StatesAssistance Listing No.: 84.126Recommendation: We recommend that the Commission implement procedures to ensure that spending requirements for pre-employment transition services are met before the grant is closed.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding: Monthly grant expenditure reports will be completed and reviewed with management to ensure that the required expenditure level for Pre-Employment Transition Services is met before the grant is closed.Name(s) of the contact person(s) responsible for corrective action: Carrie MorrisPlanned completion date for corrective action plan: 5-1-21If the Federal Cognizant of Oversight Agency for Audit has questions regarding this plan, please call Matthew Daugherty at 803-898-8835.

About Matching, Level of Effort, Earmarking →
2020-013
Reporting
SIGNIFICANT DEFICIENCYREPEAT OF 2019-028OTHER MATTERS

Key data elements reported on the Commission's RSA-911 performance reports did not agree with underlying case records.Questioned Costs: NoneContext: Two quarterly RSA-911 reports were selected for testing and the key data elements of twenty individuals were tested from each report. Discrepancies were noted for one application date, one eligibility determination date, three IPE dates, and one hourly rate at exit.Cause: Commission controls failed to identify and correct the discrepancies noted in the RSA-911 reports prior to submission, and subsequent corrections were not possible through the RSA-911 reporting process.Effect: Some of the data fields reported in the RSA-911 are inconsistent with the applicable supporting records.Recommendation: We recommend that the Commission continue implementation of the associated corrective action plan.Prior Year Single Audit Finding Number: 2019-028Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 147.

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Federal Agency: Department of EducationFederal Program Title: Rehabilitation Services-Vocational Rehabilitation Grants to StatesAssistance Listing No.: 84.126Federal Grant ID Number: VariousPass-Through Entity: Not applicableAward Period: VariousType of Finding: Significant deficiency in internal control over compliance, other mattersCriteria: 34 CFR ?361.47 requires States to maintain a case record for each applicant and eligible individual that must include documentation to support eligibility determinations, development of an individualized plan for employment, services provided, and case closure. Much of the information contained in these case records is reported as key data elements in the Case Service Report (RSA-911).Condition: Key data elements reported on the Commission's RSA-911 performance reports did not agree with underlying case records.Questioned Costs: NoneContext: Two quarterly RSA-911 reports were selected for testing and the key data elements of twenty individuals were tested from each report. Discrepancies were noted for one application date, one eligibility determination date, three IPE dates, and one hourly rate at exit.Cause: Commission controls failed to identify and correct the discrepancies noted in the RSA-911 reports prior to submission, and subsequent corrections were not possible through the RSA-911 reporting process.Effect: Some of the data fields reported in the RSA-911 are inconsistent with the applicable supporting records.Recommendation: We recommend that the Commission continue implementation of the associated corrective action plan.Prior Year Single Audit Finding Number: 2019-028Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 147.

Corrective Action Plan

U.S. Department of EducationThe South Carolina Commission for the Blind respectfully submits the following corrective action plan for the year ended June 30, 2020.The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule.2020-013 Rehabilitation Services-Vocational Rehabilitation Grants to StatesAssistance Listing No.: 84.126Recommendation: We recommend that the Commission continue implementation of the associated corrective action plan.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding: SCCB will continue to conduct quarterly data validation reviews. Based on case file documentation, data discrepancies will be resolved prior to the submission of the RSA-911. Additional staff have been added to the QualityAssurance department to ensure expediency of identifying and resolving data discrepancies. It is to be noted that 100% accuracy of all RSA-911 data elements will not be immediately attainable. Since cases are selected randomly for testing, it is possible that cases which contained data discrepancies prior to the implementation of the correction plan (May 31, 2019) may be included in the sample set due to the length of time that a consumer can be served. In addition, several of the RSA-911 data elements which are tested cannot be resubmitted to RSA for correction.Name(s) of the contact person(s) responsible for corrective action: Shana RobinsonPlanned completion date for corrective action plan: OngoingIf the Federal Cognizant of Oversight Agency for Audit has questions regarding this plan, please call Matthew Daugherty at 803-898-8835.

Prior Finding References

2019-028

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2020-014
Reporting
SIGNIFICANT DEFICIENCYREPEAT OF 2019-029OTHER MATTERS

Discrepancies existed between federal financial reports and the Commission?s supporting records.Questioned Costs: NoneContext: The 2019 RSA-2 Annual Vocational Rehabilitation Program/Cost Report and the final SF-425 report for the 2018 grant were selected for testing. Several of the items reported in Schedules I and III of the RSA-2 report did not agree to the Commission?s supporting records. Additionally, the indirect expense base amount in the SF-425 report was not adequately supported by Commission documentation.Cause: Some of the original supporting data for the RSA-2 report was corrupted in a data loss event and the Commission was unable to reconstruct the lost data in the level of detail necessary to fully support the report. Staffing shortages and turnover also contributed to the discrepancies.Effect: Some reported information could not be verified.Recommendation: We recommend that the Commission develop and implement policies and procedures that ensure the security of all data compiled to support federal reports.Prior Year Single Audit Finding Number: 2019-029Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 148.

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Federal Agency: Department of EducationFederal Program Title: Rehabilitation Services-Vocational Rehabilitation Grants to StatesAssistance Listing No.: 84.126Federal Grant ID Number: VariousPass-Through Entity: Not applicableAward Period: VariousType of Finding: Significant deficiency in internal control over compliance, other mattersCriteria: Per 34 CFR ?361.40(a)(2), the designated State agency must comply with any requirements necessary to ensure the accuracy and verification of reports.Condition: Discrepancies existed between federal financial reports and the Commission?s supporting records.Questioned Costs: NoneContext: The 2019 RSA-2 Annual Vocational Rehabilitation Program/Cost Report and the final SF-425 report for the 2018 grant were selected for testing. Several of the items reported in Schedules I and III of the RSA-2 report did not agree to the Commission?s supporting records. Additionally, the indirect expense base amount in the SF-425 report was not adequately supported by Commission documentation.Cause: Some of the original supporting data for the RSA-2 report was corrupted in a data loss event and the Commission was unable to reconstruct the lost data in the level of detail necessary to fully support the report. Staffing shortages and turnover also contributed to the discrepancies.Effect: Some reported information could not be verified.Recommendation: We recommend that the Commission develop and implement policies and procedures that ensure the security of all data compiled to support federal reports.Prior Year Single Audit Finding Number: 2019-029Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 148.

Corrective Action Plan

U.S. Department of EducationThe South Carolina Commission for the Blind respectfully submits the following corrective action plan for the year ended June 30, 2020.The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule.2020-014 Rehabilitation Services-Vocational Rehabilitation Grants to StatesAssistance Listing No.: 84.126Recommendation: We recommend that the Commission develop and implement policies and procedures that ensure the security of all data compiled to support federal reports.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding: Procedures are being developed to ensure that reports are adequately documented and that such documentation is maintained in a secure electronic manner, including an external hard drive for large amounts of data backup. Internal controls are now in place to adequately support indirect expense base. To prevent future loss of data, supporting documentation for federal reports will be uploaded to a shared drive which will be accessible by management and staff who are directly involved with compiling data and/or reporting. In addition, an external hard drive has been obtained and will be utilized as a secondary backup in case of system failures ? e.g. server issues, network outages, etc.Name(s) of the contact person(s) responsible for corrective action: Shana Robinson and Carrie MorrisPlanned completion date for corrective action plan: 7-1-21If the Federal Cognizant of Oversight Agency for Audit has questions regarding this plan, please call Matthew Daugherty at 803-898-8835.

Prior Finding References

2019-029

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2020-015
Cash Management
SIGNIFICANT DEFICIENCYREPEAT OF 2019-030OTHER MATTERS

Cash management compliance was not documented for some drawdowns.Questioned Costs: UnknownContext: For two of three drawdowns tested, adequate documentation was not maintained to support the amount of the drawdown.Cause: The Commission had not completely implemented the corrective action associated with the finding from the prior year.Effect: The Commission may drawdown funds in excess of eligible reimbursable expenditures.Recommendation: We recommend that the Commission continue implementing the corrective action plan and strengthen the associated controls to ensure compliance is clearly documented.Prior Year Single Audit Finding Number: 2019-030Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 148.

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Federal Agency: Department of EducationFederal Program Title: Rehabilitation Services-Vocational Rehabilitation Grants to StatesAssistance Listing No.: 84.126Federal Grant ID Number: H126A180061; H126A190061Pass-Through Entity: Not applicableAward Period: October 1, 2017 through September 30, 2020Type of Finding: Significant deficiency in internal control over compliance, other mattersCriteria: 2 CFR ?200.303 requires non-federal entities to establish and maintain effective internal controls that ensure material compliance with federal statutes, regulations, and the terms and conditions of the federal awards.Condition: Cash management compliance was not documented for some drawdowns.Questioned Costs: UnknownContext: For two of three drawdowns tested, adequate documentation was not maintained to support the amount of the drawdown.Cause: The Commission had not completely implemented the corrective action associated with the finding from the prior year.Effect: The Commission may drawdown funds in excess of eligible reimbursable expenditures.Recommendation: We recommend that the Commission continue implementing the corrective action plan and strengthen the associated controls to ensure compliance is clearly documented.Prior Year Single Audit Finding Number: 2019-030Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 148.

Corrective Action Plan

U.S. Department of EducationThe South Carolina Commission for the Blind respectfully submits the following corrective action plan for the year ended June 30, 2020.The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule.2020-015 Rehabilitation Services-Vocational Rehabilitation Grants to StatesAssistance Listing No.: 84.126Recommendation: We recommend that the Commission continue implementing the corrective action plan and strengthen the associated controls to ensure compliance is clearly documented.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding: Draw documentation is now being maintained electronically to prevent data loss. There is now an approval process in place to verify the accuracy of grant drawdowns. This includes a comparison of expenses incurred to cash draw.Name(s) of the contact person(s) responsible for corrective action: Carrie MorrisPlanned completion date for corrective action plan: completedIf the Federal Cognizant of Oversight Agency for Audit has questions regarding this plan, please call Matthew Daugherty at 803-898-8835.

Prior Finding References

2019-030

About Cash Management →
2020-016
Activities Allowed or Unallowed / Cost Allowability
SIGNIFICANT DEFICIENCYOTHER MATTERS

The allocation of some compensation costs was inadequately supported or improperly applied.Questioned Costs: UnknownContext: Forty payroll disbursements were randomly selected for testing and discrepancies associated with allocation of compensation to multiple grants were identified for six employees in the test. For four of the employees, the Commission used an outdated percentage to allocate costs. For the other two employees, adequate documentation was not maintained to substantiate the allocation.Cause: Commission controls failed to prevent the identified issues, but staffing shortages and turnover during the audit period were also contributing factors.Effect: The Commission may overcharge the grant for personnel cost.Recommendation: We recommend that the Commission implement procedures which will provide assurance that personnel charges are accurate, allowable, and properly allocated to applicable grants.Prior Year Single Audit Finding Number: Not applicableViews of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 149.

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Federal Agency: Department of EducationFederal Program Title: Rehabilitation Services-Vocational Rehabilitation Grants to StatesAssistance Listing No.: 84.126Federal Grant ID Number: H126A190061Pass-Through Entity: Not applicableAward Period: October 1, 2018 through September 30, 2020Type of Finding: Significant deficiency in internal control over compliance, other mattersCriteria: 2 CFR ? 200.430 (a) states that the costs of compensation are allowable to the extent that the total compensation for individual employees is reasonable for the services rendered and conforms to the established written policy of the non-federal entity consistently applied to both federal and non-federal activities.Condition: The allocation of some compensation costs was inadequately supported or improperly applied.Questioned Costs: UnknownContext: Forty payroll disbursements were randomly selected for testing and discrepancies associated with allocation of compensation to multiple grants were identified for six employees in the test. For four of the employees, the Commission used an outdated percentage to allocate costs. For the other two employees, adequate documentation was not maintained to substantiate the allocation.Cause: Commission controls failed to prevent the identified issues, but staffing shortages and turnover during the audit period were also contributing factors.Effect: The Commission may overcharge the grant for personnel cost.Recommendation: We recommend that the Commission implement procedures which will provide assurance that personnel charges are accurate, allowable, and properly allocated to applicable grants.Prior Year Single Audit Finding Number: Not applicableViews of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 149.

Corrective Action Plan

U.S. Department of EducationThe South Carolina Commission for the Blind respectfully submits the following corrective action plan for the year ended June 30, 2020.The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule.2020-016 Rehabilitation Services-Vocational Rehabilitation Grants to StatesAssistance Listing No.: 84.126Recommendation: We recommend that the Commission implement procedures which will provide assurance that personnel charges are accurate, allowable, and properly allocated to applicable grants.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding: The Commission will implement procedures to properly allocate charges to the applicable grants, including the use of consumer counts and other appropriate allocation methods.Name(s) of the contact person(s) responsible for corrective action: Carrie MorrisPlanned completion date for corrective action plan: 7-1-21If the Federal Cognizant of Oversight Agency for Audit has questions regarding this plan, please call Matthew Daugherty at 803-898-8835.

About Activities Allowed or Unallowed, Allowable Costs / Cost Principles →
2020-017
Activities Allowed or Unallowed / Cost Allowability
SIGNIFICANT DEFICIENCYQUESTIONED COSTSOTHER MATTERS

The Commission?s internal control procedures for disbursements were not documented consistently and an overpayment was noted for one non-payroll disbursement tested.Questioned Costs: $64Context: While compensating controls were identified, there was inadequate evidence of proper approval for thirty of the eighty-one non-payroll disbursements selected for testing. For one of these payments, it was also noted that the amount paid exceeded the maximum amount allowed by Commission policy.Cause: The Commission failed to retain documentation demonstrating performance of their internal control process, established during a period of staffing shortages and turnover.Effect: The Commission did not maintain adequate documentation to demonstrate compliance with its own control procedures.Recommendation: We recommend that the Commission properly document all control procedures.Prior Year Single Audit Finding Number: Not applicableViews of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 149.

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Federal Agency: Department of EducationFederal Program Title: Rehabilitation Services-Vocational Rehabilitation Grants to StatesAssistance Listing No.: 84.126Federal Grant ID Number: H126A180061; H126A190061Pass-Through Entity: Not applicableAward Period: October 1, 2017 through September 30, 2020Type of Finding: Significant deficiency in internal control over compliance, other mattersCriteria: 2 CFR ?200.303 requires non-federal entities to establish and maintain effective internal controls that ensure material compliance with federal statutes, regulations, and the terms and conditions of the federal awards.Condition: The Commission?s internal control procedures for disbursements were not documented consistently and an overpayment was noted for one non-payroll disbursement tested.Questioned Costs: $64Context: While compensating controls were identified, there was inadequate evidence of proper approval for thirty of the eighty-one non-payroll disbursements selected for testing. For one of these payments, it was also noted that the amount paid exceeded the maximum amount allowed by Commission policy.Cause: The Commission failed to retain documentation demonstrating performance of their internal control process, established during a period of staffing shortages and turnover.Effect: The Commission did not maintain adequate documentation to demonstrate compliance with its own control procedures.Recommendation: We recommend that the Commission properly document all control procedures.Prior Year Single Audit Finding Number: Not applicableViews of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 149.

Corrective Action Plan

U.S. Department of EducationThe South Carolina Commission for the Blind respectfully submits the following corrective action plan for the year ended June 30, 2020.The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule.2020-017 Rehabilitation Services-Vocational Rehabilitation Grants to StatesAssistance Listing No.: 84.126Recommendation: We recommend that the Commission properly document all control procedures.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding: The Commission has new policies and procedures in place for all case service expenditures and other direct payments. These include new authorization approval processes in our case management system (AWARE) and new approval forms for non case service expenditures. This allows for a more efficient and thorough documentation review in the approval process.Name(s) of the contact person(s) responsible for corrective action: Carrie MorrisPlanned completion date for corrective action plan: completedIf the Federal Cognizant of Oversight Agency for Audit has questions regarding this plan, please call Matthew Daugherty at 803-898-8835.

About Activities Allowed or Unallowed, Allowable Costs / Cost Principles →
2020-018
Activities Allowed or Unallowed / Cost Allowability
SIGNIFICANT DEFICIENCYQUESTIONED COSTSOTHER MATTERS

Funding information on agency approved Personnel Action Form did not agree to selected SCEIS Remuneration Statement and SCEIS Labor Distribution Report data. Additionally, excess overtime costs, resulting from employee work outside the program, were charged to program grants.Questioned Costs: $309Context: Information on agency approved Personnel Action Forms did not agree to selected SCEIS Remuneration Statement and SCEIS Labor Distribution Report data for one of forty tested employees. Additionally, for one of forty tested employees, hours worked outside the program resulted in excess overtime costs of $309 being charged to program grants.Cause: State Personnel Action Forms for program employees are not adequately reviewed on a routine basis. Additionally, SCEIS payroll system assigned all overtime costs to employee?s primary funding stream (non-program hours were entered manually by agency human resource personnel).Effect: The Office is not in compliance with applicable activities/costs requirements. Program expenditures may be overstated.Recommendation: We recommend that the Office implement policies and procedures to ensure that review of documentation related to program employee salaries occurs and is documented on a regular basis, and that hours for work outside the program completed by program employees and all resulting costs are reviewed for impact on program expenditures.Prior Year Single Audit Finding Number: Not applicableViews of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 150.

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Federal Agency: Department of DefenseFederal Program Title: National Guard Military Operations and Maintenance (O&M) ProjectsAssistance Listing No.: 12.401Federal Grant ID Number: W912QG-20-2-1001, W912QG-20-2-1021Pass-Through Entity: Not applicableAward Period: October 1, 2019 through September 30, 2020Type of Finding: Significant deficiency in internal control over compliance, other mattersCriteria: Per 2 CFR ? 200.430 (a) Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-federal entity consistently applied to both federal and non-federal activities; (2) Follows an appointment made in accordance with a non-federal entity's laws and/or rules or written policies and meets the requirements of federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, Standards for Documentation of Personnel Expenses, when applicable.Condition: Funding information on agency approved Personnel Action Form did not agree to selected SCEIS Remuneration Statement and SCEIS Labor Distribution Report data. Additionally, excess overtime costs, resulting from employee work outside the program, were charged to program grants.Questioned Costs: $309Context: Information on agency approved Personnel Action Forms did not agree to selected SCEIS Remuneration Statement and SCEIS Labor Distribution Report data for one of forty tested employees. Additionally, for one of forty tested employees, hours worked outside the program resulted in excess overtime costs of $309 being charged to program grants.Cause: State Personnel Action Forms for program employees are not adequately reviewed on a routine basis. Additionally, SCEIS payroll system assigned all overtime costs to employee?s primary funding stream (non-program hours were entered manually by agency human resource personnel).Effect: The Office is not in compliance with applicable activities/costs requirements. Program expenditures may be overstated.Recommendation: We recommend that the Office implement policies and procedures to ensure that review of documentation related to program employee salaries occurs and is documented on a regular basis, and that hours for work outside the program completed by program employees and all resulting costs are reviewed for impact on program expenditures.Prior Year Single Audit Finding Number: Not applicableViews of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 150.

Corrective Action Plan

The South Carolina Office of the Adjutant General respectfully submits the following Corrective Action Plan for the year ended 6/30/20.The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule.FINDINGS?FEDERAL AWARD PROGRAM AUDITDepartment of Defense2020-018 National Guard Military Operations and Maintenance (O&M) Projects ? Assistance Listing No. 12.401Recommendation: We recommend that the Office implement policies and procedures to ensure that review of documentation related to program employee salaries occurs and is documented on a regular basis, and that hours for work outside the program completed by program employees and all resulting costs are reviewed for impact on program expenditures.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding:The Agency?s State Human Resources Office (SHRO) will conduct of an Agency-wide internal audit of all State employee salaries and expenditures to validate the information in SCEIS against the information contained on the Personnel Action Request (PAR) forms in the employee files. Implementation will begin immediately and will be completed by 1 June 2021. SHRO will also initiate a Standard Operating Procedure (SOP) starting in July 2021 to conduct quarterly checks of twenty-five percent (25%) of Agency employees SCEIS information against their PARS in their files.Beginning immediately, when SHRO receives a request for overtime expenditures for program employees, SHRO will conduct an audit to determine the purpose of the overtime. If SHRO determines the employee?s overtime is outside program expenditures, SHRO will notify the Budget/Finance and Agreements sections to initiate an Journal Entry to move the costs to the correct cost center and to ensure the costs are either not reimbursed by the Federal program or that the Federal program is provided the appropriate credit.Name(s) of the contact person(s) responsible for corrective action: Robert FaulkPlanned completion date for corrective action plan: June 01, 2021If the U.S. Department of Defense has questions regarding this plan, please contact COL Kenneth C. Braddock, USA Retired, Chief of Staff for State Operations, at 803-299-4445 or braddockk@tag.scmd.state.sc.us.

About Activities Allowed or Unallowed, Allowable Costs / Cost Principles →
2020-019
Cash Management
MATERIAL WEAKNESSMODIFIED OPINION

Advanced funds for three transactions were not expended within the required timeframe to minimize the time elapsing between drawdown and disbursement.Questioned Costs: None.Context: For three of forty-three tested transactions, advanced funds drawn exceeded the subsequent forty-five days of expenditures.Cause: SF-270 Report and supporting information were not adequately reviewed to ensure the proper amount of advance funds were requested in order to be expended within forty-five days. Internal controls over cash advances are inadequate.Effect: The Office may not expend advanced funds in a timely manner in accordance with program regulations.Recommendation: We recommend the Office implement and/or strengthen existing policies and procedures to ensure that advanced funds are expended in a timely manner in accordance with NGR 5-1, Chapter 11-5.Prior Year Single Audit Finding Number: Not applicableViews of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 151.

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Federal Agency: Department of DefenseFederal Program Title: National Guard Military Operations and Maintenance (O&M) ProjectsAssistance Listing No.: 12.401Federal Grant ID Number: W912QG-20-2-1001, W912QG-20-2-1002Pass-Through Entity: Not applicableAward Period: October 1, 2019 through September 30, 2020Type of Finding: Material weakness in internal control over compliance, material noncomplianceCriteria: Per National Guard Regulation (NGR) 5-1, Chapter 11-5, the grantee agrees to minimize the time elapsing between the transfer of funds from the U.S. Treasury and their disbursement by the State (no more than forty-five days).Condition: Advanced funds for three transactions were not expended within the required timeframe to minimize the time elapsing between drawdown and disbursement.Questioned Costs: None.Context: For three of forty-three tested transactions, advanced funds drawn exceeded the subsequent forty-five days of expenditures.Cause: SF-270 Report and supporting information were not adequately reviewed to ensure the proper amount of advance funds were requested in order to be expended within forty-five days. Internal controls over cash advances are inadequate.Effect: The Office may not expend advanced funds in a timely manner in accordance with program regulations.Recommendation: We recommend the Office implement and/or strengthen existing policies and procedures to ensure that advanced funds are expended in a timely manner in accordance with NGR 5-1, Chapter 11-5.Prior Year Single Audit Finding Number: Not applicableViews of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 151.

Corrective Action Plan

The South Carolina Office of the Adjutant General respectfully submits the following Corrective Action Plan for the year ended 6/30/20.The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule.U.S. Department of Defense2020-019 National Guard Military Operations and Maintenance (O&M) Projects ? Assistance Listing No. 12.401Recommendation: We recommend the Office implement and/or strengthen existing policies and procedures to ensure that advanced funds are expended in a timely manner in accordance with NGR 5-1, Chapter 11-5.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding:In October 2020 after the end of the 2020 Federal Fiscal Year (FFY), the State Cooperative Agreements Grants Management Section and the Grants Officer Representative (GOR) from the US Property and Fiscal Officer (USPFO) met to review and revise the SOP-Draw of Federal Funds for the Reports used in Support of Processing of Advances (Draws) in response to shortcomings identified during FFY 2020. As the result of this meeting, the following changes have already been put into place:? The State Cooperative Agreements Grants Management Section updated the SOP ?Draw of Federal Funds for the Reports used in Support of Processing of Advances (Draws)?.? Beginning in FFY 2021, the State Cooperative Agreements Grants Management Section developed a report to show the estimated balance of Federal cash on hand as of the beginning of each advance period. The report provides specific details for the computation of each estimated balance of Federal cash on hand for each Appendix for each Advance SF270. Only the dollar amount of the estimated balance of Federal cash on hand at the beginning of the advance period is listed in the ?Comments? block on the actual SF270 form.? The State Cooperative Agreements Grants Management Section created a report with specific details for the computation of each advance Federal funding amount requested for each Appendix for each Advance SF270.Beginning NLT March 31, 2021, the State Cooperative Agreements Grants Management Section will:? Submit the estimated balance of Federal cash on hand report and the specific details for the computation of each advance Federal funding for review by the Chief of Finance for State Operations, the GOR, and the Program Manager or Program Manager?s designee before the Advance SF270 is generated.? Create a report to track the amount of the expenditures which have posted in SCEIS since the beginning date for each Advance SF270 for each Appendix to ensure advance funds are expended in a timely manner in accordance with NGR 5-1, Chapter 11-5. The State Cooperative Agreements Grants Management Section update and submit the expenditure report on a weekly basis to the Chief of Staff for State Operations, the Chief of Finance for State Operations, the Grants Office Representative (GOR), the Federal Budget Analysts, and the Federal Program Managers.The Agency would like to point out the significant impact that COVID had on the Agency and the management of Federal advance funds specifically in the area of Facilities Management. In March 2020, Appendix 1 (ARNG Facilities Programs) requested and drew $2M in Federal advance funds based on the anticipated approvals of planned construction projects by the SC Legislature?s Joint Bond Review Committee (JBRC). Due to the effects of COVID-19, the JBRC postponed its March meeting until April. In April, the JBRC cancelled its meeting with the intent to meet in May. The JBRC finally met in June. Unfortunately, due to the timelines required for the Phase I construction projects, the planned monies could not be executed within the time constraints of the FFY. The Facilities Construction Office attempted to redirect the funds but was not able to obtain the necessary approvals from National Guard Bureau resulting in the State having to return those funds to the Federal Treasury.Name(s) of the contact person(s) responsible for corrective action: Alex CountsPlanned completion date for corrective action plan: March 31, 2021If the U.S. Department of Defense has questions regarding this plan, please contact COL Kenneth C. Braddock, USA Retired, Chief of Staff for State Operations, at 803-299-4445 or braddockk@tag.scmd.state.sc.us.

About Cash Management →
2020-020
Period of Performance
SIGNIFICANT DEFICIENCYOTHER MATTERS

Expenditures were incurred prior to the start of the program?s grant period of performance. Additionally, expenditures that occurred beyond ninety days after the close of the Federal Fiscal Year (FFY) were not included on the detailed listing of unliquidated claims and undisbursed obligations.Questioned Costs: UndeterminedContext: One of eight tested expenditure transactions for costs recorded during the first period of FFY20 program grants were incurred prior to the start of the grant?s period of performance (October 1, 2019). Additionally, three of forty tested expenditure transactions recorded to program grants beyond 90 days after the close of the FFY were not included on the detailed listing of unliquidated claims and undisbursed obligations.Cause: Transactions were not adequately reviewed to ensure expenditures occurred during period of performance, and were included on the detailed listing of unliquidated claims and undisbursed obligations when necessary.Effect: Expenditures may be charged to program grants outside of the period of performance.Recommendation: We recommend that the Office strengthen its internal controls to ensure that awarded funds are expended within the award's period of performance and/or listed on the detailed listing of unliquidated claims and undisbursed obligations when necessary.Prior Year Single Audit Finding Number: Not applicableViews of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 153.

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Federal Agency: Department of DefenseFederal Program Title: National Guard Military Operations and Maintenance (O&M) ProjectsAssistance Listing No.: 12.401Federal Grant ID Number: W912QG-20-2-1001; W912QG-18-2-1001Pass-Through Entity: Not applicableAward Period: October 1, 2019 through September 30, 2020; October 1, 2017 through September 30, 2018Type of Finding: Significant deficiency in internal control over compliance, other mattersCriteria: 2 CFR 200.309 states that a non-federal entity may charge to the federal award only allowable costs incurred during the period of performance (except as described in?200.461 Publication and printing costs) and any costs incurred before the federal awarding agency or pass-through entity made the federal award that were authorized by the federal awarding agency or pass-through entity. NGR 5-1, Chapter 11-10 requires the recipient provide a detailed listing of unliquidated claims and undisbursed obligations that will remain 90 days after the close of the federal fiscal year. Costs incurred in a federal fiscal year which are not disclosed by the recipient within 90 days of the end of the federal fiscal year, except costs associated with unliquidated claims and undisbursed obligations that the recipient has reported, shall not be eligible for reimbursement.Condition: Expenditures were incurred prior to the start of the program?s grant period of performance. Additionally, expenditures that occurred beyond ninety days after the close of the Federal Fiscal Year (FFY) were not included on the detailed listing of unliquidated claims and undisbursed obligations.Questioned Costs: UndeterminedContext: One of eight tested expenditure transactions for costs recorded during the first period of FFY20 program grants were incurred prior to the start of the grant?s period of performance (October 1, 2019). Additionally, three of forty tested expenditure transactions recorded to program grants beyond 90 days after the close of the FFY were not included on the detailed listing of unliquidated claims and undisbursed obligations.Cause: Transactions were not adequately reviewed to ensure expenditures occurred during period of performance, and were included on the detailed listing of unliquidated claims and undisbursed obligations when necessary.Effect: Expenditures may be charged to program grants outside of the period of performance.Recommendation: We recommend that the Office strengthen its internal controls to ensure that awarded funds are expended within the award's period of performance and/or listed on the detailed listing of unliquidated claims and undisbursed obligations when necessary.Prior Year Single Audit Finding Number: Not applicableViews of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 153.

Corrective Action Plan

The South Carolina Office of the Adjutant General respectfully submits the following Corrective Action Plan for the year ended 6/30/20.The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule.U.S. Department of Defense2020-020 National Guard Military Operations and Maintenance (O&M) Projects ? Assistance Listing No. 12.401Recommendation: We recommend that the Office strengthen its internal controls to ensure that awarded funds are expended within the award's period of performance and/or listed on the detailed listing of unliquidated claims and undisbursed obligations when necessary.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding:Federal Program Managers or their designees submit a cash requirements statements to the State Cooperative Agreements Grants Management Section by the 10th working day of each month for their plan to expend the amount of their federal funding during the period of performance. In the future, the State Cooperative Agreements Grants Management Section will provide additional information to the Federal Program Managers and Federal Program Managers? designees to strengthen and improve the accuracy and details of the cash requirements statements.The State Cooperative Agreements Grants Management Section will create a detailed listing of unliquidated claims and undisbursed obligations and submit the report monthly to the Federal Program Managers and Federal Program Managers? designees. The detailed listing will be reviewed by the Chief of Finance for State Operations and the State Director of Procurement before submission to the Federal Program Managers and Federal Program Managers? designees.State Operations will implement a procedure for the review of posting of all transactions in SCEIS to ensure the transactions are not charged to program grants outside of the period of performance.Name(s) of the contact person(s) responsible for corrective action: Alex CountsPlanned completion date for corrective action plan: March 31, 2021If the U.S. Department of Defense has questions regarding this plan, please contact COL Kenneth C. Braddock, USA Retired, Chief of Staff for State Operations, at 803-299-4445 or braddockk@tag.scmd.state.sc.us.

About Period of Performance →
2020-021
Reporting
SIGNIFICANT DEFICIENCYOTHER MATTERS

Total program expenditures reported on final reports did not agree to SCEIS accounting records.Questioned Costs: None.Context: For all three final reports tested, the reported total expenditure amount was not supported by SCEIS data. The total variance between the reports and SCEIS data was $13,555.Cause: SF-270 Report, Grant Close-Out Report, and supporting information were not adequately reviewed to ensure that total reported expenditures were complete, accurate, and agreed to accounting records.Effect: Accounting records do not accurately reflect program expenditures; program expenditures for impacted grants may be misstated.Recommendation: We recommend the Office strengthen its internal controls to ensure that the total reported expenditures for program grants agree to underlying accounting data (SCEIS).Prior Year Single Audit Finding Number: Not ApplicableViews of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 154.

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Federal Agency: Department of DefenseFederal Program Title: National Guard Military Operations and Maintenance (O&M) ProjectsAssistance Listing No.: 12.401Federal Grant ID Number: W912QG-18-2-1002, W912QG-18-2-1021, W912QG-19-2-1007Pass-Through Entity: Not applicableAward Period: October 1, 2017 through September 30, 2018 and October 1, 2018 through September 30, 2019Type of Finding: Significant deficiency in internal control over compliance, other mattersCriteria: Per 2 CFR ? 200.303 Internal controls, 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 and the "Internal Control Integrated Framework", issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).Condition: Total program expenditures reported on final reports did not agree to SCEIS accounting records.Questioned Costs: None.Context: For all three final reports tested, the reported total expenditure amount was not supported by SCEIS data. The total variance between the reports and SCEIS data was $13,555.Cause: SF-270 Report, Grant Close-Out Report, and supporting information were not adequately reviewed to ensure that total reported expenditures were complete, accurate, and agreed to accounting records.Effect: Accounting records do not accurately reflect program expenditures; program expenditures for impacted grants may be misstated.Recommendation: We recommend the Office strengthen its internal controls to ensure that the total reported expenditures for program grants agree to underlying accounting data (SCEIS).Prior Year Single Audit Finding Number: Not ApplicableViews of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 154.

Corrective Action Plan

The South Carolina Office of the Adjutant General respectfully submits the following Corrective Action Plan for the year ended 6/30/20.The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule.U.S. Department of Defense2020-021 National Guard Military Operations and Maintenance (O&M) Projects ? Assistance Listing No. 12.401Recommendation: We recommend the Office strengthen its internal controls to ensure that the total reported expenditures for program grants agree to underlying accounting data (SCEIS).Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding:The Chief of Finance for State Operations has revised the procedures and the deadlines for tasks on the monthly checklists for State Operations. One task for the State Cooperative Agreements Grants Management Section is to ensure all SCEIS postings for the month are correct for the O&M programs. If a posting is identified as incorrect, the State Cooperative Agreements Grants Management Section will create a journal entry to correct the posting in SCEIS. The State Cooperative Agreements Grants Management Section will complete all necessary corrective journal entries on a monthly basis. Once the State Cooperative Agreements Grants Management Section creates a final SF270 for each program grant, all of the necessary corrective journal entries should have been completed.If additional corrective journal entries are needed, the State Cooperative Agreements Grants Management Section will complete the necessary journal entries and post in SCEIS before the final SF270 is completed and submitted for approval by the Chief of Finance for State Operations and the Federal Program Manager. The State Cooperative Agreements Grants Management Section will generate SCEIS reports and submit the reports with each final SF270 to ensure the total reported expenditures for program grants posted in SCEIS agree with the total reported expenditures for the program grants on each final SF270.Name(s) of the contact person(s) responsible for corrective action: Alex CountsPlanned completion date for corrective action plan: March 31, 2021If the U.S. Department of Defense has questions regarding this plan, please contact COL Kenneth C. Braddock, USA Retired, Chief of Staff for State Operations, at 803-299-4445 or braddockk@tag.scmd.state.sc.us.

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2020-022
Activities Allowed or Unallowed / Cost Allowability
MATERIAL WEAKNESSREPEAT OF 2019-018OTHER MATTERS

The Department did not have adequate controls in place to ensure timesheets were properly completed and reviewed by a supervisor, maintained by the agency and that the time and effort documentation agreed to salary allocations in the accounting system.Questioned Costs: UnknownContext: For 18 out of 60 paychecks tested, there were multiple instances where the time and effort documentation was either missing, did not contain all the required signatures, or there were discrepancies between the grant percentages from the time and effort documentation and the funding percentages paid in the accounting system.This is a repeat finding from the FY19 Single Audit. The Department stated on its Summary Schedule of Prior Year Audit Findings that this issue was ?Fully Corrected with Previously Reported Corrective Action Implemented?. Due to this issue repeating for FY20, this issue has not been fully corrected.Cause: Department controls failed to prevent the identified issues. Additionally, management prepared funding allocation spreadsheets to override the allocations based on the employee time and effort records.Effect: The Department is not in compliance with applicable allowable activities/costs requirements.Recommendation: We recommend the Department implement policies and procedures to ensure time and effort reports are properly completed, reviewed, and maintained.We also recommend the Department ensure the accounting system accurately reports actual time worked.Prior Year Single Audit Finding Number: 2019-018Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 155.

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Federal Agency: Department of Health and Human ServicesFederal Program Title: Prevention and Treatment of Substance AbuseAssistance Listing No.: 93.959Federal Grant ID Number: 3B08TI010048-19S2, 6B08TI083037-01M002Pass-Through Entity: Not applicableAward Period: October 1, 2018 through September 30, 2021Type of Finding: Material weakness in internal control over compliance, other mattersCriteria: Per 2 CFR ? 200.430 (a) Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-federal entity consistently applied to both federal and non-federal activities; (2) Follows an appointment made in accordance with a non-federal entity?s laws and/or rules or written policies and meets the requirements of federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, Standards for Documentation of Personnel Expenses, when applicable.Condition: The Department did not have adequate controls in place to ensure timesheets were properly completed and reviewed by a supervisor, maintained by the agency and that the time and effort documentation agreed to salary allocations in the accounting system.Questioned Costs: UnknownContext: For 18 out of 60 paychecks tested, there were multiple instances where the time and effort documentation was either missing, did not contain all the required signatures, or there were discrepancies between the grant percentages from the time and effort documentation and the funding percentages paid in the accounting system.This is a repeat finding from the FY19 Single Audit. The Department stated on its Summary Schedule of Prior Year Audit Findings that this issue was ?Fully Corrected with Previously Reported Corrective Action Implemented?. Due to this issue repeating for FY20, this issue has not been fully corrected.Cause: Department controls failed to prevent the identified issues. Additionally, management prepared funding allocation spreadsheets to override the allocations based on the employee time and effort records.Effect: The Department is not in compliance with applicable allowable activities/costs requirements.Recommendation: We recommend the Department implement policies and procedures to ensure time and effort reports are properly completed, reviewed, and maintained.We also recommend the Department ensure the accounting system accurately reports actual time worked.Prior Year Single Audit Finding Number: 2019-018Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 155.

Corrective Action Plan

SOUTH CAROLINA DEPARTMENT OF ALCOHOL AND OTHER DRUG ABUSE SERVICES CORRECTIVE ACTION PLAN ? YEAR ENDED JUNE 30, 2020U.S. Department of Health and Human ServicesThe South Carolina Department of Alcohol and Other Drug Abuse Services (DAODAS) respectfully submits the following corrective action plan for the year ended 6/30/20.The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered in accordance with the numbers assigned in the schedule.FINDINGS ? FEDERAL AWARD PROGRAM AUDITU.S. Department of Health and Human Services2020-022 Prevention and Treatment of Substance Abuse ? Assistance Listing No. 93.959Recommendation: We recommend the Department implement policies and procedures to ensure time and effort reports are properly completed, reviewed, and maintained. We also recommend the Department ensure the accounting system accurately reports actual time worked.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding: DAODAS plans to implement a more comprehensive control of Time & Effort allocations to include the following: The Human Resources (HR) Manager will send a monthly reminder to all staff with the current funding sources. Time & Effort sheets must be sent to all managers by the 5th working day of the month. Managers must review time sheets for correct allocations and ensure both signatures are applied. Once approved and signed, a copy must be stored in a designated location and sent to the HR Manager.Name(s) of the contact person(s) responsible for corrective action: Sharon Peterson and Angela OutingPlanned completion date for corrective action plan: Effective April 1, 2021If the U.S. Department of Health and Human Services has questions regarding this plan, please call Sharon Peterson at 803-896-1145.

Prior Finding References

2019-018

About Activities Allowed or Unallowed, Allowable Costs / Cost Principles →
2020-023
Subrecipient Monitoring
SIGNIFICANT DEFICIENCYREPEAT OF 2019-017OTHER MATTERS

The Department communicated grant and program information to each subrecipient annually through a standardized contracting agreement; however, not all of the required information was included in the agreement.Questioned Costs: NoneContext: For eight of eight subrecipients tested for the Prevention and Treatment of Substance Abuse program and for six of six subrecipients tested for the Strategic Targeted Response Opioid Crisis Grant program, the subaward documents did not include all of the information required by 2 CFR 200.331(a).This is a repeat finding from the FY19 Single Audit. Due to a timing issue on implementation of corrective action, we reviewed subawards made after January 2020 and still noted missing elements on the agreements. The Department stated on its Summary Schedule of Prior Year Audit Findings that this issue was ?Fully Corrected with Previously Reported Corrective Action Implemented?. Due to this issue repeating for FY20, this issue has not been fully corrected.Cause: The Department?s internal controls failed to ensure adequate communication to the subrecipients through the annual subaward process as required by federal regulations.Effect: The Department is not in compliance with federal subrecipient monitoring requirements.Recommendation: We recommend the Department update its subrecipient agreements to incorporate all required information to ensure adequate communication to subrecipients and to ensure compliance with federal requirements.Prior Year Single Audit Finding Number: 2019-017 (Assistance Listing No. 93.959 only)Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 155.

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Federal Agency: Department of Health and Human ServicesFederal Program Title: Strategic Targeted Response Opioid Crisis Grant; Prevention and Treatment of Substance AbuseAssistance Listing No.: 93.788; 93.959Federal Grant ID Number: VariousPass-Through Entity: Not applicableAward Period: October 1, 2018 through September 30, 2021Type of Finding: Significant deficiency in internal control over compliance, other mattersCriteria: Per 2 CFR ?331 All pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes all of the information required by 2 CFR 331(a)(1)(i-xiii) at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the federal award and subaward.Condition: The Department communicated grant and program information to each subrecipient annually through a standardized contracting agreement; however, not all of the required information was included in the agreement.Questioned Costs: NoneContext: For eight of eight subrecipients tested for the Prevention and Treatment of Substance Abuse program and for six of six subrecipients tested for the Strategic Targeted Response Opioid Crisis Grant program, the subaward documents did not include all of the information required by 2 CFR 200.331(a).This is a repeat finding from the FY19 Single Audit. Due to a timing issue on implementation of corrective action, we reviewed subawards made after January 2020 and still noted missing elements on the agreements. The Department stated on its Summary Schedule of Prior Year Audit Findings that this issue was ?Fully Corrected with Previously Reported Corrective Action Implemented?. Due to this issue repeating for FY20, this issue has not been fully corrected.Cause: The Department?s internal controls failed to ensure adequate communication to the subrecipients through the annual subaward process as required by federal regulations.Effect: The Department is not in compliance with federal subrecipient monitoring requirements.Recommendation: We recommend the Department update its subrecipient agreements to incorporate all required information to ensure adequate communication to subrecipients and to ensure compliance with federal requirements.Prior Year Single Audit Finding Number: 2019-017 (Assistance Listing No. 93.959 only)Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 155.

Corrective Action Plan

SOUTH CAROLINA DEPARTMENT OF ALCOHOL AND OTHER DRUG ABUSE SERVICES CORRECTIVE ACTION PLAN ? YEAR ENDED JUNE 30, 2020U.S. Department of Health and Human ServicesThe South Carolina Department of Alcohol and Other Drug Abuse Services (DAODAS) respectfully submits the following corrective action plan for the year ended 6/30/20.The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered in accordance with the numbers assigned in the schedule.2020-023 Prevention and Treatment of Substance Abuse, Strategic Targeted Response Opioid Crisis Grant ? Assistance Listing Nos. 93.959, 93.788Recommendation: We recommend the Department update its subrecipient agreements to incorporate all required information to ensure adequate communication to subrecipients and to ensure compliance with Federal requirements.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding: DAODAS will ensure all new sub-awards granted on or after April 1, 2021, include all applicable requirements as detailed in 2 CFR 200.331(a)(1).Name(s) of the contact person(s) responsible for corrective action: Sharon Peterson, Hannah Bonsu, Michelle Nienhius, and David CollierPlanned completion date for corrective action plan: April 1, 2021If the U.S. Department of Health and Human Services has questions regarding this plan, please call Sharon Peterson at 803-896-1145.

Prior Finding References

2019-017

About Subrecipient Monitoring →
2020-024
Reporting
SIGNIFICANT DEFICIENCYOTHER MATTERS

Financial reports were not reviewed by an employee other than the report preparer prior to submission.Questioned Costs: NoneContext: We tested the sole SF-425 reports submitted during fiscal year 2020 for both grant programs and noted that the reports were not reviewed by an individual separate from the preparer prior to submission.Cause: Department personnel stated there was a new reporting process whereby the reports were completed and submitted online. They did not update their internal control process to ensure that a supervisory review of the report was performed.Effect: Without supervisory review, there is an increased possibility of inaccurate reporting.Recommendation: We recommend the Department strengthen controls to ensure that reports are properly reviewed by supervisory personnel before submission.Prior Year Single Audit Finding Number: Not applicableViews of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 156.

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Federal Agency: Department of Health and Human ServicesFederal Program Title: Strategic Targeted Response Opioid Crisis Grant; Prevention and Treatment of Substance AbuseAssistance Listing No.: 93.788; 93.959Federal Grant ID Number: 3B08TI010048-18S1, 6H79TI081720-01M002 and 3H79TI081720-01S1Pass-Through Entity: Not applicableAward Period: October 1, 2017 through September 30, 2021Type of Finding: Significant deficiency in internal control over compliance, other mattersCriteria: Per 2 CFR ? 200.303 Internal controls, 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 and the ``Internal Control Integrated Framework??, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).Condition: Financial reports were not reviewed by an employee other than the report preparer prior to submission.Questioned Costs: NoneContext: We tested the sole SF-425 reports submitted during fiscal year 2020 for both grant programs and noted that the reports were not reviewed by an individual separate from the preparer prior to submission.Cause: Department personnel stated there was a new reporting process whereby the reports were completed and submitted online. They did not update their internal control process to ensure that a supervisory review of the report was performed.Effect: Without supervisory review, there is an increased possibility of inaccurate reporting.Recommendation: We recommend the Department strengthen controls to ensure that reports are properly reviewed by supervisory personnel before submission.Prior Year Single Audit Finding Number: Not applicableViews of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 156.

Corrective Action Plan

SOUTH CAROLINA DEPARTMENT OF ALCOHOL AND OTHER DRUG ABUSE SERVICES CORRECTIVE ACTION PLAN ? YEAR ENDED JUNE 30, 2020U.S. Department of Health and Human ServicesThe South Carolina Department of Alcohol and Other Drug Abuse Services (DAODAS) respectfully submits the following corrective action plan for the year ended 6/30/20.The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered in accordance with the numbers assigned in the schedule.2020-024 Prevention and Treatment of Substance Abuse, Strategic Targeted Response Opioid Crisis Grant ? Assistance Listing Nos. 93.959, 93.788Recommendation: We recommend the Department strengthen controls to ensure that reports are properly reviewed by supervisory personnel before submission.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding: The Manager of Finance and Operations will review and approve quarterly or annual federal reports prior to report submission. This approval may be in the form of an e-mail to proceed or actual signing of a paper copy.Name(s) of the contact person(s) responsible for corrective action: Sharon Peterson and Tina NicholsPlanned completion date for corrective action plan: Effective April 1, 2021If the U.S. Department of Health and Human Services has questions regarding this plan, please call Sharon Peterson at 803-896-1145.

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2020-025
Reporting
SIGNIFICANT DEFICIENCYOTHER MATTERS

Certain information reported on the Performance Progress Report (PPR) did not agree to supporting documentation provided by the Department.Questioned Costs: NoneContext: We tested the PPR submission that was due on December 31, 2019 to ensure the reasonableness and accuracy of the report and were unable to verify the information reported in sections 1 through 4.Cause: Department personnel did not retain documentation to support information reported on the PPR.Effect: The Department may report incorrect information to the Substance Abuse and Mental Health Services Administration (SAMHSA), an operating division of the Department of Health and Human Services (HHS).Recommendation: We recommend the Department strengthen controls to ensure information reported to the SAMHSA is accurate and properly supported by documentation.Prior Year Single Audit Finding Number: Not applicableViews of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 156.

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Federal Agency: Department of Health and Human ServicesFederal Program Title: Opioid STRAssistance Listing No.: 93.788Federal Grant ID Number: 6H79TI081720-01M002 and 3H79TI081720-01S1Pass-Through Entity: Not applicableAward Period: October 1, 2018 through September 30, 2021Type of Finding: Significant deficiency in internal control over compliance, other mattersCriteria: Per 2 CFR ? 200.333, financial records, supporting documents, statistical records, and all other non-federal entity records pertinent to a federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the federal awarding agency or pass-through entity in the case of a subrecipient.Condition: Certain information reported on the Performance Progress Report (PPR) did not agree to supporting documentation provided by the Department.Questioned Costs: NoneContext: We tested the PPR submission that was due on December 31, 2019 to ensure the reasonableness and accuracy of the report and were unable to verify the information reported in sections 1 through 4.Cause: Department personnel did not retain documentation to support information reported on the PPR.Effect: The Department may report incorrect information to the Substance Abuse and Mental Health Services Administration (SAMHSA), an operating division of the Department of Health and Human Services (HHS).Recommendation: We recommend the Department strengthen controls to ensure information reported to the SAMHSA is accurate and properly supported by documentation.Prior Year Single Audit Finding Number: Not applicableViews of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 156.

Corrective Action Plan

SOUTH CAROLINA DEPARTMENT OF ALCOHOL AND OTHER DRUG ABUSE SERVICES CORRECTIVE ACTION PLAN ? YEAR ENDED JUNE 30, 2020U.S. Department of Health and Human ServicesThe South Carolina Department of Alcohol and Other Drug Abuse Services (DAODAS) respectfully submits the following corrective action plan for the year ended 6/30/20.The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered in accordance with the numbers assigned in the schedule.2020-025 Strategic Targeted Response Opioid Crisis Grant ? Assistance Listing No. 93.788Recommendation: We recommend the Department strengthen controls to ensure information reported to the SAMHSA is accurate and properly supported by documentation.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding: Data storage and verification plan:? External partners will be required to report process for verification of the data submitted.? Internal partners will place all data/reports in folders in Microsoft Teams or Box Enterprise for storage and review by managers.? Data and program protocols will be submitted for each project on a standardized form, including back-up staff assignment to each program for data verification and to serve as secondary program contacts.Name(s) of the contact person(s) responsible for corrective action: Roberta Braneck, Lisa Davis, and Sazid Khan, Ph.D.Planned completion date for corrective action plan: Initial plan to be developed and installed by April 30, 2021, with continuous and ongoing monitoringIf the U.S. Department of Health and Human Services has questions regarding this plan, please call Sharon Peterson at 803-896-1145.

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2020-026
Cash Management
SIGNIFICANT DEFICIENCYREPEAT OF 2019-011OTHER MATTERS

Cash management compliance could not be confirmed for some federal cash draws.Questioned Costs: NoneContext: Supporting documentation was not adequate to determine that federal reimbursement was for the correct amount.Cause: The Department was unable to fully implement the corrective action associated with the finding from the prior year.Effect: The Department did not effectively document its cash management process to demonstrate compliance.Recommendation: We recommend that the Department continue implementation of the associated corrective action plan.Prior Year Single Audit Report Finding Number: 2019-011Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 157.

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Federal Agency: Department of Health and Human ServicesFederal Program Title: Child Support Enforcement, Social Services Block Grant, Adoption AssistanceAssistance Listing: 93.563, 93.667, 93.659Federal Grant ID Number: 1901SCCSES, 2001SCCSES, 1901SCSOSR, 2001SCSOSR, 1901SCADPT, 2001SCADPTPass-Through Entity: Not applicableAward Period: October 1, 2018 through September 30, 2020Type of Finding: Significant deficiency in internal control over compliance, other mattersCriteria: Per 31 CFR ? 205.12(b)(5), reimbursable funding means that a federal program agency transfers federal funds to a State after that State has already paid out the funds for federal assistance program purposes.Condition: Cash management compliance could not be confirmed for some federal cash draws.Questioned Costs: NoneContext: Supporting documentation was not adequate to determine that federal reimbursement was for the correct amount.Cause: The Department was unable to fully implement the corrective action associated with the finding from the prior year.Effect: The Department did not effectively document its cash management process to demonstrate compliance.Recommendation: We recommend that the Department continue implementation of the associated corrective action plan.Prior Year Single Audit Report Finding Number: 2019-011Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 157.

Corrective Action Plan

U.S. Department of Health and Human ServicesThe South Carolina Department of Social Services respectfully submits the following corrective action plan for the year ended June 30, 2020.The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule.FINDINGS?FEDERAL AWARD PROGRAM AUDIT2020-026 Child Support Enforcement, Social Services Block Grant, Adoption Assistance ? Assistance Listing No. 93.563, 93.667, 93.659Recommendation: We recommend that the Department continue implementation of the associated corrective action plan.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding: The Department put procedures in place to ensure proper supporting documentation from the accounting system is retained to support accurate reimbursement for all Federal cash draws. Staff turnover, and the Department?s required enactment of work-from-home policies to combat the spread of the COVID-19 virus, created unanticipated barriers to ongoing compliance with its revised procedures. Required supporting documentation is now described in detail in the cash management procedures for drawdown of federal funds. Draws will be performed on a periodic basis determined by individual grant, but at least monthly if needed. Staff will review all grants periodically to determine whether qualified expenditures have posted to grants and require draws to cover them. A master draw log has been created and will be maintained by the Grants Accounting and Reporting Manager to document the completion of these reviews and the status of draw activity for each grant.Name(s) of the contact person(s) responsible for corrective action: Reshma Parikh, Grants Accounting and Reporting ManagerPlanned completion date for corrective action plan: April 30, 2021.If the Federal Cognizant Agency of Oversight or Audit has questions regarding this plan, please call David O?Kelly at 803-898-3987.

Prior Finding References

2019-011

About Cash Management →
2020-027
Cost Allowability / Eligibility
MATERIAL WEAKNESSMODIFIED OPINIONREPEAT OF 2019-015QUESTIONED COSTS

Eligibility related discrepancies were encountered for some payments and some payments exceeded the allowable amount.Questioned Costs: $4,756Context: Sixty payments were selected for testing eligibility compliance. Two of the subsidy payments tested exceeded the foster care maintenance payment rate the child would have received in a foster family home. For two payments tested, the adoption subsidy agreement was signed after the date the adoption was finalized. Additionally, seven of the subsidy payments tested were for children no longer eligible for payment. One nonrecurring expense payment tested was on behalf of a child that did not meet the special needs criteria. Finally, the Department was unable to provide adequate documentation to support eligibility for one other subsidy payment.Cause: Department controls failed to ensure eligibility was properly determined, benefits were terminated timely, and records were retained for the required amount of time. The global pandemic also significantly limited the Department?s ability to implement corrective action.Effect: The Department did not comply with and/or could not demonstrate compliance with eligibility and allowable costs/cost principles requirements.Recommendation: We recommend that the Department continue to implement corrective action for eligibility file controls.Prior Year Single Audit Report Finding Number: 2019-015Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 158.

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Federal Agency: Department of Health and Human ServicesFederal Program Title: Adoption AssistanceAssistance Listing: 93.659Federal Grant ID Number: 1901SADPT, 2001SCADPTPass-Through Entity: Not applicableAward Period: October 1, 2018 through September 30, 2020Type of Finding: Material weakness in internal control over compliance, material noncomplianceCriteria: 45 CFR ? 75.361 outlines record retention requirements of the non-federal entity pertinent to the federal award.45 CFR ? 1356.40(b)(1) requires the adoption assistance agreement be signed and in effect at the time of or prior to the final decree of adoption.42 U.S.C. ? 673(a)(3) states that adoption assistance payments cannot exceed the foster care maintenance payment the child would have received in a foster family home for that period.42 U.S.C. ? 673(c) explains the children with special needs criteria.42 U.S.C. ? 675(8)(b) expands eligibility requirements for children over the age of eighteen.Condition: Eligibility related discrepancies were encountered for some payments and some payments exceeded the allowable amount.Questioned Costs: $4,756Context: Sixty payments were selected for testing eligibility compliance. Two of the subsidy payments tested exceeded the foster care maintenance payment rate the child would have received in a foster family home. For two payments tested, the adoption subsidy agreement was signed after the date the adoption was finalized. Additionally, seven of the subsidy payments tested were for children no longer eligible for payment. One nonrecurring expense payment tested was on behalf of a child that did not meet the special needs criteria. Finally, the Department was unable to provide adequate documentation to support eligibility for one other subsidy payment.Cause: Department controls failed to ensure eligibility was properly determined, benefits were terminated timely, and records were retained for the required amount of time. The global pandemic also significantly limited the Department?s ability to implement corrective action.Effect: The Department did not comply with and/or could not demonstrate compliance with eligibility and allowable costs/cost principles requirements.Recommendation: We recommend that the Department continue to implement corrective action for eligibility file controls.Prior Year Single Audit Report Finding Number: 2019-015Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 158.

Corrective Action Plan

U.S. Department of Health and Human ServicesThe South Carolina Department of Social Services respectfully submits the following corrective action plan for the year ended June 30, 2020.The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule.2020-027 Adoption Assistance ? Assistance Listing No. 93.659Recommendation: We recommend that the Department continue to implement corrective action for eligibility file controls.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding: All adoption subsidy agreements are now sent to the State Office Adoptions Manager for signature. When the agreements are entered into the Child Welfare Information System (CAPSS), staff verify that the agreement includes the proper signature. Some of the payments tested and identified as exceptions this year were made pursuant to subsidy agreements executed in prior years. Prior to the Department?s required enactment of work-from-home policies to combat the spread of the COVID-19 virus, the Department had begun reviewing older files to ensure the subsidy agreements included the proper signatures. The Department also had begun implementation of an eligibility review process whereby staff would pull sample cases quarterly for internal review to confirm compliance with various requirements and ensure all subsidy payments were adequately supported. The implementation of these processes was interrupted when staff began working from home because staff are not permitted to remove paper eligibility case files from Department offices, thus could no longer access case files to complete reviews.With Department offices now re-opened, operation and implementation of these controls will resume. In signing the subsidy agreements and conducting the above compliance reviews, the State Office Adoptions Manager will verify the subsidy payment amounts are correct and agree with the subsidy agreements. She will also ensure all subsidy agreements have the proper signatures and that other compliance and documentation requirements are met in accordance with federal regulations. If discrepancies are found, the manager will contact the region for clarification or corrective action.In addition, State Adoptions staff are now working with the Department?s Information Technology team to add system controls and reports to ensure timely termination of payments and maintenance of documentary support for payments to children who are 18 years and older. The Department?s CAPSS system now discontinues subsidy payments at the end of the month in which a child reaches age 21. In addition, monthly reports are under development that will facilitate advance requests for required updates to educational and medical information to assure timely receipt of support for continuing payments to children who are 18 and over. Each month staff will track the documentation requested to ensure the required updates have been received, and they will terminate payments that lack the required support.Name(s) of the contact person(s) responsible for corrective action Plan: Rebecca Carrier, State Office Adoptions ManagerPlanned completion date for corrective action plan: August 31, 2021If the Federal Cognizant Agency of Oversight or Audit has questions regarding this plan, please call David O?Kelly at 803-898-3987.

Prior Finding References

2019-015

About Allowable Costs / Cost Principles, Eligibility →
2020-028
Reporting
SIGNIFICANT DEFICIENCYREPEAT OF 2019-012OTHER MATTERS

Discrepancies existed between federal financial reports and the Department?s supporting records.Questioned Costs: NoneContext: For both CB-496 reports selected for testing, discrepancies were noted between the supporting documentation and the average monthly number of children assisted reported in Part 1, Section D of the report. Errors were also identified in the Adoption Savings Calculation used in determining the amounts reported In Part 4 of the report.Cause: The Department had not completely implemented the corrective action associated with the finding from the prior year.Effect: The accuracy of the CB-496 reports could not be fully validated.Recommendation: We recommend that the Department continue to strengthen its internal controls to ensure that federal reports are free from error and clearly supported prior to submission.Prior Year Single Audit Report Finding Number: 2019-012Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 159.

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Federal Agency: Department of Health and Human ServicesFederal Program Title: Adoption AssistanceAssistance Listing: 93.659Federal Grant ID Number: 1901SCADPT, 2001SCADPTPass-Through Entity: Not applicableAward Period: October 1, 2018 through September 30, 2020Type of Finding: Significant deficiency in internal control over compliance, other mattersCriteria: 45 CFR ? 75.303 requires effective internal controls be established and maintained in order to provide reasonable assurance that the federal award is being managed in compliance with federal statutes, regulations, and the terms and conditions of the federal award.Condition: Discrepancies existed between federal financial reports and the Department?s supporting records.Questioned Costs: NoneContext: For both CB-496 reports selected for testing, discrepancies were noted between the supporting documentation and the average monthly number of children assisted reported in Part 1, Section D of the report. Errors were also identified in the Adoption Savings Calculation used in determining the amounts reported In Part 4 of the report.Cause: The Department had not completely implemented the corrective action associated with the finding from the prior year.Effect: The accuracy of the CB-496 reports could not be fully validated.Recommendation: We recommend that the Department continue to strengthen its internal controls to ensure that federal reports are free from error and clearly supported prior to submission.Prior Year Single Audit Report Finding Number: 2019-012Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 159.

Corrective Action Plan

U.S. Department of Health and Human ServicesThe South Carolina Department of Social Services respectfully submits the following corrective action plan for the year ended June 30, 2020.The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule.2020-028 Adoption Assistance ? Assistance Listing No. 93.659Recommendation: We recommend that the Department continue to strengthen its internal controls to ensure that Federal reports are free from error and clearly supported prior to submission.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding: Staff turnover, and the Department?s required enactment of work-from-home policies to combat the spread of the COVID-19 virus, made complete implementation of improvements more difficult. The Department?s Grants Accounting and Reporting team is implementing additional training on the proper completion of the Federal Financial Reports, and procedures for tie-in and retention of relevant supporting documentation. Reports are now reviewed by a manager or the Controller prior to submission.Name(s) of the contact person(s) responsible for corrective action: Reshma Parikh, Grants Accounting and Reporting ManagerPlanned completion date for corrective action plan: April 30, 2021If the Federal Cognizant Agency of Oversight or Audit has questions regarding this plan, please call David O?Kelly at 803-898-3987.

Prior Finding References

2019-012

About Reporting →
2020-029
Eligibility
SIGNIFICANT DEFICIENCYQUESTIONED COSTSOTHER MATTERS

Discrepancies related to eligibility determinations were identified.Questioned Costs: $2,954Context: Sixty payments were selected for testing eligibility compliance. Some eligibility documentation was incomplete or unsupported within the eligibility files of four of the test items, although eligibility could be confirmed through other support in three of those files. For two of the payments tested, the child was placed in a child-care institution that did not fully meet the criminal background check requirements. For two of the payments tested, clothing allowances were paid when the child was no longer eligible.Cause: The issues encountered were primarily due to disposal of the original eligibility files for cases that had been closed. Staffing turnover and Department oversight also contributed.Effect: The Department did not comply with federal eligibility, internal control, and record retention requirements.Recommendation: We recommend that the Department implement policies and procedures to ensure eligibility documentation is maintained and supports all federal requirements.Prior Year Single Audit Report Finding Number: Not applicableViews of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 159.

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Federal Agency: Department of Health and Human ServicesFederal Program Title: Foster Care?Title IV-EAssistance Listing: 93.658Federal Grant ID Number: 1901SCFOST, 2001SCFOSTPass-Through Entity: Not applicableAward Period: October 1, 2018 through September 30, 2020Type of Finding: Significant deficiency in internal control over compliance, other mattersCriteria: 45 CFR ? 75.361 states record retention requirements of the non-federal entity pertinent to the federal award.42 USC ? 671(a)(20) outlines requirements for criminal background checks of foster care providers, including those for child-care institutions.42 U.S.C. ? 672 describes the general eligibility requirements for foster care maintenance payments.Condition: Discrepancies related to eligibility determinations were identified.Questioned Costs: $2,954Context: Sixty payments were selected for testing eligibility compliance. Some eligibility documentation was incomplete or unsupported within the eligibility files of four of the test items, although eligibility could be confirmed through other support in three of those files. For two of the payments tested, the child was placed in a child-care institution that did not fully meet the criminal background check requirements. For two of the payments tested, clothing allowances were paid when the child was no longer eligible.Cause: The issues encountered were primarily due to disposal of the original eligibility files for cases that had been closed. Staffing turnover and Department oversight also contributed.Effect: The Department did not comply with federal eligibility, internal control, and record retention requirements.Recommendation: We recommend that the Department implement policies and procedures to ensure eligibility documentation is maintained and supports all federal requirements.Prior Year Single Audit Report Finding Number: Not applicableViews of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 159.

Corrective Action Plan

U.S. Department of Health and Human ServicesThe South Carolina Department of Social Services respectfully submits the following corrective action plan for the year ended June 30, 2020.The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule.2020-029 Foster Care-Title IV-E ? Assistance Listing No. 93.658Recommendation: We recommend that the Department implement policies and procedures to ensure eligibility documentation is maintained and supports all Federal requirements.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding: All case files are now being retained in either paper or electronic form in accordance with federal and state record retention requirements.The Department is reviewing its policies and procedures and will make necessary changes to better assure compliance by providers with criminal background check requirements.The clothing allowances identified during the audit were disbursed by the Department?s county offices during the audit period, under legacy procedures. In October 2020, the Department completed its conversion to centralized state office payment of these allowances through its CAPSS system and the state?s accounting system (SCEIS). This new process permits charges to the IV-E program only for the allowances it pays for IV-E eligible children.Name(s) of the contact person(s) responsible for corrective action: Laura Claspill, Director of Program Development; Jacqueline Lowe, Director of CPA & Group Home LicensingPlanned completion date for corrective action plan: June 30, 2021If the Federal Cognizant Agency of Oversight or Audit has questions regarding this plan, please call David O?Kelly at 803-898-3987.

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2020-030
Special Tests & Provisions
SIGNIFICANT DEFICIENCYOTHER MATTERS

We were unable to confirm the inclusion of written requirements for the periodic review of maintenance payment rates in the Department?s approved plan.Questioned Costs: NoneContext: Foster care maintenance payment rates are periodically reviewed for appropriateness by the Department. However, we were unable to identify a written policy or procedure associated with an approved State plan that describes the periodic rate review process or establishes a rate review schedule.Cause: State plan documentation and related policies did not contain a description of the periodic review process and timing that the Department follows.Effect: It could not be determined if the periodic reviews, which were conducted, were carried out in accordance with management?s intent, as expressed through approved written policies.Recommendation: We recommend the Department review and update their State Plan documentation and associated policies and procedures to ensure all information referenced in their approved State Plan supports compliance with the applicable federal requirements.Prior Year Single Audit Report Finding Number: Not applicableViews of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 160.

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Federal Agency: Department of Health and Human ServicesFederal Program Title: Foster Care?Title IV-EAssistance Listing: 93.658Federal Grant ID Number: 1901SCFOST, 2001SCFOSTPass-Through Entity: Not applicableAward Period: October 1, 2018 through September 30, 2020Type of Finding: Significant deficiency in internal control over compliance, other mattersCriteria: 42 U.S.C. ? 671(a)(11) explains that in order for a State to be eligible for payments, it must have a plan approved by the Secretary which provides for periodic review of amounts paid as foster care maintenance payments to assure their continuing appropriateness.Condition: We were unable to confirm the inclusion of written requirements for the periodic review of maintenance payment rates in the Department?s approved plan.Questioned Costs: NoneContext: Foster care maintenance payment rates are periodically reviewed for appropriateness by the Department. However, we were unable to identify a written policy or procedure associated with an approved State plan that describes the periodic rate review process or establishes a rate review schedule.Cause: State plan documentation and related policies did not contain a description of the periodic review process and timing that the Department follows.Effect: It could not be determined if the periodic reviews, which were conducted, were carried out in accordance with management?s intent, as expressed through approved written policies.Recommendation: We recommend the Department review and update their State Plan documentation and associated policies and procedures to ensure all information referenced in their approved State Plan supports compliance with the applicable federal requirements.Prior Year Single Audit Report Finding Number: Not applicableViews of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 160.

Corrective Action Plan

U.S. Department of Health and Human ServicesThe South Carolina Department of Social Services respectfully submits the following corrective action plan for the year ended June 30, 2020.The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule.2020-030 Foster Care-Title IV-E ? Assistance Listing No. 93.658Recommendation: We recommend the Department review and update its state plan documentation and associated policies and procedures to ensure all information referenced in its approved state plan supports compliance with the applicable Federal requirements.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding: The Department will incorporate documentation of its processes for periodic review and update of Foster Care rates into its approved State Plan.Name(s) of the contact person(s) responsible for corrective action: Anthony Williams, Director, Office of Policy and Continuous Quality ImprovementPlanned completion date for corrective action plan: January 31, 2022.If the Federal Cognizant Agency of Oversight or Audit has questions regarding this plan, please call David O?Kelly at 803-898-3987.

About Special Tests and Provisions →
2020-031
Reporting
SIGNIFICANT DEFICIENCYOTHER MATTERS

Discrepancies existed between federal financial reports and the Department?s supporting records.Questioned Costs: NoneContext: Two quarterly CB-496 reports were selected for testing. Some administrative costs in Part 1, Section A were inadequately supported and, for one of the reports, some expenditures were omitted. Additionally, discrepancies were encountered between the number of children reported in Part 1, Section E of both reports and supporting documentation. Finally, in Part 2 of the reports, one adjustment was misclassified and another lacked supporting documentation.Cause: Department controls failed to detect and correct the identified errors and ensure all reported amounts were appropriately supported by Department records.Effect: The CB-496 reports contained errors, omissions and data which did not agree to supporting documentation.Recommendation: We recommend that the Department continue to strengthen its internal controls to ensure that federal reports are free from error and clearly supported prior to submission.Prior Year Single Audit Report Finding Number: Not applicableViews of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 160.

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Federal Agency: Department of Health and Human ServicesFederal Program Title: Foster Care?Title IV-EAssistance Listing: 93.658Federal Grant ID Number: 1901SCFOST, 2001SCFOSTPass-Through Entity: Not applicableAward Period: October 1, 2018 through September 30, 2020Type of Finding: Significant deficiency in internal control over compliance, other mattersCriteria: 45 CFR ? 75.303 requires effective internal controls be established and maintained in order to provide reasonable assurance that the federal award is being managed in compliance with federal statutes, regulations, and the terms and conditions of the federal award.Condition: Discrepancies existed between federal financial reports and the Department?s supporting records.Questioned Costs: NoneContext: Two quarterly CB-496 reports were selected for testing. Some administrative costs in Part 1, Section A were inadequately supported and, for one of the reports, some expenditures were omitted. Additionally, discrepancies were encountered between the number of children reported in Part 1, Section E of both reports and supporting documentation. Finally, in Part 2 of the reports, one adjustment was misclassified and another lacked supporting documentation.Cause: Department controls failed to detect and correct the identified errors and ensure all reported amounts were appropriately supported by Department records.Effect: The CB-496 reports contained errors, omissions and data which did not agree to supporting documentation.Recommendation: We recommend that the Department continue to strengthen its internal controls to ensure that federal reports are free from error and clearly supported prior to submission.Prior Year Single Audit Report Finding Number: Not applicableViews of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 160.

Corrective Action Plan

U.S. Department of Health and Human ServicesThe South Carolina Department of Social Services respectfully submits the following corrective action plan for the year ended June 30, 2020.The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule.2020-031 Foster Care-Title IV-E ? Assistance Listing No. 93.658Recommendation: We recommend that the Department continue to strengthen its internal controls to ensure that Federal reports are free from error and clearly supported prior to submission.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding: Staff turnover, and the Department?s required enactment of work-from-home policies to combat the spread of the COVID-19 virus, made complete implementation of improvements more difficult. The Department?s Grants Accounting and Reporting team is implementing additional training on the proper completion of the Federal Financial Reports, including the proper classification of costs, and procedures for tie-in and retention of relevant supporting documentation. Reports are now reviewed by a manager or the Controller prior to submission.Name(s) of the contact person(s) responsible for corrective action: Reshma Parikh, Grants Accounting and Reporting ManagerPlanned completion date for corrective action plan: April 30, 2021If the Federal Cognizant Agency of Oversight or Audit has questions regarding this plan, please call David O?Kelly at 803-898-3987.

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2020-032
Activities Allowed or Unallowed / Cost Allowability
SIGNIFICANT DEFICIENCYQUESTIONED COSTSOTHER MATTERS

Discrepancies related to allowable activities/costs were encountered for some program payments.Questioned Costs: $25Context: One hundred non-payroll disbursements were selected for allowable activities/costs testing. For two of the disbursements tested, the Department was unable to provide sufficient documentation to support how the costs were allocated. For five of the disbursements tested, some portion of the costs charged to the grant should have been allocated to other Department program/service areas, but the exact amount could not be determined. For two of the disbursements tested, the amounts paid for foster care maintenance exceeded the monthly rate allowed by the Department?s payment schedule by a combined total of $25. For some disbursements tested, the rate paid for non-regular foster care maintenance lacked adequate supporting documentation to determine compliance with federal allowable activities/costs requirements.Cause: Documentation and system issues caused the discrepancies noted.Effect: Charges to the grant may have been for unallowable activities and costs.Recommendation: We recommend that the Department implement policies and procedures that ensure all rates and payments charged to the program fully comply with federal requirements.Prior Year Single Audit Report Finding Number: Not applicableViews of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 161.

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Federal Agency: Department of Health and Human ServicesFederal Program Title: Foster Care?Title IV-EAssistance Listing: 93.658Federal Grant ID Number: 1901SCFOST, 2001SCFOSTPass-Through Entity: Not applicableAward Period: October 1, 2018 through September 30, 2020Type of Finding: Significant deficiency in internal control over compliance, other mattersCriteria: 45 CFR ? 75.403 outlines factors affecting allowability of costs, including adequate documentation.45 CFR ? 75.405(d) requires costs that benefit two or more projects or activities to be allocated to the projects based on the proportional benefit or, if that cannot be determined feasibly, allocated on another reasonable, documented basis.45 CFR ? 1356.60 explains fiscal requirements for title IV-E.Condition: Discrepancies related to allowable activities/costs were encountered for some program payments.Questioned Costs: $25Context: One hundred non-payroll disbursements were selected for allowable activities/costs testing. For two of the disbursements tested, the Department was unable to provide sufficient documentation to support how the costs were allocated. For five of the disbursements tested, some portion of the costs charged to the grant should have been allocated to other Department program/service areas, but the exact amount could not be determined. For two of the disbursements tested, the amounts paid for foster care maintenance exceeded the monthly rate allowed by the Department?s payment schedule by a combined total of $25. For some disbursements tested, the rate paid for non-regular foster care maintenance lacked adequate supporting documentation to determine compliance with federal allowable activities/costs requirements.Cause: Documentation and system issues caused the discrepancies noted.Effect: Charges to the grant may have been for unallowable activities and costs.Recommendation: We recommend that the Department implement policies and procedures that ensure all rates and payments charged to the program fully comply with federal requirements.Prior Year Single Audit Report Finding Number: Not applicableViews of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 161.

Corrective Action Plan

U.S. Department of Health and Human ServicesThe South Carolina Department of Social Services respectfully submits the following corrective action plan for the year ended June 30, 2020.The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule.2020-032 Foster Care-Title IV-E ? Assistance Listing No. 93.658Recommendation: We recommend that the Department implement policies and procedures that ensure all rates and payments charged to the program fully comply with Federal requirements.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding: The department will review the charges to the program for which amounts that should have been allocated were deemed unclear or insufficiently documented in order to identify and implement any improvements needed to ensure the charges are correctly allocated and that the allocations are fully documented.The $25 in question resulted from payments at established daily rates to two foster parents in the same month, when custody of the child was changed from one to the other. Payments were made to the respective parents for a total of 31 days, resulting in total payments for the month that exceeded the monthly rate equivalent computed on a 30-day basis. The Department will consult with the Children?s Bureau and review its policies with regard to the handling of these payments under the various possible scenarios and implement any changes if needed to ensure the payment amounts comply with federal rules.Name(s) of the contact person(s) responsible for corrective action: David O?Kelly, Controller; Laura Claspill, Director of Program DevelopmentPlanned completion date for corrective action plan: June 30, 2021If the Federal Cognizant Agency of Oversight or Audit has questions regarding this plan, please call David O?Kelly at 803-898-3987.

About Activities Allowed or Unallowed, Allowable Costs / Cost Principles →

FY 2020-06-30

$8,976,607,879 federal awards expended

FAC accepted this audit on April 19, 2021 — management decision was due October 19, 2021.

2020-001
Reporting
MATERIAL WEAKNESSREPEAT OF 2019-001

The agency did not prepare and submit its Data Collection Form and Reporting Package for the year ended June 30, 2020 to the Federal Audit Clearinghouse by the extended due date of September 30, 2021. Criteria: Per 200.512 of the Uniform Guidance, Report Submission, the audit shall be completed and the Data Collection Form and Reporting Package shall be electronically transmitted within the earlier of thirty (30) days after receipt of the auditor's reports, or nine (9) months after the end of the audit period. If the due date falls on a Saturday, Sunday, or federal holiday, the Data Collection Form and Reporting Package are due the next business day. The Uniform Guidance does not permit the recipient to extend the due date. Cause: Management did not review subsidiary ledgers for accuracy and reconcile them to the general ledger on a timely basis. Accordingly, the Agency's general ledger for the year ended June 30, 2019 was not closed out in a timely manner. Effect: The Agency's Data Collection Form and Reporting Package for the year ended June 30, 2020 was not prepared and submitted to the Federal Audit Clearinghouse by the due date. Recommendation: We recommend that management implement monthly financial reporting and closeout processes so that the financial closeout process can be performed timely.

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Item 2020-001: Report Submission to the Federal Audit Clearinghouse (Other Matter Required to be Reported Under the Uniform Guidance) (Material Weakness) Condition: The agency did not prepare and submit its Data Collection Form and Reporting Package for the year ended June 30, 2020 to the Federal Audit Clearinghouse by the extended due date of September 30, 2021. Criteria: Per 200.512 of the Uniform Guidance, Report Submission, the audit shall be completed and the Data Collection Form and Reporting Package shall be electronically transmitted within the earlier of thirty (30) days after receipt of the auditor's reports, or nine (9) months after the end of the audit period. If the due date falls on a Saturday, Sunday, or federal holiday, the Data Collection Form and Reporting Package are due the next business day. The Uniform Guidance does not permit the recipient to extend the due date. Cause: Management did not review subsidiary ledgers for accuracy and reconcile them to the general ledger on a timely basis. Accordingly, the Agency's general ledger for the year ended June 30, 2019 was not closed out in a timely manner. Effect: The Agency's Data Collection Form and Reporting Package for the year ended June 30, 2020 was not prepared and submitted to the Federal Audit Clearinghouse by the due date. Recommendation: We recommend that management implement monthly financial reporting and closeout processes so that the financial closeout process can be performed timely.

Corrective Action Plan

Item 2020-001 Report Submission to the Federal Audit Clearinghouse (Other Matter Required to be Reported Under the Uniform Guidance) (Material Weakness) The South Carolina Department of Employment and Workforce (SCDEW) is reviewing staffing needs and workflows to improve operations so that timely financial reports can be generated to meet SCDEW's reporting requirements. During the fiscal year July 1, 2019 to June 30, 2020 SCDEW replaced two key management positions in the finance department and began a significant project to replace its financial reporting system and update the related workflows. That project and other staffing matters were impacted by the disruptions in the workplace as a result of the Agency's response to the COVID 19 Pandemic. Staffing will continue to be evaluated as the transition to the new financial reporting system progresses. The financial reporting system replacement project was completed September 30, 2021.

Prior Finding References

2019-001

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2020-002
Reporting
MATERIAL WEAKNESSREPEAT OF 2019-002

The Agency did not submit certain quarterly reports to the United States Department of Labor ("National Office") by the required due dates. Accordingly, the Agency did not comply with the Reporting compliance requirements related to the Unemployment Insurance program. Criteria: Per Part 4 of the OMB compliance Supplement: The ETA 191 Report is required to be submitted on a quarterly basis to the National Office by the 25th of the month following the close of the quarter. Cause: Internal controls are not in place to ensure that all required reports are being submitted in the accordance with the United States Department of Labor's timelines. The reports were affected by the unprecedented COVID-19 pandemic, which required all program resources to focus on pandemic claims processing. Some of the data needed for these reports was delayed due to the program and system resources focused on claims processing as well as the difficulty experienced due to the requirement of staff to shelter at home beginning April 2020 under the South Carolina Governor's Executive Order and restricted access to records located in the office. Effect: As a result, the Agency becomes more susceptible to having its level of federal award funding reduced by the United States Department of Labor when it violates its Reporting compliance requirements applicable to the Unemployment Insurance program. Context: We inspected a sample of quarterly reports and noted the following exception: Unemployment Insurance - One(1) ETA 191 quarterly report. Recommendation: We recommend that management carefully review the terms and conditions included in the supporting grant agreements and the Reporting requirements included in the OMB Compliance Supplement applicable to the Unemployment Insurance and the Employment Services Cluster programs and implement controls to ensure that all reports are filed on a timely basis.

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Item 2020-002: Reporting (Material Weakness over Reporting and Non-Material Noncompliance). Condition: The Agency did not submit certain quarterly reports to the United States Department of Labor ("National Office") by the required due dates. Accordingly, the Agency did not comply with the Reporting compliance requirements related to the Unemployment Insurance program. Criteria: Per Part 4 of the OMB compliance Supplement: The ETA 191 Report is required to be submitted on a quarterly basis to the National Office by the 25th of the month following the close of the quarter. Cause: Internal controls are not in place to ensure that all required reports are being submitted in the accordance with the United States Department of Labor's timelines. The reports were affected by the unprecedented COVID-19 pandemic, which required all program resources to focus on pandemic claims processing. Some of the data needed for these reports was delayed due to the program and system resources focused on claims processing as well as the difficulty experienced due to the requirement of staff to shelter at home beginning April 2020 under the South Carolina Governor's Executive Order and restricted access to records located in the office. Effect: As a result, the Agency becomes more susceptible to having its level of federal award funding reduced by the United States Department of Labor when it violates its Reporting compliance requirements applicable to the Unemployment Insurance program. Context: We inspected a sample of quarterly reports and noted the following exception: Unemployment Insurance - One(1) ETA 191 quarterly report. Recommendation: We recommend that management carefully review the terms and conditions included in the supporting grant agreements and the Reporting requirements included in the OMB Compliance Supplement applicable to the Unemployment Insurance and the Employment Services Cluster programs and implement controls to ensure that all reports are filed on a timely basis.

Corrective Action Plan

Item 2020-002 Reporting (Material Weakness over Reporting and Non-Material Noncompliance) SCDEW implemented a corrective action plan in response to this finding during the year ended June 30, 2020 in response to similar finding for audits of prior periods a brief summary follows: The SCDEW Enterprise and Project Management Office (EPMO) is tasked with monitoring agency wide reporting deadlines. The EPMO developed a master reporting database that includes relevant identifying information including report name, Agency, SCDEW contact, reporting frequency and due dates. Individual reporters at SCDEW submit data to EPMO on the status of the required filings. EPMO routinely reports the status of filings to executive leadership. This finding for the year ended June 30, 2020 is a significant improvement with only one late report detected for the period under audit.

Prior Finding References

2019-002

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2020-003
Cost Allowability / Special Tests & Provisions
SIGNIFICANT DEFICIENCYREPEAT OF 2019-003OTHER MATTERS

The Department did not remit the federal share of recoveries and collections to the Medicaid program in accordance with federal regulations and the State Medicaid Manual.Questioned Costs: UnknownContext: We tested 60 receivables to ensure the Department properly credited the Medicaid program for the federal share of identified overpayments. For three receivables tested, the Department used the incorrect federal medical assistance percentage to calculate the federal share which resulted in an underpayment of $288 to the federal grantor.This is a repeat finding from the FY19 Single Audit. The Department stated on its Summary Schedule of Prior Year Audit Findings that this issue was ?Fully Corrected with Previously Reported Corrective Action Implemented?. Due to this issue repeating for FY20, this issue has not been fully corrected.Cause: Department personnel used the incorrect period of overpayment calculating and remitting the refunds due to human error.Effect: The Department?s control procedures did not detect the errors identified in our testing which could lead to further improper remittances.Recommendation: We recommend the Department continue its efforts to strengthen controls to ensure the federal share of recoveries and collections are remitted in accordance with applicable federal and State requirements.Prior Year Single Audit Finding Number: 2019-003Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 132.

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Federal Agency: Department of Health and Human ServicesFederal Program Title: Medicaid ClusterAssistance Listing: 93.775, 93.777, 93.778Federal Grant ID Number: 05-1905SC5MAP, 05-2005SC5MAPPass-Through Entity: Not applicableAward Period: October 1, 2018 through September 30, 2020Type of Finding: Significant deficiency in internal control over compliance, other mattersCriteria: Per 42 CFR 433.12 (c), the State is required to credit the Medicaid program for ??overpayments made to Medicaid providers?? In addition, Title 45 Section 2500.6 B of the Centers for Medicare & Medicaid Services? (CMS) State Medicaid Manual states to ??determine the date or period of the expenditure for which the refund is made to establish the [Federal Medical Assistance Percentage] at which the original expenditure was matched by the federal government. Make refunds of the federal share at the FMAP for which you were reimbursed.?Condition: The Department did not remit the federal share of recoveries and collections to the Medicaid program in accordance with federal regulations and the State Medicaid Manual.Questioned Costs: UnknownContext: We tested 60 receivables to ensure the Department properly credited the Medicaid program for the federal share of identified overpayments. For three receivables tested, the Department used the incorrect federal medical assistance percentage to calculate the federal share which resulted in an underpayment of $288 to the federal grantor.This is a repeat finding from the FY19 Single Audit. The Department stated on its Summary Schedule of Prior Year Audit Findings that this issue was ?Fully Corrected with Previously Reported Corrective Action Implemented?. Due to this issue repeating for FY20, this issue has not been fully corrected.Cause: Department personnel used the incorrect period of overpayment calculating and remitting the refunds due to human error.Effect: The Department?s control procedures did not detect the errors identified in our testing which could lead to further improper remittances.Recommendation: We recommend the Department continue its efforts to strengthen controls to ensure the federal share of recoveries and collections are remitted in accordance with applicable federal and State requirements.Prior Year Single Audit Finding Number: 2019-003Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 132.

Corrective Action Plan

Department of Health & Human ServicesCenters for Medicare & Medicaid Services31 Forsyth Street, SW, Room 4T20Atlanta, Georgia 30303-8909The South Carolina Department of Health and Human Services respectfully submits the following corrective action plan for the year ended 6/30/20.The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule.FINDINGS?FEDERAL AWARD PROGRAM AUDITDEPARTMENT OF HEALTH AND HUMAN SERVICES2020-003 Medicaid Cluster ? Assistance Listing No. 93.775, 93.777, 93.778Recommendation: We recommend the Department continue its efforts to strengthen controls to ensure the federal share of recoveries and collections are remitted in accordance with applicable federal and state requirements.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding:To continue to eliminate federal share miscalculation, the accounts receivable manager will continue to review 50% of each month?s receivables in FY2021 and the program director will increase the quarterly review to 20%. Management has submitted a South Carolina Enterprise Information System (SCEIS) Enhancement Request Form to create an accounts receivable workflow that will require management to approve all newly established and adjusted receivables. Furthermore, management will continue researching best practices for minimizing and eliminating manual error and miscalculation within the Accounts Receivable department.Name(s) of the contact person(s) responsible for corrective action: Lynette Wilson, Nika SimmonsPlanned completion date for corrective action plan: Ongoing

Prior Finding References

2019-003

About Allowable Costs / Cost Principles, Special Tests and Provisions →
2020-004
Eligibility
SIGNIFICANT DEFICIENCYREPEAT OF 2019-005OTHER MATTERS

Eligibility files did not contain adequate documentation to support the Medicaid and CHIP recipients? eligibility statuses.Questioned Costs: UnknownContext: We tested 120 individual recipients (60 each for Medicaid and CHIP) to ensure the Department was in compliance with applicable eligibility requirements. We determined the Department did not maintain adequate documentation of eligibility for six Medicaid recipients and three CHIP recipients.Cause: The Department transitioned to an online eligibility system, the Medicaid Eligibility Determination System (MEDS), in July 2013. According to Department personnel, documentation in some of the paper files may not have been scanned into the system since the transition. For cases opened after the transition, the omissions were due to worker error.Effect: The Department could not support eligibility determinations in accordance with its State plan.Recommendation: We recommend the Department continue its efforts to maintain documentation to support eligibility determinations in accordance with its State plan and federal regulations.Prior Year Single Audit Finding Number: 2019-005Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 133.

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Federal Agency: Department of Health and Human ServicesFederal Program Title: Medicaid Cluster; Children?s Health Insurance Program (CHIP)Assistance Listing: 93.775, 93.777, 93.778; 93.767Federal Grant ID Number: 05-1905SC5MAP, 05-2005SC5MAP; 05-1805SC5021Pass-Through Entity: Not applicableAward Period: October 1, 2017 through September 30, 2020Type of Finding: Significant deficiency in internal control over compliance, other mattersCriteria: 42 CFR 435.914 (a) states, ?The agency must include in each applicant?s case record facts to support the agency?s decision on his application.? In addition, Section 4.7 of the Department?s Title XIX (Medicaid) State Plan (Maintenance of Records) affirms that it meets the requirements outlined in 42 CFR 431.17 (b), which states, ?A State plan must provide that the Medicaid agency will maintain or supervise the maintenance of records necessary for the proper and efficient operation of the plan.? Furthermore, the Department?s Title XXI (CHIP) State Plan attests that CHIP will operate as a Medicaid expansion program; therefore, the aforementioned regulations apply to both programs.Condition: Eligibility files did not contain adequate documentation to support the Medicaid and CHIP recipients? eligibility statuses.Questioned Costs: UnknownContext: We tested 120 individual recipients (60 each for Medicaid and CHIP) to ensure the Department was in compliance with applicable eligibility requirements. We determined the Department did not maintain adequate documentation of eligibility for six Medicaid recipients and three CHIP recipients.Cause: The Department transitioned to an online eligibility system, the Medicaid Eligibility Determination System (MEDS), in July 2013. According to Department personnel, documentation in some of the paper files may not have been scanned into the system since the transition. For cases opened after the transition, the omissions were due to worker error.Effect: The Department could not support eligibility determinations in accordance with its State plan.Recommendation: We recommend the Department continue its efforts to maintain documentation to support eligibility determinations in accordance with its State plan and federal regulations.Prior Year Single Audit Finding Number: 2019-005Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 133.

Corrective Action Plan

Department of Health & Human ServicesCenters for Medicare & Medicaid Services31 Forsyth Street, SW, Room 4T20Atlanta, Georgia 30303-8909The South Carolina Department of Health and Human Services respectfully submits the following corrective action plan for the year ended 6/30/20.The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule.DEPARTMENT OF HEALTH AND HUMAN SERVICES2020-004 Medicaid Cluster; Children?s Health Insurance Program (CHIP) ? Assistance Listing No. 93.775, 93.777, 93.778; 93.767Recommendation: We recommend the Department continue its efforts to maintain documentation to support eligibility determinations in accordance with its State plan and Federal regulations.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding:Staff Performance Evaluation and Remediation: The Eligibility Performance Evaluation and Remediation process rolled out to staff in July 2019. This process includes key elements for review which lead to a correct or incorrect eligibility determination. This includes the presence of a signed application (where appropriate) and presence of other documentation required for the eligibility decision (e.g. Level of Care), correct application of financial and non-financial eligibility criteria, as well as timeliness metrics to assist the agency with meeting federally defined standards.The Eligibility Quality Assurance Team (EQAT) consists of 52 team members. Team members are trained to evaluate MAGI, Non-MAGI or Long-Term Care determinations for accuracy of those determinations, as well as vital procedural errors that are most likely to impact eligibility. On the first business day of each month, supervisors receive Employee Performance results for their staff and review these results during one on one meetings. Action plans are established, implemented, and reviewed for any needed corrective measures.Eligibility Policy and Procedures were updated March 1, 2020, providing instructions to workers to ensure the case file is complete for all eligibility criteria based on policy, prior to making an eligibility determination. This includes reviewing the case file for the following:? Required documents are in the case file (e.g. signed application, review form, adoption decrees)? Information from the application and other documents is correctly entered into the System of Record? Required verification documents for financial, non-financial and categorical eligibility criteria are in OnBase and recorded on the Documentation Template and/or System of Record where appropriate (such as SSN if not system verified, MAO99, Level of Care)? Documentation template has been completed, including details of verified information such as for income or resources? The determination reflects reported changes found on application, review forms or other reported changes received in person, by mail, fax, or phone? Information requested via FM 1233: Was requested information needed to make a determination? The worker should not deny/close a case for failure to return information if the requested information is not needed. (for instance, information is already in the case file)? Completed budget workbook where appropriateThe updated policy has been incorporated into training and delivered to staff as part of new worker and refresher courses. Application of this policy is evaluated as part of the EQA process.Implementation and Monitoring Plan:Implementation and Monitoring is a shared responsibility among eligibility staff, supervisors, and managers, as well as key program areas within eligibility.Supervisors are responsible for monitoring staff daily by using data available via system of record and workload management software, as well as through case spot reviews. Supervisors meet monthly with each staff member to review EQA findings and timeliness metrics to identify and address issues that impact performance, as well as to facilitate corrections to incorrect determinations identified through the EQA processErrors are identified via error codes and descriptions. EQA reviews are conducted and housed in a state-developed tool to allow for creation of reports that can be generated based on supervisor, worker, work type, error code or overall accuracy. Beginning in October 2020, a monthly report of the top error codes identified for each work type (e.g. MAGI, Non-MAGI, Long Term Care) is generated. A sampling of incorrect cases is analyzed by EQA, Policy and Training for trends and root causes. From this analysis, mitigation strategies are developed and implemented. This may be a combination of supervisor intervention recommendations, policy clarifications or training to be improved, developed, and/or delivered. Data regarding these errors are tracked monthly to identify impact of these mitigation strategies.Starting in the First Quarter (Q1) of CY 2021, the state will compare errors identified through audits and federal reviews such as PERM with EQA error trends and use this monitoring method to determine impact of mitigation strategies on these errors. In addition, the agency will collaborate with our third-party quality review entity, the University of South Carolina Core for Applied Research and Evaluation (USC CARE) to conduct focused reviews to assist with monitoring trends and impact of mitigation strategies. Baseline error rates will be established, based on error codes. This reporting is in development and will be available by the end of Q1 CY 2021. Error codes have been further modified to better identify and monitor specific error trends as prioritized by the agency. System work to incorporate these updated codes in the EQA tool is in development with the agency?s information technology team. An implementation date has not been established.Summary of Eligibility Quality Assurance Process:A. Monthly EQA Reviews (10/worker) ?Monthly Feedback Reports reviewed with worker by supervisor?Corrections made by worker/training needs identified and addressed?Monthly monitoring for progress and corrective actionsB. Top errors identified through EQA process from previous quarter?Root cause analysis completed by training and policy team members?Mitigation strategies identified and implemented?Quarterly monitoring for progress and need for additional/alternative strategies?Continued monitoring and implementationC. Top errors identified through EQA process, PERM, MEQC, audits captured on a quarterly basis?USC CARE conducts third party reviews for additional analysis of root cause and makes recommendations for mitigation?SCDHHS and USC CARE review recommendations, compare with current strategies and implement as appropriate?Quarterly monitoring of findings and progressName(s) of the contact person(s) responsible for corrective action: Lori RiskPlanned completion date for corrective action plan: Ongoing

Prior Finding References

2019-005

About Eligibility →
2020-005
Eligibility
SIGNIFICANT DEFICIENCYREPEAT OF 2019-006QUESTIONED COSTSOTHER MATTERS

The Department did not consistently discontinue the benefits of ineligible recipients.Questioned Costs: $5,851Context: We tested 60 individual recipients to ensure the Department was in compliance with applicable eligibility requirements. We determined the Department did not discontinue the benefits of three recipients on the dates they became ineligible.Cause: Department personnel stated the closure process for these recipients ultimately was not completed due to their interpretation of the Families First Coronavirus Response Act.Effect: The Department was not in compliance with applicable eligibility requirements. In addition, payments were made on behalf of ineligible recipients.Recommendation: We recommend the Department discontinue the benefits of ineligible recipients in accordance with its State plan and federal regulations.Prior Year Single Audit Finding Number: 2019-006Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 135.

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Federal Agency: Department of Health and Human ServicesFederal Program Title: Children?s Health Insurance Program (CHIP)Assistance Listing: 93.767Federal Grant ID Number: 05-1805SC5021Pass-Through Entity: Not applicableAward Period: October 1, 2017 through September 30, 2019Type of Finding: Significant deficiency in internal control over compliance, other mattersCriteria: Section 4.32 of the Department?s Title XIX (Medicaid) State Plan (Income and Eligibility Verification System) affirms that it meets the requirements outlined in 42 CFR 435.930 (b), which states in part, ?The agency must?continue to furnish Medicaid regularly to all eligible individuals until they are found to be ineligible.? In addition, the Department?s Title XXI (CHIP) State Plan attests that CHIP will operate as a Medicaid expansion program; therefore, the aforementioned regulation applies to both programs.Condition: The Department did not consistently discontinue the benefits of ineligible recipients.Questioned Costs: $5,851Context: We tested 60 individual recipients to ensure the Department was in compliance with applicable eligibility requirements. We determined the Department did not discontinue the benefits of three recipients on the dates they became ineligible.Cause: Department personnel stated the closure process for these recipients ultimately was not completed due to their interpretation of the Families First Coronavirus Response Act.Effect: The Department was not in compliance with applicable eligibility requirements. In addition, payments were made on behalf of ineligible recipients.Recommendation: We recommend the Department discontinue the benefits of ineligible recipients in accordance with its State plan and federal regulations.Prior Year Single Audit Finding Number: 2019-006Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 135.

Corrective Action Plan

Department of Health & Human ServicesCenters for Medicare & Medicaid Services31 Forsyth Street, SW, Room 4T20Atlanta, Georgia 30303-8909DEPARTMENT OF HEALTH AND HUMAN SERVICES2020-005 Children?s Health Insurance Program (CHIP) ? Assistance Listing No. 93.767Recommendation: We recommend the Department discontinue the benefits of ineligible recipients in accordance with its State plan and Federal regulations.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding:Root Cause: Case Reviews were not processed within the standard of promptness due to the large backlog of annual reviews and previously, a large backlog of applications.Corrective Action: SCDHHS has implemented a plan to reduce and manage the eligibility processing backlog, while also protecting the integrity of eligibility decisions. The agency?s approach has been to build staff capacity through the creation of processing centers and to maximize accuracy and timeliness of eligibility decisions via implementation of a Staff Performance Evaluation and Remediation process.Staff Capacity and Processing Centers: The agency has created and staffed five (5) processing centers in Richland (2), Aiken (1), Spartanburg (1) and Florence (1) counties. Prior to the COVID-19 Public Health Emergency, staff webinars for processing reviews were conducted for MAGI and Non-MAGI review processing, as well as updates to job aids, based on updated policies and procedures.Staff Performance Evaluation and Remediation: The Eligibility Performance Evaluation and Remediation process rolled out to staff in July 2019. This process includes key elements for review which lead to a correct or incorrect eligibility determination. This includes the presence of a signed application (where appropriate) and presence of other documentation required for the eligibility decision (e.g. Level of Care), correct application of financial and non-financial eligibility criteria, as well as timeliness metrics to assist the agency with meeting federally defined standards.The Eligibility Quality Assurance Team (EQAT) consists of 52 team members. Team members are trained to evaluate MAGI, Non-MAGI or Long-Term Care determinations for accuracy of those determinations, as well as vital procedural errors that are most likely to impact eligibility. On the first business day of each month, supervisors receive Employee Performance results for their staff and review these results during one on one meetings. Action plans are established, implemented, and reviewed for any needed corrective measures.Implementation and Monitoring Plan: Implementation and Monitoring is a shared responsibility among eligibility staff, supervisors, and managers, as well as key program areas within eligibility.Supervisors are responsible for monitoring staff daily by using data available via system of record and workload management software, as well as though case spot reviews. Supervisors meet monthly with each staff member to review EQA findings and timeliness metrics to identify and address issues that impact performance, as well as to facilitate corrections to incorrect determinations identified through the EQA process.Errors are identified via error codes and descriptions. EQA reviews are conducted and housed in a state-developed tool to allow for creation of reports that can be generated based on supervisor, worker, work type, error code or overall accuracy. Beginning in October 2020, a monthly report of the top error codes identified for each work type (e.g. MAGI, Non-MAGI, Long Term Care) is generated. A sampling of incorrect cases is analyzed by EQA, Policy and Training for trends and root causes. From this analysis, mitigation strategies are developed and implemented. This may be a combination of supervisor intervention recommendations, policy clarifications or training to be improved, developed, and/or delivered. Data regarding these errors are tracked monthly to identify impact of these mitigation strategies.Starting in the First Quarter (Q1) of CY 2021, the state will compare errors identified in audits and federal reviews with EQA error trends and use this monitoring method to determine impact of mitigation strategies on these errors. In addition, the agency will collaborate with our third-party quality review entity, the University of South Carolina Core for Applied Research and Evaluation (USC CARE) to conduct focused reviews to assist with monitoring trends and impact of mitigation strategies. Baseline error rates will be established, based on error codes. This reporting is in development and will be available by the end of Q1, CY 2021. Error codes have been further modified to better identify and monitor specific error trends as prioritized by the agency. System work to incorporate these updated codes in the EQA tool is in development with the agency?s information technology team. An implementation date has not been established.Summary of Eligibility Quality Assurance Process:A. Monthly EQA Reviews (10/worker) ?Monthly Feedback Reports reviewed with worker by supervisor?Corrections made by worker/training needs identified and addressed?Monthly monitoring for progress and corrective actionsB. Top errors identified through EQA process from previous quarter?Root cause analysis completed by training and policy team members?Mitigation strategies identified and implemented?Quarterly monitoring for progress and need for additional/alternative strategies?Continued monitoring and implementationC. Top errors identified through EQA process, PERM, MEQC, audits captured on a quarterly basis?USC CARE conducts third party reviews for additional analysis of root cause and makes recommendations for mitigation?SCDHHS and USC CARE review recommendations, compare with current strategies and implement as appropriate?Quarterly monitoring of findings and progressDelays in review processing were due to the public health emergency. The agency is developing its plan to return to normal operations for review processing at the end of the public health emergency, based on guidance provided by CMS.Name(s) of the contact person(s) responsible for corrective action: Lori RiskPlanned completion date for corrective action plan: December 2022

Prior Finding References

2019-006

About Eligibility →
2020-006
Eligibility
MATERIAL WEAKNESSMODIFIED OPINIONREPEAT OF 2019-007

The Department did not consistently perform timely annual eligibility reviews for Medicaid and CHIP recipients in accordance with Section 101.10 of the South Carolina Medicaid Policies and Procedures Manual.Questioned Costs: UnknownContext: We tested 120 individual recipients (60 each for Medicaid and CHIP) to ensure the Department was in compliance with applicable eligibility requirements. We determined the Department did not comply with the annual review requirement for 22 Medicaid recipients and 21 CHIP recipients.Cause: Department personnel stated they did not comply with the annual review requirement for these recipients due to backlog in case processing.Effect: In the absence of an annual review, Medicaid and CHIP recipients may continue to receive benefits without meeting eligibility requirements.Recommendation: We recommend eligibility reviews be performed annually in accordance with the South Carolina Medicaid Policies and Procedures Manual.Prior Year Single Audit Finding Number: 2019-007Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 138.

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Federal Agency: Department of Health and Human ServicesFederal Program Title: Medicaid Cluster; Children?s Health Insurance Program (CHIP)Assistance Listing: 93.775, 93.777, 93.778; 93.767Federal Grant ID Number: 05-1905SC5MAP, 05-2005SC5MAP, 05-1805SC5021, 05-1905SC5022Pass-Through Entity: Not applicableAward Period: October 1, 2017 through September 30, 2020Type of Finding: Material weakness in internal control over compliance, material noncomplianceCriteria: Section 2.1 of the Department?s Title XIX (Medicaid) State Plan (Application, Determination of Eligibility and Furnishing Medicaid) affirms that it meets the requirements outlined in 42 CFR Part 435.916, which states in part, ?the agency must promptly determine eligibility between regular renewals of eligibility.? In addition, Section 101.10 of the South Carolina Medicaid Policies and Procedures Manual states that the Department must complete an annual review for certain payment categories. Furthermore, the Department?s Title XXI (CHIP) State Plan attests that CHIP will operate as a Medicaid expansion program; therefore, the aforementioned regulation and polices apply to both programs.Condition: The Department did not consistently perform timely annual eligibility reviews for Medicaid and CHIP recipients in accordance with Section 101.10 of the South Carolina Medicaid Policies and Procedures Manual.Questioned Costs: UnknownContext: We tested 120 individual recipients (60 each for Medicaid and CHIP) to ensure the Department was in compliance with applicable eligibility requirements. We determined the Department did not comply with the annual review requirement for 22 Medicaid recipients and 21 CHIP recipients.Cause: Department personnel stated they did not comply with the annual review requirement for these recipients due to backlog in case processing.Effect: In the absence of an annual review, Medicaid and CHIP recipients may continue to receive benefits without meeting eligibility requirements.Recommendation: We recommend eligibility reviews be performed annually in accordance with the South Carolina Medicaid Policies and Procedures Manual.Prior Year Single Audit Finding Number: 2019-007Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 138.

Corrective Action Plan

Department of Health & Human ServicesCenters for Medicare & Medicaid Services31 Forsyth Street, SW, Room 4T20Atlanta, Georgia 30303-8909DEPARTMENT OF HEALTH AND HUMAN SERVICES2020-006 Medicaid Cluster; Children?s Health Insurance Program (CHIP) ? Assistance Listing No. 93.775, 93.777, 93.778; 93.767Recommendation: We recommend eligibility reviews be performed annually in accordance with the South Carolina Medicaid Policies and Procedures Manual.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding:Root Cause: Case Reviews were not processed within the standard of promptness due to the large backlog of annual reviews and previously, a large backlog of applications.Corrective Action: SCDHHS has implemented a plan to reduce and manage the eligibility processing backlog, while also protecting the integrity of eligibility decisions. The agency?s approach has been to build staff capacity through the creation of processing centers and to maximize accuracy and timeliness of eligibility decisions via implementation of a Staff Performance Evaluation and Remediation process.Staff Capacity and Processing Centers: The agency has created and staffed five (5) processing centers in Richland (2), Aiken (1), Spartanburg (1) and Florence (1) counties. Prior to the COVID-19 Public Health Emergency, staff webinars for processing reviews were conducted for MAGI and Non-MAGI review processing, as well as updates to job aids, based on updated policies and procedures.Staff Performance Evaluation and Remediation: The Eligibility Performance Evaluation and Remediation process rolled out to staff in July 2019. This process includes key elements for review which lead to a correct or incorrect eligibility determination. This includes the presence of a signed application (where appropriate) and presence of other documentation required for the eligibility decision (e.g. Level of Care), correct application of financial and non-financial eligibility criteria, as well as timeliness metrics to assist the agency with meeting federally defined standards.The Eligibility Quality Assurance Team (EQAT) consists of 52 team members. Team members are trained to evaluate MAGI, Non-MAGI or Long-Term Care determinations for accuracy of those determinations, as well as vital procedural errors that are most likely to impact eligibility. On the first business day of each month, supervisors receive Employee Performance results for their staff and review these results during one on one meetings. Action plans are established, implemented, and reviewed for any needed corrective measures.Implementation and Monitoring Plan: Implementation and Monitoring is a shared responsibility among eligibility staff, supervisors, and managers, as well as key program areas within eligibility.Supervisors are responsible for monitoring staff daily by using data available via system of record and workload management software, as well as though case spot reviews. Supervisors meet monthly with each staff member to review EQA findings and timeliness metrics to identify and address issues that impact performance, as well as to facilitate corrections to incorrect determinations identified through the EQA process.Errors are identified via error codes and descriptions. EQA reviews are conducted and housed in a state-developed tool to allow for creation of reports that can be generated based on supervisor, worker, work type, error code or overall accuracy. Beginning in October 2020, a monthly report of the top error codes identified for each work type (e.g. MAGI, Non-MAGI, Long Term Care) is generated. A sampling of incorrect cases is analyzed by EQA, Policy and Training for trends and root causes. From this analysis, mitigation strategies are developed and implemented. This may be a combination of supervisor intervention recommendations, policy clarifications or training to be improved, developed, and/or delivered. Data regarding these errors are tracked monthly to identify impact of these mitigation strategies.Starting in the First Quarter (Q1) of CY 2021, the state will compare errors identified by audits and federal reviews with EQA error trends and use this monitoring method to determine impact of mitigation strategies on these errors. In addition, the agency will collaborate with our third-party quality review entity, the University of South Carolina Core for Applied Research and Evaluation (USC CARE) to conduct focused reviews to assist with monitoring trends and impact of mitigation strategies. Baseline error rates will be established, based on error codes. This reporting is in development and will be available by the end of Q1 CY 2021. Error codes have been further modified to better identify and monitor specific error trends as prioritized by the agency. System work to incorporate these updated codes in the EQA tool is in development with the agency?s information technology team. An implementation date has not been established.Summary of Eligibility Quality Assurance Process:A. Monthly EQA Reviews (10/worker) ?Monthly Feedback Reports reviewed with worker by supervisor?Corrections made by worker/training needs identified and addressed?Monthly monitoring for progress and corrective actionsB. Top errors identified through EQA process from previous quarter?Root cause analysis completed by training and policy team members?Mitigation strategies identified and implemented?Quarterly monitoring for progress and need for additional/alternative strategies?Continued monitoring and implementationC. Top errors identified through EQA process, PERM, MEQC, audits captured on a quarterly basis?USC CARE conducts third party reviews for additional analysis of root cause and makes recommendations for mitigation?SCDHHS and USC CARE review recommendations, compare with current strategies and implement as appropriate?Quarterly monitoring of findings and progressDelays in review processing due to Public Health Emergency: The agency is developing its plan to return to normal operations for review processing at the end of the Public Health Emergency, based on guidance provided by CMS.Name(s) of the contact person(s) responsible for corrective action: Lori RiskPlanned completion date for corrective action plan: December 2022If the U.S. Department of Health and Human Services has questions regarding this plan, please call Cynthia Moore, Controller at 803-898-1880.

Prior Finding References

2019-007

About Eligibility →
2020-008
Subrecipient Monitoring
SIGNIFICANT DEFICIENCYREPEAT OF 2019-025OTHER MATTERS

The Department failed to comply with its policies for monitoring the programs and activities of its subrecipients.Questioned Costs: UnknownContext: Our test of subrecipients indicated progress had been made with the implementation of corrective action to address this finding reported in the prior year. However, the annual onsite visits and monitoring required by Department policy were not fully completed for the five subrecipients selected for testing.Cause: The Department?s ability to perform onsite visits and monitoring of subrecipients was constrained significantly by the global pandemic.Effect: Subrecipient programs and activities were not monitored in accordance with Department policies and federal requirements.Recommendation: We recommend that the Department continue to implement policies and procedures to facilitate compliance with Department and federal monitoring requirements.Prior Year Single Audit Report Finding Number: 2019-025Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 142.

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Federal Agency: Department of Health and Human ServicesFederal Program Title: Aging ClusterAssistance Listing: 93.044, 93.045, 93.053Federal Grant ID Number: VariousPass-Through Entity: Not applicableAward Period: VariousType of Finding: Significant deficiency in internal control over compliance, other mattersCriteria: 45 CFR ? 1321.11 directs the State agency to develop policies to address the manner in which it will monitor the performance of all programs and activities for quality and effectiveness.Condition: The Department failed to comply with its policies for monitoring the programs and activities of its subrecipients.Questioned Costs: UnknownContext: Our test of subrecipients indicated progress had been made with the implementation of corrective action to address this finding reported in the prior year. However, the annual onsite visits and monitoring required by Department policy were not fully completed for the five subrecipients selected for testing.Cause: The Department?s ability to perform onsite visits and monitoring of subrecipients was constrained significantly by the global pandemic.Effect: Subrecipient programs and activities were not monitored in accordance with Department policies and federal requirements.Recommendation: We recommend that the Department continue to implement policies and procedures to facilitate compliance with Department and federal monitoring requirements.Prior Year Single Audit Report Finding Number: 2019-025Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 142.

Corrective Action Plan

U.S. Department of Health and Human ServicesThe South Carolina Department on Aging respectfully submits the following corrective action plan for the year ended June 30, 2020.The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule.FINDINGS?FEDERAL AWARD PROGRAM AUDITU.S. Department of Health and Human Services2020-008 Aging Cluster ? Assistance Listing No. 93.044, 93.045, 93.053Recommendation: We recommend that the Department continue to implement policies and procedures to facilitate compliance with Department and Federal monitoring requirements.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding: SCDOA has hired an additional staff member in the finance department to monitor subrecipients. As of the end of March 2021, six AAA have been monitored by the finance department despite the challenges of COVID, and the four remaining agencies will be monitored by June 30, 2021.Name(s) of the contact person(s) responsible for corrective action: Rhonda Walker and Andrew Walsh.Planned completion date for corrective action plan: June 30, 2021If the U.S. Department of Health and Human Services has questions regarding this plan, please call Connie D. Munn at (803) 734-9910.

Prior Finding References

2019-025

About Subrecipient Monitoring →
2020-009
Matching, Level of Effort, Earmarking
SIGNIFICANT DEFICIENCYOTHER MATTERS

Discrepancies existed between non-federal share amounts reported to meet matching requirements and the supporting accounting records.Questioned Costs: UnknownContext: The 2017 Title III-B and C grants, which closed during the audit period, were selected for detailed testing. While the total recipient share of expenditures reported for each grant met or exceeded the total share required, in comparison to the accounting system, the non-federal share amounts reported were overstated for administration and understated for services. These classification discrepancies totaled several hundred thousand dollars across all three Title III-B and C grants.Cause: The Department chose to reclassify some non-federal services expenditures recorded in the accounting system as non-federal administration expenditures on the federal report.Effect: The Department?s accounting system does not support the amounts reported for non-federal administration and services expenditures. The risk of noncompliance is greater when classification discrepancies exist between amounts reported and the Department?s accounting system.Recommendation: We recommend that policies and procedures are put in place to ensure that non-federal share reported for each matching requirement is supported by and agrees to the Department?s accounting system.Prior Year Single Audit Report Finding Number: Not applicableViews of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 142.

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Federal Agency: Department of Health and Human ServicesFederal Program Title: Aging ClusterAssistance Listing: 93.044, 93.045, 93.053Federal Grant ID: 17AASCT3SS, 17AASCT3CM, 17AASCT3HDPass-Through Entity: Not applicableAward Period: October 1, 2016 through September 30, 2019Type of Finding: Significant deficiency in internal control over compliance, other mattersCriteria: Matching requirements of the program are mandated by 45 CFR ? 1321.47 as follows: The statewide non-federal share for State or area plan administration must not be less than 25 percent of the funds used under this part. All services statewide, including ombudsman services and services funded under Title III-B, C, D, E and F, must be funded on a statewide basis with a non-federal share of not less than 15 percent. Matching requirements for individual area agencies are determined by the State agency.Condition: Discrepancies existed between non-federal share amounts reported to meet matching requirements and the supporting accounting records.Questioned Costs: UnknownContext: The 2017 Title III-B and C grants, which closed during the audit period, were selected for detailed testing. While the total recipient share of expenditures reported for each grant met or exceeded the total share required, in comparison to the accounting system, the non-federal share amounts reported were overstated for administration and understated for services. These classification discrepancies totaled several hundred thousand dollars across all three Title III-B and C grants.Cause: The Department chose to reclassify some non-federal services expenditures recorded in the accounting system as non-federal administration expenditures on the federal report.Effect: The Department?s accounting system does not support the amounts reported for non-federal administration and services expenditures. The risk of noncompliance is greater when classification discrepancies exist between amounts reported and the Department?s accounting system.Recommendation: We recommend that policies and procedures are put in place to ensure that non-federal share reported for each matching requirement is supported by and agrees to the Department?s accounting system.Prior Year Single Audit Report Finding Number: Not applicableViews of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 142.

Corrective Action Plan

U.S. Department of Health and Human ServicesThe South Carolina Department on Aging respectfully submits the following corrective action plan for the year ended June 30, 2020.The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule.FINDINGS?FEDERAL AWARD PROGRAM AUDITU.S. Department of Health and Human Services2020-009 Aging Cluster ? Assistance Listing No. 93.044, 93.045, 93.053Recommendation: We recommend that policies and procedures are put in place to ensure that non-Federal share reported for each matching requirement is supported by and agrees to the Department?s accounting system.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding: Policies have been created that require all match funds recorded into the statewide accounting system have the grant number included for the transaction when recorded by SCDOA. Policy and procedures also require that the match funds reported to the federal reports be confirmed in the SCEIS system prior to filing the federal report.Name(s) of the contact person(s) responsible for corrective action: Lisa Crosby and Rhonda Walker.Planned completion date for corrective action plan: March 31, 2021If the U.S. Department of Health and Human Services has questions regarding this plan, please call Connie D. Munn at (803) 734-9910.

About Matching, Level of Effort, Earmarking →
2020-010
Activities Allowed or Unallowed / Cost Allowability
SIGNIFICANT DEFICIENCYOTHER MATTERS

An expenditure was posted to the incorrect fiscal year.Questioned Costs: NoneContext: One of thirty-two expenditures was posted to the incorrect fiscal year without being marked as a prior period expenditure.Cause: The Department's internal controls failed to detect an expenditure posted to the incorrect fiscal year.Effect: Expenditure reported incorrectly.Recommendation: We recommend that the Department strengthen internal controls regarding expenditure approval to ensure that expenditures are posted to the correct fiscal year.Prior Year Single Audit Finding Number: Not ApplicableViews of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 144.

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Federal Agency: US Department of EducationFederal Program Title: Special Education Cluster (IDEA)Assistance Listing: 84.027 and 84.173Federal Grant ID Number: H027A170081Pass-Through Entity: Not applicableAward Period: July 01, 2017 through September 30, 2019Type of Finding: Significant deficiency in internal control over compliance, other mattersCriteria: Per 2 CFR ? 200.303 Internal controls, 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 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 and the ``Internal Control Integrated Framework??, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).Condition: An expenditure was posted to the incorrect fiscal year.Questioned Costs: NoneContext: One of thirty-two expenditures was posted to the incorrect fiscal year without being marked as a prior period expenditure.Cause: The Department's internal controls failed to detect an expenditure posted to the incorrect fiscal year.Effect: Expenditure reported incorrectly.Recommendation: We recommend that the Department strengthen internal controls regarding expenditure approval to ensure that expenditures are posted to the correct fiscal year.Prior Year Single Audit Finding Number: Not ApplicableViews of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 144.

Corrective Action Plan

U.S. Department of EducationS.C. Department of Education respectfully submits the following corrective action plan for the year ended 6/30/20.The finding from the schedule of findings and questioned costs are discussed below. The finding is numbered consistently with the numbers assigned in the schedule.FINDING?FEDERAL AWARD PROGRAM AUDITDEPARTMENT OF EDUCATION2020-010 Activities Allowed or Unallowed and Allowable Costs/Cost PrinciplesSpecial Education Cluster (IDEA) ? Assistance Listing No. 84.027 and 84.173Recommendation: We recommend that the Department strengthen internal controls regarding review and approval to ensure that expenditures are recorded in the correct fiscal year.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding: The steps below should be followed all fiscal year. However, these steps are especially important as a fiscal year closes and another begins to ensure documents are classified correctly.The agency will strengthen its review of transactions to ensure all expenditures are recorded in the correct fiscal year. Each analyst will exercise greater caution when coding invoices determined to be prior year payables (PYP) (with appropriate amount indicated) as payments are entered into SCEIS. If the payments are processed via an interface, PYP should be added to the document?s text field (with appropriate amount indicated) as soon as a document number is established. Additionally, agency approvers (AP Lead and/or Managers) will review documents closely to determine if any portion (or the entire payment) should be classified as PYP prior to approval. If a document is not classified as a PYP, it will be returned to the analyst for correction prior to approval.Name(s) of the contact person(s) responsible for corrective action: Lori Dean, Fiscal Accounting ManagerPlanned completion date for corrective action plan: ImmediatelyIf the U.S. Department of Education has questions regarding this plan, please call Nancy W. Williams, CFO at 803-734-8108.

About Activities Allowed or Unallowed, Allowable Costs / Cost Principles →
2020-011
Cost Allowability
SIGNIFICANT DEFICIENCYOTHER MATTERS

Equipment was purchased and not managed in accordance with certain State procedures.Questioned Costs: UndeterminedContext: One of the disbursement transactions selected for testing included a preapproved purchase of numerous equipment items, some of which were not tracked by the Department in accordance with State policy. The amount of the equipment purchase that should have been tracked was not determined in our testing.Cause: Department controls failed to identify the purchase as equipment.Effect: Federally funded equipment was not tracked in accordance with State policy.Recommendation: We recommend that the Department implement procedures to ensure any equipment purchased with federal funding is managed in accordance with State requirements.Prior Year Single Audit Finding Number: Not applicableViews of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 146.

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Federal Agency: Department of EducationFederal Program Title: Rehabilitation Services-Vocational Rehabilitation Grants to StatesAssistance Listing No.: 84.126Federal Grant ID Number: H126A180060Pass-Through Entity: Not applicableAward Period: October 1, 2017 through September 30, 2019Type of Finding: Significant deficiency in internal control over compliance, other mattersCriteria: For costs to be allowable under federal awards, 2 CFR 200.403(c) requires that applicable policies and procedures must be applied uniformly to both federally-financed and other activities of the non-federal entity.Additionally, 2 CFR 200.313(b) requires a State to use, manage and dispose of equipment acquired under a federal award in accordance with State laws and procedures.Finally, the State of South Carolina Comptroller General?s Reporting Policies and Procedures Manual describes how equipment should be tracked for the purpose of ensuring compliance with the annual inventory requirements mandated by Section 10-1-140 of the South Carolina Code of Laws.Condition: Equipment was purchased and not managed in accordance with certain State procedures.Questioned Costs: UndeterminedContext: One of the disbursement transactions selected for testing included a preapproved purchase of numerous equipment items, some of which were not tracked by the Department in accordance with State policy. The amount of the equipment purchase that should have been tracked was not determined in our testing.Cause: Department controls failed to identify the purchase as equipment.Effect: Federally funded equipment was not tracked in accordance with State policy.Recommendation: We recommend that the Department implement procedures to ensure any equipment purchased with federal funding is managed in accordance with State requirements.Prior Year Single Audit Finding Number: Not applicableViews of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 146.

Corrective Action Plan

U.S. Department of EducationThe South Carolina Vocational Rehabilitation Department respectfully submits the following corrective action plan for the year ended June 30, 2020.The finding from the schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the numbers assigned in the schedule.FINDINGS?FEDERAL AWARD PROGRAM AUDITU.S. Department of Education2020-011 Vocational Services-Vocational Rehabilitation Grants to States ? Assistance Listing No. 84.126Recommendation: We recommend that the Department implement procedures to ensure any equipment purchased with Federal funding is managed in accordance with state requirements.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding: The Agency will review and update (as needed) existing procedures to correct this deficiency. Appropriate staff will receive additional training on the purchasing of equipment to ensure understanding of the requirement that capital assets are tagged and recorded appropriately within the system in order to meet both state and federal requirements.Appropriate staff will review shopping carts on a weekly basis to verify that all equipment purchases are recorded as defined by state and federal requirements. Adjustments will be made as necessary for those shopping carts/purchase orders that will need to be corrected. Procurement card purchases will continue to be reviewed on a monthly basis and appropriate action will take place to ensure those assets are tagged and recorded appropriately.Name of the contact person responsible for corrective action: Ryan FutralPlanned completion date for corrective action plan: 06/30/2021If the US Department of Education has questions regarding this plan, please call Breta Rheney at (803) 896-6602.

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2020-012
Matching, Level of Effort, Earmarking
SIGNIFICANT DEFICIENCYOTHER MATTERS

The Commission was not in compliance with the pre-employment transition services earmarking requirement.Questioned Costs: NoneContext: Testing of the one grant that closed during the audit period revealed that the amount charged to the grant for pre-employment transition services did not meet the fifteen percent requirement.Cause: Commission controls failed to ensure that the earmarking requirement was met prior to finalizing the grant.Effect: The Commission was not in compliance with the federal earmarking requirement.Recommendation: We recommend that the Commission implement procedures to ensure that spending requirements for pre-employment transition services are met before the grant is closed.Prior Year Single Audit Finding Number: Not applicableViews of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 147.

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Federal Agency: Department of EducationFederal Program Title: Rehabilitation Services-Vocational Rehabilitation Grants to StatesAssistance Listing No.: 84.126Federal Grant ID Number: H126A180061Pass-Through Entity: Not applicableAward Period: October 1, 2017 through September 30, 2019Type of Finding: Significant deficiency in internal control over compliance, other mattersCriteria: 29 USC 730(d)(1) requires States to reserve no less than fifteen percent of the allotted funds to be spent for the provision of pre-employment transition services.Condition: The Commission was not in compliance with the pre-employment transition services earmarking requirement.Questioned Costs: NoneContext: Testing of the one grant that closed during the audit period revealed that the amount charged to the grant for pre-employment transition services did not meet the fifteen percent requirement.Cause: Commission controls failed to ensure that the earmarking requirement was met prior to finalizing the grant.Effect: The Commission was not in compliance with the federal earmarking requirement.Recommendation: We recommend that the Commission implement procedures to ensure that spending requirements for pre-employment transition services are met before the grant is closed.Prior Year Single Audit Finding Number: Not applicableViews of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 147.

Corrective Action Plan

U.S. Department of EducationThe South Carolina Commission for the Blind respectfully submits the following corrective action plan for the year ended June 30, 2020.The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule.FINDINGS?FEDERAL AWARD PROGRAM AUDITU.S. Department of Education2020-012 Rehabilitation Services-Vocational Rehabilitation Grants to StatesAssistance Listing No.: 84.126Recommendation: We recommend that the Commission implement procedures to ensure that spending requirements for pre-employment transition services are met before the grant is closed.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding: Monthly grant expenditure reports will be completed and reviewed with management to ensure that the required expenditure level for Pre-Employment Transition Services is met before the grant is closed.Name(s) of the contact person(s) responsible for corrective action: Carrie MorrisPlanned completion date for corrective action plan: 5-1-21If the Federal Cognizant of Oversight Agency for Audit has questions regarding this plan, please call Matthew Daugherty at 803-898-8835.

About Matching, Level of Effort, Earmarking →
2020-013
Reporting
SIGNIFICANT DEFICIENCYREPEAT OF 2019-028OTHER MATTERS

Key data elements reported on the Commission's RSA-911 performance reports did not agree with underlying case records.Questioned Costs: NoneContext: Two quarterly RSA-911 reports were selected for testing and the key data elements of twenty individuals were tested from each report. Discrepancies were noted for one application date, one eligibility determination date, three IPE dates, and one hourly rate at exit.Cause: Commission controls failed to identify and correct the discrepancies noted in the RSA-911 reports prior to submission, and subsequent corrections were not possible through the RSA-911 reporting process.Effect: Some of the data fields reported in the RSA-911 are inconsistent with the applicable supporting records.Recommendation: We recommend that the Commission continue implementation of the associated corrective action plan.Prior Year Single Audit Finding Number: 2019-028Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 147.

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Federal Agency: Department of EducationFederal Program Title: Rehabilitation Services-Vocational Rehabilitation Grants to StatesAssistance Listing No.: 84.126Federal Grant ID Number: VariousPass-Through Entity: Not applicableAward Period: VariousType of Finding: Significant deficiency in internal control over compliance, other mattersCriteria: 34 CFR ?361.47 requires States to maintain a case record for each applicant and eligible individual that must include documentation to support eligibility determinations, development of an individualized plan for employment, services provided, and case closure. Much of the information contained in these case records is reported as key data elements in the Case Service Report (RSA-911).Condition: Key data elements reported on the Commission's RSA-911 performance reports did not agree with underlying case records.Questioned Costs: NoneContext: Two quarterly RSA-911 reports were selected for testing and the key data elements of twenty individuals were tested from each report. Discrepancies were noted for one application date, one eligibility determination date, three IPE dates, and one hourly rate at exit.Cause: Commission controls failed to identify and correct the discrepancies noted in the RSA-911 reports prior to submission, and subsequent corrections were not possible through the RSA-911 reporting process.Effect: Some of the data fields reported in the RSA-911 are inconsistent with the applicable supporting records.Recommendation: We recommend that the Commission continue implementation of the associated corrective action plan.Prior Year Single Audit Finding Number: 2019-028Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 147.

Corrective Action Plan

U.S. Department of EducationThe South Carolina Commission for the Blind respectfully submits the following corrective action plan for the year ended June 30, 2020.The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule.2020-013 Rehabilitation Services-Vocational Rehabilitation Grants to StatesAssistance Listing No.: 84.126Recommendation: We recommend that the Commission continue implementation of the associated corrective action plan.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding: SCCB will continue to conduct quarterly data validation reviews. Based on case file documentation, data discrepancies will be resolved prior to the submission of the RSA-911. Additional staff have been added to the QualityAssurance department to ensure expediency of identifying and resolving data discrepancies. It is to be noted that 100% accuracy of all RSA-911 data elements will not be immediately attainable. Since cases are selected randomly for testing, it is possible that cases which contained data discrepancies prior to the implementation of the correction plan (May 31, 2019) may be included in the sample set due to the length of time that a consumer can be served. In addition, several of the RSA-911 data elements which are tested cannot be resubmitted to RSA for correction.Name(s) of the contact person(s) responsible for corrective action: Shana RobinsonPlanned completion date for corrective action plan: OngoingIf the Federal Cognizant of Oversight Agency for Audit has questions regarding this plan, please call Matthew Daugherty at 803-898-8835.

Prior Finding References

2019-028

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2020-014
Reporting
SIGNIFICANT DEFICIENCYREPEAT OF 2019-029OTHER MATTERS

Discrepancies existed between federal financial reports and the Commission?s supporting records.Questioned Costs: NoneContext: The 2019 RSA-2 Annual Vocational Rehabilitation Program/Cost Report and the final SF-425 report for the 2018 grant were selected for testing. Several of the items reported in Schedules I and III of the RSA-2 report did not agree to the Commission?s supporting records. Additionally, the indirect expense base amount in the SF-425 report was not adequately supported by Commission documentation.Cause: Some of the original supporting data for the RSA-2 report was corrupted in a data loss event and the Commission was unable to reconstruct the lost data in the level of detail necessary to fully support the report. Staffing shortages and turnover also contributed to the discrepancies.Effect: Some reported information could not be verified.Recommendation: We recommend that the Commission develop and implement policies and procedures that ensure the security of all data compiled to support federal reports.Prior Year Single Audit Finding Number: 2019-029Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 148.

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Federal Agency: Department of EducationFederal Program Title: Rehabilitation Services-Vocational Rehabilitation Grants to StatesAssistance Listing No.: 84.126Federal Grant ID Number: VariousPass-Through Entity: Not applicableAward Period: VariousType of Finding: Significant deficiency in internal control over compliance, other mattersCriteria: Per 34 CFR ?361.40(a)(2), the designated State agency must comply with any requirements necessary to ensure the accuracy and verification of reports.Condition: Discrepancies existed between federal financial reports and the Commission?s supporting records.Questioned Costs: NoneContext: The 2019 RSA-2 Annual Vocational Rehabilitation Program/Cost Report and the final SF-425 report for the 2018 grant were selected for testing. Several of the items reported in Schedules I and III of the RSA-2 report did not agree to the Commission?s supporting records. Additionally, the indirect expense base amount in the SF-425 report was not adequately supported by Commission documentation.Cause: Some of the original supporting data for the RSA-2 report was corrupted in a data loss event and the Commission was unable to reconstruct the lost data in the level of detail necessary to fully support the report. Staffing shortages and turnover also contributed to the discrepancies.Effect: Some reported information could not be verified.Recommendation: We recommend that the Commission develop and implement policies and procedures that ensure the security of all data compiled to support federal reports.Prior Year Single Audit Finding Number: 2019-029Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 148.

Corrective Action Plan

U.S. Department of EducationThe South Carolina Commission for the Blind respectfully submits the following corrective action plan for the year ended June 30, 2020.The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule.2020-014 Rehabilitation Services-Vocational Rehabilitation Grants to StatesAssistance Listing No.: 84.126Recommendation: We recommend that the Commission develop and implement policies and procedures that ensure the security of all data compiled to support federal reports.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding: Procedures are being developed to ensure that reports are adequately documented and that such documentation is maintained in a secure electronic manner, including an external hard drive for large amounts of data backup. Internal controls are now in place to adequately support indirect expense base. To prevent future loss of data, supporting documentation for federal reports will be uploaded to a shared drive which will be accessible by management and staff who are directly involved with compiling data and/or reporting. In addition, an external hard drive has been obtained and will be utilized as a secondary backup in case of system failures ? e.g. server issues, network outages, etc.Name(s) of the contact person(s) responsible for corrective action: Shana Robinson and Carrie MorrisPlanned completion date for corrective action plan: 7-1-21If the Federal Cognizant of Oversight Agency for Audit has questions regarding this plan, please call Matthew Daugherty at 803-898-8835.

Prior Finding References

2019-029

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2020-015
Cash Management
SIGNIFICANT DEFICIENCYREPEAT OF 2019-030OTHER MATTERS

Cash management compliance was not documented for some drawdowns.Questioned Costs: UnknownContext: For two of three drawdowns tested, adequate documentation was not maintained to support the amount of the drawdown.Cause: The Commission had not completely implemented the corrective action associated with the finding from the prior year.Effect: The Commission may drawdown funds in excess of eligible reimbursable expenditures.Recommendation: We recommend that the Commission continue implementing the corrective action plan and strengthen the associated controls to ensure compliance is clearly documented.Prior Year Single Audit Finding Number: 2019-030Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 148.

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Federal Agency: Department of EducationFederal Program Title: Rehabilitation Services-Vocational Rehabilitation Grants to StatesAssistance Listing No.: 84.126Federal Grant ID Number: H126A180061; H126A190061Pass-Through Entity: Not applicableAward Period: October 1, 2017 through September 30, 2020Type of Finding: Significant deficiency in internal control over compliance, other mattersCriteria: 2 CFR ?200.303 requires non-federal entities to establish and maintain effective internal controls that ensure material compliance with federal statutes, regulations, and the terms and conditions of the federal awards.Condition: Cash management compliance was not documented for some drawdowns.Questioned Costs: UnknownContext: For two of three drawdowns tested, adequate documentation was not maintained to support the amount of the drawdown.Cause: The Commission had not completely implemented the corrective action associated with the finding from the prior year.Effect: The Commission may drawdown funds in excess of eligible reimbursable expenditures.Recommendation: We recommend that the Commission continue implementing the corrective action plan and strengthen the associated controls to ensure compliance is clearly documented.Prior Year Single Audit Finding Number: 2019-030Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 148.

Corrective Action Plan

U.S. Department of EducationThe South Carolina Commission for the Blind respectfully submits the following corrective action plan for the year ended June 30, 2020.The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule.2020-015 Rehabilitation Services-Vocational Rehabilitation Grants to StatesAssistance Listing No.: 84.126Recommendation: We recommend that the Commission continue implementing the corrective action plan and strengthen the associated controls to ensure compliance is clearly documented.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding: Draw documentation is now being maintained electronically to prevent data loss. There is now an approval process in place to verify the accuracy of grant drawdowns. This includes a comparison of expenses incurred to cash draw.Name(s) of the contact person(s) responsible for corrective action: Carrie MorrisPlanned completion date for corrective action plan: completedIf the Federal Cognizant of Oversight Agency for Audit has questions regarding this plan, please call Matthew Daugherty at 803-898-8835.

Prior Finding References

2019-030

About Cash Management →
2020-016
Activities Allowed or Unallowed / Cost Allowability
SIGNIFICANT DEFICIENCYOTHER MATTERS

The allocation of some compensation costs was inadequately supported or improperly applied.Questioned Costs: UnknownContext: Forty payroll disbursements were randomly selected for testing and discrepancies associated with allocation of compensation to multiple grants were identified for six employees in the test. For four of the employees, the Commission used an outdated percentage to allocate costs. For the other two employees, adequate documentation was not maintained to substantiate the allocation.Cause: Commission controls failed to prevent the identified issues, but staffing shortages and turnover during the audit period were also contributing factors.Effect: The Commission may overcharge the grant for personnel cost.Recommendation: We recommend that the Commission implement procedures which will provide assurance that personnel charges are accurate, allowable, and properly allocated to applicable grants.Prior Year Single Audit Finding Number: Not applicableViews of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 149.

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Federal Agency: Department of EducationFederal Program Title: Rehabilitation Services-Vocational Rehabilitation Grants to StatesAssistance Listing No.: 84.126Federal Grant ID Number: H126A190061Pass-Through Entity: Not applicableAward Period: October 1, 2018 through September 30, 2020Type of Finding: Significant deficiency in internal control over compliance, other mattersCriteria: 2 CFR ? 200.430 (a) states that the costs of compensation are allowable to the extent that the total compensation for individual employees is reasonable for the services rendered and conforms to the established written policy of the non-federal entity consistently applied to both federal and non-federal activities.Condition: The allocation of some compensation costs was inadequately supported or improperly applied.Questioned Costs: UnknownContext: Forty payroll disbursements were randomly selected for testing and discrepancies associated with allocation of compensation to multiple grants were identified for six employees in the test. For four of the employees, the Commission used an outdated percentage to allocate costs. For the other two employees, adequate documentation was not maintained to substantiate the allocation.Cause: Commission controls failed to prevent the identified issues, but staffing shortages and turnover during the audit period were also contributing factors.Effect: The Commission may overcharge the grant for personnel cost.Recommendation: We recommend that the Commission implement procedures which will provide assurance that personnel charges are accurate, allowable, and properly allocated to applicable grants.Prior Year Single Audit Finding Number: Not applicableViews of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 149.

Corrective Action Plan

U.S. Department of EducationThe South Carolina Commission for the Blind respectfully submits the following corrective action plan for the year ended June 30, 2020.The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule.2020-016 Rehabilitation Services-Vocational Rehabilitation Grants to StatesAssistance Listing No.: 84.126Recommendation: We recommend that the Commission implement procedures which will provide assurance that personnel charges are accurate, allowable, and properly allocated to applicable grants.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding: The Commission will implement procedures to properly allocate charges to the applicable grants, including the use of consumer counts and other appropriate allocation methods.Name(s) of the contact person(s) responsible for corrective action: Carrie MorrisPlanned completion date for corrective action plan: 7-1-21If the Federal Cognizant of Oversight Agency for Audit has questions regarding this plan, please call Matthew Daugherty at 803-898-8835.

About Activities Allowed or Unallowed, Allowable Costs / Cost Principles →
2020-017
Activities Allowed or Unallowed / Cost Allowability
SIGNIFICANT DEFICIENCYQUESTIONED COSTSOTHER MATTERS

The Commission?s internal control procedures for disbursements were not documented consistently and an overpayment was noted for one non-payroll disbursement tested.Questioned Costs: $64Context: While compensating controls were identified, there was inadequate evidence of proper approval for thirty of the eighty-one non-payroll disbursements selected for testing. For one of these payments, it was also noted that the amount paid exceeded the maximum amount allowed by Commission policy.Cause: The Commission failed to retain documentation demonstrating performance of their internal control process, established during a period of staffing shortages and turnover.Effect: The Commission did not maintain adequate documentation to demonstrate compliance with its own control procedures.Recommendation: We recommend that the Commission properly document all control procedures.Prior Year Single Audit Finding Number: Not applicableViews of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 149.

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Federal Agency: Department of EducationFederal Program Title: Rehabilitation Services-Vocational Rehabilitation Grants to StatesAssistance Listing No.: 84.126Federal Grant ID Number: H126A180061; H126A190061Pass-Through Entity: Not applicableAward Period: October 1, 2017 through September 30, 2020Type of Finding: Significant deficiency in internal control over compliance, other mattersCriteria: 2 CFR ?200.303 requires non-federal entities to establish and maintain effective internal controls that ensure material compliance with federal statutes, regulations, and the terms and conditions of the federal awards.Condition: The Commission?s internal control procedures for disbursements were not documented consistently and an overpayment was noted for one non-payroll disbursement tested.Questioned Costs: $64Context: While compensating controls were identified, there was inadequate evidence of proper approval for thirty of the eighty-one non-payroll disbursements selected for testing. For one of these payments, it was also noted that the amount paid exceeded the maximum amount allowed by Commission policy.Cause: The Commission failed to retain documentation demonstrating performance of their internal control process, established during a period of staffing shortages and turnover.Effect: The Commission did not maintain adequate documentation to demonstrate compliance with its own control procedures.Recommendation: We recommend that the Commission properly document all control procedures.Prior Year Single Audit Finding Number: Not applicableViews of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 149.

Corrective Action Plan

U.S. Department of EducationThe South Carolina Commission for the Blind respectfully submits the following corrective action plan for the year ended June 30, 2020.The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule.2020-017 Rehabilitation Services-Vocational Rehabilitation Grants to StatesAssistance Listing No.: 84.126Recommendation: We recommend that the Commission properly document all control procedures.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding: The Commission has new policies and procedures in place for all case service expenditures and other direct payments. These include new authorization approval processes in our case management system (AWARE) and new approval forms for non case service expenditures. This allows for a more efficient and thorough documentation review in the approval process.Name(s) of the contact person(s) responsible for corrective action: Carrie MorrisPlanned completion date for corrective action plan: completedIf the Federal Cognizant of Oversight Agency for Audit has questions regarding this plan, please call Matthew Daugherty at 803-898-8835.

About Activities Allowed or Unallowed, Allowable Costs / Cost Principles →
2020-018
Activities Allowed or Unallowed / Cost Allowability
SIGNIFICANT DEFICIENCYQUESTIONED COSTSOTHER MATTERS

Funding information on agency approved Personnel Action Form did not agree to selected SCEIS Remuneration Statement and SCEIS Labor Distribution Report data. Additionally, excess overtime costs, resulting from employee work outside the program, were charged to program grants.Questioned Costs: $309Context: Information on agency approved Personnel Action Forms did not agree to selected SCEIS Remuneration Statement and SCEIS Labor Distribution Report data for one of forty tested employees. Additionally, for one of forty tested employees, hours worked outside the program resulted in excess overtime costs of $309 being charged to program grants.Cause: State Personnel Action Forms for program employees are not adequately reviewed on a routine basis. Additionally, SCEIS payroll system assigned all overtime costs to employee?s primary funding stream (non-program hours were entered manually by agency human resource personnel).Effect: The Office is not in compliance with applicable activities/costs requirements. Program expenditures may be overstated.Recommendation: We recommend that the Office implement policies and procedures to ensure that review of documentation related to program employee salaries occurs and is documented on a regular basis, and that hours for work outside the program completed by program employees and all resulting costs are reviewed for impact on program expenditures.Prior Year Single Audit Finding Number: Not applicableViews of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 150.

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Federal Agency: Department of DefenseFederal Program Title: National Guard Military Operations and Maintenance (O&M) ProjectsAssistance Listing No.: 12.401Federal Grant ID Number: W912QG-20-2-1001, W912QG-20-2-1021Pass-Through Entity: Not applicableAward Period: October 1, 2019 through September 30, 2020Type of Finding: Significant deficiency in internal control over compliance, other mattersCriteria: Per 2 CFR ? 200.430 (a) Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-federal entity consistently applied to both federal and non-federal activities; (2) Follows an appointment made in accordance with a non-federal entity's laws and/or rules or written policies and meets the requirements of federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, Standards for Documentation of Personnel Expenses, when applicable.Condition: Funding information on agency approved Personnel Action Form did not agree to selected SCEIS Remuneration Statement and SCEIS Labor Distribution Report data. Additionally, excess overtime costs, resulting from employee work outside the program, were charged to program grants.Questioned Costs: $309Context: Information on agency approved Personnel Action Forms did not agree to selected SCEIS Remuneration Statement and SCEIS Labor Distribution Report data for one of forty tested employees. Additionally, for one of forty tested employees, hours worked outside the program resulted in excess overtime costs of $309 being charged to program grants.Cause: State Personnel Action Forms for program employees are not adequately reviewed on a routine basis. Additionally, SCEIS payroll system assigned all overtime costs to employee?s primary funding stream (non-program hours were entered manually by agency human resource personnel).Effect: The Office is not in compliance with applicable activities/costs requirements. Program expenditures may be overstated.Recommendation: We recommend that the Office implement policies and procedures to ensure that review of documentation related to program employee salaries occurs and is documented on a regular basis, and that hours for work outside the program completed by program employees and all resulting costs are reviewed for impact on program expenditures.Prior Year Single Audit Finding Number: Not applicableViews of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 150.

Corrective Action Plan

The South Carolina Office of the Adjutant General respectfully submits the following Corrective Action Plan for the year ended 6/30/20.The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule.FINDINGS?FEDERAL AWARD PROGRAM AUDITDepartment of Defense2020-018 National Guard Military Operations and Maintenance (O&M) Projects ? Assistance Listing No. 12.401Recommendation: We recommend that the Office implement policies and procedures to ensure that review of documentation related to program employee salaries occurs and is documented on a regular basis, and that hours for work outside the program completed by program employees and all resulting costs are reviewed for impact on program expenditures.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding:The Agency?s State Human Resources Office (SHRO) will conduct of an Agency-wide internal audit of all State employee salaries and expenditures to validate the information in SCEIS against the information contained on the Personnel Action Request (PAR) forms in the employee files. Implementation will begin immediately and will be completed by 1 June 2021. SHRO will also initiate a Standard Operating Procedure (SOP) starting in July 2021 to conduct quarterly checks of twenty-five percent (25%) of Agency employees SCEIS information against their PARS in their files.Beginning immediately, when SHRO receives a request for overtime expenditures for program employees, SHRO will conduct an audit to determine the purpose of the overtime. If SHRO determines the employee?s overtime is outside program expenditures, SHRO will notify the Budget/Finance and Agreements sections to initiate an Journal Entry to move the costs to the correct cost center and to ensure the costs are either not reimbursed by the Federal program or that the Federal program is provided the appropriate credit.Name(s) of the contact person(s) responsible for corrective action: Robert FaulkPlanned completion date for corrective action plan: June 01, 2021If the U.S. Department of Defense has questions regarding this plan, please contact COL Kenneth C. Braddock, USA Retired, Chief of Staff for State Operations, at 803-299-4445 or braddockk@tag.scmd.state.sc.us.

About Activities Allowed or Unallowed, Allowable Costs / Cost Principles →
2020-019
Cash Management
MATERIAL WEAKNESSMODIFIED OPINION

Advanced funds for three transactions were not expended within the required timeframe to minimize the time elapsing between drawdown and disbursement.Questioned Costs: None.Context: For three of forty-three tested transactions, advanced funds drawn exceeded the subsequent forty-five days of expenditures.Cause: SF-270 Report and supporting information were not adequately reviewed to ensure the proper amount of advance funds were requested in order to be expended within forty-five days. Internal controls over cash advances are inadequate.Effect: The Office may not expend advanced funds in a timely manner in accordance with program regulations.Recommendation: We recommend the Office implement and/or strengthen existing policies and procedures to ensure that advanced funds are expended in a timely manner in accordance with NGR 5-1, Chapter 11-5.Prior Year Single Audit Finding Number: Not applicableViews of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 151.

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Federal Agency: Department of DefenseFederal Program Title: National Guard Military Operations and Maintenance (O&M) ProjectsAssistance Listing No.: 12.401Federal Grant ID Number: W912QG-20-2-1001, W912QG-20-2-1002Pass-Through Entity: Not applicableAward Period: October 1, 2019 through September 30, 2020Type of Finding: Material weakness in internal control over compliance, material noncomplianceCriteria: Per National Guard Regulation (NGR) 5-1, Chapter 11-5, the grantee agrees to minimize the time elapsing between the transfer of funds from the U.S. Treasury and their disbursement by the State (no more than forty-five days).Condition: Advanced funds for three transactions were not expended within the required timeframe to minimize the time elapsing between drawdown and disbursement.Questioned Costs: None.Context: For three of forty-three tested transactions, advanced funds drawn exceeded the subsequent forty-five days of expenditures.Cause: SF-270 Report and supporting information were not adequately reviewed to ensure the proper amount of advance funds were requested in order to be expended within forty-five days. Internal controls over cash advances are inadequate.Effect: The Office may not expend advanced funds in a timely manner in accordance with program regulations.Recommendation: We recommend the Office implement and/or strengthen existing policies and procedures to ensure that advanced funds are expended in a timely manner in accordance with NGR 5-1, Chapter 11-5.Prior Year Single Audit Finding Number: Not applicableViews of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 151.

Corrective Action Plan

The South Carolina Office of the Adjutant General respectfully submits the following Corrective Action Plan for the year ended 6/30/20.The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule.U.S. Department of Defense2020-019 National Guard Military Operations and Maintenance (O&M) Projects ? Assistance Listing No. 12.401Recommendation: We recommend the Office implement and/or strengthen existing policies and procedures to ensure that advanced funds are expended in a timely manner in accordance with NGR 5-1, Chapter 11-5.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding:In October 2020 after the end of the 2020 Federal Fiscal Year (FFY), the State Cooperative Agreements Grants Management Section and the Grants Officer Representative (GOR) from the US Property and Fiscal Officer (USPFO) met to review and revise the SOP-Draw of Federal Funds for the Reports used in Support of Processing of Advances (Draws) in response to shortcomings identified during FFY 2020. As the result of this meeting, the following changes have already been put into place:? The State Cooperative Agreements Grants Management Section updated the SOP ?Draw of Federal Funds for the Reports used in Support of Processing of Advances (Draws)?.? Beginning in FFY 2021, the State Cooperative Agreements Grants Management Section developed a report to show the estimated balance of Federal cash on hand as of the beginning of each advance period. The report provides specific details for the computation of each estimated balance of Federal cash on hand for each Appendix for each Advance SF270. Only the dollar amount of the estimated balance of Federal cash on hand at the beginning of the advance period is listed in the ?Comments? block on the actual SF270 form.? The State Cooperative Agreements Grants Management Section created a report with specific details for the computation of each advance Federal funding amount requested for each Appendix for each Advance SF270.Beginning NLT March 31, 2021, the State Cooperative Agreements Grants Management Section will:? Submit the estimated balance of Federal cash on hand report and the specific details for the computation of each advance Federal funding for review by the Chief of Finance for State Operations, the GOR, and the Program Manager or Program Manager?s designee before the Advance SF270 is generated.? Create a report to track the amount of the expenditures which have posted in SCEIS since the beginning date for each Advance SF270 for each Appendix to ensure advance funds are expended in a timely manner in accordance with NGR 5-1, Chapter 11-5. The State Cooperative Agreements Grants Management Section update and submit the expenditure report on a weekly basis to the Chief of Staff for State Operations, the Chief of Finance for State Operations, the Grants Office Representative (GOR), the Federal Budget Analysts, and the Federal Program Managers.The Agency would like to point out the significant impact that COVID had on the Agency and the management of Federal advance funds specifically in the area of Facilities Management. In March 2020, Appendix 1 (ARNG Facilities Programs) requested and drew $2M in Federal advance funds based on the anticipated approvals of planned construction projects by the SC Legislature?s Joint Bond Review Committee (JBRC). Due to the effects of COVID-19, the JBRC postponed its March meeting until April. In April, the JBRC cancelled its meeting with the intent to meet in May. The JBRC finally met in June. Unfortunately, due to the timelines required for the Phase I construction projects, the planned monies could not be executed within the time constraints of the FFY. The Facilities Construction Office attempted to redirect the funds but was not able to obtain the necessary approvals from National Guard Bureau resulting in the State having to return those funds to the Federal Treasury.Name(s) of the contact person(s) responsible for corrective action: Alex CountsPlanned completion date for corrective action plan: March 31, 2021If the U.S. Department of Defense has questions regarding this plan, please contact COL Kenneth C. Braddock, USA Retired, Chief of Staff for State Operations, at 803-299-4445 or braddockk@tag.scmd.state.sc.us.

About Cash Management →
2020-020
Period of Performance
SIGNIFICANT DEFICIENCYOTHER MATTERS

Expenditures were incurred prior to the start of the program?s grant period of performance. Additionally, expenditures that occurred beyond ninety days after the close of the Federal Fiscal Year (FFY) were not included on the detailed listing of unliquidated claims and undisbursed obligations.Questioned Costs: UndeterminedContext: One of eight tested expenditure transactions for costs recorded during the first period of FFY20 program grants were incurred prior to the start of the grant?s period of performance (October 1, 2019). Additionally, three of forty tested expenditure transactions recorded to program grants beyond 90 days after the close of the FFY were not included on the detailed listing of unliquidated claims and undisbursed obligations.Cause: Transactions were not adequately reviewed to ensure expenditures occurred during period of performance, and were included on the detailed listing of unliquidated claims and undisbursed obligations when necessary.Effect: Expenditures may be charged to program grants outside of the period of performance.Recommendation: We recommend that the Office strengthen its internal controls to ensure that awarded funds are expended within the award's period of performance and/or listed on the detailed listing of unliquidated claims and undisbursed obligations when necessary.Prior Year Single Audit Finding Number: Not applicableViews of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 153.

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Federal Agency: Department of DefenseFederal Program Title: National Guard Military Operations and Maintenance (O&M) ProjectsAssistance Listing No.: 12.401Federal Grant ID Number: W912QG-20-2-1001; W912QG-18-2-1001Pass-Through Entity: Not applicableAward Period: October 1, 2019 through September 30, 2020; October 1, 2017 through September 30, 2018Type of Finding: Significant deficiency in internal control over compliance, other mattersCriteria: 2 CFR 200.309 states that a non-federal entity may charge to the federal award only allowable costs incurred during the period of performance (except as described in?200.461 Publication and printing costs) and any costs incurred before the federal awarding agency or pass-through entity made the federal award that were authorized by the federal awarding agency or pass-through entity. NGR 5-1, Chapter 11-10 requires the recipient provide a detailed listing of unliquidated claims and undisbursed obligations that will remain 90 days after the close of the federal fiscal year. Costs incurred in a federal fiscal year which are not disclosed by the recipient within 90 days of the end of the federal fiscal year, except costs associated with unliquidated claims and undisbursed obligations that the recipient has reported, shall not be eligible for reimbursement.Condition: Expenditures were incurred prior to the start of the program?s grant period of performance. Additionally, expenditures that occurred beyond ninety days after the close of the Federal Fiscal Year (FFY) were not included on the detailed listing of unliquidated claims and undisbursed obligations.Questioned Costs: UndeterminedContext: One of eight tested expenditure transactions for costs recorded during the first period of FFY20 program grants were incurred prior to the start of the grant?s period of performance (October 1, 2019). Additionally, three of forty tested expenditure transactions recorded to program grants beyond 90 days after the close of the FFY were not included on the detailed listing of unliquidated claims and undisbursed obligations.Cause: Transactions were not adequately reviewed to ensure expenditures occurred during period of performance, and were included on the detailed listing of unliquidated claims and undisbursed obligations when necessary.Effect: Expenditures may be charged to program grants outside of the period of performance.Recommendation: We recommend that the Office strengthen its internal controls to ensure that awarded funds are expended within the award's period of performance and/or listed on the detailed listing of unliquidated claims and undisbursed obligations when necessary.Prior Year Single Audit Finding Number: Not applicableViews of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 153.

Corrective Action Plan

The South Carolina Office of the Adjutant General respectfully submits the following Corrective Action Plan for the year ended 6/30/20.The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule.U.S. Department of Defense2020-020 National Guard Military Operations and Maintenance (O&M) Projects ? Assistance Listing No. 12.401Recommendation: We recommend that the Office strengthen its internal controls to ensure that awarded funds are expended within the award's period of performance and/or listed on the detailed listing of unliquidated claims and undisbursed obligations when necessary.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding:Federal Program Managers or their designees submit a cash requirements statements to the State Cooperative Agreements Grants Management Section by the 10th working day of each month for their plan to expend the amount of their federal funding during the period of performance. In the future, the State Cooperative Agreements Grants Management Section will provide additional information to the Federal Program Managers and Federal Program Managers? designees to strengthen and improve the accuracy and details of the cash requirements statements.The State Cooperative Agreements Grants Management Section will create a detailed listing of unliquidated claims and undisbursed obligations and submit the report monthly to the Federal Program Managers and Federal Program Managers? designees. The detailed listing will be reviewed by the Chief of Finance for State Operations and the State Director of Procurement before submission to the Federal Program Managers and Federal Program Managers? designees.State Operations will implement a procedure for the review of posting of all transactions in SCEIS to ensure the transactions are not charged to program grants outside of the period of performance.Name(s) of the contact person(s) responsible for corrective action: Alex CountsPlanned completion date for corrective action plan: March 31, 2021If the U.S. Department of Defense has questions regarding this plan, please contact COL Kenneth C. Braddock, USA Retired, Chief of Staff for State Operations, at 803-299-4445 or braddockk@tag.scmd.state.sc.us.

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2020-021
Reporting
SIGNIFICANT DEFICIENCYOTHER MATTERS

Total program expenditures reported on final reports did not agree to SCEIS accounting records.Questioned Costs: None.Context: For all three final reports tested, the reported total expenditure amount was not supported by SCEIS data. The total variance between the reports and SCEIS data was $13,555.Cause: SF-270 Report, Grant Close-Out Report, and supporting information were not adequately reviewed to ensure that total reported expenditures were complete, accurate, and agreed to accounting records.Effect: Accounting records do not accurately reflect program expenditures; program expenditures for impacted grants may be misstated.Recommendation: We recommend the Office strengthen its internal controls to ensure that the total reported expenditures for program grants agree to underlying accounting data (SCEIS).Prior Year Single Audit Finding Number: Not ApplicableViews of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 154.

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Federal Agency: Department of DefenseFederal Program Title: National Guard Military Operations and Maintenance (O&M) ProjectsAssistance Listing No.: 12.401Federal Grant ID Number: W912QG-18-2-1002, W912QG-18-2-1021, W912QG-19-2-1007Pass-Through Entity: Not applicableAward Period: October 1, 2017 through September 30, 2018 and October 1, 2018 through September 30, 2019Type of Finding: Significant deficiency in internal control over compliance, other mattersCriteria: Per 2 CFR ? 200.303 Internal controls, 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 and the "Internal Control Integrated Framework", issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).Condition: Total program expenditures reported on final reports did not agree to SCEIS accounting records.Questioned Costs: None.Context: For all three final reports tested, the reported total expenditure amount was not supported by SCEIS data. The total variance between the reports and SCEIS data was $13,555.Cause: SF-270 Report, Grant Close-Out Report, and supporting information were not adequately reviewed to ensure that total reported expenditures were complete, accurate, and agreed to accounting records.Effect: Accounting records do not accurately reflect program expenditures; program expenditures for impacted grants may be misstated.Recommendation: We recommend the Office strengthen its internal controls to ensure that the total reported expenditures for program grants agree to underlying accounting data (SCEIS).Prior Year Single Audit Finding Number: Not ApplicableViews of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 154.

Corrective Action Plan

The South Carolina Office of the Adjutant General respectfully submits the following Corrective Action Plan for the year ended 6/30/20.The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule.U.S. Department of Defense2020-021 National Guard Military Operations and Maintenance (O&M) Projects ? Assistance Listing No. 12.401Recommendation: We recommend the Office strengthen its internal controls to ensure that the total reported expenditures for program grants agree to underlying accounting data (SCEIS).Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding:The Chief of Finance for State Operations has revised the procedures and the deadlines for tasks on the monthly checklists for State Operations. One task for the State Cooperative Agreements Grants Management Section is to ensure all SCEIS postings for the month are correct for the O&M programs. If a posting is identified as incorrect, the State Cooperative Agreements Grants Management Section will create a journal entry to correct the posting in SCEIS. The State Cooperative Agreements Grants Management Section will complete all necessary corrective journal entries on a monthly basis. Once the State Cooperative Agreements Grants Management Section creates a final SF270 for each program grant, all of the necessary corrective journal entries should have been completed.If additional corrective journal entries are needed, the State Cooperative Agreements Grants Management Section will complete the necessary journal entries and post in SCEIS before the final SF270 is completed and submitted for approval by the Chief of Finance for State Operations and the Federal Program Manager. The State Cooperative Agreements Grants Management Section will generate SCEIS reports and submit the reports with each final SF270 to ensure the total reported expenditures for program grants posted in SCEIS agree with the total reported expenditures for the program grants on each final SF270.Name(s) of the contact person(s) responsible for corrective action: Alex CountsPlanned completion date for corrective action plan: March 31, 2021If the U.S. Department of Defense has questions regarding this plan, please contact COL Kenneth C. Braddock, USA Retired, Chief of Staff for State Operations, at 803-299-4445 or braddockk@tag.scmd.state.sc.us.

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2020-022
Activities Allowed or Unallowed / Cost Allowability
MATERIAL WEAKNESSREPEAT OF 2019-018OTHER MATTERS

The Department did not have adequate controls in place to ensure timesheets were properly completed and reviewed by a supervisor, maintained by the agency and that the time and effort documentation agreed to salary allocations in the accounting system.Questioned Costs: UnknownContext: For 18 out of 60 paychecks tested, there were multiple instances where the time and effort documentation was either missing, did not contain all the required signatures, or there were discrepancies between the grant percentages from the time and effort documentation and the funding percentages paid in the accounting system.This is a repeat finding from the FY19 Single Audit. The Department stated on its Summary Schedule of Prior Year Audit Findings that this issue was ?Fully Corrected with Previously Reported Corrective Action Implemented?. Due to this issue repeating for FY20, this issue has not been fully corrected.Cause: Department controls failed to prevent the identified issues. Additionally, management prepared funding allocation spreadsheets to override the allocations based on the employee time and effort records.Effect: The Department is not in compliance with applicable allowable activities/costs requirements.Recommendation: We recommend the Department implement policies and procedures to ensure time and effort reports are properly completed, reviewed, and maintained.We also recommend the Department ensure the accounting system accurately reports actual time worked.Prior Year Single Audit Finding Number: 2019-018Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 155.

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Federal Agency: Department of Health and Human ServicesFederal Program Title: Prevention and Treatment of Substance AbuseAssistance Listing No.: 93.959Federal Grant ID Number: 3B08TI010048-19S2, 6B08TI083037-01M002Pass-Through Entity: Not applicableAward Period: October 1, 2018 through September 30, 2021Type of Finding: Material weakness in internal control over compliance, other mattersCriteria: Per 2 CFR ? 200.430 (a) Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-federal entity consistently applied to both federal and non-federal activities; (2) Follows an appointment made in accordance with a non-federal entity?s laws and/or rules or written policies and meets the requirements of federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, Standards for Documentation of Personnel Expenses, when applicable.Condition: The Department did not have adequate controls in place to ensure timesheets were properly completed and reviewed by a supervisor, maintained by the agency and that the time and effort documentation agreed to salary allocations in the accounting system.Questioned Costs: UnknownContext: For 18 out of 60 paychecks tested, there were multiple instances where the time and effort documentation was either missing, did not contain all the required signatures, or there were discrepancies between the grant percentages from the time and effort documentation and the funding percentages paid in the accounting system.This is a repeat finding from the FY19 Single Audit. The Department stated on its Summary Schedule of Prior Year Audit Findings that this issue was ?Fully Corrected with Previously Reported Corrective Action Implemented?. Due to this issue repeating for FY20, this issue has not been fully corrected.Cause: Department controls failed to prevent the identified issues. Additionally, management prepared funding allocation spreadsheets to override the allocations based on the employee time and effort records.Effect: The Department is not in compliance with applicable allowable activities/costs requirements.Recommendation: We recommend the Department implement policies and procedures to ensure time and effort reports are properly completed, reviewed, and maintained.We also recommend the Department ensure the accounting system accurately reports actual time worked.Prior Year Single Audit Finding Number: 2019-018Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 155.

Corrective Action Plan

SOUTH CAROLINA DEPARTMENT OF ALCOHOL AND OTHER DRUG ABUSE SERVICES CORRECTIVE ACTION PLAN ? YEAR ENDED JUNE 30, 2020U.S. Department of Health and Human ServicesThe South Carolina Department of Alcohol and Other Drug Abuse Services (DAODAS) respectfully submits the following corrective action plan for the year ended 6/30/20.The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered in accordance with the numbers assigned in the schedule.FINDINGS ? FEDERAL AWARD PROGRAM AUDITU.S. Department of Health and Human Services2020-022 Prevention and Treatment of Substance Abuse ? Assistance Listing No. 93.959Recommendation: We recommend the Department implement policies and procedures to ensure time and effort reports are properly completed, reviewed, and maintained. We also recommend the Department ensure the accounting system accurately reports actual time worked.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding: DAODAS plans to implement a more comprehensive control of Time & Effort allocations to include the following: The Human Resources (HR) Manager will send a monthly reminder to all staff with the current funding sources. Time & Effort sheets must be sent to all managers by the 5th working day of the month. Managers must review time sheets for correct allocations and ensure both signatures are applied. Once approved and signed, a copy must be stored in a designated location and sent to the HR Manager.Name(s) of the contact person(s) responsible for corrective action: Sharon Peterson and Angela OutingPlanned completion date for corrective action plan: Effective April 1, 2021If the U.S. Department of Health and Human Services has questions regarding this plan, please call Sharon Peterson at 803-896-1145.

Prior Finding References

2019-018

About Activities Allowed or Unallowed, Allowable Costs / Cost Principles →
2020-023
Subrecipient Monitoring
SIGNIFICANT DEFICIENCYREPEAT OF 2019-017OTHER MATTERS

The Department communicated grant and program information to each subrecipient annually through a standardized contracting agreement; however, not all of the required information was included in the agreement.Questioned Costs: NoneContext: For eight of eight subrecipients tested for the Prevention and Treatment of Substance Abuse program and for six of six subrecipients tested for the Strategic Targeted Response Opioid Crisis Grant program, the subaward documents did not include all of the information required by 2 CFR 200.331(a).This is a repeat finding from the FY19 Single Audit. Due to a timing issue on implementation of corrective action, we reviewed subawards made after January 2020 and still noted missing elements on the agreements. The Department stated on its Summary Schedule of Prior Year Audit Findings that this issue was ?Fully Corrected with Previously Reported Corrective Action Implemented?. Due to this issue repeating for FY20, this issue has not been fully corrected.Cause: The Department?s internal controls failed to ensure adequate communication to the subrecipients through the annual subaward process as required by federal regulations.Effect: The Department is not in compliance with federal subrecipient monitoring requirements.Recommendation: We recommend the Department update its subrecipient agreements to incorporate all required information to ensure adequate communication to subrecipients and to ensure compliance with federal requirements.Prior Year Single Audit Finding Number: 2019-017 (Assistance Listing No. 93.959 only)Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 155.

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Federal Agency: Department of Health and Human ServicesFederal Program Title: Strategic Targeted Response Opioid Crisis Grant; Prevention and Treatment of Substance AbuseAssistance Listing No.: 93.788; 93.959Federal Grant ID Number: VariousPass-Through Entity: Not applicableAward Period: October 1, 2018 through September 30, 2021Type of Finding: Significant deficiency in internal control over compliance, other mattersCriteria: Per 2 CFR ?331 All pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes all of the information required by 2 CFR 331(a)(1)(i-xiii) at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the federal award and subaward.Condition: The Department communicated grant and program information to each subrecipient annually through a standardized contracting agreement; however, not all of the required information was included in the agreement.Questioned Costs: NoneContext: For eight of eight subrecipients tested for the Prevention and Treatment of Substance Abuse program and for six of six subrecipients tested for the Strategic Targeted Response Opioid Crisis Grant program, the subaward documents did not include all of the information required by 2 CFR 200.331(a).This is a repeat finding from the FY19 Single Audit. Due to a timing issue on implementation of corrective action, we reviewed subawards made after January 2020 and still noted missing elements on the agreements. The Department stated on its Summary Schedule of Prior Year Audit Findings that this issue was ?Fully Corrected with Previously Reported Corrective Action Implemented?. Due to this issue repeating for FY20, this issue has not been fully corrected.Cause: The Department?s internal controls failed to ensure adequate communication to the subrecipients through the annual subaward process as required by federal regulations.Effect: The Department is not in compliance with federal subrecipient monitoring requirements.Recommendation: We recommend the Department update its subrecipient agreements to incorporate all required information to ensure adequate communication to subrecipients and to ensure compliance with federal requirements.Prior Year Single Audit Finding Number: 2019-017 (Assistance Listing No. 93.959 only)Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 155.

Corrective Action Plan

SOUTH CAROLINA DEPARTMENT OF ALCOHOL AND OTHER DRUG ABUSE SERVICES CORRECTIVE ACTION PLAN ? YEAR ENDED JUNE 30, 2020U.S. Department of Health and Human ServicesThe South Carolina Department of Alcohol and Other Drug Abuse Services (DAODAS) respectfully submits the following corrective action plan for the year ended 6/30/20.The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered in accordance with the numbers assigned in the schedule.2020-023 Prevention and Treatment of Substance Abuse, Strategic Targeted Response Opioid Crisis Grant ? Assistance Listing Nos. 93.959, 93.788Recommendation: We recommend the Department update its subrecipient agreements to incorporate all required information to ensure adequate communication to subrecipients and to ensure compliance with Federal requirements.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding: DAODAS will ensure all new sub-awards granted on or after April 1, 2021, include all applicable requirements as detailed in 2 CFR 200.331(a)(1).Name(s) of the contact person(s) responsible for corrective action: Sharon Peterson, Hannah Bonsu, Michelle Nienhius, and David CollierPlanned completion date for corrective action plan: April 1, 2021If the U.S. Department of Health and Human Services has questions regarding this plan, please call Sharon Peterson at 803-896-1145.

Prior Finding References

2019-017

About Subrecipient Monitoring →
2020-024
Reporting
SIGNIFICANT DEFICIENCYOTHER MATTERS

Financial reports were not reviewed by an employee other than the report preparer prior to submission.Questioned Costs: NoneContext: We tested the sole SF-425 reports submitted during fiscal year 2020 for both grant programs and noted that the reports were not reviewed by an individual separate from the preparer prior to submission.Cause: Department personnel stated there was a new reporting process whereby the reports were completed and submitted online. They did not update their internal control process to ensure that a supervisory review of the report was performed.Effect: Without supervisory review, there is an increased possibility of inaccurate reporting.Recommendation: We recommend the Department strengthen controls to ensure that reports are properly reviewed by supervisory personnel before submission.Prior Year Single Audit Finding Number: Not applicableViews of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 156.

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Federal Agency: Department of Health and Human ServicesFederal Program Title: Strategic Targeted Response Opioid Crisis Grant; Prevention and Treatment of Substance AbuseAssistance Listing No.: 93.788; 93.959Federal Grant ID Number: 3B08TI010048-18S1, 6H79TI081720-01M002 and 3H79TI081720-01S1Pass-Through Entity: Not applicableAward Period: October 1, 2017 through September 30, 2021Type of Finding: Significant deficiency in internal control over compliance, other mattersCriteria: Per 2 CFR ? 200.303 Internal controls, 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 and the ``Internal Control Integrated Framework??, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).Condition: Financial reports were not reviewed by an employee other than the report preparer prior to submission.Questioned Costs: NoneContext: We tested the sole SF-425 reports submitted during fiscal year 2020 for both grant programs and noted that the reports were not reviewed by an individual separate from the preparer prior to submission.Cause: Department personnel stated there was a new reporting process whereby the reports were completed and submitted online. They did not update their internal control process to ensure that a supervisory review of the report was performed.Effect: Without supervisory review, there is an increased possibility of inaccurate reporting.Recommendation: We recommend the Department strengthen controls to ensure that reports are properly reviewed by supervisory personnel before submission.Prior Year Single Audit Finding Number: Not applicableViews of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 156.

Corrective Action Plan

SOUTH CAROLINA DEPARTMENT OF ALCOHOL AND OTHER DRUG ABUSE SERVICES CORRECTIVE ACTION PLAN ? YEAR ENDED JUNE 30, 2020U.S. Department of Health and Human ServicesThe South Carolina Department of Alcohol and Other Drug Abuse Services (DAODAS) respectfully submits the following corrective action plan for the year ended 6/30/20.The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered in accordance with the numbers assigned in the schedule.2020-024 Prevention and Treatment of Substance Abuse, Strategic Targeted Response Opioid Crisis Grant ? Assistance Listing Nos. 93.959, 93.788Recommendation: We recommend the Department strengthen controls to ensure that reports are properly reviewed by supervisory personnel before submission.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding: The Manager of Finance and Operations will review and approve quarterly or annual federal reports prior to report submission. This approval may be in the form of an e-mail to proceed or actual signing of a paper copy.Name(s) of the contact person(s) responsible for corrective action: Sharon Peterson and Tina NicholsPlanned completion date for corrective action plan: Effective April 1, 2021If the U.S. Department of Health and Human Services has questions regarding this plan, please call Sharon Peterson at 803-896-1145.

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2020-025
Reporting
SIGNIFICANT DEFICIENCYOTHER MATTERS

Certain information reported on the Performance Progress Report (PPR) did not agree to supporting documentation provided by the Department.Questioned Costs: NoneContext: We tested the PPR submission that was due on December 31, 2019 to ensure the reasonableness and accuracy of the report and were unable to verify the information reported in sections 1 through 4.Cause: Department personnel did not retain documentation to support information reported on the PPR.Effect: The Department may report incorrect information to the Substance Abuse and Mental Health Services Administration (SAMHSA), an operating division of the Department of Health and Human Services (HHS).Recommendation: We recommend the Department strengthen controls to ensure information reported to the SAMHSA is accurate and properly supported by documentation.Prior Year Single Audit Finding Number: Not applicableViews of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 156.

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Federal Agency: Department of Health and Human ServicesFederal Program Title: Opioid STRAssistance Listing No.: 93.788Federal Grant ID Number: 6H79TI081720-01M002 and 3H79TI081720-01S1Pass-Through Entity: Not applicableAward Period: October 1, 2018 through September 30, 2021Type of Finding: Significant deficiency in internal control over compliance, other mattersCriteria: Per 2 CFR ? 200.333, financial records, supporting documents, statistical records, and all other non-federal entity records pertinent to a federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the federal awarding agency or pass-through entity in the case of a subrecipient.Condition: Certain information reported on the Performance Progress Report (PPR) did not agree to supporting documentation provided by the Department.Questioned Costs: NoneContext: We tested the PPR submission that was due on December 31, 2019 to ensure the reasonableness and accuracy of the report and were unable to verify the information reported in sections 1 through 4.Cause: Department personnel did not retain documentation to support information reported on the PPR.Effect: The Department may report incorrect information to the Substance Abuse and Mental Health Services Administration (SAMHSA), an operating division of the Department of Health and Human Services (HHS).Recommendation: We recommend the Department strengthen controls to ensure information reported to the SAMHSA is accurate and properly supported by documentation.Prior Year Single Audit Finding Number: Not applicableViews of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 156.

Corrective Action Plan

SOUTH CAROLINA DEPARTMENT OF ALCOHOL AND OTHER DRUG ABUSE SERVICES CORRECTIVE ACTION PLAN ? YEAR ENDED JUNE 30, 2020U.S. Department of Health and Human ServicesThe South Carolina Department of Alcohol and Other Drug Abuse Services (DAODAS) respectfully submits the following corrective action plan for the year ended 6/30/20.The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered in accordance with the numbers assigned in the schedule.2020-025 Strategic Targeted Response Opioid Crisis Grant ? Assistance Listing No. 93.788Recommendation: We recommend the Department strengthen controls to ensure information reported to the SAMHSA is accurate and properly supported by documentation.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding: Data storage and verification plan:? External partners will be required to report process for verification of the data submitted.? Internal partners will place all data/reports in folders in Microsoft Teams or Box Enterprise for storage and review by managers.? Data and program protocols will be submitted for each project on a standardized form, including back-up staff assignment to each program for data verification and to serve as secondary program contacts.Name(s) of the contact person(s) responsible for corrective action: Roberta Braneck, Lisa Davis, and Sazid Khan, Ph.D.Planned completion date for corrective action plan: Initial plan to be developed and installed by April 30, 2021, with continuous and ongoing monitoringIf the U.S. Department of Health and Human Services has questions regarding this plan, please call Sharon Peterson at 803-896-1145.

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2020-026
Cash Management
SIGNIFICANT DEFICIENCYREPEAT OF 2019-011OTHER MATTERS

Cash management compliance could not be confirmed for some federal cash draws.Questioned Costs: NoneContext: Supporting documentation was not adequate to determine that federal reimbursement was for the correct amount.Cause: The Department was unable to fully implement the corrective action associated with the finding from the prior year.Effect: The Department did not effectively document its cash management process to demonstrate compliance.Recommendation: We recommend that the Department continue implementation of the associated corrective action plan.Prior Year Single Audit Report Finding Number: 2019-011Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 157.

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Federal Agency: Department of Health and Human ServicesFederal Program Title: Child Support Enforcement, Social Services Block Grant, Adoption AssistanceAssistance Listing: 93.563, 93.667, 93.659Federal Grant ID Number: 1901SCCSES, 2001SCCSES, 1901SCSOSR, 2001SCSOSR, 1901SCADPT, 2001SCADPTPass-Through Entity: Not applicableAward Period: October 1, 2018 through September 30, 2020Type of Finding: Significant deficiency in internal control over compliance, other mattersCriteria: Per 31 CFR ? 205.12(b)(5), reimbursable funding means that a federal program agency transfers federal funds to a State after that State has already paid out the funds for federal assistance program purposes.Condition: Cash management compliance could not be confirmed for some federal cash draws.Questioned Costs: NoneContext: Supporting documentation was not adequate to determine that federal reimbursement was for the correct amount.Cause: The Department was unable to fully implement the corrective action associated with the finding from the prior year.Effect: The Department did not effectively document its cash management process to demonstrate compliance.Recommendation: We recommend that the Department continue implementation of the associated corrective action plan.Prior Year Single Audit Report Finding Number: 2019-011Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 157.

Corrective Action Plan

U.S. Department of Health and Human ServicesThe South Carolina Department of Social Services respectfully submits the following corrective action plan for the year ended June 30, 2020.The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule.FINDINGS?FEDERAL AWARD PROGRAM AUDIT2020-026 Child Support Enforcement, Social Services Block Grant, Adoption Assistance ? Assistance Listing No. 93.563, 93.667, 93.659Recommendation: We recommend that the Department continue implementation of the associated corrective action plan.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding: The Department put procedures in place to ensure proper supporting documentation from the accounting system is retained to support accurate reimbursement for all Federal cash draws. Staff turnover, and the Department?s required enactment of work-from-home policies to combat the spread of the COVID-19 virus, created unanticipated barriers to ongoing compliance with its revised procedures. Required supporting documentation is now described in detail in the cash management procedures for drawdown of federal funds. Draws will be performed on a periodic basis determined by individual grant, but at least monthly if needed. Staff will review all grants periodically to determine whether qualified expenditures have posted to grants and require draws to cover them. A master draw log has been created and will be maintained by the Grants Accounting and Reporting Manager to document the completion of these reviews and the status of draw activity for each grant.Name(s) of the contact person(s) responsible for corrective action: Reshma Parikh, Grants Accounting and Reporting ManagerPlanned completion date for corrective action plan: April 30, 2021.If the Federal Cognizant Agency of Oversight or Audit has questions regarding this plan, please call David O?Kelly at 803-898-3987.

Prior Finding References

2019-011

About Cash Management →
2020-027
Cost Allowability / Eligibility
MATERIAL WEAKNESSMODIFIED OPINIONREPEAT OF 2019-015QUESTIONED COSTS

Eligibility related discrepancies were encountered for some payments and some payments exceeded the allowable amount.Questioned Costs: $4,756Context: Sixty payments were selected for testing eligibility compliance. Two of the subsidy payments tested exceeded the foster care maintenance payment rate the child would have received in a foster family home. For two payments tested, the adoption subsidy agreement was signed after the date the adoption was finalized. Additionally, seven of the subsidy payments tested were for children no longer eligible for payment. One nonrecurring expense payment tested was on behalf of a child that did not meet the special needs criteria. Finally, the Department was unable to provide adequate documentation to support eligibility for one other subsidy payment.Cause: Department controls failed to ensure eligibility was properly determined, benefits were terminated timely, and records were retained for the required amount of time. The global pandemic also significantly limited the Department?s ability to implement corrective action.Effect: The Department did not comply with and/or could not demonstrate compliance with eligibility and allowable costs/cost principles requirements.Recommendation: We recommend that the Department continue to implement corrective action for eligibility file controls.Prior Year Single Audit Report Finding Number: 2019-015Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 158.

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Federal Agency: Department of Health and Human ServicesFederal Program Title: Adoption AssistanceAssistance Listing: 93.659Federal Grant ID Number: 1901SADPT, 2001SCADPTPass-Through Entity: Not applicableAward Period: October 1, 2018 through September 30, 2020Type of Finding: Material weakness in internal control over compliance, material noncomplianceCriteria: 45 CFR ? 75.361 outlines record retention requirements of the non-federal entity pertinent to the federal award.45 CFR ? 1356.40(b)(1) requires the adoption assistance agreement be signed and in effect at the time of or prior to the final decree of adoption.42 U.S.C. ? 673(a)(3) states that adoption assistance payments cannot exceed the foster care maintenance payment the child would have received in a foster family home for that period.42 U.S.C. ? 673(c) explains the children with special needs criteria.42 U.S.C. ? 675(8)(b) expands eligibility requirements for children over the age of eighteen.Condition: Eligibility related discrepancies were encountered for some payments and some payments exceeded the allowable amount.Questioned Costs: $4,756Context: Sixty payments were selected for testing eligibility compliance. Two of the subsidy payments tested exceeded the foster care maintenance payment rate the child would have received in a foster family home. For two payments tested, the adoption subsidy agreement was signed after the date the adoption was finalized. Additionally, seven of the subsidy payments tested were for children no longer eligible for payment. One nonrecurring expense payment tested was on behalf of a child that did not meet the special needs criteria. Finally, the Department was unable to provide adequate documentation to support eligibility for one other subsidy payment.Cause: Department controls failed to ensure eligibility was properly determined, benefits were terminated timely, and records were retained for the required amount of time. The global pandemic also significantly limited the Department?s ability to implement corrective action.Effect: The Department did not comply with and/or could not demonstrate compliance with eligibility and allowable costs/cost principles requirements.Recommendation: We recommend that the Department continue to implement corrective action for eligibility file controls.Prior Year Single Audit Report Finding Number: 2019-015Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 158.

Corrective Action Plan

U.S. Department of Health and Human ServicesThe South Carolina Department of Social Services respectfully submits the following corrective action plan for the year ended June 30, 2020.The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule.2020-027 Adoption Assistance ? Assistance Listing No. 93.659Recommendation: We recommend that the Department continue to implement corrective action for eligibility file controls.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding: All adoption subsidy agreements are now sent to the State Office Adoptions Manager for signature. When the agreements are entered into the Child Welfare Information System (CAPSS), staff verify that the agreement includes the proper signature. Some of the payments tested and identified as exceptions this year were made pursuant to subsidy agreements executed in prior years. Prior to the Department?s required enactment of work-from-home policies to combat the spread of the COVID-19 virus, the Department had begun reviewing older files to ensure the subsidy agreements included the proper signatures. The Department also had begun implementation of an eligibility review process whereby staff would pull sample cases quarterly for internal review to confirm compliance with various requirements and ensure all subsidy payments were adequately supported. The implementation of these processes was interrupted when staff began working from home because staff are not permitted to remove paper eligibility case files from Department offices, thus could no longer access case files to complete reviews.With Department offices now re-opened, operation and implementation of these controls will resume. In signing the subsidy agreements and conducting the above compliance reviews, the State Office Adoptions Manager will verify the subsidy payment amounts are correct and agree with the subsidy agreements. She will also ensure all subsidy agreements have the proper signatures and that other compliance and documentation requirements are met in accordance with federal regulations. If discrepancies are found, the manager will contact the region for clarification or corrective action.In addition, State Adoptions staff are now working with the Department?s Information Technology team to add system controls and reports to ensure timely termination of payments and maintenance of documentary support for payments to children who are 18 years and older. The Department?s CAPSS system now discontinues subsidy payments at the end of the month in which a child reaches age 21. In addition, monthly reports are under development that will facilitate advance requests for required updates to educational and medical information to assure timely receipt of support for continuing payments to children who are 18 and over. Each month staff will track the documentation requested to ensure the required updates have been received, and they will terminate payments that lack the required support.Name(s) of the contact person(s) responsible for corrective action Plan: Rebecca Carrier, State Office Adoptions ManagerPlanned completion date for corrective action plan: August 31, 2021If the Federal Cognizant Agency of Oversight or Audit has questions regarding this plan, please call David O?Kelly at 803-898-3987.

Prior Finding References

2019-015

About Allowable Costs / Cost Principles, Eligibility →
2020-028
Reporting
SIGNIFICANT DEFICIENCYREPEAT OF 2019-012OTHER MATTERS

Discrepancies existed between federal financial reports and the Department?s supporting records.Questioned Costs: NoneContext: For both CB-496 reports selected for testing, discrepancies were noted between the supporting documentation and the average monthly number of children assisted reported in Part 1, Section D of the report. Errors were also identified in the Adoption Savings Calculation used in determining the amounts reported In Part 4 of the report.Cause: The Department had not completely implemented the corrective action associated with the finding from the prior year.Effect: The accuracy of the CB-496 reports could not be fully validated.Recommendation: We recommend that the Department continue to strengthen its internal controls to ensure that federal reports are free from error and clearly supported prior to submission.Prior Year Single Audit Report Finding Number: 2019-012Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 159.

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Federal Agency: Department of Health and Human ServicesFederal Program Title: Adoption AssistanceAssistance Listing: 93.659Federal Grant ID Number: 1901SCADPT, 2001SCADPTPass-Through Entity: Not applicableAward Period: October 1, 2018 through September 30, 2020Type of Finding: Significant deficiency in internal control over compliance, other mattersCriteria: 45 CFR ? 75.303 requires effective internal controls be established and maintained in order to provide reasonable assurance that the federal award is being managed in compliance with federal statutes, regulations, and the terms and conditions of the federal award.Condition: Discrepancies existed between federal financial reports and the Department?s supporting records.Questioned Costs: NoneContext: For both CB-496 reports selected for testing, discrepancies were noted between the supporting documentation and the average monthly number of children assisted reported in Part 1, Section D of the report. Errors were also identified in the Adoption Savings Calculation used in determining the amounts reported In Part 4 of the report.Cause: The Department had not completely implemented the corrective action associated with the finding from the prior year.Effect: The accuracy of the CB-496 reports could not be fully validated.Recommendation: We recommend that the Department continue to strengthen its internal controls to ensure that federal reports are free from error and clearly supported prior to submission.Prior Year Single Audit Report Finding Number: 2019-012Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 159.

Corrective Action Plan

U.S. Department of Health and Human ServicesThe South Carolina Department of Social Services respectfully submits the following corrective action plan for the year ended June 30, 2020.The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule.2020-028 Adoption Assistance ? Assistance Listing No. 93.659Recommendation: We recommend that the Department continue to strengthen its internal controls to ensure that Federal reports are free from error and clearly supported prior to submission.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding: Staff turnover, and the Department?s required enactment of work-from-home policies to combat the spread of the COVID-19 virus, made complete implementation of improvements more difficult. The Department?s Grants Accounting and Reporting team is implementing additional training on the proper completion of the Federal Financial Reports, and procedures for tie-in and retention of relevant supporting documentation. Reports are now reviewed by a manager or the Controller prior to submission.Name(s) of the contact person(s) responsible for corrective action: Reshma Parikh, Grants Accounting and Reporting ManagerPlanned completion date for corrective action plan: April 30, 2021If the Federal Cognizant Agency of Oversight or Audit has questions regarding this plan, please call David O?Kelly at 803-898-3987.

Prior Finding References

2019-012

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2020-029
Eligibility
SIGNIFICANT DEFICIENCYQUESTIONED COSTSOTHER MATTERS

Discrepancies related to eligibility determinations were identified.Questioned Costs: $2,954Context: Sixty payments were selected for testing eligibility compliance. Some eligibility documentation was incomplete or unsupported within the eligibility files of four of the test items, although eligibility could be confirmed through other support in three of those files. For two of the payments tested, the child was placed in a child-care institution that did not fully meet the criminal background check requirements. For two of the payments tested, clothing allowances were paid when the child was no longer eligible.Cause: The issues encountered were primarily due to disposal of the original eligibility files for cases that had been closed. Staffing turnover and Department oversight also contributed.Effect: The Department did not comply with federal eligibility, internal control, and record retention requirements.Recommendation: We recommend that the Department implement policies and procedures to ensure eligibility documentation is maintained and supports all federal requirements.Prior Year Single Audit Report Finding Number: Not applicableViews of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 159.

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Federal Agency: Department of Health and Human ServicesFederal Program Title: Foster Care?Title IV-EAssistance Listing: 93.658Federal Grant ID Number: 1901SCFOST, 2001SCFOSTPass-Through Entity: Not applicableAward Period: October 1, 2018 through September 30, 2020Type of Finding: Significant deficiency in internal control over compliance, other mattersCriteria: 45 CFR ? 75.361 states record retention requirements of the non-federal entity pertinent to the federal award.42 USC ? 671(a)(20) outlines requirements for criminal background checks of foster care providers, including those for child-care institutions.42 U.S.C. ? 672 describes the general eligibility requirements for foster care maintenance payments.Condition: Discrepancies related to eligibility determinations were identified.Questioned Costs: $2,954Context: Sixty payments were selected for testing eligibility compliance. Some eligibility documentation was incomplete or unsupported within the eligibility files of four of the test items, although eligibility could be confirmed through other support in three of those files. For two of the payments tested, the child was placed in a child-care institution that did not fully meet the criminal background check requirements. For two of the payments tested, clothing allowances were paid when the child was no longer eligible.Cause: The issues encountered were primarily due to disposal of the original eligibility files for cases that had been closed. Staffing turnover and Department oversight also contributed.Effect: The Department did not comply with federal eligibility, internal control, and record retention requirements.Recommendation: We recommend that the Department implement policies and procedures to ensure eligibility documentation is maintained and supports all federal requirements.Prior Year Single Audit Report Finding Number: Not applicableViews of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 159.

Corrective Action Plan

U.S. Department of Health and Human ServicesThe South Carolina Department of Social Services respectfully submits the following corrective action plan for the year ended June 30, 2020.The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule.2020-029 Foster Care-Title IV-E ? Assistance Listing No. 93.658Recommendation: We recommend that the Department implement policies and procedures to ensure eligibility documentation is maintained and supports all Federal requirements.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding: All case files are now being retained in either paper or electronic form in accordance with federal and state record retention requirements.The Department is reviewing its policies and procedures and will make necessary changes to better assure compliance by providers with criminal background check requirements.The clothing allowances identified during the audit were disbursed by the Department?s county offices during the audit period, under legacy procedures. In October 2020, the Department completed its conversion to centralized state office payment of these allowances through its CAPSS system and the state?s accounting system (SCEIS). This new process permits charges to the IV-E program only for the allowances it pays for IV-E eligible children.Name(s) of the contact person(s) responsible for corrective action: Laura Claspill, Director of Program Development; Jacqueline Lowe, Director of CPA & Group Home LicensingPlanned completion date for corrective action plan: June 30, 2021If the Federal Cognizant Agency of Oversight or Audit has questions regarding this plan, please call David O?Kelly at 803-898-3987.

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2020-030
Special Tests & Provisions
SIGNIFICANT DEFICIENCYOTHER MATTERS

We were unable to confirm the inclusion of written requirements for the periodic review of maintenance payment rates in the Department?s approved plan.Questioned Costs: NoneContext: Foster care maintenance payment rates are periodically reviewed for appropriateness by the Department. However, we were unable to identify a written policy or procedure associated with an approved State plan that describes the periodic rate review process or establishes a rate review schedule.Cause: State plan documentation and related policies did not contain a description of the periodic review process and timing that the Department follows.Effect: It could not be determined if the periodic reviews, which were conducted, were carried out in accordance with management?s intent, as expressed through approved written policies.Recommendation: We recommend the Department review and update their State Plan documentation and associated policies and procedures to ensure all information referenced in their approved State Plan supports compliance with the applicable federal requirements.Prior Year Single Audit Report Finding Number: Not applicableViews of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 160.

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Federal Agency: Department of Health and Human ServicesFederal Program Title: Foster Care?Title IV-EAssistance Listing: 93.658Federal Grant ID Number: 1901SCFOST, 2001SCFOSTPass-Through Entity: Not applicableAward Period: October 1, 2018 through September 30, 2020Type of Finding: Significant deficiency in internal control over compliance, other mattersCriteria: 42 U.S.C. ? 671(a)(11) explains that in order for a State to be eligible for payments, it must have a plan approved by the Secretary which provides for periodic review of amounts paid as foster care maintenance payments to assure their continuing appropriateness.Condition: We were unable to confirm the inclusion of written requirements for the periodic review of maintenance payment rates in the Department?s approved plan.Questioned Costs: NoneContext: Foster care maintenance payment rates are periodically reviewed for appropriateness by the Department. However, we were unable to identify a written policy or procedure associated with an approved State plan that describes the periodic rate review process or establishes a rate review schedule.Cause: State plan documentation and related policies did not contain a description of the periodic review process and timing that the Department follows.Effect: It could not be determined if the periodic reviews, which were conducted, were carried out in accordance with management?s intent, as expressed through approved written policies.Recommendation: We recommend the Department review and update their State Plan documentation and associated policies and procedures to ensure all information referenced in their approved State Plan supports compliance with the applicable federal requirements.Prior Year Single Audit Report Finding Number: Not applicableViews of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 160.

Corrective Action Plan

U.S. Department of Health and Human ServicesThe South Carolina Department of Social Services respectfully submits the following corrective action plan for the year ended June 30, 2020.The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule.2020-030 Foster Care-Title IV-E ? Assistance Listing No. 93.658Recommendation: We recommend the Department review and update its state plan documentation and associated policies and procedures to ensure all information referenced in its approved state plan supports compliance with the applicable Federal requirements.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding: The Department will incorporate documentation of its processes for periodic review and update of Foster Care rates into its approved State Plan.Name(s) of the contact person(s) responsible for corrective action: Anthony Williams, Director, Office of Policy and Continuous Quality ImprovementPlanned completion date for corrective action plan: January 31, 2022.If the Federal Cognizant Agency of Oversight or Audit has questions regarding this plan, please call David O?Kelly at 803-898-3987.

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2020-031
Reporting
SIGNIFICANT DEFICIENCYOTHER MATTERS

Discrepancies existed between federal financial reports and the Department?s supporting records.Questioned Costs: NoneContext: Two quarterly CB-496 reports were selected for testing. Some administrative costs in Part 1, Section A were inadequately supported and, for one of the reports, some expenditures were omitted. Additionally, discrepancies were encountered between the number of children reported in Part 1, Section E of both reports and supporting documentation. Finally, in Part 2 of the reports, one adjustment was misclassified and another lacked supporting documentation.Cause: Department controls failed to detect and correct the identified errors and ensure all reported amounts were appropriately supported by Department records.Effect: The CB-496 reports contained errors, omissions and data which did not agree to supporting documentation.Recommendation: We recommend that the Department continue to strengthen its internal controls to ensure that federal reports are free from error and clearly supported prior to submission.Prior Year Single Audit Report Finding Number: Not applicableViews of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 160.

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Federal Agency: Department of Health and Human ServicesFederal Program Title: Foster Care?Title IV-EAssistance Listing: 93.658Federal Grant ID Number: 1901SCFOST, 2001SCFOSTPass-Through Entity: Not applicableAward Period: October 1, 2018 through September 30, 2020Type of Finding: Significant deficiency in internal control over compliance, other mattersCriteria: 45 CFR ? 75.303 requires effective internal controls be established and maintained in order to provide reasonable assurance that the federal award is being managed in compliance with federal statutes, regulations, and the terms and conditions of the federal award.Condition: Discrepancies existed between federal financial reports and the Department?s supporting records.Questioned Costs: NoneContext: Two quarterly CB-496 reports were selected for testing. Some administrative costs in Part 1, Section A were inadequately supported and, for one of the reports, some expenditures were omitted. Additionally, discrepancies were encountered between the number of children reported in Part 1, Section E of both reports and supporting documentation. Finally, in Part 2 of the reports, one adjustment was misclassified and another lacked supporting documentation.Cause: Department controls failed to detect and correct the identified errors and ensure all reported amounts were appropriately supported by Department records.Effect: The CB-496 reports contained errors, omissions and data which did not agree to supporting documentation.Recommendation: We recommend that the Department continue to strengthen its internal controls to ensure that federal reports are free from error and clearly supported prior to submission.Prior Year Single Audit Report Finding Number: Not applicableViews of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 160.

Corrective Action Plan

U.S. Department of Health and Human ServicesThe South Carolina Department of Social Services respectfully submits the following corrective action plan for the year ended June 30, 2020.The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule.2020-031 Foster Care-Title IV-E ? Assistance Listing No. 93.658Recommendation: We recommend that the Department continue to strengthen its internal controls to ensure that Federal reports are free from error and clearly supported prior to submission.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding: Staff turnover, and the Department?s required enactment of work-from-home policies to combat the spread of the COVID-19 virus, made complete implementation of improvements more difficult. The Department?s Grants Accounting and Reporting team is implementing additional training on the proper completion of the Federal Financial Reports, including the proper classification of costs, and procedures for tie-in and retention of relevant supporting documentation. Reports are now reviewed by a manager or the Controller prior to submission.Name(s) of the contact person(s) responsible for corrective action: Reshma Parikh, Grants Accounting and Reporting ManagerPlanned completion date for corrective action plan: April 30, 2021If the Federal Cognizant Agency of Oversight or Audit has questions regarding this plan, please call David O?Kelly at 803-898-3987.

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2020-032
Activities Allowed or Unallowed / Cost Allowability
SIGNIFICANT DEFICIENCYQUESTIONED COSTSOTHER MATTERS

Discrepancies related to allowable activities/costs were encountered for some program payments.Questioned Costs: $25Context: One hundred non-payroll disbursements were selected for allowable activities/costs testing. For two of the disbursements tested, the Department was unable to provide sufficient documentation to support how the costs were allocated. For five of the disbursements tested, some portion of the costs charged to the grant should have been allocated to other Department program/service areas, but the exact amount could not be determined. For two of the disbursements tested, the amounts paid for foster care maintenance exceeded the monthly rate allowed by the Department?s payment schedule by a combined total of $25. For some disbursements tested, the rate paid for non-regular foster care maintenance lacked adequate supporting documentation to determine compliance with federal allowable activities/costs requirements.Cause: Documentation and system issues caused the discrepancies noted.Effect: Charges to the grant may have been for unallowable activities and costs.Recommendation: We recommend that the Department implement policies and procedures that ensure all rates and payments charged to the program fully comply with federal requirements.Prior Year Single Audit Report Finding Number: Not applicableViews of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 161.

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Federal Agency: Department of Health and Human ServicesFederal Program Title: Foster Care?Title IV-EAssistance Listing: 93.658Federal Grant ID Number: 1901SCFOST, 2001SCFOSTPass-Through Entity: Not applicableAward Period: October 1, 2018 through September 30, 2020Type of Finding: Significant deficiency in internal control over compliance, other mattersCriteria: 45 CFR ? 75.403 outlines factors affecting allowability of costs, including adequate documentation.45 CFR ? 75.405(d) requires costs that benefit two or more projects or activities to be allocated to the projects based on the proportional benefit or, if that cannot be determined feasibly, allocated on another reasonable, documented basis.45 CFR ? 1356.60 explains fiscal requirements for title IV-E.Condition: Discrepancies related to allowable activities/costs were encountered for some program payments.Questioned Costs: $25Context: One hundred non-payroll disbursements were selected for allowable activities/costs testing. For two of the disbursements tested, the Department was unable to provide sufficient documentation to support how the costs were allocated. For five of the disbursements tested, some portion of the costs charged to the grant should have been allocated to other Department program/service areas, but the exact amount could not be determined. For two of the disbursements tested, the amounts paid for foster care maintenance exceeded the monthly rate allowed by the Department?s payment schedule by a combined total of $25. For some disbursements tested, the rate paid for non-regular foster care maintenance lacked adequate supporting documentation to determine compliance with federal allowable activities/costs requirements.Cause: Documentation and system issues caused the discrepancies noted.Effect: Charges to the grant may have been for unallowable activities and costs.Recommendation: We recommend that the Department implement policies and procedures that ensure all rates and payments charged to the program fully comply with federal requirements.Prior Year Single Audit Report Finding Number: Not applicableViews of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 161.

Corrective Action Plan

U.S. Department of Health and Human ServicesThe South Carolina Department of Social Services respectfully submits the following corrective action plan for the year ended June 30, 2020.The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule.2020-032 Foster Care-Title IV-E ? Assistance Listing No. 93.658Recommendation: We recommend that the Department implement policies and procedures that ensure all rates and payments charged to the program fully comply with Federal requirements.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding: The department will review the charges to the program for which amounts that should have been allocated were deemed unclear or insufficiently documented in order to identify and implement any improvements needed to ensure the charges are correctly allocated and that the allocations are fully documented.The $25 in question resulted from payments at established daily rates to two foster parents in the same month, when custody of the child was changed from one to the other. Payments were made to the respective parents for a total of 31 days, resulting in total payments for the month that exceeded the monthly rate equivalent computed on a 30-day basis. The Department will consult with the Children?s Bureau and review its policies with regard to the handling of these payments under the various possible scenarios and implement any changes if needed to ensure the payment amounts comply with federal rules.Name(s) of the contact person(s) responsible for corrective action: David O?Kelly, Controller; Laura Claspill, Director of Program DevelopmentPlanned completion date for corrective action plan: June 30, 2021If the Federal Cognizant Agency of Oversight or Audit has questions regarding this plan, please call David O?Kelly at 803-898-3987.

About Activities Allowed or Unallowed, Allowable Costs / Cost Principles →

FY 2019-06-30

$94,733,217 federal awards expended

FAC accepted this audit on November 21, 2021 — management decision was due May 21, 2022.

2019-002
Subrecipient Monitoring
SIGNIFICANT DEFICIENCYREPEAT OF 2018-040OTHER MATTERS

Documentation was not adequate to demonstrate that the pass-through entity verified each applicable subrecipient was audited as required.Questioned Costs: NoneContext: This is a repeat finding from the FY18 Single Audit. For all five subrecipients randomly selected for testing, a Single Audit was completed but documentation did not support that the Single Audit had been timely reviewed by program personnel.Cause: Office documentation requirements lack adequate evidence that Single Audits of all subrecipients were verified and reviewed as required.Effect: The Office may not identify and properly follow up on noncompliance of subrecipients.Recommendation: We recommend that Office policies and procedures ensure that subrecipient monitoring is performed in accordance with federal regulations and clearly supports the collection and review of all required Single Audit reports of its subrecipients.Prior Year Single Audit Finding Number: 2018-040Views of Responsible Offices and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 147.

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Subrecipient MonitoringFederal Agency: Department of Homeland SecurityFederal Program Title: Disaster Grants ? Public Assistance (Presidentially Declared Disasters)CFDA No.: 97.036Federal Grant ID Number: FEMA-4166-DR-SC; FEMA-4241-DR-SC; FEMA-4286-DR-SC; FEMA-4346-DR-SCPass-Through Entity: Not applicableType of Finding: Significant Deficiency in internal control over compliance, other mattersCriteria: 2 CFR 200.331 (d) (1) (2) requires the pass-through entity to review the audit reports required of the subrecipient and follow-up as necessary.Condition: Documentation was not adequate to demonstrate that the pass-through entity verified each applicable subrecipient was audited as required.Questioned Costs: NoneContext: This is a repeat finding from the FY18 Single Audit. For all five subrecipients randomly selected for testing, a Single Audit was completed but documentation did not support that the Single Audit had been timely reviewed by program personnel.Cause: Office documentation requirements lack adequate evidence that Single Audits of all subrecipients were verified and reviewed as required.Effect: The Office may not identify and properly follow up on noncompliance of subrecipients.Recommendation: We recommend that Office policies and procedures ensure that subrecipient monitoring is performed in accordance with federal regulations and clearly supports the collection and review of all required Single Audit reports of its subrecipients.Prior Year Single Audit Finding Number: 2018-040Views of Responsible Offices and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 147.

Corrective Action Plan

U.S. Department of Homeland SecurityState of S.C Adjutant General?s Office respectfully submits the following corrective action plan for the year ended 6/30/19.The findings form the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule.FINDINGS-FEDERAL AWARD PROGRAM AUDITU.S. Department of Homeland Security2019-002 Disaster Grants ? Public Assistance (Presidentially Declared Disasters)-97.036Recommendation: We recommend that Office policies and procedures ensure that subrecipient monitoring is performed in accordance with federal regulations and clearly supports the collection and review of all required Single Audit reports of its subrecipients.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding:? Purchased and implemented risk assessment and monitoring module for South Carolina Recovery Grants (SCRG) grants management platform (www.screcoverygrants.org). Integrated criteria from SCEMD policy into SCRG module.? Loaded subrecipient single audits and single-audit-not-required forms in SCRG.? Developed and implemented risk assessment and monitoring procedure and criteria.? Developed staff assignments for audit collection, review, and monitoring activities and regular reporting in SCRG module.? Sent correspondence to subrecipients for which audits not received and provide additional staff outreach to follow up on audit requirements.? Developed correspondence template for use if payment is to be withheld because of lack of audit compliance.? Continued to provide information and reminders about 2 CFR 200 single audit requirements and quarterly progress reports with applicants/subrecipients via multiple means including applicants? briefings, presentations, and specialist contacts.? Continued to include requirements for single audits and quarterly progress reports in funding agreements.Name(s) of the contact person(s) responsible for corrective action: Emily Bentley, Chief of Recovery and Mitigation and Cynthia Smith, Chief of Finance and Administration.Planned completion date for corrective action plan: Most corrections, including repository and tracking of single audits, complete as of January 2020; risk assessment rating of subrecipients based on audit compliance and other criteria to be complete in SCRG by March 31, 2020.If the Department of Homeland Security has questions regarding this plan, please call Steven Batson at 803-201-3440.

Prior Finding References

2018-040

About Subrecipient Monitoring →
2019-002
Reporting
MATERIAL WEAKNESSREPEAT OF 2018-006

The Agency did not submit certain quarterly and annual reports to the United States Department of Labor ("National Office") by the required due dates. Accordingly, the Agency did not comply with the Reporting compliance requirements related to the Unemployment Insurance and the Employment Services Cluster programs. Cause: Internal Controls are not in place to ensure that all required reports are being submitted in accordance with the United States Department of Labor's timelines. Effect: As a result, the Agency becomes more susceptible to having its level of federal award funding reduced by the United States Department of Labor when it violates its Reporting compliance requirements applicable to the Unemployment Insurance and the Employment Services programs. Context: We inspected a sample of quarterly reports and annual reports and noted the following number of exceptions: Unemployment Insurance -One(1) ETA 191 quarterly report; Employment Services Cluster - 3 ETA-9130 quarterly reports. Recommendation: We recommend that management carefully review the terms and conditions included in the supporting grant agreements and the Reporting requirements included in the OMB Compliance Supplement applicable to the Unemployment Insurance and Employment Services Cluster programs.

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Item 2019-002: Reporting(Material Weakness over Reporting and Non-Material Noncompliance) Condition: The Agency did not submit certain quarterly and annual reports to the United States Department of Labor ("National Office") by the required due dates. Accordingly, the Agency did not comply with the Reporting compliance requirements related to the Unemployment Insurance and the Employment Services Cluster programs. Cause: Internal Controls are not in place to ensure that all required reports are being submitted in accordance with the United States Department of Labor's timelines. Effect: As a result, the Agency becomes more susceptible to having its level of federal award funding reduced by the United States Department of Labor when it violates its Reporting compliance requirements applicable to the Unemployment Insurance and the Employment Services programs. Context: We inspected a sample of quarterly reports and annual reports and noted the following number of exceptions: Unemployment Insurance -One(1) ETA 191 quarterly report; Employment Services Cluster - 3 ETA-9130 quarterly reports. Recommendation: We recommend that management carefully review the terms and conditions included in the supporting grant agreements and the Reporting requirements included in the OMB Compliance Supplement applicable to the Unemployment Insurance and Employment Services Cluster programs.

Corrective Action Plan

SCDEW implemented a corrective action plan in response to this finding during the year ended June 30, 2020 a brief summary follows: The SCDEW Enterprise and Project Management Office (EPMO) is tasked with monitoring agency wide reporting deadlines. The EPMO developed a master reporting database that includes relevant identifying information including report name, Agency, SCDEW contact, reporting frequency and due dates. Individual reporters at SCDEW submit data to EPMO on the status of the required filings. EPMO routinely reports the status of filings to executive leadership. This finding for the year ended June 30, 2019 reports late filings that occurred before the plan to monitor the status of filings was implemented.

Prior Finding References

2018-006

About Reporting →
2019-003
Cost Allowability
SIGNIFICANT DEFICIENCYREPEAT OF 2018-001OTHER MATTERS

The Department did not remit the federal share of recoveries and collections to the Medicaid program in accordance with Federal regulations and the State Medicaid Manual.Questioned Costs: UnknownContext: We tested sixty receivables to ensure the Department properly credited the Medicaid program for the federal share of identified overpayments. For one receivable tested, the Department used the incorrect Federal medical assistance percentage to calculate the federal share which resulted in an underpayment of $2 to the federal grantor.This is a repeat finding from the FY18 Single Audit. The Department stated on its Summary Schedule of Prior Year Audit Findings that this issue was ?Fully Corrected with Previously Reported Corrective Action Implemented?. Due to this issue repeating for FY19, this issue has not been fully corrected.Cause: Department personnel used the incorrect period of overpayment calculating and remitting the refunds due to human error. Department personnel further stated that quarterly reviews of randomly selected receivables are performed.Effect: The Department?s control procedures did not detect the errors identified in our testing which could lead to further improper remittances.Recommendation: We recommend the Department strengthen its control procedures to ensure the federal share of recoveries and collections are remitted in accordance with applicable federal and state requirements.Prior Year Single Audit Finding Number: 2018-001Views of Responsible Offices and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 149.

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Allowable Costs/Cost Principles - Federal Share of Recoveries / CollectionsFederal Agency: Department of Health and Human ServicesFederal Program Title: Medicaid ClusterCFDA No.: 93.775, 93.777, 93.778Federal Grant ID Number: 05-1905SC5MAPPass-Through Entity: Not applicableAward Period: October 1, 2018 through September 30, 2019Type of Finding: Significant deficiency in internal control over compliance, other mattersCriteria: Per 42 CFR 433.12 (c), the State is required to credit the Medicaid program for ??overpayments made to Medicaid providers?? In addition, Title 45 Section 2500.6 B of the Centers for Medicare & Medicaid Services? (CMS) State Medicaid Manual states to ??determine the date or period of the expenditure for which the refund is made to establish the [Federal Medical Assistance Percentage] at which the original expenditure was matched by the Federal government. Make refunds of the federal share at the FMAP for which you were reimbursed.?Condition: The Department did not remit the federal share of recoveries and collections to the Medicaid program in accordance with Federal regulations and the State Medicaid Manual.Questioned Costs: UnknownContext: We tested sixty receivables to ensure the Department properly credited the Medicaid program for the federal share of identified overpayments. For one receivable tested, the Department used the incorrect Federal medical assistance percentage to calculate the federal share which resulted in an underpayment of $2 to the federal grantor.This is a repeat finding from the FY18 Single Audit. The Department stated on its Summary Schedule of Prior Year Audit Findings that this issue was ?Fully Corrected with Previously Reported Corrective Action Implemented?. Due to this issue repeating for FY19, this issue has not been fully corrected.Cause: Department personnel used the incorrect period of overpayment calculating and remitting the refunds due to human error. Department personnel further stated that quarterly reviews of randomly selected receivables are performed.Effect: The Department?s control procedures did not detect the errors identified in our testing which could lead to further improper remittances.Recommendation: We recommend the Department strengthen its control procedures to ensure the federal share of recoveries and collections are remitted in accordance with applicable federal and state requirements.Prior Year Single Audit Finding Number: 2018-001Views of Responsible Offices and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 149.

Corrective Action Plan

Department of Health & Human ServicesCenters for Medicare & Medicaid Services31 Forsyth Street, SW, Room 4T20Atlanta, Georgia 30303-8909The South Carolina Department of Health and Human Services respectfully submits the following corrective action plan for the year ended 6/30/19.The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule.FINDINGS?FEDERAL AWARD PROGRAM AUDIT2019-003 Medicaid Cluster ? CFDA No. 93.775, 93.777 & 93.778Recommendation: We recommend the Department strengthen its control procedures to ensure the federal share of recoveries and collections are remitted in accordance with applicable federal and state requirements.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding:Currently, accounting operations? Accounts Receivable Manager is reviewing 25% of each month?s receivables. Additionally, the program director is reviewing 10% of each quarter?s receivables. In an effort to continue to eliminate federal share miscalculation, management will begin to review 50% of each month?s receivables in FY2021 and the program director will increase the quarterly review to 20%. Management is currently in communication with South Carolina Enterprise Information System (SCEIS) personnel to create an accounts receivable workflow that will require management to approve all newly established receivables. Furthermore, management will continue researching best practices for minimizing and eliminating manual error and miscalculation within the Accounts Receivable department.Name of the contact person responsible for corrective action: Nika SimmonsPlanned completion date for corrective action plan: OngoingIf the U.S. Department of Health and Human Services has questions regarding this plan, please call Thomas C. Phillip, CFO, at 803-898-1017.

Prior Finding References

2018-001

About Allowable Costs / Cost Principles →
2019-004
Matching, Level of Effort, Earmarking
SIGNIFICANT DEFICIENCYREPEAT OF 2018-003OTHER MATTERS

The Department was not in compliance with the Federal matching requirement for family planning services or family planning related services.Questioned Costs: NoneContext: We tested sixty individual claims to ensure the Department was in compliance with matching requirements. We determined the Department did not use the proper Federal medical assistance percentage for three of the four contraceptive services selected for testing as well as all (two) of the STI diagnosis services selected for testing.Cause: Department personnel stated that errors within the Medicaid Management Information System (MMIS) as well as the utilization of the improper modifier caused contraceptive services and STI diagnosis services to map to the incorrect internal fund code and Federal medical assistance percentage.Effect: The Department?s control procedures did not detect the errors identified in our testing which could lead to further improper payments.Recommendation: We recommend the Department correct the errors in MMIS to ensure compliance with the Federal matching requirement for family planning services and family planning related services.Prior Year Single Audit Finding Number: 2018-003Views of Responsible Offices and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 150.

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Matching, Level of Effort, EarmarkingFederal Agency: Department of Health and Human ServicesFederal Program Title: Medicaid ClusterCFDA No.: 93.775, 93.777, 93.778Federal Grant ID Number: 05-1905SC5MAPPass-Through Entity: Not applicableAward Period: October 1, 2018 through September 30, 2019Type of Finding: Significant deficiency in internal control over compliance, other mattersCriteria: 42 CFR 433.10 (c) (1) states, ?Under Section 1905 (a) (5) of the Act, the Federal share of State expenditures for family planning services is 90 percent.? In addition, the Centers for Medicare & Medicaid Services (CMS) State Medicaid Director Letter 14-003 states in part, ??family planning related services are matched at the states? regular Federal medical assistance percentage.?Condition: The Department was not in compliance with the Federal matching requirement for family planning services or family planning related services.Questioned Costs: NoneContext: We tested sixty individual claims to ensure the Department was in compliance with matching requirements. We determined the Department did not use the proper Federal medical assistance percentage for three of the four contraceptive services selected for testing as well as all (two) of the STI diagnosis services selected for testing.Cause: Department personnel stated that errors within the Medicaid Management Information System (MMIS) as well as the utilization of the improper modifier caused contraceptive services and STI diagnosis services to map to the incorrect internal fund code and Federal medical assistance percentage.Effect: The Department?s control procedures did not detect the errors identified in our testing which could lead to further improper payments.Recommendation: We recommend the Department correct the errors in MMIS to ensure compliance with the Federal matching requirement for family planning services and family planning related services.Prior Year Single Audit Finding Number: 2018-003Views of Responsible Offices and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 150.

Corrective Action Plan

Department of Health & Human ServicesCenters for Medicare & Medicaid Services31 Forsyth Street, SW, Room 4T20Atlanta, Georgia 30303-8909The South Carolina Department of Health and Human Services respectfully submits the following corrective action plan for the year ended 6/30/19.The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule.FINDINGS?FEDERAL AWARD PROGRAM AUDIT2019-004Medicaid Cluster ? CFDA No. 93.775, 93.777 & 93.778Recommendation: We recommend the Department correct the errors in MMIS to ensure compliance with the Federal matching requirement for family planning services and family planning related services.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding:A modification became effective on 8/15/2019 that removed the ?0FP? modifier from system logic for fund code MK. This correction eliminated the auto assignment of 90/10 funding that overrode the family planning-related (70/30) procedure codes submitted by providers of service. This led to the return of $43,946.57 in Federal funds for the review period of January through Aug 2019.Name of the contact person responsible for corrective action: Kevin Bonds Planned completion date for corrective action plan: OngoingIf the U.S. Department of Health and Human Services has questions regarding this plan, please call Thomas C. Phillip, CFO, at 803-898-1017.

Prior Finding References

2018-003

About Matching, Level of Effort, Earmarking →
2019-005
Eligibility
SIGNIFICANT DEFICIENCYREPEAT OF 2018-004OTHER MATTERS

Eligibility files did not contain adequate documentation to support the Medicaid and CHIP recipients? eligibility statuses.Questioned Costs: UnknownContext: We tested one hundred twenty individual recipients (sixty each for Medicaid and CHIP) to ensure the Department was in compliance with applicable eligibility requirements. We determined the Department did not maintain adequate documentation of eligibility for thirteen Medicaid recipients and eight CHIP recipients.This is a repeat finding from the FY18 Single Audit. The Department stated on its Summary Schedule of Prior Year Audit Findings that this issue was ?Fully Corrected with Previously Reported Corrective Action Implemented?. Due to this issue repeating for FY19, this issue has not been fully corrected.Cause: The Department transitioned to an online eligibility system, the Medicaid Eligibility Determination System (MEDS), in July 2013. According to Department personnel, documentation in some of the paper files may not have been scanned into the system since the transition. For cases opened after the transition, the omissions were due to human error.Effect: The Department could not support eligibility determinations in accordance with its State plan.Recommendation: We recommend the Department maintain documentation to support its eligibility determinations in accordance with its State plan and Federal regulations.Prior Year Single Audit Finding Number: 2018-004Views of Responsible Offices and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 150.

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Documentation of EligibilityFederal Agency: Department of Health and Human ServicesFederal Program Title: Medicaid Cluster; Children?s Health Insurance Program (CHIP)CFDA No.: 93.775, 93.777, 93.778; 93.767Federal Grant ID Number: 05-1805SC5MAP, 05-1905SC5MAP; 05-1805SC5021, 05-1905SC5022Pass-Through Entity: Not applicableAward Period: October 1, 2017 through September 30, 2020Type of Finding: Significant deficiency in internal control over compliance, other mattersCriteria: 42 CFR 435.914 (a) states, ?The agency must include in each applicant?s case record facts to support the agency?s decision on his application.? In addition, Section 4.7 of the Department?s Title XIX (Medicaid) State Plan (Maintenance of Records) affirms that it meets the requirements outlined in 42 CFR 431.17 (b), which states, ?A State plan must provide that the Medicaid agency will maintain or supervise the maintenance of records necessary for the proper and efficient operation of the plan.? Furthermore, the Department?s Title XXI (CHIP) State Plan attests that CHIP will operate as a Medicaid expansion program; therefore, the aforementioned regulations apply to both programs.Condition: Eligibility files did not contain adequate documentation to support the Medicaid and CHIP recipients? eligibility statuses.Questioned Costs: UnknownContext: We tested one hundred twenty individual recipients (sixty each for Medicaid and CHIP) to ensure the Department was in compliance with applicable eligibility requirements. We determined the Department did not maintain adequate documentation of eligibility for thirteen Medicaid recipients and eight CHIP recipients.This is a repeat finding from the FY18 Single Audit. The Department stated on its Summary Schedule of Prior Year Audit Findings that this issue was ?Fully Corrected with Previously Reported Corrective Action Implemented?. Due to this issue repeating for FY19, this issue has not been fully corrected.Cause: The Department transitioned to an online eligibility system, the Medicaid Eligibility Determination System (MEDS), in July 2013. According to Department personnel, documentation in some of the paper files may not have been scanned into the system since the transition. For cases opened after the transition, the omissions were due to human error.Effect: The Department could not support eligibility determinations in accordance with its State plan.Recommendation: We recommend the Department maintain documentation to support its eligibility determinations in accordance with its State plan and Federal regulations.Prior Year Single Audit Finding Number: 2018-004Views of Responsible Offices and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 150.

Corrective Action Plan

Department of Health & Human ServicesCenters for Medicare & Medicaid Services31 Forsyth Street, SW, Room 4T20Atlanta, Georgia 30303-8909The South Carolina Department of Health and Human Services respectfully submits the following corrective action plan for the year ended 6/30/19.The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule.2019-005 Medicaid Cluster; Children?s Health Insurance Program ? CFDA No. 93.775, 93.777 & 93.778; 93.767Recommendation: We recommend the Department maintain documentation to support its eligibility determinations in accordance with its State plan and Federal regulations.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding:Pre-Electronic Document Management: In January 2019, the agency completed a scanning project in pursuit of a paper free environment. Any remaining paper case files for active beneficiaries were scanned into OnBase. There will always be the risk of paper files that have not been uploaded into the electronic case file as anticipated. The corrective action for reducing this risk was the implementation of OnBase. However, it is recognized that the agency is still accountable for having required documents or documentation in the case file and/or eligibility systems. For any document not found as part of a case review or audit, the corrective action for that review will be to pursue any needed documentation required to continue or end eligibility. The State's quality assurance strategy facilitates this process. The annual review process also requires the worker to ensure that required historical documents are in the case file.Post-Electronic Document Management: While the implementation of OnBase significantly reduces the risk of required documentation not being present in the case file, a thorough quality review process as described in this document is needed to help ensure compliance.SCDHHS Quality Assurance Strategy: The quality review process implemented in July 2019 includes key elements for review which lead to a correct or incorrect eligibility determination. This includes the presence of a signed application (where appropriate) and presence of other documentation required for the eligibility decision (e.g. Level of Care).The Eligibility Quality Assurance Team (EQAT) consists of 52 team members. Team members are trained to evaluate MAGI, Non-MAGI or Long-Term Care determinations for accuracy of those determinations, as well as vital procedural errors that are most likely to impact eligibility. Review findings are used as part of a monthly employee feedback process in conjunction with employee production metrics. On the first business day of each month, supervisors receive Employee Performance results for their staff and review these results during one on one meetings. Action plans are established, implemented and reviewed for any needed corrective measures. Between August 1, 2019 and January 31, 2020, the state has reviewed 40,015 cases with a 95% accuracy rate.SCDHHS will utilize audit and EQAT findings to analyze current trends regarding these errors. The State will develop and implement a strategy, including refresher training and policy clarifications to ensure staff fully understand policies and procedures regarding required documentation for eligibility determinations and the importance of this documentation.Names of the contact persons responsible for corrective action: Elizabeth Ryan, Michael Jones, Lori RiskPlanned completion date for corrective action plan: June 30, 2020If the U.S. Department of Health and Human Services has questions regarding this plan, please call Thomas C. Phillip, CFO, at 803-898-1017.

Prior Finding References

2018-004

About Eligibility →
2019-006
Eligibility
SIGNIFICANT DEFICIENCYREPEAT OF 2018-005QUESTIONED COSTSOTHER MATTERS

The Department did not consistently discontinue the Medicaid and CHIP benefits of ineligible recipients.Questioned Costs: $22,460Context: We tested one hundred twenty individual recipients (sixty each for Medicaid and CHIP) to ensure the Department was in compliance with applicable eligibility requirements. We determined the Department did not discontinue the benefits of five Medicaid recipients and three CHIP recipients on the dates they became ineligible.Cause: Department personnel stated the closure process for these recipients ultimately was not completed due to backlog in case processing and the continued prioritization of applications.Effect: The Department was not in compliance with applicable eligibility requirements. In addition, Medicaid and CHIP payments were made on behalf of ineligible recipients.Recommendation: We recommend the Department discontinue the Medicaid and CHIP benefits of ineligible recipients in accordance with its State plan and Federal regulations.Prior Year Single Audit Finding Number: 2018-005Views of Responsible Offices and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 151.

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Discontinuation of BenefitsFederal Agency: Department of Health and Human ServicesFederal Program Title: Medicaid Cluster; Children?s Health Insurance Program (CHIP)CFDA No.: 93.775, 93.777, 93.778; 93.767Federal Grant ID Number: 05-1805SC5MAP, 05-1905SC5MAP; 05-1805SC5021Pass-Through Entity: Not applicableAward Period: October 1, 2017 through September 30, 2019Type of Finding: Significant deficiency in internal control over compliance, other mattersCriteria: Section 4.32 of the Department?s Title XIX (Medicaid) State Plan (Income and Eligibility Verification System) affirms that it meets the requirements outlined in 42 CFR 435.930 (b), which states in part, ?The agency must?continue to furnish Medicaid regularly to all eligible individuals until they are found to be ineligible.? In addition, the Department?s Title XXI (CHIP) State Plan attests that CHIP will operate as a Medicaid expansion program; therefore, the aforementioned regulation applies to both programs.Condition: The Department did not consistently discontinue the Medicaid and CHIP benefits of ineligible recipients.Questioned Costs: $22,460Context: We tested one hundred twenty individual recipients (sixty each for Medicaid and CHIP) to ensure the Department was in compliance with applicable eligibility requirements. We determined the Department did not discontinue the benefits of five Medicaid recipients and three CHIP recipients on the dates they became ineligible.Cause: Department personnel stated the closure process for these recipients ultimately was not completed due to backlog in case processing and the continued prioritization of applications.Effect: The Department was not in compliance with applicable eligibility requirements. In addition, Medicaid and CHIP payments were made on behalf of ineligible recipients.Recommendation: We recommend the Department discontinue the Medicaid and CHIP benefits of ineligible recipients in accordance with its State plan and Federal regulations.Prior Year Single Audit Finding Number: 2018-005Views of Responsible Offices and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 151.

Corrective Action Plan

Department of Health & Human ServicesCenters for Medicare & Medicaid Services31 Forsyth Street, SW, Room 4T20Atlanta, Georgia 30303-8909The South Carolina Department of Health and Human Services respectfully submits the following corrective action plan for the year ended 6/30/19.The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule.2019-006 Medicaid Cluster; Children?s Health Insurance Program ? CFDA No. 93.775, 93.777 & 93.778; 93.767Recommendation: We recommend the Department discontinue the Medicaid and CHIP benefits of ineligible recipients in accordance with its State plan and Federal regulations.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding:The errors are caused by delays in annual review processing. SCDHHS has continued to implement a plan to reduce and manage the eligibility processing backlog, while also protecting the integrity of eligibility decisions. The agency?s approach has been to build staff capacity through the creation of processing centers and to maximize accuracy and timeliness of eligibility decisions via implementation of a Staff Performance Evaluation and Remediation process.Staff Capacity and Processing Centers: The agency has created and staffed four (4) processing centers in Richland (2), Aiken (1) and Spartanburg (1) counties. Staff processing MAGI, Non-MAGI and Long-Term Care applications now complete available work for processing applications daily, allowing for staff assignments for processing reviews. Staff webinars for processing reviews have been conducted for MAGI and Non-MAGI review processing in the past six months, as well as updates to job aids, based on updated policies and procedures. One additional processing center will be added in Florence County for additional MAGI application and review processing.Staff Performance Evaluation and Remediation: The performance evaluation plan rolled out to staff in July 2019. On the first business day of each month, supervisors receive Employee Performance results for their staff regarding both timeliness and accuracy of eligibility determinations and review these results during one on one meetings. Action plans are established, implemented and reviewed for any needed corrective measures in response to accuracy and/or timeliness metrics. Between August 1, 2019 and January 31, 2020, the state has reviewed 40,015 cases with a 95% accuracy rate.Names of the contact persons responsible for corrective action: Elizabeth Ryan, Michael Jones, Lori RiskPlanned completion date for corrective action plan: September 30, 2020 (New Processing Center)If the U.S. Department of Health and Human Services has questions regarding this plan, please call Thomas C. Phillip, CFO, at 803-898-1017.

Prior Finding References

2018-005

About Eligibility →
2019-007
Eligibility
MATERIAL WEAKNESSMODIFIED OPINIONREPEAT OF 2018-006

The Department did not consistently perform timely annual eligibility reviews for Medicaid and CHIP recipients in accordance with Section 101.10 of the South Carolina Medicaid Policies and Procedures Manual.Questioned Costs: UnknownContext: We tested one hundred twenty individual recipients (sixty each for Medicaid and CHIP) to ensure the Department was in compliance with applicable eligibility requirements. We determined the Department did not comply with the annual review requirement for fourteen Medicaid recipients (payment categories 10, 12, 32, 57, 59, 60, and 71) and twenty-one CHIP recipients (payment category 88).Cause: Department personnel stated they did not comply with the annual review requirement for these recipients due to backlog in case processing and the continued prioritization of applications.Effect: In the absence of an annual review, Medicaid and CHIP recipients may continue to receive benefits without meeting eligibility requirements.Recommendation: We recommend the Department ensure that eligibility reviews are performed annually in accordance with the South Carolina Medicaid Policies and Procedures Manual.Prior Year Single Audit Finding Number: 2018-006Views of Responsible Offices and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 152.

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Annual Eligibility ReviewsFederal Agency: Department of Health and Human ServicesFederal Program Title: Medicaid Cluster; Children?s Health Insurance Program (CHIP)CFDA No.: 93.775, 93.777, 93.778; 93.767Federal Grant ID Number: 05-1805SC5MAP, 05-1905SC5MAP; 05-1805SC5021, 05-1905SC5022Pass-Through Entity: Not applicableAward Period: October 1, 2017 through September 30, 2020Type of Finding: Material weakness in internal control over compliance, material noncomplianceCriteria: Section 2.1 of the Department?s Title XIX (Medicaid) State Plan (Application, Determination of Eligibility and Furnishing Medicaid) affirms that it meets the requirements outlined in 42 CFR Part 435.916, which states in part, ?the agency must promptly determine eligibility between regular renewals of eligibility.? In addition, Section 101.10 of the South Carolina Medicaid Policies and Procedures Manual states that the Department must complete an annual review for payment categories 10, 12, 32, 57, 59, 60, 71, and 88. Furthermore, the Department?s Title XXI (CHIP) State Plan attests that CHIP will operate as a Medicaid expansion program; therefore, the aforementioned regulation and policies apply to both programs.Condition: The Department did not consistently perform timely annual eligibility reviews for Medicaid and CHIP recipients in accordance with Section 101.10 of the South Carolina Medicaid Policies and Procedures Manual.Questioned Costs: UnknownContext: We tested one hundred twenty individual recipients (sixty each for Medicaid and CHIP) to ensure the Department was in compliance with applicable eligibility requirements. We determined the Department did not comply with the annual review requirement for fourteen Medicaid recipients (payment categories 10, 12, 32, 57, 59, 60, and 71) and twenty-one CHIP recipients (payment category 88).Cause: Department personnel stated they did not comply with the annual review requirement for these recipients due to backlog in case processing and the continued prioritization of applications.Effect: In the absence of an annual review, Medicaid and CHIP recipients may continue to receive benefits without meeting eligibility requirements.Recommendation: We recommend the Department ensure that eligibility reviews are performed annually in accordance with the South Carolina Medicaid Policies and Procedures Manual.Prior Year Single Audit Finding Number: 2018-006Views of Responsible Offices and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 152.

Corrective Action Plan

Department of Health & Human ServicesCenters for Medicare & Medicaid Services31 Forsyth Street, SW, Room 4T20Atlanta, Georgia 30303-8909The South Carolina Department of Health and Human Services respectfully submits the following corrective action plan for the year ended 6/30/19.The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule.2019-007 Medicaid Cluster; Children?s Health Insurance Program ? CFDA No. 93.775, 93.777 & 93.778; 93.767Recommendation: We recommend eligibility reviews are performed annually in accordance with the South Carolina Medicaid Policies and Procedures Manual.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding:The errors are caused by delays in annual review processing. SCDHHS has continued to implement a plan to reduce and manage the eligibility processing backlog, while also protecting the integrity of eligibility decisions. The agency?s approach has been to build staff capacity through the creation of processing centers and to maximize accuracy and timeliness of eligibility decisions via implementation of a Staff Performance Evaluation and Remediation process.Staff Capacity and Processing Centers: The agency has created and staffed four (4) processing centers in Richland (2), Aiken (1) and Spartanburg (1) counties. Staff processing MAGI, Non-MAGI and Long-Term Care applications now complete available work for processing applications daily, allowing for staff assignments for processing reviews. Staff webinars for processing reviews have been conducted for MAGI and Non-MAGI review processing in the past six months, as well as updates to job aids, based on updated policies and procedures. One additional processing center will be added in Florence County for additional MAGI application and review processing.Staff Performance Evaluation and Remediation: The performance evaluation plan rolled out to staff in July 2019. On the first business day of each month, supervisors receive Employee Performance results for their staff regarding both timeliness and accuracy of eligibility determinations and review these results during one on one meetings. Action plans are established, implemented and reviewed for any needed corrective measures in response to accuracy and/or timeliness metrics. Between August 1, 2019 and January 31, 2020, the state has reviewed 40,015 cases with a 95% accuracy rate.Names of the contact persons responsible for corrective action: Elizabeth Ryan, Michael Jones, Lori RiskPlanned completion date for corrective action plan: September 30, 2020 (New Processing Center)If the U.S. Department of Health and Human Services has questions regarding this plan, please call Thomas C. Phillip, CFO, at 803-898-1017.

Prior Finding References

2018-006

About Eligibility →
2019-009
Reporting
SIGNIFICANT DEFICIENCYREPEAT OF 2018-011OTHER MATTERS

The automated data processing and information retrieval system had not been fully implemented during the audit period.Questioned Costs: UnknownContext: As reported in the prior year, the Department did not implement the automated data processing and information retrieval system as required by Section 454 (24) (B) and as a result has been assessed penalty payments for noncompliance. The Department began implementation of the system in State fiscal year 2019, completed implementation shortly after the State fiscal year, and subsequently received Federal approval of the system.Cause: The Department and its contractor were in process of finalizing implementation of the system during State fiscal year 2019.Effect: Prior to the system being fully implemented, certain data necessary for proper completion of the Office of Child Support Enforcement (OCSE) 34A financial report was not available and, as a result, the Department was not in compliance with its Federal requirements during the audit period.Recommendation: We recommend that Department internal controls remain in place and operating to ensure that the Federally approved child support automated data processing and information retrieval system continues to meet all applicable Federal requirements.Prior Year Single Audit Report Finding Number: 2018-011Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 156.

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ReportingFederal Agency: Department of Health and Human ServicesFederal Program Title: Child Support EnforcementCFDA No.: 93.563Federal Grant ID Number: VariousPass-Through Entity: Not applicableAward Period: VariousType of Finding: Significant deficiency in internal control over compliance, other mattersCriteria: Section 454 (24) of the Social Security Act (the Act), as amended, by the Personal Responsibility and Work Opportunity Reconciliation Act of 1996 (PRWORA), requires states to have an operational automated data processing and information retrieval system for child and spousal support. The system must be in place by October 1, 1997, and meet all the requirements of paragraph (16) of the Act. The secretary of the U.S. Department of Health and Human Services (USDHHS) must approve the system.Condition: The automated data processing and information retrieval system had not been fully implemented during the audit period.Questioned Costs: UnknownContext: As reported in the prior year, the Department did not implement the automated data processing and information retrieval system as required by Section 454 (24) (B) and as a result has been assessed penalty payments for noncompliance. The Department began implementation of the system in State fiscal year 2019, completed implementation shortly after the State fiscal year, and subsequently received Federal approval of the system.Cause: The Department and its contractor were in process of finalizing implementation of the system during State fiscal year 2019.Effect: Prior to the system being fully implemented, certain data necessary for proper completion of the Office of Child Support Enforcement (OCSE) 34A financial report was not available and, as a result, the Department was not in compliance with its Federal requirements during the audit period.Recommendation: We recommend that Department internal controls remain in place and operating to ensure that the Federally approved child support automated data processing and information retrieval system continues to meet all applicable Federal requirements.Prior Year Single Audit Report Finding Number: 2018-011Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 156.

Corrective Action Plan

Department of Health and Human ServicesThe South Carolina Department of Social Services respectfully submits the following corrective action plan for the year ended June 30, 2019.Audit period: June 30, 2019The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule.FINDINGS?FEDERAL AWARD PROGRAM AUDITDEPARTMENT OF SOCIAL SERVICES2019-009 Child Support Enforcement ? CFDA No. 93.563Recommendation: We recommend that Department internal controls remain in place and operating to ensure that the Federally approved child support automated data processing and information retrieval system continues to meet all applicable Federal requirements.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding: The Department completed state-wide system implementation in August 2019 and received Federal Certification from the Office of Child Support Enforcement (OCSE) on September 6, 2019.Name(s) of the contact person(s) responsible for corrective action: Jimmy Early, Project DirectorPlanned completion date for corrective action plan: September 30, 2019If the Federal Cognizant of Oversight Agency for Audit has questions regarding this plan, please call Susan Roben, Controller at 803-898-7427.

Prior Finding References

2018-011

About Reporting →
2019-010
Reporting
MATERIAL WEAKNESSMODIFIED OPINIONREPEAT OF 2018-014

The schedule of expenditures of Federal awards initially prepared by Department management contained several errors, including the incorrect amount of program funds passed through to subrecipients.Questioned Costs: NoneContext: Auditor corrections were necessary for accurate presentation of the schedule of expenditures of Federal awards. In order to agree schedule expenditures to the accounting records, auditor corrections were necessary, including an adjustment in the amount of $3,630,763 to correct the reported subrecipient expenditures.Cause: Management review of the schedule of expenditures of Federal awards failed to detect and correct several presentation errors and accounting transactions that were improperly included in the reported subrecipient expenditure amounts.Effect: Auditor corrections and adjustments were required to correct the schedule of expenditures of Federal awards.Recommendation: We recommend that the Department review procedures for preparing, reviewing and approving its schedule of expenditures of Federal awards to ensure accurate reporting.Prior Year Single Audit Report Finding Number: 2018-014Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 157.

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ReportingFederal Agency: Department of Health and Human ServicesFederal Program Title: Child Support EnforcementCFDA No.: 93.563Federal Grant ID Number: 1804SCCSES, 1904SCCESPass-Through Entity: Not applicableAward Period: October 1, 2017 through September 30, 2019Type of Finding: Material weakness in internal control over compliance, material noncomplianceCriteria: Per 2 CFR ? 200.510(b), the auditee must prepare a schedule of expenditures of Federal awards for the period covered by the auditee?s financial statements which must include the total Federal awards expended as determined in accordance with 2 CFR ? 200.502. Per this section, the schedule must include the total amount provided to subrecipients from each Federal program.Condition: The schedule of expenditures of Federal awards initially prepared by Department management contained several errors, including the incorrect amount of program funds passed through to subrecipients.Questioned Costs: NoneContext: Auditor corrections were necessary for accurate presentation of the schedule of expenditures of Federal awards. In order to agree schedule expenditures to the accounting records, auditor corrections were necessary, including an adjustment in the amount of $3,630,763 to correct the reported subrecipient expenditures.Cause: Management review of the schedule of expenditures of Federal awards failed to detect and correct several presentation errors and accounting transactions that were improperly included in the reported subrecipient expenditure amounts.Effect: Auditor corrections and adjustments were required to correct the schedule of expenditures of Federal awards.Recommendation: We recommend that the Department review procedures for preparing, reviewing and approving its schedule of expenditures of Federal awards to ensure accurate reporting.Prior Year Single Audit Report Finding Number: 2018-014Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 157.

Corrective Action Plan

Department of Health and Human ServicesThe South Carolina Department of Social Services respectfully submits the following corrective action plan for the year ended June 30, 2019.Audit period: June 30, 2019The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule.FINDINGS?FEDERAL AWARD PROGRAM AUDIT2019-010 Child Support Enforcement ? CFDA No. 93.563Recommendation: We recommend that the Department review procedures for preparing, reviewing and approving its Schedule of Expenditures of Federal Awards to ensure accurate reporting.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding: This finding resulted from the incorrect inclusion of Incentive Grant expenditures in subrecipient costs. Procedures have already been implemented to review subrecipient expenditures to be reported to ensure they exclude Incentive funds. The Department will also implement an additional level of review of the SEFA report to ensure accurate reporting.Name(s) of the contact person(s) responsible for corrective action: Ashley Harris, Grants Accounting and Reporting ManagerPlanned completion date for corrective action plan: August 30, 2020If the Federal Cognizant of Oversight Agency for Audit has questions regarding this plan, please call Susan Roben, Controller at 803-898-7427.

Prior Finding References

2018-014

About Reporting →
2019-011
Cash Management
SIGNIFICANT DEFICIENCYOTHER MATTERS

Documentation supporting Federal cash draws was not adequate to confirm compliance with cash management requirements.Questioned Costs: NoneContext: Department supporting documentation was not adequate to fully support accurate reimbursement for fifteen of fifteen Federal cash draws tested. In addition two related instances of amounts subsequently being required to be returned to their respective grantors were noted.Cause: Due to staffing turnover, the Department?s internal controls associated with Federal cash draws were not operating effectively to demonstrate compliance and prevent errors.Effect: The Department did not adequately document their Federal cash draw process to demonstrate compliance. Additionally, there were two instances in which the Department returned overdrawn funding to the grantor: one for $781,141 to the Child Support Enforcement program and another for $121,539 to the Adoption Assistance program.Recommendation: We recommend that the Department review its internal controls over the Federal cash draws process to ensure compliance with cash management requirements.Prior Year Single Audit Report Finding Number: Not applicableViews of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 157.

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Cash ManagementFederal Agency: Department of Health and Human ServicesFederal Program Title: Child Support Enforcement, Social Services Block Grant, Adoption AssistanceCFDA No.: 93.563, 93.667, 93.659Federal Grant ID Number: 1804SCCSES, 1802SCSORSR, 1801SCADPT, 1901SCADPTPass-Through Entity: Not applicableAward Period: October 1, 2017 through September 30, 2019Type of Finding: Significant deficiency in internal control over compliance, other mattersCriteria: Per 31 CFR ? 205.12(b)(5) reimbursable funding means that a Federal Program Agency transfers Federal funds to a State after that State has already paid out the funds for Federal assistance program purposes.Condition: Documentation supporting Federal cash draws was not adequate to confirm compliance with cash management requirements.Questioned Costs: NoneContext: Department supporting documentation was not adequate to fully support accurate reimbursement for fifteen of fifteen Federal cash draws tested. In addition two related instances of amounts subsequently being required to be returned to their respective grantors were noted.Cause: Due to staffing turnover, the Department?s internal controls associated with Federal cash draws were not operating effectively to demonstrate compliance and prevent errors.Effect: The Department did not adequately document their Federal cash draw process to demonstrate compliance. Additionally, there were two instances in which the Department returned overdrawn funding to the grantor: one for $781,141 to the Child Support Enforcement program and another for $121,539 to the Adoption Assistance program.Recommendation: We recommend that the Department review its internal controls over the Federal cash draws process to ensure compliance with cash management requirements.Prior Year Single Audit Report Finding Number: Not applicableViews of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 157.

Corrective Action Plan

Department of Health and Human ServicesThe South Carolina Department of Social Services respectfully submits the following corrective action plan for the year ended June 30, 2019.Audit period: June 30, 2019The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule.FINDINGS?FEDERAL AWARD PROGRAM AUDIT2019-011 Child Support Enforcement, Social Services Block Grant, Adoption Assistance ? CFDA No.93.563, 93.667, 93.659Recommendation: We recommend that the Department review its internal controls over the Federal cash draws process to ensure compliance with cash management requirements.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding: The Department will put procedures in place to ensure proper supporting documentation from the accounting system is retained to support accurate reimbursement for all Federal cash draws. Draws will also be performed on a periodic basis to be determined by individual grant, but at least monthly if needed.Name(s) of the contact person(s) responsible for corrective action: Ashley Harris, Grants Accounting and Reporting ManagerPlanned completion date for corrective action plan: March 31, 2020If the Federal Cognizant of Oversight Agency for Audit has questions regarding this plan, please call Susan Roben, Controller at 803-898-7427.

About Cash Management →
2019-012
Matching, Level of Effort, Earmarking / Reporting
SIGNIFICANT DEFICIENCYOTHER MATTERS

An annual federal financial report, SF-425, and two quarterly CB-496 reports were submitted with financial and statistical errors.Questioned Costs: NoneContext: For one of two annual SF-425 reports selected for testing, incorrect amounts were reported for Federal cash receipts and cash disbursements. Receipts occurring after the report date were included on the cash basis report and total Federal funds authorized were mistakenly reported as disbursements.For both CB-496 reports selected for testing, administrative costs ? non-recurring were reported with administrative costs ? agency, rather than separately as required by the report instructions. In addition, discrepancies were noted between the supporting documentation and number of payments for children assisted reported in Part 1, Section D of the report. Finally, in Part 4 of the report, discrepancies were noted when agreeing to data used to calculate amounts reported on lines 3 and 5 and the Department was unable to provide support for the amount reported on line 10. Because of the relationship of the amount on line 10 to level of effort compliance, level of effort compliance could not be confirmed.Cause: The Department?s internal controls failed to detect the errors prior to submission of the reports.Effect: Federal cash receipts and cash disbursements were overstated on the SF-425 report.All administrative costs ? non-recurring were misclassified as administrative costs ? agency on each of the two CB-496 reports tested. Certain amounts reported in Part 1, Section D, and in Part 4 of the report could not be validated.Recommendation: We recommend that the Department strengthen its internal controls and processes to ensure that Federal reports are free from error and clearly supported prior to submission of the report.Prior Year Single Audit Report Finding Number: Not applicableViews of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 157.

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Reporting/Level of EffortFederal Agency: Department of Health and Human ServicesFederal Program Title: Social Services Block Grant, Adoption AssistanceCFDA No.: 93.667, 93.659Federal Grant ID Number: 1802SCSOSR, 1801SCADPT, 1901SCADPTPass-Through Entity: Not applicableAward Period: October 1, 2017 through September 30, 2019Type of Finding: Significant deficiency in internal control over compliance, other mattersCriteria: 45 CFR ? 75.342 requires compliance with the provisions of monitoring and reporting program performance. The Department's internal controls should be designed to ensure compliance with those provisions.42 U.S.C. ? 673(a)(8) outlines the level of effort requirements for adoption savings.Condition: An annual federal financial report, SF-425, and two quarterly CB-496 reports were submitted with financial and statistical errors.Questioned Costs: NoneContext: For one of two annual SF-425 reports selected for testing, incorrect amounts were reported for Federal cash receipts and cash disbursements. Receipts occurring after the report date were included on the cash basis report and total Federal funds authorized were mistakenly reported as disbursements.For both CB-496 reports selected for testing, administrative costs ? non-recurring were reported with administrative costs ? agency, rather than separately as required by the report instructions. In addition, discrepancies were noted between the supporting documentation and number of payments for children assisted reported in Part 1, Section D of the report. Finally, in Part 4 of the report, discrepancies were noted when agreeing to data used to calculate amounts reported on lines 3 and 5 and the Department was unable to provide support for the amount reported on line 10. Because of the relationship of the amount on line 10 to level of effort compliance, level of effort compliance could not be confirmed.Cause: The Department?s internal controls failed to detect the errors prior to submission of the reports.Effect: Federal cash receipts and cash disbursements were overstated on the SF-425 report.All administrative costs ? non-recurring were misclassified as administrative costs ? agency on each of the two CB-496 reports tested. Certain amounts reported in Part 1, Section D, and in Part 4 of the report could not be validated.Recommendation: We recommend that the Department strengthen its internal controls and processes to ensure that Federal reports are free from error and clearly supported prior to submission of the report.Prior Year Single Audit Report Finding Number: Not applicableViews of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 157.

Corrective Action Plan

Department of Health and Human ServicesThe South Carolina Department of Social Services respectfully submits the following corrective action plan for the year ended June 30, 2019.Audit period: June 30, 2019The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule.FINDINGS?FEDERAL AWARD PROGRAM AUDIT2019-012 Social Services Block Grant, Adoption Assistance ? CFDA No. 93.667, 93.659Recommendation: We recommend that the Department strengthen its internal controls and processes to ensure that Federal reports are free from error and clearly supported prior to submission of the report.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding: Due to staff turnover, the Department has an entirely new Grants Accounting and Reporting team. All staff are being trained on the proper completion of the Federal Financial Reports, including period of performance cut-off dates. In addition, each report will be reviewed by a manager or the Controller prior to submission.Name(s) of the contact person(s) responsible for corrective action: Ashley Harris, Grants Accounting and Reporting ManagerPlanned completion date for corrective action plan: June 30, 2020If the Federal Cognizant of Oversight Agency for Audit has questions regarding this plan, please call Susan Roben, Controller at 803-898-7427.

About Matching, Level of Effort, Earmarking, Reporting →
2019-013
Activities Allowed or Unallowed
SIGNIFICANT DEFICIENCYQUESTIONED COSTSOTHER MATTERS

A Department case service expenditure unrelated to the Adoption Assistance program was charged to the grant.Questioned Costs: $3,345Context: One of sixty expenditures selected for testing was for an activity not related to the Adoption Assistance program.Cause: The Department?s internal controls failed to prevent an improper charge to the grant.Effect: Program funds were used to pay a claim that was not allowable in accordance with federal regulations.Recommendation: We recommend that the Department strengthen its internal controls and processes to ensure that all charges to the grant are for allowable activities only.Prior Year Single Audit Report Finding Number: Not applicableViews of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 158.

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Activities Allowed or UnallowedFederal Agency: Department of Health and Human ServicesFederal Program Title: Adoption AssistanceCFDA No.: 93.659Federal Grant ID Number: 1901SCADPTPass-Through Entity: Not applicableAward Period: October 1, 2018 through September 30, 2019Type of Finding: Significant deficiency in internal control over compliance, other mattersCriteria: 45 CFR ? 1356 identifies the allowable activities of the Adoption Assistance grant program.Condition: A Department case service expenditure unrelated to the Adoption Assistance program was charged to the grant.Questioned Costs: $3,345Context: One of sixty expenditures selected for testing was for an activity not related to the Adoption Assistance program.Cause: The Department?s internal controls failed to prevent an improper charge to the grant.Effect: Program funds were used to pay a claim that was not allowable in accordance with federal regulations.Recommendation: We recommend that the Department strengthen its internal controls and processes to ensure that all charges to the grant are for allowable activities only.Prior Year Single Audit Report Finding Number: Not applicableViews of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 158.

Corrective Action Plan

Department of Health and Human ServicesThe South Carolina Department of Social Services respectfully submits the following corrective action plan for the year ended June 30, 2019.Audit period: June 30, 2019The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule.FINDINGS?FEDERAL AWARD PROGRAM AUDIT2019-013 Adoption Assistance ? CFDA No. 93.659Recommendation: We recommend that the Department strengthen its internal controls and processes to ensure that all charges to the grant are for allowable activities only.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding: The Department will conduct additional staff training to stress the importance of coding invoices to the general ledger account segments that are listed and approved on the invoice. An Accounts Payable manager or supervisor will also review the coding on the invoice when approving the invoice through workflow in SCEIS to ensure it matches what has been entered in SCEIS.Name(s) of the contact person(s) responsible for corrective action: Zandria Buck, Accounts Payable ManagerPlanned completion date for corrective action plan: March 31, 2020If the Federal Cognizant of Oversight Agency for Audit has questions regarding this plan, please call Susan Roben, Controller at 803-898-7427.

About Activities Allowed or Unallowed →
2019-014
Cost Allowability
SIGNIFICANT DEFICIENCYQUESTIONED COSTSOTHER MATTERS

Allowable training costs charged to the program were not adequately supported.Questioned Costs: $73,338Context: Seven of eight administrative and training disbursement transactions selected for testing were for allowable training costs benefitting multiple grant programs. The Department?s allocation of the cost, and related cost share, to the various grant programs was not adequately supported.Cause: Training costs benefitting multiple programs were charged using a previously determined rate without updating the charge to match the actual proportional benefit to each program.Effect: The potential for overcharging the grant exists when costs are charged to the programs without documenting the proportional benefit in accordance with the federal regulations.Recommendation: We recommend the Department update internal controls for charging direct training costs benefitting multiple programs to ensure that the costs charged only reflect the net proportional benefit applicable to each program.Prior Year Single Audit Report Finding Number: Not applicableViews of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 158.

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Allowable Costs/Cost PrinciplesFederal Agency: Department of Health and Human ServicesFederal Program Title: Adoption AssistanceCFDA No.: 93.659Federal Grant ID Number: 1801SCADPT, 1901SCADPTPass-Through Entity: Not applicableAward Period: October 1, 2017 through September 30, 2019Type of Finding: Significant deficiency in internal control over compliance, other mattersCriteria: 45 CFR ? 75.405(d) addresses the requirements and guidance for the allocation of direct costs applicable to multiple projects.Condition: Allowable training costs charged to the program were not adequately supported.Questioned Costs: $73,338Context: Seven of eight administrative and training disbursement transactions selected for testing were for allowable training costs benefitting multiple grant programs. The Department?s allocation of the cost, and related cost share, to the various grant programs was not adequately supported.Cause: Training costs benefitting multiple programs were charged using a previously determined rate without updating the charge to match the actual proportional benefit to each program.Effect: The potential for overcharging the grant exists when costs are charged to the programs without documenting the proportional benefit in accordance with the federal regulations.Recommendation: We recommend the Department update internal controls for charging direct training costs benefitting multiple programs to ensure that the costs charged only reflect the net proportional benefit applicable to each program.Prior Year Single Audit Report Finding Number: Not applicableViews of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 158.

Corrective Action Plan

Department of Health and Human ServicesThe South Carolina Department of Social Services respectfully submits the following corrective action plan for the year ended June 30, 2019.Audit period: June 30, 2019The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule.FINDINGS?FEDERAL AWARD PROGRAM AUDIT2019-014 Adoption Assistance ? CFDA No. 93.659Recommendation: We recommend the Department update internal controls for charging direct training costs benefitting multiple programs to ensure that the costs charged only reflect the net proportional benefit applicable to each program.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding: The Department has already begun updating its process for charging training costs beginning July 1, 2019. Each invoice submitted will have a listing of each training course that was provided, along with a listing of the costsseparated between training and administrative costs. This will allow the Department to charge each training to the benefitting program based on the specific training course conducted.Name(s) of the contact person(s) responsible for corrective action: Susan Roben, ControllerPlanned completion date for corrective action plan: June 30, 2020If the Federal Cognizant of Oversight Agency for Audit has questions regarding this plan, please call Susan Roben, Controller at 803-898-7427.

About Allowable Costs / Cost Principles →
2019-015
Eligibility
MATERIAL WEAKNESSMODIFIED OPINIONQUESTIONED COSTS

Eligibility could not be confirmed for some payments tested.Questioned Costs: $2,346Context: Sixty payments were selected for testing of eligibility compliance. The adoption subsidy agreement on file for four of those payments was not signed in accordance with the federal regulations, and one of those files lacked any additional documentation to verify eligibility. For another payment tested, the subsidy payment exceeded the amount documented on the adoption subsidy agreement. In addition, documentation was not adequate to support three subsidy payments tested for eligible children no longer under the age of eighteen at the time of the payment.Cause: Documentation in some case files was not adequate to support the applicable subsidy payments.Effect: Eligibility, in accordance with federal and/or Department requirements, could not be confirmed for some subsidy payments.Recommendation: We recommend that the Department review eligibility file controls to ensure that all payments are adequately supported throughout the eligibility period.Prior Year Single Audit Report Finding Number: Not applicableViews of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 159.

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EligibilityFederal Agency: Department of Health and Human ServicesFederal Program Title: Adoption AssistanceCFDA No.: 93.659Federal Grant ID Number: 1801ASADPT, 1901SCADPTPass-Through Entity: Not applicableAward Period: October 1, 2017 through September 30, 2019Type of Finding: Material weakness in internal control over compliance, material noncomplianceCriteria: 45 CFR ? 75.361 outlines record retention requirements of the non-Federal entity pertinent to the Federal award.45 CFR ? 1356.40(b) outlines the requirements pertaining to signed adoption agreements.42 U.S.C. ? 673(a) outlines eligibility requirements for subsidy payments.42 U.S.C. ? 675(8) expands eligibility requirements for children over the age of 18.Condition: Eligibility could not be confirmed for some payments tested.Questioned Costs: $2,346Context: Sixty payments were selected for testing of eligibility compliance. The adoption subsidy agreement on file for four of those payments was not signed in accordance with the federal regulations, and one of those files lacked any additional documentation to verify eligibility. For another payment tested, the subsidy payment exceeded the amount documented on the adoption subsidy agreement. In addition, documentation was not adequate to support three subsidy payments tested for eligible children no longer under the age of eighteen at the time of the payment.Cause: Documentation in some case files was not adequate to support the applicable subsidy payments.Effect: Eligibility, in accordance with federal and/or Department requirements, could not be confirmed for some subsidy payments.Recommendation: We recommend that the Department review eligibility file controls to ensure that all payments are adequately supported throughout the eligibility period.Prior Year Single Audit Report Finding Number: Not applicableViews of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 159.

Corrective Action Plan

Department of Health and Human ServicesThe South Carolina Department of Social Services respectfully submits the following corrective action plan for the year ended June 30, 2019.Audit period: June 30, 2019The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule.FINDINGS?FEDERAL AWARD PROGRAM AUDIT2019-015 Adoption Assistance ? CFDA No. 93.659Recommendation: We recommend that the Department review eligibility file controls to ensure that all payments are adequately supported throughout the eligibility period.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding: All adoption subsidy agreements are currently sent to the State Office Adoptions Manager for signature. When the agreements are entered into CAPSS, staff verify that the agreement includes the proper signature. The Department will begin reviewing older files to ensure all subsidy agreements have the proper signatures in accordance with federal regulations.The Department will also create a review tool to verify eligibility and staff will pull fifteen (15) sample cases quarterly to conduct internal review to ensure all subsidy payments are adequately supported. The State Office Adoptions Manager will verify the subsidy agreement with the subsidy payment to ensure the amounts are correct. If a discrepancy is found, the manager will contact the region for clarification.The Department will send school verification letters prior to the child?s 18th birthday if documentation was not previously provided to ensure subsidy payments are terminated at the end of the 18th birthday month.Name(s) of the contact person(s) responsible for corrective action: Dawn Barton, Director of Permanency ManagementPlanned completion date for corrective action plan: June 30, 2020If the Federal Cognizant of Oversight Agency for Audit has questions regarding this plan, please call Susan Roben, Controller at 803-898-7427.

About Eligibility →
2019-016
Period of Performance
SIGNIFICANT DEFICIENCYOTHER MATTERS

Matching funds charged to the grant were liquidated after the end of the succeeding fiscal year of the grant.Questioned Costs: UndeterminedContext: One of five transactions selected for testing was a journal entry which traced back to disbursement transactions that were liquidated after the end of the liquidation period of the grant.Cause: The Department?s internal controls failed to identify and prevent the liquidation of funds after the allowed period.Effect: Expenditures may be charged to the grant that are outside the allowed period of performance.Recommendation: We recommend that the Department strengthen internal controls to ensure that all awarded funds are liquidated within the award?s period of performance.Prior Year Single Audit Report Finding Number: Not applicableViews of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 159.

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Period of PerformanceFederal Agency: Department of Health and Human ServicesFederal Program Title: Child Care and Development FundCFDA No.: 93.575, 93.596Federal Grant ID Number: 1701SCCCDFPass-Through Entity: Not applicableAward Period: October 1, 2016 through September 30, 2018Type of Finding: Significant deficiency in internal control over compliance, other mattersCriteria: 45 CFR ? 98.60(d)(3) states, both the Federal and non-Federal share of the Matching Fund shall be obligated in the fiscal year in which the funds are granted and liquidated no later than the end of the succeeding fiscal year.Condition: Matching funds charged to the grant were liquidated after the end of the succeeding fiscal year of the grant.Questioned Costs: UndeterminedContext: One of five transactions selected for testing was a journal entry which traced back to disbursement transactions that were liquidated after the end of the liquidation period of the grant.Cause: The Department?s internal controls failed to identify and prevent the liquidation of funds after the allowed period.Effect: Expenditures may be charged to the grant that are outside the allowed period of performance.Recommendation: We recommend that the Department strengthen internal controls to ensure that all awarded funds are liquidated within the award?s period of performance.Prior Year Single Audit Report Finding Number: Not applicableViews of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 159.

Corrective Action Plan

Department of Health and Human ServicesThe South Carolina Department of Social Services respectfully submits the following corrective action plan for the year ended June 30, 2019.Audit period: June 30, 2019The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule.FINDINGS?FEDERAL AWARD PROGRAM AUDIT2019-016 Child Care Development Fund ? CFDA No. 93.575, 93.596Recommendation: We recommend that the Department strengthen internal controls toensure that all awarded funds are liquidated within the award?s period of performance.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding: The Department has already put procedures in place to review invoices before they are paid to ensure each invoice is paid to the correct period of performance. Staff will also review general ledger posting and transaction dates to ensure that all awarded funds are posted to the correct period of performance.Name(s) of the contact person(s) responsible for corrective action: Ashley Harris, Grants and Reporting ManagerPlanned completion date for corrective action plan: March 31, 2020If the Federal Cognizant of Oversight Agency for Audit has questions regarding this plan, please call Susan Roben, Controller at 803-898-7427.

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2019-017
Subrecipient Monitoring
MATERIAL WEAKNESSMODIFIED OPINION

The Department communicates grant and program information to each subrecipient annually through a standardized contracting agreement, however not all of the required information is included in the process.Questioned Costs: NoneContext: For eight of eight subrecipients tested, subaward documents did not include all of the federally required information.Cause: The Department?s internal controls failed to ensure adequate communications to the subrecipients through the annual subaward process as required by the federal regulations.Effect: The Department is not in compliance with the requirements for pass-through entities.Recommendation: We recommend that the Department update subrecipient agreements to incorporate all of the required information to ensure adequate communication to their subrecipients.Prior Year Single Audit Finding Number: Not applicableViews of Responsible Offices and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 161.

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Subrecipient MonitoringFederal Agency: Department of Health and Human ServicesFederal Program Title: Prevention and Treatment of Substance AbuseCFDA No.: 93.959Federal Grant ID Number: J2001SAPBG17, J2001SAPBG18, J2001SAPBG19Pass-Through Entity: Not applicableAward Period: October 1, 2016 through September 30, 2020Type of Finding: Material weakness in internal control over compliance, material noncomplianceCriteria: Per 45 CFR ?75.352(a) All pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes all of the information required by 45 CFR 75.352 (a)(1)(i-xiii) at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward.Condition: The Department communicates grant and program information to each subrecipient annually through a standardized contracting agreement, however not all of the required information is included in the process.Questioned Costs: NoneContext: For eight of eight subrecipients tested, subaward documents did not include all of the federally required information.Cause: The Department?s internal controls failed to ensure adequate communications to the subrecipients through the annual subaward process as required by the federal regulations.Effect: The Department is not in compliance with the requirements for pass-through entities.Recommendation: We recommend that the Department update subrecipient agreements to incorporate all of the required information to ensure adequate communication to their subrecipients.Prior Year Single Audit Finding Number: Not applicableViews of Responsible Offices and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 161.

Corrective Action Plan

U.S. Department of Health and Human ServicesRE: Corrective Action Plan for Year Ended June 30, 2019The South Carolina Department of Alcohol and Other Drug Abuse Services respectfully submits the following corrective action plan for the year ended June 30, 2019.The schedule of findings and questioned costs are discussed below. The findings are numbered in accordance with the numbers assigned in the schedule.FINDINGS - FEDERAL AWARD PROGRAM AUDIT2019-017. Prevention and Treatment of Substance Abuse - CFDA No.: 93.959Recommendation: We recommend that the Department update subrecipient agreements to incorporate all of the required information to ensure adequate communication to their subrecipients.Explanation of disagreement with audit finding: NIAAction taken in response to finding: Since the Single Audit, all required information has been added to the sub-awards, to include the Federal Award Identification Number (FAIN) and the federal award date. In State Fiscal Year 2021, the awards will contain all the required information.Name(s) of the contact person(s) responsible for corrective action:Carmen TatePlanned completion date for corrective action plan: Any sub-awards implemented in January 2020 contained the required information.If there are any questions regarding this corrective action plan, please contact me at 803-896-1145 .

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2019-018
Activities Allowed or Unallowed / Cost Allowability
MATERIAL WEAKNESSOTHER MATTERS

The Department did not have adequately functioning controls over time and effort reporting to ensure timesheets were reviewed by a direct supervisor and supporting evidence was maintained.Questioned Costs: UnknownContext: For nineteen of forty payroll transactions tested, employee time and effort review and approval documentation was not maintained in order to adequately support control process.Cause: The Department did not maintain documentation of direct supervisor review and approval of time and effort.Effect: The Department is not in compliance with applicable allowable activities/costs requirements.Recommendation: We recommend that the Department implement policies and procedures to ensure that sufficient documentation of reviews and approvals are maintained.Prior Year Single Audit Finding Number: Not applicableViews of Responsible Offices and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 161.

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Activities Allowed or Unallowed and Allowable Costs/Cost PrinciplesFederal Agency: Department of Health and Human ServicesFederal Program Title: Prevention and Treatment of Substance AbuseCFDA No.: 93.959Federal Grant ID Number: J2001SAPBG18, J2001SAPBG19Pass-Through Entity: Not applicableAward Period: October 1, 2017 through September 30, 2020Type of Finding: Material Weakness in internal control over compliance, other mattersCriteria: Per 2 CFR ? 200.430 (a) Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities; (2) Follows an appointment made in accordance with a non-Federal entity?s laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, Standards for Documentation of Personnel Expenses, when applicable.Condition: The Department did not have adequately functioning controls over time and effort reporting to ensure timesheets were reviewed by a direct supervisor and supporting evidence was maintained.Questioned Costs: UnknownContext: For nineteen of forty payroll transactions tested, employee time and effort review and approval documentation was not maintained in order to adequately support control process.Cause: The Department did not maintain documentation of direct supervisor review and approval of time and effort.Effect: The Department is not in compliance with applicable allowable activities/costs requirements.Recommendation: We recommend that the Department implement policies and procedures to ensure that sufficient documentation of reviews and approvals are maintained.Prior Year Single Audit Finding Number: Not applicableViews of Responsible Offices and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 161.

Corrective Action Plan

U.S. Department of Health and Human ServicesRE: Corrective Action Plan for Year Ended June 30, 2019The South Carolina Department of Alcohol and Other Drug Abuse Services respectfully submits the following corrective action plan for the year ended June 30, 2019.The schedule of findings and questioned costs are discussed below. The findings are numbered in accordance with the numbers assigned in the schedule.2019-018. Prevention and Treatment of Substance Abuse - CFDA No.: 93.959Recommendation: We recommend that the Department implement policies and procedures to ensure that sufficient documentation of reviews and approvals is maintained.Explanation of disagreement with audit finding: NIAAction taken in response to finding: Effective January 2020, the agency automated the time-and-effort process. Upon the completion of a DAODAS Time Sheet, employees convert the sheet to a PDFcontaining their electronic signature, which is due to their managers by the fifth of each month. The time sheets must be approved by the manager with an electronic signature and placed in a shared folder by the 10th of each month. The Human Resource Manager is responsible for sending notifications/reminders to employees on or after the 10th if any timesheets are missing.Name(s) of the contact person(s) responsible for corrective action: Sharon PetersonPlanned completion date for corrective action plan: The new process was implemented with the submission of January 2020 time-and-effort information.If there are any questions regarding this corrective action plan, please contact me at 803-896-1145 .

About Activities Allowed or Unallowed, Allowable Costs / Cost Principles →
2019-019
Cash Management
SIGNIFICANT DEFICIENCYREPEAT OF 2018-036OTHER MATTERS

For the full fiscal year, the Department did not have an internal control process in place to ensure that reimbursement requests sent to the federal cognizant agency were fully supported by expenditures previously paid out by the state.Questioned Costs: NoneContext: The Department was deemed to be in compliance with these provisions for the fiscal year; however, standardized internal control processes did not exist before February 11, 2019 to ensure that reimbursement was for expenditures already incurred and paid prior to receipt of federal funds. This was noted for twenty-five of the sixty reimbursement requests tested, all of which occurred prior to the implementation of the new policies and procedures.Cause: The Department implemented a new process on February 11, 2019. Policies and procedures prior to this date were ineffective to ensure that documentation was maintained to support that each reimbursement request was adequately supported and reviewed prior to request for funds.Effect: The Department may draw funds in excess of the allowable expenses.Recommendation: We recommend that the Department continue to follow the newly implemented policies and procedures.Prior Year Single Audit Report Finding Number: 2018-036Views of Responsible Offices and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 163.

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Cash ManagementFederal Agency: VariousFederal Program Title: Research and Development ClusterCFDA No.: VariousFederal Grant ID Number: VariousPass-Through Entity: VariousAward Period: VariousType of Finding: Significant deficiency in internal control over compliance, other mattersCriteria: Per 31 CFR ? 205.12(c)(5) Reimbursable funding means that a Federal Program Agency transfers Federal funds to a State after that State has already paid out the funds for Federal assistance program purposes.Condition: For the full fiscal year, the Department did not have an internal control process in place to ensure that reimbursement requests sent to the federal cognizant agency were fully supported by expenditures previously paid out by the state.Questioned Costs: NoneContext: The Department was deemed to be in compliance with these provisions for the fiscal year; however, standardized internal control processes did not exist before February 11, 2019 to ensure that reimbursement was for expenditures already incurred and paid prior to receipt of federal funds. This was noted for twenty-five of the sixty reimbursement requests tested, all of which occurred prior to the implementation of the new policies and procedures.Cause: The Department implemented a new process on February 11, 2019. Policies and procedures prior to this date were ineffective to ensure that documentation was maintained to support that each reimbursement request was adequately supported and reviewed prior to request for funds.Effect: The Department may draw funds in excess of the allowable expenses.Recommendation: We recommend that the Department continue to follow the newly implemented policies and procedures.Prior Year Single Audit Report Finding Number: 2018-036Views of Responsible Offices and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 163.

Corrective Action Plan

U.S. Department of InteriorSouth Carolina Department of Natural Resources respectfuly submits the following corrective action plan for the year ended 6/30/19.The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule.FINDINGS?FEDERAL AWARD PROGRAM AUDITFederal Agency: Various2019-019 Research and Development ClusterRecommendation: We recommend that the Department continue to follow the newly implemented policies and procedures.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding: Policies and procedures were implemented February 11, 2019 to ensure the proper and consistent documentation in our grants files throughout the Department to include the drawdown of funds. The Department will continue to follow these policies and procedures.Name(s) of the contact person(s) responsible for corrective action: Caleb-Scott CohoonPlanned completion date for corrective action plan: February 11, 2019If the U.S. Department of Interior Services has questions regarding this plan, please call Caleb- Scott Cohoon at 803-734-1518.

Prior Finding References

2018-036

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2019-020
Reporting
SIGNIFICANT DEFICIENCYREPEAT OF 2018-037

The Department submitted a Schedule of Expenditures of Federal Awards (SEFA) that contained incorrect information for certain awards.Questioned Costs: NoneContext: For one of the two hundred eighteen federal awards within the Department's Research and Development Cluster there was incorrect information noted on the submitted SEFA.Cause: The Department's internal controls failed to identify errors on the SEFA that was submitted.Effect: The Department may report incorrect information on the SEFA.Recommendation: We recommend that the Department strengthen internal controls regarding the preparation and review of their SEFA to ensure such errors are identified and corrected prior to submission.Prior Year Single Audit Report Finding Number: 2018-037Views of Responsible Offices and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 164.

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ReportingFederal Agency: VariousFederal Program Title: Research and Development ClusterCFDA No.: VariousFederal Grant ID Number: VariousPass-Through Entity: VariousAward Period: VariousType of Finding: Significant deficiency in internal control over complianceCriteria: Per 2 CFR ? 200.303 Internal controls, 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 and the ``Internal Control Integrated Framework??, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).Condition: The Department submitted a Schedule of Expenditures of Federal Awards (SEFA) that contained incorrect information for certain awards.Questioned Costs: NoneContext: For one of the two hundred eighteen federal awards within the Department's Research and Development Cluster there was incorrect information noted on the submitted SEFA.Cause: The Department's internal controls failed to identify errors on the SEFA that was submitted.Effect: The Department may report incorrect information on the SEFA.Recommendation: We recommend that the Department strengthen internal controls regarding the preparation and review of their SEFA to ensure such errors are identified and corrected prior to submission.Prior Year Single Audit Report Finding Number: 2018-037Views of Responsible Offices and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 164.

Corrective Action Plan

U.S. Department of InteriorSouth Carolina Department of Natural Resources respectfuly submits the following corrective action plan for the year ended 6/30/19.The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule.FINDINGS?FEDERAL AWARD PROGRAM AUDITFederal Agency: Various2019-020 Research and Development ClusterRecommendation: We recommend that the Department strengten internal controls regarding the preparation and review of their SEFA to ensure such errors are identified and corrected prior to submission.Explanation of disagreement with audit finding: There is no disagreement with audit findings.Action taken in response to finding: Policies and procedures were implemented March 1, 2019 to ensure that the SEFA is completed correctly and reviewed in order to identify and correct errors prior to submission. The Department will work to better document the review process of the SEFA per those procedures.Name(s) of the contact person(s) responsible for corrective action: Caleb-Scott CohoonPlanned completion date for corrective action plan: March 1, 2019If the U.S. Department of Interior Services has questions regarding this plan, please call Caleb- Scott Cohoon at 803-734-1518.

Prior Finding References

2018-037

About Reporting →
2019-021
Period of Performance
SIGNIFICANT DEFICIENCYREPEAT OF 2018-033OTHER MATTERS

The Department charged the federal award for services performed prior to the related award's period of performance.Questioned Costs: UnknownContext: For one of the twenty-five transactions tested with period of performance beginning dates during the fiscal year, it was noted that the cost charged to the award was for services performed prior to the period of performance.Cause: The Department did not timely process the expenditure, resulting in the expenditure incorrectly being charged to the subsequent year grant.Effect: The Department may request reimbursement for expenses not incurred within the period of performance.Recommendation: We recommend that the Department strengthen internal controls to ensure all expenditures charged to a grant are incurred during the award's period of performance.Prior Year Single Audit Finding Number: 2018-033Views of Responsible Offices and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 165.

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Period of PerformanceFederal Agency: VariousFederal Program Title: Research and Development ClusterCFDA No.: VariousFederal Grant ID Number: VariousPass-Through Entity: VariousAward Period: VariousType of Finding: Significant deficiency in internal control over compliance, other mattersCriteria: Per 2 CFR ? 200.309 Period of Performance, a non-Federal entity may charge to the Federal award only allowable costs incurred during the period of performance (except as described in ?200.461 Publication and printing costs) and any costs incurred before the Federal awarding agency or pass-through entity made the Federal award that were authorized by the Federal awarding agency or pass-through entity.Condition: The Department charged the federal award for services performed prior to the related award's period of performance.Questioned Costs: UnknownContext: For one of the twenty-five transactions tested with period of performance beginning dates during the fiscal year, it was noted that the cost charged to the award was for services performed prior to the period of performance.Cause: The Department did not timely process the expenditure, resulting in the expenditure incorrectly being charged to the subsequent year grant.Effect: The Department may request reimbursement for expenses not incurred within the period of performance.Recommendation: We recommend that the Department strengthen internal controls to ensure all expenditures charged to a grant are incurred during the award's period of performance.Prior Year Single Audit Finding Number: 2018-033Views of Responsible Offices and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 165.

Corrective Action Plan

U.S. Department of Health and Human ServicesSouth Carolina Department of Health and Environmental Control respectfully submits the following corrective action plan for the year ended 6/30/19.The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule.FINDINGS-FEDERAL AWARD PROGRAM AUDITVarious2019-021 Research and Development ClusterRecommendation: We recommend that the Department strengthen internal controls to ensure all expenditures charged to a grant are incurred during the award's period of performance.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding: The Department discussed the finding with staff and will continue to strengthen its internal controls to ensure that all expenditures are allocated to the correct grant based on its validity date.Name(s) of the contact person(s) responsible for corrective action: Sandra CraigPlanned completion date for corrective action plan: Finding already addressedIf the U.S. Department of Health and Human Services has questions regarding this plan, please call Kim Paradeses at 803-898-3390.

Prior Finding References

2018-033

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2019-022
Subrecipient Monitoring
MATERIAL WEAKNESSMODIFIED OPINION

The Department did not clearly communicate all of the required information to subrecipients.Questioned Costs: NoneContext: For three of the six subrecipients tested, the subrecipient agreement did not include all of the required information.Cause: The Department does not have the necessary policies and procedures in place regarding subrecipient agreements to facilitate compliance with federal requirements.Effect: The Department is not in compliance with the Federal subrecipient monitoring requirements.Recommendation: We recommend that the Department implement policies and procedures to facilitate compliance with federal subrecipient monitoring requirements.Prior Year Single Audit Finding Number: Not applicableViews of Responsible Offices and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 166.

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Subrecipient MonitoringFederal Agency: Department of Health and Human ServicesFederal Program Title: HIV Care Formula Grants (Ryan White HIV/AIDS Program Part B)CFDA No.: 93.917Federal Grant ID Number: X08HA32379-01-00; X07HA00038-28-02; X07HA00038-29-00Pass-Through Entity: Not applicableAward Period: VariousType of Finding: Material weakness in internal control over compliance, material noncomplianceCriteria: Per 2 CFR ? 200.331 all pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes all of the required information at the time of the subaward (b) Evaluate each subrecipient?s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraph (e) of this section, (c) Consider imposing specific subaward conditions upon a subrecipient if appropriate as described in ? 200.207 Specific conditions. (d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. (f) Verify that every subrecipient is audited as required by Subpart F? Audit Requirements of this part when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ? 200.501 Audit requirements. (g) Consider whether the results of the subrecipient?s audits, on-site reviews, or other monitoring indicate conditions that necessitate adjustments to the pass-through entity?s own records. (h) Consider taking enforcement action against noncompliant subrecipients as described in ? 200.338 Remedies for noncompliance of this part and in program regulations.Condition: The Department did not clearly communicate all of the required information to subrecipients.Questioned Costs: NoneContext: For three of the six subrecipients tested, the subrecipient agreement did not include all of the required information.Cause: The Department does not have the necessary policies and procedures in place regarding subrecipient agreements to facilitate compliance with federal requirements.Effect: The Department is not in compliance with the Federal subrecipient monitoring requirements.Recommendation: We recommend that the Department implement policies and procedures to facilitate compliance with federal subrecipient monitoring requirements.Prior Year Single Audit Finding Number: Not applicableViews of Responsible Offices and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 166.

Corrective Action Plan

U.S. Department of Health and Human ServicesSouth Carolina Department of Health and Environmental Control respectfully submits the following corrective action plan for the year ended 6/30/19.The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule.FINDINGS-FEDERAL AWARD PROGRAM AUDIT2019-022 HIV Care Formula Grants {Ryan White HIV/AIDS Program Part B) CFDA No.: 93 .917Recommendation: We recommend that the Department implement policies and procedures to facilitate compliance with federal subrecipient monitoring requirements.Explanation of disagreement with audit finding: There is no disagreement with audit findings.Action taken in response to finding: The Department is identifying all active subrecipient agreements still using outdated templates and issuing amendments to notify the subrecipients of both the FAIN and Duns#.Name(s) of the contact person(s) responsible for corrective action: Larry MaddoxPlanned completion date for corrective action plan: The Department has already updated the subrecipient award template to include all information required by 2.CFR.200, which is used for all new awards. We are currently working towards issuing amendments to provide the information missing from the old templates.If the U.S. Department of Health and Human Services has questions regarding this plan, please call Kim Paradeses at 803-898-3390.

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2019-023
Subrecipient Monitoring
SIGNIFICANT DEFICIENCYREPEAT OF 2018-038OTHER MATTERS

The Consortium does not have adequate policies and procedures in place regarding subrecipient monitoring to facilitate compliance with federal requirements.Questioned Costs: UnknownContext: For two of the six subrecipients selected for testing, monitoring procedures were not completed to satisfy the federal requirements.Cause: The Consortium has implemented policies and procedures for subrecipient monitoring, however, it was noted that these policies and procedures do not address all federal requirements.Effect: The Consortium is not in compliance with the Federal subrecipient monitoring requirements.Recommendation: We recommend that the Consortium continue to evaluate their current subrecipient monitoring policies and procedures and make revisions to ensure compliance with federal requirements.Prior Year Single Audit Report Finding Number: 2018-038Views of Responsible Offices and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 167.

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Subrecipient MonitoringFederal Agency: VariousFederal Program Title: Research and Development ClusterCFDA No.: VariousFederal Grant ID Number: VariousPass-Through Entity: VariousAward Period: VariousType of Finding: Significant deficiency in internal control over compliance, other mattersCriteria: Per 2 CFR ? 200.331 all pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes all of the required information at the time of the subaward (b) Evaluate each subrecipient?s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraph (e) of this section, (c) Consider imposing specific subaward conditions upon a subrecipient if appropriate as described in ? 200.207 Specific conditions. (d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. (f) Verify that every subrecipient is audited as required by Subpart F? Audit Requirements of this part when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ? 200.501 Audit requirements. (g) Consider whether the results of the subrecipient?s audits, on-site reviews, or other monitoring indicate conditions that necessitate adjustments to the pass-through entity?s own records. (h) Consider taking enforcement action againstnoncompliant subrecipients as described in ? 200.338 Remedies for noncompliance of this part and in program regulations.Condition: The Consortium does not have adequate policies and procedures in place regarding subrecipient monitoring to facilitate compliance with federal requirements.Questioned Costs: UnknownContext: For two of the six subrecipients selected for testing, monitoring procedures were not completed to satisfy the federal requirements.Cause: The Consortium has implemented policies and procedures for subrecipient monitoring, however, it was noted that these policies and procedures do not address all federal requirements.Effect: The Consortium is not in compliance with the Federal subrecipient monitoring requirements.Recommendation: We recommend that the Consortium continue to evaluate their current subrecipient monitoring policies and procedures and make revisions to ensure compliance with federal requirements.Prior Year Single Audit Report Finding Number: 2018-038Views of Responsible Offices and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 167.

Corrective Action Plan

U.S. Department of Commerce1401 Constitution Avenue NWWashington, D.C. 20230South Carolina Sea Grant Consortium respectfully submits the following corrective action plan for the year ended June 30, 2019.Audit period: July 1, 2018 through June 30, 2019The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule.FINDINGS?FEDERAL AWARD PROGRAM AUDITU.S. Department of Commerce2019-023 Research and Development ClusterRecommendation: We recommend that the Consortium continue to evaluate their current subrecipient monitoring policies and procedures and make revisions to ensure compliance with federal requirements.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding: Per this finding, the Consortium will continue to evaluate and amend its current subrecipient monitoring policies and procedures first implemented in July 2017 and revised in February 2018 and June 2019. Since the inception of the current corrective action plan, the Consortium has implemented new requirements for all subrecipients in regards to reimbursement requests and financial reporting as well as establish risk assessment and external audit processes for select entities that received subaward funds during the previous fiscal year. These actions have yielded very positive results and significant progress has been made since the original single audit finding in fiscal year 2015-16.Per discussions with audit staff from January 2020, the Consortium has already revised our internal agreement package (as of February 2020) to include federally mandated information required from all subreceipient awardees. In addition, Consortium Administration will expandupon its current risk aversion processes and procedures to include all subreceipients receiving funds from the previous fiscal year (previously only Consortium member institutions were included in agency assessments).Name(s) of the contact person(s) responsible for corrective action: Ryan C. Bradley, Assistant Director for AdministrationPlanned completion date for corrective action plan: Implemented July 1, 2017 // Amended February 1, 2020If the Department of Commerce has questions regarding this plan, please contact Ryan Bradley at ryan.bradley@scseagrant.org (843) 953-2078.

Prior Finding References

2018-038

About Subrecipient Monitoring →
2019-024
Matching, Level of Effort, Earmarking
SIGNIFICANT DEFICIENCYOTHER MATTERS

The Department's federal fiscal year 2018 MOE certification was not calculated correctly prior to submission to the federal oversight agency.Questioned Costs: NoneContext: For the period under audit the MOE was not calculated correctly.Cause: Internal controls failed to detect the calculation error prior to the certification submission.Effect: The Department submitted an inaccurate calculation of maintenance of effort on their certification.Recommendation: We recommend that the Department strengthen internal controls to ensure maintenance of effort certifications are calculated correctly prior to submission.Prior Year Single Audit Report Finding Number: Not applicableViews of Responsible Offices and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 169.

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Matching, Level of Effort, Earmarking - Maintenance of EffortFederal Agency: Department of Health and Human ServicesFederal Program Title: Aging ClusterCFDA No.: 93.044, 93.045, 93.053Federal Grant ID Number: VariousPass-Through Entity: Not applicableAward Period: VariousType of Finding: Significant deficiency in internal control over compliance, other mattersCriteria: Per 45 CFR ? 1321.49 - State agency maintenance of effort. In order to avoid a penalty, each fiscal year the State agency, to meet the required non-federal share applicable to its allotments under this part, shall spend under the State plan for bothservices and administration at least the average amount of State funds it spent under the plan for the three previous fiscal years. If the State agency spends less than this amount, the Commissioner reduces the State's allotments for supportive and nutrition services under this part by a percentage equal to the percentage by which the State reduced its expenditures.Condition: The Department's federal fiscal year 2018 MOE certification was not calculated correctly prior to submission to the federal oversight agency.Questioned Costs: NoneContext: For the period under audit the MOE was not calculated correctly.Cause: Internal controls failed to detect the calculation error prior to the certification submission.Effect: The Department submitted an inaccurate calculation of maintenance of effort on their certification.Recommendation: We recommend that the Department strengthen internal controls to ensure maintenance of effort certifications are calculated correctly prior to submission.Prior Year Single Audit Report Finding Number: Not applicableViews of Responsible Offices and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 169.

Corrective Action Plan

U.S. Department of Health and Human ServicesSouth Carolina Department on Aging respectfully submits the following corrective action plan for the year ended 6/30/19.The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule.FINDINGS?FEDERAL AWARD PROGRAMS AUDITU.S Department of Health and Human Services2019-024 Title III part B, Title III part C, Nutrition Services Incentive Program? CFDA No. 93.044, 93.045, 93.053Recommendation: We recommend that the Department strengthen internal controls to ensure maintenance of effort certifications are calculated correctly prior to submission.Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding:Additional training is being obtained from ACL, the federal funding source, on reportingrequirements and calculations. The agency has recalculated, reviewed and filed the corrected FY 2018 Certification for the Maintenance of Effort report.Name(s) of the contact person(s) responsible for corrective action: Lisa Crosby, Rhonda WalkerPlanned completion date for corrective action plan: June 30, 2020If the U.S. Department of Health and Human Services has questions regarding this plan, please call Connie Munn at (803) 734-9910.

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2019-025
Subrecipient Monitoring
MATERIAL WEAKNESSMODIFIED OPINION

The Department does not have the necessary policies and procedures in place regarding subrecipient monitoring to facilitate compliance with federal requirements.Questioned Costs: UnknownContext: For five of five subrecipients selected for testing, monitoring procedures were not completed to satisfy the federal requirements.Cause: The Department has implemented policies and procedures for subrecipient monitoring, however, it was noted that these policies and procedures do not address all federal requirements.Effect: The Department is not in compliance with the Federal subrecipient monitoring requirements.Recommendation: We recommend that the Department implement policies and procedures to facilitate compliance with federal subrecipient monitoring requirements.Prior Year Single Audit Report Finding Number: Not applicableViews of Responsible Offices and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 170.

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Subrecipient MonitoringFederal Agency: Department of Health and Human ServicesFederal Program Title: Aging ClusterCFDA No.: 93.044, 93.045, 93.053Federal Grant ID Number: VariousPass-Through Entity: Not applicableAward Period: VariousType of Finding: Material weakness in internal control over compliance, material noncomplianceCriteria: Per 45 CFR ?75.352(a) All pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes all of the information required by 45 CFR 75.352 (a)(1)(i-xiii) at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward. (b) Evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section. (c) Consider imposing specific subaward conditions upon a sub-\recipient if appropriate as described in ? 75.207 (d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. (e) Depending upon the pass-through entity's assessment of risk posed by the subrecipient (as described in paragraph (b) of this section), the following monitoring tools may be useful for the pass-through entity to ensure proper accountability and compliance with program requirements and achievement of performance goals. (f) Verify that every subrecipient is audited as required by subpart F of this part when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ? 75.501. (g) Consider whether the results of the subrecipient's audits, on-site reviews, or other monitoring indicate conditions that necessitate adjustments to the pass-through entity's own records. (h) Consider taking enforcement action against noncompliant subrecipients as described in ? 75.371 and in program regulations.Condition: The Department does not have the necessary policies and procedures in place regarding subrecipient monitoring to facilitate compliance with federal requirements.Questioned Costs: UnknownContext: For five of five subrecipients selected for testing, monitoring procedures were not completed to satisfy the federal requirements.Cause: The Department has implemented policies and procedures for subrecipient monitoring, however, it was noted that these policies and procedures do not address all federal requirements.Effect: The Department is not in compliance with the Federal subrecipient monitoring requirements.Recommendation: We recommend that the Department implement policies and procedures to facilitate compliance with federal subrecipient monitoring requirements.Prior Year Single Audit Report Finding Number: Not applicableViews of Responsible Offices and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 170.

Corrective Action Plan

U.S. Department of Health and Human ServicesSouth Carolina Department on Aging respectfully submits the following corrective action plan for the year ended 6/30/19.The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule.FINDINGS?FEDERAL AWARD PROGRAMS AUDITU.S Department of Health and Human Services2019-025 Title III part B, Title III part C, Nutrition Services Incentive Program? CFDA No. 93.044, 93.045, 93.053Recommendation: We recommend that the Department implement policies and procedures to facilitate compliance with federal subrecipient monitoring requirements.Explanation of disagreement with audit finding: There is no disagreement with audit findings.Action taken in response to finding: SCDOA implemented agency wide fiscal and programmatic monitoring during FY 2019 that was not completed by year end. The agency will be in compliance when fully implemented. In addition, SCDOA will hire an additional staff member in the finance department who whose primary job will be to monitor subrecipients of the grants.Name(s) of the contact person(s) responsible for corrective action: Rhonda Walker Planned completion date for corrective action plan: June 30, 2020If the U.S. Department of Health and Human Services has questions regarding this plan, please call Connie Munn at (803) 734-9910.

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2019-026
Activities Allowed or Unallowed / Cost Allowability
MATERIAL WEAKNESSMODIFIED OPINION

Evidence of the Personnel/Budget Action Request in effect as of the time wages were earned were not maintained or were inconsistent with the amounts charged to the award.Questioned Costs: UnknownContext: For nine of sixty payroll transactions tested, adequate documentation was not received to support the controls in place over allowable costs and cost principles in accordance with federal regulations.Cause: The Department does not have policies and procedures in place to ensure payroll is charged in accordance with federal requirements.Effect: The Department is not in compliance with applicable allowable activities/costs requirements.Recommendation: We recommend that the Department strengthen their internal controls over payroll to ensure compliance with federal requirementsPrior Year Single Audit Report Finding Number: Not applicableViews of Responsible Offices and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 170.

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Activities Allowed or Unallowed and Allowable Costs/ Cost PrinciplesFederal Agency: Department of Health and Human ServicesFederal Program Title: Aging ClusterCFDA No.: 93.044, 93.045, 93.053Federal Grant ID Number: VariousPass-Through Entity: Not applicableAward Period: VariousType of Finding: Material weakness in internal control over compliance, material noncomplianceCriteria: Per 45 ? 75.430 (a) General. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities; (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, when applicable.Condition: Evidence of the Personnel/Budget Action Request in effect as of the time wages were earned were not maintained or were inconsistent with the amounts charged to the award.Questioned Costs: UnknownContext: For nine of sixty payroll transactions tested, adequate documentation was not received to support the controls in place over allowable costs and cost principles in accordance with federal regulations.Cause: The Department does not have policies and procedures in place to ensure payroll is charged in accordance with federal requirements.Effect: The Department is not in compliance with applicable allowable activities/costs requirements.Recommendation: We recommend that the Department strengthen their internal controls over payroll to ensure compliance with federal requirementsPrior Year Single Audit Report Finding Number: Not applicableViews of Responsible Offices and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 170.

Corrective Action Plan

U.S. Department of Health and Human ServicesSouth Carolina Department on Aging respectfully submits the following corrective action plan for the year ended 6/30/19.The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule.FINDINGS?FEDERAL AWARD PROGRAMS AUDITU.S Department of Health and Human Services2019-026 Title III part B, Title III part C, Nutrition Services Incentive Program? CFDA No. 93.044, 93.045, 93.053Recommendation: We recommend that the Department strengthen their internal controls over payroll to ensure compliance with federal requirementsExplanation of disagreement with audit finding: There is no disagreement with audit findings.Action taken in response to finding: This issue had been previously identified after FY 2019 year end and policies were revised. The agency is reconciling payroll information on a more frequent basis and continues to train staff to ensure that the procedures are followed.Name(s) of the contact person(s) responsible for corrective action: Rhonda Walker Planned completion date for corrective action plan: March 30, 2020If the U.S. Department of Health and Human Services has questions regarding this plan, please call Connie Munn at (803) 734-9910.

About Activities Allowed or Unallowed, Allowable Costs / Cost Principles →
2019-027
Matching, Level of Effort, Earmarking
SIGNIFICANT DEFICIENCYOTHER MATTERS

The Department did not adequately track administrative costs charged to the grant.Questioned Costs: UnknownContext: The grant that closed during the audit period was tested for the earmarking requirement. The amount charged to the grant for State Plan administration exceeded the earmarking requirement.Cause: The Department does not have policies and procedures in place to ensure that the earmarking requirements are met.Effect: The Department is not in compliance with the federal earmarking requirements.Recommendation: We recommend that the Department implement internal controls for tracking administrative costs charged to the grant to ensure that the federal requirements are being met.Prior Year Single Audit Report Finding Number: Not applicableViews of Responsible Offices and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 171.

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Matching, Level of Effort, EarmarkingFederal Agency: Department of Health and Human ServicesFederal Program Title: Aging ClusterCFDA No.: 93.044, 93.045, 93.053Federal Grant ID Number: VariousPass-Through Entity: Not applicableAward Period: VariousType of Finding: Significant deficiency in internal control over compliance, other mattersCriteria: Overall expenditures for administration are limited to the greater of five percent (or $300,000 or $500,000 depending on the aggregate amount appropriated or a lesser amount for the U.S. Territories) of the overall allotment to a State under Title III unless a waiver is granted by the Assistant Secretary for Aging (42 USC 3028 (b)(1), (2), and (3)).Condition: The Department did not adequately track administrative costs charged to the grant.Questioned Costs: UnknownContext: The grant that closed during the audit period was tested for the earmarking requirement. The amount charged to the grant for State Plan administration exceeded the earmarking requirement.Cause: The Department does not have policies and procedures in place to ensure that the earmarking requirements are met.Effect: The Department is not in compliance with the federal earmarking requirements.Recommendation: We recommend that the Department implement internal controls for tracking administrative costs charged to the grant to ensure that the federal requirements are being met.Prior Year Single Audit Report Finding Number: Not applicableViews of Responsible Offices and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 171.

Corrective Action Plan

U.S. Department of Health and Human ServicesSouth Carolina Department on Aging respectfully submits the following corrective action plan for the year ended 6/30/19.The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule.FINDINGS?FEDERAL AWARD PROGRAMS AUDIT2019-027 Title III part B, Title III part C, Nutrition Services Incentive Program? CFDA No. 93.044, 93.045, 93.053Recommendation: We recommend that the Department implement internal controls for tracking administrative costs charged to the grant to ensure that the federal requirements are being met.Explanation of disagreement with audit finding: There is no disagreement with audit findings.Action taken in response to finding: Additional review measures are now in place to prevent excess budget from being loaded into the state accounting system and having Earmarked funds overspent. In addition, quarterly reviews of all grants are being performed to ensure all grants are within budget for each identified area.Name(s) of the contact person(s) responsible for corrective action: Rhonda Walker Planned completion date for corrective action plan: February 28, 2020.If the U.S. Department of Health and Human Services has questions regarding this plan, please call Connie Munn at (803) 734-9910.

About Matching, Level of Effort, Earmarking →
2019-028
Reporting
SIGNIFICANT DEFICIENCYREPEAT OF 2018-046OTHER MATTERS

Key data elements reported on the Commission's RSA-911 performance reports did not agree with underlying case service documentation.Questioned Costs: NoneContext: For one of two RSA-911 performance reports tested, key data reported was contradictory to the supporting documentation.Cause: This finding was noted in the prior year and the Commission developed a corrective action plan. However, due to the timing of the implementation of the plan during part of the year the Commission did not have sufficient internal controls and policies/procedures in place to ensure that all key data reported was in agreement with the underlying documentation.Effect: The Commission may report incorrect information to the Rehabilitation Services Administration.Recommendation: We recommend that the Commission continue to fully implement their corrective action plan prepared in response to the prior year Single Audit finding.Prior Year Single Audit Finding Number: 2018-046Views of Responsible Offices and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 172.

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ReportingFederal Agency: Department of EducationFederal Program Title: Rehabilitation Services-Vocational Rehabilitation Grants to StatesCFDA No.: 84.126Federal Grant ID Number: H126A170061; H126A180061; H126A190061Pass-Through Entity: Not applicableAward Period: October 1, 2016 through September 30, 2020Type of Finding: Significant Deficiency in internal control over compliance, other mattersCriteria: The requirements in 34 CFR ?361.47 and 34 CFR ?361.56, taken together, require State Vocational Rehabilitation agencies to maintain verifying documentation in an individual?s case file, particularly regarding eligibility determinations, development of the individualized plan for employment, services provided, and case closure. Much of this information are key data elements required to be reported on the Case Service Report (RSA-911) to the Rehabilitation Services Administration (RSA).Condition: Key data elements reported on the Commission's RSA-911 performance reports did not agree with underlying case service documentation.Questioned Costs: NoneContext: For one of two RSA-911 performance reports tested, key data reported was contradictory to the supporting documentation.Cause: This finding was noted in the prior year and the Commission developed a corrective action plan. However, due to the timing of the implementation of the plan during part of the year the Commission did not have sufficient internal controls and policies/procedures in place to ensure that all key data reported was in agreement with the underlying documentation.Effect: The Commission may report incorrect information to the Rehabilitation Services Administration.Recommendation: We recommend that the Commission continue to fully implement their corrective action plan prepared in response to the prior year Single Audit finding.Prior Year Single Audit Finding Number: 2018-046Views of Responsible Offices and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 172.

Corrective Action Plan

U.S. Department of EducationSouth Carolina Commission for the Blind respectfully submits the following corrective action plan for the year ended 6/30/19.The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule.FINDINGS?FEDERAL AWARD PROGRAM AUDITSouth Carolina Commission for the Blind (L24)2019-028. Rehabilitation Services-Vocational Rehabilitation Grants to States ? CFDA No. 84.126Recommendation: We recommend that the Commission continue to fully implement their corrective action plan prepared in response to the prior year Single Audit finding.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding: Statewide caseload reviews will continue to be conducted on a quarterly basis in order to validate data accuracy in reporting prior to the submission of the RSA-911 Case Service Reports.Name(s) of the contact person(s) responsible for corrective action: Shana RobinsonPlanned completion date for corrective action plan: CompletedIf the U.S. Department of Education has questions regarding this plan, please call Matthew Daugherty at 803-898-8835.

Prior Finding References

2018-046

About Reporting →
2019-029
Reporting
SIGNIFICANT DEFICIENCYOTHER MATTERS

Data submitted in the RSA-2 Annual Vocational Rehabilitation Program/Cost Report and SF-425 Federal were not submitted in a timely manner.Questioned Costs: NoneContext: For the one RSA-2 financial report and one SF-425 report tested, it was noted the report submissions were made after the federal due date. While testing the reports, non-material variances were noted between the report and supporting documentation.Cause: The Commission did not have sufficient internal controls and policies/procedures in place to ensure that reports were filed timely. In addition underlying documentation for the SF-425 report included minor inaccuracies.Effect: The Commission may report incorrect information to the Rehabilitation Services Administration and may not submit reports prior to the prescribed due date.Recommendation: We recommend that the Commission implement policies and procedures necessary to ensure that reports include accurate data and are submitted in a timely manner.Prior Year Single Audit Finding Number: Not applicableViews of Responsible Offices and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 172.

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ReportingFederal Agency: Department of EducationFederal Program Title: Rehabilitation Services-Vocational Rehabilitation Grants to StatesCFDA No.: 84.126Federal Grant ID Number: H126A170061; H126A180061; H126A190061Pass-Through Entity: Not applicableAward Period: October 1, 2016 through September 30, 2020Type of Finding: Significant Deficiency in internal control over compliance, other mattersCriteria: Per 34 CFR ?361.40 (a) Reports. (1) The vocational rehabilitation services portion of the Unified or Combined State Plan must assure that the designated State agency will submit reports, including reports required under sections 13, 14, and 101(a)(10) of the Act - (i) In the form and level of detail and at the time required by the Secretary regarding applicants for and eligible individuals receiving services, including students receiving pre-employment transition services in accordance with ? 361.48(a); and (ii) In a manner that provides a complete count (other than the information obtained through sampling consistent with section 101(a)(10)(E) of the Act) of the applicants and eligible individuals to - (A) Permit the greatest possible cross-classification of data; and (B) Protect the confidentiality of the identity of each individual. (2) The designated State agency must comply with any requirements necessary to ensure the accuracy and verification of those reports.Condition: Data submitted in the RSA-2 Annual Vocational Rehabilitation Program/Cost Report and SF-425 Federal were not submitted in a timely manner.Questioned Costs: NoneContext: For the one RSA-2 financial report and one SF-425 report tested, it was noted the report submissions were made after the federal due date. While testing the reports, non-material variances were noted between the report and supporting documentation.Cause: The Commission did not have sufficient internal controls and policies/procedures in place to ensure that reports were filed timely. In addition underlying documentation for the SF-425 report included minor inaccuracies.Effect: The Commission may report incorrect information to the Rehabilitation Services Administration and may not submit reports prior to the prescribed due date.Recommendation: We recommend that the Commission implement policies and procedures necessary to ensure that reports include accurate data and are submitted in a timely manner.Prior Year Single Audit Finding Number: Not applicableViews of Responsible Offices and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 172.

Corrective Action Plan

U.S. Department of EducationSouth Carolina Commission for the Blind respectfully submits the following corrective action plan for the year ended 6/30/19.The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule.FINDINGS?FEDERAL AWARD PROGRAM AUDITSouth Carolina Commission for the Blind (L24)2019-029 Rehabilitation Services - Vocational Rehabilitation Grants to States CFDA No.: 84.126Recommendation: We recommend that the Commission implement policies and procedures necessary to ensure that reports include accurate data and are submitted in a timely manner.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding: Key positions will continue to be filled and backup staff assigned, which will allow for the development and implementation of the policies and procedures necessary to ensure the accurate and timely completion and submission of the RSA-2 Annual Vocational Rehabilitation Program/Cost Report.Name(s) of the contact person(s) responsible for corrective action: Shana Robinson and Matt DaughertyPlanned completion date for corrective action plan: July 1, 2020If the U.S. Department of Education has questions regarding this plan, please call Matthew Daugherty at 803-898-8835.

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2019-030
Cash Management
SIGNIFICANT DEFICIENCYOTHER MATTERS

The Commission did not consider the effect of program expenditures that were refunded, resulting in reimbursements exceeding actual expenditures during the respective drawdown period. Per discussion with the Commission refunds are subtracted from the final reimbursement request for the respective grant period.Questioned Costs: UnknownContext: For the three drawdowns made in fiscal year 2019, it was noted that refunded expenditures were not netted against program expenditures to determine the proper reimbursement amount was requested.Cause: As refunds of program expenditures occur the Commission?s procedure is to record these refunds in a revenue account as opposed to an offset to expenditures. For reimbursement requests the Commission?s procedures only consider refunded program expenditures when calculating the final drawdown for the respective grant.Effect: The Commission may drawdown funds in excess of eligible reimbursable expenditures.Recommendation: We recommend that the Commission implement policies and procedures to ensure that refunded expenditure credits are netted against program expenditures prior to drawing down funds. Additionally, it is recommended that the Commission implement policies and procedures to ensure reimbursement requests are submitted timely.Prior Year Single Audit Finding Number: Not applicableViews of Responsible Offices and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 173.

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Cash ManagementFederal Agency: Department of EducationFederal Program Title: Rehabilitation Services-Vocational Rehabilitation Grants to StatesCFDA No.: 84.126Federal Grant ID Number: H126A170061; H126A180061; H126A190061Pass-Through Entity: Not applicableAward Period: October 1, 2016 through September 30, 2020Type of Finding: Significant Deficiency in internal control over compliance, other mattersCriteria: Per 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of monitoring and reporting program performance. The Commission should have internal controls designed to ensure compliance with those provisions.Condition: The Commission did not consider the effect of program expenditures that were refunded, resulting in reimbursements exceeding actual expenditures during the respective drawdown period. Per discussion with the Commission refunds are subtracted from the final reimbursement request for the respective grant period.Questioned Costs: UnknownContext: For the three drawdowns made in fiscal year 2019, it was noted that refunded expenditures were not netted against program expenditures to determine the proper reimbursement amount was requested.Cause: As refunds of program expenditures occur the Commission?s procedure is to record these refunds in a revenue account as opposed to an offset to expenditures. For reimbursement requests the Commission?s procedures only consider refunded program expenditures when calculating the final drawdown for the respective grant.Effect: The Commission may drawdown funds in excess of eligible reimbursable expenditures.Recommendation: We recommend that the Commission implement policies and procedures to ensure that refunded expenditure credits are netted against program expenditures prior to drawing down funds. Additionally, it is recommended that the Commission implement policies and procedures to ensure reimbursement requests are submitted timely.Prior Year Single Audit Finding Number: Not applicableViews of Responsible Offices and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 173.

Corrective Action Plan

U.S. Department of EducationSouth Carolina Commission for the Blind respectfully submits the following corrective action plan for the year ended 6/30/19.The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule.FINDINGS?FEDERAL AWARD PROGRAM AUDIT2019-030 Rehabilitation Services - Vocational Rehabilitation Grants to States CFDA No.: 84.126Recommendation: We recommend that the Commission implement policies and procedures to ensure that refunded expenditure credits are netted against program expenditures prior to drawing down funds.Additionally, it is recommended that the Commission implement policies and procedures to ensure reimbursement requests are submitted timely.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding: Key positions will continue to be filled and backup staff assigned, which will allow for the development and implementation of the policies and procedures necessary to ensure that refunded expenditure credits are netted against program expenditures prior to drawing down funds, and that reimbursement requests are submitted in a timely fashion.Name(s) of the contact person(s) responsible for corrective action: Matthew DaughertyPlanned completion date for corrective action plan: July 1, 2020If the U.S. Department of Education has questions regarding this plan, please call Matthew Daugherty at 803-898-8835.

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2019-031
Reporting
SIGNIFICANT DEFICIENCY

The Commission submitted a Schedule of Expenditures of Federal Awards (SEFA) that contained incorrect information for certain awards.Questioned Costs: NoneContext: For five of the thirty-eight federal awards reported on the Commission?s SEFA there was incorrect information submitted.Cause: The Commission's internal controls failed to identify errors on the SEFA that was submitted.Effect: The commission may report incorrect information on the SEFA.Recommendation: We recommend that the Commission strengthen internal controls regarding the preparation and review of their SEFA to ensure such errors are identified and corrected prior to submission.Prior Year Single Audit Finding Number: Not applicableViews of Responsible Offices and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 174.

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ReportingFederal Agency: Department of EducationFederal Program Title: Rehabilitation Services-Vocational Rehabilitation Grants to StatesCFDA No.: 84.126Federal Grant ID Number: H126A170061; H126A180061; H126A190061Pass-Through Entity: Not applicableAward Period: October 1, 2016 through September 30, 2020Type of Finding: Significant Deficiency in internal control over complianceCriteria: 2 CFR ? 200.303 Internal controls, 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 and the ``Internal Control Integrated Framework??, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).Condition: The Commission submitted a Schedule of Expenditures of Federal Awards (SEFA) that contained incorrect information for certain awards.Questioned Costs: NoneContext: For five of the thirty-eight federal awards reported on the Commission?s SEFA there was incorrect information submitted.Cause: The Commission's internal controls failed to identify errors on the SEFA that was submitted.Effect: The commission may report incorrect information on the SEFA.Recommendation: We recommend that the Commission strengthen internal controls regarding the preparation and review of their SEFA to ensure such errors are identified and corrected prior to submission.Prior Year Single Audit Finding Number: Not applicableViews of Responsible Offices and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 174.

Corrective Action Plan

U.S. Department of EducationSouth Carolina Commission for the Blind respectfully submits the following corrective action plan for the year ended 6/30/19.The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule.FINDINGS?FEDERAL AWARD PROGRAM AUDIT2019-031 Rehabilitation Services - Vocational Rehabilitation Grants to States CFDA No.: 84.126Recommendation: We recommend that the Commission strengthen internal controls regarding the preparation and review of their SEFA to ensure such errors are identified and corrected prior to submission.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding: Key positions will continue to be filled and backup staff assigned, which will allow for the development and implementation of the policies and procedures necessary to ensure the identification and correction of errors prior to the submission of the SEFA.Name(s) of the contact person(s) responsible for corrective action: Matthew DaughertyPlanned completion date for corrective action plan: July 1, 2020If the U.S. Department of Education has questions regarding this plan, please call Matthew Daugherty at 803-898-8835.

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2019-032
Activities Allowed or Unallowed / Cost Allowability
MATERIAL WEAKNESSMODIFIED OPINION

The Commission did not have adequate internal controls and policies/procedures in place to substantiate indirect costs charged to federal awards.Questioned Costs: UnknownContext: For the indirect costs charged to the federal awards, the Commission was not able to substantiate their validity in order to satisfy the testing objectives.Cause: The Commission did not adequately track and is unable to substantiate the calculations for indirect costs charged to federal awards.Effect: The Commission may report inaccurate indirect costs to federal awards.Recommendation: We recommend that the Commission implement internal controls and policies/procedures to substantiate indirect costs charged to federal awards.Prior Year Single Audit Finding Number: Not applicableViews of Responsible Offices and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 174.

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Activities Allowed or Unallowed & Allowable costs/Cost Principles ? Indirect CostsFederal Agency: Department of EducationFederal Program Title: Rehabilitation Services-Vocational Rehabilitation Grants to StatesCFDA No.: 84.126Federal Grant ID Number: H126A170061; H126A180061; H126A190061Pass-Through Entity: Not applicableAward Period: October 1, 2016 through September 30, 2020Type of Finding: Material weakness in internal control over compliance, material noncomplianceCriteria: Per 2 CFR ? 225 Appendix A (F) (1) General. Indirect costs are those: Incurred for a common or joint purpose benefiting more than one cost objective, and not readily assignable to the cost objectives specifically benefitted, without effort disproportionate to the results achieved. The term ``indirect costs,?? as used herein, applies to costs of this type originating in the grantee department, as well as those incurred by other departments in supplying goods, services, and facilities. To facilitate equitable distribution of indirect expenses to the cost objectives served, it may be necessary to establish a number of pools of indirect costs within a governmental unit department or in other agencies providing services to a governmental unit department. Indirect cost pools should be distributed to benefitted cost objectives on bases that will produce an equitable result in consideration of relative benefits derived.Condition: The Commission did not have adequate internal controls and policies/procedures in place to substantiate indirect costs charged to federal awards.Questioned Costs: UnknownContext: For the indirect costs charged to the federal awards, the Commission was not able to substantiate their validity in order to satisfy the testing objectives.Cause: The Commission did not adequately track and is unable to substantiate the calculations for indirect costs charged to federal awards.Effect: The Commission may report inaccurate indirect costs to federal awards.Recommendation: We recommend that the Commission implement internal controls and policies/procedures to substantiate indirect costs charged to federal awards.Prior Year Single Audit Finding Number: Not applicableViews of Responsible Offices and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 174.

Corrective Action Plan

U.S. Department of EducationSouth Carolina Commission for the Blind respectfully submits the following corrective action plan for the year ended 6/30/19.The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule.FINDINGS?FEDERAL AWARD PROGRAM AUDIT2019-032 Rehabilitation Services - Vocational Rehabilitation Grants to States CFDA No.: 84.126Recommendation: We recommend that the Commission implement internal controls and policies/procedures to substantiate indirect costs charged to federal awards.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding: Key positions will continue to be filled and backup staff assigned, which will allow for the development and implementation of the policies and procedures necessary to ensure that indirect costs charged to federal awards can be substantiated.Name(s) of the contact person(s) responsible for corrective action: Matthew DaughertyPlanned completion date for corrective action plan: July 1, 2020If the U.S. Department of Education has questions regarding this plan, please call Matthew Daugherty at 803-898-8835.

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2019-033
Matching, Level of Effort, Earmarking
MATERIAL WEAKNESSMODIFIED OPINION

The Commission did not comply with the level of effort requirements for maintenance of effort.Questioned Costs: UnknownContext: The Commission did not comply with federally required level of effort ? maintenance of effort.Cause: The Commission did not have sufficient internal controls and policies/procedures in place to ensure that level of effort requirements for maintenance of effort were being monitored and met.Effect: The Commission may not comply with federally required level of effort requirements for maintenance of effort.Recommendation: We recommend that the Commission implement internal controls and policies/procedures to ensure federal level of effort requirements for maintenance of effort are being monitored and met.Prior Year Single Audit Finding Number: Not applicableViews of Responsible Offices and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 175.

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Matching, Level of Effort, Earmarking ? Maintenance of EffortFederal Agency: Department of EducationFederal Program Title: Rehabilitation Services-Vocational Rehabilitation Grants to StatesCFDA No.: 84.126Federal Grant ID Number: H126A170061; H126A180061; H126A190061Pass-Through Entity: Not applicableAward Period: October 1, 2016 through September 30, 2020Type of Finding: Material Weakness in internal control over compliance, material noncomplianceCriteria: Per (29 USC 731(a)(2)(B)) the amount otherwise payable to a State for a fiscal year under this section shall be reduced by the amount by which expenditures from non-Federal sources under the State plan under this subchapter for any previous fiscal year are less than the total of such expenditures for the second fiscal year preceding that previous fiscal year.Condition: The Commission did not comply with the level of effort requirements for maintenance of effort.Questioned Costs: UnknownContext: The Commission did not comply with federally required level of effort ? maintenance of effort.Cause: The Commission did not have sufficient internal controls and policies/procedures in place to ensure that level of effort requirements for maintenance of effort were being monitored and met.Effect: The Commission may not comply with federally required level of effort requirements for maintenance of effort.Recommendation: We recommend that the Commission implement internal controls and policies/procedures to ensure federal level of effort requirements for maintenance of effort are being monitored and met.Prior Year Single Audit Finding Number: Not applicableViews of Responsible Offices and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 175.

Corrective Action Plan

U.S. Department of EducationSouth Carolina Commission for the Blind respectfully submits the following corrective action plan for the year ended 6/30/19.The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule.FINDINGS?FEDERAL AWARD PROGRAM AUDIT2019-033 Rehabilitation Services - Vocational Rehabilitation Grants to States CFDA No.: 84.126Recommendation: We recommend that the Commission implement internal controls and policies/procedures to ensure federal level of effort requirements for maintenance of effort are being monitored and met.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding: Key positions will continue to be filled and backup staff assigned, which will allow for the development and implementation of the policies and procedures necessary to ensure federal level of effort requirements for maintenance of effort are being monitored and met.Name(s) of the contact person(s) responsible for corrective action: Matthew DaughertyPlanned completion date for corrective action plan: July 1, 2020If the U.S. Department of Education has questions regarding this plan, please call Matthew Daugherty at 803-898-8835.

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FY 2019-06-30

$8,418,459,854 federal awards expended

FAC accepted this audit on March 15, 2020 — management decision was due September 15, 2020.

2019-002
Subrecipient Monitoring
SIGNIFICANT DEFICIENCYREPEAT OF 2018-040OTHER MATTERS

Documentation was not adequate to demonstrate that the pass-through entity verified each applicable subrecipient was audited as required.Questioned Costs: NoneContext: This is a repeat finding from the FY18 Single Audit. For all five subrecipients randomly selected for testing, a Single Audit was completed but documentation did not support that the Single Audit had been timely reviewed by program personnel.Cause: Office documentation requirements lack adequate evidence that Single Audits of all subrecipients were verified and reviewed as required.Effect: The Office may not identify and properly follow up on noncompliance of subrecipients.Recommendation: We recommend that Office policies and procedures ensure that subrecipient monitoring is performed in accordance with federal regulations and clearly supports the collection and review of all required Single Audit reports of its subrecipients.Prior Year Single Audit Finding Number: 2018-040Views of Responsible Offices and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 147.

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Subrecipient MonitoringFederal Agency: Department of Homeland SecurityFederal Program Title: Disaster Grants ? Public Assistance (Presidentially Declared Disasters)CFDA No.: 97.036Federal Grant ID Number: FEMA-4166-DR-SC; FEMA-4241-DR-SC; FEMA-4286-DR-SC; FEMA-4346-DR-SCPass-Through Entity: Not applicableType of Finding: Significant Deficiency in internal control over compliance, other mattersCriteria: 2 CFR 200.331 (d) (1) (2) requires the pass-through entity to review the audit reports required of the subrecipient and follow-up as necessary.Condition: Documentation was not adequate to demonstrate that the pass-through entity verified each applicable subrecipient was audited as required.Questioned Costs: NoneContext: This is a repeat finding from the FY18 Single Audit. For all five subrecipients randomly selected for testing, a Single Audit was completed but documentation did not support that the Single Audit had been timely reviewed by program personnel.Cause: Office documentation requirements lack adequate evidence that Single Audits of all subrecipients were verified and reviewed as required.Effect: The Office may not identify and properly follow up on noncompliance of subrecipients.Recommendation: We recommend that Office policies and procedures ensure that subrecipient monitoring is performed in accordance with federal regulations and clearly supports the collection and review of all required Single Audit reports of its subrecipients.Prior Year Single Audit Finding Number: 2018-040Views of Responsible Offices and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 147.

Corrective Action Plan

U.S. Department of Homeland SecurityState of S.C Adjutant General?s Office respectfully submits the following corrective action plan for the year ended 6/30/19.The findings form the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule.FINDINGS-FEDERAL AWARD PROGRAM AUDITU.S. Department of Homeland Security2019-002 Disaster Grants ? Public Assistance (Presidentially Declared Disasters)-97.036Recommendation: We recommend that Office policies and procedures ensure that subrecipient monitoring is performed in accordance with federal regulations and clearly supports the collection and review of all required Single Audit reports of its subrecipients.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding:? Purchased and implemented risk assessment and monitoring module for South Carolina Recovery Grants (SCRG) grants management platform (www.screcoverygrants.org). Integrated criteria from SCEMD policy into SCRG module.? Loaded subrecipient single audits and single-audit-not-required forms in SCRG.? Developed and implemented risk assessment and monitoring procedure and criteria.? Developed staff assignments for audit collection, review, and monitoring activities and regular reporting in SCRG module.? Sent correspondence to subrecipients for which audits not received and provide additional staff outreach to follow up on audit requirements.? Developed correspondence template for use if payment is to be withheld because of lack of audit compliance.? Continued to provide information and reminders about 2 CFR 200 single audit requirements and quarterly progress reports with applicants/subrecipients via multiple means including applicants? briefings, presentations, and specialist contacts.? Continued to include requirements for single audits and quarterly progress reports in funding agreements.Name(s) of the contact person(s) responsible for corrective action: Emily Bentley, Chief of Recovery and Mitigation and Cynthia Smith, Chief of Finance and Administration.Planned completion date for corrective action plan: Most corrections, including repository and tracking of single audits, complete as of January 2020; risk assessment rating of subrecipients based on audit compliance and other criteria to be complete in SCRG by March 31, 2020.If the Department of Homeland Security has questions regarding this plan, please call Steven Batson at 803-201-3440.

Prior Finding References

2018-040

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2019-002
Reporting
MATERIAL WEAKNESSREPEAT OF 2018-006

The Agency did not submit certain quarterly and annual reports to the United States Department of Labor ("National Office") by the required due dates. Accordingly, the Agency did not comply with the Reporting compliance requirements related to the Unemployment Insurance and the Employment Services Cluster programs. Cause: Internal Controls are not in place to ensure that all required reports are being submitted in accordance with the United States Department of Labor's timelines. Effect: As a result, the Agency becomes more susceptible to having its level of federal award funding reduced by the United States Department of Labor when it violates its Reporting compliance requirements applicable to the Unemployment Insurance and the Employment Services programs. Context: We inspected a sample of quarterly reports and annual reports and noted the following number of exceptions: Unemployment Insurance -One(1) ETA 191 quarterly report; Employment Services Cluster - 3 ETA-9130 quarterly reports. Recommendation: We recommend that management carefully review the terms and conditions included in the supporting grant agreements and the Reporting requirements included in the OMB Compliance Supplement applicable to the Unemployment Insurance and Employment Services Cluster programs.

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Item 2019-002: Reporting(Material Weakness over Reporting and Non-Material Noncompliance) Condition: The Agency did not submit certain quarterly and annual reports to the United States Department of Labor ("National Office") by the required due dates. Accordingly, the Agency did not comply with the Reporting compliance requirements related to the Unemployment Insurance and the Employment Services Cluster programs. Cause: Internal Controls are not in place to ensure that all required reports are being submitted in accordance with the United States Department of Labor's timelines. Effect: As a result, the Agency becomes more susceptible to having its level of federal award funding reduced by the United States Department of Labor when it violates its Reporting compliance requirements applicable to the Unemployment Insurance and the Employment Services programs. Context: We inspected a sample of quarterly reports and annual reports and noted the following number of exceptions: Unemployment Insurance -One(1) ETA 191 quarterly report; Employment Services Cluster - 3 ETA-9130 quarterly reports. Recommendation: We recommend that management carefully review the terms and conditions included in the supporting grant agreements and the Reporting requirements included in the OMB Compliance Supplement applicable to the Unemployment Insurance and Employment Services Cluster programs.

Corrective Action Plan

SCDEW implemented a corrective action plan in response to this finding during the year ended June 30, 2020 a brief summary follows: The SCDEW Enterprise and Project Management Office (EPMO) is tasked with monitoring agency wide reporting deadlines. The EPMO developed a master reporting database that includes relevant identifying information including report name, Agency, SCDEW contact, reporting frequency and due dates. Individual reporters at SCDEW submit data to EPMO on the status of the required filings. EPMO routinely reports the status of filings to executive leadership. This finding for the year ended June 30, 2019 reports late filings that occurred before the plan to monitor the status of filings was implemented.

Prior Finding References

2018-006

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2019-003
Cost Allowability
SIGNIFICANT DEFICIENCYREPEAT OF 2018-001OTHER MATTERS

The Department did not remit the federal share of recoveries and collections to the Medicaid program in accordance with Federal regulations and the State Medicaid Manual.Questioned Costs: UnknownContext: We tested sixty receivables to ensure the Department properly credited the Medicaid program for the federal share of identified overpayments. For one receivable tested, the Department used the incorrect Federal medical assistance percentage to calculate the federal share which resulted in an underpayment of $2 to the federal grantor.This is a repeat finding from the FY18 Single Audit. The Department stated on its Summary Schedule of Prior Year Audit Findings that this issue was ?Fully Corrected with Previously Reported Corrective Action Implemented?. Due to this issue repeating for FY19, this issue has not been fully corrected.Cause: Department personnel used the incorrect period of overpayment calculating and remitting the refunds due to human error. Department personnel further stated that quarterly reviews of randomly selected receivables are performed.Effect: The Department?s control procedures did not detect the errors identified in our testing which could lead to further improper remittances.Recommendation: We recommend the Department strengthen its control procedures to ensure the federal share of recoveries and collections are remitted in accordance with applicable federal and state requirements.Prior Year Single Audit Finding Number: 2018-001Views of Responsible Offices and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 149.

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Allowable Costs/Cost Principles - Federal Share of Recoveries / CollectionsFederal Agency: Department of Health and Human ServicesFederal Program Title: Medicaid ClusterCFDA No.: 93.775, 93.777, 93.778Federal Grant ID Number: 05-1905SC5MAPPass-Through Entity: Not applicableAward Period: October 1, 2018 through September 30, 2019Type of Finding: Significant deficiency in internal control over compliance, other mattersCriteria: Per 42 CFR 433.12 (c), the State is required to credit the Medicaid program for ??overpayments made to Medicaid providers?? In addition, Title 45 Section 2500.6 B of the Centers for Medicare & Medicaid Services? (CMS) State Medicaid Manual states to ??determine the date or period of the expenditure for which the refund is made to establish the [Federal Medical Assistance Percentage] at which the original expenditure was matched by the Federal government. Make refunds of the federal share at the FMAP for which you were reimbursed.?Condition: The Department did not remit the federal share of recoveries and collections to the Medicaid program in accordance with Federal regulations and the State Medicaid Manual.Questioned Costs: UnknownContext: We tested sixty receivables to ensure the Department properly credited the Medicaid program for the federal share of identified overpayments. For one receivable tested, the Department used the incorrect Federal medical assistance percentage to calculate the federal share which resulted in an underpayment of $2 to the federal grantor.This is a repeat finding from the FY18 Single Audit. The Department stated on its Summary Schedule of Prior Year Audit Findings that this issue was ?Fully Corrected with Previously Reported Corrective Action Implemented?. Due to this issue repeating for FY19, this issue has not been fully corrected.Cause: Department personnel used the incorrect period of overpayment calculating and remitting the refunds due to human error. Department personnel further stated that quarterly reviews of randomly selected receivables are performed.Effect: The Department?s control procedures did not detect the errors identified in our testing which could lead to further improper remittances.Recommendation: We recommend the Department strengthen its control procedures to ensure the federal share of recoveries and collections are remitted in accordance with applicable federal and state requirements.Prior Year Single Audit Finding Number: 2018-001Views of Responsible Offices and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 149.

Corrective Action Plan

Department of Health & Human ServicesCenters for Medicare & Medicaid Services31 Forsyth Street, SW, Room 4T20Atlanta, Georgia 30303-8909The South Carolina Department of Health and Human Services respectfully submits the following corrective action plan for the year ended 6/30/19.The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule.FINDINGS?FEDERAL AWARD PROGRAM AUDIT2019-003 Medicaid Cluster ? CFDA No. 93.775, 93.777 & 93.778Recommendation: We recommend the Department strengthen its control procedures to ensure the federal share of recoveries and collections are remitted in accordance with applicable federal and state requirements.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding:Currently, accounting operations? Accounts Receivable Manager is reviewing 25% of each month?s receivables. Additionally, the program director is reviewing 10% of each quarter?s receivables. In an effort to continue to eliminate federal share miscalculation, management will begin to review 50% of each month?s receivables in FY2021 and the program director will increase the quarterly review to 20%. Management is currently in communication with South Carolina Enterprise Information System (SCEIS) personnel to create an accounts receivable workflow that will require management to approve all newly established receivables. Furthermore, management will continue researching best practices for minimizing and eliminating manual error and miscalculation within the Accounts Receivable department.Name of the contact person responsible for corrective action: Nika SimmonsPlanned completion date for corrective action plan: OngoingIf the U.S. Department of Health and Human Services has questions regarding this plan, please call Thomas C. Phillip, CFO, at 803-898-1017.

Prior Finding References

2018-001

About Allowable Costs / Cost Principles →
2019-004
Matching, Level of Effort, Earmarking
SIGNIFICANT DEFICIENCYREPEAT OF 2018-003OTHER MATTERS

The Department was not in compliance with the Federal matching requirement for family planning services or family planning related services.Questioned Costs: NoneContext: We tested sixty individual claims to ensure the Department was in compliance with matching requirements. We determined the Department did not use the proper Federal medical assistance percentage for three of the four contraceptive services selected for testing as well as all (two) of the STI diagnosis services selected for testing.Cause: Department personnel stated that errors within the Medicaid Management Information System (MMIS) as well as the utilization of the improper modifier caused contraceptive services and STI diagnosis services to map to the incorrect internal fund code and Federal medical assistance percentage.Effect: The Department?s control procedures did not detect the errors identified in our testing which could lead to further improper payments.Recommendation: We recommend the Department correct the errors in MMIS to ensure compliance with the Federal matching requirement for family planning services and family planning related services.Prior Year Single Audit Finding Number: 2018-003Views of Responsible Offices and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 150.

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Matching, Level of Effort, EarmarkingFederal Agency: Department of Health and Human ServicesFederal Program Title: Medicaid ClusterCFDA No.: 93.775, 93.777, 93.778Federal Grant ID Number: 05-1905SC5MAPPass-Through Entity: Not applicableAward Period: October 1, 2018 through September 30, 2019Type of Finding: Significant deficiency in internal control over compliance, other mattersCriteria: 42 CFR 433.10 (c) (1) states, ?Under Section 1905 (a) (5) of the Act, the Federal share of State expenditures for family planning services is 90 percent.? In addition, the Centers for Medicare & Medicaid Services (CMS) State Medicaid Director Letter 14-003 states in part, ??family planning related services are matched at the states? regular Federal medical assistance percentage.?Condition: The Department was not in compliance with the Federal matching requirement for family planning services or family planning related services.Questioned Costs: NoneContext: We tested sixty individual claims to ensure the Department was in compliance with matching requirements. We determined the Department did not use the proper Federal medical assistance percentage for three of the four contraceptive services selected for testing as well as all (two) of the STI diagnosis services selected for testing.Cause: Department personnel stated that errors within the Medicaid Management Information System (MMIS) as well as the utilization of the improper modifier caused contraceptive services and STI diagnosis services to map to the incorrect internal fund code and Federal medical assistance percentage.Effect: The Department?s control procedures did not detect the errors identified in our testing which could lead to further improper payments.Recommendation: We recommend the Department correct the errors in MMIS to ensure compliance with the Federal matching requirement for family planning services and family planning related services.Prior Year Single Audit Finding Number: 2018-003Views of Responsible Offices and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 150.

Corrective Action Plan

Department of Health & Human ServicesCenters for Medicare & Medicaid Services31 Forsyth Street, SW, Room 4T20Atlanta, Georgia 30303-8909The South Carolina Department of Health and Human Services respectfully submits the following corrective action plan for the year ended 6/30/19.The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule.FINDINGS?FEDERAL AWARD PROGRAM AUDIT2019-004Medicaid Cluster ? CFDA No. 93.775, 93.777 & 93.778Recommendation: We recommend the Department correct the errors in MMIS to ensure compliance with the Federal matching requirement for family planning services and family planning related services.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding:A modification became effective on 8/15/2019 that removed the ?0FP? modifier from system logic for fund code MK. This correction eliminated the auto assignment of 90/10 funding that overrode the family planning-related (70/30) procedure codes submitted by providers of service. This led to the return of $43,946.57 in Federal funds for the review period of January through Aug 2019.Name of the contact person responsible for corrective action: Kevin Bonds Planned completion date for corrective action plan: OngoingIf the U.S. Department of Health and Human Services has questions regarding this plan, please call Thomas C. Phillip, CFO, at 803-898-1017.

Prior Finding References

2018-003

About Matching, Level of Effort, Earmarking →
2019-005
Eligibility
SIGNIFICANT DEFICIENCYREPEAT OF 2018-004OTHER MATTERS

Eligibility files did not contain adequate documentation to support the Medicaid and CHIP recipients? eligibility statuses.Questioned Costs: UnknownContext: We tested one hundred twenty individual recipients (sixty each for Medicaid and CHIP) to ensure the Department was in compliance with applicable eligibility requirements. We determined the Department did not maintain adequate documentation of eligibility for thirteen Medicaid recipients and eight CHIP recipients.This is a repeat finding from the FY18 Single Audit. The Department stated on its Summary Schedule of Prior Year Audit Findings that this issue was ?Fully Corrected with Previously Reported Corrective Action Implemented?. Due to this issue repeating for FY19, this issue has not been fully corrected.Cause: The Department transitioned to an online eligibility system, the Medicaid Eligibility Determination System (MEDS), in July 2013. According to Department personnel, documentation in some of the paper files may not have been scanned into the system since the transition. For cases opened after the transition, the omissions were due to human error.Effect: The Department could not support eligibility determinations in accordance with its State plan.Recommendation: We recommend the Department maintain documentation to support its eligibility determinations in accordance with its State plan and Federal regulations.Prior Year Single Audit Finding Number: 2018-004Views of Responsible Offices and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 150.

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Documentation of EligibilityFederal Agency: Department of Health and Human ServicesFederal Program Title: Medicaid Cluster; Children?s Health Insurance Program (CHIP)CFDA No.: 93.775, 93.777, 93.778; 93.767Federal Grant ID Number: 05-1805SC5MAP, 05-1905SC5MAP; 05-1805SC5021, 05-1905SC5022Pass-Through Entity: Not applicableAward Period: October 1, 2017 through September 30, 2020Type of Finding: Significant deficiency in internal control over compliance, other mattersCriteria: 42 CFR 435.914 (a) states, ?The agency must include in each applicant?s case record facts to support the agency?s decision on his application.? In addition, Section 4.7 of the Department?s Title XIX (Medicaid) State Plan (Maintenance of Records) affirms that it meets the requirements outlined in 42 CFR 431.17 (b), which states, ?A State plan must provide that the Medicaid agency will maintain or supervise the maintenance of records necessary for the proper and efficient operation of the plan.? Furthermore, the Department?s Title XXI (CHIP) State Plan attests that CHIP will operate as a Medicaid expansion program; therefore, the aforementioned regulations apply to both programs.Condition: Eligibility files did not contain adequate documentation to support the Medicaid and CHIP recipients? eligibility statuses.Questioned Costs: UnknownContext: We tested one hundred twenty individual recipients (sixty each for Medicaid and CHIP) to ensure the Department was in compliance with applicable eligibility requirements. We determined the Department did not maintain adequate documentation of eligibility for thirteen Medicaid recipients and eight CHIP recipients.This is a repeat finding from the FY18 Single Audit. The Department stated on its Summary Schedule of Prior Year Audit Findings that this issue was ?Fully Corrected with Previously Reported Corrective Action Implemented?. Due to this issue repeating for FY19, this issue has not been fully corrected.Cause: The Department transitioned to an online eligibility system, the Medicaid Eligibility Determination System (MEDS), in July 2013. According to Department personnel, documentation in some of the paper files may not have been scanned into the system since the transition. For cases opened after the transition, the omissions were due to human error.Effect: The Department could not support eligibility determinations in accordance with its State plan.Recommendation: We recommend the Department maintain documentation to support its eligibility determinations in accordance with its State plan and Federal regulations.Prior Year Single Audit Finding Number: 2018-004Views of Responsible Offices and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 150.

Corrective Action Plan

Department of Health & Human ServicesCenters for Medicare & Medicaid Services31 Forsyth Street, SW, Room 4T20Atlanta, Georgia 30303-8909The South Carolina Department of Health and Human Services respectfully submits the following corrective action plan for the year ended 6/30/19.The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule.2019-005 Medicaid Cluster; Children?s Health Insurance Program ? CFDA No. 93.775, 93.777 & 93.778; 93.767Recommendation: We recommend the Department maintain documentation to support its eligibility determinations in accordance with its State plan and Federal regulations.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding:Pre-Electronic Document Management: In January 2019, the agency completed a scanning project in pursuit of a paper free environment. Any remaining paper case files for active beneficiaries were scanned into OnBase. There will always be the risk of paper files that have not been uploaded into the electronic case file as anticipated. The corrective action for reducing this risk was the implementation of OnBase. However, it is recognized that the agency is still accountable for having required documents or documentation in the case file and/or eligibility systems. For any document not found as part of a case review or audit, the corrective action for that review will be to pursue any needed documentation required to continue or end eligibility. The State's quality assurance strategy facilitates this process. The annual review process also requires the worker to ensure that required historical documents are in the case file.Post-Electronic Document Management: While the implementation of OnBase significantly reduces the risk of required documentation not being present in the case file, a thorough quality review process as described in this document is needed to help ensure compliance.SCDHHS Quality Assurance Strategy: The quality review process implemented in July 2019 includes key elements for review which lead to a correct or incorrect eligibility determination. This includes the presence of a signed application (where appropriate) and presence of other documentation required for the eligibility decision (e.g. Level of Care).The Eligibility Quality Assurance Team (EQAT) consists of 52 team members. Team members are trained to evaluate MAGI, Non-MAGI or Long-Term Care determinations for accuracy of those determinations, as well as vital procedural errors that are most likely to impact eligibility. Review findings are used as part of a monthly employee feedback process in conjunction with employee production metrics. On the first business day of each month, supervisors receive Employee Performance results for their staff and review these results during one on one meetings. Action plans are established, implemented and reviewed for any needed corrective measures. Between August 1, 2019 and January 31, 2020, the state has reviewed 40,015 cases with a 95% accuracy rate.SCDHHS will utilize audit and EQAT findings to analyze current trends regarding these errors. The State will develop and implement a strategy, including refresher training and policy clarifications to ensure staff fully understand policies and procedures regarding required documentation for eligibility determinations and the importance of this documentation.Names of the contact persons responsible for corrective action: Elizabeth Ryan, Michael Jones, Lori RiskPlanned completion date for corrective action plan: June 30, 2020If the U.S. Department of Health and Human Services has questions regarding this plan, please call Thomas C. Phillip, CFO, at 803-898-1017.

Prior Finding References

2018-004

About Eligibility →
2019-006
Eligibility
SIGNIFICANT DEFICIENCYREPEAT OF 2018-005QUESTIONED COSTSOTHER MATTERS

The Department did not consistently discontinue the Medicaid and CHIP benefits of ineligible recipients.Questioned Costs: $22,460Context: We tested one hundred twenty individual recipients (sixty each for Medicaid and CHIP) to ensure the Department was in compliance with applicable eligibility requirements. We determined the Department did not discontinue the benefits of five Medicaid recipients and three CHIP recipients on the dates they became ineligible.Cause: Department personnel stated the closure process for these recipients ultimately was not completed due to backlog in case processing and the continued prioritization of applications.Effect: The Department was not in compliance with applicable eligibility requirements. In addition, Medicaid and CHIP payments were made on behalf of ineligible recipients.Recommendation: We recommend the Department discontinue the Medicaid and CHIP benefits of ineligible recipients in accordance with its State plan and Federal regulations.Prior Year Single Audit Finding Number: 2018-005Views of Responsible Offices and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 151.

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Discontinuation of BenefitsFederal Agency: Department of Health and Human ServicesFederal Program Title: Medicaid Cluster; Children?s Health Insurance Program (CHIP)CFDA No.: 93.775, 93.777, 93.778; 93.767Federal Grant ID Number: 05-1805SC5MAP, 05-1905SC5MAP; 05-1805SC5021Pass-Through Entity: Not applicableAward Period: October 1, 2017 through September 30, 2019Type of Finding: Significant deficiency in internal control over compliance, other mattersCriteria: Section 4.32 of the Department?s Title XIX (Medicaid) State Plan (Income and Eligibility Verification System) affirms that it meets the requirements outlined in 42 CFR 435.930 (b), which states in part, ?The agency must?continue to furnish Medicaid regularly to all eligible individuals until they are found to be ineligible.? In addition, the Department?s Title XXI (CHIP) State Plan attests that CHIP will operate as a Medicaid expansion program; therefore, the aforementioned regulation applies to both programs.Condition: The Department did not consistently discontinue the Medicaid and CHIP benefits of ineligible recipients.Questioned Costs: $22,460Context: We tested one hundred twenty individual recipients (sixty each for Medicaid and CHIP) to ensure the Department was in compliance with applicable eligibility requirements. We determined the Department did not discontinue the benefits of five Medicaid recipients and three CHIP recipients on the dates they became ineligible.Cause: Department personnel stated the closure process for these recipients ultimately was not completed due to backlog in case processing and the continued prioritization of applications.Effect: The Department was not in compliance with applicable eligibility requirements. In addition, Medicaid and CHIP payments were made on behalf of ineligible recipients.Recommendation: We recommend the Department discontinue the Medicaid and CHIP benefits of ineligible recipients in accordance with its State plan and Federal regulations.Prior Year Single Audit Finding Number: 2018-005Views of Responsible Offices and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 151.

Corrective Action Plan

Department of Health & Human ServicesCenters for Medicare & Medicaid Services31 Forsyth Street, SW, Room 4T20Atlanta, Georgia 30303-8909The South Carolina Department of Health and Human Services respectfully submits the following corrective action plan for the year ended 6/30/19.The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule.2019-006 Medicaid Cluster; Children?s Health Insurance Program ? CFDA No. 93.775, 93.777 & 93.778; 93.767Recommendation: We recommend the Department discontinue the Medicaid and CHIP benefits of ineligible recipients in accordance with its State plan and Federal regulations.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding:The errors are caused by delays in annual review processing. SCDHHS has continued to implement a plan to reduce and manage the eligibility processing backlog, while also protecting the integrity of eligibility decisions. The agency?s approach has been to build staff capacity through the creation of processing centers and to maximize accuracy and timeliness of eligibility decisions via implementation of a Staff Performance Evaluation and Remediation process.Staff Capacity and Processing Centers: The agency has created and staffed four (4) processing centers in Richland (2), Aiken (1) and Spartanburg (1) counties. Staff processing MAGI, Non-MAGI and Long-Term Care applications now complete available work for processing applications daily, allowing for staff assignments for processing reviews. Staff webinars for processing reviews have been conducted for MAGI and Non-MAGI review processing in the past six months, as well as updates to job aids, based on updated policies and procedures. One additional processing center will be added in Florence County for additional MAGI application and review processing.Staff Performance Evaluation and Remediation: The performance evaluation plan rolled out to staff in July 2019. On the first business day of each month, supervisors receive Employee Performance results for their staff regarding both timeliness and accuracy of eligibility determinations and review these results during one on one meetings. Action plans are established, implemented and reviewed for any needed corrective measures in response to accuracy and/or timeliness metrics. Between August 1, 2019 and January 31, 2020, the state has reviewed 40,015 cases with a 95% accuracy rate.Names of the contact persons responsible for corrective action: Elizabeth Ryan, Michael Jones, Lori RiskPlanned completion date for corrective action plan: September 30, 2020 (New Processing Center)If the U.S. Department of Health and Human Services has questions regarding this plan, please call Thomas C. Phillip, CFO, at 803-898-1017.

Prior Finding References

2018-005

About Eligibility →
2019-007
Eligibility
MATERIAL WEAKNESSMODIFIED OPINIONREPEAT OF 2018-006

The Department did not consistently perform timely annual eligibility reviews for Medicaid and CHIP recipients in accordance with Section 101.10 of the South Carolina Medicaid Policies and Procedures Manual.Questioned Costs: UnknownContext: We tested one hundred twenty individual recipients (sixty each for Medicaid and CHIP) to ensure the Department was in compliance with applicable eligibility requirements. We determined the Department did not comply with the annual review requirement for fourteen Medicaid recipients (payment categories 10, 12, 32, 57, 59, 60, and 71) and twenty-one CHIP recipients (payment category 88).Cause: Department personnel stated they did not comply with the annual review requirement for these recipients due to backlog in case processing and the continued prioritization of applications.Effect: In the absence of an annual review, Medicaid and CHIP recipients may continue to receive benefits without meeting eligibility requirements.Recommendation: We recommend the Department ensure that eligibility reviews are performed annually in accordance with the South Carolina Medicaid Policies and Procedures Manual.Prior Year Single Audit Finding Number: 2018-006Views of Responsible Offices and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 152.

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Annual Eligibility ReviewsFederal Agency: Department of Health and Human ServicesFederal Program Title: Medicaid Cluster; Children?s Health Insurance Program (CHIP)CFDA No.: 93.775, 93.777, 93.778; 93.767Federal Grant ID Number: 05-1805SC5MAP, 05-1905SC5MAP; 05-1805SC5021, 05-1905SC5022Pass-Through Entity: Not applicableAward Period: October 1, 2017 through September 30, 2020Type of Finding: Material weakness in internal control over compliance, material noncomplianceCriteria: Section 2.1 of the Department?s Title XIX (Medicaid) State Plan (Application, Determination of Eligibility and Furnishing Medicaid) affirms that it meets the requirements outlined in 42 CFR Part 435.916, which states in part, ?the agency must promptly determine eligibility between regular renewals of eligibility.? In addition, Section 101.10 of the South Carolina Medicaid Policies and Procedures Manual states that the Department must complete an annual review for payment categories 10, 12, 32, 57, 59, 60, 71, and 88. Furthermore, the Department?s Title XXI (CHIP) State Plan attests that CHIP will operate as a Medicaid expansion program; therefore, the aforementioned regulation and policies apply to both programs.Condition: The Department did not consistently perform timely annual eligibility reviews for Medicaid and CHIP recipients in accordance with Section 101.10 of the South Carolina Medicaid Policies and Procedures Manual.Questioned Costs: UnknownContext: We tested one hundred twenty individual recipients (sixty each for Medicaid and CHIP) to ensure the Department was in compliance with applicable eligibility requirements. We determined the Department did not comply with the annual review requirement for fourteen Medicaid recipients (payment categories 10, 12, 32, 57, 59, 60, and 71) and twenty-one CHIP recipients (payment category 88).Cause: Department personnel stated they did not comply with the annual review requirement for these recipients due to backlog in case processing and the continued prioritization of applications.Effect: In the absence of an annual review, Medicaid and CHIP recipients may continue to receive benefits without meeting eligibility requirements.Recommendation: We recommend the Department ensure that eligibility reviews are performed annually in accordance with the South Carolina Medicaid Policies and Procedures Manual.Prior Year Single Audit Finding Number: 2018-006Views of Responsible Offices and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 152.

Corrective Action Plan

Department of Health & Human ServicesCenters for Medicare & Medicaid Services31 Forsyth Street, SW, Room 4T20Atlanta, Georgia 30303-8909The South Carolina Department of Health and Human Services respectfully submits the following corrective action plan for the year ended 6/30/19.The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule.2019-007 Medicaid Cluster; Children?s Health Insurance Program ? CFDA No. 93.775, 93.777 & 93.778; 93.767Recommendation: We recommend eligibility reviews are performed annually in accordance with the South Carolina Medicaid Policies and Procedures Manual.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding:The errors are caused by delays in annual review processing. SCDHHS has continued to implement a plan to reduce and manage the eligibility processing backlog, while also protecting the integrity of eligibility decisions. The agency?s approach has been to build staff capacity through the creation of processing centers and to maximize accuracy and timeliness of eligibility decisions via implementation of a Staff Performance Evaluation and Remediation process.Staff Capacity and Processing Centers: The agency has created and staffed four (4) processing centers in Richland (2), Aiken (1) and Spartanburg (1) counties. Staff processing MAGI, Non-MAGI and Long-Term Care applications now complete available work for processing applications daily, allowing for staff assignments for processing reviews. Staff webinars for processing reviews have been conducted for MAGI and Non-MAGI review processing in the past six months, as well as updates to job aids, based on updated policies and procedures. One additional processing center will be added in Florence County for additional MAGI application and review processing.Staff Performance Evaluation and Remediation: The performance evaluation plan rolled out to staff in July 2019. On the first business day of each month, supervisors receive Employee Performance results for their staff regarding both timeliness and accuracy of eligibility determinations and review these results during one on one meetings. Action plans are established, implemented and reviewed for any needed corrective measures in response to accuracy and/or timeliness metrics. Between August 1, 2019 and January 31, 2020, the state has reviewed 40,015 cases with a 95% accuracy rate.Names of the contact persons responsible for corrective action: Elizabeth Ryan, Michael Jones, Lori RiskPlanned completion date for corrective action plan: September 30, 2020 (New Processing Center)If the U.S. Department of Health and Human Services has questions regarding this plan, please call Thomas C. Phillip, CFO, at 803-898-1017.

Prior Finding References

2018-006

About Eligibility →
2019-009
Reporting
SIGNIFICANT DEFICIENCYREPEAT OF 2018-011OTHER MATTERS

The automated data processing and information retrieval system had not been fully implemented during the audit period.Questioned Costs: UnknownContext: As reported in the prior year, the Department did not implement the automated data processing and information retrieval system as required by Section 454 (24) (B) and as a result has been assessed penalty payments for noncompliance. The Department began implementation of the system in State fiscal year 2019, completed implementation shortly after the State fiscal year, and subsequently received Federal approval of the system.Cause: The Department and its contractor were in process of finalizing implementation of the system during State fiscal year 2019.Effect: Prior to the system being fully implemented, certain data necessary for proper completion of the Office of Child Support Enforcement (OCSE) 34A financial report was not available and, as a result, the Department was not in compliance with its Federal requirements during the audit period.Recommendation: We recommend that Department internal controls remain in place and operating to ensure that the Federally approved child support automated data processing and information retrieval system continues to meet all applicable Federal requirements.Prior Year Single Audit Report Finding Number: 2018-011Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 156.

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ReportingFederal Agency: Department of Health and Human ServicesFederal Program Title: Child Support EnforcementCFDA No.: 93.563Federal Grant ID Number: VariousPass-Through Entity: Not applicableAward Period: VariousType of Finding: Significant deficiency in internal control over compliance, other mattersCriteria: Section 454 (24) of the Social Security Act (the Act), as amended, by the Personal Responsibility and Work Opportunity Reconciliation Act of 1996 (PRWORA), requires states to have an operational automated data processing and information retrieval system for child and spousal support. The system must be in place by October 1, 1997, and meet all the requirements of paragraph (16) of the Act. The secretary of the U.S. Department of Health and Human Services (USDHHS) must approve the system.Condition: The automated data processing and information retrieval system had not been fully implemented during the audit period.Questioned Costs: UnknownContext: As reported in the prior year, the Department did not implement the automated data processing and information retrieval system as required by Section 454 (24) (B) and as a result has been assessed penalty payments for noncompliance. The Department began implementation of the system in State fiscal year 2019, completed implementation shortly after the State fiscal year, and subsequently received Federal approval of the system.Cause: The Department and its contractor were in process of finalizing implementation of the system during State fiscal year 2019.Effect: Prior to the system being fully implemented, certain data necessary for proper completion of the Office of Child Support Enforcement (OCSE) 34A financial report was not available and, as a result, the Department was not in compliance with its Federal requirements during the audit period.Recommendation: We recommend that Department internal controls remain in place and operating to ensure that the Federally approved child support automated data processing and information retrieval system continues to meet all applicable Federal requirements.Prior Year Single Audit Report Finding Number: 2018-011Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 156.

Corrective Action Plan

Department of Health and Human ServicesThe South Carolina Department of Social Services respectfully submits the following corrective action plan for the year ended June 30, 2019.Audit period: June 30, 2019The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule.FINDINGS?FEDERAL AWARD PROGRAM AUDITDEPARTMENT OF SOCIAL SERVICES2019-009 Child Support Enforcement ? CFDA No. 93.563Recommendation: We recommend that Department internal controls remain in place and operating to ensure that the Federally approved child support automated data processing and information retrieval system continues to meet all applicable Federal requirements.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding: The Department completed state-wide system implementation in August 2019 and received Federal Certification from the Office of Child Support Enforcement (OCSE) on September 6, 2019.Name(s) of the contact person(s) responsible for corrective action: Jimmy Early, Project DirectorPlanned completion date for corrective action plan: September 30, 2019If the Federal Cognizant of Oversight Agency for Audit has questions regarding this plan, please call Susan Roben, Controller at 803-898-7427.

Prior Finding References

2018-011

About Reporting →
2019-010
Reporting
MATERIAL WEAKNESSMODIFIED OPINIONREPEAT OF 2018-014

The schedule of expenditures of Federal awards initially prepared by Department management contained several errors, including the incorrect amount of program funds passed through to subrecipients.Questioned Costs: NoneContext: Auditor corrections were necessary for accurate presentation of the schedule of expenditures of Federal awards. In order to agree schedule expenditures to the accounting records, auditor corrections were necessary, including an adjustment in the amount of $3,630,763 to correct the reported subrecipient expenditures.Cause: Management review of the schedule of expenditures of Federal awards failed to detect and correct several presentation errors and accounting transactions that were improperly included in the reported subrecipient expenditure amounts.Effect: Auditor corrections and adjustments were required to correct the schedule of expenditures of Federal awards.Recommendation: We recommend that the Department review procedures for preparing, reviewing and approving its schedule of expenditures of Federal awards to ensure accurate reporting.Prior Year Single Audit Report Finding Number: 2018-014Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 157.

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ReportingFederal Agency: Department of Health and Human ServicesFederal Program Title: Child Support EnforcementCFDA No.: 93.563Federal Grant ID Number: 1804SCCSES, 1904SCCESPass-Through Entity: Not applicableAward Period: October 1, 2017 through September 30, 2019Type of Finding: Material weakness in internal control over compliance, material noncomplianceCriteria: Per 2 CFR ? 200.510(b), the auditee must prepare a schedule of expenditures of Federal awards for the period covered by the auditee?s financial statements which must include the total Federal awards expended as determined in accordance with 2 CFR ? 200.502. Per this section, the schedule must include the total amount provided to subrecipients from each Federal program.Condition: The schedule of expenditures of Federal awards initially prepared by Department management contained several errors, including the incorrect amount of program funds passed through to subrecipients.Questioned Costs: NoneContext: Auditor corrections were necessary for accurate presentation of the schedule of expenditures of Federal awards. In order to agree schedule expenditures to the accounting records, auditor corrections were necessary, including an adjustment in the amount of $3,630,763 to correct the reported subrecipient expenditures.Cause: Management review of the schedule of expenditures of Federal awards failed to detect and correct several presentation errors and accounting transactions that were improperly included in the reported subrecipient expenditure amounts.Effect: Auditor corrections and adjustments were required to correct the schedule of expenditures of Federal awards.Recommendation: We recommend that the Department review procedures for preparing, reviewing and approving its schedule of expenditures of Federal awards to ensure accurate reporting.Prior Year Single Audit Report Finding Number: 2018-014Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 157.

Corrective Action Plan

Department of Health and Human ServicesThe South Carolina Department of Social Services respectfully submits the following corrective action plan for the year ended June 30, 2019.Audit period: June 30, 2019The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule.FINDINGS?FEDERAL AWARD PROGRAM AUDIT2019-010 Child Support Enforcement ? CFDA No. 93.563Recommendation: We recommend that the Department review procedures for preparing, reviewing and approving its Schedule of Expenditures of Federal Awards to ensure accurate reporting.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding: This finding resulted from the incorrect inclusion of Incentive Grant expenditures in subrecipient costs. Procedures have already been implemented to review subrecipient expenditures to be reported to ensure they exclude Incentive funds. The Department will also implement an additional level of review of the SEFA report to ensure accurate reporting.Name(s) of the contact person(s) responsible for corrective action: Ashley Harris, Grants Accounting and Reporting ManagerPlanned completion date for corrective action plan: August 30, 2020If the Federal Cognizant of Oversight Agency for Audit has questions regarding this plan, please call Susan Roben, Controller at 803-898-7427.

Prior Finding References

2018-014

About Reporting →
2019-011
Cash Management
SIGNIFICANT DEFICIENCYOTHER MATTERS

Documentation supporting Federal cash draws was not adequate to confirm compliance with cash management requirements.Questioned Costs: NoneContext: Department supporting documentation was not adequate to fully support accurate reimbursement for fifteen of fifteen Federal cash draws tested. In addition two related instances of amounts subsequently being required to be returned to their respective grantors were noted.Cause: Due to staffing turnover, the Department?s internal controls associated with Federal cash draws were not operating effectively to demonstrate compliance and prevent errors.Effect: The Department did not adequately document their Federal cash draw process to demonstrate compliance. Additionally, there were two instances in which the Department returned overdrawn funding to the grantor: one for $781,141 to the Child Support Enforcement program and another for $121,539 to the Adoption Assistance program.Recommendation: We recommend that the Department review its internal controls over the Federal cash draws process to ensure compliance with cash management requirements.Prior Year Single Audit Report Finding Number: Not applicableViews of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 157.

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Cash ManagementFederal Agency: Department of Health and Human ServicesFederal Program Title: Child Support Enforcement, Social Services Block Grant, Adoption AssistanceCFDA No.: 93.563, 93.667, 93.659Federal Grant ID Number: 1804SCCSES, 1802SCSORSR, 1801SCADPT, 1901SCADPTPass-Through Entity: Not applicableAward Period: October 1, 2017 through September 30, 2019Type of Finding: Significant deficiency in internal control over compliance, other mattersCriteria: Per 31 CFR ? 205.12(b)(5) reimbursable funding means that a Federal Program Agency transfers Federal funds to a State after that State has already paid out the funds for Federal assistance program purposes.Condition: Documentation supporting Federal cash draws was not adequate to confirm compliance with cash management requirements.Questioned Costs: NoneContext: Department supporting documentation was not adequate to fully support accurate reimbursement for fifteen of fifteen Federal cash draws tested. In addition two related instances of amounts subsequently being required to be returned to their respective grantors were noted.Cause: Due to staffing turnover, the Department?s internal controls associated with Federal cash draws were not operating effectively to demonstrate compliance and prevent errors.Effect: The Department did not adequately document their Federal cash draw process to demonstrate compliance. Additionally, there were two instances in which the Department returned overdrawn funding to the grantor: one for $781,141 to the Child Support Enforcement program and another for $121,539 to the Adoption Assistance program.Recommendation: We recommend that the Department review its internal controls over the Federal cash draws process to ensure compliance with cash management requirements.Prior Year Single Audit Report Finding Number: Not applicableViews of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 157.

Corrective Action Plan

Department of Health and Human ServicesThe South Carolina Department of Social Services respectfully submits the following corrective action plan for the year ended June 30, 2019.Audit period: June 30, 2019The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule.FINDINGS?FEDERAL AWARD PROGRAM AUDIT2019-011 Child Support Enforcement, Social Services Block Grant, Adoption Assistance ? CFDA No.93.563, 93.667, 93.659Recommendation: We recommend that the Department review its internal controls over the Federal cash draws process to ensure compliance with cash management requirements.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding: The Department will put procedures in place to ensure proper supporting documentation from the accounting system is retained to support accurate reimbursement for all Federal cash draws. Draws will also be performed on a periodic basis to be determined by individual grant, but at least monthly if needed.Name(s) of the contact person(s) responsible for corrective action: Ashley Harris, Grants Accounting and Reporting ManagerPlanned completion date for corrective action plan: March 31, 2020If the Federal Cognizant of Oversight Agency for Audit has questions regarding this plan, please call Susan Roben, Controller at 803-898-7427.

About Cash Management →
2019-012
Matching, Level of Effort, Earmarking / Reporting
SIGNIFICANT DEFICIENCYOTHER MATTERS

An annual federal financial report, SF-425, and two quarterly CB-496 reports were submitted with financial and statistical errors.Questioned Costs: NoneContext: For one of two annual SF-425 reports selected for testing, incorrect amounts were reported for Federal cash receipts and cash disbursements. Receipts occurring after the report date were included on the cash basis report and total Federal funds authorized were mistakenly reported as disbursements.For both CB-496 reports selected for testing, administrative costs ? non-recurring were reported with administrative costs ? agency, rather than separately as required by the report instructions. In addition, discrepancies were noted between the supporting documentation and number of payments for children assisted reported in Part 1, Section D of the report. Finally, in Part 4 of the report, discrepancies were noted when agreeing to data used to calculate amounts reported on lines 3 and 5 and the Department was unable to provide support for the amount reported on line 10. Because of the relationship of the amount on line 10 to level of effort compliance, level of effort compliance could not be confirmed.Cause: The Department?s internal controls failed to detect the errors prior to submission of the reports.Effect: Federal cash receipts and cash disbursements were overstated on the SF-425 report.All administrative costs ? non-recurring were misclassified as administrative costs ? agency on each of the two CB-496 reports tested. Certain amounts reported in Part 1, Section D, and in Part 4 of the report could not be validated.Recommendation: We recommend that the Department strengthen its internal controls and processes to ensure that Federal reports are free from error and clearly supported prior to submission of the report.Prior Year Single Audit Report Finding Number: Not applicableViews of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 157.

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Reporting/Level of EffortFederal Agency: Department of Health and Human ServicesFederal Program Title: Social Services Block Grant, Adoption AssistanceCFDA No.: 93.667, 93.659Federal Grant ID Number: 1802SCSOSR, 1801SCADPT, 1901SCADPTPass-Through Entity: Not applicableAward Period: October 1, 2017 through September 30, 2019Type of Finding: Significant deficiency in internal control over compliance, other mattersCriteria: 45 CFR ? 75.342 requires compliance with the provisions of monitoring and reporting program performance. The Department's internal controls should be designed to ensure compliance with those provisions.42 U.S.C. ? 673(a)(8) outlines the level of effort requirements for adoption savings.Condition: An annual federal financial report, SF-425, and two quarterly CB-496 reports were submitted with financial and statistical errors.Questioned Costs: NoneContext: For one of two annual SF-425 reports selected for testing, incorrect amounts were reported for Federal cash receipts and cash disbursements. Receipts occurring after the report date were included on the cash basis report and total Federal funds authorized were mistakenly reported as disbursements.For both CB-496 reports selected for testing, administrative costs ? non-recurring were reported with administrative costs ? agency, rather than separately as required by the report instructions. In addition, discrepancies were noted between the supporting documentation and number of payments for children assisted reported in Part 1, Section D of the report. Finally, in Part 4 of the report, discrepancies were noted when agreeing to data used to calculate amounts reported on lines 3 and 5 and the Department was unable to provide support for the amount reported on line 10. Because of the relationship of the amount on line 10 to level of effort compliance, level of effort compliance could not be confirmed.Cause: The Department?s internal controls failed to detect the errors prior to submission of the reports.Effect: Federal cash receipts and cash disbursements were overstated on the SF-425 report.All administrative costs ? non-recurring were misclassified as administrative costs ? agency on each of the two CB-496 reports tested. Certain amounts reported in Part 1, Section D, and in Part 4 of the report could not be validated.Recommendation: We recommend that the Department strengthen its internal controls and processes to ensure that Federal reports are free from error and clearly supported prior to submission of the report.Prior Year Single Audit Report Finding Number: Not applicableViews of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 157.

Corrective Action Plan

Department of Health and Human ServicesThe South Carolina Department of Social Services respectfully submits the following corrective action plan for the year ended June 30, 2019.Audit period: June 30, 2019The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule.FINDINGS?FEDERAL AWARD PROGRAM AUDIT2019-012 Social Services Block Grant, Adoption Assistance ? CFDA No. 93.667, 93.659Recommendation: We recommend that the Department strengthen its internal controls and processes to ensure that Federal reports are free from error and clearly supported prior to submission of the report.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding: Due to staff turnover, the Department has an entirely new Grants Accounting and Reporting team. All staff are being trained on the proper completion of the Federal Financial Reports, including period of performance cut-off dates. In addition, each report will be reviewed by a manager or the Controller prior to submission.Name(s) of the contact person(s) responsible for corrective action: Ashley Harris, Grants Accounting and Reporting ManagerPlanned completion date for corrective action plan: June 30, 2020If the Federal Cognizant of Oversight Agency for Audit has questions regarding this plan, please call Susan Roben, Controller at 803-898-7427.

About Matching, Level of Effort, Earmarking, Reporting →
2019-013
Activities Allowed or Unallowed
SIGNIFICANT DEFICIENCYQUESTIONED COSTSOTHER MATTERS

A Department case service expenditure unrelated to the Adoption Assistance program was charged to the grant.Questioned Costs: $3,345Context: One of sixty expenditures selected for testing was for an activity not related to the Adoption Assistance program.Cause: The Department?s internal controls failed to prevent an improper charge to the grant.Effect: Program funds were used to pay a claim that was not allowable in accordance with federal regulations.Recommendation: We recommend that the Department strengthen its internal controls and processes to ensure that all charges to the grant are for allowable activities only.Prior Year Single Audit Report Finding Number: Not applicableViews of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 158.

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Activities Allowed or UnallowedFederal Agency: Department of Health and Human ServicesFederal Program Title: Adoption AssistanceCFDA No.: 93.659Federal Grant ID Number: 1901SCADPTPass-Through Entity: Not applicableAward Period: October 1, 2018 through September 30, 2019Type of Finding: Significant deficiency in internal control over compliance, other mattersCriteria: 45 CFR ? 1356 identifies the allowable activities of the Adoption Assistance grant program.Condition: A Department case service expenditure unrelated to the Adoption Assistance program was charged to the grant.Questioned Costs: $3,345Context: One of sixty expenditures selected for testing was for an activity not related to the Adoption Assistance program.Cause: The Department?s internal controls failed to prevent an improper charge to the grant.Effect: Program funds were used to pay a claim that was not allowable in accordance with federal regulations.Recommendation: We recommend that the Department strengthen its internal controls and processes to ensure that all charges to the grant are for allowable activities only.Prior Year Single Audit Report Finding Number: Not applicableViews of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 158.

Corrective Action Plan

Department of Health and Human ServicesThe South Carolina Department of Social Services respectfully submits the following corrective action plan for the year ended June 30, 2019.Audit period: June 30, 2019The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule.FINDINGS?FEDERAL AWARD PROGRAM AUDIT2019-013 Adoption Assistance ? CFDA No. 93.659Recommendation: We recommend that the Department strengthen its internal controls and processes to ensure that all charges to the grant are for allowable activities only.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding: The Department will conduct additional staff training to stress the importance of coding invoices to the general ledger account segments that are listed and approved on the invoice. An Accounts Payable manager or supervisor will also review the coding on the invoice when approving the invoice through workflow in SCEIS to ensure it matches what has been entered in SCEIS.Name(s) of the contact person(s) responsible for corrective action: Zandria Buck, Accounts Payable ManagerPlanned completion date for corrective action plan: March 31, 2020If the Federal Cognizant of Oversight Agency for Audit has questions regarding this plan, please call Susan Roben, Controller at 803-898-7427.

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2019-014
Cost Allowability
SIGNIFICANT DEFICIENCYQUESTIONED COSTSOTHER MATTERS

Allowable training costs charged to the program were not adequately supported.Questioned Costs: $73,338Context: Seven of eight administrative and training disbursement transactions selected for testing were for allowable training costs benefitting multiple grant programs. The Department?s allocation of the cost, and related cost share, to the various grant programs was not adequately supported.Cause: Training costs benefitting multiple programs were charged using a previously determined rate without updating the charge to match the actual proportional benefit to each program.Effect: The potential for overcharging the grant exists when costs are charged to the programs without documenting the proportional benefit in accordance with the federal regulations.Recommendation: We recommend the Department update internal controls for charging direct training costs benefitting multiple programs to ensure that the costs charged only reflect the net proportional benefit applicable to each program.Prior Year Single Audit Report Finding Number: Not applicableViews of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 158.

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Allowable Costs/Cost PrinciplesFederal Agency: Department of Health and Human ServicesFederal Program Title: Adoption AssistanceCFDA No.: 93.659Federal Grant ID Number: 1801SCADPT, 1901SCADPTPass-Through Entity: Not applicableAward Period: October 1, 2017 through September 30, 2019Type of Finding: Significant deficiency in internal control over compliance, other mattersCriteria: 45 CFR ? 75.405(d) addresses the requirements and guidance for the allocation of direct costs applicable to multiple projects.Condition: Allowable training costs charged to the program were not adequately supported.Questioned Costs: $73,338Context: Seven of eight administrative and training disbursement transactions selected for testing were for allowable training costs benefitting multiple grant programs. The Department?s allocation of the cost, and related cost share, to the various grant programs was not adequately supported.Cause: Training costs benefitting multiple programs were charged using a previously determined rate without updating the charge to match the actual proportional benefit to each program.Effect: The potential for overcharging the grant exists when costs are charged to the programs without documenting the proportional benefit in accordance with the federal regulations.Recommendation: We recommend the Department update internal controls for charging direct training costs benefitting multiple programs to ensure that the costs charged only reflect the net proportional benefit applicable to each program.Prior Year Single Audit Report Finding Number: Not applicableViews of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 158.

Corrective Action Plan

Department of Health and Human ServicesThe South Carolina Department of Social Services respectfully submits the following corrective action plan for the year ended June 30, 2019.Audit period: June 30, 2019The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule.FINDINGS?FEDERAL AWARD PROGRAM AUDIT2019-014 Adoption Assistance ? CFDA No. 93.659Recommendation: We recommend the Department update internal controls for charging direct training costs benefitting multiple programs to ensure that the costs charged only reflect the net proportional benefit applicable to each program.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding: The Department has already begun updating its process for charging training costs beginning July 1, 2019. Each invoice submitted will have a listing of each training course that was provided, along with a listing of the costsseparated between training and administrative costs. This will allow the Department to charge each training to the benefitting program based on the specific training course conducted.Name(s) of the contact person(s) responsible for corrective action: Susan Roben, ControllerPlanned completion date for corrective action plan: June 30, 2020If the Federal Cognizant of Oversight Agency for Audit has questions regarding this plan, please call Susan Roben, Controller at 803-898-7427.

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2019-015
Eligibility
MATERIAL WEAKNESSMODIFIED OPINIONQUESTIONED COSTS

Eligibility could not be confirmed for some payments tested.Questioned Costs: $2,346Context: Sixty payments were selected for testing of eligibility compliance. The adoption subsidy agreement on file for four of those payments was not signed in accordance with the federal regulations, and one of those files lacked any additional documentation to verify eligibility. For another payment tested, the subsidy payment exceeded the amount documented on the adoption subsidy agreement. In addition, documentation was not adequate to support three subsidy payments tested for eligible children no longer under the age of eighteen at the time of the payment.Cause: Documentation in some case files was not adequate to support the applicable subsidy payments.Effect: Eligibility, in accordance with federal and/or Department requirements, could not be confirmed for some subsidy payments.Recommendation: We recommend that the Department review eligibility file controls to ensure that all payments are adequately supported throughout the eligibility period.Prior Year Single Audit Report Finding Number: Not applicableViews of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 159.

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EligibilityFederal Agency: Department of Health and Human ServicesFederal Program Title: Adoption AssistanceCFDA No.: 93.659Federal Grant ID Number: 1801ASADPT, 1901SCADPTPass-Through Entity: Not applicableAward Period: October 1, 2017 through September 30, 2019Type of Finding: Material weakness in internal control over compliance, material noncomplianceCriteria: 45 CFR ? 75.361 outlines record retention requirements of the non-Federal entity pertinent to the Federal award.45 CFR ? 1356.40(b) outlines the requirements pertaining to signed adoption agreements.42 U.S.C. ? 673(a) outlines eligibility requirements for subsidy payments.42 U.S.C. ? 675(8) expands eligibility requirements for children over the age of 18.Condition: Eligibility could not be confirmed for some payments tested.Questioned Costs: $2,346Context: Sixty payments were selected for testing of eligibility compliance. The adoption subsidy agreement on file for four of those payments was not signed in accordance with the federal regulations, and one of those files lacked any additional documentation to verify eligibility. For another payment tested, the subsidy payment exceeded the amount documented on the adoption subsidy agreement. In addition, documentation was not adequate to support three subsidy payments tested for eligible children no longer under the age of eighteen at the time of the payment.Cause: Documentation in some case files was not adequate to support the applicable subsidy payments.Effect: Eligibility, in accordance with federal and/or Department requirements, could not be confirmed for some subsidy payments.Recommendation: We recommend that the Department review eligibility file controls to ensure that all payments are adequately supported throughout the eligibility period.Prior Year Single Audit Report Finding Number: Not applicableViews of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 159.

Corrective Action Plan

Department of Health and Human ServicesThe South Carolina Department of Social Services respectfully submits the following corrective action plan for the year ended June 30, 2019.Audit period: June 30, 2019The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule.FINDINGS?FEDERAL AWARD PROGRAM AUDIT2019-015 Adoption Assistance ? CFDA No. 93.659Recommendation: We recommend that the Department review eligibility file controls to ensure that all payments are adequately supported throughout the eligibility period.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding: All adoption subsidy agreements are currently sent to the State Office Adoptions Manager for signature. When the agreements are entered into CAPSS, staff verify that the agreement includes the proper signature. The Department will begin reviewing older files to ensure all subsidy agreements have the proper signatures in accordance with federal regulations.The Department will also create a review tool to verify eligibility and staff will pull fifteen (15) sample cases quarterly to conduct internal review to ensure all subsidy payments are adequately supported. The State Office Adoptions Manager will verify the subsidy agreement with the subsidy payment to ensure the amounts are correct. If a discrepancy is found, the manager will contact the region for clarification.The Department will send school verification letters prior to the child?s 18th birthday if documentation was not previously provided to ensure subsidy payments are terminated at the end of the 18th birthday month.Name(s) of the contact person(s) responsible for corrective action: Dawn Barton, Director of Permanency ManagementPlanned completion date for corrective action plan: June 30, 2020If the Federal Cognizant of Oversight Agency for Audit has questions regarding this plan, please call Susan Roben, Controller at 803-898-7427.

About Eligibility →
2019-016
Period of Performance
SIGNIFICANT DEFICIENCYOTHER MATTERS

Matching funds charged to the grant were liquidated after the end of the succeeding fiscal year of the grant.Questioned Costs: UndeterminedContext: One of five transactions selected for testing was a journal entry which traced back to disbursement transactions that were liquidated after the end of the liquidation period of the grant.Cause: The Department?s internal controls failed to identify and prevent the liquidation of funds after the allowed period.Effect: Expenditures may be charged to the grant that are outside the allowed period of performance.Recommendation: We recommend that the Department strengthen internal controls to ensure that all awarded funds are liquidated within the award?s period of performance.Prior Year Single Audit Report Finding Number: Not applicableViews of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 159.

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Period of PerformanceFederal Agency: Department of Health and Human ServicesFederal Program Title: Child Care and Development FundCFDA No.: 93.575, 93.596Federal Grant ID Number: 1701SCCCDFPass-Through Entity: Not applicableAward Period: October 1, 2016 through September 30, 2018Type of Finding: Significant deficiency in internal control over compliance, other mattersCriteria: 45 CFR ? 98.60(d)(3) states, both the Federal and non-Federal share of the Matching Fund shall be obligated in the fiscal year in which the funds are granted and liquidated no later than the end of the succeeding fiscal year.Condition: Matching funds charged to the grant were liquidated after the end of the succeeding fiscal year of the grant.Questioned Costs: UndeterminedContext: One of five transactions selected for testing was a journal entry which traced back to disbursement transactions that were liquidated after the end of the liquidation period of the grant.Cause: The Department?s internal controls failed to identify and prevent the liquidation of funds after the allowed period.Effect: Expenditures may be charged to the grant that are outside the allowed period of performance.Recommendation: We recommend that the Department strengthen internal controls to ensure that all awarded funds are liquidated within the award?s period of performance.Prior Year Single Audit Report Finding Number: Not applicableViews of Responsible Officials and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 159.

Corrective Action Plan

Department of Health and Human ServicesThe South Carolina Department of Social Services respectfully submits the following corrective action plan for the year ended June 30, 2019.Audit period: June 30, 2019The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule.FINDINGS?FEDERAL AWARD PROGRAM AUDIT2019-016 Child Care Development Fund ? CFDA No. 93.575, 93.596Recommendation: We recommend that the Department strengthen internal controls toensure that all awarded funds are liquidated within the award?s period of performance.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding: The Department has already put procedures in place to review invoices before they are paid to ensure each invoice is paid to the correct period of performance. Staff will also review general ledger posting and transaction dates to ensure that all awarded funds are posted to the correct period of performance.Name(s) of the contact person(s) responsible for corrective action: Ashley Harris, Grants and Reporting ManagerPlanned completion date for corrective action plan: March 31, 2020If the Federal Cognizant of Oversight Agency for Audit has questions regarding this plan, please call Susan Roben, Controller at 803-898-7427.

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2019-017
Subrecipient Monitoring
MATERIAL WEAKNESSMODIFIED OPINION

The Department communicates grant and program information to each subrecipient annually through a standardized contracting agreement, however not all of the required information is included in the process.Questioned Costs: NoneContext: For eight of eight subrecipients tested, subaward documents did not include all of the federally required information.Cause: The Department?s internal controls failed to ensure adequate communications to the subrecipients through the annual subaward process as required by the federal regulations.Effect: The Department is not in compliance with the requirements for pass-through entities.Recommendation: We recommend that the Department update subrecipient agreements to incorporate all of the required information to ensure adequate communication to their subrecipients.Prior Year Single Audit Finding Number: Not applicableViews of Responsible Offices and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 161.

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Subrecipient MonitoringFederal Agency: Department of Health and Human ServicesFederal Program Title: Prevention and Treatment of Substance AbuseCFDA No.: 93.959Federal Grant ID Number: J2001SAPBG17, J2001SAPBG18, J2001SAPBG19Pass-Through Entity: Not applicableAward Period: October 1, 2016 through September 30, 2020Type of Finding: Material weakness in internal control over compliance, material noncomplianceCriteria: Per 45 CFR ?75.352(a) All pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes all of the information required by 45 CFR 75.352 (a)(1)(i-xiii) at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward.Condition: The Department communicates grant and program information to each subrecipient annually through a standardized contracting agreement, however not all of the required information is included in the process.Questioned Costs: NoneContext: For eight of eight subrecipients tested, subaward documents did not include all of the federally required information.Cause: The Department?s internal controls failed to ensure adequate communications to the subrecipients through the annual subaward process as required by the federal regulations.Effect: The Department is not in compliance with the requirements for pass-through entities.Recommendation: We recommend that the Department update subrecipient agreements to incorporate all of the required information to ensure adequate communication to their subrecipients.Prior Year Single Audit Finding Number: Not applicableViews of Responsible Offices and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 161.

Corrective Action Plan

U.S. Department of Health and Human ServicesRE: Corrective Action Plan for Year Ended June 30, 2019The South Carolina Department of Alcohol and Other Drug Abuse Services respectfully submits the following corrective action plan for the year ended June 30, 2019.The schedule of findings and questioned costs are discussed below. The findings are numbered in accordance with the numbers assigned in the schedule.FINDINGS - FEDERAL AWARD PROGRAM AUDIT2019-017. Prevention and Treatment of Substance Abuse - CFDA No.: 93.959Recommendation: We recommend that the Department update subrecipient agreements to incorporate all of the required information to ensure adequate communication to their subrecipients.Explanation of disagreement with audit finding: NIAAction taken in response to finding: Since the Single Audit, all required information has been added to the sub-awards, to include the Federal Award Identification Number (FAIN) and the federal award date. In State Fiscal Year 2021, the awards will contain all the required information.Name(s) of the contact person(s) responsible for corrective action:Carmen TatePlanned completion date for corrective action plan: Any sub-awards implemented in January 2020 contained the required information.If there are any questions regarding this corrective action plan, please contact me at 803-896-1145 .

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2019-018
Activities Allowed or Unallowed / Cost Allowability
MATERIAL WEAKNESSOTHER MATTERS

The Department did not have adequately functioning controls over time and effort reporting to ensure timesheets were reviewed by a direct supervisor and supporting evidence was maintained.Questioned Costs: UnknownContext: For nineteen of forty payroll transactions tested, employee time and effort review and approval documentation was not maintained in order to adequately support control process.Cause: The Department did not maintain documentation of direct supervisor review and approval of time and effort.Effect: The Department is not in compliance with applicable allowable activities/costs requirements.Recommendation: We recommend that the Department implement policies and procedures to ensure that sufficient documentation of reviews and approvals are maintained.Prior Year Single Audit Finding Number: Not applicableViews of Responsible Offices and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 161.

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Activities Allowed or Unallowed and Allowable Costs/Cost PrinciplesFederal Agency: Department of Health and Human ServicesFederal Program Title: Prevention and Treatment of Substance AbuseCFDA No.: 93.959Federal Grant ID Number: J2001SAPBG18, J2001SAPBG19Pass-Through Entity: Not applicableAward Period: October 1, 2017 through September 30, 2020Type of Finding: Material Weakness in internal control over compliance, other mattersCriteria: Per 2 CFR ? 200.430 (a) Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities; (2) Follows an appointment made in accordance with a non-Federal entity?s laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, Standards for Documentation of Personnel Expenses, when applicable.Condition: The Department did not have adequately functioning controls over time and effort reporting to ensure timesheets were reviewed by a direct supervisor and supporting evidence was maintained.Questioned Costs: UnknownContext: For nineteen of forty payroll transactions tested, employee time and effort review and approval documentation was not maintained in order to adequately support control process.Cause: The Department did not maintain documentation of direct supervisor review and approval of time and effort.Effect: The Department is not in compliance with applicable allowable activities/costs requirements.Recommendation: We recommend that the Department implement policies and procedures to ensure that sufficient documentation of reviews and approvals are maintained.Prior Year Single Audit Finding Number: Not applicableViews of Responsible Offices and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 161.

Corrective Action Plan

U.S. Department of Health and Human ServicesRE: Corrective Action Plan for Year Ended June 30, 2019The South Carolina Department of Alcohol and Other Drug Abuse Services respectfully submits the following corrective action plan for the year ended June 30, 2019.The schedule of findings and questioned costs are discussed below. The findings are numbered in accordance with the numbers assigned in the schedule.2019-018. Prevention and Treatment of Substance Abuse - CFDA No.: 93.959Recommendation: We recommend that the Department implement policies and procedures to ensure that sufficient documentation of reviews and approvals is maintained.Explanation of disagreement with audit finding: NIAAction taken in response to finding: Effective January 2020, the agency automated the time-and-effort process. Upon the completion of a DAODAS Time Sheet, employees convert the sheet to a PDFcontaining their electronic signature, which is due to their managers by the fifth of each month. The time sheets must be approved by the manager with an electronic signature and placed in a shared folder by the 10th of each month. The Human Resource Manager is responsible for sending notifications/reminders to employees on or after the 10th if any timesheets are missing.Name(s) of the contact person(s) responsible for corrective action: Sharon PetersonPlanned completion date for corrective action plan: The new process was implemented with the submission of January 2020 time-and-effort information.If there are any questions regarding this corrective action plan, please contact me at 803-896-1145 .

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2019-019
Cash Management
SIGNIFICANT DEFICIENCYREPEAT OF 2018-036OTHER MATTERS

For the full fiscal year, the Department did not have an internal control process in place to ensure that reimbursement requests sent to the federal cognizant agency were fully supported by expenditures previously paid out by the state.Questioned Costs: NoneContext: The Department was deemed to be in compliance with these provisions for the fiscal year; however, standardized internal control processes did not exist before February 11, 2019 to ensure that reimbursement was for expenditures already incurred and paid prior to receipt of federal funds. This was noted for twenty-five of the sixty reimbursement requests tested, all of which occurred prior to the implementation of the new policies and procedures.Cause: The Department implemented a new process on February 11, 2019. Policies and procedures prior to this date were ineffective to ensure that documentation was maintained to support that each reimbursement request was adequately supported and reviewed prior to request for funds.Effect: The Department may draw funds in excess of the allowable expenses.Recommendation: We recommend that the Department continue to follow the newly implemented policies and procedures.Prior Year Single Audit Report Finding Number: 2018-036Views of Responsible Offices and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 163.

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Cash ManagementFederal Agency: VariousFederal Program Title: Research and Development ClusterCFDA No.: VariousFederal Grant ID Number: VariousPass-Through Entity: VariousAward Period: VariousType of Finding: Significant deficiency in internal control over compliance, other mattersCriteria: Per 31 CFR ? 205.12(c)(5) Reimbursable funding means that a Federal Program Agency transfers Federal funds to a State after that State has already paid out the funds for Federal assistance program purposes.Condition: For the full fiscal year, the Department did not have an internal control process in place to ensure that reimbursement requests sent to the federal cognizant agency were fully supported by expenditures previously paid out by the state.Questioned Costs: NoneContext: The Department was deemed to be in compliance with these provisions for the fiscal year; however, standardized internal control processes did not exist before February 11, 2019 to ensure that reimbursement was for expenditures already incurred and paid prior to receipt of federal funds. This was noted for twenty-five of the sixty reimbursement requests tested, all of which occurred prior to the implementation of the new policies and procedures.Cause: The Department implemented a new process on February 11, 2019. Policies and procedures prior to this date were ineffective to ensure that documentation was maintained to support that each reimbursement request was adequately supported and reviewed prior to request for funds.Effect: The Department may draw funds in excess of the allowable expenses.Recommendation: We recommend that the Department continue to follow the newly implemented policies and procedures.Prior Year Single Audit Report Finding Number: 2018-036Views of Responsible Offices and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 163.

Corrective Action Plan

U.S. Department of InteriorSouth Carolina Department of Natural Resources respectfuly submits the following corrective action plan for the year ended 6/30/19.The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule.FINDINGS?FEDERAL AWARD PROGRAM AUDITFederal Agency: Various2019-019 Research and Development ClusterRecommendation: We recommend that the Department continue to follow the newly implemented policies and procedures.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding: Policies and procedures were implemented February 11, 2019 to ensure the proper and consistent documentation in our grants files throughout the Department to include the drawdown of funds. The Department will continue to follow these policies and procedures.Name(s) of the contact person(s) responsible for corrective action: Caleb-Scott CohoonPlanned completion date for corrective action plan: February 11, 2019If the U.S. Department of Interior Services has questions regarding this plan, please call Caleb- Scott Cohoon at 803-734-1518.

Prior Finding References

2018-036

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2019-020
Reporting
SIGNIFICANT DEFICIENCYREPEAT OF 2018-037

The Department submitted a Schedule of Expenditures of Federal Awards (SEFA) that contained incorrect information for certain awards.Questioned Costs: NoneContext: For one of the two hundred eighteen federal awards within the Department's Research and Development Cluster there was incorrect information noted on the submitted SEFA.Cause: The Department's internal controls failed to identify errors on the SEFA that was submitted.Effect: The Department may report incorrect information on the SEFA.Recommendation: We recommend that the Department strengthen internal controls regarding the preparation and review of their SEFA to ensure such errors are identified and corrected prior to submission.Prior Year Single Audit Report Finding Number: 2018-037Views of Responsible Offices and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 164.

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ReportingFederal Agency: VariousFederal Program Title: Research and Development ClusterCFDA No.: VariousFederal Grant ID Number: VariousPass-Through Entity: VariousAward Period: VariousType of Finding: Significant deficiency in internal control over complianceCriteria: Per 2 CFR ? 200.303 Internal controls, 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 and the ``Internal Control Integrated Framework??, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).Condition: The Department submitted a Schedule of Expenditures of Federal Awards (SEFA) that contained incorrect information for certain awards.Questioned Costs: NoneContext: For one of the two hundred eighteen federal awards within the Department's Research and Development Cluster there was incorrect information noted on the submitted SEFA.Cause: The Department's internal controls failed to identify errors on the SEFA that was submitted.Effect: The Department may report incorrect information on the SEFA.Recommendation: We recommend that the Department strengthen internal controls regarding the preparation and review of their SEFA to ensure such errors are identified and corrected prior to submission.Prior Year Single Audit Report Finding Number: 2018-037Views of Responsible Offices and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 164.

Corrective Action Plan

U.S. Department of InteriorSouth Carolina Department of Natural Resources respectfuly submits the following corrective action plan for the year ended 6/30/19.The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule.FINDINGS?FEDERAL AWARD PROGRAM AUDITFederal Agency: Various2019-020 Research and Development ClusterRecommendation: We recommend that the Department strengten internal controls regarding the preparation and review of their SEFA to ensure such errors are identified and corrected prior to submission.Explanation of disagreement with audit finding: There is no disagreement with audit findings.Action taken in response to finding: Policies and procedures were implemented March 1, 2019 to ensure that the SEFA is completed correctly and reviewed in order to identify and correct errors prior to submission. The Department will work to better document the review process of the SEFA per those procedures.Name(s) of the contact person(s) responsible for corrective action: Caleb-Scott CohoonPlanned completion date for corrective action plan: March 1, 2019If the U.S. Department of Interior Services has questions regarding this plan, please call Caleb- Scott Cohoon at 803-734-1518.

Prior Finding References

2018-037

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2019-021
Period of Performance
SIGNIFICANT DEFICIENCYREPEAT OF 2018-033OTHER MATTERS

The Department charged the federal award for services performed prior to the related award's period of performance.Questioned Costs: UnknownContext: For one of the twenty-five transactions tested with period of performance beginning dates during the fiscal year, it was noted that the cost charged to the award was for services performed prior to the period of performance.Cause: The Department did not timely process the expenditure, resulting in the expenditure incorrectly being charged to the subsequent year grant.Effect: The Department may request reimbursement for expenses not incurred within the period of performance.Recommendation: We recommend that the Department strengthen internal controls to ensure all expenditures charged to a grant are incurred during the award's period of performance.Prior Year Single Audit Finding Number: 2018-033Views of Responsible Offices and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 165.

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Period of PerformanceFederal Agency: VariousFederal Program Title: Research and Development ClusterCFDA No.: VariousFederal Grant ID Number: VariousPass-Through Entity: VariousAward Period: VariousType of Finding: Significant deficiency in internal control over compliance, other mattersCriteria: Per 2 CFR ? 200.309 Period of Performance, a non-Federal entity may charge to the Federal award only allowable costs incurred during the period of performance (except as described in ?200.461 Publication and printing costs) and any costs incurred before the Federal awarding agency or pass-through entity made the Federal award that were authorized by the Federal awarding agency or pass-through entity.Condition: The Department charged the federal award for services performed prior to the related award's period of performance.Questioned Costs: UnknownContext: For one of the twenty-five transactions tested with period of performance beginning dates during the fiscal year, it was noted that the cost charged to the award was for services performed prior to the period of performance.Cause: The Department did not timely process the expenditure, resulting in the expenditure incorrectly being charged to the subsequent year grant.Effect: The Department may request reimbursement for expenses not incurred within the period of performance.Recommendation: We recommend that the Department strengthen internal controls to ensure all expenditures charged to a grant are incurred during the award's period of performance.Prior Year Single Audit Finding Number: 2018-033Views of Responsible Offices and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 165.

Corrective Action Plan

U.S. Department of Health and Human ServicesSouth Carolina Department of Health and Environmental Control respectfully submits the following corrective action plan for the year ended 6/30/19.The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule.FINDINGS-FEDERAL AWARD PROGRAM AUDITVarious2019-021 Research and Development ClusterRecommendation: We recommend that the Department strengthen internal controls to ensure all expenditures charged to a grant are incurred during the award's period of performance.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding: The Department discussed the finding with staff and will continue to strengthen its internal controls to ensure that all expenditures are allocated to the correct grant based on its validity date.Name(s) of the contact person(s) responsible for corrective action: Sandra CraigPlanned completion date for corrective action plan: Finding already addressedIf the U.S. Department of Health and Human Services has questions regarding this plan, please call Kim Paradeses at 803-898-3390.

Prior Finding References

2018-033

About Period of Performance →
2019-022
Subrecipient Monitoring
MATERIAL WEAKNESSMODIFIED OPINION

The Department did not clearly communicate all of the required information to subrecipients.Questioned Costs: NoneContext: For three of the six subrecipients tested, the subrecipient agreement did not include all of the required information.Cause: The Department does not have the necessary policies and procedures in place regarding subrecipient agreements to facilitate compliance with federal requirements.Effect: The Department is not in compliance with the Federal subrecipient monitoring requirements.Recommendation: We recommend that the Department implement policies and procedures to facilitate compliance with federal subrecipient monitoring requirements.Prior Year Single Audit Finding Number: Not applicableViews of Responsible Offices and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 166.

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Subrecipient MonitoringFederal Agency: Department of Health and Human ServicesFederal Program Title: HIV Care Formula Grants (Ryan White HIV/AIDS Program Part B)CFDA No.: 93.917Federal Grant ID Number: X08HA32379-01-00; X07HA00038-28-02; X07HA00038-29-00Pass-Through Entity: Not applicableAward Period: VariousType of Finding: Material weakness in internal control over compliance, material noncomplianceCriteria: Per 2 CFR ? 200.331 all pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes all of the required information at the time of the subaward (b) Evaluate each subrecipient?s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraph (e) of this section, (c) Consider imposing specific subaward conditions upon a subrecipient if appropriate as described in ? 200.207 Specific conditions. (d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. (f) Verify that every subrecipient is audited as required by Subpart F? Audit Requirements of this part when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ? 200.501 Audit requirements. (g) Consider whether the results of the subrecipient?s audits, on-site reviews, or other monitoring indicate conditions that necessitate adjustments to the pass-through entity?s own records. (h) Consider taking enforcement action against noncompliant subrecipients as described in ? 200.338 Remedies for noncompliance of this part and in program regulations.Condition: The Department did not clearly communicate all of the required information to subrecipients.Questioned Costs: NoneContext: For three of the six subrecipients tested, the subrecipient agreement did not include all of the required information.Cause: The Department does not have the necessary policies and procedures in place regarding subrecipient agreements to facilitate compliance with federal requirements.Effect: The Department is not in compliance with the Federal subrecipient monitoring requirements.Recommendation: We recommend that the Department implement policies and procedures to facilitate compliance with federal subrecipient monitoring requirements.Prior Year Single Audit Finding Number: Not applicableViews of Responsible Offices and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 166.

Corrective Action Plan

U.S. Department of Health and Human ServicesSouth Carolina Department of Health and Environmental Control respectfully submits the following corrective action plan for the year ended 6/30/19.The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule.FINDINGS-FEDERAL AWARD PROGRAM AUDIT2019-022 HIV Care Formula Grants {Ryan White HIV/AIDS Program Part B) CFDA No.: 93 .917Recommendation: We recommend that the Department implement policies and procedures to facilitate compliance with federal subrecipient monitoring requirements.Explanation of disagreement with audit finding: There is no disagreement with audit findings.Action taken in response to finding: The Department is identifying all active subrecipient agreements still using outdated templates and issuing amendments to notify the subrecipients of both the FAIN and Duns#.Name(s) of the contact person(s) responsible for corrective action: Larry MaddoxPlanned completion date for corrective action plan: The Department has already updated the subrecipient award template to include all information required by 2.CFR.200, which is used for all new awards. We are currently working towards issuing amendments to provide the information missing from the old templates.If the U.S. Department of Health and Human Services has questions regarding this plan, please call Kim Paradeses at 803-898-3390.

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2019-023
Subrecipient Monitoring
SIGNIFICANT DEFICIENCYREPEAT OF 2018-038OTHER MATTERS

The Consortium does not have adequate policies and procedures in place regarding subrecipient monitoring to facilitate compliance with federal requirements.Questioned Costs: UnknownContext: For two of the six subrecipients selected for testing, monitoring procedures were not completed to satisfy the federal requirements.Cause: The Consortium has implemented policies and procedures for subrecipient monitoring, however, it was noted that these policies and procedures do not address all federal requirements.Effect: The Consortium is not in compliance with the Federal subrecipient monitoring requirements.Recommendation: We recommend that the Consortium continue to evaluate their current subrecipient monitoring policies and procedures and make revisions to ensure compliance with federal requirements.Prior Year Single Audit Report Finding Number: 2018-038Views of Responsible Offices and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 167.

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Subrecipient MonitoringFederal Agency: VariousFederal Program Title: Research and Development ClusterCFDA No.: VariousFederal Grant ID Number: VariousPass-Through Entity: VariousAward Period: VariousType of Finding: Significant deficiency in internal control over compliance, other mattersCriteria: Per 2 CFR ? 200.331 all pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes all of the required information at the time of the subaward (b) Evaluate each subrecipient?s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraph (e) of this section, (c) Consider imposing specific subaward conditions upon a subrecipient if appropriate as described in ? 200.207 Specific conditions. (d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. (f) Verify that every subrecipient is audited as required by Subpart F? Audit Requirements of this part when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ? 200.501 Audit requirements. (g) Consider whether the results of the subrecipient?s audits, on-site reviews, or other monitoring indicate conditions that necessitate adjustments to the pass-through entity?s own records. (h) Consider taking enforcement action againstnoncompliant subrecipients as described in ? 200.338 Remedies for noncompliance of this part and in program regulations.Condition: The Consortium does not have adequate policies and procedures in place regarding subrecipient monitoring to facilitate compliance with federal requirements.Questioned Costs: UnknownContext: For two of the six subrecipients selected for testing, monitoring procedures were not completed to satisfy the federal requirements.Cause: The Consortium has implemented policies and procedures for subrecipient monitoring, however, it was noted that these policies and procedures do not address all federal requirements.Effect: The Consortium is not in compliance with the Federal subrecipient monitoring requirements.Recommendation: We recommend that the Consortium continue to evaluate their current subrecipient monitoring policies and procedures and make revisions to ensure compliance with federal requirements.Prior Year Single Audit Report Finding Number: 2018-038Views of Responsible Offices and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 167.

Corrective Action Plan

U.S. Department of Commerce1401 Constitution Avenue NWWashington, D.C. 20230South Carolina Sea Grant Consortium respectfully submits the following corrective action plan for the year ended June 30, 2019.Audit period: July 1, 2018 through June 30, 2019The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule.FINDINGS?FEDERAL AWARD PROGRAM AUDITU.S. Department of Commerce2019-023 Research and Development ClusterRecommendation: We recommend that the Consortium continue to evaluate their current subrecipient monitoring policies and procedures and make revisions to ensure compliance with federal requirements.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding: Per this finding, the Consortium will continue to evaluate and amend its current subrecipient monitoring policies and procedures first implemented in July 2017 and revised in February 2018 and June 2019. Since the inception of the current corrective action plan, the Consortium has implemented new requirements for all subrecipients in regards to reimbursement requests and financial reporting as well as establish risk assessment and external audit processes for select entities that received subaward funds during the previous fiscal year. These actions have yielded very positive results and significant progress has been made since the original single audit finding in fiscal year 2015-16.Per discussions with audit staff from January 2020, the Consortium has already revised our internal agreement package (as of February 2020) to include federally mandated information required from all subreceipient awardees. In addition, Consortium Administration will expandupon its current risk aversion processes and procedures to include all subreceipients receiving funds from the previous fiscal year (previously only Consortium member institutions were included in agency assessments).Name(s) of the contact person(s) responsible for corrective action: Ryan C. Bradley, Assistant Director for AdministrationPlanned completion date for corrective action plan: Implemented July 1, 2017 // Amended February 1, 2020If the Department of Commerce has questions regarding this plan, please contact Ryan Bradley at ryan.bradley@scseagrant.org (843) 953-2078.

Prior Finding References

2018-038

About Subrecipient Monitoring →
2019-024
Matching, Level of Effort, Earmarking
SIGNIFICANT DEFICIENCYOTHER MATTERS

The Department's federal fiscal year 2018 MOE certification was not calculated correctly prior to submission to the federal oversight agency.Questioned Costs: NoneContext: For the period under audit the MOE was not calculated correctly.Cause: Internal controls failed to detect the calculation error prior to the certification submission.Effect: The Department submitted an inaccurate calculation of maintenance of effort on their certification.Recommendation: We recommend that the Department strengthen internal controls to ensure maintenance of effort certifications are calculated correctly prior to submission.Prior Year Single Audit Report Finding Number: Not applicableViews of Responsible Offices and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 169.

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Matching, Level of Effort, Earmarking - Maintenance of EffortFederal Agency: Department of Health and Human ServicesFederal Program Title: Aging ClusterCFDA No.: 93.044, 93.045, 93.053Federal Grant ID Number: VariousPass-Through Entity: Not applicableAward Period: VariousType of Finding: Significant deficiency in internal control over compliance, other mattersCriteria: Per 45 CFR ? 1321.49 - State agency maintenance of effort. In order to avoid a penalty, each fiscal year the State agency, to meet the required non-federal share applicable to its allotments under this part, shall spend under the State plan for bothservices and administration at least the average amount of State funds it spent under the plan for the three previous fiscal years. If the State agency spends less than this amount, the Commissioner reduces the State's allotments for supportive and nutrition services under this part by a percentage equal to the percentage by which the State reduced its expenditures.Condition: The Department's federal fiscal year 2018 MOE certification was not calculated correctly prior to submission to the federal oversight agency.Questioned Costs: NoneContext: For the period under audit the MOE was not calculated correctly.Cause: Internal controls failed to detect the calculation error prior to the certification submission.Effect: The Department submitted an inaccurate calculation of maintenance of effort on their certification.Recommendation: We recommend that the Department strengthen internal controls to ensure maintenance of effort certifications are calculated correctly prior to submission.Prior Year Single Audit Report Finding Number: Not applicableViews of Responsible Offices and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 169.

Corrective Action Plan

U.S. Department of Health and Human ServicesSouth Carolina Department on Aging respectfully submits the following corrective action plan for the year ended 6/30/19.The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule.FINDINGS?FEDERAL AWARD PROGRAMS AUDITU.S Department of Health and Human Services2019-024 Title III part B, Title III part C, Nutrition Services Incentive Program? CFDA No. 93.044, 93.045, 93.053Recommendation: We recommend that the Department strengthen internal controls to ensure maintenance of effort certifications are calculated correctly prior to submission.Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding:Additional training is being obtained from ACL, the federal funding source, on reportingrequirements and calculations. The agency has recalculated, reviewed and filed the corrected FY 2018 Certification for the Maintenance of Effort report.Name(s) of the contact person(s) responsible for corrective action: Lisa Crosby, Rhonda WalkerPlanned completion date for corrective action plan: June 30, 2020If the U.S. Department of Health and Human Services has questions regarding this plan, please call Connie Munn at (803) 734-9910.

About Matching, Level of Effort, Earmarking →
2019-025
Subrecipient Monitoring
MATERIAL WEAKNESSMODIFIED OPINION

The Department does not have the necessary policies and procedures in place regarding subrecipient monitoring to facilitate compliance with federal requirements.Questioned Costs: UnknownContext: For five of five subrecipients selected for testing, monitoring procedures were not completed to satisfy the federal requirements.Cause: The Department has implemented policies and procedures for subrecipient monitoring, however, it was noted that these policies and procedures do not address all federal requirements.Effect: The Department is not in compliance with the Federal subrecipient monitoring requirements.Recommendation: We recommend that the Department implement policies and procedures to facilitate compliance with federal subrecipient monitoring requirements.Prior Year Single Audit Report Finding Number: Not applicableViews of Responsible Offices and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 170.

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Subrecipient MonitoringFederal Agency: Department of Health and Human ServicesFederal Program Title: Aging ClusterCFDA No.: 93.044, 93.045, 93.053Federal Grant ID Number: VariousPass-Through Entity: Not applicableAward Period: VariousType of Finding: Material weakness in internal control over compliance, material noncomplianceCriteria: Per 45 CFR ?75.352(a) All pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes all of the information required by 45 CFR 75.352 (a)(1)(i-xiii) at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward. (b) Evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section. (c) Consider imposing specific subaward conditions upon a sub-\recipient if appropriate as described in ? 75.207 (d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. (e) Depending upon the pass-through entity's assessment of risk posed by the subrecipient (as described in paragraph (b) of this section), the following monitoring tools may be useful for the pass-through entity to ensure proper accountability and compliance with program requirements and achievement of performance goals. (f) Verify that every subrecipient is audited as required by subpart F of this part when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ? 75.501. (g) Consider whether the results of the subrecipient's audits, on-site reviews, or other monitoring indicate conditions that necessitate adjustments to the pass-through entity's own records. (h) Consider taking enforcement action against noncompliant subrecipients as described in ? 75.371 and in program regulations.Condition: The Department does not have the necessary policies and procedures in place regarding subrecipient monitoring to facilitate compliance with federal requirements.Questioned Costs: UnknownContext: For five of five subrecipients selected for testing, monitoring procedures were not completed to satisfy the federal requirements.Cause: The Department has implemented policies and procedures for subrecipient monitoring, however, it was noted that these policies and procedures do not address all federal requirements.Effect: The Department is not in compliance with the Federal subrecipient monitoring requirements.Recommendation: We recommend that the Department implement policies and procedures to facilitate compliance with federal subrecipient monitoring requirements.Prior Year Single Audit Report Finding Number: Not applicableViews of Responsible Offices and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 170.

Corrective Action Plan

U.S. Department of Health and Human ServicesSouth Carolina Department on Aging respectfully submits the following corrective action plan for the year ended 6/30/19.The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule.FINDINGS?FEDERAL AWARD PROGRAMS AUDITU.S Department of Health and Human Services2019-025 Title III part B, Title III part C, Nutrition Services Incentive Program? CFDA No. 93.044, 93.045, 93.053Recommendation: We recommend that the Department implement policies and procedures to facilitate compliance with federal subrecipient monitoring requirements.Explanation of disagreement with audit finding: There is no disagreement with audit findings.Action taken in response to finding: SCDOA implemented agency wide fiscal and programmatic monitoring during FY 2019 that was not completed by year end. The agency will be in compliance when fully implemented. In addition, SCDOA will hire an additional staff member in the finance department who whose primary job will be to monitor subrecipients of the grants.Name(s) of the contact person(s) responsible for corrective action: Rhonda Walker Planned completion date for corrective action plan: June 30, 2020If the U.S. Department of Health and Human Services has questions regarding this plan, please call Connie Munn at (803) 734-9910.

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2019-026
Activities Allowed or Unallowed / Cost Allowability
MATERIAL WEAKNESSMODIFIED OPINION

Evidence of the Personnel/Budget Action Request in effect as of the time wages were earned were not maintained or were inconsistent with the amounts charged to the award.Questioned Costs: UnknownContext: For nine of sixty payroll transactions tested, adequate documentation was not received to support the controls in place over allowable costs and cost principles in accordance with federal regulations.Cause: The Department does not have policies and procedures in place to ensure payroll is charged in accordance with federal requirements.Effect: The Department is not in compliance with applicable allowable activities/costs requirements.Recommendation: We recommend that the Department strengthen their internal controls over payroll to ensure compliance with federal requirementsPrior Year Single Audit Report Finding Number: Not applicableViews of Responsible Offices and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 170.

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Activities Allowed or Unallowed and Allowable Costs/ Cost PrinciplesFederal Agency: Department of Health and Human ServicesFederal Program Title: Aging ClusterCFDA No.: 93.044, 93.045, 93.053Federal Grant ID Number: VariousPass-Through Entity: Not applicableAward Period: VariousType of Finding: Material weakness in internal control over compliance, material noncomplianceCriteria: Per 45 ? 75.430 (a) General. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities; (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, when applicable.Condition: Evidence of the Personnel/Budget Action Request in effect as of the time wages were earned were not maintained or were inconsistent with the amounts charged to the award.Questioned Costs: UnknownContext: For nine of sixty payroll transactions tested, adequate documentation was not received to support the controls in place over allowable costs and cost principles in accordance with federal regulations.Cause: The Department does not have policies and procedures in place to ensure payroll is charged in accordance with federal requirements.Effect: The Department is not in compliance with applicable allowable activities/costs requirements.Recommendation: We recommend that the Department strengthen their internal controls over payroll to ensure compliance with federal requirementsPrior Year Single Audit Report Finding Number: Not applicableViews of Responsible Offices and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 170.

Corrective Action Plan

U.S. Department of Health and Human ServicesSouth Carolina Department on Aging respectfully submits the following corrective action plan for the year ended 6/30/19.The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule.FINDINGS?FEDERAL AWARD PROGRAMS AUDITU.S Department of Health and Human Services2019-026 Title III part B, Title III part C, Nutrition Services Incentive Program? CFDA No. 93.044, 93.045, 93.053Recommendation: We recommend that the Department strengthen their internal controls over payroll to ensure compliance with federal requirementsExplanation of disagreement with audit finding: There is no disagreement with audit findings.Action taken in response to finding: This issue had been previously identified after FY 2019 year end and policies were revised. The agency is reconciling payroll information on a more frequent basis and continues to train staff to ensure that the procedures are followed.Name(s) of the contact person(s) responsible for corrective action: Rhonda Walker Planned completion date for corrective action plan: March 30, 2020If the U.S. Department of Health and Human Services has questions regarding this plan, please call Connie Munn at (803) 734-9910.

About Activities Allowed or Unallowed, Allowable Costs / Cost Principles →
2019-027
Matching, Level of Effort, Earmarking
SIGNIFICANT DEFICIENCYOTHER MATTERS

The Department did not adequately track administrative costs charged to the grant.Questioned Costs: UnknownContext: The grant that closed during the audit period was tested for the earmarking requirement. The amount charged to the grant for State Plan administration exceeded the earmarking requirement.Cause: The Department does not have policies and procedures in place to ensure that the earmarking requirements are met.Effect: The Department is not in compliance with the federal earmarking requirements.Recommendation: We recommend that the Department implement internal controls for tracking administrative costs charged to the grant to ensure that the federal requirements are being met.Prior Year Single Audit Report Finding Number: Not applicableViews of Responsible Offices and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 171.

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Matching, Level of Effort, EarmarkingFederal Agency: Department of Health and Human ServicesFederal Program Title: Aging ClusterCFDA No.: 93.044, 93.045, 93.053Federal Grant ID Number: VariousPass-Through Entity: Not applicableAward Period: VariousType of Finding: Significant deficiency in internal control over compliance, other mattersCriteria: Overall expenditures for administration are limited to the greater of five percent (or $300,000 or $500,000 depending on the aggregate amount appropriated or a lesser amount for the U.S. Territories) of the overall allotment to a State under Title III unless a waiver is granted by the Assistant Secretary for Aging (42 USC 3028 (b)(1), (2), and (3)).Condition: The Department did not adequately track administrative costs charged to the grant.Questioned Costs: UnknownContext: The grant that closed during the audit period was tested for the earmarking requirement. The amount charged to the grant for State Plan administration exceeded the earmarking requirement.Cause: The Department does not have policies and procedures in place to ensure that the earmarking requirements are met.Effect: The Department is not in compliance with the federal earmarking requirements.Recommendation: We recommend that the Department implement internal controls for tracking administrative costs charged to the grant to ensure that the federal requirements are being met.Prior Year Single Audit Report Finding Number: Not applicableViews of Responsible Offices and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 171.

Corrective Action Plan

U.S. Department of Health and Human ServicesSouth Carolina Department on Aging respectfully submits the following corrective action plan for the year ended 6/30/19.The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule.FINDINGS?FEDERAL AWARD PROGRAMS AUDIT2019-027 Title III part B, Title III part C, Nutrition Services Incentive Program? CFDA No. 93.044, 93.045, 93.053Recommendation: We recommend that the Department implement internal controls for tracking administrative costs charged to the grant to ensure that the federal requirements are being met.Explanation of disagreement with audit finding: There is no disagreement with audit findings.Action taken in response to finding: Additional review measures are now in place to prevent excess budget from being loaded into the state accounting system and having Earmarked funds overspent. In addition, quarterly reviews of all grants are being performed to ensure all grants are within budget for each identified area.Name(s) of the contact person(s) responsible for corrective action: Rhonda Walker Planned completion date for corrective action plan: February 28, 2020.If the U.S. Department of Health and Human Services has questions regarding this plan, please call Connie Munn at (803) 734-9910.

About Matching, Level of Effort, Earmarking →
2019-028
Reporting
SIGNIFICANT DEFICIENCYREPEAT OF 2018-046OTHER MATTERS

Key data elements reported on the Commission's RSA-911 performance reports did not agree with underlying case service documentation.Questioned Costs: NoneContext: For one of two RSA-911 performance reports tested, key data reported was contradictory to the supporting documentation.Cause: This finding was noted in the prior year and the Commission developed a corrective action plan. However, due to the timing of the implementation of the plan during part of the year the Commission did not have sufficient internal controls and policies/procedures in place to ensure that all key data reported was in agreement with the underlying documentation.Effect: The Commission may report incorrect information to the Rehabilitation Services Administration.Recommendation: We recommend that the Commission continue to fully implement their corrective action plan prepared in response to the prior year Single Audit finding.Prior Year Single Audit Finding Number: 2018-046Views of Responsible Offices and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 172.

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ReportingFederal Agency: Department of EducationFederal Program Title: Rehabilitation Services-Vocational Rehabilitation Grants to StatesCFDA No.: 84.126Federal Grant ID Number: H126A170061; H126A180061; H126A190061Pass-Through Entity: Not applicableAward Period: October 1, 2016 through September 30, 2020Type of Finding: Significant Deficiency in internal control over compliance, other mattersCriteria: The requirements in 34 CFR ?361.47 and 34 CFR ?361.56, taken together, require State Vocational Rehabilitation agencies to maintain verifying documentation in an individual?s case file, particularly regarding eligibility determinations, development of the individualized plan for employment, services provided, and case closure. Much of this information are key data elements required to be reported on the Case Service Report (RSA-911) to the Rehabilitation Services Administration (RSA).Condition: Key data elements reported on the Commission's RSA-911 performance reports did not agree with underlying case service documentation.Questioned Costs: NoneContext: For one of two RSA-911 performance reports tested, key data reported was contradictory to the supporting documentation.Cause: This finding was noted in the prior year and the Commission developed a corrective action plan. However, due to the timing of the implementation of the plan during part of the year the Commission did not have sufficient internal controls and policies/procedures in place to ensure that all key data reported was in agreement with the underlying documentation.Effect: The Commission may report incorrect information to the Rehabilitation Services Administration.Recommendation: We recommend that the Commission continue to fully implement their corrective action plan prepared in response to the prior year Single Audit finding.Prior Year Single Audit Finding Number: 2018-046Views of Responsible Offices and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 172.

Corrective Action Plan

U.S. Department of EducationSouth Carolina Commission for the Blind respectfully submits the following corrective action plan for the year ended 6/30/19.The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule.FINDINGS?FEDERAL AWARD PROGRAM AUDITSouth Carolina Commission for the Blind (L24)2019-028. Rehabilitation Services-Vocational Rehabilitation Grants to States ? CFDA No. 84.126Recommendation: We recommend that the Commission continue to fully implement their corrective action plan prepared in response to the prior year Single Audit finding.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding: Statewide caseload reviews will continue to be conducted on a quarterly basis in order to validate data accuracy in reporting prior to the submission of the RSA-911 Case Service Reports.Name(s) of the contact person(s) responsible for corrective action: Shana RobinsonPlanned completion date for corrective action plan: CompletedIf the U.S. Department of Education has questions regarding this plan, please call Matthew Daugherty at 803-898-8835.

Prior Finding References

2018-046

About Reporting →
2019-029
Reporting
SIGNIFICANT DEFICIENCYOTHER MATTERS

Data submitted in the RSA-2 Annual Vocational Rehabilitation Program/Cost Report and SF-425 Federal were not submitted in a timely manner.Questioned Costs: NoneContext: For the one RSA-2 financial report and one SF-425 report tested, it was noted the report submissions were made after the federal due date. While testing the reports, non-material variances were noted between the report and supporting documentation.Cause: The Commission did not have sufficient internal controls and policies/procedures in place to ensure that reports were filed timely. In addition underlying documentation for the SF-425 report included minor inaccuracies.Effect: The Commission may report incorrect information to the Rehabilitation Services Administration and may not submit reports prior to the prescribed due date.Recommendation: We recommend that the Commission implement policies and procedures necessary to ensure that reports include accurate data and are submitted in a timely manner.Prior Year Single Audit Finding Number: Not applicableViews of Responsible Offices and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 172.

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ReportingFederal Agency: Department of EducationFederal Program Title: Rehabilitation Services-Vocational Rehabilitation Grants to StatesCFDA No.: 84.126Federal Grant ID Number: H126A170061; H126A180061; H126A190061Pass-Through Entity: Not applicableAward Period: October 1, 2016 through September 30, 2020Type of Finding: Significant Deficiency in internal control over compliance, other mattersCriteria: Per 34 CFR ?361.40 (a) Reports. (1) The vocational rehabilitation services portion of the Unified or Combined State Plan must assure that the designated State agency will submit reports, including reports required under sections 13, 14, and 101(a)(10) of the Act - (i) In the form and level of detail and at the time required by the Secretary regarding applicants for and eligible individuals receiving services, including students receiving pre-employment transition services in accordance with ? 361.48(a); and (ii) In a manner that provides a complete count (other than the information obtained through sampling consistent with section 101(a)(10)(E) of the Act) of the applicants and eligible individuals to - (A) Permit the greatest possible cross-classification of data; and (B) Protect the confidentiality of the identity of each individual. (2) The designated State agency must comply with any requirements necessary to ensure the accuracy and verification of those reports.Condition: Data submitted in the RSA-2 Annual Vocational Rehabilitation Program/Cost Report and SF-425 Federal were not submitted in a timely manner.Questioned Costs: NoneContext: For the one RSA-2 financial report and one SF-425 report tested, it was noted the report submissions were made after the federal due date. While testing the reports, non-material variances were noted between the report and supporting documentation.Cause: The Commission did not have sufficient internal controls and policies/procedures in place to ensure that reports were filed timely. In addition underlying documentation for the SF-425 report included minor inaccuracies.Effect: The Commission may report incorrect information to the Rehabilitation Services Administration and may not submit reports prior to the prescribed due date.Recommendation: We recommend that the Commission implement policies and procedures necessary to ensure that reports include accurate data and are submitted in a timely manner.Prior Year Single Audit Finding Number: Not applicableViews of Responsible Offices and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 172.

Corrective Action Plan

U.S. Department of EducationSouth Carolina Commission for the Blind respectfully submits the following corrective action plan for the year ended 6/30/19.The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule.FINDINGS?FEDERAL AWARD PROGRAM AUDITSouth Carolina Commission for the Blind (L24)2019-029 Rehabilitation Services - Vocational Rehabilitation Grants to States CFDA No.: 84.126Recommendation: We recommend that the Commission implement policies and procedures necessary to ensure that reports include accurate data and are submitted in a timely manner.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding: Key positions will continue to be filled and backup staff assigned, which will allow for the development and implementation of the policies and procedures necessary to ensure the accurate and timely completion and submission of the RSA-2 Annual Vocational Rehabilitation Program/Cost Report.Name(s) of the contact person(s) responsible for corrective action: Shana Robinson and Matt DaughertyPlanned completion date for corrective action plan: July 1, 2020If the U.S. Department of Education has questions regarding this plan, please call Matthew Daugherty at 803-898-8835.

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2019-030
Cash Management
SIGNIFICANT DEFICIENCYOTHER MATTERS

The Commission did not consider the effect of program expenditures that were refunded, resulting in reimbursements exceeding actual expenditures during the respective drawdown period. Per discussion with the Commission refunds are subtracted from the final reimbursement request for the respective grant period.Questioned Costs: UnknownContext: For the three drawdowns made in fiscal year 2019, it was noted that refunded expenditures were not netted against program expenditures to determine the proper reimbursement amount was requested.Cause: As refunds of program expenditures occur the Commission?s procedure is to record these refunds in a revenue account as opposed to an offset to expenditures. For reimbursement requests the Commission?s procedures only consider refunded program expenditures when calculating the final drawdown for the respective grant.Effect: The Commission may drawdown funds in excess of eligible reimbursable expenditures.Recommendation: We recommend that the Commission implement policies and procedures to ensure that refunded expenditure credits are netted against program expenditures prior to drawing down funds. Additionally, it is recommended that the Commission implement policies and procedures to ensure reimbursement requests are submitted timely.Prior Year Single Audit Finding Number: Not applicableViews of Responsible Offices and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 173.

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Cash ManagementFederal Agency: Department of EducationFederal Program Title: Rehabilitation Services-Vocational Rehabilitation Grants to StatesCFDA No.: 84.126Federal Grant ID Number: H126A170061; H126A180061; H126A190061Pass-Through Entity: Not applicableAward Period: October 1, 2016 through September 30, 2020Type of Finding: Significant Deficiency in internal control over compliance, other mattersCriteria: Per 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of monitoring and reporting program performance. The Commission should have internal controls designed to ensure compliance with those provisions.Condition: The Commission did not consider the effect of program expenditures that were refunded, resulting in reimbursements exceeding actual expenditures during the respective drawdown period. Per discussion with the Commission refunds are subtracted from the final reimbursement request for the respective grant period.Questioned Costs: UnknownContext: For the three drawdowns made in fiscal year 2019, it was noted that refunded expenditures were not netted against program expenditures to determine the proper reimbursement amount was requested.Cause: As refunds of program expenditures occur the Commission?s procedure is to record these refunds in a revenue account as opposed to an offset to expenditures. For reimbursement requests the Commission?s procedures only consider refunded program expenditures when calculating the final drawdown for the respective grant.Effect: The Commission may drawdown funds in excess of eligible reimbursable expenditures.Recommendation: We recommend that the Commission implement policies and procedures to ensure that refunded expenditure credits are netted against program expenditures prior to drawing down funds. Additionally, it is recommended that the Commission implement policies and procedures to ensure reimbursement requests are submitted timely.Prior Year Single Audit Finding Number: Not applicableViews of Responsible Offices and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 173.

Corrective Action Plan

U.S. Department of EducationSouth Carolina Commission for the Blind respectfully submits the following corrective action plan for the year ended 6/30/19.The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule.FINDINGS?FEDERAL AWARD PROGRAM AUDIT2019-030 Rehabilitation Services - Vocational Rehabilitation Grants to States CFDA No.: 84.126Recommendation: We recommend that the Commission implement policies and procedures to ensure that refunded expenditure credits are netted against program expenditures prior to drawing down funds.Additionally, it is recommended that the Commission implement policies and procedures to ensure reimbursement requests are submitted timely.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding: Key positions will continue to be filled and backup staff assigned, which will allow for the development and implementation of the policies and procedures necessary to ensure that refunded expenditure credits are netted against program expenditures prior to drawing down funds, and that reimbursement requests are submitted in a timely fashion.Name(s) of the contact person(s) responsible for corrective action: Matthew DaughertyPlanned completion date for corrective action plan: July 1, 2020If the U.S. Department of Education has questions regarding this plan, please call Matthew Daugherty at 803-898-8835.

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2019-031
Reporting
SIGNIFICANT DEFICIENCY

The Commission submitted a Schedule of Expenditures of Federal Awards (SEFA) that contained incorrect information for certain awards.Questioned Costs: NoneContext: For five of the thirty-eight federal awards reported on the Commission?s SEFA there was incorrect information submitted.Cause: The Commission's internal controls failed to identify errors on the SEFA that was submitted.Effect: The commission may report incorrect information on the SEFA.Recommendation: We recommend that the Commission strengthen internal controls regarding the preparation and review of their SEFA to ensure such errors are identified and corrected prior to submission.Prior Year Single Audit Finding Number: Not applicableViews of Responsible Offices and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 174.

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ReportingFederal Agency: Department of EducationFederal Program Title: Rehabilitation Services-Vocational Rehabilitation Grants to StatesCFDA No.: 84.126Federal Grant ID Number: H126A170061; H126A180061; H126A190061Pass-Through Entity: Not applicableAward Period: October 1, 2016 through September 30, 2020Type of Finding: Significant Deficiency in internal control over complianceCriteria: 2 CFR ? 200.303 Internal controls, 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 and the ``Internal Control Integrated Framework??, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).Condition: The Commission submitted a Schedule of Expenditures of Federal Awards (SEFA) that contained incorrect information for certain awards.Questioned Costs: NoneContext: For five of the thirty-eight federal awards reported on the Commission?s SEFA there was incorrect information submitted.Cause: The Commission's internal controls failed to identify errors on the SEFA that was submitted.Effect: The commission may report incorrect information on the SEFA.Recommendation: We recommend that the Commission strengthen internal controls regarding the preparation and review of their SEFA to ensure such errors are identified and corrected prior to submission.Prior Year Single Audit Finding Number: Not applicableViews of Responsible Offices and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 174.

Corrective Action Plan

U.S. Department of EducationSouth Carolina Commission for the Blind respectfully submits the following corrective action plan for the year ended 6/30/19.The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule.FINDINGS?FEDERAL AWARD PROGRAM AUDIT2019-031 Rehabilitation Services - Vocational Rehabilitation Grants to States CFDA No.: 84.126Recommendation: We recommend that the Commission strengthen internal controls regarding the preparation and review of their SEFA to ensure such errors are identified and corrected prior to submission.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding: Key positions will continue to be filled and backup staff assigned, which will allow for the development and implementation of the policies and procedures necessary to ensure the identification and correction of errors prior to the submission of the SEFA.Name(s) of the contact person(s) responsible for corrective action: Matthew DaughertyPlanned completion date for corrective action plan: July 1, 2020If the U.S. Department of Education has questions regarding this plan, please call Matthew Daugherty at 803-898-8835.

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2019-032
Activities Allowed or Unallowed / Cost Allowability
MATERIAL WEAKNESSMODIFIED OPINION

The Commission did not have adequate internal controls and policies/procedures in place to substantiate indirect costs charged to federal awards.Questioned Costs: UnknownContext: For the indirect costs charged to the federal awards, the Commission was not able to substantiate their validity in order to satisfy the testing objectives.Cause: The Commission did not adequately track and is unable to substantiate the calculations for indirect costs charged to federal awards.Effect: The Commission may report inaccurate indirect costs to federal awards.Recommendation: We recommend that the Commission implement internal controls and policies/procedures to substantiate indirect costs charged to federal awards.Prior Year Single Audit Finding Number: Not applicableViews of Responsible Offices and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 174.

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Activities Allowed or Unallowed & Allowable costs/Cost Principles ? Indirect CostsFederal Agency: Department of EducationFederal Program Title: Rehabilitation Services-Vocational Rehabilitation Grants to StatesCFDA No.: 84.126Federal Grant ID Number: H126A170061; H126A180061; H126A190061Pass-Through Entity: Not applicableAward Period: October 1, 2016 through September 30, 2020Type of Finding: Material weakness in internal control over compliance, material noncomplianceCriteria: Per 2 CFR ? 225 Appendix A (F) (1) General. Indirect costs are those: Incurred for a common or joint purpose benefiting more than one cost objective, and not readily assignable to the cost objectives specifically benefitted, without effort disproportionate to the results achieved. The term ``indirect costs,?? as used herein, applies to costs of this type originating in the grantee department, as well as those incurred by other departments in supplying goods, services, and facilities. To facilitate equitable distribution of indirect expenses to the cost objectives served, it may be necessary to establish a number of pools of indirect costs within a governmental unit department or in other agencies providing services to a governmental unit department. Indirect cost pools should be distributed to benefitted cost objectives on bases that will produce an equitable result in consideration of relative benefits derived.Condition: The Commission did not have adequate internal controls and policies/procedures in place to substantiate indirect costs charged to federal awards.Questioned Costs: UnknownContext: For the indirect costs charged to the federal awards, the Commission was not able to substantiate their validity in order to satisfy the testing objectives.Cause: The Commission did not adequately track and is unable to substantiate the calculations for indirect costs charged to federal awards.Effect: The Commission may report inaccurate indirect costs to federal awards.Recommendation: We recommend that the Commission implement internal controls and policies/procedures to substantiate indirect costs charged to federal awards.Prior Year Single Audit Finding Number: Not applicableViews of Responsible Offices and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 174.

Corrective Action Plan

U.S. Department of EducationSouth Carolina Commission for the Blind respectfully submits the following corrective action plan for the year ended 6/30/19.The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule.FINDINGS?FEDERAL AWARD PROGRAM AUDIT2019-032 Rehabilitation Services - Vocational Rehabilitation Grants to States CFDA No.: 84.126Recommendation: We recommend that the Commission implement internal controls and policies/procedures to substantiate indirect costs charged to federal awards.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding: Key positions will continue to be filled and backup staff assigned, which will allow for the development and implementation of the policies and procedures necessary to ensure that indirect costs charged to federal awards can be substantiated.Name(s) of the contact person(s) responsible for corrective action: Matthew DaughertyPlanned completion date for corrective action plan: July 1, 2020If the U.S. Department of Education has questions regarding this plan, please call Matthew Daugherty at 803-898-8835.

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2019-033
Matching, Level of Effort, Earmarking
MATERIAL WEAKNESSMODIFIED OPINION

The Commission did not comply with the level of effort requirements for maintenance of effort.Questioned Costs: UnknownContext: The Commission did not comply with federally required level of effort ? maintenance of effort.Cause: The Commission did not have sufficient internal controls and policies/procedures in place to ensure that level of effort requirements for maintenance of effort were being monitored and met.Effect: The Commission may not comply with federally required level of effort requirements for maintenance of effort.Recommendation: We recommend that the Commission implement internal controls and policies/procedures to ensure federal level of effort requirements for maintenance of effort are being monitored and met.Prior Year Single Audit Finding Number: Not applicableViews of Responsible Offices and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 175.

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Matching, Level of Effort, Earmarking ? Maintenance of EffortFederal Agency: Department of EducationFederal Program Title: Rehabilitation Services-Vocational Rehabilitation Grants to StatesCFDA No.: 84.126Federal Grant ID Number: H126A170061; H126A180061; H126A190061Pass-Through Entity: Not applicableAward Period: October 1, 2016 through September 30, 2020Type of Finding: Material Weakness in internal control over compliance, material noncomplianceCriteria: Per (29 USC 731(a)(2)(B)) the amount otherwise payable to a State for a fiscal year under this section shall be reduced by the amount by which expenditures from non-Federal sources under the State plan under this subchapter for any previous fiscal year are less than the total of such expenditures for the second fiscal year preceding that previous fiscal year.Condition: The Commission did not comply with the level of effort requirements for maintenance of effort.Questioned Costs: UnknownContext: The Commission did not comply with federally required level of effort ? maintenance of effort.Cause: The Commission did not have sufficient internal controls and policies/procedures in place to ensure that level of effort requirements for maintenance of effort were being monitored and met.Effect: The Commission may not comply with federally required level of effort requirements for maintenance of effort.Recommendation: We recommend that the Commission implement internal controls and policies/procedures to ensure federal level of effort requirements for maintenance of effort are being monitored and met.Prior Year Single Audit Finding Number: Not applicableViews of Responsible Offices and Corrective Action Plan: Management agrees with the finding. See Corrective Action Plan at page 175.

Corrective Action Plan

U.S. Department of EducationSouth Carolina Commission for the Blind respectfully submits the following corrective action plan for the year ended 6/30/19.The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule.FINDINGS?FEDERAL AWARD PROGRAM AUDIT2019-033 Rehabilitation Services - Vocational Rehabilitation Grants to States CFDA No.: 84.126Recommendation: We recommend that the Commission implement internal controls and policies/procedures to ensure federal level of effort requirements for maintenance of effort are being monitored and met.Explanation of disagreement with audit finding: There is no disagreement with the audit finding.Action taken in response to finding: Key positions will continue to be filled and backup staff assigned, which will allow for the development and implementation of the policies and procedures necessary to ensure federal level of effort requirements for maintenance of effort are being monitored and met.Name(s) of the contact person(s) responsible for corrective action: Matthew DaughertyPlanned completion date for corrective action plan: July 1, 2020If the U.S. Department of Education has questions regarding this plan, please call Matthew Daugherty at 803-898-8835.

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FY 2018-06-30

$95,296,363 federal awards expended

FAC accepted this audit on December 3, 2020 — management decision was due June 3, 2021.

2018-001
Cost Allowability
SIGNIFICANT DEFICIENCYOTHER MATTERS

GSA_MIGRATION

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GSA_MIGRATION

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GSA_MIGRATION

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2018-002
Activities Allowed or Unallowed / Cost Allowability
SIGNIFICANT DEFICIENCYQUESTIONED COSTSOTHER MATTERS

GSA_MIGRATION

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GSA_MIGRATION

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GSA_MIGRATION

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2018-003
Matching, Level of Effort, Earmarking
SIGNIFICANT DEFICIENCYREPEAT OF 2017-004OTHER MATTERS

GSA_MIGRATION

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GSA_MIGRATION

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GSA_MIGRATION

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2017-004

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2018-004
Eligibility
SIGNIFICANT DEFICIENCYREPEAT OF 2017-005OTHER MATTERS

GSA_MIGRATION

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GSA_MIGRATION

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GSA_MIGRATION

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2017-005

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2018-005
Eligibility
SIGNIFICANT DEFICIENCYREPEAT OF 2017-006QUESTIONED COSTSOTHER MATTERS

GSA_MIGRATION

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GSA_MIGRATION

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GSA_MIGRATION

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2017-006

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2018-006
Eligibility
MATERIAL WEAKNESSMODIFIED OPINIONREPEAT OF 2017-007

GSA_MIGRATION

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GSA_MIGRATION

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GSA_MIGRATION

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2017-007

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2018-006
Reporting
MATERIAL WEAKNESS

GSA_MIGRATION

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GSA_MIGRATION

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GSA_MIGRATION

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2018-007
Reporting
SIGNIFICANT DEFICIENCYOTHER MATTERS

GSA_MIGRATION

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GSA_MIGRATION

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GSA_MIGRATION

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2018-008
Matching, Level of Effort, Earmarking
SIGNIFICANT DEFICIENCYQUESTIONED COSTSOTHER MATTERS

GSA_MIGRATION

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GSA_MIGRATION

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GSA_MIGRATION

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2018-009
Reporting
SIGNIFICANT DEFICIENCYOTHER MATTERS

GSA_MIGRATION

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GSA_MIGRATION

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GSA_MIGRATION

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2018-010
Subrecipient Monitoring
SIGNIFICANT DEFICIENCYOTHER MATTERS

GSA_MIGRATION

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GSA_MIGRATION

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GSA_MIGRATION

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2018-011
Reporting
MATERIAL WEAKNESSREPEAT OF 2017-025OTHER MATTERS

GSA_MIGRATION

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GSA_MIGRATION

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GSA_MIGRATION

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2017-025

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2018-012
Period of Performance
SIGNIFICANT DEFICIENCYOTHER MATTERS

GSA_MIGRATION

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GSA_MIGRATION

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GSA_MIGRATION

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2018-013
Subrecipient Monitoring
SIGNIFICANT DEFICIENCYOTHER MATTERS

GSA_MIGRATION

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GSA_MIGRATION

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GSA_MIGRATION

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2018-014
Reporting
SIGNIFICANT DEFICIENCYREPEAT OF 2017-032OTHER MATTERS

GSA_MIGRATION

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GSA_MIGRATION

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GSA_MIGRATION

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2017-032

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2018-015
Reporting
SIGNIFICANT DEFICIENCYOTHER MATTERS

GSA_MIGRATION

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GSA_MIGRATION

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GSA_MIGRATION

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2018-016
Activities Allowed or Unallowed / Cost Allowability
SIGNIFICANT DEFICIENCYQUESTIONED COSTSOTHER MATTERS

GSA_MIGRATION

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GSA_MIGRATION

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GSA_MIGRATION

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2018-017
Eligibility
SIGNIFICANT DEFICIENCYOTHER MATTERS

GSA_MIGRATION

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GSA_MIGRATION

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GSA_MIGRATION

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2018-018
Cash Management
SIGNIFICANT DEFICIENCYREPEAT OF 2017-014OTHER MATTERS

GSA_MIGRATION

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GSA_MIGRATION

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GSA_MIGRATION

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2017-014

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2018-019
Matching, Level of Effort, Earmarking
SIGNIFICANT DEFICIENCY

GSA_MIGRATION

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GSA_MIGRATION

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GSA_MIGRATION

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2018-020
Reporting
SIGNIFICANT DEFICIENCYOTHER MATTERS

GSA_MIGRATION

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GSA_MIGRATION

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GSA_MIGRATION

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2018-021
Subrecipient Monitoring
SIGNIFICANT DEFICIENCYREPEAT OF 2017-017OTHER MATTERS

GSA_MIGRATION

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2017-017

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2018-022
Cash Management
SIGNIFICANT DEFICIENCY

GSA_MIGRATION

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GSA_MIGRATION

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GSA_MIGRATION

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2018-023
Period of Performance
SIGNIFICANT DEFICIENCYOTHER MATTERS

GSA_MIGRATION

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GSA_MIGRATION

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GSA_MIGRATION

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2018-024
Eligibility
SIGNIFICANT DEFICIENCYOTHER MATTERS

GSA_MIGRATION

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GSA_MIGRATION

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GSA_MIGRATION

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2018-025
Special Tests & Provisions
SIGNIFICANT DEFICIENCY

GSA_MIGRATION

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GSA_MIGRATION

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GSA_MIGRATION

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2018-026
Special Tests & Provisions
SIGNIFICANT DEFICIENCYOTHER MATTERS

GSA_MIGRATION

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GSA_MIGRATION

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GSA_MIGRATION

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2018-027
Special Tests & Provisions
SIGNIFICANT DEFICIENCY

GSA_MIGRATION

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GSA_MIGRATION

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GSA_MIGRATION

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2018-028
Procurement & Suspension/Debarment
SIGNIFICANT DEFICIENCY

GSA_MIGRATION

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GSA_MIGRATION

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GSA_MIGRATION

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2018-029
Activities Allowed or Unallowed / Cost Allowability
SIGNIFICANT DEFICIENCYOTHER MATTERS

GSA_MIGRATION

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GSA_MIGRATION

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GSA_MIGRATION

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2018-030
Procurement & Suspension/Debarment
SIGNIFICANT DEFICIENCYREPEAT OF 2017-019

GSA_MIGRATION

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GSA_MIGRATION

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GSA_MIGRATION

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2017-019

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2018-031
Subrecipient Monitoring
MATERIAL WEAKNESSMODIFIED OPINION

GSA_MIGRATION

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GSA_MIGRATION

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GSA_MIGRATION

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2018-032
Activities Allowed or Unallowed / Cost Allowability
SIGNIFICANT DEFICIENCYOTHER MATTERS

GSA_MIGRATION

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GSA_MIGRATION

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GSA_MIGRATION

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2018-033
Period of Performance
SIGNIFICANT DEFICIENCYOTHER MATTERS

GSA_MIGRATION

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GSA_MIGRATION

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GSA_MIGRATION

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2018-034
Activities Allowed or Unallowed / Cost Allowability
SIGNIFICANT DEFICIENCYOTHER MATTERS

GSA_MIGRATION

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GSA_MIGRATION

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GSA_MIGRATION

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2018-035
Subrecipient Monitoring
MATERIAL WEAKNESSMODIFIED OPINIONREPEAT OF 2017-020

GSA_MIGRATION

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GSA_MIGRATION

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GSA_MIGRATION

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2017-020

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2018-036
Cash Management
SIGNIFICANT DEFICIENCYREPEAT OF 2014-024

GSA_MIGRATION

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GSA_MIGRATION

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GSA_MIGRATION

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2014-024

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2018-037
Reporting
SIGNIFICANT DEFICIENCY

GSA_MIGRATION

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GSA_MIGRATION

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GSA_MIGRATION

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2018-038
Subrecipient Monitoring
MATERIAL WEAKNESSMODIFIED OPINIONREPEAT OF 2017-020

GSA_MIGRATION

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GSA_MIGRATION

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GSA_MIGRATION

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2017-020

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2018-039
Procurement & Suspension/Debarment
MATERIAL WEAKNESSREPEAT OF 2017-019

GSA_MIGRATION

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GSA_MIGRATION

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GSA_MIGRATION

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2017-019

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2018-040
Subrecipient Monitoring
MATERIAL WEAKNESSMODIFIED OPINIONREPEAT OF 2017-010

GSA_MIGRATION

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GSA_MIGRATION

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GSA_MIGRATION

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2017-010

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2018-041
Procurement & Suspension/Debarment
SIGNIFICANT DEFICIENCY

GSA_MIGRATION

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GSA_MIGRATION

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GSA_MIGRATION

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2018-042
Period of Performance
SIGNIFICANT DEFICIENCYOTHER MATTERS

GSA_MIGRATION

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GSA_MIGRATION

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GSA_MIGRATION

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2018-043
Eligibility
SIGNIFICANT DEFICIENCYOTHER MATTERS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Eligibility →
2018-044
Procurement & Suspension/Debarment
MATERIAL WEAKNESS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Procurement and Suspension and Debarment →
2018-045
Eligibility
MATERIAL WEAKNESSMODIFIED OPINION

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Eligibility →
2018-046
Reporting
MATERIAL WEAKNESSMODIFIED OPINION

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Reporting →
2018-047
Special Tests & Provisions
MATERIAL WEAKNESSMODIFIED OPINION

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Special Tests and Provisions →
2018-048
Procurement & Suspension/Debarment
MATERIAL WEAKNESS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Procurement and Suspension and Debarment →

FY 2018-06-30

$8,376,109,824 federal awards expended

FAC accepted this audit on March 25, 2019 — management decision was due September 25, 2019.

2018-001
Cost Allowability
SIGNIFICANT DEFICIENCYOTHER MATTERS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Allowable Costs / Cost Principles →
2018-002
Activities Allowed or Unallowed / Cost Allowability
SIGNIFICANT DEFICIENCYQUESTIONED COSTSOTHER MATTERS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Activities Allowed or Unallowed, Allowable Costs / Cost Principles →
2018-003
Matching, Level of Effort, Earmarking
SIGNIFICANT DEFICIENCYREPEAT OF 2017-004OTHER MATTERS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

Prior Finding References

2017-004

About Matching, Level of Effort, Earmarking →
2018-004
Eligibility
SIGNIFICANT DEFICIENCYREPEAT OF 2017-005OTHER MATTERS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

Prior Finding References

2017-005

About Eligibility →
2018-005
Eligibility
SIGNIFICANT DEFICIENCYREPEAT OF 2017-006QUESTIONED COSTSOTHER MATTERS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

Prior Finding References

2017-006

About Eligibility →
2018-006
Eligibility
MATERIAL WEAKNESSMODIFIED OPINIONREPEAT OF 2017-007

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

Prior Finding References

2017-007

About Eligibility →
2018-006
Reporting
MATERIAL WEAKNESS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Reporting →
2018-007
Reporting
SIGNIFICANT DEFICIENCYOTHER MATTERS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Reporting →
2018-008
Matching, Level of Effort, Earmarking
SIGNIFICANT DEFICIENCYQUESTIONED COSTSOTHER MATTERS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Matching, Level of Effort, Earmarking →
2018-009
Reporting
SIGNIFICANT DEFICIENCYOTHER MATTERS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Reporting →
2018-010
Subrecipient Monitoring
SIGNIFICANT DEFICIENCYOTHER MATTERS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Subrecipient Monitoring →
2018-011
Reporting
MATERIAL WEAKNESSREPEAT OF 2017-025OTHER MATTERS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

Prior Finding References

2017-025

About Reporting →
2018-012
Period of Performance
SIGNIFICANT DEFICIENCYOTHER MATTERS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Period of Performance →
2018-013
Subrecipient Monitoring
SIGNIFICANT DEFICIENCYOTHER MATTERS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Subrecipient Monitoring →
2018-014
Reporting
SIGNIFICANT DEFICIENCYREPEAT OF 2017-032OTHER MATTERS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

Prior Finding References

2017-032

About Reporting →
2018-015
Reporting
SIGNIFICANT DEFICIENCYOTHER MATTERS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Reporting →
2018-016
Activities Allowed or Unallowed / Cost Allowability
SIGNIFICANT DEFICIENCYQUESTIONED COSTSOTHER MATTERS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Activities Allowed or Unallowed, Allowable Costs / Cost Principles →
2018-017
Eligibility
SIGNIFICANT DEFICIENCYOTHER MATTERS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Eligibility →
2018-018
Cash Management
SIGNIFICANT DEFICIENCYREPEAT OF 2017-014OTHER MATTERS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

Prior Finding References

2017-014

About Cash Management →
2018-019
Matching, Level of Effort, Earmarking
SIGNIFICANT DEFICIENCY

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Matching, Level of Effort, Earmarking →
2018-020
Reporting
SIGNIFICANT DEFICIENCYOTHER MATTERS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Reporting →
2018-021
Subrecipient Monitoring
SIGNIFICANT DEFICIENCYREPEAT OF 2017-017OTHER MATTERS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

Prior Finding References

2017-017

About Subrecipient Monitoring →
2018-022
Cash Management
SIGNIFICANT DEFICIENCY

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Cash Management →
2018-023
Period of Performance
SIGNIFICANT DEFICIENCYOTHER MATTERS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Period of Performance →
2018-024
Eligibility
SIGNIFICANT DEFICIENCYOTHER MATTERS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Eligibility →
2018-025
Special Tests & Provisions
SIGNIFICANT DEFICIENCY

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Special Tests and Provisions →
2018-026
Special Tests & Provisions
SIGNIFICANT DEFICIENCYOTHER MATTERS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Special Tests and Provisions →
2018-027
Special Tests & Provisions
SIGNIFICANT DEFICIENCY

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Special Tests and Provisions →
2018-028
Procurement & Suspension/Debarment
SIGNIFICANT DEFICIENCY

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Procurement and Suspension and Debarment →
2018-029
Activities Allowed or Unallowed / Cost Allowability
SIGNIFICANT DEFICIENCYOTHER MATTERS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Activities Allowed or Unallowed, Allowable Costs / Cost Principles →
2018-030
Procurement & Suspension/Debarment
SIGNIFICANT DEFICIENCYREPEAT OF 2017-019

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

Prior Finding References

2017-019

About Procurement and Suspension and Debarment →
2018-031
Subrecipient Monitoring
MATERIAL WEAKNESSMODIFIED OPINION

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Subrecipient Monitoring →
2018-032
Activities Allowed or Unallowed / Cost Allowability
SIGNIFICANT DEFICIENCYOTHER MATTERS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Activities Allowed or Unallowed, Allowable Costs / Cost Principles →
2018-033
Period of Performance
SIGNIFICANT DEFICIENCYOTHER MATTERS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Period of Performance →
2018-034
Activities Allowed or Unallowed / Cost Allowability
SIGNIFICANT DEFICIENCYOTHER MATTERS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Activities Allowed or Unallowed, Allowable Costs / Cost Principles →
2018-035
Subrecipient Monitoring
MATERIAL WEAKNESSMODIFIED OPINIONREPEAT OF 2017-020

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

Prior Finding References

2017-020

About Subrecipient Monitoring →
2018-036
Cash Management
SIGNIFICANT DEFICIENCYREPEAT OF 2014-024

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

Prior Finding References

2014-024

About Cash Management →
2018-037
Reporting
SIGNIFICANT DEFICIENCY

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Reporting →
2018-038
Subrecipient Monitoring
MATERIAL WEAKNESSMODIFIED OPINIONREPEAT OF 2017-020

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

Prior Finding References

2017-020

About Subrecipient Monitoring →
2018-039
Procurement & Suspension/Debarment
MATERIAL WEAKNESSREPEAT OF 2017-019

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

Prior Finding References

2017-019

About Procurement and Suspension and Debarment →
2018-040
Subrecipient Monitoring
MATERIAL WEAKNESSMODIFIED OPINIONREPEAT OF 2017-010

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

Prior Finding References

2017-010

About Subrecipient Monitoring →
2018-041
Procurement & Suspension/Debarment
SIGNIFICANT DEFICIENCY

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Procurement and Suspension and Debarment →
2018-042
Period of Performance
SIGNIFICANT DEFICIENCYOTHER MATTERS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Period of Performance →
2018-043
Eligibility
SIGNIFICANT DEFICIENCYOTHER MATTERS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Eligibility →
2018-044
Procurement & Suspension/Debarment
MATERIAL WEAKNESS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Procurement and Suspension and Debarment →
2018-045
Eligibility
MATERIAL WEAKNESSMODIFIED OPINION

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Eligibility →
2018-046
Reporting
MATERIAL WEAKNESSMODIFIED OPINION

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Reporting →
2018-047
Special Tests & Provisions
MATERIAL WEAKNESSMODIFIED OPINION

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Special Tests and Provisions →
2018-048
Procurement & Suspension/Debarment
MATERIAL WEAKNESS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Procurement and Suspension and Debarment →

FY 2017-06-30

MATERIAL NONCOMPLIANCE DISCLOSED$139,727,445 federal awards expended

FAC accepted this audit on July 31, 2019 — management decision was due January 31, 2020.

2017-004
Matching, Level of Effort, Earmarking
SIGNIFICANT DEFICIENCYREPEAT OF 2016-014OTHER MATTERS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

Prior Finding References

2016-014

About Matching, Level of Effort, Earmarking →
2017-005
Eligibility
SIGNIFICANT DEFICIENCYREPEAT OF 2016-015OTHER MATTERS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

Prior Finding References

2016-015

About Eligibility →
2017-006
Eligibility
SIGNIFICANT DEFICIENCYREPEAT OF 2016-016OTHER MATTERS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

Prior Finding References

2016-016

About Eligibility →
2017-007
Eligibility
MATERIAL WEAKNESSMODIFIED OPINIONREPEAT OF 2016-017

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

Prior Finding References

2016-017

About Eligibility →
2017-008
Reporting
SIGNIFICANT DEFICIENCYOTHER MATTERS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Reporting →
2017-009
Cost Allowability
MATERIAL WEAKNESSMODIFIED OPINIONREPEAT OF 2016-020

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

Prior Finding References

2016-020

About Allowable Costs / Cost Principles →
2017-009
Reporting
MATERIAL WEAKNESSOTHER MATTERS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Reporting →
2017-010
Subrecipient Monitoring
SIGNIFICANT DEFICIENCYOTHER MATTERS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Subrecipient Monitoring →
2017-010
Other
MATERIAL WEAKNESSOTHER MATTERS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Other →
2017-011
Period of Performance
SIGNIFICANT DEFICIENCYOTHER MATTERS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Period of Performance →
2017-012
Procurement & Suspension/Debarment
SIGNIFICANT DEFICIENCY

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Procurement and Suspension and Debarment →
2017-013
Subrecipient Monitoring
SIGNIFICANT DEFICIENCYREPEAT OF 2016-005

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

Prior Finding References

2016-005

About Subrecipient Monitoring →
2017-014
Cash Management
SIGNIFICANT DEFICIENCYREPEAT OF 2016-012

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

Prior Finding References

2016-012

About Cash Management →
2017-015
Subrecipient Monitoring
SIGNIFICANT DEFICIENCYOTHER MATTERS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Subrecipient Monitoring →
2017-016
Matching, Level of Effort, Earmarking
SIGNIFICANT DEFICIENCY

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Matching, Level of Effort, Earmarking →
2017-017
Subrecipient Monitoring
SIGNIFICANT DEFICIENCYREPEAT OF 2016-007OTHER MATTERS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

Prior Finding References

2016-007

About Subrecipient Monitoring →
2017-018
Reporting
SIGNIFICANT DEFICIENCYOTHER MATTERS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Reporting →
2017-019
Procurement & Suspension/Debarment
MATERIAL WEAKNESSREPEAT OF 2016-030

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

Prior Finding References

2016-030

About Procurement and Suspension and Debarment →
2017-020
Subrecipient Monitoring
MATERIAL WEAKNESSMODIFIED OPINIONREPEAT OF 2016-024

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

Prior Finding References

2016-024

About Subrecipient Monitoring →
2017-021
Cash Management
MATERIAL WEAKNESSREPEAT OF 2016-025

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

Prior Finding References

2016-025

About Cash Management →
2017-022
Activities Allowed or Unallowed / Cost Allowability
SIGNIFICANT DEFICIENCYREPEAT OF 2016-026QUESTIONED COSTSOTHER MATTERS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

Prior Finding References

2016-026

About Activities Allowed or Unallowed, Allowable Costs / Cost Principles →
2017-023
Matching, Level of Effort, Earmarking
SIGNIFICANT DEFICIENCYREPEAT OF 2016-027QUESTIONED COSTSOTHER MATTERS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

Prior Finding References

2016-027

About Matching, Level of Effort, Earmarking →
2017-024
Cash Management
SIGNIFICANT DEFICIENCYREPEAT OF 2016-028

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

Prior Finding References

2016-028

About Cash Management →
2017-025
Reporting
MATERIAL WEAKNESSMODIFIED OPINIONREPEAT OF 2016-018

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

Prior Finding References

2016-018

About Reporting →
2017-026
Subrecipient Monitoring
SIGNIFICANT DEFICIENCYOTHER MATTERS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Subrecipient Monitoring →
2017-027
Reporting
SIGNIFICANT DEFICIENCYOTHER MATTERS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Reporting →
2017-028
Activities Allowed or Unallowed / Cost Allowability
SIGNIFICANT DEFICIENCYOTHER MATTERS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Activities Allowed or Unallowed, Allowable Costs / Cost Principles →
2017-029
Reporting
SIGNIFICANT DEFICIENCYOTHER MATTERS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Reporting →
2017-030
Reporting
SIGNIFICANT DEFICIENCYOTHER MATTERS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Reporting →
2017-031
Period of Performance
SIGNIFICANT DEFICIENCYOTHER MATTERS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Period of Performance →
2017-032
Reporting
MATERIAL WEAKNESSMODIFIED OPINION

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Reporting →
2017-033
Reporting
SIGNIFICANT DEFICIENCYOTHER MATTERS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Reporting →
2017-034
Special Tests & Provisions
SIGNIFICANT DEFICIENCYOTHER MATTERS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Special Tests and Provisions →

FY 2017-06-30

$8,196,342,310 federal awards expended

FAC accepted this audit on March 29, 2018 — management decision was due September 29, 2018.

2017-004
Matching, Level of Effort, Earmarking
SIGNIFICANT DEFICIENCYREPEAT OF 2016-014OTHER MATTERS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

Prior Finding References

2016-014

About Matching, Level of Effort, Earmarking →
2017-005
Eligibility
SIGNIFICANT DEFICIENCYREPEAT OF 2016-015OTHER MATTERS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

Prior Finding References

2016-015

About Eligibility →
2017-006
Eligibility
SIGNIFICANT DEFICIENCYREPEAT OF 2016-016OTHER MATTERS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

Prior Finding References

2016-016

About Eligibility →
2017-007
Eligibility
MATERIAL WEAKNESSMODIFIED OPINIONREPEAT OF 2016-017

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

Prior Finding References

2016-017

About Eligibility →
2017-008
Reporting
SIGNIFICANT DEFICIENCYOTHER MATTERS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Reporting →
2017-009
Cost Allowability
MATERIAL WEAKNESSMODIFIED OPINIONREPEAT OF 2016-020

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

Prior Finding References

2016-020

About Allowable Costs / Cost Principles →
2017-009
Reporting
MATERIAL WEAKNESSOTHER MATTERS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Reporting →
2017-010
Subrecipient Monitoring
SIGNIFICANT DEFICIENCYOTHER MATTERS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Subrecipient Monitoring →
2017-010
Other
MATERIAL WEAKNESSOTHER MATTERS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Other →
2017-011
Period of Performance
SIGNIFICANT DEFICIENCYOTHER MATTERS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Period of Performance →
2017-012
Procurement & Suspension/Debarment
SIGNIFICANT DEFICIENCY

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Procurement and Suspension and Debarment →
2017-013
Subrecipient Monitoring
SIGNIFICANT DEFICIENCYREPEAT OF 2016-005

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

Prior Finding References

2016-005

About Subrecipient Monitoring →
2017-014
Cash Management
SIGNIFICANT DEFICIENCYREPEAT OF 2016-012

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

Prior Finding References

2016-012

About Cash Management →
2017-015
Subrecipient Monitoring
SIGNIFICANT DEFICIENCYOTHER MATTERS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Subrecipient Monitoring →
2017-016
Matching, Level of Effort, Earmarking
SIGNIFICANT DEFICIENCY

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Matching, Level of Effort, Earmarking →
2017-017
Subrecipient Monitoring
SIGNIFICANT DEFICIENCYREPEAT OF 2016-007OTHER MATTERS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

Prior Finding References

2016-007

About Subrecipient Monitoring →
2017-018
Reporting
SIGNIFICANT DEFICIENCYOTHER MATTERS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Reporting →
2017-019
Procurement & Suspension/Debarment
MATERIAL WEAKNESSREPEAT OF 2016-030

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

Prior Finding References

2016-030

About Procurement and Suspension and Debarment →
2017-020
Subrecipient Monitoring
MATERIAL WEAKNESSMODIFIED OPINIONREPEAT OF 2016-024

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

Prior Finding References

2016-024

About Subrecipient Monitoring →
2017-021
Cash Management
MATERIAL WEAKNESSREPEAT OF 2016-025

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

Prior Finding References

2016-025

About Cash Management →
2017-022
Activities Allowed or Unallowed / Cost Allowability
SIGNIFICANT DEFICIENCYREPEAT OF 2016-026QUESTIONED COSTSOTHER MATTERS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

Prior Finding References

2016-026

About Activities Allowed or Unallowed, Allowable Costs / Cost Principles →
2017-023
Matching, Level of Effort, Earmarking
SIGNIFICANT DEFICIENCYREPEAT OF 2016-027QUESTIONED COSTSOTHER MATTERS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

Prior Finding References

2016-027

About Matching, Level of Effort, Earmarking →
2017-024
Cash Management
SIGNIFICANT DEFICIENCYREPEAT OF 2016-028

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

Prior Finding References

2016-028

About Cash Management →
2017-025
Reporting
MATERIAL WEAKNESSMODIFIED OPINIONREPEAT OF 2016-018

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

Prior Finding References

2016-018

About Reporting →
2017-026
Subrecipient Monitoring
SIGNIFICANT DEFICIENCYOTHER MATTERS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Subrecipient Monitoring →
2017-027
Reporting
SIGNIFICANT DEFICIENCYOTHER MATTERS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Reporting →
2017-028
Activities Allowed or Unallowed / Cost Allowability
SIGNIFICANT DEFICIENCYOTHER MATTERS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Activities Allowed or Unallowed, Allowable Costs / Cost Principles →
2017-029
Reporting
SIGNIFICANT DEFICIENCYOTHER MATTERS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Reporting →
2017-030
Reporting
SIGNIFICANT DEFICIENCYOTHER MATTERS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Reporting →
2017-031
Period of Performance
SIGNIFICANT DEFICIENCYOTHER MATTERS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Period of Performance →
2017-032
Reporting
MATERIAL WEAKNESSMODIFIED OPINION

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Reporting →
2017-033
Reporting
SIGNIFICANT DEFICIENCYOTHER MATTERS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Reporting →
2017-034
Special Tests & Provisions
SIGNIFICANT DEFICIENCYOTHER MATTERS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Special Tests and Provisions →

FY 2016-06-30

UNMODIFIED OPINION, QUALIFIED OPINIONMATERIAL NONCOMPLIANCE DISCLOSED$7,921,178,224 federal awards expended

FAC accepted this audit on March 30, 2017 — management decision was due September 30, 2017.

2016-004
Subrecipient Monitoring
MATERIAL WEAKNESSMODIFIED OPINIONREPEAT OF 2015-003

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

Prior Finding References

2015-003

About Subrecipient Monitoring →
2016-005
Subrecipient Monitoring
MATERIAL WEAKNESSMODIFIED OPINION

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Subrecipient Monitoring →
2016-006
Subrecipient Monitoring
MATERIAL WEAKNESSMODIFIED OPINION

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Subrecipient Monitoring →
2016-007
Subrecipient Monitoring
MATERIAL WEAKNESSMODIFIED OPINION

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Subrecipient Monitoring →
2016-008
Matching, Level of Effort, Earmarking
MATERIAL WEAKNESS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Matching, Level of Effort, Earmarking →
2016-009
Activities Allowed or Unallowed / Cost Allowability
SIGNIFICANT DEFICIENCY

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Activities Allowed or Unallowed, Allowable Costs / Cost Principles →
2016-010
Procurement & Suspension/Debarment / Reporting
SIGNIFICANT DEFICIENCY

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Procurement and Suspension and Debarment, Reporting →
2016-011
Period of Performance
SIGNIFICANT DEFICIENCYQUESTIONED COSTSOTHER MATTERS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Period of Performance →
2016-012
Cash Management
SIGNIFICANT DEFICIENCY

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Cash Management →
2016-013
Matching, Level of Effort, Earmarking
SIGNIFICANT DEFICIENCYQUESTIONED COSTSOTHER MATTERS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Matching, Level of Effort, Earmarking →
2016-014
Matching, Level of Effort, Earmarking
SIGNIFICANT DEFICIENCYOTHER MATTERS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Matching, Level of Effort, Earmarking →
2016-015
Eligibility
SIGNIFICANT DEFICIENCYREPEAT OF 2015-006OTHER MATTERS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

Prior Finding References

2015-006

About Eligibility →
2016-016
Eligibility
SIGNIFICANT DEFICIENCYQUESTIONED COSTSOTHER MATTERS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Eligibility →
2016-017
Eligibility
SIGNIFICANT DEFICIENCYREPEAT OF 2015-005OTHER MATTERS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

Prior Finding References

2015-005

About Eligibility →
2016-018
Reporting
MATERIAL WEAKNESSREPEAT OF 2015-011

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

Prior Finding References

2015-011

About Reporting →
2016-019
Cost Allowability
SIGNIFICANT DEFICIENCYOTHER MATTERS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Allowable Costs / Cost Principles →
2016-020
Cost Allowability
MATERIAL WEAKNESS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Allowable Costs / Cost Principles →
2016-021
Cost Allowability
SIGNIFICANT DEFICIENCYQUESTIONED COSTSOTHER MATTERS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Allowable Costs / Cost Principles →
2016-022
Cost Allowability
SIGNIFICANT DEFICIENCYQUESTIONED COSTSOTHER MATTERS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Allowable Costs / Cost Principles →
2016-023
Reporting
SIGNIFICANT DEFICIENCYOTHER MATTERS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Reporting →
2016-024
Subrecipient Monitoring
MATERIAL WEAKNESSMODIFIED OPINION

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Subrecipient Monitoring →
2016-025
Cash Management
MATERIAL WEAKNESS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Cash Management →
2016-026
Activities Allowed or Unallowed / Cost Allowability
SIGNIFICANT DEFICIENCYQUESTIONED COSTSOTHER MATTERS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Activities Allowed or Unallowed, Allowable Costs / Cost Principles →
2016-027
Matching, Level of Effort, Earmarking
SIGNIFICANT DEFICIENCYOTHER MATTERS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Matching, Level of Effort, Earmarking →
2016-028
Cash Management
SIGNIFICANT DEFICIENCY

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Cash Management →
2016-029
Cost Allowability
SIGNIFICANT DEFICIENCYOTHER MATTERS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Allowable Costs / Cost Principles →
2016-030
Procurement & Suspension/Debarment
MATERIAL WEAKNESS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Procurement and Suspension and Debarment →
2016-031
Period of Performance
SIGNIFICANT DEFICIENCYOTHER MATTERS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Period of Performance →

FY 2016-06-30

$113,537,447 federal awards expended

FAC accepted this audit on February 26, 2017 — management decision was due August 26, 2017.

2016-004
Subrecipient Monitoring
MATERIAL WEAKNESSMODIFIED OPINIONREPEAT OF 2015-003

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

Prior Finding References

2015-003

About Subrecipient Monitoring →
2016-005
Subrecipient Monitoring
MATERIAL WEAKNESSMODIFIED OPINION

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Subrecipient Monitoring →
2016-006
Subrecipient Monitoring
MATERIAL WEAKNESSMODIFIED OPINION

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Subrecipient Monitoring →
2016-007
Subrecipient Monitoring
MATERIAL WEAKNESSMODIFIED OPINION

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Subrecipient Monitoring →
2016-008
Matching, Level of Effort, Earmarking
MATERIAL WEAKNESS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Matching, Level of Effort, Earmarking →
2016-009
Activities Allowed or Unallowed / Cost Allowability
SIGNIFICANT DEFICIENCY

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Activities Allowed or Unallowed, Allowable Costs / Cost Principles →
2016-010
Procurement & Suspension/Debarment / Reporting
SIGNIFICANT DEFICIENCY

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Procurement and Suspension and Debarment, Reporting →
2016-011
Period of Performance
SIGNIFICANT DEFICIENCYQUESTIONED COSTSOTHER MATTERS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Period of Performance →
2016-012
Cash Management
SIGNIFICANT DEFICIENCY

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Cash Management →
2016-013
Matching, Level of Effort, Earmarking
SIGNIFICANT DEFICIENCYQUESTIONED COSTSOTHER MATTERS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Matching, Level of Effort, Earmarking →
2016-014
Matching, Level of Effort, Earmarking
SIGNIFICANT DEFICIENCYOTHER MATTERS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Matching, Level of Effort, Earmarking →
2016-015
Eligibility
SIGNIFICANT DEFICIENCYREPEAT OF 2015-006OTHER MATTERS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

Prior Finding References

2015-006

About Eligibility →
2016-016
Eligibility
SIGNIFICANT DEFICIENCYQUESTIONED COSTSOTHER MATTERS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Eligibility →
2016-017
Eligibility
SIGNIFICANT DEFICIENCYREPEAT OF 2015-005OTHER MATTERS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

Prior Finding References

2015-005

About Eligibility →
2016-018
Reporting
MATERIAL WEAKNESSREPEAT OF 2015-011

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

Prior Finding References

2015-011

About Reporting →
2016-019
Cost Allowability
SIGNIFICANT DEFICIENCYOTHER MATTERS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Allowable Costs / Cost Principles →
2016-020
Cost Allowability
MATERIAL WEAKNESS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Allowable Costs / Cost Principles →
2016-021
Cost Allowability
SIGNIFICANT DEFICIENCYQUESTIONED COSTSOTHER MATTERS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Allowable Costs / Cost Principles →
2016-022
Cost Allowability
SIGNIFICANT DEFICIENCYQUESTIONED COSTSOTHER MATTERS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Allowable Costs / Cost Principles →
2016-023
Reporting
SIGNIFICANT DEFICIENCYOTHER MATTERS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Reporting →
2016-024
Subrecipient Monitoring
MATERIAL WEAKNESSMODIFIED OPINION

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Subrecipient Monitoring →
2016-025
Cash Management
MATERIAL WEAKNESS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Cash Management →
2016-026
Activities Allowed or Unallowed / Cost Allowability
SIGNIFICANT DEFICIENCYQUESTIONED COSTSOTHER MATTERS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Activities Allowed or Unallowed, Allowable Costs / Cost Principles →
2016-027
Matching, Level of Effort, Earmarking
SIGNIFICANT DEFICIENCYOTHER MATTERS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Matching, Level of Effort, Earmarking →
2016-028
Cash Management
SIGNIFICANT DEFICIENCY

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Cash Management →
2016-029
Cost Allowability
SIGNIFICANT DEFICIENCYOTHER MATTERS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Allowable Costs / Cost Principles →
2016-030
Procurement & Suspension/Debarment
MATERIAL WEAKNESS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Procurement and Suspension and Debarment →
2016-031
Period of Performance
SIGNIFICANT DEFICIENCYOTHER MATTERS

GSA_MIGRATION

Show full finding ▾
Full finding narrative

GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

About Period of Performance →

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