State of Missouri Single Audit Year Ended June 30, 2021

Source document: State of Missouri Single Audit Year Ended June 30, 2021; document type: inspector-general-sigpr-reports.

Full text

auditor.mo.gov
State of Missouri
Single Audit
Year Ended June 30, 2021
Report No. 2022-043

July 2022

July 2022

Nicole Galloway, CPA
Missouri State Auditor
CITIZENS SUMMARY

Findings in the Fiscal Year 2021 State of Missouri Single Audit

A single audit requires an audit of the state's financial statements and
expenditures of federal awards. The state spent approximately $20.6 billion
in federal awards during the fiscal year ended June 30, 2021. Our Single Audit
involved audit work on 20 major federal programs administered by 10 state
agencies, with expenditures totaling approximately $13.8 billion.

Improvements are needed in the Department of Economic Development's
(DED) internal controls related to subrecipient determinations. During state
fiscal year 2021, the DED did not comply with the Uniform Guidance
requirements regarding subrecipient monitoring for the Emergency Rental
Assistance (ERA) Program.

The expenditures reported on the DED's schedule of expenditures of federal
awards (SEFA) submitted to the Office of Administration - Division of
Accounting (DOA) for inclusion in the statewide SEFA for the year ended
June 30, 2021, were misstated. If the misstatement had not been identified
during the audit, DED program expenditures would have been understated by
$337,542,257 in the statewide SEFA.

The DED did not establish an internal control system over required federal
reporting of the ERA Program and did not identify a significant inaccuracy in
a performance report. In addition, the required Federal Funding
Accountability and Transparency Act (FFATA) reporting was not submitted
for state fiscal year 2021.

As noted in our previous audit, the Department of Social Services (DSS) -
MO HealthNet Division has not fully implemented the Medicaid National
Correct Coding Initiative edits in the Medicaid Management Information
System as required.

As similarly noted in our 2 previous audits, the DSS does not have sufficient
controls to ensure compliance with the eligibility requirements of the Medical
Assistance Program (Medicaid) and the Children's Health Insurance Program
(CHIP) for certain participants whose eligibility is based on their Modified
Adjusted Gross Income (MAGI). The DSS did not correct system overrides
for some MAGI-based participants, preventing their cases from being closed
when necessary.

The DSS has not documented policies and procedures, including a periodic
schedule, for reviews of Foster Care program maintenance payment rates. In
addition, the DSS could not provide documentation supporting any review of
the rates in effect for the year ended June 30, 2021.

DSS controls over the Child Care Development Fund (Child Care) program's
corrective (manual) subsidy payments to child care providers are not
sufficient to prevent improper payments. The DSS made unsupported
corrective payments and/or overpaid providers on behalf of 3 children.

Background
DED Subrecipient
Determination and Monitoring
DED SEFA
DED Performance and
FFATA Reporting
Medicaid National Correct
Coding Initiative
Medicaid and CHIP
Participant Eligibility
Foster Care Maintenance
Payment Rates
Child Care Corrective
Payments

The DSS - Division of Finance and Administrative Services (DFAS) needs to
strengthen internal controls related to FFATA reporting for the TANF,
LIHEAP, and CVA programs. During state fiscal year 2021, the DFAS did
not fully comply with FFATA reporting requirements for more than half of
the subawards reviewed.

The Department of Health and Senior Services (DHSS) did not have
sufficient controls and procedures to ensure Epidemiology and Laboratory
Capacity for Infectious Diseases (ELC) program reimbursements to
subrecipients were allowable, reasonable, and supported with sufficient
documentation. As a result, unsupported reimbursements totaling $105,507
were made to some subrecipients.

The DHSS - Division of Community and Public Health did not perform
subrecipient monitoring procedures in accordance with the department
monitoring policy.

During state fiscal year 2021, the DHSS did not complete FFATA reporting
within required timeframes for some ELC program subawards.

The DHSS - Division of Senior and Disability Services does not have
effective controls in place to ensure Participant Choice Agreements were
obtained and/or retained for participants of the State Plan Personal Care
(SPPC) program. A Participant Choice Agreement was not in the web tool or
retained elsewhere for 5 participants (8 percent) reviewed.

The DHSS - Section for Long-Term Care Registration did not perform facility
survey procedures within required timeframes.

As noted in our prior 6 audit reports, the Department of Mental Health -
Division of Developmental Disabilities (DD) continued to pay historical per
diem rates to providers for residential habilitation services provided to
participants of the Home and Community Based Services, Developmental
Disabilities Comprehensive Waiver (Comprehensive Waiver) program, but
did not retain adequate documentation to support these rates. As a result, the
DD could not demonstrate some amounts paid were allowable costs of the
Comprehensive Waiver program.

The Department of Elementary and Secondary Education (DESE) did not
report subaward information in its annual performance report of the
Governor's Emergency Education Relief (GEER) Fund for the period March
13 through September 30, 2020.

During state fiscal year 2021, the DESE did not comply with FFATA
reporting requirements for any of the subawards reviewed for the GEER Fund
and the Elementary and Secondary School Emergency Relief Fund grants.

The DESE needs to strengthen internal controls to ensure compliance with
subrecipient monitoring requirements. During the year ended June 30, 2021,
the DESE did not perform subrecipient monitoring reviews in accordance
with its monitoring guide for the Special Education Cluster.

DSS FFATA Reporting
ELC Program Subrecipient
Reimbursements
ELC Program Subrecipient
Monitoring
DHSS FFATA Reporting
Medicaid SPPC Participant
Choice Agreements
Medicaid Facility Survey
Timeliness
Medicaid Developmental
Disabilities Comprehensive
Waiver Per Diem Rates
GEER Fund Annual
Performance Reporting
DESE FFATA Reporting
Special Education Cluster
Subrecipient Monitoring

The DESE's controls and procedures related to the preparation of the SEFA
were not sufficient; and as a result, expenditures reported on the DESE SEFA
submitted to the DOA for inclusion in the statewide SEFA for the year ended
June 30, 2021, were misstated. If the errors and omissions had not been
identified during the audit, expenditures would have been understated by
approximately $77.1 million in the statewide SEFA for various DESE
programs.

The Department of Labor and Industrial Relations needs to improve certain
UInteract system controls. System controls were not sufficient to prevent or
detect improper payments authorized by an employee totaling approximately
$123,000 during fiscal years 2020 and 2021.

During the year ended June 30, 2021, the Department of Public Safety - State
Emergency Management Agency (SEMA) did not have adequate procedures
to ensure the timely verification that subrecipients of the Disaster Grants -
Public Assistance (Presidentially Declared Disasters) (DGPA) program were
not suspended or debarred.

The SEMA needs to strengthen internal controls related to FFATA reporting
for the DGPA program. During state fiscal year 2021, the SEMA did not
comply with FFATA reporting requirements for any of the subawards
reviewed.

The Missouri Department of Transportation (MoDOT) needs to strengthen
internal controls related to FFATA reporting for the Airport Improvement
Program.

DESE SEFA
Department of Labor and
Industrial Relations UInteract
System Controls
SEMA Suspension and
Debarment Procedures
SEMA FFATA Reporting
MoDOT FFATA Reporting
Because of the nature of this audit, no rating is provided.

1
State of Missouri
Single Audit - Table of Contents

3

Independent Auditor's Report on Compliance for Each Major Federal
Program; Report on Internal Control Over Compliance; and Report
on the Schedule of Expenditures of Federal Awards Required by the
Uniform Guidance ..................................................................................... 12

16

Notes to the Schedule of Expenditures of Federal Awards .......................... 24

Section I - Summary of Auditor's Results .................................................... 29

Section II - Financial Statement Findings .................................................... 31

Section III - Federal Award Findings and Questioned Costs

Department of Economic Development
2021-001. DED Subrecipient Determination and Monitoring ................... 32
2021-002. DED SEFA ............................................................................... 35
2021-003. DED Performance and FFATA Reporting ............................... 36

Department of Social Services
2021-004. Medicaid National Correct Coding Initiative ........................... 38
2021-005. Medicaid and CHIP Participant Eligibility ............................... 40
2021-006. Foster Care Maintenance Payment Rates ................................. 43
2021-007. Child Care Corrective Payments .............................................. 45
2021-008. DSS FFATA Reporting ............................................................ 47

Department of Health and Senior Services
2021-009. ELC Program Subrecipient Reimbursements ........................... 50
2021-010. ELC Program Subrecipient Monitoring .................................... 52
2021-011. DHSS FFATA Reporting ......................................................... 53
2021-012. Medicaid SPPC Participant Choice Agreements ...................... 54
2021-013. Medicaid Facility Survey Timeliness ....................................... 56

Department of Mental Health
2021-014. Medicaid Developmental Disabilities Comprehensive
Waiver Per Diem Rates .......................................................... 57

Introduction and Summary
State Auditor's Report
Schedule of Expenditures of
Federal Awards
State of Missouri
Single Audit
Table of Contents
Schedule of Findings and
Questioned Costs

2
State of Missouri
Single Audit - Table of Contents
Department of Elementary and Secondary Education
2021-015. GEER Fund Annual Performance Reporting ........................... 60
2021-016. DESE FFATA Reporting .......................................................... 61
2021-017. Special Education Cluster Subrecipient Monitoring ................ 62
2021-018. DESE SEFA ............................................................................. 65

Department of Labor and Industrial Relations
2021-019. Department of Labor and Industrial Relations UInteract
System Controls ..................................................................... 66

Department of Public Safety - State Emergency Management Agency
2021-020
SEMA Suspension and Debarment Procedures ........................ 67
2021-021. SEMA FFATA Reporting ........................................................ 69

Department of Transportation
2021-022. MoDOT FFATA Reporting ...................................................... 71

Additional State Auditor's Reports ............................................................... 73

74

87

Common Abbreviations

ACFR
Annual Comprehensive Financial Report
AL
Assistance Listing
CAP
Corrective Action Plan
CFR
Code of Federal Regulations
CSR
Code of State Regulations
COVID-19
Coronavirus Disease 2019
FFATA
Federal Funding Accountability and Transparency Act
FPUC
Federal Pandemic Unemployment Compensation
LWA
Lost Wages Assistance
OMB
Office of Management and Budget
PEUC
Pandemic Emergency Unemployment Compensation
PUA
Pandemic Unemployment Assistance
RSMo
Missouri Revised Statutes
SAM II
Statewide Advantage for Missouri
SEFA
Schedule of Expenditures of Federal Awards
USC
United States Code
Summary Schedule of Prior
Audit Findings
Corrective Action Plans
State of Missouri
Single Audit
Table of Contents

3
State of Missouri - Single Audit
Introduction and Summary
Year Ended June 30, 2021
The United States Congress passed the Single Audit Act Amendments of
1996 to establish uniform requirements for audits of federal awards. The
Office of Management and Budget (OMB) issued Title 2 U.S. Code of
Federal Regulations Part 200, Uniform Administrative Requirements, Cost
Principles, and Audit Requirements for Federal Awards (Uniform Guidance)
to set forth uniform cost principles and audit requirements for federal awards
to nonfederal entities and administrative requirements for all federal grants
and cooperative agreements.

A single audit under the Uniform Guidance requires an audit of the State of
Missouri's financial statements and expenditures of federal awards. The audit
is required to determine whether:


The state's basic financial statements are presented fairly in all material
respects in conformity with generally accepted accounting principles.


The state's schedule of expenditures of federal awards is stated fairly in
all material respects in relation to the financial statements as a whole.


The state has adequate internal controls to ensure compliance with federal
award requirements.


The state has complied with federal statutes, regulations, and the terms
and conditions of federal awards that could have a direct and material
effect on each of its major federal programs.


The state's summary schedule of prior audit findings materially represents
the status of the prior audit findings.

The Single Audit report includes the federal awards expended by all state
agencies and offices that are part of the primary government. The report does
not include the public universities and other component units, which are
legally separate from the state and audited by other auditors. The state
expended approximately $20.6 billion in federal awards during the state fiscal
year ended June 30, 2021.

State of Missouri - Single Audit
Introduction and Summary
Year Ended June 30, 2021
Introduction

4
State of Missouri - Single Audit
Introduction and Summary
Year Ended June 30, 2021
The following is the summary of our Single Audit results for the state fiscal
year ended June 30, 2021.

We issued our audit report (Report No. 2022-0021) of the state's Annual
Comprehensive Financial Report (ACFR), as of and for the year ended
June 30, 2021, in January 2022. In addition, we issued our Annual
Comprehensive Financial Report - Report on Internal Control, Compliance,
and Other Matters (Report No. 2022-0222) in March 2022. In that report, we
reported four findings related to internal control deficiencies. The state
agencies' responses to the audit findings are included in that report. The
agencies prepared a Corrective Action Plan (CAP) for each finding. The
CAPs were submitted to the Office of Administration (OA) and are in the
Corrective Action Plans section of this report. The state agencies prepared
and submitted to the OA the status of the prior financial statement audit
findings. These are presented in the Summary Schedule of Prior Audit
Findings section of this report.

We issued our report on the accompanying Schedule of Expenditures of
Federal Awards (SEFA). The state's SEFA, which does not include federal
award expenditures of the public universities and other component units,
reported the state expended approximately $20.6 billion in federal funds in
state fiscal year 2021. Our report expressed the opinion that the SEFA is fairly
stated, in all material respects, in relation to the basic financial statements as
a whole.

We audited 20 major federal programs with expenditures totaling
approximately $13.8 billion, administered by 10 state agencies.

We issued a qualified opinion on 5 major federal programs and an unmodified
opinion on 15 major federal programs. A qualified opinion is issued when the
audit of a major federal program detects material noncompliance with direct
and material compliance requirements. A qualified opinion was issued on the
following major programs administered by the Department of Economic
Development, the Department of Social Services, the Department of Health
and Senior Services, and the Department of Elementary and Secondary
Education:


Emergency Rental Assistance Program, modified for Subrecipient
Monitoring and Reporting

Children's Health Insurance Program, modified for Special Tests and
Provisions

1The
ACFR
is
available
online
at:
<https://oa.mo.gov/accounting/reports/annual-
reports/annual-comprehensive-financial-reports>.
2See report at <https://auditor.mo.gov/AuditReport/ViewReport?report=2022022>.
Summary of Single
Audit Results
Financial Statements
Federal Awards

5
State of Missouri - Single Audit
Introduction and Summary
Year Ended June 30, 2021

Medicaid Cluster, modified for Special Tests and Provisions

Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
program, modified for Activities Allowed or Unallowed, Allowable
Costs/Cost Principles, and Subrecipient Monitoring

Education Stabilization Fund program, modified for Reporting

In total, we reported 22 audit findings related to 15 major federal programs at
8 state agencies. We identified over $192,000 in known questioned costs
related to federal awards. Of the 22 audit findings, 3 were repeated from prior
Single Audits. These findings have been reported for 2 to 7 years.

Of the 22 federal award audit findings, 16 related to internal control
deficiencies. We consider 5 findings of internal control deficiencies to be
material weaknesses and 11 to be significant deficiencies.

The state agencies' responses to the audit findings are included in this report.
The state agencies prepared a CAP for each audit finding and submitted them
to the OA. These are presented in the Corrective Action Plans section of this
report.

In addition, the state agencies prepared and submitted to the OA the status of
the prior audit findings. These are presented in the Summary Schedule of
Prior Audit Findings section of this report.

Expenditures of federal awards increased significantly in state fiscal years
2020 and 2021. The increases were primarily due to the additional federal
funding made available to state agencies to help pay for the state's emergency
response to the Coronavirus Disease 2019 (COVID-19).

Total Expenditures of Federal Awards
5 Year Comparison

12.03
12.54
12.32
17.08
20.64
8
9
10
11
12
13
14
15
16
17
18
19
20
21
2017
2018
2019
2020
2021
Billions ($)
State Fiscal Year

6
State of Missouri - Single Audit
Introduction and Summary
Year Ended June 30, 2021
Of the 20 state agencies and offices that expended federal awards, 6 agencies
and offices spent the majority of the awards (95 percent) during state fiscal
year 2021.

Expenditures of Federal Awards by State Agency

The state expended federal awards received from 24 federal agencies. Most
of the federal award expenditures (95 percent) were from programs of 6
federal agencies.

Expenditures of Federal Awards by Federal Agency

55%
18%
7%
6%
6%
3%
5%
Social Services
Labor and Industrial Relations
Transportation
Elementary and Secondary Education
Office of Administration
Health and Senior Services
Other
47%
17%
12%
6% 8%
5%
5%
Health and Human Services
Labor
Agriculture
Transportation
Treasury
Education
Other

7
State of Missouri - Single Audit
Introduction and Summary
Year Ended June 30, 2021
Overall, the state expended federal awards in 305 programs. These programs
are listed in the accompanying Schedule of Expenditures of Federal Awards.

The Uniform Guidance requires federal programs to be labeled Type A
programs or Type B programs based on a dollar threshold. For the State of
Missouri, the Uniform Guidance defines the dollar threshold as $30.96
million (total expenditures of $20,642,024,177 times 0.0015) since the federal
award expenditures exceeded $20 billion during state fiscal year 2021.

Programs with federal award expenditures over $30.96 million are Type A
programs and programs with federal award expenditures under $30.96
million are Type B programs. Of the 305 federal award programs, 33 were
Type A programs and 272 were Type B programs.

Type A and Type B Programs
Number of Programs

The 33 Type A programs had expenditures totaling approximately $19.9
billion, or 97 percent of total expenditures. The 272 Type B programs had
expenditures totaling approximately $708 million, or 3 percent of total
expenditures.

Type A and Type B Programs
Expenditures of Federal Awards

11%
89%
Type A Programs
Type B Programs
97%
3%
Type A Programs
Type B Programs

8
State of Missouri - Single Audit
Introduction and Summary
Year Ended June 30, 2021
The Uniform Guidance requires the auditor to perform risk assessments on
Type A programs and to audit as major each Type A program assessed as
high risk based on specified risk factors. We performed a risk assessment on
each Type A program and determined 15 of the 33 Type A programs were
low risk and did not need to be audited as major. In accordance with the
Uniform Guidance, we audited as major the 18 Type A programs assessed as
high risk.

The Uniform Guidance also requires the auditor to perform risk assessments
on larger Type B programs to determine which are high risk and need to be
audited as major. The dollar threshold to determine the larger Type B
programs is 25 percent of the Type A threshold, or $7.7 million. We
performed risk assessments on the 26 larger Type B programs and determined
2 programs were high risk. In accordance with the Uniform Guidance, we
audited the programs as major.

The programs audited as major are listed in the summary of auditor's results
section of the Schedule of Findings and Questioned Costs section of this
report. We audited 67 percent of total state fiscal year 2021 federal
expenditures.

Major and Non-major Federal Programs
Type of Programs

Number of
Programs

Expenditures
Percentage of
Expenditures
Programs Audited

  Type A major programs
18
$
13,789,892,872
  Type B major programs
2
41,329,484
      Total major programs
20
13,831,222,356
67%
Programs not Audited

  Type A non-major programs
15
6,143,784,963
  Type B non-major programs
270
   667,016,858
      Total non-major programs
285
6,810,801,821
33%
          Total programs

305

$
20,642,024,177

100%

State of Missouri
Summary of Type A Programs and Total Expenditures of Federal Awards
Year Ended June 30, 2021
AL
Number
Program or Cluster Name
Federal Grantor Agency
SNAP Cluster:
10.551
COVID-19 - Supplemental Nutrition Assistance Program
Agriculture
$
547,008,067
10.551
Supplemental Nutrition Assistance Program
Agriculture
1,165,551,473
Total Supplemental Nutrition Assistance Program
1,712,559,540
10.561
Agriculture
54,634,651
   Total SNAP Cluster
1,767,194,191
Child Nutrition Cluster:
10.553
School Breakfast Program
Agriculture
42,918,604
10.555
COVID-19 - National School Lunch Program
Agriculture
31,908,495
10.555
National School Lunch Program
Agriculture
147,506,059
Total National School Lunch Program
179,414,554
10.556
Special Milk Program for Children
Agriculture
178,672
10.559
COVID-19 - Summer Food Service Program for Children
Agriculture
28,336,789
10.559
Summer Food Service Program for Children
Agriculture
250,036,685
Total Summer Food Service Program for Children
278,373,474
10.579
Child Nutrition Discretionary Grants Limited Availability
Agriculture
380,247
   Total Child Nutrition Cluster
501,265,551
10.557
Agriculture
6,927,185
10.557
Agriculture
53,054,342
Total WIC Special Supplemental Nutrition Program for Women, Infants, and
Children
59,981,527
10.558
COVID-19 - Child and Adult Care Food Program
Agriculture
3,763,211
10.558
Child and Adult Care Food Program
Agriculture
74,322,202
Total Child and Adult Care Food Program
78,085,413
Food Distribution Cluster:
10.565
Commodity Supplemental Food Program
Agriculture
8,447,182
10.568
COVID-19 - Emergency Food Assistance Program (Administrative Costs)
Agriculture
1,886,317
10.568
Emergency Food Assistance Program (Administrative Costs)
Agriculture
1,655,524
Total Emergency Food Assistance Program (Administrative Costs)
3,541,841
10.569
Emergency Food Assistance Program (Food Commodities)
Agriculture
37,492,653
   Total Food Distribution Cluster
49,481,676
12.401
National Guard Military Operations and Maintenance (O&M) Projects
Defense
50,508,267
16.575
Crime Victim Assistance
Justice
51,911,934
17.225
COVID-19 - Unemployment Insurance
Labor
2,763,304,371
17.225
Unemployment Insurance
Labor
722,782,686
Total Unemployment Insurance
3,486,087,057
WIOA Cluster:
17.258
WIOA Adult Program
Labor
9,817,899
17.259
WIOA Youth Activities
Labor
9,361,350
17.278
WIOA Dislocated Worker Formula Grants
Labor
12,447,024
   Total WIOA Cluster
31,626,273
20.106
Transportation
1,536,003
20.106
Airport Improvement Program and COVID-19 Airports Programs
Transportation
38,820,139
Total Airport Improvement Program and COVID-19 Airports Programs
40,356,142
Highway Planning and Construction Cluster:
20.205
COVID-19 - Highway Planning and Construction
Transportation
206,248,389
20.205
Highway Planning and Construction
Transportation
1,040,190,628
Total Highway Planning and Construction
1,246,439,017
20.219
Recreational Trails Program
Transportation
2,493,258
20.224
Federal Lands Access Program
Transportation
654,715
   Total Highway Planning and Construction Cluster
1,249,586,990
Federal Awards Expended
State Administrative Matching Grants for the Supplemental Nutrition
Assistance Program
COVID-19 - WIC Special Supplemental Nutrition Program for Women, Infants,
and Children
WIC Special Supplemental Nutrition Program for Women, Infants, and Children
COVID-19 - Airport Improvement Program and COVID-19 Airports Programs
9

State of Missouri
Summary of Type A Programs and Total Expenditures of Federal Awards
Year Ended June 30, 2021
AL
Number
Program or Cluster Name
Federal Grantor Agency
Federal Awards Expended
21.019
COVID-19 - Coronavirus Relief Fund
Treasury
1,246,132,205
21.023
COVID-19 - Emergency Rental Assistance Program
Treasury
323,715,323
64.015
Veterans State Nursing Home Care
Veterans Affairs
57,442,683
Clean Water State Revolving Fund Cluster:
66.458
Capitalization Grants for Clean Water State Revolving Funds
Environmental Protection Agency
34,654,070
   Total Clean Water State Revolving Fund Cluster
34,654,070
84.010
Title I Grants to Local Educational Agencies
Education
236,361,821
Special Education Cluster (IDEA):
84.027
Special Education Grants to States
Education
228,737,367
84.173
Special Education Preschool Grants
Education
6,332,142
   Total Special Education Cluster (IDEA)
235,069,509
84.126
Rehabilitation Services Vocational Rehabilitation Grants to States
Education
65,811,774
84.367
Education
34,801,708
84.425C
COVID-19 - Governor's Emergency Education Relief (GEER) Fund
Education
37,787,301
84.425D
Education
311,615,343
84.425R
Education
2,719,128
Total Education Stabilization Fund
352,121,772
93.268
COVID-19 - Immunization Cooperative Agreements
Health and Human Services
4,112,496
93.268
Immunization Cooperative Agreements
Health and Human Services
71,624,040
Total Immunization Cooperative Agreements
75,736,536
93.323
Health and Human Services
41,754,468
93.323
Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
Health and Human Services
1,274,577
Total Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
43,029,045
93.558
Temporary Assistance for Needy Families
Health and Human Services
193,397,098
93.568
COVID-19 - Low-Income Home Energy Assistance
Health and Human Services
1,840,445
93.568
Low-Income Home Energy Assistance
Health and Human Services
77,896,593
Total Low-Income Home Energy Assistance
79,737,038
CCDF Cluster:
93.575
COVID-19 - Child Care and Development Block Grant
Health and Human Services
33,399,582
93.575
Child Care and Development Block Grant
Health and Human Services
83,387,816
Total Child Care and Development Block Grant
116,787,398
93.596
Health and Human Services
26,580,191
   Total CCDF Cluster
143,367,589
93.658
Foster Care Title IV-E
Health and Human Services
38,022,365
93.659
Adoption Assistance
Health and Human Services
50,708,111
93.667
Social Services Block Grant
Health and Human Services
51,383,271
93.767
Children's Health Insurance Program
Health and Human Services
313,483,831
COVID-19 - Epidemiology and Laboratory Capacity for Infectious Diseases
(ELC)
Supporting Effective Instruction State Grants (formerly Improving Teacher
Quality State Grants)
Child Care Mandatory and Matching Funds of the Child Care and
Development Fund
COVID-19 - Coronavirus Response and Relief Supplemental Appropriations
Act, 2021- Emergency Assistance to Non-Public Schools (CRRSA EANS)
Program
COVID-19 - Elementary and Secondary School Emergency Relief (ESSER)
Fund
10

State of Missouri
Summary of Type A Programs and Total Expenditures of Federal Awards
Year Ended June 30, 2021
AL
Number
Program or Cluster Name
Federal Grantor Agency
Federal Awards Expended
Medicaid Cluster:
93.775
State Medicaid Fraud Control Units
Health and Human Services
1,810,624
93.777
Health and Human Services
1,324,432
93.777
Health and Human Services
17,342,972
Total State Survey and Certification of Health Care Providers and Suppliers
(Title XVIII) Medicare
18,667,404
93.778
COVID-19 - Medical Assistance Program
Health and Human Services
678,681,707
93.778
Medical Assistance Program
Health and Human Services
7,745,998,573
Total Medical Assistance Program
8,424,680,280
   Total Medicaid Cluster
8,445,158,308
Disability Insurance/SSI Cluster:
96.001
Social Security Disability Insurance
Social Security Administration
45,546,858
   Total Disability Insurance/SSI Cluster
45,546,858
97.036
Homeland Security
96,288
97.036
Disaster Grants - Public Assistance (Presidentially Declared Disasters)
Homeland Security
201,057,747
Total Disaster Grants - Public Assistance (Presidentially Declared Disasters)
201,154,035
97.050
Homeland Security
300,757,864
   Total Type A Programs (expenditures greater than $30,963,036)
19,933,677,835
   Total Type B Programs (expenditures less than $30,963,036)
708,346,342
   Total Expenditures of Federal Awards
$
20,642,024,177
COVID-19 - State Survey and Certification of Health Care Providers and
Suppliers (Title XVIII) Medicare
State Survey and Certification of Health Care Providers and Suppliers (Title
XVIII) Medicare
COVID-19 -  Disaster Grants - Public Assistance (Presidentially Declared
Disasters)
COVID-19 - Presidential Declared Disaster Assistance to Individuals and
Households - Other Needs
11

NICOLE GALLOWAY, CPA
Missouri State Auditor

P.O. Box 869    Jefferson City, MO 65102    (573) 751-4213    FAX (573) 751-7984
12

INDEPENDENT AUDITOR'S REPORT ON COMPLIANCE
FOR EACH MAJOR FEDERAL PROGRAM; REPORT ON INTERNAL CONTROL OVER
COMPLIANCE; AND REPORT ON THE SCHEDULE OF EXPENDITURES OF FEDERAL
AWARDS REQUIRED BY THE UNIFORM GUIDANCE

Honorable Michael L. Parson, Governor
and
Members of the General Assembly

Report on Compliance for Each Major Federal Program

We have audited the State of Missouri's compliance with the types of compliance requirements
described in the U.S. Office of Management and Budget (OMB) Compliance Supplement that could have
a direct and material effect on each of the state's major federal programs for the year ended June 30, 2021.
The state's major federal programs are identified in the summary of auditor's results section of the
accompanying Schedule of Findings and Questioned Costs.

The state's basic financial statements include the operations of certain public universities and other
component units which expended federal awards that are not included in the state's Schedule of
Expenditures of Federal Awards for the year ended June 30, 2021. Our audit, described below, did not
include the operations of these component units since they engaged other auditors to perform an audit of
compliance, if required.

Management's Responsibility

The state's management is responsible for compliance with federal statutes, regulations, and the
terms and conditions of its federal awards applicable to its federal programs.

Auditor's Responsibility

Our responsibility is to express an opinion on compliance for each of the state's major federal
programs based on our audit of the types of compliance requirements referred to above. We conducted our
audit of compliance in accordance with auditing standards generally accepted in the United States of
America; the standards applicable to financial audits contained in Government Auditing Standards, issued
by the Comptroller General of the United States; and the audit requirements of Title 2 U.S. Code of Federal
Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for
Federal Awards (Uniform Guidance). Those standards and the Uniform Guidance require that we plan and
perform the audit to obtain reasonable assurance about whether noncompliance with the types of
compliance requirements referred to above that could have a direct and material effect on a major federal
program occurred. An audit includes examining, on a test basis, evidence about the state's compliance with
those requirements and performing such other procedures as we considered necessary in the circumstances.

13
We believe that our audit provides a reasonable basis for our qualified and unmodified opinions on
compliance for major federal programs. However, our audit does not provide a legal determination of the
state's compliance.

Basis for Qualified Opinion on Certain Major Federal Programs

As described in the accompanying Schedule of Findings and Questioned Costs, the state did not
comply with requirements regarding the following:

Finding
Number
AL
Number(s)
Program (or Cluster) Name
Compliance Requirement(s)
2021-001
21.023
Emergency Rental Assistance Program
Subrecipient Monitoring
2021-003
21.023
Emergency Rental Assistance Program
Reporting
2021-004
93.767
93.775
93.777
93.778
Children's Health Insurance Program
and Medicaid Cluster
Special Tests and Provisions
2021-009
93.323
Epidemiology and Laboratory
Capacity for Infectious Diseases (ELC)
Activities Allowed or Unallowed,
Allowable Costs/Cost Principles
2021-010
93.323
Epidemiology and Laboratory
Capacity for Infectious Diseases (ELC)
Subrecipient Monitoring
2021-015
84.425C
84.425D
84.425R
Education Stabilization Fund
Reporting
2021-016
84.425C
84.425D
84.425R
Education Stabilization Fund
Reporting

Compliance with such requirements is necessary, in our opinion, for the state to comply with the
requirements applicable to those programs.

Qualified Opinion on Certain Major Federal Programs

In our opinion, except for the noncompliance described in the "Basis for Qualified Opinion"
paragraph, the state complied, in all material respects, with the types of compliance requirements referred
to above that could have a direct and material effect on the Emergency Rental Assistance Program, the
Children's Health Insurance Program, the Medicaid Cluster, the Epidemiology and Laboratory Capacity for
Infectious Diseases (ELC) program, and the Education Stabilization Fund program for the year ended
June 30, 2021.

Unmodified Opinion on Each of the Other Major Federal Programs

In our opinion, the state complied, in all material respects, with the types of compliance
requirements referred to above that could have a direct and material effect on each of its other major federal
programs identified in the summary of auditor's results section of the accompanying Schedule of Findings
and Questioned Costs for the year ended June 30, 2021.

Other Matters

The results of our auditing procedures disclosed other instances of noncompliance which are
required to be reported in accordance with the Uniform Guidance and which are described in the
accompanying Schedule of Findings and Questioned Costs as finding numbers 2021-005 through 2021-

14
008, 2021-012, and 2021-017 through 2021-022. Our opinion on each major federal program is not
modified with respect to these matters.

The state's responses to and corrective action plans for the noncompliance findings identified in
our audit are included in the accompanying Schedule of Findings and Questioned Costs and Corrective
Action Plans. The state's responses and corrective action plans were not subjected to the auditing procedures
applied in the audit of compliance and, accordingly, we express no opinion on them.

Report on Internal Control over Compliance

Management of the state is responsible for establishing and maintaining effective internal control
over compliance with the types of compliance requirements referred to above. In planning and performing
our audit of compliance, we considered the state's internal control over compliance with the types of
requirements that could have a direct and material effect on each major federal program to determine the
auditing procedures that are appropriate in the circumstances for the purpose of expressing an opinion on
compliance for each major federal program and to test and report on internal control over compliance in
accordance with the Uniform Guidance, but not for the purpose of expressing an opinion on the
effectiveness of internal control over compliance. Accordingly, we do not express an opinion on the
effectiveness of the state's internal control over compliance.

Our consideration of internal control over compliance was for the limited purpose described in the
preceding paragraph and was not designed to identify all deficiencies in internal control over compliance
that might be material weaknesses or significant deficiencies and therefore, material weaknesses or
significant deficiencies may exist that were not identified. However, as discussed below, we did identify
certain deficiencies in internal control over compliance that we consider to be material weaknesses and
significant deficiencies.

A deficiency in internal control over compliance exists when the design or operation of a control
over compliance does not allow management or employees, in the normal course of performing their
assigned functions, to prevent, or detect and correct, noncompliance with a type of compliance requirement
of a federal program on a timely basis. A material weakness in internal control over compliance is a
deficiency, or combination of deficiencies, in internal control over compliance, such that there is reasonable
possibility that material noncompliance with a type of compliance requirement of a federal program will
not be prevented, or detected and corrected, on a timely basis. We consider the deficiencies in internal
control over compliance described in the accompanying Schedule of Findings and Questioned Costs as
finding numbers 2021-001, 2021-003, 2021-004, 2021-009, and 2021-010 to be material weaknesses.

A significant deficiency in internal control over compliance is a deficiency, or combination of
deficiencies, in internal control over compliance with a type of compliance requirement of a federal program
that is less severe than a material weakness in internal control over compliance, yet important enough to
merit attention by those charged with governance. We consider the deficiencies in internal control over
compliance described in the accompanying Schedule of Findings and Questioned Costs as finding numbers
2021-005 through 2021-008, 2021-012, and 2021-017 through 2021-022 to be significant deficiencies.

The state's responses to and corrective action plans for the internal control over compliance findings
identified in our audit are described in the accompanying Schedule of Findings and Questioned Costs and
Corrective Action Plans. The state's responses and corrective action plans were not subjected to the auditing
procedures applied in the audit of compliance and, accordingly, we express no opinion on them.

The purpose of this report on internal control over compliance is solely to describe the scope of our
testing of internal control over compliance and the results of that testing based on the requirements of the

15
Uniform Guidance. Accordingly, this report is not suitable for any other purpose. However, pursuant to
Section 29.200, RSMo, this report is a matter of public record and its distribution is not limited.

Report on the Schedule of Expenditures of Federal Awards Required by the Uniform Guidance

We have audited the financial statements of the governmental activities, the business-type
activities, the aggregate discretely presented component units, each major fund, and the aggregate
remaining fund information of the state, as of and for the year ended June 30, 2021, and the related notes
to financial statements, which collectively comprise the state's basic financial statements. We issued our
report thereon dated January 21, 2022, which contained qualified opinions on the governmental activities
and the General Fund, a major fund, and unmodified opinions on all remaining opinion units.

Our audit was conducted for the purpose of forming opinions on the financial statements that
collectively comprise the state's basic financial statements. The accompanying Schedule of Expenditures
of Federal Awards is presented for purposes of additional analysis as required by the Uniform Guidance
and is not a required part of the basic financial statements. Such information is the responsibility of
management and was derived from and relates directly to the underlying accounting and other records used
to prepare the basic financial statements. The information has been subjected to the auditing procedures
applied in the audit of the basic financial statements and certain additional procedures, including comparing
and reconciling such information directly to the underlying accounting and other records used to prepare
the basic financial statements or to the financial statements themselves, and other additional procedures in
accordance with auditing standards generally accepted in the United States of America. In our opinion, the
Schedule of Expenditures of Federal Awards is fairly stated, in all material respects, in relation to the basic
financial statements as a whole.

Nicole R. Galloway, CPA
State Auditor

June 30, 2022, except for our report
on the Schedule of Expenditures of
Federal Awards, for which the date is
January 21, 2022

State of Missouri
Schedule of Expenditure of Federal Awards
Year Ended June 30, 2021
Federal Awards
Amount Provided
Number
Federal Grantor Agency - Program or Cluster Name
Expended
to Subrecipients
Department of Agriculture
10.025
Plant and Animal Disease, Pest Control, and Animal Care
$
794,936 $
-
10.069
Conservation Reserve Program
465,809
-
10.093
Voluntary Public Access and Habitat Incentive Program
365,254
-
10.125
Hazardous Waste Management
29,642
-
10.153
Market News
15,771
-
10.163
Market Protection and Promotion
45,732
-
10.170
Specialty Crop Block Grant Program - Farm Bill
342,440
310,001
10.171
Organic Certification Cost Share Programs
12,312
10,932
10.178
Trade Mitigation Program Eligible Recipient Agency Operational Funds
655,815
655,815
10.304
Homeland Security Agricultural
75,670
-
10.351
Rural Business Development Grant
21,096
-
10.435
State Mediation Grants
6,925
-
10.475
Cooperative Agreements with States for Intrastate Meat and Poultry Inspection
1,213,324
-
10.479
Food Safety Cooperative Agreements
256,038
-
10.542
COVID-19 - Pandemic EBT Food Benefits
4,075,997
-
SNAP Cluster:
10.551
COVID-19 - Supplemental Nutrition Assistance Program
547,008,067
-
10.551
Supplemental Nutrition Assistance Program
1,165,551,473
-
Total Supplemental Nutrition Assistance Program
1,712,559,540
-
10.561
State Administrative Matching Grants for the Supplemental Nutrition Assistance Program
54,634,651
11,892,226
Total SNAP Cluster
1,767,194,191
11,892,226
Child Nutrition Cluster:
10.553
School Breakfast Program
42,918,604
42,918,604
10.555
COVID-19 - National School Lunch Program
31,908,495
31,908,495
10.555
National School Lunch Program
147,506,059
147,506,059
Total National School Lunch Program
179,414,554
179,414,554
10.556
Special Milk Program for Children
178,672
178,672
10.559
COVID-19 - Summer Food Service Program for Children
28,336,789
28,256,161
10.559
Summer Food Service Program for Children
250,036,685
249,679,139
Total Summer Food Service Program for Children
278,373,474
277,935,300
10.579
Child Nutrition Discretionary Grants Limited Availability
380,247
374,445
Total Child Nutrition Cluster
501,265,551
500,821,575
10.557
COVID-19 - WIC Special Supplemental Nutrition Program for Women, Infants, and Children
6,927,185
2,694,346
10.557
WIC Special Supplemental Nutrition Program for Women, Infants, and Children
53,054,342
22,698,333
Total WIC Special Supplemental Nutrition Program for Women, Infants, and Children
59,981,527
25,392,679
10.558
COVID-19 - Child and Adult Care Food Program
3,763,211
3,763,211
10.558
Child and Adult Care Food Program
74,322,202
73,236,185
Total Child and Adult Care Food Program
78,085,413
76,999,396
10.560
State Administrative Expenses for Child Nutrition
4,124,702
1,479,345
Food Distribution Cluster:
10.565
Commodity Supplemental Food Program
8,447,182
1,929,018
10.568
COVID-19 - Emergency Food Assistance Program (Administrative Costs)
1,886,317
1,886,317
10.568
Emergency Food Assistance Program (Administrative Costs)
1,655,524
1,556,631
Total Emergency Food Assistance Program (Administrative Costs)
3,541,841
3,442,948
10.569
Emergency Food Assistance Program (Food Commodities)
37,492,653
31,631
Total Food Distribution Cluster
49,481,676
5,403,597
10.574
Team Nutrition Grants
74,528
5,710
10.576
Senior Farmers Market Nutrition Program
83,325
83,325
10.578
WIC Grants To States (WGS)
2,332,240
761,795
10.582
Fresh Fruit and Vegetable Program
2,328,772
2,328,772
10.649
COVID-19 - Pandemic EBT Administrative Costs
3,333,403
-
10.664
Cooperative Forestry Assistance
1,315,431
407,946
Forest Service Schools and Roads Cluster:
10.665
Schools and Roads - Grants to States
1,527,218
1,527,218
Total Forest Service Schools and Roads Cluster
1,527,218
1,527,218
10.674
Wood Utilization Assistance
190,000
190,000
10.680
Forest Health Protection
8,748
-
10.698
State & Private Forestry Cooperative Fire Assistance
352,786
352,786
10.902
Soil and Water Conservation
1,581,660
769,094
Total Department of Agriculture
2,481,637,932
629,392,212
Department of Commerce
11.549
State and Local Implementation Grant Program
19,166
-
Total Department of Commerce
19,166
-
Department of Defense
12.U01
Excess Property Program
627,945
-
12.112
Payments to States in Lieu of Real Estate Taxes
1,578,468
1,578,468
12.113
State Memorandum of Agreement Program for the Reimbursement of Technical Services
700,317
-
AL
16

State of Missouri
Schedule of Expenditure of Federal Awards
Year Ended June 30, 2021
Federal Awards
Amount Provided
Number
Federal Grantor Agency - Program or Cluster Name
Expended
to Subrecipients
AL
12.401
National Guard Military Operations and Maintenance (O&M) Projects
50,508,267
-
12.620
Troops to Teachers Grant Program
72,838
-
Total Department of Defense
53,487,835
1,578,468
Department of Housing and Urban Development
14.228
320
-
14.228
Community Development Block Grants/State's program and Non-Entitlement Grants in Hawaii
28,547,228
26,904,181
Total Community Development Block Grants/State's program and Non-Entitlement Grants in
Hawaii
28,547,548
26,904,181
14.231
COVID-19 - Emergency Solutions Grant Program
15,973,768
15,973,768
14.231
Emergency Solutions Grant Program
3,152,828
3,134,117
Total Emergency Solutions Grant Program
19,126,596
19,107,885
14.241
Housing Opportunities for Persons with AIDS
1,142,827
1,142,827
14.267
Continuum of Care Program
12,515,098
-
Total Department of Housing and Urban Development
61,332,069
47,154,893
Department of the Interior
15.250
Regulation of Surface Coal Mining and Surface Effects of Underground Coal Mining
166,871
-
15.252
Abandoned Mine Land Reclamation (AMLR)
2,090,437
1,339,116
15.433
Flood Control Act Lands
27,555
27,555
15.438
National Forest Acquired Lands
2,617,633
2,617,633
Fish and Wildlife Cluster:
15.605
Sport Fish Restoration
8,095,532
180,099
15.611
Wildlife Restoration and Basic Hunter Education
18,556,005
310,951
Total Fish and Wildlife Cluster
26,651,537
491,050
15.608
Fish and Wildlife Management Assistance
447,126
149,159
15.615
Cooperative Endangered Species Conservation Fund
338,518
74,487
15.634
State Wildlife Grants
1,119,090
88,552
15.647
Migratory Bird Conservation
29,710
-
15.657
Endangered Species Recovery Implementation
412
-
15.658
Natural Resource Damage Assessment and Restoration
1,330
-
15.684
White-nose Syndrome National Response Implementation
12,793
-
15.808
U.S. Geological Survey Research and Data Collection
107,407
-
15.810
National Cooperative Geologic Mapping
230,038
-
15.814
National Geological and Geophysical Data Preservation
93,189
-
15.904
Historic Preservation Fund Grants-In-Aid
1,031,199
203,563
15.916
Outdoor Recreation Acquisition, Development and Planning
1,725,363
1,674,085
15.978
Upper Mississippi River Restoration Long Term Resource Monitoring
476,493
-
15.980
National Ground-Water Monitoring Network
55,723
-
15.981
Water Use and Data Research
24,668
-
Total Department of the Interior
37,247,092
6,665,200
Department of Justice
16.U01
FBI Joint Terrorism Task Force
3,848
-
16.017
Sexual Assault Services Formula Program
381,101
369,031
16.034
COVID-19 - Coronavirus Emergency Supplemental Funding Program
14,635
-
16.540
Juvenile Justice and Delinquency Prevention
995,799
767,560
16.550
State Justice Statistics Program for Statistical Analysis Centers
65,461
-
16.554
National Criminal History Improvement Program (NCHIP)
966,318
817,989
16.575
Crime Victim Assistance
51,911,934
50,087,674
16.576
Crime Victim Compensation
4,147,700
4,147,700
16.582
Crime Victim Assistance/Discretionary Grants
40,520
-
16.585
Drug Court Discretionary Grant Program
285,532
-
16.588
Violence Against Women Formula Grants
2,698,951
2,504,730
16.593
Residential Substance Abuse Treatment for State Prisoners
275,966
106,826
16.606
State Criminal Alien Assistance Program
13,570
-
16.607
Bulletproof Vest Partnership Program
4,298
4,298
16.609
Project Safe Neighborhoods
151,949
135,696
16.710
Public Safety Partnership and Community Policing Grants
173,588
-
16.738
Edward Byrne Memorial Justice Assistance Grant Program
3,628,588
3,239,744
16.741
DNA Backlog Reduction Program
348,293
-
16.742
Paul Coverdell Forensic Sciences Improvement Grant Program
167,514
163,264
16.750
Support for Adam Walsh Act Implementation Grant Program
4,790
-
16.812
Second Chance Act Reentry Initiative
81,253
81,253
16.813
NICS Act Record Improvement Program
900,747
826,987
16.833
National Sexual Assault Kit Initiative
1,444,658
-
16.839
STOP School Violence
108,855
76,712
16.922
Equitable Sharing Program
410,791
-
Total Department of Justice
69,226,659
63,329,464
COVID-19 - Community Development Block Grants/State's program and Non-Entitlement Grants
in Hawaii
17

State of Missouri
Schedule of Expenditure of Federal Awards
Year Ended June 30, 2021
Federal Awards
Amount Provided
Number
Federal Grantor Agency - Program or Cluster Name
Expended
to Subrecipients
AL
Department of Labor
17.002
Labor Force Statistics
958,265
-
17.005
Compensation and Working Conditions
312,736
-
Employment Service Cluster:
17.207
Employment Service/Wagner-Peyser Funded Activities
9,573,875
-
17.801
Jobs for Veterans State Grants
2,020,723
-
17.804
Local Veterans' Employment Representative Program
1,273,592
-
Total Employment Service Cluster
12,868,190
-
17.225
COVID-19 - Unemployment Insurance
2,763,304,371
-
17.225
Unemployment Insurance
722,782,686
-
Total Unemployment Insurance
3,486,087,057
-
17.235
Senior Community Service Employment Program
1,888,875
1,856,289
17.245
Trade Adjustment Assistance
3,132,472
-
WIOA Cluster:
17.258
WIOA Adult Program
9,817,899
8,581,782
17.259
WIOA Youth Activities
9,361,350
8,893,404
17.278
WIOA Dislocated Worker Formula Grants
12,447,024
9,825,036
Total WIOA Cluster
31,626,273
27,300,222
17.261
WIOA Pilots, Demonstrations, and Research Projects
615,475
-
17.271
Work Opportunity Tax Credit Program (WOTC)
233,420
-
17.273
Temporary Labor Certification for Foreign Workers
115,678
-
17.277
COVID-19 - WIOA National Dislocated Worker Grants / WIA National Emergency Grants
424,936
383,103
17.277
WIOA National Dislocated Worker Grants / WIA National Emergency Grants
941,048
917,962
Total WIOA National Dislocated Worker Grants / WIA National Emergency Grants
1,365,984
1,301,065
17.285
Apprenticeship USA Grants
916,487
327,990
17.504
Consultation Agreements
1,413,161
-
17.600
Mine Health and Safety Grants
416,036
-
Total Department of Labor
3,541,950,109
30,785,566
Department of Transportation
20.106
COVID-19 - Airport Improvement Program and COVID-19 Airports Programs
1,536,003
1,536,003
20.106
Airport Improvement Program and COVID-19 Airports Programs
38,820,139
38,820,139
Total Airport Improvement Program and COVID-19 Airports Programs
40,356,142
40,356,142
Highway Planning and Construction Cluster:
20.205
COVID-19 - Highway Planning and Construction
206,248,389
-
20.205
Highway Planning and Construction
1,040,190,628
101,017,191
Total Highway Planning and Construction
1,246,439,017
101,017,191
20.219
Recreational Trails Program
2,493,258
2,285,916
20.224
Federal Lands Access Program
654,715
654,715
Total Highway Planning and Construction Cluster
1,249,586,990
103,957,822
20.232
Commercial Driver's License Program Implementation Grant
63,647
-
20.240
Fuel Tax Evasion-Intergovernmental Enforcement Effort
9,849
-
Federal Transit Cluster:
20.500
Federal Transit Capital Investment Grants
25,933
25,933
20.526
Buses and Bus Facilities Formula, Competitive, and Low or No Emissions Programs
496,554
496,554
Total Federal Transit Cluster
522,487
522,487
20.505
Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research
124,486
83,172
20.509
COVID-19 - Formula Grants for Rural Areas and Tribal Transit Program
19,852,770
19,852,770
20.509
Formula Grants for Rural Areas and Tribal Transit Program
2,350,118
1,539,067
Total Formula Grants for Rural Areas and Tribal Transit Program
22,202,888
21,391,837
Transit Services Programs Cluster:
20.513
Enhanced Mobility of Seniors and Individuals with Disabilities
915,635
750,548
Total Transit Services Programs Cluster
915,635
750,548
20.528
355,017
257,118
Highway Safety Cluster:
20.600
State and Community Highway Safety
5,587,517
4,622,938
20.616
National Priority Safety Programs
4,652,497
3,624,542
Total Highway Safety Cluster
10,240,014
8,247,480
20.607
Alcohol Open Container Requirements
4,843,016
4,843,016
20.614
201,132
-
20.615
E-911 Grant Program
372,469
331,476
20.700
Pipeline Safety Program State Base Grant
701,814
-
20.703
Interagency Hazardous Materials Public Sector Training and Planning Grants
287,994
225,879
20.720
State Damage Prevention Program Grants
71,574
-
20.721
PHMSA Pipeline Safety Program One Call Grant
7,790
-
Total Department of Transportation
1,330,862,944
180,966,977
Rail Fixed Guideway Public Transportation System State Safety Oversight Formula Grant
National Highway Traffic Safety Administration (NHTSA) Discretionary Safety Grants and
Cooperative Agreements
18

State of Missouri
Schedule of Expenditure of Federal Awards
Year Ended June 30, 2021
Federal Awards
Amount Provided
Number
Federal Grantor Agency - Program or Cluster Name
Expended
to Subrecipients
AL
Department of the Treasury
21.019
COVID-19 - Coronavirus Relief Fund
1,246,132,205
8,372,483
21.023
COVID-19 - Emergency Rental Assistance Program
323,715,323
323,715,323
21.026
COVID-19 - Homeowner Assistance Fund
13,826,934
13,826,934
Total Department of the Treasury
1,583,674,462
345,914,740
Equal Employment Opportunity Commission
30.001
Employment Discrimination Title VII of the Civil Rights Act of 1964
350,730
-
Total Equal Employment Opportunity Commission
350,730
-
General Services Administration
39.003
Donation of Federal Surplus Personal Property
1,678,749
1,376,706
Total General Services Administration
1,678,749
1,376,706
National Endowment for the Arts
45.025
COVID-19 - Promotion of the Arts Partnership Agreements
405,346
405,346
45.025
Promotion of the Arts Partnership Agreements
779,700
611,080
Total Promotion of the Arts Partnership Agreements
1,185,046
1,016,426
45.301
Museums for America
7,299
-
45.310
COVID-19 - Grants to States
271,461
271,461
45.310
Grants to States
2,704,063
1,820,376
Total Grants to States
2,975,524
2,091,837
Total National Endowments for the Arts
4,167,869
3,108,263
Small Business Administration
59.061
State Trade Expansion
229,431
105,874
Total Small Business Administration
229,431
105,874
Department of Veterans Affairs
64.005
Grants to States for Construction of State Home Facilities
1,225,559
-
64.015
Veterans State Nursing Home Care
57,442,683
-
64.024
VA Homeless Providers Grant and Per Diem Program
855,994
-
64.101
Burial Expenses Allowance for Veterans
1,190,145
-
64.115
Veterans Information and Assistance
584,403
-
Total Department of Veterans Affairs
61,298,784
-
Environmental Protection Agency
66.032
State Indoor Radon Grants
58,906
-
66.034
572,904
-
66.040
Diesel Emissions Reduction Act (DERA) State Grants
611,807
384,808
66.204
Multipurpose Grants to States and Tribes
28,517
-
66.419
Water Pollution Control State, Interstate, and Tribal Program Support
162,952
-
66.433
State Underground Water Source Protection
126,254
-
66.436
67,196
67,196
66.442
495,369
495,369
66.444
103,560
-
66.454
Water Quality Management Planning
354,126
141,610
Clean Water State Revolving Fund Cluster:
66.458
Capitalization Grants for Clean Water State Revolving Funds
34,654,070
31,159,567
Total Clean Water State Revolving Fund Cluster
34,654,070
31,159,567
66.460
Nonpoint Source Implementation Grants
1,521,372
1,491,449
Drinking Water State Revolving Fund Cluster:
66.468
Capitalization Grants for Drinking Water State Revolving Funds
13,997,501
7,997,362
Total Drinking Water State Revolving Fund Cluster
13,997,501
7,997,362
66.605
Performance Partnership Grants
13,604,331
257,358
66.707
TSCA Title IV State Lead Grants Certification of Lead-Based Paint Professionals
164,527
-
66.802
Superfund State, Political Subdivision, and Indian Tribe Site-Specific Cooperative Agreements
1,699,071
377,306
66.804
Underground Storage Tank (UST) Prevention, Detection, and Compliance Program
411,930
62,400
66.805
Leaking Underground Storage Tank Trust Fund Corrective Action Program
919,603
22,874
66.817
State and Tribal Response Program Grants
1,054,130
-
66.818
16,266
-
Total Environmental Protection Agency
70,624,392
42,457,299
Department of Energy
81.041
State Energy Program
789,825
-
81.042
Weatherization Assistance for Low-Income Persons
6,863,649
6,080,123
81.119
State Energy Program Special Projects
68,279
-
Assistance for Small and Disadvantaged Communities Drinking Water Grant Program (SDWA
1459A)
Surveys, Studies, Investigations, Demonstrations, and Training Grants and Cooperative
Agreements- Sections 104(b)(3) of the Clean Water Act
Brownfields Multipurpose, Assessment, Revolving Loan Fund, and Cleanup Cooperative
Surveys, Studies, Research, Investigations, Demonstrations, and Special Purpose Activities
Relating to the Clean Air Act
Lead Testing in School and Child Care Program Drinking Water (SDWA 1464(d))
19

State of Missouri
Schedule of Expenditure of Federal Awards
Year Ended June 30, 2021
Federal Awards
Amount Provided
Number
Federal Grantor Agency - Program or Cluster Name
Expended
to Subrecipients
AL
81.136
Long-Term Surveillance and Maintenance
61,471
-
81.138
State Heating Oil and Propane Program
4,098
-
Total Department of Energy
7,787,322
6,080,123
Department of Education
84.002
Adult Education - Basic Grants to States
8,274,683
7,242,071
84.010
Title I Grants to Local Educational Agencies
236,361,821
234,377,199
84.011
Migrant Education State Grant Program
864,797
854,422
84.013
Title I State Agency Program for Neglected and Delinquent Children and Youth
2,196,397
2,183,737
Special Education Cluster (IDEA):
84.027
Special Education Grants to States
228,737,367
206,005,233
84.173
Special Education Preschool Grants
6,332,142
6,332,142
Total Special Education Cluster (IDEA)
235,069,509
212,337,375
84.032
Federal Family Education Loans
17,762,033
-
84.048
Career and Technical Education -- Basic Grants to States
22,056,879
20,329,341
84.126
Rehabilitation Services Vocational Rehabilitation Grants to States
65,811,774
-
84.177
Rehabilitation Services Independent Living Services for Older Individuals Who are Blind
595,630
-
84.181
Special Education-Grants for Infants and Families
9,716,948
-
84.187
Supported Employment Services for Individuals with the Most Significant Disabilities
541,078
-
84.196
Education for Homeless Children and Youth
1,189,371
1,187,937
84.224
Assistive Technology
517,139
517,139
84.287
Twenty-First Century Community Learning Centers
17,583,216
17,224,043
84.323
Special Education - State Personnel Development
1,066,370
-
84.325
179,647
-
84.326
151,559
-
84.358
Rural Education
2,581,668
2,447,121
84.365
English Language Acquisition State Grants
4,760,247
4,522,319
84.367
Supporting Effective Instruction State Grants (formerly Improving Teacher Quality State Grants)
34,801,708
32,218,880
84.369
Grants for State Assessments and Related Activities
6,715,095
-
84.371
Comprehensive Literacy Development
297,790
256,440
84.377
School Improvement Grants
4,372,414
3,797,460
84.424
Student Support and Academic Enrichment Program
17,501,192
17,313,117
84.425C
COVID-19 - Governor's Emergency Education Relief (GEER) Fund
37,787,301
29,493,818
84.425D
COVID-19 - Elementary and Secondary School Emergency Relief (ESSER) Fund
311,615,343
306,854,615
84.425R
2,719,128
2,711,956
Total Education Stabilization Fund
352,121,772
339,060,389
84.902
National Assessment of Educational Progress
105,685
-
Total Department of Education
1,043,196,422
895,868,990
National Archives and Records Administration
89.003
National Historical Publications and Records Grants
11,310
8,560
Total National Archives and Records Administration
11,310
8,560
Elections Assistance Commission
90.404
COVID-19 - 2018 HAVA Election Security Grants
3,834,944
384,797
90.404
2018 HAVA Election Security Grants
820,954
2,648
Total 2018 HAVA Election Security Grants
4,655,898
387,445
Total Elections Assistance Commission
4,655,898
387,445
Department of Health and Human Services
93.041
103,863
23,032
93.042
245,603
222,044
93.042
337,238
133,833
Total Special Programs for the Aging, Title VII, Chapter 2, Long Term Care Ombudsman
Services for Older Individuals
582,841
355,877
93.043
385,044
362,167
Aging Cluster:
93.044
COVID-19 Special Programs for the Aging, Title III, Part B, Grants for Supportive Services and
Senior Centers
2,519,278
2,519,278
93.044
Special Programs for the Aging, Title III, Part B, Grants for Supportive Services and Senior
Centers
5,715,809
5,411,208
Total Special Programs for the Aging, Title III, Part B, Grants for Supportive Services and
Senior Centers
8,235,087
7,930,486
Special Programs for the Aging, Title III, Part D, Disease Prevention and Health Promotion
Services
COVID-19 - Coronavirus Response and Relief Supplemental Appropriations Act, 2021-
Emergency Assistance to Non-Public Schools (CRRSA EANS) Program
Special Programs for the Aging, Title VII, Chapter 3, Programs for Prevention of Elder Abuse,
Neglect, and Exploitation
Special Education - Personnel Development to Improve Services and Results for Children with
Disabilities
Special Education Technical Assistance and Dissemination to Improve Services and Results for
Children with Disabilities
Special Programs for the Aging, Title VII, Chapter 2, Long Term Care Ombudsman Services for
Older Individuals
COVID-19 - Special Programs for the Aging, Title VII, Chapter 2, Long Term Care Ombudsman
Services for Older Individuals
20

State of Missouri
Schedule of Expenditure of Federal Awards
Year Ended June 30, 2021
Federal Awards
Amount Provided
Number
Federal Grantor Agency - Program or Cluster Name
Expended
to Subrecipients
AL
93.045
COVID-19 - Special Programs for the Aging, Title III, Part C, Nutrition Services
10,727,307
10,727,307
93.045
7,100,680
6,645,030
Total Special Programs for the Aging, Title III, Part C, Nutrition Services
17,827,987
17,372,337
93.053
Nutrition Services Incentive Program
2,885,997
2,885,997
Total Aging Cluster
28,949,071
28,188,820
93.052
COVID-19 - National Family Caregiver Support, Title III, Part E
1,276,240
1,276,240
93.052
National Family Caregiver Support, Title III, Part E
1,827,655
1,655,222
Total National Family Caregiver Support, Title III, Part E
3,103,895
2,931,462
93.069
Public Health Emergency Preparedness
8,789,578
4,852,327
93.070
Environmental Public Health and Emergency Response
1,600,990
440,087
93.071
Medicare Enrollment Assistance Program
533,069
196,915
93.079
32,445
32,445
93.090
Guardianship Assistance
10,294,526
-
93.092
Affordable Care Act (ACA) Personal Responsibility Education Program
652,857
466,851
93.093
Health Profession Opportunity Grants
2,399,797
2,365,256
93.103
Food and Drug Administration Research
2,069,302
-
93.104
339,759
-
93.110
Maternal and Child Health Federal Consolidated Programs
551,568
-
93.116
Project Grants and Cooperative Agreements for Tuberculosis Control Programs
574,165
162,593
93.118
Acquired Immunodeficiency Syndrome (AIDS) Activity
144,827
-
93.130
240,854
84,003
93.136
COVID-19 - Injury Prevention and Control Research and State and Community Based Programs
21,374
93.136
Injury Prevention and Control Research and State and Community Based Programs
3,663,615
1,139,351
Total Injury Prevention and Control Research and State and Community Based Programs
3,684,989
1,139,351
93.150
Projects for Assistance in Transition from Homelessness (PATH)
835,911
-
93.165
Grants to States for Loan Repayment
450,000
450,000
93.184
Disabilities Prevention
135,747
112,343
93.197
440,274
-
93.234
Traumatic Brain Injury State Demonstration Grant Program
172,641
134,057
93.235
Title V State Sexual Risk Avoidance Education (Title V State SRAE) Program
848,692
644,975
93.236
Grants to States to Support Oral Health Workforce Activities
125,637
-
93.240
State Capacity Building
340,956
-
93.241
State Rural Hospital Flexibility Program
337,728
191,233
93.243
Substance Abuse and Mental Health Services Projects of Regional and National Significance
5,856,570
156,192
93.251
COVID-19 - Early Hearing Detection and Intervention
9,153
-
93.251
Early Hearing Detection and Intervention
201,051
105,341
Total Early Hearing Detection and Intervention
210,204
105,341
93.268
COVID-19 - Immunization Cooperative Agreements
4,112,496
1,245,591
93.268
Immunization Cooperative Agreements
71,624,040
275,582
Total Immunization Cooperative Agreements
75,736,536
1,521,173
93.270
Viral Hepatitis Prevention and Control
210,238
4,915
93.301
COVID-19 - Small Rural Hospital Improvement Grant Program
3,259,290
3,259,290
93.301
Small Rural Hospital Improvement Grant Program
497,276
433,227
Total Small Rural Hospital Improvement Grant Program
3,756,566
3,692,517
93.305
1,257,702
358,957
93.310
COVID-19 - Trans-NIH Research Support
235,585
114,576
93.314
Early Hearing Detection and Intervention Information System (EHDI-IS) Surveillance Program
91,663
-
93.323
COVID-19 - Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
41,754,468
22,684,825
93.323
Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
1,274,577
48,767
Total Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
43,029,045
22,733,592
93.324
State Health Insurance Assistance Program
1,036,368
-
93.336
Behavioral Risk Factor Surveillance System
184,015
-
93.345
Leading Edge Acceleration Projects (LEAP) in Health Information Technology
133,814
-
93.354
1,664,374
-
93.366
379,791
112,944
93.367
380,374
-
93.369
ACL Independent Living State Grants
288,253
206,913
93.387
National and State Tobacco Control Program
931,727
23,877
93.426
1,947,057
1,139,483
93.434
Every Student Succeeds Act/Preschool Development Grants
5,724,136
-
Childhood Lead Poisoning Prevention Projects, State and Local Childhood Lead Poisoning
Prevention and Surveillance of Blood Lead Levels in Children
Flexible Funding Model - Infrastructure Development and Maintenance for State Manufactured
Food Regulatory Programs
Improving the Health of Americans through Prevention and Management of Diabetes and Heart
Disease and Stroke
State Actions to Improve Oral Health Outcomes and Partner Actions to Improve Oral Health
Outcomes
Cooperative Agreements to Promote Adolescent Health through School-Based HIV/STD
Prevention and School-Based Surveillance
COVID-19 - Public Health Emergency Response:  Cooperative Agreement for Emergency
Response: Public Health Crisis Response
Comprehensive Community Mental Health Services for Children with Serious Emotional
Disturbances (SED)
Cooperative Agreements to States/Territories for the Coordination and Development of Primary
Care Offices
Special Programs for the Aging, Title III, Part C, Nutrition Services
PPHF 2018: Office of Smoking and Health-National State-Based Tobacco Control Programs-
Financed in part by 2018 Prevention and Public Health funds (PPHF)
21

State of Missouri
Schedule of Expenditure of Federal Awards
Year Ended June 30, 2021
Federal Awards
Amount Provided
Number
Federal Grantor Agency - Program or Cluster Name
Expended
to Subrecipients
AL
93.435
1,483,908
1,424,263
93.436
583,845
272,287
93.439
State Physical Activity and Nutrition (SPAN)
704,853
398,503
93.464
ACL Assistive Technology
661,304
391,054
93.471
Title IV-E Kinship Navigator Program
505,737
-
93.478
Preventing Maternal Deaths: Supporting Maternal Mortality Review Committees
403,260
239,146
93.556
MaryLee Allen Promoting Safe and Stable Families Program
2,605,475
-
93.558
Temporary Assistance for Needy Families
193,397,098
12,081,610
93.563
Child Support Enforcement
19,066,289
1,880,225
93.564
Child Support Enforcement Research
181,891
-
93.568
COVID-19 - Low-Income Home Energy Assistance
1,840,445
1,816,965
93.568
Low-Income Home Energy Assistance
77,896,593
51,841,093
Total Low-Income Home Energy Assistance
79,737,038
53,658,058
93.569
COVID-19 - Community Services Block Grant
5,649,424
4,658,874
93.569
Community Services Block Grant
17,421,850
16,627,640
Total Community Services Block Grant
23,071,274
21,286,514
CCDF Cluster:
93.575
COVID-19 - Child Care and Development Block Grant
33,399,582
-
93.575
Child Care and Development Block Grant
83,387,816
4,831,217
Total Child Care and Development Block Grant
116,787,398
4,831,217
93.596
Child Care Mandatory and Matching Funds of the Child Care and Development Fund
26,580,191
-
Total CCDF Cluster
143,367,589
4,831,217
93.586
State Court Improvement Program
473,894
-
93.590
Community-Based Child Abuse Prevention Grants
652,798
652,798
93.597
Grants to States for Access and Visitation Programs
221,355
221,355
93.599
Chafee Education and Training Vouchers Program (ETV)
1,200,347
-
Head Start Cluster:
93.600
Head Start
547
547
Total Head Start Cluster
547
547
93.630
Developmental Disabilities Basic Support and Advocacy Grants
1,416,001
-
93.643
Children's Justice Grants to States
145,259
-
93.645
COVID-19 - Stephanie Tubbs Jones Child Welfare Services Program
268,780
-
93.658
Foster Care Title IV-E
38,022,365
70,631
93.659
Adoption Assistance
50,708,111
-
93.665
COVID-19 - Emergency Grants to Address Mental and Substance Use Disorders During COVID-19
1,372,999
-
93.667
Social Services Block Grant
51,383,271
8,694,431
93.669
Child Abuse and Neglect State Grants
764,308
-
93.671
506,141
506,141
93.671
Family Violence Prevention and Services/Domestic Violence Shelter and Supportive Services
1,648,663
1,611,219
Total Family Violence Prevention and Services/Domestic Violence Shelter and Supportive
Services
2,154,804
2,117,360
93.674
John H. Chafee Foster Care Program for Successful Transition to Adulthood
2,651,347
-
93.686
Ending the HIV Epidemic:  A Plan for America — Ryan White HIV/AIDS Program Parts A and B
447,824
101,040
93.687
Maternal Opioid Misuse Model
275,830
-
93.735
129,752
129,752
93.747
Elder Abuse Prevention Interventions Program
53,254
-
93.758
3,608,160
782,702
93.767
Children's Health Insurance Program
313,483,831
-
Medicaid Cluster:
93.775
State Medicaid Fraud Control Units
1,810,624
-
93.777
COVID-19 - State Survey and Certification of Health Care Providers and Suppliers (Title XVIII)
Medicare
1,324,432
-
93.777
State Survey and Certification of Health Care Providers and Suppliers (Title XVIII) Medicare
17,342,972
-
Total State Survey and Certification of Health Care Providers and Suppliers (Title XVIII)
Medicare
18,667,404
-
93.778
COVID-19 - Medical Assistance Program
678,681,707
-
93.778
Medical Assistance Program
7,745,998,573
1,968,902
Total Medical Assistance Program
8,424,680,280
1,968,902
Total Medicaid Cluster
8,445,158,308
1,968,902
93.788
Opioid STR
19,157,567
-
93.791
Money Follows the Person Rebalancing Demonstration
2,508,450
-
93.817
Hospital Preparedness Program (HPP) Ebola Preparedness and Response Activities
291,190
290,736
93.870
Maternal, Infant and Early Childhood Home Visiting Grant
3,295,855
2,850,991
93.876
Antimicrobial Resistance Surveillance in Retail Food Specimens
134,842
-
93.889
National Bioterrorism Hospital Preparedness Program
3,314,971
1,932,332
93.898
Cancer Prevention and Control Programs for State, Territorial and Tribal Organizations
3,813,971
2,654,284
State Public Health Approaches for Ensuring Quitline Capacity – Funded in part by Prevention
and Public Health Funds (PPHF)
Preventive Health and Health Services Block Grant funded solely with Prevention and Public
Health Funds (PPHF)
Well-Integrated Screening and Evaluation for Women Across the Nation (WISEWOMAN)
COVID-19 - Family Violence Prevention and Services/Domestic Violence Shelter and Supportive
Services
Innovative State and Local Public Health Strategies to prevent and Manage Diabetes and Heart
Disease and Stroke
22

State of Missouri
Schedule of Expenditure of Federal Awards
Year Ended June 30, 2021
Federal Awards
Amount Provided
Number
Federal Grantor Agency - Program or Cluster Name
Expended
to Subrecipients
AL
93.913
Grants to States for Operation of State Offices of Rural Health
233,439
19,998
93.917
COVID-19 - HIV Care Formula Grants
311,258
293,398
93.917
HIV Care Formula Grants
17,290,892
16,891,905
Total HIV Care Formula Grants
17,602,150
17,185,303
93.940
HIV Prevention Activities Health Department Based
3,743,864
2,083,607
93.945
Assistance Programs for Chronic Disease Prevention and Control
273,311
261,194
93.946
179,237
-
93.958
Block Grants for Community Mental Health Services
11,276,480
-
93.959
Block Grants for Prevention and Treatment of Substance Abuse
23,299,135
-
93.977
Sexually Transmitted Diseases (STD) Prevention and Control Grants
1,387,005
204,408
93.981
274,809
207,064
93.981
365,262
289,857
Total Improving Student Health and Academic Achievement through Nutrition, Physical Activity
and the Management of Chronic Conditions in Schools
640,071
496,921
93.982
COVID-19 - Mental Health Disaster Assistance and Emergency Mental Health
3,999,679
-
93.982
Mental Health Disaster Assistance and Emergency Mental Health
1,648,374
-
Total Mental Health Disaster Assistance and Emergency Mental Health
5,648,053
-
93.994
Maternal and Child Health Services Block Grant to the States
10,141,029
5,419,492
Total Department of Health and Human Services
9,699,078,370
217,905,935
Corporation for National and Community Service
94.003
State Commissions
367,984
943
94.006
AmeriCorps
5,564,216
5,537,395
94.008
Commission Investment Fund
192,800
68,594
Total Corporation for National and Community Service
6,125,000
5,606,932
Executive Office of the President
95.001
High Intensity Drug Trafficking Areas Program
3,417,998
2,605,162
Total Executive Office of the President
3,417,998
2,605,162
Social Security Administration
Disability Insurance/SSI Cluster:
96.001
Social Security Disability Insurance
45,546,858
-
Total Disability Insurance/SSI Cluster
45,546,858
-
Total Social Security Administration
45,546,858
-
Department of Homeland Security
97.008
Non-Profit Security Program
83,277
83,277
97.012
Boating Safety Financial Assistance
2,419,407
-
97.023
Community Assistance Program State Support Services Element (CAP-SSSE)
231,615
-
97.029
Flood Mitigation Assistance
242,238
223,739
97.036
COVID-19 -  Disaster Grants - Public Assistance (Presidentially Declared Disasters)
96,288
-
97.036
Disaster Grants - Public Assistance (Presidentially Declared Disasters)
201,057,747
121,672,899
Total Disaster Grants - Public Assistance (Presidentially Declared Disasters)
201,154,035
121,672,899
97.039
Hazard Mitigation Grant
6,350,785
5,887,473
97.041
National Dam Safety Program
97,903
-
97.042
Emergency Management Performance Grants
7,148,924
4,626,264
97.045
Cooperating Technical Partners
3,339,613
-
97.047
BRIC: Building Resilient Infrastructure and Communities
5,361,922
5,361,922
97.050
300,757,864
-
97.056
Port Security Grant Program
28,995
-
97.067
Homeland Security Grant Program
5,388,721
4,329,994
97.082
Earthquake Consortium
24,544
-
97.088
Disaster Assistance Projects
1,786,933
1,786,933
Total Department of Homeland Security
534,416,776
143,972,501
Total Expenditures of Federal Awards
$
20,642,024,177 $
2,625,271,310
The accompanying Notes to the Schedule of Expenditures of Federal Awards are an integral part of this schedule.
COVID-19 - Improving Student Health and Academic Achievement through Nutrition, Physical
Activity and the Management of Chronic Conditions in Schools
COVID-19 - Presidential Declared Disaster Assistance to Individuals and Households - Other
Needs
Improving Student Health and Academic Achievement through Nutrition, Physical Activity and the
Management of Chronic Conditions in Schools
Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative
Programs
23

24
State of Missouri - Single Audit
Notes to the Schedule of Expenditures of Federal Awards
Year Ended June 30, 2021
The following is a summary of the significant accounting policies used by the
State of Missouri.

The accompanying Schedule of Expenditures of Federal Awards (Schedule)
of the State of Missouri is presented for purposes of additional analysis as
required by Title 2 U.S. Code of Federal Regulations Part 200, Uniform
Administrative Requirements, Cost Principles, and Audit Requirements for
Federal Awards (Uniform Guidance) and the U.S. Office of Management and
Budget (OMB) 2021 Compliance Supplement. The Schedule is not a required
part of the State's basic financial statements. The Uniform Guidance requires
a schedule that shows total federal awards expended for each federal financial
assistance program, the Assistance Listing, and the total amount provided to
subrecipients from each federal program. Federal financial assistance
programs that have not been assigned a Assistance Listing number are
identified as Assistance Listing Number XX.Uxx, where XX represents the
federal grantor agency and Uxx represents an unknown extension number.
Appendix VII of the supplement states that expenditures of federal awards
made under the Coronavirus Preparedness and Response Supplemental
Appropriations Act, the Families First Coronavirus Response Act, the
Coronavirus Aid, Relief and Economic Security Act (CARES Act), the
Coronavirus Response and Relief Supplemental Appropriations Act
(CRRSAA), and the American Rescue Plan Act (ARP) should be identified
separately on the schedule with the inclusion of the prefix "COVID-19-" in
the name of the federal program.

The Schedule includes all federal awards expended by the State during the
year ended June 30, 2021, except for those programs administered by public
universities and other component units, which are legally separate from the
State and audited by other auditors. They are responsible for engaging other
auditors to perform audits in accordance with the Uniform Guidance, if
required.

To compile the Schedule, the Office of Administration required each
department, agency, and office that expended direct and/or indirect federal
funding during the state fiscal year to prepare a schedule of expenditures of
federal awards. The schedules for the departments, agencies, and offices were
combined to form the Schedule of Expenditures of Federal Awards for the
State of Missouri.

The accompanying Schedule includes the federal award activity of the State
of Missouri for the year ended June 30, 2021. The information in this
Schedule is presented in accordance with the requirements of the Uniform
Guidance, which defines federal awards as federal financial assistance and
cost-reimbursement contracts that non-federal entities receive or administer
in the form of grants, loans, loan guarantees, non-cash assistance, property
1. Significant Accounting Policies
State of Missouri - Single Audit
Notes to the Schedule of Expenditures of Federal Awards
Year Ended June 30, 2021
A. Purpose of Schedule and
Reporting Entity
B. Basis of Presentation

25
State of Missouri - Single Audit
Notes to the Schedule of Expenditures of Federal Awards
Year Ended June 30, 2021
(including donated surplus property), cooperative agreements, interest
subsidies, insurance, food commodities, direct appropriations, and other
assistance, but does not include other contracts that a federal agency uses to
buy goods or services from a contractor. Because the Schedule presents only
a selected portion of the operations of the State, it is not intended to and does
not present the financial position, changes in net assets, or cash flows of the
State.

Most expenditures presented in the Schedule are reported on the cash basis of
accounting, while some are presented on the modified accrual basis of
accounting. Such expenditures are recognized following the cost principles
contained in the Uniform Guidance; wherein certain types of expenditures are
not allowable or are limited as to reimbursement.

The state agencies administering the federal programs presented in the
Schedule did not elect to use the de minimis cost rate per the Uniform
Guidance.

The Unemployment Insurance program (Assistance Listing No. 17.225) is
administered by the Department of Labor and Industrial Relations through a
unique federal-state partnership that was founded upon federal law but
implemented through state law. Benefits are paid from federal funds and state
unemployment taxes that are deposited into the State's account in the Federal
Unemployment Trust Fund. The State's administrative expenditures incurred
under this program are funded by federal grants. For the purposes of
presenting the expenditures of this program in the Schedule, both state and
federal funds have been considered federal awards expended. The breakdown
of the state and federal portions of the total program expenditures for the
fiscal year ended June 30, 2021, is as follows:

State Portion (Benefits Paid)
$      661,647,372
Federal Portion (Benefits Paid)
16,794,017
Federal Portion (Administrative Costs)
44,341,297

Federal Portion (Benefits Paid) - CARES Act Related
2,702,121,738

Federal Portion (Employer Reimbursements) -
CARES Act Related
30,281,478

Federal Portion (Federal Reimbursement of Waiting
Week) - CARES Act Related
20,934,863

Federal Portion (Administrative Costs) - CARES and
Families First Coronavirus Response Act Related
9,966,293

Total Program Expenditures
$  3,486,087,058

C. Basis of Accounting
D. Indirect Cost Rate
2. Unemployment Insurance Expenditures

26
State of Missouri - Single Audit
Notes to the Schedule of Expenditures of Federal Awards
Year Ended June 30, 2021
The State received cash rebates from an infant formula manufacturer totaling
$28,312,122 on sales of formula to participants in the WIC program
(Assistance Listing No. 10.557) administered by the Department of Health
and Senior Services (DHSS). This amount was excluded from total program
expenditures. Rebate contracts with infant formula manufacturers are
authorized by 7 CFR Section 246.16a as a cost containment measure. Rebates
represent a reduction of expenditures previously incurred for WIC food
benefit costs. The State was able to extend program benefits to more persons
than could have been served this fiscal year in the absence of the rebate
contract.

The State received cash rebates from drug manufacturers totaling
$549,203,791 (federal share) on purchases of covered outpatient drugs for
participants in the Medicaid and the CHIP (Assistance Listing Nos. 93.778
and 93.767) administered by the Department of Social Services - MO
HealthNet Division. This amount was excluded from total program
expenditures. Rebate contracts with drug manufacturers are authorized by 42
USC Section 1396r-8 as a cost containment measure. Rebates represent a
reduction of expenditures previously incurred for medical assistance costs.

The State received cash rebates from drug manufacturers totaling
$58,041,955 on purchases of covered drugs for participants in the HIV Care
Formula Grants program (Assistance Listing No. 93.917) administered by the
DHSS. If program expenditures are available the rebates will offset the
program expenditures resulting in a reduction in expenditures incurred by the
program. Of the amount of rebates received, $35,172,770 reduced total
program expenditures and these expenditures were not reported on the SEFA.
The remaining rebates of $22,869,186 did not offset program expenditures
and were not used to reduce program expenditures. The allowable use of drug
rebates is restricted by 42 USC Section 300ff-26(g).

Because of the Healthcare and Education Affordability Reconciliation Act
enacted March 30, 2010 (Public Law 111-152), the authority to make or
ensure loans under the Federal Family Education Loans program (Assistance
Listing No. 84.032) ended June 30, 2010. The Department of Higher
Education and Workforce Development (DHEWD) will continue to act as the
federal Department of Education's agent in fulfilling the responsibilities
3. Special Supplemental Nutrition Program for Women, Infants and Children
(WIC) Rebates
4. Medical Assistance Program (Medicaid) and Children's Health Insurance
Program (CHIP) Prescription Drug Rebates
5. HIV Care Formula Grants Prescription Drug Rebates
6. Federal Loan Guarantees

27
State of Missouri - Single Audit
Notes to the Schedule of Expenditures of Federal Awards
Year Ended June 30, 2021
related to the outstanding guarantees. The original principal outstanding of all
loans guaranteed by the DHEWD is $736,431,231 as of June 30, 2021. The
balance of defaulted loans (including principal and accrued interest) that the
federal Department of Education imposes continuing compliance
requirements of the DHEWD is $172,509,799 as of June 30, 2021.

The Schedule contains values for non-cash assistance for several programs.

Supplemental
Nutrition
Assistance
Program
expenditures
totaling
$1,716,634,049 ($1,712,558,052 for Assistance Listing No. 10.551 and
$4,075,997 for Assistance Listing No. 10.542) represent actual disbursements
for client purchases of authorized food products through the use of the
electronic benefits card program administered by the Department of Social
Services - Family Support Division (DSS-FSD).

The Department of Elementary and Secondary Education distributes food
commodities to school districts under the National School Lunch Program
(Assistance Listing No. 10.555). Distributions are valued at the cost of the
food paid by the federal government and totaled $25,941,494.

The DSS-FSD, through the Summer Food Service Program for Children
(Assistance Listing No. 10.559), provides United States Department of
Agriculture (USDA)-donated foods to providers who serve free healthy meals
to children and teens in low-income areas during the summer months when
school is not is session. The DSS-FSD, through the Emergency Food
Assistance Program (Food Commodities) (Assistance Listing No. 10.569),
provides USDA-donated foods for disaster relief and to six non-profit food
banks for distribution to food pantries and community groups for feeding
those in need. Distributions are valued at the federally assigned value of the
product distributed and totaled $62,704 for the Summer Food Service
Program for Children, $27,804,015 for the Emergency Food Assistance
Program, and $9,657,007 for Trade Mitigation.

The DHSS distributes food commodities to low-income persons under the
Commodity Supplemental Food Program (Assistance Listing No. 10.565).
Distributions are valued at the cost of the food paid by the federal government
and totaled $6,433,876.

The Department of Public Safety distributes excess federal Department of
Defense (DOD) equipment to state and local law enforcement agencies under
the DOD Excess Property Program (Assistance Listing No. 12.U01). Property
distributions totaled $2,690,426 when valued at the historical cost assigned
by the federal government. Distributions are presented at the estimated fair
market value of the property at the time of distribution, calculated as 23.34
percent of the historical cost, or $627,945.
7. Non-cash Assistance

28
State of Missouri - Single Audit
Notes to the Schedule of Expenditures of Federal Awards
Year Ended June 30, 2021
The State Agency for Surplus Property distributes federal surplus property to
eligible donees under the Donation of Federal Surplus Personal Property
program (Assistance Listing No. 39.003). Property distributions totaled
$7,192,582 when valued at the historical cost assigned by the federal
government. Distributions are presented at the estimated fair market value of
the property at the time of distribution, calculated as 23.34 percent of the
historical cost, or $1,678,749.

The DHSS distributes vaccines to local health agencies and other health care
professionals under the Immunization Cooperative Agreements program
(Assistance Listing No. 93.268). Distributions are valued at the cost of the
vaccines paid by the federal government and totaled $67,601,764.

The DHSS received donated testing supplies from the Federal Emergency
Management Agency for activities related to the COVID-19 pandemic
(Assistance Listing 97.036). Donated items are valued at the fair market value
at time of donation and totaled $96,288.

The DHSS received donated testing equipment and supplies from the
Department of Health and Human Services Strategic National Stockpile for
activities related to the COVID-19 pandemic (Assistance Listing 93.323).
Donated items are valued at the fair market value at time of donation and
totaled $10,822,520.

The Schedule does not contain donations for non-cash assistance provided
without any compliance or reporting requirements or Assistance Listing
information from the donors.

The State Emergency Management Agency received donated personal
protective items from the Federal Emergency Management Agency for
activities related to the COVID-19 pandemic. Donated items are valued at the
fair market value at time of donation and totaled $9,851,784 and are
unaudited.

8. Other Non-cash Assistance

29
State of Missouri - Single Audit
Schedule of Findings and Questioned Costs
Year Ended June 30, 2021
Section I - Summary of Auditor's Results

Financial Statements

Type of auditor's report issued on whether the
financial statements audited were prepared in
accordance with GAAP:
Qualified

Unmodified for all opinion units except for the governmental activities and the General Fund, which were
qualified.

Internal control over financial reporting:

•
Material weaknesses identified?

yes
X
no
•
Significant deficiencies identified?
X
yes

none reported

Noncompliance material to financial statements noted?

yes
X
no

Federal Awards
Internal control over major federal programs:

•
Material weaknesses identified?
X
yes

no
•
Significant deficiencies identified?
X
yes

none reported

Type of auditor's report issued on compliance for

major federal programs:

Unmodified for all major programs except for the following major programs that were qualified:
AL
Number(s)
Name of Federal Program or Cluster
21.023
Emergency Rental Assistance Program, modified for Subrecipient Monitoring and
Reporting
84.425C,D,R
Education Stabilization Fund, modified for Reporting
93.323
Epidemiology and Laboratory Capacity for Infectious Diseases (ELC), modified for
Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and Subrecipient
Monitoring
93.767
Children's Health Insurance Program, modified for Special Tests and Provisions
93.775, 93.777, 93.778 Medicaid Cluster, modified for Special Tests and Provisions

Any audit findings disclosed that are required to be

reported in accordance with the Uniform Guidance

(2 CFR 200.516(a))?
X
yes

no

State of Missouri - Single Audit
Schedule of Findings and Questioned Costs
Year Ended June 30, 2021

30
State of Missouri - Single Audit
Schedule of Findings and Questioned Costs
Year Ended June 30, 2021
Identification of major federal programs:

AL
Number(s)
Name of Federal Program or Cluster
10.553
10.555
10.556
10.559
10.579
Child Nutrition Cluster
14.231
Emergency Solutions Grant Program
16.575
Crime Victim Assistance
17.258
17.259
17.278
Workforce Innovation and Opportunity Act (WIOA) Cluster
20.205
20.219
20.224
Highway Planning and Construction Cluster
20.106
Airport Improvement Program and COVID-19 Airports Programs
20.509
Formula Grants for Rural Areas and Tribal Transit Program
21.019
Coronavirus Relief Fund
21.023
Emergency Rental Assistance Program
84.027
84.173
Special Education Cluster (IDEA)
84.425C
84.425D
84.425R
Education Stabilization Fund
93.323
Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)
93.558
Temporary Assistance for Needy Families
93.568
Low-Income Home Energy Assistance
93.575
93.596
Child Care and Development Fund (CCDF) Cluster
93.658
Foster Care Title IV-E
93.767
Children's Health Insurance Program
93.775
93.777
93.778
Medicaid Cluster
97.036
Disaster Grants - Public Assistance (Presidentially Declared Disasters)
97.050
Presidential Declared Disaster Assistance to Individuals and Households - Other Needs

Dollar threshold used to distinguish

between Type A and Type B programs:
$30,963,036

Auditee qualified as a low-risk auditee?

yes
X
no

31
State of Missouri - Single Audit
Schedule of Findings and Questioned Costs
Year Ended June 30, 2021
Section II - Financial Statement Findings

The findings related to the financial statement audit are reported in the
Comprehensive Annual Financial Report - Report on Internal Control,
Compliance, and Other Matters (Report No. 2022-0223). That report included
the following findings:

FS2021-001.
Department of Revenue Financial Reporting Controls

FS2021-002.
Department of Natural Resources Capital Asset Controls

FS2021-003.
Department of Social Services Financial Reporting Controls

FS2021-004.
Department of Labor and Industrial Relations UInteract
System Controls

3See report at <https://auditor.mo.gov/AuditReport/ViewReport?report=2022022>.

32
State of Missouri - Single Audit
Schedule of Findings and Questioned Costs
Year Ended June 30, 2021
Section III - Federal Award Findings and Questioned Costs

Federal Agency
Department of the Treasury
Federal Program:
21.023 COVID-19 - Emergency Rental Assistance
Program

2021 - ERAE0511 and ERAE0512
State Agency:
Department of Economic Development (DED)
Type of Finding:
A - Internal Control (Material Weakness) and
Noncompliance
B - Noncompliance

Improvements are needed in the DED's internal controls related to
subrecipient determinations. During state fiscal year 2021, the DED did not
comply with the Uniform Guidance (UG) requirements regarding identifying
subrecipients, performing subrecipient risk assessments, and establishing
subrecipient monitoring procedures. During state fiscal year 2021, the DED
passed through $323,715,323 to a subrecipient, the Missouri Housing
Development Commission (MHDC), for the Emergency Rental Assistance
(ERA) Program. The amount paid to the MHDC represents 100 percent of the
ERA Program expenditures made by the DED.

The DED is responsible for administering the ERA Program. In order to
implement the ERA Program, the DED entered into a contract with the
MHDC in February 2021. This contract requires the MHDC to implement the
ERA Program, including determining eligibility and processing payments to
eligible applicants, and taking responsibility for programmatic decision-
making and adherence to federal program requirements.

Rule 2 CFR Section 200.331 states a pass-through entity must make case-by-
case determinations whether each agreement it makes for the disbursement of
federal program funds casts the party receiving the funds in the role of a
subrecipient or a contractor. The classification of a subrecipient4 is dependent
on if the entity is responsible for making eligibility determinations for
assistance, has its performance measured in relation to whether the objectives
of the federal program were met, has responsibility for programmatic decision
making, is responsible for adherence to federal program requirements, and
uses the federal funds to carry out a program for its public purpose.

Rule 2 CFR 200.332(b) states that pass-through entities must 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. Rule 2 CFR 200.332(d) requires pass-
through entities to monitor the activities of the subrecipient as necessary to

4As defined by 2 CFR Section 200.331(a).
2021-001.
DED Subrecipient
Determination and
Monitoring

33
State of Missouri - Single Audit
Schedule of Findings and Questioned Costs
Year Ended June 30, 2021
ensure that the subrecipient is in compliance with federal statutes, regulations,
and the terms and conditions of the subaward.

Rule 2 CFR 200.332(d)(2) requires the pass-through entity to follow up and
ensure the subrecipient takes timely and appropriate action on all deficiencies
pertaining to the federal award provided to the subrecipient from the pass-
through entity detected through audits, highlighting the status of actions
planned or taken to address single audit findings related to the particular
subaward. Additionally, Rule 2 CFR 200.332(d)(3) requires the pass-through
entity to issue a management decision for applicable findings pertaining only
to the federal award provided to the subrecipient from the pass-through entity.

The DED has not established policies and procedures to determine if the
recipients of federal program funds are subrecipients or contractors.
Additionally, the DED made an inaccurate determination and did not classify
the MHDC as a subrecipient. The assessment performed to make this
determination was not documented.

DED officials stated they did not have policies and procedures because
making this type of determination does not occur often and all other DED
federal funds recipients have already been classified as a subrecipient or a
contractor. DED officials stated they had not had to make a determination of
this nature in several years and were unsure how to perform a subrecipient
determination. No guidance was sought from the UG5 to make the
determination. Additionally, the assessment was not documented because
DED officials were unaware it needed to be.

DED officials stated they believed the MHDC was not a subrecipient at the
time of the award. DED officials further stated since they originally did not
consider the MHDC to be a subrecipient, they did not implement the required
subrecipient monitoring (see section B), filed an inaccurate schedule of
expenditures of federal awards (see finding number 2021-002), and did not
identify a significant error in a federal report submitted by the MHDC (see
finding number 2021-003A). Officials believed that because the MHDC is a
state entity, subrecipient monitoring was not required.6 As part of the audit
process, we requested DED officials justify how the MHDC is not a

52 CFR Section 200.331(a), (b), and (c) list criteria to consider when making this
determination.
6The Missouri Housing Development Commission (MHDC) was established under Chapter
215, RSMo, in 1969 and under Section 215.020, RSMo, is an instrumentality of the state of
Missouri, which constitutes a body corporate and politic. The Commission includes the
Governor, Lieutenant Governor, State Treasurer, Attorney General and six persons appointed
by the Governor with the advice and consent of the Senate.
A. Subrecipient Classification

34
State of Missouri - Single Audit
Schedule of Findings and Questioned Costs
Year Ended June 30, 2021
subrecipient when considering the UG requirements.7 Based on these
discussions, officials agreed the MHDC was a subrecipient.

The DED did not implement a subrecipient monitoring program to monitor
the MHDC, the sole subrecipient.

The DED did not perform a risk assessment of its subrecipient, MHDC, to
determine the extent of monitoring necessary for an effective subrecipient
monitoring system. The risk assessment was not performed because the DED
did not properly classify the MHDC as a subrecipient (see section A). In
addition, without consideration of the subrecipient's risk of noncompliance,
the DED did not develop an adequate monitoring approach necessary to
ensure compliance with the ERA Program award it passes through to the
subrecipient.

The DED did not monitor the MHDC for the ERA Program in the following
areas:


Activities allowed and unallowed, to ensure the activities performed by
the MHDC were compliant with ERA Program requirements.


Costs allowed and unallowed, to ensure the costs paid by the MHDC were
compliant with ERA Program requirements.


Eligibility, to ensure MHDC only provided program monies to applicants
who were eligible based on ERA Program requirements.

Additionally, the DED did not follow up on and ensure the MHDC took
appropriate action to address the deficiency identified in MHDC's Single
Audit, for the year ended June 30, 2021, related to approximately $1 million
in questioned costs.8 Also, the DED did not issue a management decision
related to the deficiency identified in MHDC's Single Audit as required by
federal regulations.

DED officials stated they did not perform the risk assessments or implement
a subrecipient monitoring program because they originally believed the
MHDC was not a subrecipient. See section A for more information about this
incorrect determination. Without an established subrecipient monitoring
program, the DED cannot provide assurance that MHDC is complying with
ERA Program requirements. Additionally, the DED cannot ensure

7Rule 2 CFR Section 200.331(a) and (b).
8The audit report stated MHDC identified $462,448 of known questioned costs and $599,879
of potential questioned costs.
B. Subrecipient Monitoring

Risk assessment

Subrecipient monitoring
procedures

Conclusions

35
State of Missouri - Single Audit
Schedule of Findings and Questioned Costs
Year Ended June 30, 2021
deficiencies identified through the subrecipient's audits are timely and
appropriately addressed.

The DED:

A.  Develop
and
implement
procedures
regarding
subrecipient
determinations and ensure a determination is made when program funds
are disbursed to determine if the recipient of the funds is a subrecipient
or a vendor.

B. Formally assess and document 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. Additionally, develop a subrecipient monitoring program
that includes ensuring the subrecipient is compliant with program and
relevant legal provisions and appropriate monitoring of subrecipient audit
findings related to the program.

A. We agree with the auditor's finding. Our Corrective Action Plan includes
our planned actions to address the finding.

B.  We agree with the auditor's finding. Our Corrective Action Plan includes
our planned actions to address the finding.

Federal Agency:
Department of the Treasury
Federal Program:
21.023 COVID-19 - Emergency Rental Assistance
Program

21.026 COVID-19 - Homeowner Assistance Fund
State Agency:
Department of Economic Development (DED)
Type of Finding:
Noncompliance

The expenditures reported on the DED's schedule of expenditures of federal
awards (SEFA) submitted to the Office of Administration - Division of
Accounting (DOA) for inclusion in the statewide SEFA for the year ended
June 30, 2021, were misstated. If the misstatement had not been identified
during the audit, DED program expenditures would have been understated by
$337,542,2579 in the statewide SEFA as shown below:

Reported Expenditures
Actual Expenditures
Understated
$0
$337,542,257
$337,542,257

9Of this amount, $323,715,323 applies to the Emergency Rental Assistance Program and
$13,826,934 applies to the Homeowner Assistance Fund.
Recommendations
Auditee's Response
2021-002.
DED SEFA

36
State of Missouri - Single Audit
Schedule of Findings and Questioned Costs
Year Ended June 30, 2021
Rule 2 CFR Section 200.510(b) requires the recipient of federal awards to
prepare a SEFA including federal awards expended for each federal program.
The omitted expenditures were all payments to a subrecipient. DED officials
stated they did not include the expenditures to the subrecipient on their SEFA
because they considered the subrecipient to be a state agency instead of a
subrecipient. See finding number 2021-001 for more information about this
incorrect determination. After discussion with agency officials, they agreed
these expenditures should have been reported on the SEFA and subsequently
submitted a revised SEFA to the DOA. The DOA included the revised amount
in the statewide SEFA.

The DED ensure an accurate SEFA is prepared and submitted to the DOA.

We agree with the auditor's finding. Our Corrective Action Plan includes our
planned actions to address the finding.

Federal Agency:
Department of the Treasury (Treasury)
Federal Program:
21.023
COVID-19 - Emergency Rental Assistance
Program

2021 - ERAE0511 and ERAE0512
State Agency:
Department of Economic Development (DED)
Type of Finding:
A - Internal Control (Material Weakness) and
Noncompliance
B - Noncompliance

The DED did not establish an internal control system over required federal
reporting of the Emergency Rental Assistance (ERA) Program and did not
identify a significant inaccuracy in a performance report. In addition, the
required Federal Funding Accountability and Transparency Act (FFATA)
reporting was not submitted for state fiscal year 2021. The DED provided a
$324 million subaward to the Missouri Housing Development Commission
(MHDC) from the ERA Program in fiscal year 2021. This first-tier
subaward10 accounted for 100 percent of the program's expenditures.

The DED is responsible for administering the ERA Program. The DED
contracted with the MHDC to implement the ERA Program and to follow all
federal guidelines related to the ERA Program, including reporting
requirements.

The ERA Program requires recipients to certify and submit monthly and
quarterly performance reports, which include a brief narrative describing the
performance and accomplishments over the reporting period. The monthly

10First-tier subawards are federal awards made to non-federal entities by the prime award
recipient, in this case the DED, on behalf of the federal awarding agency, the Treasury.
Recommendation
Auditee's Response
2021-003.
DED Performance and
FFATA Reporting

37
State of Missouri - Single Audit
Schedule of Findings and Questioned Costs
Year Ended June 30, 2021
reports provide the Treasury with the number of households receiving
assistance and the amount of ERA funds expended in the reporting period.
The quarterly reports include a standard federal financial report, various
financial data points, and participant household payment data. The DED
contracted with the MHDC to prepare and submit these reports on the DED's
behalf.

The FFATA requires comprehensive reporting for certain federal awards to
promote transparency and accountability over the use of the federal funds.
Per the ERA Reporting Guidance issued by the Treasury,11 the Treasury
would submit, on behalf of the recipients, the required FFATA reports into
the FFATA Subaward Reporting System (FSRS) based off the information
provided by the DED on its first quarter performance reports.

An internal control system to achieve compliance with federal reporting
requirements has not yet been developed and a quarterly performance report
was inaccurate.

The DED contracted with MHDC to submit the ERA Program performance
reports on the DED's behalf. DED officials believed the contract with MHDC
stating MHDC would administer the ERA Program and follow all federal
guidelines, including the federal reporting requirements, was adequate
reasoning for their lack of a control system and review process. Therefore, no
additional controls were implemented, such as reviewing the reports for
accuracy and completeness before the report is filed. A DED official stated
the DED reviewed the reports submitted by the MHDC, but this review was
performed after the report had already been submitted by the MHDC, was to
ensure the report was complete, and was not documented.

To test compliance of the performance report accuracy and timely submittal,
we reviewed reporting documentation for 2 of the reports that were required
to be submitted within our audit period. We identified 1 quarterly report that
inaccurately stated the MHDC was a contractor instead of a subrecipient. A
DED official stated this error was not identified during review because the
DED did not consider the MHDC to be a subrecipient (see finding number
2021-001A). Because of this error, the Treasury did not file the FFATA report
on behalf of the DED (see section B).

Rule 2 CFR Section 200.329(c), requires non-federal entities to submit
performance reports at the interval required by the federal awarding agency
containing data elements approved by the OMB. Additionally, Rule 2 CFR
200.303(a) requires the non-federal entity to "[e]stablish and maintain

11<https://home.treasury.gov/system/files/136/ERA-Reporting-Guidance-v2.pdf>, page 14,
accessed on April 28, 2022.
A. Performance Reporting

38
State of Missouri - Single Audit
Schedule of Findings and Questioned Costs
Year Ended June 30, 2021
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."

The DED did not take the appropriate steps to ensure the required FFATA
reporting occurred. The Treasury provided guidance to recipients stating the
Treasury would submit, on behalf of the recipients, the required FFATA
reports based on the quarterly performance reports submitted. However, the
MHDC incorrectly listed itself as a contractor instead of a subrecipient, and
the DED did not identify the error in the quarterly performance report,
causing the Treasury to not submit the required FFATA reports.

Contractor payments are not required to be reported under FFATA; therefore,
the Treasury did not submit the FFATA report for ERA Program based off of
the performance report information. As a result, payments made by the DED
have not been reported into the FSRS, resulting in the lack of the FFATA
reporting.

Rule 2 CFR Part 170, Appendix A, requires non-federal entities to report first-
tier subawards of $30,000 or more to the FSRS no later than the end of the
month following the month in which the subaward was made. Information
entered into the FSRS is publicly available at USASpending.gov. In addition
to noncompliance with federal requirements, not reporting subawards to the
FSRS accurately and timely increases the risk that those using the reports
could rely on inaccurate information.

The DED:

A.  Develop an internal control system over federal reporting requirements
for the ERA Program and ensure reports are submitted accurately.

B.  Take the steps necessary to ensure the FFATA reporting requirements are
met.

A.  We agree with the auditor's finding. Our Corrective Action Plan includes
our planned actions to address the finding.

B.  We agree with the auditor's finding. Our Corrective Action Plan includes
our planned actions to address the finding.

Federal Agency:
Department of Health and Human Services (DHHS)
Federal Program:
93.767
Children's Health Insurance Program

 2020 - 2005MO5021
2021 - 2105MO5021

93.778
COVID-19 - Medical Assistance Program
B. Transparency Reporting
Recommendations
Auditee's Response
2021-004.
Medicaid National Correct
Coding Initiative

39
State of Missouri - Single Audit
Schedule of Findings and Questioned Costs
Year Ended June 30, 2021
93.778
Medical Assistance Program

 2020 - 2005MO5MAP and 2005MO5ADM
2021 - 2105MO5MAP and 2105MO5ADM
State Agency:
Department of Social Services (DSS) - MO HealthNet
Division (MHD)
Type of Finding:
Internal Control (Material Weakness) and
Noncompliance

As noted in our previous audit,12 the MHD has not fully implemented the
Medicaid National Correct Coding Initiative (NCCI) edits in the Medicaid
Management Information System (MMIS) as required. During the year ended
June 30, 2021, the MHD made Medical Assistance Program (Medicaid) and
Children's Health Insurance Program (CHIP) payments, subject to NCCI
edits, totaling approximately $8 billion.

The DSS contracts for the operation and maintenance of the MMIS. Medical
providers submit fee-for-service claims for services provided to Medicaid and
CHIP participants in the MMIS, and payments are made through the MMIS.
To help ensure only allowable claims are paid, system edit checks flag and/or
deny payment on suspicious or unusual claims. Section 6507 of the
Affordable Care Act (Section 1903(r) of the Social Security Act13) requires
the MHD to completely and correctly implement specific NCCI
methodologies and edits into the MMIS. The purpose of the NCCI is to
promote correct coding, prevent coding errors, prevent coding manipulation,
and reduce improper payments. The DHHS - Centers for Medicare and
Medicaid Services (CMS) published the Medicaid NCCI Policy Manual and
the Medicaid NCCI Technical Guidance Manual to provide specific
requirements and assist state Medicaid agencies to implement the NCCI
methodologies.

The two NCCI edit categories are Procedure-to-Procedure (PTP) edits that
are designed to identify pairs of procedure codes that should not be reported
together; and Medically Unlikely Edits (MUE) that limit the number of units
of service allowed for certain services and items. The DHHS-CMS provides
PTP and MUE edit files to the MHD quarterly. Each quarterly edit file
contains all current edits and replaces the previously provided edit file.
Section 7 of the Medicaid NCCI Technical Guidance Manual requires the
MHD to implement the edit files into the MMIS on the first day of each
quarter. If the applicable edit files are not implemented by the first day of the
second month of the quarter, the MHD is required to reprocess any claims
processed with outdated edits once the updates are implemented.

12See single audit report at <https://auditor.mo.gov/AuditReport/Reports?SearchLocalState=
35>, finding number 2020-002.
13Title 42 USC 1396b(r)

40
State of Missouri - Single Audit
Schedule of Findings and Questioned Costs
Year Ended June 30, 2021
Rather than quarterly implementation, the MHD through the MMIS
contractor implements the PTP edit files annually; and the MHD does not
reprocess claims upon implementation of the edits. For example, the MMIS
contractor implemented the PTP edit file for the quarter ended March 31,
2021, in January 2021; and the MHD did not reprocess claims paid for the
quarters ended June 30, 2020, September 30, 2020, and December 31, 2020,
with the updated edits. In addition, the MHD has not implemented any of the
MUE edit files received. MHD officials indicated they are working with the
MMIS contractor to fully implement both the PTP and MUE edits.

In addition to noncompliance with Section 6507 of the Affordable Care Act,
the failure to fully implement the NCCI edits and reprocess claims paid with
incorrect edits increases the risk that coding errors or irregularities will go
undetected, and improper payments will be made. To ensure compliance with
the NCCI requirements, the MHD should establish internal controls over
NCCI edits. Rule 45 CFR Section 75.303(a) requires the non-Federal entity
to "[e]stablish 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."

The DSS through the MHD strengthen controls over the NCCI requirements
to ensure NCCI edits are fully implemented and reprocess claims paid when
edits are not implemented timely, as required.

We agree with the auditor's finding. Our Corrective Action Plan includes our
planned actions to address the finding.

Federal Agency:
Department of Health and Human Services
Federal Program:
93.767
Children's Health Insurance Program

 2020 - 2005MO5021
2021 - 2105MO5021

93.778
93.778
COVID-19 - Medical Assistance Program
Medical Assistance Program

 2020 - 2005MO5MAP and 2005MO5ADM
2021 - 2105MO5MAP and 2105MO5ADM
State Agency:
Department of Social Services (DSS) - MO HealthNet
Division (MHD) and Family Support Division (FSD)
Type of Finding:
Internal Control (Significant Deficiency) and
Noncompliance

Recommendation
Auditee's Response
2021-005.
Medicaid and CHIP
Participant Eligibility

41
State of Missouri - Single Audit
Schedule of Findings and Questioned Costs
Year Ended June 30, 2021
As similarly noted in our 2 previous audits,14 the DSS does not have sufficient
controls to ensure compliance with the eligibility requirements of the Medical
Assistance Program (Medicaid) and the Children's Health Insurance Program
(CHIP) for certain participants whose eligibility is based on their Modified
Adjusted Gross Income (MAGI). The DSS did not correct system overrides
for some MAGI-based participants, preventing their cases from being closed
when necessary. There were approximately 1.1 million Medicaid and CHIP
participants as of June 30, 2021.

To ensure MAGI-based participants continue to be eligible for benefits, 42
CFR Sections 435.916 requires a redetermination of eligibility once every 12
months, or when circumstances affecting a participant's eligibility change.
The regulation requires termination of benefits when a participant no longer
meets eligibility requirements. On March 19, 2020, the eligibility
redetermination and most termination requirements were temporarily
suspended in response to the COVID-19 public health emergency (PHE) and
the suspension remained in effect for the entire audit period. All validly
enrolled participants on March 19, 2020, remained continuously enrolled
throughout the audit period except for participants who requested removal,
relocated to another state, or died.

The Medicaid Eligibility Determination and Enrollment System (MEDES),
implemented in January 2014, tracks eligibility information for MAGI-based
participants, including redetermination due dates; and in some cases,
performs redeterminations. Non-automatic redeterminations for MAGI-based
participants are performed manually by FSD specialists. Eligibility
information is transferred from the MEDES into the Medicaid Management
System (MMIS), the Medicaid claims payment system, nightly. To ensure
continuous enrollment during the PHE, the DSS programmed the MEDES to
continue coverage effective March 18, 2020, except in the case of a
participant's death, move out of state, or voluntary closure. For some
exceptions, the MEDES automatically closes the case. For other exceptions,
an FSD specialist manually records the reason for closure and initiates closure
of the participant's case in the MEDES.

MEDES operations have been problematic since implementation and manual
overrides to individual cases to compensate for previous system errors and
limitations were not corrected. DSS officials explained there was a period of
time when the MEDES was incorrectly closing some eligible cases before a
redetermination could be performed. To prevent affected cases from being
closed, DSS personnel manually overrode system controls. However, once
these system limitations were corrected in June 2017, the DSS did not remove

14See single audit reports at <https://auditor.mo.gov/AuditReport/Reports?SearchLocalState=35>,
finding numbers 2020-003 and 2019-005.

42
State of Missouri - Single Audit
Schedule of Findings and Questioned Costs
Year Ended June 30, 2021
the previously-established manual overrides, which prevented the system
from taking automatic actions such as identifying cases needing
redetermination and closing cases.

To test compliance with eligibility requirements in effect during the audit
period, we reviewed 60 MAGI-based participants that were continuously
enrolled during the year ended June 30, 2021. We identified 3 participants
with previously-established system overrides, 1 of whom (2 percent) was no
longer eligible for Medicaid. This participant was initially enrolled in
December 2014 and became ineligible in February 2016 when she moved out
of state. An FSD specialist recorded in the participant's file the reason the
participant was ineligible and initiated closure of the case; however, DSS
officials indicated the previously-established system overrides prevented the
case from closing. No Medicaid payments were made on behalf of this
ineligible participant during the year ended June 30, 2021.

In response to prior audit recommendations, DSS officials indicated they
recently developed a report to identify MEDES participants with overdue
redeterminations due to these system problems; however, the DSS has not
reviewed these participants to ensure they remain eligible and do not meet
one of the exceptions requiring case closure during the PHE. DSS officials
indicated once the PHE ends, they plan to begin removing the manual
overrides and performing redeterminations for these participants.

The failure to implement adequate internal controls to ensure ineligible
participant cases are closed can result in Medicaid and CHIP payments being
made on behalf of ineligible individuals, which would be unallowable costs
of the federal programs. Rule 45 CFR Section 75.303(a) requires the non-
federal entity to "[e]stablish 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."

The DSS through the MHD and the FSD review participants with manual
overrides in the MEDES to ensure the participants remain eligible and do not
meet one of the exceptions requiring removal from the Medicaid and the
CHIP during the PHE. In addition, the DSS should review and correct the
eligibility for the ineligible participant identified in this finding.

We disagree with the auditor's finding. Our Corrective Action Plan includes
an explanation and specific reasons for our disagreement.

The DSS Corrective Action Plan (CAP) states the DSS disagrees there is a
significant deficiency in internal controls because only one ineligible
participant was identified, there were no questioned costs, and the case has
since been closed. The CAP states the DSS has processes in place to terminate
Recommendation
Auditee's Response
Auditor's Comment

43
State of Missouri - Single Audit
Schedule of Findings and Questioned Costs
Year Ended June 30, 2021
eligibility for individuals who are deceased, voluntarily request closure, or
report they have moved out of state. However, these processes are not in place
for participant cases with manual overrides, and although recommended in
prior audits, the DSS has not reviewed those cases to ensure the participants
remain eligible and do not meet one of the exceptions requiring termination
during the PHE. Until the manual overrides are corrected and/or applicable
participants reviewed, there is continued risk of improper payments on these
cases. Therefore, this finding is valid.

Federal Agency:
Department of Health and Human Services
Federal Program:
93.658 Foster Care - Title IV-E

2020 - G2001MOFOST
2021 - G2101MOFOST
State Agency:
Department of Social Services (DSS) - Children's
Division (CD) and Division of Finance and
Administrative Services (DFAS)
Type of Finding:
Internal Control (Significant Deficiency) and
Noncompliance

The DSS has not documented policies and procedures, including a periodic
schedule, for reviews of Foster Care program maintenance payment rates. In
addition, the DSS could not provide documentation supporting any review of
the rates in effect for the year ended June 30, 2021. During that period, the
DSS paid maintenance payments totaling about $42 million (excluding prior
quarter adjustments) for approximately 7,000 children.

The DSS provides Foster Care maintenance payments to foster homes,
relative homes, and residential facilities to cover the cost of (and the cost of
providing) food, clothing, shelter, daily supervision, school supplies, and
other travel and incidental expenses benefiting the child. Foster Care
maintenance payment rates are set during the annual budget process, in which
the DSS submits budget requests based on proposed rates and amounts. These
requests are reviewed, potentially revised, and approved by the general
assembly and the governor. The rates approved for the year ended June 30,
2021, were the same as those set for the year ended June 30, 2020. The fiscal
year 2020 rates increased by 1.5 percent from the prior year rates.

Title 42 USC Section 671(a)(11) provides that in order for a state to be
eligible for payments, the State Plan must provide for periodic review of
amounts paid as Foster Care maintenance payments, to assure their
continuing appropriateness. In addition, 45 CFR Section 1356.21(m)(1)
requires the DSS to review the Foster Care maintenance payment amounts at
reasonable, specific, time-limited periods established by the DSS.

DSS has not implemented a schedule or any procedures for reviewing and
determining the appropriateness of the Foster Care maintenance payment
2021-006.
Foster Care Maintenance
Payment Rates

44
State of Missouri - Single Audit
Schedule of Findings and Questioned Costs
Year Ended June 30, 2021
rates as required. In addition, for the rates in effect for the year ended
June 30, 2021, DSS officials could not provide any documentation detailing
a review or analysis supporting the rates requested during the budget process.
Without a schedule or documented reviews, the DSS cannot demonstrate that
reviews were completed as required or that the rates paid are appropriate.

Rule 45 CFR Section 75.303(a) requires the non-federal entity to "[e]stablish
and maintain effective internal control over the Federal award that provides
reasonable assurance that the non-Federal entity is managing the Federal
award in compliance with Federal statutes, regulations, and the terms and
conditions of the Federal award. These internal controls should be in
compliance with guidance in Standards for Internal Control in the Federal
Government, issued by the Comptroller General of the United States or the
Internal Control Integrated Framework, issued by the Committee of
Sponsoring Organizations of the Treadway Commission." Paragraph 12.01 of
the Standards for Internal Control in the Federal Government, also known as
the Green Book, states "management should implement control activities
through policies."

The DSS through the CD and the DFAS develop policies and procedures,
including a reasonable and specific schedule, for periodic reviews of Foster
Care program maintenance payments and rates, and implement the schedule
for reviewing and determining the appropriateness of the payments and rates
as required. Also, maintain documentation of all reviews performed.

We disagree with the auditor's finding. Our Corrective Action Plan includes
an explanation and specific reasons for our disagreement.

The DSS Corrective Action Plan (CAP) states the DSS disagrees with the
finding because the department has existing procedures to review the Foster
Care maintenance payment rates as part of the annual budget preparation
process. The CAP also states the DSS provided auditors documentation of the
annual budget meeting to demonstrate the review occurred. Budget meeting
documentation provided showed the requested rates were discussed, but did
not include any evidence a detailed review or analysis of the rates for
continued appropriateness occurred. Without retaining documentation of
reviews or analyses of the rates, the DSS cannot demonstrate the rates were
reviewed for continued appropriateness annually or reviewed at all. Without
documented policies and procedures, the DSS cannot demonstrate proper
internal controls have been established to ensure the rates are reviewed
periodically as required. Therefore, this finding is valid. In addition, the CAP
states the DSS will record the minutes from the portion of the meeting
regarding review of maintenance payment rates going forward. However,
recordings of budget meeting discussions are not sufficient in place of
documented policies and procedures, and detailed reviews or analyses.

Recommendation
Auditee's Response
Auditor's Comment

45
State of Missouri - Single Audit
Schedule of Findings and Questioned Costs
Year Ended June 30, 2021
Federal Agency:
Department of Health and Human Services
Federal Program:
93.575 COVID-19 - Child Care and Developmental
Block Grant
2020 - G2001MOCCC3

93.575 Child Care and Developmental Block Grant
2020 - G2001MOCCDF
2021 - G2101MOCCDF

93.596 Child Care Mandatory and Matching Funds
of the Child Care and Development Fund
2020 - G2001MOCCDF
2021 - G2101MOCCDF
State Agency:
Department of Social Services (DSS)
Type of Finding:
Internal Control (Significant Deficiency) and
Noncompliance
Questioned Costs:
$179

DSS controls over the Child Care Development Fund (Child Care) program's
corrective (manual) subsidy payments to child care providers are not
sufficient to prevent improper payments. The DSS made unsupported
corrective payments and/or overpaid providers on behalf of 3 children.
During the year ended June 30, 2021, the DSS paid over 2,800 providers
serving approximately 44,400 children of eligible clients about $121 million,
including about $8 million in corrective payments.

The DSS provides subsidy funds to child care providers who serve eligible
clients (parents/caregivers). Once approved for services, the client selects a
provider and the DSS enters into an agreement/contract with the provider. An
eligibility specialist sets maximum authorized service units for the amount
and type of care that best meets the client's need, and enters this into the
Family Assistance Management Information System (FAMIS) for each child.
In October 2019, the DSS implemented a new electronic time and attendance
reporting system, the Child Care Business Information Solution (CCBIS).
Clients create and use CCBIS profiles to check their children in and out of the
provider's care. The CCBIS maintains information related to these events,
such as the date, time, and client presence; and requires this information for
payment. This information is later approved by clients and used by providers
to invoice the DSS monthly. The CCBIS interfaces with the FAMIS to
systematically process payments. The DSS added providers to the CCBIS
throughout the year ended June 30, 2021, and most providers were using the
CCBIS by June 2021.

While most provider payments are systematic through the CCBIS/FAMIS
interface, some corrective (manual) payments are needed. If a provider
identifies discrepancies in its systematic payment(s), the provider may
request corrective payment from the DSS within 60 days of a service month's
end. Corrective payment requests must be supported by payment resolution
request (PRR) forms summarizing the discrepancy and client-signed copies
2021-007.
Child Care Corrective
Payments

46
State of Missouri - Single Audit
Schedule of Findings and Questioned Costs
Year Ended June 30, 2021
of attendance records. DSS personnel within the Child Care Payment Unit
review and approve the PRR form and attendance records and issue the
corrective payment. Payment discrepancies requiring corrective payments
can occur for various reasons, such as instances in which a client failed to
sign the child in and/or out. There was an increase in corrective payments
during the year ended June 30, 2021, as a result of certain leniencies granted
during the pandemic and possibly attributable to clients and providers gaining
experience with the CCBIS.

To test compliance with program requirements, we selected a sample of 60
children. For each child, we reviewed related provider agreements and
documentation supporting payment(s) for one service month, including
corrective payments if applicable. The department made payments totaling
approximately $32,400 to providers on behalf of these 60 children for the
month reviewed, including approximately $2,300 in corrective payments for
13 children. Documentation was not adequate to support corrective payments
for 3 of 13 cases with corrective payments reviewed (23 percent). The DSS
could not locate the PRR form or attendance records supporting the corrective
payment for 1 case. The corrective payments for the other 2 cases were made
in error because the submitted attendance records did not support the payment
and/or total payments exceeded the maximum monthly amount authorized for
the child. Unsupported/unauthorized corrective payments for these 3 cases
totaled $196. We question the federal share, or $179 (91.51 percent).

Rule 45 CFR Section 75.303(a) requires the non-federal entity to "[e]stablish
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." Rule 45 CFR Section 98.68(a) requires the
lead agency to document in its Child Care subsidy state plan that is has
effective controls to ensure integrity and accountability in the program. To
ensure controls are effective, the DSS needs to review, strengthen, and
enforce policies and procedures to ensure Child Care subsidy provider
corrective payments are properly supported and authorized.

Effective August 28, 2021, through Executive Order 21-02, the Governor
transferred the Child Care program, including some personnel, from the DSS
to the Department of Elementary and Secondary Education (DESE) - Office
of Childhood. The DSS remained the lead agency responsible for all Child
Care program policies and procedures during the year ended June 30, 2021.
In subsequent years, the DSS will continue to perform certain agreed-upon
responsibilities for the program.

The DSS and the DESE review, strengthen, and enforce policies and
procedures regarding Child Care subsidy provider corrective payments.
These procedures should include receipt and retention of payment resolution
request forms and attendance records that sufficiently support the corrective

Program transfer
Recommendation

47
State of Missouri - Single Audit
Schedule of Findings and Questioned Costs
Year Ended June 30, 2021
payments. The DSS should review and correct the overpayments for the
children identified in this finding.

We partially agree with the auditor's finding. Our Corrective Action Plan
includes an explanation and specific reasons for our disagreement and any
planned actions to address the finding.

The Corrective Action Plan (CAP), issued by the DSS and the DESE, states
the DSS and the DESE disagree the errors identified in the finding are
significant. In the CAP, the DSS and the DESE recalculated an immaterial
audit test error rate; and argued that even though payments were made without
required documentation for 2 of the 3 errors, the errors were not "true" errors
because they did not result in improper payments.

The DSS's and the DESE's attempt to restate the audit test results, for the
purpose of minimizing these errors, is misleading. The DSS/DESE-
recalculated error rate includes each individual service unit (attendance date)
for both types of payments (systematic and corrective) tested in our sample
of 60. While the total test results were considered when giving our opinion
on the Child Care program as a whole, it was necessary to evaluate the results
of the testing of systematic and corrective payments separately because the
payment types are under separate internal control structures. The finding
addresses the internal control deficiencies and errors associated with the
corrective payments; therefore, in order to put these items into proper
perspective, it is more appropriate to describe the test results specific to
corrective payments. Because documentation was not adequate to support
corrective payments for 3 of 13 cases with corrective payments reviewed (23
percent), and corrective payments were material to the program (about $8
million during the year), there is a reasonable possibility that noncompliance
was not prevented, or detected and corrected, on a timely basis during the
audit period. Therefore the finding is valid.

Federal Agency:
Department of Health and Human Services (DHHS)
Federal Program:
93.558 Temporary Assistance for Needy Families
(TANF)

2020 - 2001MOTANF
2021 - 2101MOTANF

93.568 COVID-19 - Low-Income Home Energy
Assistance (LIHEAP)

93.568 Low-Income Home Energy Assistance
(LIHEAP)

2021 - 2101MOLIEA
Federal Agency:
Department of Justice (DOJ)
Federal Program:
16.575 Crime Victim Assistance (CVA)

2017 - 2017-VA-GX-0079
2018 - 2018-V2-GX-0035
Auditee's Response
Auditor's Comment
2021-008.
DSS FFATA Reporting

48
State of Missouri - Single Audit
Schedule of Findings and Questioned Costs
Year Ended June 30, 2021
2019 - 2019-V2-GX-0044
State Agency:
Department of Social Services (DSS) - Division of
Finance and Administrative Services (DFAS)
Type of Finding:
Internal Control (Significant Deficiency) and
Noncompliance

The DFAS needs to strengthen internal controls related to Federal Funding
Accountability and Transparency Act (FFATA) reporting for the TANF,
LIHEAP, and CVA programs. During state fiscal year 2021, the DFAS did
not fully comply with FFATA reporting requirements for more than half of
the subawards reviewed. During state fiscal year 2021, the DSS disbursed
approximately $12 million in first-tier subawards15 to 133 subrecipients of the
TANF program, $54 million in first-tier subawards to 21 subrecipients of the
LIHEAP, and $50 million in first-tier subawards to 131 subrecipients of the
CVA program. First-tier subawards accounted for approximately 6 percent,
67 percent, and 97 percent of the TANF, LIHEAP, and CVA programs'
expenditures, respectively.

The FFATA requires comprehensive reporting for certain federal awards to
promote transparency and accountability over the use of the federal funds.
Rule 2 CFR Part 170, Appendix A, requires the DFAS to report first-tier
subawards of $30,000 or more to the FFATA Subaward Reporting System
(FSRS) no later than the end of the month following the month in which the
subaward was made. Information entered into the FSRS is publicly available
at USASpending.gov.

DFAS policies and procedures over the FFATA reporting process require a
supervisory review of the information uploaded to the FSRS, but do not
require the supervisors maintain documentation of reviews performed.

DFAS personnel prepare a monthly excel spreadsheet of data from various
sources including contracts and federal funding disclosure information sheets.
DFAS personnel transfer the spreadsheet data to the federal FSRS template,
and upload the data to the FSRS. Various subaward data is uploaded,
including the entity name, award amount, and the date issued. No one could
provide documentation supporting the supervisory reviews performed.

Without adequate documented supervisory review over FFATA reporting, the
DFAS has less assurance the information included in the FFATA reporting
for the TANF, LIHEAP, and CVA programs are complete and accurate. Rule
2 CFR Section 200.303(a) requires the non-federal entity to "[e]stablish and
maintain effective internal control over the Federal award that provides

15First-tier subawards are federal awards made to non-federal entities by the prime award
recipient, in this case the DSS, on behalf of the federal awarding agencies, the DHHS and the
DOJ.

Internal controls

49
State of Missouri - Single Audit
Schedule of Findings and Questioned Costs
Year Ended June 30, 2021
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."

The DFAS did not comply with FFATA reporting requirements for the
TANF, LIHEAP, and CVA programs. To test compliance with FFATA
reporting requirements, we reviewed 41 program subawards totaling $14
million for the TANF, LIHEAP, and CVA programs awarded in fiscal year
2021. Instances of noncompliance identified are shown in the following table.

Transactions
Tested
Subaward not
reported (1)
Report not
timely (2)
Subaward
amount incorrect
Subaward missing key data
elements
41
3
24
0
0
Dollar Amount
of Tested Transactions
Subaward not
reported
Report not
timely (2)
Subaward
amount incorrect
Subaward missing key data
elements
$14,019,443
$362,528
$13,098,375
$0
$0
(1) All were CVA subawards.
(2) Reports were submitted 14 days to 3 months after the last day of the month following the month in which the subawards were made. We
identified 20 errors totaling $955,500 for the TANF program and 4 errors totaling $12,142,875 for the LIHEAP program.

DFAS personnel could not explain why these errors occurred. In addition to
noncompliance with federal requirements, not reporting subawards to the
FSRS accurately and timely increases the risk that those using the reports
could rely on inaccurate information.

The DSS through the DFAS strengthen internal controls related to FFATA
reporting by having supervisors maintain documentation of reviews
performed of the information reported to the FSRS for the TANF, LIHEAP,
and CVA programs. In addition, the DFAS should complete FFATA
reporting in accordance with the applicable requirements.

We partially agree with the auditor's finding. Our Corrective Action Plan
includes an explanation and specific reasons for our disagreement and any
planned actions to address the finding.

The DSS Corrective Action Plan (CAP) states the DSS disagrees that having
supervisors document their review of information reported to the FSRS is a
necessary component of strong internal controls because regulations do not
require documentation of such reviews. The CAP states the DSS adheres to
formalized procedures for FFATA reporting. However, without requiring
documentation of supervisory reviews performed, the DSS cannot
demonstrate adherence to the established policies and procedures. Because
effective internal controls include documentation demonstrating the controls

FFATA reporting
Recommendation
Auditee's Response
Auditor's Comment

50
State of Missouri - Single Audit
Schedule of Findings and Questioned Costs
Year Ended June 30, 2021
are operating in accordance with the established internal control system, this
finding is valid.

Federal Agency:
Department of Health and Human Services
Federal Program:
93.323 COVID-19 - Epidemiology and Laboratory
Capacity for Infectious Diseases (ELC)

93.323 Epidemiology and Laboratory Capacity for
Infectious Diseases (ELC)

2019 and 2020 - NU50CK000546
State Agency:
Department of Health and Senior Services (DHSS) -
Division of Community and Public Health (DCPH)
Type of Finding:
Internal Control (Material Weakness) and
Noncompliance
Questioned Costs:
$105,507

The DHSS did not have sufficient controls and procedures to ensure ELC
program reimbursements to subrecipients were allowable, reasonable, and
supported with sufficient documentation. As a result, unsupported
reimbursements totaling $105,507 were made to some subrecipients.

The ELC program was developed to help combat infectious diseases and
support public health agencies, with funding and resources for detection and
prevention of disease. With the rise of COVID-19, the DHSS, through the
ELC program, received and spent funds for testing, contact tracing,
vaccinations, and other COVID-19 activities. The DHSS, through the DCPH,
provides ELC program funding to subrecipients to provide COVID-19
support to communities. During the year ended June 30, 2021, the DHSS
disbursed approximately $22.7 million to 123 subrecipients of the ELC
program, including county and city health departments and universities.
Disbursements to subrecipients represented approximately 53 percent of the
program's expenditures.

Rule 2 CFR Section 200.403 provides that costs charged to federal programs
should be necessary and reasonable for the performance of the federal award
and adequately documented.

Per Section 6 of the program services contract, ELC program subrecipients
must submit a completed request for payment form monthly for
reimbursement of costs. The request for payment form consists of one single
amount, representing the total amount of expenditures requested for
reimbursement. No other documentation is required for reimbursement.
DCPH staff review, approve, and process the forms for reimbursement;
however, the DCPH has not implemented procedures for reviewing detailed
supporting documentation, at least on a test basis. In addition, as noted in
finding number 2021-010, the DCPH did not adequately monitor the ELC
program subrecipients.

2021-009.
ELC Program Subrecipient
Reimbursements

51
State of Missouri - Single Audit
Schedule of Findings and Questioned Costs
Year Ended June 30, 2021
To test compliance with program requirements, we selected a sample of 60
reimbursements totaling $469,675 to 33 subrecipients during the year ended
June 30, 2021. Documentation was not adequate to support 14 of 60
reimbursements reviewed (23 percent).16 These 14 reimbursements, which
were made to 13 county health departments, were supported by a request for
payment form but no other documentation. To determine whether these 14
reimbursements were allowable and adequately supported, we requested
DCPH staff obtain detailed supporting documentation such as invoices,
receipts, and/or payroll records from the subrecipients. In response to our
request, the DCPH provided quarterly activity reports prepared by the
subrecipients, containing brief written summaries and descriptions of services
performed during the quarter. The DCPH did not obtain and provide any
detailed supporting documentation for these 14 reimbursements. DCPH
officials indicated they believed the quarterly reports were sufficient to
support the reimbursements; however, relying on quarterly summary reports
without detailed supporting documentation does not provide adequate
assurance the reimbursements were in accordance with federal requirements.
We question the federal share of the 14 unsupported reimbursements, or
$105,507 (100 percent). Known questioned costs for unsupported
reimbursements to ELC program subrecipients represent approximately 22
percent of reimbursements reviewed. If similar errors were made on the
remaining population of ELC program subrecipient reimbursements,
questioned costs could be significant.

Without procedures for reviewing detailed documentation supporting
reimbursements to ELC program subrecipients, the DCPH cannot
demonstrate adequate internal controls to ensure costs are allowable,
reasonable, and supported. Rule 2 CFR Section 200.303(a) requires the non-
federal entity to "[e]stablish and maintain effective internal control over the
Federal award that provides reasonable assurance that the non-federal entity
is managing that Federal award in compliance with Federal statutes,
regulations, and the terms and conditions of the Federal award."

The DHSS through the DCPH establish procedures for reviewing detailed
documentation supporting reimbursements to ELC program subrecipients to
ensure costs are allowable, reasonable, and supported.

We disagree with the auditor's finding. Our Corrective Action Plan includes
an explanation and specific reasons for our disagreement.

The DHSS Corrective Action Plan states the DHSS disagrees with the finding
because the department plans to begin reviewing detailed documentation

16 Although not required, some subrecipients attached detailed supporting documentation to
their request for payment forms.
Recommendation
Auditee's Response
Auditor's Comment

52
State of Missouri - Single Audit
Schedule of Findings and Questioned Costs
Year Ended June 30, 2021
supporting subrecipient reimbursements when it starts performing
subrecipient monitoring procedures in state fiscal year 2023. However,
because the DCPH did not review documentation supporting reimbursements
to ELC program subrecipients during the audit period, this finding is valid.

Federal Agency:
Department of Health and Human Services
Federal Program:
93.323 COVID-19 - Epidemiology and Laboratory
Capacity for Infectious Diseases (ELC)

93.323 Epidemiology and Laboratory Capacity for
Infectious Diseases (ELC)

2019 and 2020 - NU50CK000546
State Agency:
Department of Health and Senior Services (DHSS) -
Division of Community and Public Health (DCPH)
Type of Finding:
Internal Control (Material Weakness) and
Noncompliance

The DCPH did not perform subrecipient monitoring procedures in accordance
with the department monitoring policy. During the year ended June 30, 2021,
the DHSS disbursed approximately $22.7 million to 123 ELC subrecipients.

Rule 2 CFR Section 200.332(b) requires pass-through entities to 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. Rule 2 CFR Section 200.332(d) requires
pass-through entities to monitor the activities of subrecipients as necessary to
ensure the subaward is used for authorized purposes, complies with the terms
and conditions of the subaward, and achieves performance goals. Pass-
through entities are required to follow up and ensure the subrecipient takes
timely and appropriate action on all deficiencies detected through audits, on-
site reviews, and other means.

The DHSS's subrecipient monitoring process, outlined in the DHSS's
Financial Policy, provides the requirements for monitoring the department's
subrecipient financial assistance agreements. Program divisions are required
to develop a monitoring plan for each subrecipient contract. Monitoring plans
include the planned frequency of monitoring activities, monitoring
procedures to be utilized, and potential corrective actions. The types of
monitoring can include routine receipt and review of required reports,
invoices, receipts, and supporting documentation and periodic on-site visits
or desk reviews. In addition, the monitoring process requires a risk
assessment at the start of a new subrecipient contract and categorizes each
subrecipient contract as high, medium, or low risk. The risk category
determines the required type and nature of further monitoring of the
subrecipient contract.

2021-010.
ELC Program Subrecipient
Monitoring

53
State of Missouri - Single Audit
Schedule of Findings and Questioned Costs
Year Ended June 30, 2021
During state fiscal year 2021, the DCPH did not adequately monitor ELC
program subrecipients. The DCPH did not develop a monitoring plan as
required by the DHSS monitoring policy. In addition, risk assessments to
determine the nature, timing, and extent of monitoring procedures; and
monitoring reviews were not performed as required by federal regulations and
the monitoring policy. DCPH officials indicated subrecipient monitoring
procedures were not performed due to the rapid distribution of COVID-19
funding to subrecipients. DCPH officials also indicated they intend to start
performing monitoring reviews in state fiscal year 2023 with all reviews
completed by March 2024.

When subrecipient monitoring procedures are not performed, there is
increased risk that noncompliance with program requirements will go
undetected. A detailed monitoring plan for ELC subrecipients is necessary to
demonstrate adequate internal controls over compliance with subrecipient
monitoring requirements. Rule 2 CFR Section 200.303(a) requires the non-
federal entity to "[e]stablish and maintain effective internal control over the
Federal award that provides reasonable assurance that the non-federal entity
is managing that Federal award in compliance with Federal statutes,
regulations, and the terms and conditions of the Federal award."

The DHSS through the DCPH ensure subrecipient monitoring procedures are
performed in accordance with the department monitoring policy.

We agree with the auditor's finding. Our Corrective Action Plan includes our
planned actions to address the finding.

Federal Agency:
Department of Health and Human Services (DHHS)
Federal Program:
93.323 COVID-19 - Epidemiology and Laboratory
Capacity for Infectious Diseases (ELC)

93.323 Epidemiology and Laboratory Capacity for
Infectious Diseases (ELC)

2019 NU50CK000546
2020 NU50CK000546
State Agency:
Department of Health and Senior Services (DHSS)
Type of Finding:
Noncompliance

During state fiscal year 2021, the DHSS did not complete Federal Funding
Accountability and Transparency Act (FFATA) reporting within required
timeframes for some ELC program subawards. During that fiscal year, the
DHSS disbursed $22.7 million in first-tier subawards17 to 123 subrecipients

17First-tier subawards are federal awards made to non-federal entities by the prime award
recipient, in this case the DHSS, on behalf of the federal awarding agency, the DHHS.
Recommendation
Auditee's Response
2021-011.
DHSS FFATA Reporting

54
State of Missouri - Single Audit
Schedule of Findings and Questioned Costs
Year Ended June 30, 2021
of the ELC program. First-tier subawards accounted for approximately 53
percent of the program's expenditures.

The FFATA requires comprehensive reporting for certain federal awards to
promote transparency and accountability over the use of the federal funds.
Rule 2 CFR Part 170, Appendix A, requires the DHSS to report first-tier
subawards of $30,000 or more to the FFATA Subaward Reporting System
(FSRS) no later than the end of the month following the month in which the
subaward was made. Various subaward data is reported, including the entity
name, award amount, and the date issued. Information entered into the FSRS
is publicly available at USASpending.gov.

To test compliance with FFATA reporting requirements, we reviewed 24
ELC program subawards totaling approximately $1.5 million, awarded in
state fiscal year 2021. Of the subawards reviewed, 8 (33 percent) totaling
$553,050 were not uploaded to the FSRS timely. These subawards were
reported 25 days to 7 months after the last day of the month following the
month in which the subawards were made. DHSS officials indicated the
delays occurred because other COVID-19 related responsibilities took
precedence over FFATA reporting.

In addition to noncompliance with federal requirements, not reporting
subawards to the FSRS timely increases the risk that those using the reports
could rely on inaccurate information.

The DHSS complete FFATA reporting for the ELC program within required
timeframes.

We agree with the auditor's finding. Our Corrective Action Plan includes our
planned actions to address the finding.

Federal Agency:
Department of Health and Human Services
Federal Program:
93.778
93.778
COVID-19 - Medical Assistance Program
Medical Assistance Program

 2020 - 2005MO5MAP and 2005MO5ADM
2021 - 2105MO5MAP and 2105MO5ADM
State Agency:
Department of Health and Senior Services (DHSS) -
Division of Senior and Disability Services (DSDS)
Type of Finding:
Internal Control (Significant Deficiency) and
Noncompliance

The DSDS does not have effective controls in place to ensure Participant
Choice Agreements were obtained and/or retained for participants of the State
Plan Personal Care (SPPC) program.

Recommendation
Auditee's Response
2021-012.
Medicaid SPPC Participant
Choice Agreements

55
State of Missouri - Single Audit
Schedule of Findings and Questioned Costs
Year Ended June 30, 2021
The DSDS is responsible for the direct administration of various Medical
Assistance Program (Medicaid)-funded Home and Community Based
Services (HCBS) programs for seniors and adults with disabilities, including
the SPPC. During the year ended June 30, 2021, the DHSS made payments
totaling approximately $816 million on behalf of approximately 63,000
participants of the SPPC.

As part of the initial assessment and annual reassessment processes, DSDS
personnel are required to ensure a Participant Choice Agreement (DA-3 form)
was signed by the participant and the assessor, and uploaded to the
CyberAccess web tool. The DSDS utilizes Participant Choice Agreements to
comply with 42 CFR Section 441.301(c)(4) and 42 CFR Section 441.302(d)
that require participants be provided information and given choices regarding
their care. Assessments and reassessments are completed by either DSDS
personnel or provider personnel. DSDS personnel perform quality assurance
reviews of assessments and reassessments completed by provider personnel,
and are to ensure a signed Participant Choice Agreement was uploaded. Once
the Participant Choice Agreement is uploaded to the CyberAccess web tool
by the assessor, the original agreement is not retained.

To test compliance with federal requirements, we reviewed CyberAccess web
tool records for 60 participants enrolled in the SPPC program during the year
ended June 30, 2021. A Participant Choice Agreement was not in the web
tool or retained elsewhere for 5 participants (8 percent) reviewed.
Assessments or reassessments for these 5 participants were completed by
providers, and DSDS quality assurance reviews did not identify these missing
agreements. DSDS officials were unable to determine whether the forms were
obtained but not uploaded to the CyberAccess web tool or were never
obtained.

Without obtaining and retaining a Participant Choice Agreement, the DSDS
cannot demonstrate the participant was provided the proper choices in care
services as required. Rule 45 CFR Section 75.303(a) requires the non-federal
entity to "[e]stablish 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."

The DHSS through the DSDS implement procedures to ensure a signed
Participant Choice Agreement is obtained and retained for all participants of
the State Plan Personal Care program.

We agree with the auditor's finding. Our Corrective Action Plan includes our
planned actions to address the finding.

Recommendation
Auditee's Response

56
State of Missouri - Single Audit
Schedule of Findings and Questioned Costs
Year Ended June 30, 2021
Federal Agency:
Department of Health and Human Services (DHHS)
Federal Program:
93.777 COVID-19 - State Survey and Certification
of Health Care Providers and Suppliers (Title
XVIII) Medicare

93.777 State Survey and Certification of Health Care
Providers and Suppliers (Title XVIII)
Medicare

2017, 2019, 2020, and 2021 - TITLEXVIII
2019, 2020, and 2021 - TITLEXIXSS

2020 and 2021 - CLIA

2020 and 2021 - TITLE18CRS
2020 and 2021 - XVIIIIMPAC
State Agency:
Department of Health and Senior Services (DHSS) -
Section for Long-Term Care Regulation (SLCR)
Type of Finding:
Noncompliance

The SLCR did not perform facility survey procedures within required
timeframes. During the year ended June 30, 2021, the DHSS through the
SLCR surveyed 539 providers, including 526 long-term care nursing facilities
and 13 independent care facilities for individuals with intellectual disabilities.

The DHSS is the state survey agency charged with inspecting providers of the
Medical Assistance Program (Medicaid), including hospitals, nursing
facilities, and other long-term care facilities. Under 42 CFR Section 431.108,
as a basis for participation in Medicaid, providers are subject to survey and
certification by the DHHS - Centers for Medicare and Medicaid Services
(DHHS-CMS) or the DHSS to ensure providers and suppliers are in
compliance with regulatory health and safety standards and conditions of
participation.

The DHHS-CMS provides the State Operations Manual (SOM) to state
agencies as guidelines for the survey and certification of providers. SOM
Chapter 2, Section 2728, requires the state agency to mail the provider a copy
of Form CMS-2567 (Statement of Deficiencies and Plan of Correction)
within 10 working days after the survey. In addition, SOM Chapter 7, Section
7317.2, requires onsite revisits to occur any time between the last correction
date on the plan of correction and the 60th day from the survey date to confirm
the facility is in substantial compliance, and in certain cases, has the ability
to remain in substantial compliance. Due to the COVID-19 pandemic, in
March 2020, the DHHS issued a memo to all state survey agencies that
suspended non-emergency surveys and prioritized all remaining survey
activity. This allowed agencies to focus their surveys on infectious disease
and abuse concerns and complaints. In August 2020, the DHHS-CMS issued
a memo allowing for the resumption of suspended surveys as long as the state
survey agencies had the necessary resources available to conduct those
surveys.
2021-013.
Medicaid Facility Survey
Timeliness

57
State of Missouri - Single Audit
Schedule of Findings and Questioned Costs
Year Ended June 30, 2021
To test compliance with survey and certification requirements, we reviewed
32 provider surveys performed between September 1, 2020, and June 30,
2021. Of 31 surveys that required a Statement of Deficiencies and Plan of
Correction, 8 statements (26 percent) were sent to facilities between 11 and
27 working days after survey exit instead of within 10 working days as
required. DHSS officials indicated these delays were due in part to staff being
reassigned to duties associated with COVID-19, staffing shortages within the
DHSS, and increased findings of noncompliance leading to longer write-up
time. In addition, of the 12 providers that required a revisit, the revisits to 2
facilities (17 percent) were completed 71 and 85 days after the initial survey
date instead of within 60 days as required. DHSS officials indicated these
items were delayed due to various facility issues including staffing shortages,
large number of deficiencies, and/or inadequate plans of correction.

The DHSS through the SLCR ensure survey procedures are conducted within
required timeframes.

We agree with the auditor's finding. Our Corrective Action Plan includes our
planned actions to address the finding.

Federal Agency:
Department of Health and Human Services (DHHS)
Federal Program:
93.778
93.778
COVID-19 - Medical Assistance Program
Medical Assistance Program

2020 - 2005MO5MAP and 2005MO5ADM
2021 - 2105MO5MAP and 2105MO5ADM
State Agency:
Department of Mental Health (DMH) - Division of
Developmental Disabilities (DD)
Type of Finding:
Noncompliance

As noted in our prior 6 audit reports,18 the DD continued to pay historical per
diem rates to providers for residential habilitation services provided to
participants of the Home and Community Based Services (HCBS),
Developmental
Disabilities
Comprehensive Waiver
(Comprehensive
Waiver) program, but did not retain adequate documentation to support these
rates. As a result, the DD could not demonstrate some amounts paid were
allowable costs of the Comprehensive Waiver program.

The DD with its six habilitation centers and five regional offices is
responsible for the direct administration of various Medical Assistance
Program (Medicaid)-funded HCBS programs for children and adults with
disabilities, including the Comprehensive Waiver program. Various types of

18See single audit reports at <https://auditor.mo.gov/AuditReport/Reports?SearchLocalState=
35>, finding numbers 2020-005, 2019-007, 2018-014, 2017-017, 2016-006, and 2015-015.

Recommendation
Auditee's Response
2021-014.
Medicaid Developmental
Disabilities
Comprehensive Waiver
Per Diem Rates

58
State of Missouri - Single Audit
Schedule of Findings and Questioned Costs
Year Ended June 30, 2021
services are allowed under the waiver, including residential habilitation
services provided to 1,511 participants in group homes and 5,487 participants
served by individualized supported living (ISL) providers during the year
ended June 30, 2021. Residential habilitation services include care,
supervision, and skills training in activities of daily living, home
management, and community integration. Providers are paid a per diem rate
for each participant receiving these services, based on the individual's needs.
Certain costs, such as room and board, are not allowed to be included in per
diem rates under the waiver program. During the year ended June 30, 2021,
per diem payments for group home services totaled approximately $125
million, and per diem payments for ISL services totaled approximately $670
million.

In October 2013, the DD began phasing in acuity-based per diem rates to
replace historical rates for residential habilitation services, and renewed the
Comprehensive Waiver in July 2016 to include the new rates. However, these
acuity-based per diem rates were not fully phased in as of June 30, 2021.
Payments at the historical per diem rates are expressed as a percentage of the
acuity-based rates, but some of these rates exceed 100 percent of the acuity-
based rates. For participants who received residential habilitation services
during the year ended June 30, 2021, DD officials indicated the DMH paid
acuity-based per diem rates for approximately 92 percent of the participants
in group homes and approximately 60 percent of the participants in ISL
placements, and historical per diem rates for the remaining 8 percent and 40
percent, respectively. In state fiscal year 2022, the DMH received funding to
fully phase in group home and ISL rates to the acuity-based rates. A corrective
action plan approved by the federal DHHS - Centers for Medicare and
Medicaid Services (DHHS-CMS), Division of Medicaid Field Operations-
North in June 2019, stated the rates for ISL providers are planned to be fully
implemented by 2024.

As noted in prior audits, the DD does not retain documentation to support per
diem rates paid at historical rates exceeding acuity-based rates. The DD
retains the group home individual plan of care and cost of living allowance
(COLA) notices supporting some per diem rate increases. However, these
documents do not show how the rate was originally determined or what costs
were included in the per diem rate. To test compliance with various
Comprehensive Waiver program requirements, we tested 60 payments to
service providers during the year ended June 30, 2021. Of these 60 payments,
32 were to ISL providers, and 9 were to group homes for habilitation services.
All ISL and group home payments tested were based on acuity-based per
diem rates or historical rates that were less than or equal to acuity-based rates;
therefore, no questioned costs were identified for the year ended June 30,
2021.

59
State of Missouri - Single Audit
Schedule of Findings and Questioned Costs
Year Ended June 30, 2021
Audits performed by the DHHS - Office of Inspector General (DHHS-OIG),
Missouri Claimed Unallowable and Unsupported Medicaid Payments for
Group Home Habilitation Services, released in August 2015, and Missouri
Claimed Unallowable Medicaid Payments for Individualized Supported
Living Habilitation Services, released in March 2016, noted similar concerns
with unsupported per diem rates for some group home payments and noted
some ISL payments included unapproved and unallowable costs.

Payments to providers for those participants that have not been transitioned
from the historical per diem rates to the acuity-based per diem rates, and at
rates that exceed 100 percent of the acuity-based rates, are not adequately
supported and documented as required by federal regulations. Similar errors
of noncompliance will likely continue until all participants are transitioned to
the acuity-based rate model.

Without proper documentation of the payment rates, the DD cannot
demonstrate that payments based on these rates are proper and only include
allowable costs. Rule 42 CFR Section 447.203(a) states, "[t]he agency must
maintain documentation of payment rates. . . ." Rule 2 CFR Section
200.403(g) states costs must be adequately documented to be allowable. Also,
the approved DD Comprehensive Waiver Program Application, Appendix I:
Financial Accountability, section I-2(e), states "[r]ecords documenting the
audit trail of adjudicated claims (including supporting documentation) are
maintained by the Medicaid agency, the operating agency (if applicable), and
providers of waiver services for a minimum period of 3 years." Adequate
documentation of habilitation services per diem rates is necessary to ensure
compliance with the federal requirements related to the Comprehensive
Waiver program and to ensure only allowable costs are included in the per
diem rates.

The DMH through the DD continue to transition all per diem rates paid to
providers for residential habilitation services provided under the
Comprehensive Waiver program from historical rates to acuity-based rates
and ensure documentation to support per diem rates is maintained as required.

We disagree with the auditor's finding. Our Corrective Action Plan includes
an explanation and specific reasons for our disagreement.

The DMH Corrective Action Plan states the DMH disagrees with the finding
because all existing rates are now a factor of a rate study, the rate study serves
as the documentation for all residential rates paid, and any other forms of
documentation are irrelevant. However, as stated in the finding, payments to
providers for any participants at historical per diem rates that exceed 100
percent of amounts calculated using the rate study are not adequately
supported and documented, as required by federal regulations. Because the
Recommendation
Auditee's Response
Auditor's Comment

60
State of Missouri - Single Audit
Schedule of Findings and Questioned Costs
Year Ended June 30, 2021
DMH had not transitioned all participants to the acuity-based model as of the
year ended June 30, 2021, this finding is valid.

Federal Agency:
Department of Education (USDE)
Federal Program:
84.425C COVID-19 - Governor's Emergency
Education Relief (GEER) Fund

 2020 - S425C200016
State Agency:
Department of Elementary and Secondary Education
(DESE)
Type of Finding:
Noncompliance

The DESE did not report subaward information in its annual performance
report of the GEER Fund for the period March 13 through September 30,
2020.

Rule 2 CFR Section 200.329(c), requires non-federal entities to submit
performance reports at the interval required by the federal awarding agency
containing data elements approved by the OMB. GEER Fund recipients are
required to submit an annual performance report (OMB Form No. 1810-0748)
to the USDE describing how the state and subgrantees used the awarded funds
during the performance period. In the report, recipients are to report total
amounts allocated and expended as well as various subaward information
including each subgrantee and award amount.

The GEER Fund grant was initially awarded to the Governor's office. The
Office of Administration (OA), on behalf of the Governor's office, entered
into an interagency agreement with the DESE and the Department of Higher
Education and Workforce Development (DHEWD), designating the DESE as
the fiscal agent for the GEER Fund for the State of Missouri. The DESE
draws down and disburses the funds to DESE subrecipients (Local Education
Agencies [LEAs]) or to the DHEWD. The DHEWD disburses funds to the
DHEWD subrecipients (Institutions of Higher Education [IHEs]). The
interagency agreement states the DESE shall manage all reporting
requirements by collecting information and data including data from the
DHEWD and the OA.

In the annual performance report submitted for the period March 13 through
September 30, 2020, the DESE did not correctly report the GEER Fund
subawards. In the subgrantee sections, the DESE did not report any detail for
the 549 LEA subawards totaling $30 million and the 23 IHE subawards
totaling $23.6 million. Instead, the DESE incorrectly reported the amounts
allocated by the state to the DESE and the DHEWD. DESE personnel
indicated the reporting errors occurred due to the unusual nature of the GEER
Fund allocations and a misunderstanding of guidance received from the
USDE. DESE personnel also indicated most of the performance report data
was transferred from the Federal Funding Accountability and Transparency
2021-015.
GEER Fund Annual
Performance Reporting

61
State of Missouri - Single Audit
Schedule of Findings and Questioned Costs
Year Ended June 30, 2021
Act submissions, which also incorrectly excluded subgrantee information
(see finding number 2021-016).

In addition to noncompliance with federal requirements, not accurately
reporting annual performance data increases the risk that those using the
report could rely on inaccurate information.

The DESE ensure accurate annual performance reports are submitted for the
GEER Fund.

We agree with the auditor's finding. Our Corrective Action Plan includes our
planned actions to address the finding.

Federal Agency:
Department of Education (USDE)
Federal Program:
84.425C COVID-19 - Governor's Emergency
Education Relief (GEER) Fund

 2020 - S425C200016

84.425D COVID-19 - Elementary and Secondary
School Emergency Relief (ESSER) Fund

 2021 - S425D210021 and S425U210021
State Agency:
Department of Elementary and Secondary Education
(DESE)
Type of Finding:
Noncompliance

During state fiscal year 2021, the DESE did not comply with Federal Funding
Accountability and Transparency Act (FFATA) reporting requirements for
any of the subawards reviewed for the GEER Fund and the ESSER Fund
grants.

The FFATA requires comprehensive reporting for certain federal awards to
promote transparency and accountability over the use of the federal funds.
Rule 2 CFR Part 170, Appendix A, requires the DESE to report first-tier
subawards19 of $30,000 or more to the FFATA Subaward Reporting System
(FSRS) no later than the end of the month following the month in which the
subaward was made. Various subaward data is reported, including the entity
name, award amount, and the date issued. Information entered into the FSRS
is publicly available at USASpending.gov.

The GEER Fund grant was initially awarded to the Governor's office. The
Office of Administration (OA), on behalf of the Governor's office, entered
into an interagency agreement with the DESE and the Department of Higher
Education and Workforce Development (DHEWD), designating the DESE as
the fiscal agent for the GEER Fund for the State of Missouri. The DESE

19First-tier subawards are federal awards made to non-federal entities by the prime award
recipient, in this case the DESE, on behalf of the federal awarding agency, the USDE.
Recommendation
Auditee's Response
2021-016.
DESE FFATA Reporting

62
State of Missouri - Single Audit
Schedule of Findings and Questioned Costs
Year Ended June 30, 2021
draws down and disburses the funds to the DESE subrecipients (Local
Education Agencies [LEAs]) or to the DHEWD. The DHEWD disburses
funds to the DHEWD subrecipients (Institutions of Higher Education
[IHEs]). The interagency agreement states the DESE shall manage all
reporting requirements by collecting information and data including data
from the DHEWD and the OA. During state fiscal year 2021, the DESE and
the DHEWD disbursed approximately $29.5 million in first-tier subawards to
401 subrecipients of the GEER Fund and the DESE disbursed approximately
$306.9 million in first-tier subawards to 554 subrecipients of the ESSER
Fund. First-tier subawards accounted for approximately 78 percent of the
GEER Fund expenditures and 99 percent of the ESSER Fund expenditures.

To test compliance with FFATA reporting requirements for the GEER Fund,
we reviewed the sole FSRS report submitted by DESE personnel during state
fiscal year 2021. The DESE did not report any of the 549 LEA subawards
totaling $30 million or the 23 IHE subawards totaling approximately $23.6
million in the FSRS. Instead, the DESE incorrectly reported as subawards,
the allocations by the state to the DESE and the DHEWD.

To test compliance with FFATA reporting requirements for the ESSER Fund,
we reviewed 40 ESSER Fund subawards totaling approximately $73.2
million awarded in state fiscal year 2021. Of the subawards reviewed, 40
subawards (100 percent) were not uploaded to the FSRS timely. These
subawards were reported 4 to 7 months after the last day of the month
following the month in which the subawards were made.

DESE personnel indicated the FFATA reporting errors occurred due to a
misunderstanding of FFATA reporting requirements as well as the unusual
nature of the GEER Fund allocations. In addition to noncompliance with
federal requirements, not reporting subawards to the FSRS accurately and
timely increases the risk that those using the reports could rely on inaccurate
information.

The DESE complete FFATA reporting for the GEER Fund and the ESSER
Fund in accordance with the applicable requirements.

We agree with the auditor's finding. Our Corrective Action Plan includes our
planned actions to address the finding.

Federal Agency:
Department of Education
Federal Program:
84.027 Special Education Grants to States

2018 - H027A180040 and H027A18004018A
2019 - H027A190040 and H027A19004019A
2020 - H027A200040 and H027A20004020A

84.173 Special Education Preschool Grants

2019 - H173A190103
2020 - H173A200103
Recommendation
Auditee's Response
2021-017.
Special Education Cluster
Subrecipient Monitoring

63
State of Missouri - Single Audit
Schedule of Findings and Questioned Costs
Year Ended June 30, 2021
State Agency:
Department of Elementary and Secondary Education
(DESE)
Type of Finding:
Internal Control (Significant Deficiency) and
Noncompliance

The DESE needs to strengthen internal controls to ensure compliance with
subrecipient monitoring requirements. During the year ended June 30, 2021,
the DESE did not perform subrecipient monitoring reviews in accordance
with its monitoring guide for the Special Education Cluster. The DESE
disbursed $212.3 million to 541 subrecipients for costs related to the Special
Education Cluster during the year ended June 30, 2021.

Rule 2 CFR Section 200.332(b) requires pass-through entities to 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. Rule 2 CFR section 200.332(d) requires
pass-through entities to monitor the activities of the subrecipient as necessary
to ensure that the subaward is used for authorized purposes, complies with
the terms and conditions of the subaward, and achieves performance goals.
Pass-through entities are required to follow up and ensure the subrecipient
takes timely and appropriate action on all deficiencies detected through
audits, on-site reviews, and other means.

Subrecipients for the Special Education Cluster are Local Education Agencies
(LEAs). The DESE's tiered monitoring process, outlined in the DESE's
Special Education Fiscal Monitoring Guide, provides for annual desk audits
and application reviews of all LEAs. Desk audit and application reviews
include review and approval of budget applications, payment requests, and
final expenditure reports. In addition, the monitoring guide requires an annual
risk assessment that evaluates various risk indicators and categorizes each
LEA as high, medium, or low risk. The risk category determines the required
type and nature of further monitoring of the LEA. With some exceptions, for
high-risk LEAs, on-site/virtual visits consisting of inspections of records,
tours of facilities, interviews of employees, and other procedures are required.
For medium-risk LEAs, self-assessment/desk monitoring reviews consisting
of review and verification of documentation supporting the LEA's responses
to a compliance questionnaire are required. For low-risk LEAs, no additional
action is required. No additional action is required for high-risk LEAs that
attended fiscal training, received phone monitoring, or received targeted
technical assistance in the prior fiscal year.

The monitoring guide provides that review reports listing any deficiencies
noted be generated for on-site/virtual visits and self-assessment/desk
monitoring reviews. The LEA is required to prepare a corrective action plan
(CAP) by a required due date outlining plans to correct the deficiencies and
implement procedural changes.

64
State of Missouri - Single Audit
Schedule of Findings and Questioned Costs
Year Ended June 30, 2021
During state fiscal year 2021, DESE Special Education personnel performed
risk assessments for all 541 Special Education Cluster LEAs; however, the
DESE did not perform monitoring reviews for some LEAs in accordance with
the monitoring guide. The following table shows the results of the risk
assessment performed for that fiscal year, and the monitoring reviews
required.

Assessed Risk
High
Medium
Low
 Number of LEAs
18
213
310

 Type of Monitoring
Required
On-site/
virtual visit
Self-assessment/
desk monitoring
No additional
action

For 7 of 18 LEAs categorized as high-risk, the DESE did not perform the
required on-site/virtual monitoring visits. Monitoring records indicate these 7
LEAs were exempt from such visits because they had attended fiscal training
in the prior fiscal year; however, no fiscal training took place in fiscal year
2020 due to the ongoing pandemic. DESE personnel indicated they
considered attendance at the state fiscal year 2019 training to meet the
monitoring guide's visit exemption requirement.

Our review of 25 on-site/virtual visits and self-assessment/desk monitoring
reviews performed during the state fiscal year ended June 30, 2021, identified
two incomplete reviews (8 percent). For both reviews, the LEAs had not
submitted requested or required information and DESE personnel had not
timely followed up with the LEAs about the outstanding items. One
onsite/virtual review was initiated in May 2021, but was not fully completed
as of April 2022. For one desk monitoring review completed in May 2021,
the LEA did not submit a CAP until January 2022, after our inquiry.

When subrecipient monitoring reviews are not performed in accordance with
the monitoring guide, there is increased risk that noncompliance with
program requirements will go undetected. Adequate internal controls are
necessary to ensure established policies and procedures over subrecipient
monitoring are followed. In addition, 2 CFR Section 200.303(a) requires the
non-federal entity to "[e]stablish 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."

The DESE strengthen controls and procedures to ensure subrecipients of the
Special Education Cluster are monitored in accordance with the monitoring
guide.

We agree with the auditor's finding. Our Corrective Action Plan includes our
planned actions to address the finding.

Recommendation
Auditee's Response

65
State of Missouri - Single Audit
Schedule of Findings and Questioned Costs
Year Ended June 30, 2021
Federal Agency:
Department of Education
Federal Program:
10.555

10.555
COVID-19 - National School Lunch
Program
National School Lunch Program

84.425C
COVID-19 - Governor's Emergency
Education Relief (GEER) Fund

84.126
Rehabilitation Services Vocational
Rehabilitation Grants to States

96.001
Social Security Disability Insurance
State Agency:
Department of Elementary and Secondary Education
(DESE)
Type of Finding:
Internal Control (Significant Deficiency) and
Noncompliance

The DESE's controls and procedures related to the preparation of the schedule
of expenditures of federal awards (SEFA) were not sufficient, and as a result,
expenditures reported on the DESE SEFA submitted to the Office of
Administration - Division of Accounting (DOA) for inclusion in the statewide
SEFA for the year ended June 30, 2021, were misstated. If the errors and
omissions had not been identified during the audit, expenditures would have
been understated by approximately $77.1 million in the statewide SEFA for
various DESE programs.

The following table summarizes the DESE SEFA errors identified:

Error Type
Overstated/(Understated)

Allocated and Indirect Cost omissions
$ (28,148,983)

GEER Fund omission
(23,643,000)

Food Donations omission
(25,941,494)

Data Entry errors
589,990

Total Errors
$ (77,143,487)


Allocated and indirect costs such as payroll benefits, building rent,
computer systems, and other adjustments recorded as Federal Aid Charge
(FX) documents in the statewide accounting (SAM II) system, totaling
$28,148,983, were not included for most programs.


GEER Fund drawdowns totaling $23,643,000 for reimbursement of
Department of Higher Education and Workforce Development
(DHEWD) expenditures were not included. These funds were direct
expenditures of the DESE and indirect expenditures of the DHEWD.


The value of food donations ($25,941,494) were not included in the
National School Lunch Program expenditures.

2021-018.
DESE SEFA

66
State of Missouri - Single Audit
Schedule of Findings and Questioned Costs
Year Ended June 30, 2021

Data entry errors for 2 programs resulted in a net overstatement of
$589,990.

The errors occurred without detection due to (1) staff turnover, (2) inadequate
documented procedures for preparing the SEFA, and (3) inadequate review
procedures. After we notified the DESE of these errors, the DESE submitted
a revised SEFA to the DOA, and the DOA included the revised amounts in
the statewide SEFA.

Rule 2 CFR Section 200.510(b) requires the recipient of federal awards to
prepare a SEFA including federal awards expended for each federal program.
Rule 2 CFR Section 200.303(a) requires the non-federal entity to "[e]stablish
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." Effective internal controls should include
procedures to ensure federal expenditures are accurately reported on the
SEFA.

The DESE implement controls and procedures to prepare and submit an
accurate SEFA to the DOA.

We agree with the auditor's finding. Our Corrective Action Plan includes our
planned actions to address the finding.

Federal Agency:
Department of Labor
Department of Homeland Security
Federal Program:
17.225
COVID-19 - Unemployment Insurance

 2020 - UI-34725-20-55-A-29 and

UI-34866-20-55-A-29

17.225
Unemployment Insurance

 2020 - UI-34068-20-55-A-29

 2021 - UI-35658-21-55-A-29

97.050
COVID-19 - Presidential Declared Disaster
Assistance to Individuals and Households -
Other Needs

 2020 - DHS-20-ONA-050-00-99
State Agency:
Department of Labor and Industrial Relations
(DOLIR)
Type of Finding:
Internal Control (Significant Deficiency) and
Noncompliance
Questioned Costs:
$86,500

The DOLIR needs to improve certain UInteract system controls. System
controls were not sufficient to prevent or detect improper payments
authorized by an employee totaling approximately $123,000 during fiscal
Recommendation
Auditee's Response
2021-019.
Department of Labor and
Industrial Relations
UInteract System Controls

67
State of Missouri - Single Audit
Schedule of Findings and Questioned Costs
Year Ended June 30, 2021
years 2020 and 2021. See Financial Statement Finding number FS2021-004
in the Annual Comprehensive Financial Report - Report on Internal Control,
Compliance, and Other Matters (Report No. 2022-02220), issued in March
2022.

We question the overpayments during the year ended June 30, 2021,
identified in the finding. The overpayment amounts by program and fiscal
year are detailed in the following table:

Program
Fiscal Year
2021
Fiscal Year
2020

Total
FPUC
$
49,165
27,600
76,765
PEUC
4,672
0
4,672
PUA
13,975
5,044
19,019
Regular UI
15,088
3,363
18,451
LWA
3,600
0
3,600
Total
$
86,500
36,007
122,507

Federal Agency:
Department of Homeland Security - Federal
Emergency Management Agency (FEMA)
Federal Program:
97.036 Disaster Grants - Public Assistance
(Presidentially Declared Disasters)

2013 - FEMA-4144-DR-MO
2015 - FEMA-4238-DR-MO
2016 - FEMA-4250-DR-MO
2017 - FEMA-4317-DR-MO
2019 - FEMA-4435-DR-MO and
FEMA-4451-DR-MO
2020 - FEMA-4490-DR-MO and
FEMA-4552-DR-MO
State Agency:
Department of Public Safety - State Emergency
Management Agency (SEMA)
Type of Finding:
Internal Control (Significant Deficiency) and
Noncompliance

During the year ended June 30, 2021, the SEMA did not have adequate
procedures to ensure the timely verification that subrecipients of the Disaster
Grants - Public Assistance (Presidentially Declared Disasters) (DGPA)
program were not suspended or debarred.

Through the DGPA program, the SEMA provides assistance to local
governments and certain private non-profit organizations to respond to

20See report at <https://auditor.mo.gov/AuditReport/ViewReport?report=2022022>
2021-020.
SEMA Suspension and
Debarment Procedures

68
State of Missouri - Single Audit
Schedule of Findings and Questioned Costs
Year Ended June 30, 2021
disasters. Applications for funding are reviewed and approved by SEMA and
FEMA personnel, and the SEMA makes payments to the subrecipients based
on approved funding amounts and actual costs. During the year ended
June 30, 2021, the SEMA disbursed approximately $69 million21 to
approximately 480 subrecipients of the DGPA program.

Rule 2 CFR Section 200.214 requires non-federal entities to comply with the
non-procurement debarment and suspension regulations in 2 CFR Part 180,
which restrict subawards with parties that are debarred, suspended, or
otherwise excluded from or ineligible for participation in federal assistance
programs. Rule 2 CFR Section 180.300 states, "[w]hen you enter into a
covered transaction with another person at the next lower tier, you must verify
that the person with whom you intend to do business is not excluded or
disqualified. You do this by: (a) Checking SAM Exclusions;[22] or (b)
Collecting a certification from that person; or (c) Adding a clause or condition
to the covered transaction with that person."

SEMA procedures in effect during the year ended June 30, 2021, required
SEMA personnel to verify each subrecipient was not suspended or debarred
at project completion rather than prior to approving funding as required.
When a project is ready to be closed, SEMA personnel complete an Applicant
Processing Checklist form documenting various verifications performed for
each subrecipient, including verification that the subrecipient was not
suspended or debarred. SEMA officials indicated if subrecipients are
identified as suspended or debarred, the SEMA would require reimbursement
of grant funds disbursed. Our review of checklist forms for 48 haphazardly
selected subrecipients that received DGPA program payments during the year
ended June 30, 2021, noted the suspension and debarment verification was
performed 2 months to 43 months after the funding approval date for 15
subrecipients, no verification date was recorded for 1 subrecipient, and
verifications had not been performed as of January 2022 for 32 subrecipients.
SEMA officials indicated they were not fully aware of the requirements until
they were brought to their attention during a FEMA financial monitoring
review in 2021. In response to the FEMA review, in 2022, the SEMA began
requiring applicants of the DGPA program to certify they are not suspended
or debarred during the application process.

Not verifying that subrecipients are not suspended or debarred prior to
approving funding increases the risk that the SEMA could contract with a
subrecipient that is suspended or debarred and be required to return the funds

21The Schedule of Expenditures of Federal Awards, Amount Provided to Subrecipients
column, includes approximately $52 million in expenditures by other state agencies that has
been excluded from this total.
22System for Award Management

69
State of Missouri - Single Audit
Schedule of Findings and Questioned Costs
Year Ended June 30, 2021
paid to the subrecipient to the federal awarding agency. To ensure compliance
with suspension and debarment requirements, the SEMA should continue to
strengthen and enforce internal controls to ensure verifications are performed
prior to approving funding. Rule 2 CFR Section 200.303(a) requires the non-
federal entity to "[e]stablish 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."

The SEMA should continue to strengthen and enforce internal controls over
suspension and debarment requirements to verify each subrecipient of the
DGPA program was not suspended or debarred prior to approving funding.

We agree with the auditor's finding. Our Corrective Action Plan includes our
planned actions to address the finding.

Federal Agency
Department of Homeland Security - Federal
Emergency Management Agency (FEMA)
Federal Program:
97.036 Disaster Grants - Public Assistance
(Presidentially Declared Disasters)
2020 - FEMA-4490-DR-MO and FEMA-
4552-DR-MO
State Agency:
Department of Public Safety - State Emergency
Management Agency (SEMA)
Type of Finding:
Internal Control (Significant Deficiency) and
Noncompliance

The SEMA needs to strengthen internal controls related to Federal Funding
Accountability and Transparency Act (FFATA) reporting for the Disaster
Grants - Public Assistance (Presidentially Declared Disasters) (DGPA)
program. During state fiscal year 2021, the SEMA did not comply with
FFATA reporting requirements for any of the subawards reviewed. During
state fiscal year 2021, the SEMA disbursed approximately $69.2 million in
first-tier subawards23 to 484 subrecipients of the DGPA program. First-tier
subaward payments accounted for approximately 61 percent of the program's
expenditures.

The FFATA requires comprehensive reporting for certain federal awards to
promote transparency and accountability over the use of the federal funds.
Rule 2 CFR Part 170, Appendix A, requires the SEMA to report first-tier
subawards of $30,000 or more to the FFATA Subaward Reporting System
(FSRS) no later than the end of the month following the month in which the

23First-tier subawards are federal awards made to non-federal entities by the prime award
recipient, in this case the SEMA, on behalf of the federal awarding agency, the FEMA.
Recommendation
Auditee's Response
2021-021.
SEMA FFATA Reporting

70
State of Missouri - Single Audit
Schedule of Findings and Questioned Costs
Year Ended June 30, 2021
subaward was made. Information entered into the FSRS is publicly available
at USASpending.gov.

On a monthly basis, SEMA procedures provide that SEMA personnel
download information pertaining to subrecipient awards from the FEMA data
warehouse and enter the information into an excel spreadsheet. SEMA
personnel filter the spreadsheet information to identify subawards that require
FFATA reporting, transfer the data to the federal FSRS template, and upload
the data to the FSRS. Various subaward data is uploaded, including the entity
name, award amount, and the date issued.

The SEMA's policies and procedures over the FFATA reporting process do
not include procedures for compiling subaward data or requiring a
documented supervisory review of the information uploaded to the FSRS.

Without sufficiently detailed policies and procedures or adequate supervisory
review over FFATA reporting, the SEMA has less assurance the information
included in the FFATA reporting for the DGPA program is complete and
accurate. Policies and procedures, at a minimum, should define the
responsibilities of various program personnel and include procedures for
ensuring the accuracy and completeness of all FFATA reporting elements.
Rule 2 CFR Section 200.303(a) requires the non-federal entity to "[e]stablish
and maintain effective internal control over the Federal award that provides
reasonable assurance that the non-Federal entity is managing the Federal
award in compliance with Federal statutes, regulations, and the terms and
conditions of the Federal award. These internal controls should be in
compliance with guidance in Standards for Internal Control in the Federal
Government, issued by the Comptroller General of the United States or the
Internal Control Integrated Framework, issued by the Committee of
Sponsoring Organizations of the Treadway Commission." The Standards for
Internal Control in the Federal Government, also known as the Green Book,
provides that management should document responsibilities through policies.
Paragraph 12.02 of the Green Book states, "management documents in
policies the internal control responsibilities of the organization." Paragraph
12.04 states policies may be further defined through day-to-day procedures
and "[m]anagement communicates the policies and procedures to personnel
so that personnel can implement the control activities for their assigned
responsibilities."

The SEMA did not comply with FFATA reporting requirements for the
DGPA program. To test compliance with FFATA reporting requirements, we
reviewed 28 DGPA program subawards, totaling approximately $2.7 million,
awarded in state fiscal year 2021. Instances of noncompliance identified are
shown in the following table.

Internal controls

FFATA reporting

71
State of Missouri - Single Audit
Schedule of Findings and Questioned Costs
Year Ended June 30, 2021

Transactions
Tested
Subaward not
reported (1)
Report not
timely (2)
Subaward
amount incorrect
Key subaward elements
missing and/or incorrect (3)
28
1
27
0
4
Dollar Amount
of Tested Transactions
Subaward not
reported
Report not
timely
Subaward
amount incorrect
Key subaward elements
missing and/or incorrect
$2,728,702
$428,036
$2,300,666
$0
$109,852
 (1) When SEMA officials investigated this error, they discovered an additional 6 subawards totaling $1,194,755 that had not been reported.
 (2) Reports were submitted 1 to 8 months after the last day of the month following the month in which the subawards were made.
 (3) For these 4 subawards, key data elements such as subawardee's name, address, and DUNS number were incorrect.

SEMA personnel indicated the FFATA reporting errors occurred because
other disaster-related duties took precedence over FFATA reporting. In
addition to noncompliance with federal requirements, not reporting
subawards to the FSRS accurately and timely increases the risk that those
using the reports could rely on inaccurate information.

The SEMA strengthen internal controls related to FFATA reporting to
include formal written policies and procedures for compiling subaward data
and documented supervisory reviews of the information reported to the FSRS
for the Disaster Grants - Public Assistance (Presidentially Declared
Disasters) program. In addition, the SEMA should complete FFATA
reporting in accordance with the applicable requirements.

We agree with the auditor's finding. Our Corrective Action Plan includes our
planned actions to address the finding.

Federal Agency:
Department of Transportation
Federal Program:
20.106 COVID-19 - Airport Improvement Program
and COVID-19 Airports Programs

20.106 Airport Improvement Program and COVID-
19 Airports Programs

2015 - 3-29-SBGP-64-2015
2017 - 3-29-SBGP-78-2017
2018 - 3-29-SBGP-91-2018
2019 - 3-29-SBGP-97-2019
2020 - 3-29-SBGP-106-2020,
3-29-SBGP-107-2020, 3-29-SBGP-108-2020,
3-29-SBGP-109-2020, 3-29-SBGP-111-2020,
3-29-SBGP-113-2020, 3-29-SBGP-115-2020,
3-29-SBGP-118-2020, 3-29-SBGP-119-2020
2021 - 3-29-SBGP-114-2021
State Agency:
Missouri Department of Transportation (MoDOT)
Type of Finding:
Internal Control (Significant Deficiency)
Recommendation
Auditee's Response
2021-022.
MoDOT FFATA Reporting

72
State of Missouri - Single Audit
Schedule of Findings and Questioned Costs
Year Ended June 30, 2021
The MoDOT needs to strengthen internal controls related to Federal Funding
Accountability and Transparency Act (FFATA) reporting for the Airport
Improvement Program (AIP). During state fiscal year 2021, the MoDOT
disbursed approximately $40.4 million in first-tier subawards24 to 98
subrecipients of the AIP. First-tier subaward payments accounted for 100
percent of the program's expenditures.

The FFATA requires comprehensive reporting for certain federal awards to
promote transparency and accountability over the use of the federal funds.
Rule 2 CFR Part 170, Appendix A, requires the MoDOT to report first-tier
subawards of $30,000 or more to the FFATA Subaward Reporting System
(FSRS) no later than the end of the month following the month in which the
subaward was made. Information entered into the FSRS is publicly available
at USASpending.gov.

On a monthly basis, MoDOT personnel filter grant tracking spreadsheet
information to identify subawards that require FFATA reporting and enter the
information into a FFATA excel spreadsheet. MoDOT procedures provide
for a documented supervisory review of the FFATA spreadsheet prior to
manual entry and upload of the information to the FSRS. Various subaward
data is uploaded, including the entity name, award amount, and the date
issued.

While some internal controls are in place, the MoDOT's formal written
policies and procedures over the FFATA reporting process do not include
procedures for compiling subaward data to be uploaded to the FSRS. In
addition, documented supervisory reviews of information uploaded to the
FSRS were not always performed. To test compliance with FFATA reporting
requirements, we reviewed 20 AIP subawards totaling $9,098,841. The
MoDOT did not perform a documented review of subaward information in
FFATA spreadsheets prior to FSRS submission for 15 of 20 subawards (75
percent) reviewed. MoDOT personnel indicated the review process was
interrupted due to staff turnover.

Without sufficiently detailed policies and procedures or adequate
documented supervisory review over FFATA reporting, the MoDOT has less
assurance the information included in the FFATA reporting for the AIP
program is complete and accurate. Policies and procedures, at a minimum,
should define the responsibilities of various program personnel and include
procedures for ensuring the accuracy and completeness of all FFATA
reporting elements. Rule 2 CFR Section 200.303(a) requires the non-federal
entity to "[e]stablish and maintain effective internal control over the Federal

24First-tier subawards are federal awards made to non-federal entities by the prime award
recipient, in this case the MoDOT, on behalf of the federal awarding agency, the Department
of Transportation.

73
State of Missouri - Single Audit
Schedule of Findings and Questioned Costs
Year Ended June 30, 2021
award that provides reasonable assurance that the non-Federal entity is
managing the Federal award in compliance with Federal statutes, regulations,
and the terms and conditions of the Federal award. These internal controls
should be in compliance with guidance in Standards for Internal Control in
the Federal Government, issued by the Comptroller General of the United
States or the Internal Control Integrated Framework, issued by the
Committee of Sponsoring Organizations of the Treadway Commission." The
Standards for Internal Control in the Federal Government, also known as the
Green Book, provides that management should document responsibilities
through policies. Paragraph 12.02 of the Green Book states, "management
documents in policies the internal control responsibilities of the
organization." Paragraph 12.04 states policies may be further defined through
day-to-day procedures and "[m]anagement communicates the policies and
procedures to personnel so that personnel can implement the control activities
for their assigned responsibilities."

The MoDOT strengthen internal controls related to FFATA reporting to
include formal written policies and procedures for compiling subaward data,
and perform documented supervisory reviews of the information reported to
the FSRS for the Airport Improvement Program.

We agree with the auditor's finding. Our Corrective Action Plan includes our
planned actions to address the finding.

The Missouri State Auditor's Office regularly issues audit reports on various
programs, agencies, and divisions of the state. Audit reports may include
issues related to the administration of federal programs. We reviewed the
reports issued from May 2021 to May 2022 and the following report relates
to a federal program.

Report Number Report Name
2021-049
 Missouri WIC Information Network System Data
Security

All reports are available on the Missouri State Auditor's Office website:
http://auditor.mo.gov.

Recommendation
Auditee's Response
Additional State Auditor's
Reports

74
State of Missouri - Single Audit
Summary Schedule of Prior Audit Findings
Year Ended June 30, 2021
The Uniform Guidance requires the auditee to prepare a Summary Schedule
of Prior Audit Findings to report the status of all audit findings included in
the prior audit's Schedule of Findings and Questioned Costs. The schedule is
also to report the status of findings included in the prior audit's Summary
Schedule of Prior Audit Findings, except those that were corrected, no longer
valid, or not warranting further action.

The Uniform Guidance requires the auditor to follow up on prior audit
findings; perform procedures to assess the reasonableness of the Summary
Schedule of Prior Audit Findings; and report, as a current year audit finding,
when the auditor concludes the schedule materially misrepresents the status
of any prior audit finding.

State of Missouri - Single Audit
Summary Schedule of Prior Audit Findings
Year Ended June 30, 2021

75
State of Missouri - Single Audit
Summary Schedule of Prior Audit Findings
Year Ended June 30, 2021

76
State of Missouri - Single Audit
Summary Schedule of Prior Audit Findings
Year Ended June 30, 2021

77
State of Missouri - Single Audit
Summary Schedule of Prior Audit Findings
Year Ended June 30, 2021

78
State of Missouri - Single Audit
Summary Schedule of Prior Audit Findings
Year Ended June 30, 2021

79
State of Missouri - Single Audit
Summary Schedule of Prior Audit Findings
Year Ended June 30, 2021

80
State of Missouri - Single Audit
Summary Schedule of Prior Audit Findings
Year Ended June 30, 2021

81
State of Missouri - Single Audit
Summary Schedule of Prior Audit Findings
Year Ended June 30, 2021

82
State of Missouri - Single Audit
Summary Schedule of Prior Audit Findings
Year Ended June 30, 2021

83
State of Missouri - Single Audit
Summary Schedule of Prior Audit Findings
Year Ended June 30, 2021

84
State of Missouri - Single Audit
Summary Schedule of Prior Audit Findings
Year Ended June 30, 2021

85
State of Missouri - Single Audit
Summary Schedule of Prior Audit Findings
Year Ended June 30, 2021

86
State of Missouri - Single Audit
Summary Schedule of Prior Audit Findings
Year Ended June 30, 2021

87
State of Missouri - Single Audit
Corrective Action Plans
Year Ended June 30, 2021
The Uniform Guidance requires the auditee to prepare a Corrective Action
Plan (CAP) for each finding reported in the Schedule of Findings and
Questioned Costs. The CAPs were prepared by the management of the
applicable state agencies.

State of Missouri - Single Audit
Corrective Action Plans
Year Ended June 30, 2021

88
State of Missouri - Single Audit
Corrective Action Plans
Year Ended June 30, 2021

89
State of Missouri - Single Audit
Corrective Action Plans
Year Ended June 30, 2021

90
State of Missouri - Single Audit
Corrective Action Plans
Year Ended June 30, 2021

91
State of Missouri - Single Audit
Corrective Action Plans
Year Ended June 30, 2021

92
State of Missouri - Single Audit
Corrective Action Plans
Year Ended June 30, 2021

93
State of Missouri - Single Audit
Corrective Action Plans
Year Ended June 30, 2021

94
State of Missouri - Single Audit
Corrective Action Plans
Year Ended June 30, 2021

95
State of Missouri - Single Audit
Corrective Action Plans
Year Ended June 30, 2021

96
State of Missouri - Single Audit
Corrective Action Plans
Year Ended June 30, 2021

97
State of Missouri - Single Audit
Corrective Action Plans
Year Ended June 30, 2021

98
State of Missouri - Single Audit
Corrective Action Plans
Year Ended June 30, 2021

99
State of Missouri - Single Audit
Corrective Action Plans
Year Ended June 30, 2021

100
State of Missouri - Single Audit
Corrective Action Plans
Year Ended June 30, 2021

101
State of Missouri - Single Audit
Corrective Action Plans
Year Ended June 30, 2021

102
State of Missouri - Single Audit
Corrective Action Plans
Year Ended June 30, 2021

103
State of Missouri - Single Audit
Corrective Action Plans
Year Ended June 30, 2021

104
State of Missouri - Single Audit
Corrective Action Plans
Year Ended June 30, 2021

105
State of Missouri - Single Audit
Corrective Action Plans
Year Ended June 30, 2021

106
State of Missouri - Single Audit
Corrective Action Plans
Year Ended June 30, 2021

107
State of Missouri - Single Audit
Corrective Action Plans
Year Ended June 30, 2021

108
State of Missouri - Single Audit
Corrective Action Plans
Year Ended June 30, 2021

109
State of Missouri - Single Audit
Corrective Action Plans
Year Ended June 30, 2021

110
State of Missouri - Single Audit
Corrective Action Plans
Year Ended June 30, 2021

111
State of Missouri - Single Audit
Corrective Action Plans
Year Ended June 30, 2021

112
State of Missouri - Single Audit
Corrective Action Plans
Year Ended June 30, 2021

113
State of Missouri - Single Audit
Corrective Action Plans
Year Ended June 30, 2021

114
State of Missouri - Single Audit
Corrective Action Plans
Year Ended June 30, 2021

115
State of Missouri - Single Audit
Corrective Action Plans
Year Ended June 30, 2021

116
State of Missouri - Single Audit
Corrective Action Plans
Year Ended June 30, 2021

File and source

File

REPORT_MO-State-Auditor_Statewide-Single-Audit-FY2021-UI-improper-payments_2022-07.pdf

Size

16,611,433 bytes

SHA-256

478252e1e19aa1b1c071f2aa7ca8f2ddc66b89c7599d8eab0937acc2477ac81c

Our copy

REPORT_MO-State-Auditor_Statewide-Single-Audit-FY2021-UI-improper-payments_2022-07.pdf

Original

auditor.mo.gov