2022-002 – Allocation Percentage Charged – Significant Deficiency in Internal Controls over
Compliance
ALN: 84.126
Federal Award Title: Rehabilitation Services Vocational Rehabilitation Grants to States
Federal Agency: United States Department of Education
Pass-Through Entity: Texas Health and Human Services Commission
Award Number(s): HHS000186000005, HHS000202900008
Federal Award Year: 2022
Condition: The Entity charged the incorrect allocation % in 9 out of 20 nonpayroll expenses and 5
out of 25 payroll expenses.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, non-federal entities must
establish and maintain effective internal control over the Federal award that provides reasonable
assurance that the non-Federal entities is managing the Federal award in compliance with Federal
statutes, regulations, and the terms and conditions of the Federal award. These internal controls
should be in compliance with guidance in “Standards for Internal Control in the Federal
Government” issued by the Comptroller General of the United States or the “Internal Control
Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway
Commission (COSO).
According to 2 CFR 200.405(a)(2), costs allocated to a Federal award must be distributed in
proportions that may be approximated using reasonable methods.
Effect: The Entity may unintentionally under/over charge expenses to the grant which could lead
to questioned costs and repayment of funds to the Grantor agency.
Cause: The Entity does not have proper controls in place to verify the approved allocation % is
charged on expenses.
Questioned Costs:
Nonpayroll allocated costs – known questioned costs of $727 and likely questioned costs of
$14,513.
Payroll allocated costs – No questioned costs. Federal award was undercharged by $71 and, when
extrapolated, the undercharge was calculated at $7,132.
Combined questioned costs: known questioned costs of $655 and likely questioned costs of
$7,381
ALN: 84.126
Federal Award Title: Rehabilitation Services Vocational Rehabilitation Grants to States
Federal Agency: United States Department of Education
Pass-Through Entity: Texas Health and Human Services Commission
Award Number(s): HHS000186000005, HHS000202900008
Federal Award Year: 2022
Condition: During our review of payroll related transactions, 2 of the 25 payroll samples tested
did not have review and approval of the Supervisor on the timecard.
Criteria: 2 CFR section 200.303 – Internal Controls of the Uniform Guidance states that the nonfederal
entity must: (a) Establish and maintain effective internal controls over Federal award that
provides reasonable assurance that the non-Federal entity is managing the Federal award in
compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
These internal controls should be in compliance with guidance in “Standards for Internal Control
in the Federal Government” issued by the Comptroller General of the United States or the
“Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations
of the Treadway Commission (COSO). Per 2 CFR section 200.430 – Compensation – personal services, paragraph (i) Charges to Federal
awards for salaries and wages must be based on records that accurately reflect the work
performed.
Effect: The Entity may unintentionally under/over compensate what is applicable for the work
performed by that employee. This could lead to questioned costs and repayment of funds to the
Grantor agency.
Cause: The Entity does not have proper controls in place to verify that documentation was
maintained to indicate the employees’ time paid under the federal grant.
Questioned Costs: No questioned costs identified.
ALN: 84.126
Federal Award Title: Rehabilitation Services Vocational Rehabilitation Grants to States
Federal Agency: United States Department of Education
Pass-Through Entity: Texas Health and Human Services Commission
Award Number(s): HHS000186000005, HHS000202900008
Federal Award Year: 2022
Condition: LIFE was not verifying the classification of consumer goals agreed in the ILS system
and DRS system on 1 of 49 consumers tested. In addition, inaccurate listings of consumers were
initially provided to the auditors.
Criteria: 2 CFR 200.303 requires a non-Federal entity to Establish and maintain effective internal
control over the Federal award that provides reasonable assurance that the non-Federal entity is
managing the Federal award in compliance with Federal statutes, regulations, and the terms and
conditions of the Federal award. These internal controls should be in compliance with guidance
in ‘‘Standards for Internal Control in the Federal Government’’ issued by the Comptroller General
of the United States and the ‘‘Internal Control Integrated Framework’’, issued by the Committee
of Sponsoring Organizations of the Treadway Commission (COSO).
Per ILS Program Standards 5.6.3.5 Revision 19-1, all entries to the Independent Living Services
Data Reporting System made by the service provider will be considered a part of the consumer
case file. Each consumer case file must minimally meet the requirements of 34 CFR, Subtitle B,
Chapter III, Part 364, §364.53, and provide documentation concerning: the consumer’s goals for
independence and anticipated methods and services to achieve the goals.
Effect: The classification of consumer goals reported and tracked in the DRS system may have
been reported in the wrong category.
Cause: Lack of internal controls at LIFE to ensure that consumer goals are reported correctly in
both the ILS and DRS system and accurate reports are generated.
Questioned Costs: No questioned costs identified.
2022-002 – Allocation Percentage Charged – Significant Deficiency in Internal Controls over
Compliance
ALN: 84.126
Federal Award Title: Rehabilitation Services Vocational Rehabilitation Grants to States
Federal Agency: United States Department of Education
Pass-Through Entity: Texas Health and Human Services Commission
Award Number(s): HHS000186000005, HHS000202900008
Federal Award Year: 2022
Condition: The Entity charged the incorrect allocation % in 9 out of 20 nonpayroll expenses and 5
out of 25 payroll expenses.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, non-federal entities must
establish and maintain effective internal control over the Federal award that provides reasonable
assurance that the non-Federal entities is managing the Federal award in compliance with Federal
statutes, regulations, and the terms and conditions of the Federal award. These internal controls
should be in compliance with guidance in “Standards for Internal Control in the Federal
Government” issued by the Comptroller General of the United States or the “Internal Control
Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway
Commission (COSO).
According to 2 CFR 200.405(a)(2), costs allocated to a Federal award must be distributed in
proportions that may be approximated using reasonable methods.
Effect: The Entity may unintentionally under/over charge expenses to the grant which could lead
to questioned costs and repayment of funds to the Grantor agency.
Cause: The Entity does not have proper controls in place to verify the approved allocation % is
charged on expenses.
Questioned Costs:
Nonpayroll allocated costs – known questioned costs of $727 and likely questioned costs of
$14,513.
Payroll allocated costs – No questioned costs. Federal award was undercharged by $71 and, when
extrapolated, the undercharge was calculated at $7,132.
Combined questioned costs: known questioned costs of $655 and likely questioned costs of
$7,381
ALN: 84.126
Federal Award Title: Rehabilitation Services Vocational Rehabilitation Grants to States
Federal Agency: United States Department of Education
Pass-Through Entity: Texas Health and Human Services Commission
Award Number(s): HHS000186000005, HHS000202900008
Federal Award Year: 2022
Condition: During our review of payroll related transactions, 2 of the 25 payroll samples tested
did not have review and approval of the Supervisor on the timecard.
Criteria: 2 CFR section 200.303 – Internal Controls of the Uniform Guidance states that the nonfederal
entity must: (a) Establish and maintain effective internal controls over Federal award that
provides reasonable assurance that the non-Federal entity is managing the Federal award in
compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
These internal controls should be in compliance with guidance in “Standards for Internal Control
in the Federal Government” issued by the Comptroller General of the United States or the
“Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations
of the Treadway Commission (COSO). Per 2 CFR section 200.430 – Compensation – personal services, paragraph (i) Charges to Federal
awards for salaries and wages must be based on records that accurately reflect the work
performed.
Effect: The Entity may unintentionally under/over compensate what is applicable for the work
performed by that employee. This could lead to questioned costs and repayment of funds to the
Grantor agency.
Cause: The Entity does not have proper controls in place to verify that documentation was
maintained to indicate the employees’ time paid under the federal grant.
Questioned Costs: No questioned costs identified.
ALN: 84.126
Federal Award Title: Rehabilitation Services Vocational Rehabilitation Grants to States
Federal Agency: United States Department of Education
Pass-Through Entity: Texas Health and Human Services Commission
Award Number(s): HHS000186000005, HHS000202900008
Federal Award Year: 2022
Condition: LIFE was not verifying the classification of consumer goals agreed in the ILS system
and DRS system on 1 of 49 consumers tested. In addition, inaccurate listings of consumers were
initially provided to the auditors.
Criteria: 2 CFR 200.303 requires a non-Federal entity to Establish and maintain effective internal
control over the Federal award that provides reasonable assurance that the non-Federal entity is
managing the Federal award in compliance with Federal statutes, regulations, and the terms and
conditions of the Federal award. These internal controls should be in compliance with guidance
in ‘‘Standards for Internal Control in the Federal Government’’ issued by the Comptroller General
of the United States and the ‘‘Internal Control Integrated Framework’’, issued by the Committee
of Sponsoring Organizations of the Treadway Commission (COSO).
Per ILS Program Standards 5.6.3.5 Revision 19-1, all entries to the Independent Living Services
Data Reporting System made by the service provider will be considered a part of the consumer
case file. Each consumer case file must minimally meet the requirements of 34 CFR, Subtitle B,
Chapter III, Part 364, §364.53, and provide documentation concerning: the consumer’s goals for
independence and anticipated methods and services to achieve the goals.
Effect: The classification of consumer goals reported and tracked in the DRS system may have
been reported in the wrong category.
Cause: Lack of internal controls at LIFE to ensure that consumer goals are reported correctly in
both the ILS and DRS system and accurate reports are generated.
Questioned Costs: No questioned costs identified.
2022-002 – Allocation Percentage Charged – Significant Deficiency in Internal Controls over
Compliance
ALN: 84.126
Federal Award Title: Rehabilitation Services Vocational Rehabilitation Grants to States
Federal Agency: United States Department of Education
Pass-Through Entity: Texas Health and Human Services Commission
Award Number(s): HHS000186000005, HHS000202900008
Federal Award Year: 2022
Condition: The Entity charged the incorrect allocation % in 9 out of 20 nonpayroll expenses and 5
out of 25 payroll expenses.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, non-federal entities must
establish and maintain effective internal control over the Federal award that provides reasonable
assurance that the non-Federal entities is managing the Federal award in compliance with Federal
statutes, regulations, and the terms and conditions of the Federal award. These internal controls
should be in compliance with guidance in “Standards for Internal Control in the Federal
Government” issued by the Comptroller General of the United States or the “Internal Control
Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway
Commission (COSO).
According to 2 CFR 200.405(a)(2), costs allocated to a Federal award must be distributed in
proportions that may be approximated using reasonable methods.
Effect: The Entity may unintentionally under/over charge expenses to the grant which could lead
to questioned costs and repayment of funds to the Grantor agency.
Cause: The Entity does not have proper controls in place to verify the approved allocation % is
charged on expenses.
Questioned Costs:
Nonpayroll allocated costs – known questioned costs of $727 and likely questioned costs of
$14,513.
Payroll allocated costs – No questioned costs. Federal award was undercharged by $71 and, when
extrapolated, the undercharge was calculated at $7,132.
Combined questioned costs: known questioned costs of $655 and likely questioned costs of
$7,381
ALN: 84.126
Federal Award Title: Rehabilitation Services Vocational Rehabilitation Grants to States
Federal Agency: United States Department of Education
Pass-Through Entity: Texas Health and Human Services Commission
Award Number(s): HHS000186000005, HHS000202900008
Federal Award Year: 2022
Condition: During our review of payroll related transactions, 2 of the 25 payroll samples tested
did not have review and approval of the Supervisor on the timecard.
Criteria: 2 CFR section 200.303 – Internal Controls of the Uniform Guidance states that the nonfederal
entity must: (a) Establish and maintain effective internal controls over Federal award that
provides reasonable assurance that the non-Federal entity is managing the Federal award in
compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
These internal controls should be in compliance with guidance in “Standards for Internal Control
in the Federal Government” issued by the Comptroller General of the United States or the
“Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations
of the Treadway Commission (COSO). Per 2 CFR section 200.430 – Compensation – personal services, paragraph (i) Charges to Federal
awards for salaries and wages must be based on records that accurately reflect the work
performed.
Effect: The Entity may unintentionally under/over compensate what is applicable for the work
performed by that employee. This could lead to questioned costs and repayment of funds to the
Grantor agency.
Cause: The Entity does not have proper controls in place to verify that documentation was
maintained to indicate the employees’ time paid under the federal grant.
Questioned Costs: No questioned costs identified.
ALN: 84.126
Federal Award Title: Rehabilitation Services Vocational Rehabilitation Grants to States
Federal Agency: United States Department of Education
Pass-Through Entity: Texas Health and Human Services Commission
Award Number(s): HHS000186000005, HHS000202900008
Federal Award Year: 2022
Condition: LIFE was not verifying the classification of consumer goals agreed in the ILS system
and DRS system on 1 of 49 consumers tested. In addition, inaccurate listings of consumers were
initially provided to the auditors.
Criteria: 2 CFR 200.303 requires a non-Federal entity to Establish and maintain effective internal
control over the Federal award that provides reasonable assurance that the non-Federal entity is
managing the Federal award in compliance with Federal statutes, regulations, and the terms and
conditions of the Federal award. These internal controls should be in compliance with guidance
in ‘‘Standards for Internal Control in the Federal Government’’ issued by the Comptroller General
of the United States and the ‘‘Internal Control Integrated Framework’’, issued by the Committee
of Sponsoring Organizations of the Treadway Commission (COSO).
Per ILS Program Standards 5.6.3.5 Revision 19-1, all entries to the Independent Living Services
Data Reporting System made by the service provider will be considered a part of the consumer
case file. Each consumer case file must minimally meet the requirements of 34 CFR, Subtitle B,
Chapter III, Part 364, §364.53, and provide documentation concerning: the consumer’s goals for
independence and anticipated methods and services to achieve the goals.
Effect: The classification of consumer goals reported and tracked in the DRS system may have
been reported in the wrong category.
Cause: Lack of internal controls at LIFE to ensure that consumer goals are reported correctly in
both the ILS and DRS system and accurate reports are generated.
Questioned Costs: No questioned costs identified.
2022-002 – Allocation Percentage Charged – Significant Deficiency in Internal Controls over
Compliance
ALN: 84.126
Federal Award Title: Rehabilitation Services Vocational Rehabilitation Grants to States
Federal Agency: United States Department of Education
Pass-Through Entity: Texas Health and Human Services Commission
Award Number(s): HHS000186000005, HHS000202900008
Federal Award Year: 2022
Condition: The Entity charged the incorrect allocation % in 9 out of 20 nonpayroll expenses and 5
out of 25 payroll expenses.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, non-federal entities must
establish and maintain effective internal control over the Federal award that provides reasonable
assurance that the non-Federal entities is managing the Federal award in compliance with Federal
statutes, regulations, and the terms and conditions of the Federal award. These internal controls
should be in compliance with guidance in “Standards for Internal Control in the Federal
Government” issued by the Comptroller General of the United States or the “Internal Control
Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway
Commission (COSO).
According to 2 CFR 200.405(a)(2), costs allocated to a Federal award must be distributed in
proportions that may be approximated using reasonable methods.
Effect: The Entity may unintentionally under/over charge expenses to the grant which could lead
to questioned costs and repayment of funds to the Grantor agency.
Cause: The Entity does not have proper controls in place to verify the approved allocation % is
charged on expenses.
Questioned Costs:
Nonpayroll allocated costs – known questioned costs of $727 and likely questioned costs of
$14,513.
Payroll allocated costs – No questioned costs. Federal award was undercharged by $71 and, when
extrapolated, the undercharge was calculated at $7,132.
Combined questioned costs: known questioned costs of $655 and likely questioned costs of
$7,381
ALN: 84.126
Federal Award Title: Rehabilitation Services Vocational Rehabilitation Grants to States
Federal Agency: United States Department of Education
Pass-Through Entity: Texas Health and Human Services Commission
Award Number(s): HHS000186000005, HHS000202900008
Federal Award Year: 2022
Condition: During our review of payroll related transactions, 2 of the 25 payroll samples tested
did not have review and approval of the Supervisor on the timecard.
Criteria: 2 CFR section 200.303 – Internal Controls of the Uniform Guidance states that the nonfederal
entity must: (a) Establish and maintain effective internal controls over Federal award that
provides reasonable assurance that the non-Federal entity is managing the Federal award in
compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
These internal controls should be in compliance with guidance in “Standards for Internal Control
in the Federal Government” issued by the Comptroller General of the United States or the
“Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations
of the Treadway Commission (COSO). Per 2 CFR section 200.430 – Compensation – personal services, paragraph (i) Charges to Federal
awards for salaries and wages must be based on records that accurately reflect the work
performed.
Effect: The Entity may unintentionally under/over compensate what is applicable for the work
performed by that employee. This could lead to questioned costs and repayment of funds to the
Grantor agency.
Cause: The Entity does not have proper controls in place to verify that documentation was
maintained to indicate the employees’ time paid under the federal grant.
Questioned Costs: No questioned costs identified.
ALN: 84.126
Federal Award Title: Rehabilitation Services Vocational Rehabilitation Grants to States
Federal Agency: United States Department of Education
Pass-Through Entity: Texas Health and Human Services Commission
Award Number(s): HHS000186000005, HHS000202900008
Federal Award Year: 2022
Condition: LIFE was not verifying the classification of consumer goals agreed in the ILS system
and DRS system on 1 of 49 consumers tested. In addition, inaccurate listings of consumers were
initially provided to the auditors.
Criteria: 2 CFR 200.303 requires a non-Federal entity to Establish and maintain effective internal
control over the Federal award that provides reasonable assurance that the non-Federal entity is
managing the Federal award in compliance with Federal statutes, regulations, and the terms and
conditions of the Federal award. These internal controls should be in compliance with guidance
in ‘‘Standards for Internal Control in the Federal Government’’ issued by the Comptroller General
of the United States and the ‘‘Internal Control Integrated Framework’’, issued by the Committee
of Sponsoring Organizations of the Treadway Commission (COSO).
Per ILS Program Standards 5.6.3.5 Revision 19-1, all entries to the Independent Living Services
Data Reporting System made by the service provider will be considered a part of the consumer
case file. Each consumer case file must minimally meet the requirements of 34 CFR, Subtitle B,
Chapter III, Part 364, §364.53, and provide documentation concerning: the consumer’s goals for
independence and anticipated methods and services to achieve the goals.
Effect: The classification of consumer goals reported and tracked in the DRS system may have
been reported in the wrong category.
Cause: Lack of internal controls at LIFE to ensure that consumer goals are reported correctly in
both the ILS and DRS system and accurate reports are generated.
Questioned Costs: No questioned costs identified.