FAC Explorer

Audit 24458

FY End
2022-12-31
Total Expended
$14.45M
Findings
2
Programs
18
Organization: Legal Aid Services of Oklahoma, Inc. (OK)
Year: 2022 Accepted: 2023-05-25
Auditor: Arledge & Associates

Organization Exclusion Status:

Findings

ID Ref Severity Repeat Requirement
34641 2022-002 Significant Deficiency - E
611083 2022-002 Significant Deficiency - E

Programs

ALN Program Spent Major Findings
09.737 Basic Field Grant $5.87M Yes 0
21.023 Emergency Rental Assistance Program $2.24M Yes 1
93.332 Cooperative Agreement to Support Navigators in Federally-Facilitated and State Partnership Marketplaces $2.20M - 0
16.575 Crime Victim Assistance $1.19M - 0
14.418 Private Enforcement Initiatives $484,166 - 0
93.044 Special Programs for the Aging_title Iii, Part B_grants for Supportive Services and Senior Centers $431,126 - 0
93.658 Foster Care_title IV-E $354,864 - 0
14.537 Eviction Protection Grant Program $309,505 - 0
09.737 Disaster Response Supplemental $282,577 Yes 0
09.737 Migrant Component $213,182 Yes 0
93.767 Children's Health Insurance Program $192,561 - 0
14.231 Emergency Solutions Grant Program $91,015 - 0
09.737 Midwest Disaster Coordination $78,105 Yes 0
21.008 Low Income Taxpayer Clinics $69,646 - 0
16.589 Rural Domestic Violence, Dating Violence, Sexual Assault, and Stalking Assistance Program $56,256 - 0
16.524 Legal Assistance for Victims $23,961 - 0
93.048 Special Programs for the Aging_title Iv_and Title Ii_discretionary Projects $11,083 - 0
64.033 Va Supportive Services for Veteran Families Program $5,618 - 0

Contacts

Name Title Type
W9MEDKURA7N8 Michael Figgins Auditee
4055570020 Ladonna Sinning Auditor
No contacts on file

Notes to SEFA

Title: 3. CONTINGENT LIABILITIES Accounting Policies: 1. BASIS OF PRESENTATION The accompanying schedule of expenditures of federal awards include the federal grant activity of LASO, under programs of the federal government for the year ended December 31, 2022. The information in the schedule of expenditures of federal awards is presented in accordance with the requirement of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Because the schedule presents only a selected portion of the operations of LASO, it is not intended to and does not present the financial position, changes in net assets or cash flows of LASO. 2. SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES Expenditures reported on the schedule are reported on the 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. LASO uses a provisional indirect cost rate method throughout the period pending the establishment of a final rate after actual indirect and direct costs are determined. LASO has elected not to use the 10% de minimis indirect cost rate allowed under the Uniform Guidance. The indirect cost rates charged to federal awards in 2022 range from 28.49% to 31.04% of direct costs. LASO has proposed to change the rate type from provisional to a predetermined rate, which is pending approval with the U.S. Department of Justice as of May 11, 2022. De Minimis Rate Used: N Rate Explanation: The auditee did not use the de minimis cost rate. LASO participated in a number of federal assisted programs. These programs are audited in accordance with Government Auditing Standards and the Uniform Guidance, if applicable, in accordance with the required levels of Federal Financial assistance. Audits of prior years have not resulted in any significant disallowed costs. Additionally, the grant programs are subject to audits by the granting authority, the purpose of which is to ensure compliance with conditions precedent to the granting of the funds. Management believes that any liability for reimbursement which may arise as the result of audits of grant funds would not be material.
Title: 4. RELATIONSHIP TO FEDERAL FINANCIAL REPORTS Accounting Policies: 1. BASIS OF PRESENTATION The accompanying schedule of expenditures of federal awards include the federal grant activity of LASO, under programs of the federal government for the year ended December 31, 2022. The information in the schedule of expenditures of federal awards is presented in accordance with the requirement of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Because the schedule presents only a selected portion of the operations of LASO, it is not intended to and does not present the financial position, changes in net assets or cash flows of LASO. 2. SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES Expenditures reported on the schedule are reported on the 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. LASO uses a provisional indirect cost rate method throughout the period pending the establishment of a final rate after actual indirect and direct costs are determined. LASO has elected not to use the 10% de minimis indirect cost rate allowed under the Uniform Guidance. The indirect cost rates charged to federal awards in 2022 range from 28.49% to 31.04% of direct costs. LASO has proposed to change the rate type from provisional to a predetermined rate, which is pending approval with the U.S. Department of Justice as of May 11, 2022. De Minimis Rate Used: N Rate Explanation: The auditee did not use the de minimis cost rate. Amounts reported in the accompanying schedule may not agree with the amounts reported in the related Federal financial reports filed with the grantor agencies because of accruals made in the schedule which will be included in future reports with agencies.
Title: 5. SUBSEQUENT EVENTS Accounting Policies: 1. BASIS OF PRESENTATION The accompanying schedule of expenditures of federal awards include the federal grant activity of LASO, under programs of the federal government for the year ended December 31, 2022. The information in the schedule of expenditures of federal awards is presented in accordance with the requirement of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Because the schedule presents only a selected portion of the operations of LASO, it is not intended to and does not present the financial position, changes in net assets or cash flows of LASO. 2. SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES Expenditures reported on the schedule are reported on the 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. LASO uses a provisional indirect cost rate method throughout the period pending the establishment of a final rate after actual indirect and direct costs are determined. LASO has elected not to use the 10% de minimis indirect cost rate allowed under the Uniform Guidance. The indirect cost rates charged to federal awards in 2022 range from 28.49% to 31.04% of direct costs. LASO has proposed to change the rate type from provisional to a predetermined rate, which is pending approval with the U.S. Department of Justice as of May 11, 2022. De Minimis Rate Used: N Rate Explanation: The auditee did not use the de minimis cost rate. LASO has evaluated the effects of all subsequent events from December 31, 2022, through Aril 28, 2022, the date the SEFA was available to be issued, for potential recognition or disclosure in this SEFA. LASO is not aware of any subsequent events which would require recognition or disclosure in the SEFA.

Finding Details

Finding 2022-002
Finding 2022-002 ? Eligibility and documentation of Emergency Rental Assistance Program (ERAP) Criteria: Per the Compliance Supplement ? CFR 2 Part 200, assistance listing 21.023, under ERAP 1, housing stability services should include cases related to the COVID-19 outbreak and are intended to help keep eligible households stably housed. Condition: Case files relating to housing stability service applicants under ERAP 1 lacked sufficient documentation or self-attestation in LASO?s case management system for providing evidence of how COVID-19 resulted in the applicant?s financial hardship. Additionally, case files which were noted by LASO as not COVID-19 related but still assigned to ERAP 1, and documented financial hardship linked to no illness, health, or related COVID-19 impacts resulting in ineligible cases for ERAP 1. Cause and Effect: During the intake process COVID-19 related inquiries were left unanswered and/or the case management system was marked as COVID-19 related without any further documentation as to how the applicant was affected. As a result, incorrectly identified cases were assigned to the ERAP 1 grant and insufficient documentation existed. Questioned Costs: Unknown Recommendation: We recommend management provides additional training to intake staff as well as attorneys working on ERAP 1 cases to ensure a COVID-19 related link exists for the applicant and the casefile appropriately documents how COVID-19 resulted in financial hardship of the eligible household. Management Response: LASO agrees with the finding. LASO ERAP 1 (Emergency Rental Assistance Program) grant eligibility relied on the existence of a hardship directly or indirectly related to Covid. By comparison, LASO ERAP 2 grant eligibility relies more on financial hardship. LASO ERAP 1 funds were primarily earned by LASO through efforts to prevent the eviction of clients during the peak of COVID by LASO attorney presence at every FED docket. Many of the LASO eviction defenses were facilitated by the COVID eviction moratorium and the availability of additional ERAP 1 funds thru CCP (Community Cares Partners) to pay for both past and future rent for tenants directly or indirectly impacted by COVID. LASO agrees with the auditor?s finding that a portion of the sampled LASO ERAP 1 cases did not have clear documentation of how the client was impacted by COVID-19, though all cases were of an eligible type of case. The ERAP 1 grant has ended. For the ERAP 2 grant LASO has two grant managers to oversee implementation of the grant and provide training to staff on the eligibility requirements and documentation of such.
Finding 2022-002
Finding 2022-002 ? Eligibility and documentation of Emergency Rental Assistance Program (ERAP) Criteria: Per the Compliance Supplement ? CFR 2 Part 200, assistance listing 21.023, under ERAP 1, housing stability services should include cases related to the COVID-19 outbreak and are intended to help keep eligible households stably housed. Condition: Case files relating to housing stability service applicants under ERAP 1 lacked sufficient documentation or self-attestation in LASO?s case management system for providing evidence of how COVID-19 resulted in the applicant?s financial hardship. Additionally, case files which were noted by LASO as not COVID-19 related but still assigned to ERAP 1, and documented financial hardship linked to no illness, health, or related COVID-19 impacts resulting in ineligible cases for ERAP 1. Cause and Effect: During the intake process COVID-19 related inquiries were left unanswered and/or the case management system was marked as COVID-19 related without any further documentation as to how the applicant was affected. As a result, incorrectly identified cases were assigned to the ERAP 1 grant and insufficient documentation existed. Questioned Costs: Unknown Recommendation: We recommend management provides additional training to intake staff as well as attorneys working on ERAP 1 cases to ensure a COVID-19 related link exists for the applicant and the casefile appropriately documents how COVID-19 resulted in financial hardship of the eligible household. Management Response: LASO agrees with the finding. LASO ERAP 1 (Emergency Rental Assistance Program) grant eligibility relied on the existence of a hardship directly or indirectly related to Covid. By comparison, LASO ERAP 2 grant eligibility relies more on financial hardship. LASO ERAP 1 funds were primarily earned by LASO through efforts to prevent the eviction of clients during the peak of COVID by LASO attorney presence at every FED docket. Many of the LASO eviction defenses were facilitated by the COVID eviction moratorium and the availability of additional ERAP 1 funds thru CCP (Community Cares Partners) to pay for both past and future rent for tenants directly or indirectly impacted by COVID. LASO agrees with the auditor?s finding that a portion of the sampled LASO ERAP 1 cases did not have clear documentation of how the client was impacted by COVID-19, though all cases were of an eligible type of case. The ERAP 1 grant has ended. For the ERAP 2 grant LASO has two grant managers to oversee implementation of the grant and provide training to staff on the eligibility requirements and documentation of such.