Material Weakness in Internal Control over Financial Reporting and Noncompliance – Allowable Costs/Cost Principles. IDENTIFICATION OF FEDERAL PROGRAM: 64.033 VA Support Services for Veteran Families Program
Award 20-AK-152 Department of Veterans Affairs. CRITERIA: Title 2 U.S. Code Part 200.403(g) requires that for costs charged to a federal program to be allowable, they must be adequately documented. CONDITION: Payroll and non-payroll related costs charged to the federal major program were not documented in accordance with the Mission’s financial policies and procedures. This indicates pervasiveness across the entity. CAUSE: The Mission does not have a procedure in place to monitor all supporting documents are properly secured and documented. EFFECT OR POTENTIAL EFFECT: Not following established financial policies and procedures increases the risk that internal control failures, questioned costs and noncompliance could arise in the future over federal programs. RECOMMENDATION: We recommend the Mission reviews its financial policies and procedures and implement and/or revise accordingly to ensure they conform to both Uniform Guidance and internal policies and procedures to satisfy adequate internal control design to account for proper segregation of duties, records retention, and audit trail. VIEWS OF RESPONSIBLE OFFICIALS: See Corrective Action Plan
Material Weakness in Internal Control over Compliance and Noncompliance – Cash Management. IDENTIFICATION OF FEDERAL PROGRAM: 64.033 VA Support Services for Veteran Families Program Award 20-AK-152 Department of Veterans Affairs. CRITERIA: Per the grant award - Recipients must have procedures for minimizing the time elapsing between the transfer of any advance payments of funds under the award and disbursement of the funds for direct program costs and the proportionate share of any allowable indirect or facilities and administrative costs. Recipients must ensure that the timing and amount of any payments to sub-recipients under the award conform to this standard. Per the SSVF Program Guide Section VII – Fiscal Administration Cash Dra Down Process – 1. Overview of Disbursement Grantees may draw down supportive services grant funds prospectively via the internet-based PMS in accordance with the restrictions laid out in the NOFA. Draw down requests are submitted and processed online via the request functions of the PMS platform. Once a draw down request is submitted, disbursement is completed by electronic funds transfer to the grantee's bank account the following business day. Grantees have three days to expend the funds that are drawn down from the HHS system. If funds are not expended within three days, a grantee must contact the VA to plan for paying interest on those funds.CONDITION: It was noted during the audit of fiscal year 2021 that the Mission did not still have records maintained from all the drawdown requests that occurred during the fiscal year 2021. CAUSE: There was turnover at the Mission and prior management did not have an adequate administrative filing system and are not available to track down documents related to the fiscal year 2021. EFFECT OR POTENTIAL EFFECT: The Mission could have been out of compliance with Uniform Guidance cash management standards. QUESTIONED COSTS: None. CONTEXT: For this program, there were 45 cash drawdowns that occurred during fiscal year 2021, a random sample of five were requested to test against the grant awards cash draw down requirements, of those five, current management was unable to locate the support showing that the Mission followed the cash draw down process for those three cash draw downs. IDENTIFICATION OF REPEAT FINDING: Not Applicable. RECOMMENDATIONS: We recommend that as a part of the Mission’s internal control structure over compliance with cash management requirements to establish monitoring procedures to ensure records documenting the Mission’s cash management procedures are maintained. VIEWS OF RESPONSIBLE OFFICIALS: See Corrective Action Plan
Material Weakness in Internal Control over Compliance and Noncompliance - Eligibility Requirement IDENTIFICATION OF FEDERAL PROGRAM: 64.033 VA Support Services for Veteran Families Program Award 20-AK-152 Department of Veterans Affairs. CRITERIA: Per the SSVF Program Guide, each participant household's file must include documentation verifying that the participant meets SSVF program eligibility requirements and specifying the participant's category of “occupying permanent housing.” Grantees with insufficient case file documentation may be found out of compliance with SSVF Program regulations during a VA monitoring visit. Grantees
must develop policies and procedures that ensure appropriate documentation is obtained and included in participants’ files. To become a participant household under the SSVF Program, the following conditions must be met:
1. A member of a "Veteran family": Either (a) a Veteran; or (b) a member of a family in which the
head of household, or the spouse of the head of household, is a Veteran.
2. "Very low-income": Household income does not exceed 50 percent of area median income. Unless VA
announces otherwise in the NOFA, the median income for an area or community will be determined
using the income limits most recently published by the Department of Housing and Urban Development
for programs under section 8 of the United States Housing Act of 1937 (42 U.S.C. 1437f), which can
be found at: http://www.huduser.org/portal/datasets/il.html
3. "Occupying Permanent Housing": A very low-income Veteran family is considered to be “occupying permanent housing” if they fall into one of three categories:
(Category 1) Is residing in permanent housing and at risk of becoming literally homeless but for grantee’s assistance; (Category 2) Is literally homeless, and at risk to remain in this situation but for grantee’s assistance, and scheduled to become a resident of permanent housing within 90 days pending the location or development of housing suitable for permanent housing; or (Category 3) Is literally homeless after exiting permanent housing to seek other housing that is responsive to the very low-income Veteran family’s needs and preferences. CONDITION: The Mission was unable to provide complete records documenting that participants met all of the eligibility requirements. EFFECT OR POTENTIAL EFFECT: The Mission’s current management was unable to provide records showing that participant files were complete. QUESTIONED COSTS: None. CONTEXT: For this funding, there were 156 participants who received benefits through the SSVF program during the fiscal year under audit. During the single audit testwork the auditors selected a random sample of 16 participant files to test against eligibility requirements. Of those 16 participants, 8 of them did not have complete documentation supporting that the participants met all of the eligibility requirements. IDENTIFICATION OF REPEAT FINDING: Not Applicable. RECOMMENDATION: We recommend that as a part of the Mission’s internal control structure over compliance with eligibility requirements to establish monitoring procedures to ensure federal reporting deadlines are met and proof of submission and reports submitted are maintained. VIEWS OF RESPONSBLE OFFICIALS: See Corrective Action Plan.
Material Weakness in Internal Control over Compliance and Noncompliance - Reporting Requirements IDENTIFICATION OF FEDERAL PROGRAM: 64.033 VA Support Services for Veteran Families Program Award 20-AK-152 Department of Veterans Affairs. CRITERIA: Per the award agreement the Mission is required to submit quarterly progress reports. Progress reports shall be submitted within 30 days after the end of the reporting periods, which are December 31st, March 31st, June 30th and September 30th. This report will include detailed information about the project(s) funded, including, but not limited to, the number of disabled Veterans who benefited, administrative expenses, information about how the funds were actually used, data to support statements of progress, and data concerning individual results and outcomes of funded projects reflecting project success and impacts. CONDITION: The Mission was unable to provide records of the quarterly reports being
submitted during the fiscal year ended March 31, 2021. CAUSE: The Mission has had turnover in all management positions since the fiscal year ended March 31, 2021. Prior management did not maintain complete or accurate files. EFFECT OR POTENTIAL EFFECT: The Mission’s current management was unable to provide records showing that the reporting compliance requirements were met. QUESTIONED COSTS: None. CONTEXT: For this funding, four quarterly progress reports were due during the fiscal year under audit. During the single audit testwork the auditors requested to test two reports and neither were available for inspection. IDENTIFICATION OF REPEAT FINDING: Not Applicable. RECOMMENDATION: We recommend that as a part of the Mission’s internal control structure over compliance with reporting requirements to establish monitoring procedures to ensure federal reporting deadlines are met and proof of submission and reports submitted are maintained. VIEWS OF RESPONSIBLE OFFICIALS: See Corrective Action Plan
Material Weakness in Internal Control over Compliance and Noncompliance – Subrecipient Monitoring IDENTIFICATION OF FEDERAL PROGRAM: 64.033 VA Support Services for Veteran Families Program Award 20-AK-152 Department of Veterans Affairs. CRITERIA: Per Part 3 of the Uniform Guidance Compliance Supplement, A pass-through entity (PTE) must: - Identify the Award and Applicable Requirements- clearly identify to the subrecipient: (1) the award as a subaward at the time of subaward (2) all requirements imposed by the PTE on the subrecipient so that the federal award is used in accordance with federal statutes, regulations, and the terms and conditions of the award. - Evaluate Risk - evaluate each subrecipient's risk of noncompliance for the purpose of determining the appropriate subrecipient monitoring related to the subaward. - Monitor - monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies terms and conditions of the subaward, and achieves performance goals. CONDITION: The Mission was unable to provide documentation that the evaluation of risk and monitoring of the activities of the subrecipient was performed. CAUSE: The Mission has had turnover in all management positions since the fiscal year ended March 31, 2021. Prior management did not maintain complete or accurate files. EFFECT OR POTENTIAL EFFECT: The Mission’s current management was unable to provide records showing that the evaluation and monitoring of subrecipients was performed. QUESTIONED COSTS: None. CONTEXT: The Mission entered into 3 subawards during the period under audit. The sub awardees were approved in the SSVF program budget by the federal agency. There were 116 disbursements made to the 3 subrecipients. The auditor selected a random sample of 12 disbursements to test against supporting documentation showing that the Mission monitored the sub awardees, none of that documentation was available for inspection. IDENTIFCATION OF REPEAT FINDING: Not Applicable. RECOMMENDATION: We recommend that as a part of the Mission’s internal control structure over compliance with subrecipient monitoring requirements to establish monitoring procedures to ensure federal subrecipient requirements are
met and proof of evaluation and monitoring is maintained. VIEWS OF RESPONSIBLE OFFICIALS: See Corrective Action Plan
Material Weakness in Internal Control over Financial Reporting and Noncompliance – Allowable Costs/Cost Principles. IDENTIFICATION OF FEDERAL PROGRAM: 64.033 VA Support Services for Veteran Families Program
Award 20-AK-152 Department of Veterans Affairs. CRITERIA: Title 2 U.S. Code Part 200.403(g) requires that for costs charged to a federal program to be allowable, they must be adequately documented. CONDITION: Payroll and non-payroll related costs charged to the federal major program were not documented in accordance with the Mission’s financial policies and procedures. This indicates pervasiveness across the entity. CAUSE: The Mission does not have a procedure in place to monitor all supporting documents are properly secured and documented. EFFECT OR POTENTIAL EFFECT: Not following established financial policies and procedures increases the risk that internal control failures, questioned costs and noncompliance could arise in the future over federal programs. RECOMMENDATION: We recommend the Mission reviews its financial policies and procedures and implement and/or revise accordingly to ensure they conform to both Uniform Guidance and internal policies and procedures to satisfy adequate internal control design to account for proper segregation of duties, records retention, and audit trail. VIEWS OF RESPONSIBLE OFFICIALS: See Corrective Action Plan
Material Weakness in Internal Control over Compliance and Noncompliance – Cash Management. IDENTIFICATION OF FEDERAL PROGRAM: 64.033 VA Support Services for Veteran Families Program Award 20-AK-152 Department of Veterans Affairs. CRITERIA: Per the grant award - Recipients must have procedures for minimizing the time elapsing between the transfer of any advance payments of funds under the award and disbursement of the funds for direct program costs and the proportionate share of any allowable indirect or facilities and administrative costs. Recipients must ensure that the timing and amount of any payments to sub-recipients under the award conform to this standard. Per the SSVF Program Guide Section VII – Fiscal Administration Cash Dra Down Process – 1. Overview of Disbursement Grantees may draw down supportive services grant funds prospectively via the internet-based PMS in accordance with the restrictions laid out in the NOFA. Draw down requests are submitted and processed online via the request functions of the PMS platform. Once a draw down request is submitted, disbursement is completed by electronic funds transfer to the grantee's bank account the following business day. Grantees have three days to expend the funds that are drawn down from the HHS system. If funds are not expended within three days, a grantee must contact the VA to plan for paying interest on those funds.CONDITION: It was noted during the audit of fiscal year 2021 that the Mission did not still have records maintained from all the drawdown requests that occurred during the fiscal year 2021. CAUSE: There was turnover at the Mission and prior management did not have an adequate administrative filing system and are not available to track down documents related to the fiscal year 2021. EFFECT OR POTENTIAL EFFECT: The Mission could have been out of compliance with Uniform Guidance cash management standards. QUESTIONED COSTS: None. CONTEXT: For this program, there were 45 cash drawdowns that occurred during fiscal year 2021, a random sample of five were requested to test against the grant awards cash draw down requirements, of those five, current management was unable to locate the support showing that the Mission followed the cash draw down process for those three cash draw downs. IDENTIFICATION OF REPEAT FINDING: Not Applicable. RECOMMENDATIONS: We recommend that as a part of the Mission’s internal control structure over compliance with cash management requirements to establish monitoring procedures to ensure records documenting the Mission’s cash management procedures are maintained. VIEWS OF RESPONSIBLE OFFICIALS: See Corrective Action Plan
Material Weakness in Internal Control over Compliance and Noncompliance - Eligibility Requirement IDENTIFICATION OF FEDERAL PROGRAM: 64.033 VA Support Services for Veteran Families Program Award 20-AK-152 Department of Veterans Affairs. CRITERIA: Per the SSVF Program Guide, each participant household's file must include documentation verifying that the participant meets SSVF program eligibility requirements and specifying the participant's category of “occupying permanent housing.” Grantees with insufficient case file documentation may be found out of compliance with SSVF Program regulations during a VA monitoring visit. Grantees
must develop policies and procedures that ensure appropriate documentation is obtained and included in participants’ files. To become a participant household under the SSVF Program, the following conditions must be met:
1. A member of a "Veteran family": Either (a) a Veteran; or (b) a member of a family in which the
head of household, or the spouse of the head of household, is a Veteran.
2. "Very low-income": Household income does not exceed 50 percent of area median income. Unless VA
announces otherwise in the NOFA, the median income for an area or community will be determined
using the income limits most recently published by the Department of Housing and Urban Development
for programs under section 8 of the United States Housing Act of 1937 (42 U.S.C. 1437f), which can
be found at: http://www.huduser.org/portal/datasets/il.html
3. "Occupying Permanent Housing": A very low-income Veteran family is considered to be “occupying permanent housing” if they fall into one of three categories:
(Category 1) Is residing in permanent housing and at risk of becoming literally homeless but for grantee’s assistance; (Category 2) Is literally homeless, and at risk to remain in this situation but for grantee’s assistance, and scheduled to become a resident of permanent housing within 90 days pending the location or development of housing suitable for permanent housing; or (Category 3) Is literally homeless after exiting permanent housing to seek other housing that is responsive to the very low-income Veteran family’s needs and preferences. CONDITION: The Mission was unable to provide complete records documenting that participants met all of the eligibility requirements. EFFECT OR POTENTIAL EFFECT: The Mission’s current management was unable to provide records showing that participant files were complete. QUESTIONED COSTS: None. CONTEXT: For this funding, there were 156 participants who received benefits through the SSVF program during the fiscal year under audit. During the single audit testwork the auditors selected a random sample of 16 participant files to test against eligibility requirements. Of those 16 participants, 8 of them did not have complete documentation supporting that the participants met all of the eligibility requirements. IDENTIFICATION OF REPEAT FINDING: Not Applicable. RECOMMENDATION: We recommend that as a part of the Mission’s internal control structure over compliance with eligibility requirements to establish monitoring procedures to ensure federal reporting deadlines are met and proof of submission and reports submitted are maintained. VIEWS OF RESPONSBLE OFFICIALS: See Corrective Action Plan.
Material Weakness in Internal Control over Compliance and Noncompliance - Reporting Requirements IDENTIFICATION OF FEDERAL PROGRAM: 64.033 VA Support Services for Veteran Families Program Award 20-AK-152 Department of Veterans Affairs. CRITERIA: Per the award agreement the Mission is required to submit quarterly progress reports. Progress reports shall be submitted within 30 days after the end of the reporting periods, which are December 31st, March 31st, June 30th and September 30th. This report will include detailed information about the project(s) funded, including, but not limited to, the number of disabled Veterans who benefited, administrative expenses, information about how the funds were actually used, data to support statements of progress, and data concerning individual results and outcomes of funded projects reflecting project success and impacts. CONDITION: The Mission was unable to provide records of the quarterly reports being
submitted during the fiscal year ended March 31, 2021. CAUSE: The Mission has had turnover in all management positions since the fiscal year ended March 31, 2021. Prior management did not maintain complete or accurate files. EFFECT OR POTENTIAL EFFECT: The Mission’s current management was unable to provide records showing that the reporting compliance requirements were met. QUESTIONED COSTS: None. CONTEXT: For this funding, four quarterly progress reports were due during the fiscal year under audit. During the single audit testwork the auditors requested to test two reports and neither were available for inspection. IDENTIFICATION OF REPEAT FINDING: Not Applicable. RECOMMENDATION: We recommend that as a part of the Mission’s internal control structure over compliance with reporting requirements to establish monitoring procedures to ensure federal reporting deadlines are met and proof of submission and reports submitted are maintained. VIEWS OF RESPONSIBLE OFFICIALS: See Corrective Action Plan
Material Weakness in Internal Control over Compliance and Noncompliance – Subrecipient Monitoring IDENTIFICATION OF FEDERAL PROGRAM: 64.033 VA Support Services for Veteran Families Program Award 20-AK-152 Department of Veterans Affairs. CRITERIA: Per Part 3 of the Uniform Guidance Compliance Supplement, A pass-through entity (PTE) must: - Identify the Award and Applicable Requirements- clearly identify to the subrecipient: (1) the award as a subaward at the time of subaward (2) all requirements imposed by the PTE on the subrecipient so that the federal award is used in accordance with federal statutes, regulations, and the terms and conditions of the award. - Evaluate Risk - evaluate each subrecipient's risk of noncompliance for the purpose of determining the appropriate subrecipient monitoring related to the subaward. - Monitor - monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies terms and conditions of the subaward, and achieves performance goals. CONDITION: The Mission was unable to provide documentation that the evaluation of risk and monitoring of the activities of the subrecipient was performed. CAUSE: The Mission has had turnover in all management positions since the fiscal year ended March 31, 2021. Prior management did not maintain complete or accurate files. EFFECT OR POTENTIAL EFFECT: The Mission’s current management was unable to provide records showing that the evaluation and monitoring of subrecipients was performed. QUESTIONED COSTS: None. CONTEXT: The Mission entered into 3 subawards during the period under audit. The sub awardees were approved in the SSVF program budget by the federal agency. There were 116 disbursements made to the 3 subrecipients. The auditor selected a random sample of 12 disbursements to test against supporting documentation showing that the Mission monitored the sub awardees, none of that documentation was available for inspection. IDENTIFCATION OF REPEAT FINDING: Not Applicable. RECOMMENDATION: We recommend that as a part of the Mission’s internal control structure over compliance with subrecipient monitoring requirements to establish monitoring procedures to ensure federal subrecipient requirements are
met and proof of evaluation and monitoring is maintained. VIEWS OF RESPONSIBLE OFFICIALS: See Corrective Action Plan
Material Weakness in Internal Control over Financial Reporting and Noncompliance – Allowable Costs/Cost Principles. IDENTIFICATION OF FEDERAL PROGRAM: 64.033 VA Support Services for Veteran Families Program
Award 20-AK-152 Department of Veterans Affairs. CRITERIA: Title 2 U.S. Code Part 200.403(g) requires that for costs charged to a federal program to be allowable, they must be adequately documented. CONDITION: Payroll and non-payroll related costs charged to the federal major program were not documented in accordance with the Mission’s financial policies and procedures. This indicates pervasiveness across the entity. CAUSE: The Mission does not have a procedure in place to monitor all supporting documents are properly secured and documented. EFFECT OR POTENTIAL EFFECT: Not following established financial policies and procedures increases the risk that internal control failures, questioned costs and noncompliance could arise in the future over federal programs. RECOMMENDATION: We recommend the Mission reviews its financial policies and procedures and implement and/or revise accordingly to ensure they conform to both Uniform Guidance and internal policies and procedures to satisfy adequate internal control design to account for proper segregation of duties, records retention, and audit trail. VIEWS OF RESPONSIBLE OFFICIALS: See Corrective Action Plan
Material Weakness in Internal Control over Compliance and Noncompliance – Cash Management. IDENTIFICATION OF FEDERAL PROGRAM: 64.033 VA Support Services for Veteran Families Program Award 20-AK-152 Department of Veterans Affairs. CRITERIA: Per the grant award - Recipients must have procedures for minimizing the time elapsing between the transfer of any advance payments of funds under the award and disbursement of the funds for direct program costs and the proportionate share of any allowable indirect or facilities and administrative costs. Recipients must ensure that the timing and amount of any payments to sub-recipients under the award conform to this standard. Per the SSVF Program Guide Section VII – Fiscal Administration Cash Dra Down Process – 1. Overview of Disbursement Grantees may draw down supportive services grant funds prospectively via the internet-based PMS in accordance with the restrictions laid out in the NOFA. Draw down requests are submitted and processed online via the request functions of the PMS platform. Once a draw down request is submitted, disbursement is completed by electronic funds transfer to the grantee's bank account the following business day. Grantees have three days to expend the funds that are drawn down from the HHS system. If funds are not expended within three days, a grantee must contact the VA to plan for paying interest on those funds.CONDITION: It was noted during the audit of fiscal year 2021 that the Mission did not still have records maintained from all the drawdown requests that occurred during the fiscal year 2021. CAUSE: There was turnover at the Mission and prior management did not have an adequate administrative filing system and are not available to track down documents related to the fiscal year 2021. EFFECT OR POTENTIAL EFFECT: The Mission could have been out of compliance with Uniform Guidance cash management standards. QUESTIONED COSTS: None. CONTEXT: For this program, there were 45 cash drawdowns that occurred during fiscal year 2021, a random sample of five were requested to test against the grant awards cash draw down requirements, of those five, current management was unable to locate the support showing that the Mission followed the cash draw down process for those three cash draw downs. IDENTIFICATION OF REPEAT FINDING: Not Applicable. RECOMMENDATIONS: We recommend that as a part of the Mission’s internal control structure over compliance with cash management requirements to establish monitoring procedures to ensure records documenting the Mission’s cash management procedures are maintained. VIEWS OF RESPONSIBLE OFFICIALS: See Corrective Action Plan
Material Weakness in Internal Control over Compliance and Noncompliance - Eligibility Requirement IDENTIFICATION OF FEDERAL PROGRAM: 64.033 VA Support Services for Veteran Families Program Award 20-AK-152 Department of Veterans Affairs. CRITERIA: Per the SSVF Program Guide, each participant household's file must include documentation verifying that the participant meets SSVF program eligibility requirements and specifying the participant's category of “occupying permanent housing.” Grantees with insufficient case file documentation may be found out of compliance with SSVF Program regulations during a VA monitoring visit. Grantees
must develop policies and procedures that ensure appropriate documentation is obtained and included in participants’ files. To become a participant household under the SSVF Program, the following conditions must be met:
1. A member of a "Veteran family": Either (a) a Veteran; or (b) a member of a family in which the
head of household, or the spouse of the head of household, is a Veteran.
2. "Very low-income": Household income does not exceed 50 percent of area median income. Unless VA
announces otherwise in the NOFA, the median income for an area or community will be determined
using the income limits most recently published by the Department of Housing and Urban Development
for programs under section 8 of the United States Housing Act of 1937 (42 U.S.C. 1437f), which can
be found at: http://www.huduser.org/portal/datasets/il.html
3. "Occupying Permanent Housing": A very low-income Veteran family is considered to be “occupying permanent housing” if they fall into one of three categories:
(Category 1) Is residing in permanent housing and at risk of becoming literally homeless but for grantee’s assistance; (Category 2) Is literally homeless, and at risk to remain in this situation but for grantee’s assistance, and scheduled to become a resident of permanent housing within 90 days pending the location or development of housing suitable for permanent housing; or (Category 3) Is literally homeless after exiting permanent housing to seek other housing that is responsive to the very low-income Veteran family’s needs and preferences. CONDITION: The Mission was unable to provide complete records documenting that participants met all of the eligibility requirements. EFFECT OR POTENTIAL EFFECT: The Mission’s current management was unable to provide records showing that participant files were complete. QUESTIONED COSTS: None. CONTEXT: For this funding, there were 156 participants who received benefits through the SSVF program during the fiscal year under audit. During the single audit testwork the auditors selected a random sample of 16 participant files to test against eligibility requirements. Of those 16 participants, 8 of them did not have complete documentation supporting that the participants met all of the eligibility requirements. IDENTIFICATION OF REPEAT FINDING: Not Applicable. RECOMMENDATION: We recommend that as a part of the Mission’s internal control structure over compliance with eligibility requirements to establish monitoring procedures to ensure federal reporting deadlines are met and proof of submission and reports submitted are maintained. VIEWS OF RESPONSBLE OFFICIALS: See Corrective Action Plan.
Material Weakness in Internal Control over Compliance and Noncompliance - Reporting Requirements IDENTIFICATION OF FEDERAL PROGRAM: 64.033 VA Support Services for Veteran Families Program Award 20-AK-152 Department of Veterans Affairs. CRITERIA: Per the award agreement the Mission is required to submit quarterly progress reports. Progress reports shall be submitted within 30 days after the end of the reporting periods, which are December 31st, March 31st, June 30th and September 30th. This report will include detailed information about the project(s) funded, including, but not limited to, the number of disabled Veterans who benefited, administrative expenses, information about how the funds were actually used, data to support statements of progress, and data concerning individual results and outcomes of funded projects reflecting project success and impacts. CONDITION: The Mission was unable to provide records of the quarterly reports being
submitted during the fiscal year ended March 31, 2021. CAUSE: The Mission has had turnover in all management positions since the fiscal year ended March 31, 2021. Prior management did not maintain complete or accurate files. EFFECT OR POTENTIAL EFFECT: The Mission’s current management was unable to provide records showing that the reporting compliance requirements were met. QUESTIONED COSTS: None. CONTEXT: For this funding, four quarterly progress reports were due during the fiscal year under audit. During the single audit testwork the auditors requested to test two reports and neither were available for inspection. IDENTIFICATION OF REPEAT FINDING: Not Applicable. RECOMMENDATION: We recommend that as a part of the Mission’s internal control structure over compliance with reporting requirements to establish monitoring procedures to ensure federal reporting deadlines are met and proof of submission and reports submitted are maintained. VIEWS OF RESPONSIBLE OFFICIALS: See Corrective Action Plan
Material Weakness in Internal Control over Compliance and Noncompliance – Subrecipient Monitoring IDENTIFICATION OF FEDERAL PROGRAM: 64.033 VA Support Services for Veteran Families Program Award 20-AK-152 Department of Veterans Affairs. CRITERIA: Per Part 3 of the Uniform Guidance Compliance Supplement, A pass-through entity (PTE) must: - Identify the Award and Applicable Requirements- clearly identify to the subrecipient: (1) the award as a subaward at the time of subaward (2) all requirements imposed by the PTE on the subrecipient so that the federal award is used in accordance with federal statutes, regulations, and the terms and conditions of the award. - Evaluate Risk - evaluate each subrecipient's risk of noncompliance for the purpose of determining the appropriate subrecipient monitoring related to the subaward. - Monitor - monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies terms and conditions of the subaward, and achieves performance goals. CONDITION: The Mission was unable to provide documentation that the evaluation of risk and monitoring of the activities of the subrecipient was performed. CAUSE: The Mission has had turnover in all management positions since the fiscal year ended March 31, 2021. Prior management did not maintain complete or accurate files. EFFECT OR POTENTIAL EFFECT: The Mission’s current management was unable to provide records showing that the evaluation and monitoring of subrecipients was performed. QUESTIONED COSTS: None. CONTEXT: The Mission entered into 3 subawards during the period under audit. The sub awardees were approved in the SSVF program budget by the federal agency. There were 116 disbursements made to the 3 subrecipients. The auditor selected a random sample of 12 disbursements to test against supporting documentation showing that the Mission monitored the sub awardees, none of that documentation was available for inspection. IDENTIFCATION OF REPEAT FINDING: Not Applicable. RECOMMENDATION: We recommend that as a part of the Mission’s internal control structure over compliance with subrecipient monitoring requirements to establish monitoring procedures to ensure federal subrecipient requirements are
met and proof of evaluation and monitoring is maintained. VIEWS OF RESPONSIBLE OFFICIALS: See Corrective Action Plan
Material Weakness in Internal Control over Financial Reporting and Noncompliance – Allowable Costs/Cost Principles. IDENTIFICATION OF FEDERAL PROGRAM: 64.033 VA Support Services for Veteran Families Program
Award 20-AK-152 Department of Veterans Affairs. CRITERIA: Title 2 U.S. Code Part 200.403(g) requires that for costs charged to a federal program to be allowable, they must be adequately documented. CONDITION: Payroll and non-payroll related costs charged to the federal major program were not documented in accordance with the Mission’s financial policies and procedures. This indicates pervasiveness across the entity. CAUSE: The Mission does not have a procedure in place to monitor all supporting documents are properly secured and documented. EFFECT OR POTENTIAL EFFECT: Not following established financial policies and procedures increases the risk that internal control failures, questioned costs and noncompliance could arise in the future over federal programs. RECOMMENDATION: We recommend the Mission reviews its financial policies and procedures and implement and/or revise accordingly to ensure they conform to both Uniform Guidance and internal policies and procedures to satisfy adequate internal control design to account for proper segregation of duties, records retention, and audit trail. VIEWS OF RESPONSIBLE OFFICIALS: See Corrective Action Plan
Material Weakness in Internal Control over Compliance and Noncompliance – Cash Management. IDENTIFICATION OF FEDERAL PROGRAM: 64.033 VA Support Services for Veteran Families Program Award 20-AK-152 Department of Veterans Affairs. CRITERIA: Per the grant award - Recipients must have procedures for minimizing the time elapsing between the transfer of any advance payments of funds under the award and disbursement of the funds for direct program costs and the proportionate share of any allowable indirect or facilities and administrative costs. Recipients must ensure that the timing and amount of any payments to sub-recipients under the award conform to this standard. Per the SSVF Program Guide Section VII – Fiscal Administration Cash Dra Down Process – 1. Overview of Disbursement Grantees may draw down supportive services grant funds prospectively via the internet-based PMS in accordance with the restrictions laid out in the NOFA. Draw down requests are submitted and processed online via the request functions of the PMS platform. Once a draw down request is submitted, disbursement is completed by electronic funds transfer to the grantee's bank account the following business day. Grantees have three days to expend the funds that are drawn down from the HHS system. If funds are not expended within three days, a grantee must contact the VA to plan for paying interest on those funds.CONDITION: It was noted during the audit of fiscal year 2021 that the Mission did not still have records maintained from all the drawdown requests that occurred during the fiscal year 2021. CAUSE: There was turnover at the Mission and prior management did not have an adequate administrative filing system and are not available to track down documents related to the fiscal year 2021. EFFECT OR POTENTIAL EFFECT: The Mission could have been out of compliance with Uniform Guidance cash management standards. QUESTIONED COSTS: None. CONTEXT: For this program, there were 45 cash drawdowns that occurred during fiscal year 2021, a random sample of five were requested to test against the grant awards cash draw down requirements, of those five, current management was unable to locate the support showing that the Mission followed the cash draw down process for those three cash draw downs. IDENTIFICATION OF REPEAT FINDING: Not Applicable. RECOMMENDATIONS: We recommend that as a part of the Mission’s internal control structure over compliance with cash management requirements to establish monitoring procedures to ensure records documenting the Mission’s cash management procedures are maintained. VIEWS OF RESPONSIBLE OFFICIALS: See Corrective Action Plan
Material Weakness in Internal Control over Compliance and Noncompliance - Eligibility Requirement IDENTIFICATION OF FEDERAL PROGRAM: 64.033 VA Support Services for Veteran Families Program Award 20-AK-152 Department of Veterans Affairs. CRITERIA: Per the SSVF Program Guide, each participant household's file must include documentation verifying that the participant meets SSVF program eligibility requirements and specifying the participant's category of “occupying permanent housing.” Grantees with insufficient case file documentation may be found out of compliance with SSVF Program regulations during a VA monitoring visit. Grantees
must develop policies and procedures that ensure appropriate documentation is obtained and included in participants’ files. To become a participant household under the SSVF Program, the following conditions must be met:
1. A member of a "Veteran family": Either (a) a Veteran; or (b) a member of a family in which the
head of household, or the spouse of the head of household, is a Veteran.
2. "Very low-income": Household income does not exceed 50 percent of area median income. Unless VA
announces otherwise in the NOFA, the median income for an area or community will be determined
using the income limits most recently published by the Department of Housing and Urban Development
for programs under section 8 of the United States Housing Act of 1937 (42 U.S.C. 1437f), which can
be found at: http://www.huduser.org/portal/datasets/il.html
3. "Occupying Permanent Housing": A very low-income Veteran family is considered to be “occupying permanent housing” if they fall into one of three categories:
(Category 1) Is residing in permanent housing and at risk of becoming literally homeless but for grantee’s assistance; (Category 2) Is literally homeless, and at risk to remain in this situation but for grantee’s assistance, and scheduled to become a resident of permanent housing within 90 days pending the location or development of housing suitable for permanent housing; or (Category 3) Is literally homeless after exiting permanent housing to seek other housing that is responsive to the very low-income Veteran family’s needs and preferences. CONDITION: The Mission was unable to provide complete records documenting that participants met all of the eligibility requirements. EFFECT OR POTENTIAL EFFECT: The Mission’s current management was unable to provide records showing that participant files were complete. QUESTIONED COSTS: None. CONTEXT: For this funding, there were 156 participants who received benefits through the SSVF program during the fiscal year under audit. During the single audit testwork the auditors selected a random sample of 16 participant files to test against eligibility requirements. Of those 16 participants, 8 of them did not have complete documentation supporting that the participants met all of the eligibility requirements. IDENTIFICATION OF REPEAT FINDING: Not Applicable. RECOMMENDATION: We recommend that as a part of the Mission’s internal control structure over compliance with eligibility requirements to establish monitoring procedures to ensure federal reporting deadlines are met and proof of submission and reports submitted are maintained. VIEWS OF RESPONSBLE OFFICIALS: See Corrective Action Plan.
Material Weakness in Internal Control over Compliance and Noncompliance - Reporting Requirements IDENTIFICATION OF FEDERAL PROGRAM: 64.033 VA Support Services for Veteran Families Program Award 20-AK-152 Department of Veterans Affairs. CRITERIA: Per the award agreement the Mission is required to submit quarterly progress reports. Progress reports shall be submitted within 30 days after the end of the reporting periods, which are December 31st, March 31st, June 30th and September 30th. This report will include detailed information about the project(s) funded, including, but not limited to, the number of disabled Veterans who benefited, administrative expenses, information about how the funds were actually used, data to support statements of progress, and data concerning individual results and outcomes of funded projects reflecting project success and impacts. CONDITION: The Mission was unable to provide records of the quarterly reports being
submitted during the fiscal year ended March 31, 2021. CAUSE: The Mission has had turnover in all management positions since the fiscal year ended March 31, 2021. Prior management did not maintain complete or accurate files. EFFECT OR POTENTIAL EFFECT: The Mission’s current management was unable to provide records showing that the reporting compliance requirements were met. QUESTIONED COSTS: None. CONTEXT: For this funding, four quarterly progress reports were due during the fiscal year under audit. During the single audit testwork the auditors requested to test two reports and neither were available for inspection. IDENTIFICATION OF REPEAT FINDING: Not Applicable. RECOMMENDATION: We recommend that as a part of the Mission’s internal control structure over compliance with reporting requirements to establish monitoring procedures to ensure federal reporting deadlines are met and proof of submission and reports submitted are maintained. VIEWS OF RESPONSIBLE OFFICIALS: See Corrective Action Plan
Material Weakness in Internal Control over Compliance and Noncompliance – Subrecipient Monitoring IDENTIFICATION OF FEDERAL PROGRAM: 64.033 VA Support Services for Veteran Families Program Award 20-AK-152 Department of Veterans Affairs. CRITERIA: Per Part 3 of the Uniform Guidance Compliance Supplement, A pass-through entity (PTE) must: - Identify the Award and Applicable Requirements- clearly identify to the subrecipient: (1) the award as a subaward at the time of subaward (2) all requirements imposed by the PTE on the subrecipient so that the federal award is used in accordance with federal statutes, regulations, and the terms and conditions of the award. - Evaluate Risk - evaluate each subrecipient's risk of noncompliance for the purpose of determining the appropriate subrecipient monitoring related to the subaward. - Monitor - monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies terms and conditions of the subaward, and achieves performance goals. CONDITION: The Mission was unable to provide documentation that the evaluation of risk and monitoring of the activities of the subrecipient was performed. CAUSE: The Mission has had turnover in all management positions since the fiscal year ended March 31, 2021. Prior management did not maintain complete or accurate files. EFFECT OR POTENTIAL EFFECT: The Mission’s current management was unable to provide records showing that the evaluation and monitoring of subrecipients was performed. QUESTIONED COSTS: None. CONTEXT: The Mission entered into 3 subawards during the period under audit. The sub awardees were approved in the SSVF program budget by the federal agency. There were 116 disbursements made to the 3 subrecipients. The auditor selected a random sample of 12 disbursements to test against supporting documentation showing that the Mission monitored the sub awardees, none of that documentation was available for inspection. IDENTIFCATION OF REPEAT FINDING: Not Applicable. RECOMMENDATION: We recommend that as a part of the Mission’s internal control structure over compliance with subrecipient monitoring requirements to establish monitoring procedures to ensure federal subrecipient requirements are
met and proof of evaluation and monitoring is maintained. VIEWS OF RESPONSIBLE OFFICIALS: See Corrective Action Plan