Audit 316423

Finding Number: 2023-005 Refer to Section II for findings 2023-001, 2023-002 and 2023-003 Information on the Federal Program: Federal Agency: United States Department of Veteran Affairs Program Name: VA Supportive Services for Veteran Families Program (SSVF) CFDA: 64.033 Federal Award Identification Number: 14-MA-209 Federal Award Year: 2023 Specific Requirement: In accordance with Title 2 U.S. Code of Federal Regulations Part 200, Subpart D, Section 200.303a, the Organization is required 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. Condition Found: We noted there was limited or no segregation of duties in several areas during our audit. See Section II for findings 2023-001, 2023-002 and 2023-003. Context: We noted these conditions while obtaining an understanding of internal control for the respective transaction cycles listed in the findings. Questioned Costs: None noted Identification as a Repeat Finding, if Applicable: A repeat finding; See finding 2022-005, 2021-005, 2020-006 and 2019-007 Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan attached.

Finding Number: 2023-006 Information on the Federal Program: Federal Agency: United States Department of Veteran Affairs Program Name: SSVF CFDA: 64.033 Federal Award Identification Number: 14-MA-209 Federal Award Year: 2023 Specific Requirement: Required by 2 CFR, Part 200 for federally funded programs, when an institution enters into a covered transaction with an entity or individual, an institution must verify that the vendor is not suspended or debarred or otherwise excluded from participating in federal programs. Generally, a covered transaction is a transaction expected to equal or exceed $25,000 and be funded with federal dollars. This verification may be accomplished by checking the System for Award Management (SAM), formerly the Excluded Parties List System, maintained by the General Services Administration, collecting a certification from the vendor, or by adding a clause or condition to the covered transaction. Condition Found: The Organization did not have an internal control procedure designed to identify vendors and employees meeting the covered transaction threshold and crosschecking those vendors and employees against SAM. None of the vendors or employees tested were identified on SAM. Context: We selected a nonstatistical sample of 35 vendors and 15 employees funded by SSVF. Questioned Costs: None Cause and Effect: The Organization was aware of the requirement to verify vendors and employees against the SAM; however, a process was not implemented to verify vendors or employees. Without performing the required check of vendors and employees against SAM, the Organization could pay a vendor or an employee with federal funds inappropriately. Identification as a Repeat Finding, if Applicable: A repeat finding; See finding 2022-006, 2021-006, 2020-007 and 2019-008 Recommendation: We recommend the Organization implement a process to compare all vendors and employees meeting the covered transaction threshold funded by a federal program to SAM on a regular basis and when a new vendor or employee is entered into the accounting system. The Organization should maintain documentation that the comparison has been performed. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan attached.

Finding Number: 2023-007 Information on the Federal Program: Federal Agency: United States Department of Veteran Affairs Program Name: SSVF CFDA: 64.033 Federal Award Identification Number: 14-MA-209 Federal Award Year: 2023 Specific Requirement: In accordance with the SSVF Program Guide dated December 2020, an organization must maintain adequate eligibility documentation. Grantees must implement policies and procedures that ensure appropriate documentation is obtained and is included in each participant’s file. Condition Found: During our testing of participant eligibility, we noted the following: 1. Documented approval by either the Program Coordinator or the Case Manager was missing for documentation related to 14 participant files out of the 37 selected for testing. 2. 90-day eligibility recertifications were not performed or not documented appropriately for 17 participants out of the 37 requiring recertification. Context: We sampled 37 participants out of 159 total participants, using a nonstatistical sample, who were provided support from the Organization’s SSVF program. Questioned Costs: N/A Cause and Effect: The Organization is aware of the eligibility requirements under the SSVF program, but was unaware of the importance of retaining all of the required documentation set forth in the SSVF Program Guide. Under the terms of the SSVF grant, grantees with insufficient case file documentation may be found out of compliance with SSVF Program regulations. The Organization also is at risk for providing services to ineligible participants. As a result of the Organization’s inability to provide certain documents, compliance over eligibility was unable to be tested. Identification as a Repeat Finding, if Applicable: A repeat finding; See finding 2022-007, 2021-008, 2020-010 and 2019-011 Recommendation: We recommend the Organization implement a system of controls that would properly document the eligibility requirements of participants under the SSVF program and compliance with the eligibility requirements set forth under the SSVF program. Participants’ documented eligibility should be properly reviewed, evidenced by appropriate supervisor signatures. All eligibility forms, recertification forms and other required forms should be maintained in a file for each participant. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan attached.

Finding Number: 2023-008 Information on the Federal Program: Federal Agency: United States Department of Veteran Affairs Program Name: SSVF CFDA: 64.033 Federal Award Identification Number: 14-MA-209 Federal Award Year: 2023 Specific Requirement: In accordance with the Uniform Guidance §200.512, Report Submission, the audit must be completed, and the data collection form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor’s reports, or nine months after the end of the audit period. Condition Found: The Organization did not submit the data collection form prior to the 9 month extended deadline of March 31, 2024. Context: The late report submission is a condition identified per examination of the audit report date, in comparison to the required submission deadline date of the data collection form and reporting package. Questioned Costs: N/A Cause and Effect: Uniform Guidance audit was not completed by the reporting deadline due to issues with staffing. This presented delays in scheduling and other data gathering that likely could have been avoided or reduced had there been adequate staffing. Identification as a Repeat Finding, if Applicable: Not applicable Recommendation: We recommend that staff organize an internal control structure that can facilitate timely preparation of the data collection form and the related reconciliations for the completion of the audit and submission of the data collection form before the submission deadline. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan attached.

Finding Number: 2023-005 Refer to Section II for findings 2023-001, 2023-002 and 2023-003 Information on the Federal Program: Federal Agency: United States Department of Veteran Affairs Program Name: VA Supportive Services for Veteran Families Program (SSVF) CFDA: 64.033 Federal Award Identification Number: 14-MA-209 Federal Award Year: 2023 Specific Requirement: In accordance with Title 2 U.S. Code of Federal Regulations Part 200, Subpart D, Section 200.303a, the Organization is required 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. Condition Found: We noted there was limited or no segregation of duties in several areas during our audit. See Section II for findings 2023-001, 2023-002 and 2023-003. Context: We noted these conditions while obtaining an understanding of internal control for the respective transaction cycles listed in the findings. Questioned Costs: None noted Identification as a Repeat Finding, if Applicable: A repeat finding; See finding 2022-005, 2021-005, 2020-006 and 2019-007 Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan attached.

Finding Number: 2023-006 Information on the Federal Program: Federal Agency: United States Department of Veteran Affairs Program Name: SSVF CFDA: 64.033 Federal Award Identification Number: 14-MA-209 Federal Award Year: 2023 Specific Requirement: Required by 2 CFR, Part 200 for federally funded programs, when an institution enters into a covered transaction with an entity or individual, an institution must verify that the vendor is not suspended or debarred or otherwise excluded from participating in federal programs. Generally, a covered transaction is a transaction expected to equal or exceed $25,000 and be funded with federal dollars. This verification may be accomplished by checking the System for Award Management (SAM), formerly the Excluded Parties List System, maintained by the General Services Administration, collecting a certification from the vendor, or by adding a clause or condition to the covered transaction. Condition Found: The Organization did not have an internal control procedure designed to identify vendors and employees meeting the covered transaction threshold and crosschecking those vendors and employees against SAM. None of the vendors or employees tested were identified on SAM. Context: We selected a nonstatistical sample of 35 vendors and 15 employees funded by SSVF. Questioned Costs: None Cause and Effect: The Organization was aware of the requirement to verify vendors and employees against the SAM; however, a process was not implemented to verify vendors or employees. Without performing the required check of vendors and employees against SAM, the Organization could pay a vendor or an employee with federal funds inappropriately. Identification as a Repeat Finding, if Applicable: A repeat finding; See finding 2022-006, 2021-006, 2020-007 and 2019-008 Recommendation: We recommend the Organization implement a process to compare all vendors and employees meeting the covered transaction threshold funded by a federal program to SAM on a regular basis and when a new vendor or employee is entered into the accounting system. The Organization should maintain documentation that the comparison has been performed. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan attached.

Finding Number: 2023-007 Information on the Federal Program: Federal Agency: United States Department of Veteran Affairs Program Name: SSVF CFDA: 64.033 Federal Award Identification Number: 14-MA-209 Federal Award Year: 2023 Specific Requirement: In accordance with the SSVF Program Guide dated December 2020, an organization must maintain adequate eligibility documentation. Grantees must implement policies and procedures that ensure appropriate documentation is obtained and is included in each participant’s file. Condition Found: During our testing of participant eligibility, we noted the following: 1. Documented approval by either the Program Coordinator or the Case Manager was missing for documentation related to 14 participant files out of the 37 selected for testing. 2. 90-day eligibility recertifications were not performed or not documented appropriately for 17 participants out of the 37 requiring recertification. Context: We sampled 37 participants out of 159 total participants, using a nonstatistical sample, who were provided support from the Organization’s SSVF program. Questioned Costs: N/A Cause and Effect: The Organization is aware of the eligibility requirements under the SSVF program, but was unaware of the importance of retaining all of the required documentation set forth in the SSVF Program Guide. Under the terms of the SSVF grant, grantees with insufficient case file documentation may be found out of compliance with SSVF Program regulations. The Organization also is at risk for providing services to ineligible participants. As a result of the Organization’s inability to provide certain documents, compliance over eligibility was unable to be tested. Identification as a Repeat Finding, if Applicable: A repeat finding; See finding 2022-007, 2021-008, 2020-010 and 2019-011 Recommendation: We recommend the Organization implement a system of controls that would properly document the eligibility requirements of participants under the SSVF program and compliance with the eligibility requirements set forth under the SSVF program. Participants’ documented eligibility should be properly reviewed, evidenced by appropriate supervisor signatures. All eligibility forms, recertification forms and other required forms should be maintained in a file for each participant. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan attached.

Finding Number: 2023-008 Information on the Federal Program: Federal Agency: United States Department of Veteran Affairs Program Name: SSVF CFDA: 64.033 Federal Award Identification Number: 14-MA-209 Federal Award Year: 2023 Specific Requirement: In accordance with the Uniform Guidance §200.512, Report Submission, the audit must be completed, and the data collection form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor’s reports, or nine months after the end of the audit period. Condition Found: The Organization did not submit the data collection form prior to the 9 month extended deadline of March 31, 2024. Context: The late report submission is a condition identified per examination of the audit report date, in comparison to the required submission deadline date of the data collection form and reporting package. Questioned Costs: N/A Cause and Effect: Uniform Guidance audit was not completed by the reporting deadline due to issues with staffing. This presented delays in scheduling and other data gathering that likely could have been avoided or reduced had there been adequate staffing. Identification as a Repeat Finding, if Applicable: Not applicable Recommendation: We recommend that staff organize an internal control structure that can facilitate timely preparation of the data collection form and the related reconciliations for the completion of the audit and submission of the data collection form before the submission deadline. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan attached.