Audit 324497

Corporation for National and Community Service Foster Grandparent/Senior Companion Cluster – Assistance Listing #94.011, #94.016 #2023-002 – Significant Deficiency: Grant and Contract Management Compliance Finding: Adherence to Administrative Policies Requirements of Uniform Guidance This is a partial repeat of prior year finding #2022-002. Conditions and Criteria: • Policies associated with Financial Management and Cash Management as they pertain to the management of federal awards were in need of enhancement to meet the administrative requirements of Uniform Guidance at the start of the year under audit. Policies were put into place in February and September 2023. • Once these policies were established, they were not being followed, resulting in the delayed preparation of Schedule of Expenditures of Federal Awards. Certain balances were not reconciled to supporting documentation. Cause/Context: • Catholic Charities West Michigan had general policies and procedures that are applicable to federal awards. However, there are additional unique policy requirements related to Financial Management and Cash Management that are key to the Organization’s federal programs that were missing from the policies in place at the start of the year under audit. • Polices were adopted in February and September 2023. However, as of September 30, 2023, these policies were not being followed. Catholic Charities relies on information provided by passthrough agencies in the preparation of the SEFA. Necessary information was not received from one such agency until February 2024. Catholic Charities did not reconcile this information to documentation and the general ledger. Unreconciled differences were identified during the audit and required an adjustment to the federal expenditures reported on the SEFA. Recommendations: We recommend that financial management policies be followed to ensure that the SEFA is prepared timely and reconciled against the general ledger and other supporting documentation to ensure accuracy. Views of Responsible Officials and Planned Corrective Actions: Modifications of the Administrative Financial Management and Cash Management policies will be made to further address concerns identified in the Single Audit. In addition, the reconciliation process will be reviewed and improved to assure timely preparation of the SEFA. CCWM will reconcile federal programs to the passthrough agencies 9 months into the fiscal year at a minimum as part of the preparation of the SEFA report.

Corporation for National and Community Service Foster Grandparent/Senior Companion Cluster – Assistance Listing #94.011, #94.016 #2023-002 – Significant Deficiency: Grant and Contract Management Compliance Finding: Adherence to Administrative Policies Requirements of Uniform Guidance This is a partial repeat of prior year finding #2022-002. Conditions and Criteria: • Policies associated with Financial Management and Cash Management as they pertain to the management of federal awards were in need of enhancement to meet the administrative requirements of Uniform Guidance at the start of the year under audit. Policies were put into place in February and September 2023. • Once these policies were established, they were not being followed, resulting in the delayed preparation of Schedule of Expenditures of Federal Awards. Certain balances were not reconciled to supporting documentation. Cause/Context: • Catholic Charities West Michigan had general policies and procedures that are applicable to federal awards. However, there are additional unique policy requirements related to Financial Management and Cash Management that are key to the Organization’s federal programs that were missing from the policies in place at the start of the year under audit. • Polices were adopted in February and September 2023. However, as of September 30, 2023, these policies were not being followed. Catholic Charities relies on information provided by passthrough agencies in the preparation of the SEFA. Necessary information was not received from one such agency until February 2024. Catholic Charities did not reconcile this information to documentation and the general ledger. Unreconciled differences were identified during the audit and required an adjustment to the federal expenditures reported on the SEFA. Recommendations: We recommend that financial management policies be followed to ensure that the SEFA is prepared timely and reconciled against the general ledger and other supporting documentation to ensure accuracy. Views of Responsible Officials and Planned Corrective Actions: Modifications of the Administrative Financial Management and Cash Management policies will be made to further address concerns identified in the Single Audit. In addition, the reconciliation process will be reviewed and improved to assure timely preparation of the SEFA. CCWM will reconcile federal programs to the passthrough agencies 9 months into the fiscal year at a minimum as part of the preparation of the SEFA report.

Corporation for National and Community Service Foster Grandparent/Senior Companion Cluster – Assistance Listing #94.011, #94.016 #2023-002 – Significant Deficiency: Grant and Contract Management Compliance Finding: Adherence to Administrative Policies Requirements of Uniform Guidance This is a partial repeat of prior year finding #2022-002. Conditions and Criteria: • Policies associated with Financial Management and Cash Management as they pertain to the management of federal awards were in need of enhancement to meet the administrative requirements of Uniform Guidance at the start of the year under audit. Policies were put into place in February and September 2023. • Once these policies were established, they were not being followed, resulting in the delayed preparation of Schedule of Expenditures of Federal Awards. Certain balances were not reconciled to supporting documentation. Cause/Context: • Catholic Charities West Michigan had general policies and procedures that are applicable to federal awards. However, there are additional unique policy requirements related to Financial Management and Cash Management that are key to the Organization’s federal programs that were missing from the policies in place at the start of the year under audit. • Polices were adopted in February and September 2023. However, as of September 30, 2023, these policies were not being followed. Catholic Charities relies on information provided by passthrough agencies in the preparation of the SEFA. Necessary information was not received from one such agency until February 2024. Catholic Charities did not reconcile this information to documentation and the general ledger. Unreconciled differences were identified during the audit and required an adjustment to the federal expenditures reported on the SEFA. Recommendations: We recommend that financial management policies be followed to ensure that the SEFA is prepared timely and reconciled against the general ledger and other supporting documentation to ensure accuracy. Views of Responsible Officials and Planned Corrective Actions: Modifications of the Administrative Financial Management and Cash Management policies will be made to further address concerns identified in the Single Audit. In addition, the reconciliation process will be reviewed and improved to assure timely preparation of the SEFA. CCWM will reconcile federal programs to the passthrough agencies 9 months into the fiscal year at a minimum as part of the preparation of the SEFA report.

Corporation for National and Community Service Foster Grandparent/Senior Companion Cluster – Assistance Listing #94.011, #94.016 #2023-003 – Material Weakness in Internal Controls over Compliance: Special Tests and Provisions Compliance Finding: Special Tests and Provisions This is a repeat of prior year finding #2022-005. Criteria: • Foster Grandparent and Senior Companion eligibility require background checks for Foster Grandparent and Senior Companion volunteers and Catholic Charities West Michigan staff involved in the program to be completed prior to the date they begin to work/serve. • All background checks are required to be adjudicated by Catholic Charities West Michigan to ensure the volunteer is eligible for service prior to the date they begin to work/serve. This adjudication should be documented within the AmeriCorps-approved software when used or Catholic Charities may manually document the eligibility decision and the date of this adjudication. Conditions/Context: • In the spring of 2023, the Corporation for National and Community Service (CNCS) completed an audit of the National Service Criminal History Checks (NSCHC) requirement compliance of a sample of volunteers who received a stipend during the period of 4/1/2022 through 12/31/2022 as well as all staff working in the programs. As a result of this audit, 86 noncompliance findings were noted. This audit was closed as of March 18, 2024, with the corrective action plan and findings resolved. • We tested a sample of 24 volunteers and 2 staff members who worked or received stipends during the fiscal year ending September 30, 2023, many of which were also subject to the CNCS audit previously performed. • For 13 of the 24 volunteers and both staff members we tested, at least one of the required background check components were not completed correctly prior to their start date. These missing background checks were completed before September 30, 2023 for 12 of the volunteers. The checks for the remaining volunteer and two staff members were completed subsequent to year-end, but prior to the audit beginning in April 2024. • For 23 of the 24 volunteers and both staff members we tested, adjudication of the check by Catholic Charities West Michigan staff was not completed or properly documented for at least one of the required background check components. All checks were adjudicated and properly documented subsequent to year-end, but prior to the audit beginning in April 2024. Cause: The Organization had not adequately trained the responsible staff of all program requirements for background checks. Additionally, policies and procedures in place did not adequately reflect all such requirements. Questioned Costs: The Organization repaid CNCS approximately $54,000 related to the CNCS audit findings for the period April 1, 2022 to December 31, 2022, referred to above. A portion of this obligation may be associated with the year ended September 30, 2023, although that amount is not able to be determined. Any additional questioned costs for the period January 1, 2023 through September 30, 2023 have not been determined. Identification of How Questioned Costs Were Computed: As a result of the CNCS audit findings noted above, cost-based disallowance was identified by the CNCS. The obligation for the period ended December 31, 2022 was based on the amount repaid to CNCS. Catholic Charities West Michigan recorded this obligation in the financial statements as of September 30, 2023 and repaid the amount subsequent to year end. Recommendations: • We recommend that the Organization undergo (and provide) further training to promote the awareness of requirements for all staff performing background checks. • We recommend that the Organization enhance its policies and procedures to promote future compliance with all program requirements. Views of Responsible Officials and Planned Corrective Actions: The Senior Programs have undergone significant improvements in the last 6 months following an audit by the federal funder which resulted in a corrective action plan (CAP) and a repayment of $54,228. Plans were implemented during the spring of 2024 in response to the CAP which resulted in an overhaul of the processes in place to properly develop the volunteer checklists and assure all records for staff and volunteers are now compliant. Our Quality and Compliance and Finance team worked closely with the new Program Manager to assure that we will be fully compliant and remain so.

Corporation for National and Community Service Foster Grandparent/Senior Companion Cluster – Assistance Listing #94.011, #94.016 #2023-003 – Material Weakness in Internal Controls over Compliance: Special Tests and Provisions Compliance Finding: Special Tests and Provisions This is a repeat of prior year finding #2022-005. Criteria: • Foster Grandparent and Senior Companion eligibility require background checks for Foster Grandparent and Senior Companion volunteers and Catholic Charities West Michigan staff involved in the program to be completed prior to the date they begin to work/serve. • All background checks are required to be adjudicated by Catholic Charities West Michigan to ensure the volunteer is eligible for service prior to the date they begin to work/serve. This adjudication should be documented within the AmeriCorps-approved software when used or Catholic Charities may manually document the eligibility decision and the date of this adjudication. Conditions/Context: • In the spring of 2023, the Corporation for National and Community Service (CNCS) completed an audit of the National Service Criminal History Checks (NSCHC) requirement compliance of a sample of volunteers who received a stipend during the period of 4/1/2022 through 12/31/2022 as well as all staff working in the programs. As a result of this audit, 86 noncompliance findings were noted. This audit was closed as of March 18, 2024, with the corrective action plan and findings resolved. • We tested a sample of 24 volunteers and 2 staff members who worked or received stipends during the fiscal year ending September 30, 2023, many of which were also subject to the CNCS audit previously performed. • For 13 of the 24 volunteers and both staff members we tested, at least one of the required background check components were not completed correctly prior to their start date. These missing background checks were completed before September 30, 2023 for 12 of the volunteers. The checks for the remaining volunteer and two staff members were completed subsequent to year-end, but prior to the audit beginning in April 2024. • For 23 of the 24 volunteers and both staff members we tested, adjudication of the check by Catholic Charities West Michigan staff was not completed or properly documented for at least one of the required background check components. All checks were adjudicated and properly documented subsequent to year-end, but prior to the audit beginning in April 2024. Cause: The Organization had not adequately trained the responsible staff of all program requirements for background checks. Additionally, policies and procedures in place did not adequately reflect all such requirements. Questioned Costs: The Organization repaid CNCS approximately $54,000 related to the CNCS audit findings for the period April 1, 2022 to December 31, 2022, referred to above. A portion of this obligation may be associated with the year ended September 30, 2023, although that amount is not able to be determined. Any additional questioned costs for the period January 1, 2023 through September 30, 2023 have not been determined. Identification of How Questioned Costs Were Computed: As a result of the CNCS audit findings noted above, cost-based disallowance was identified by the CNCS. The obligation for the period ended December 31, 2022 was based on the amount repaid to CNCS. Catholic Charities West Michigan recorded this obligation in the financial statements as of September 30, 2023 and repaid the amount subsequent to year end. Recommendations: • We recommend that the Organization undergo (and provide) further training to promote the awareness of requirements for all staff performing background checks. • We recommend that the Organization enhance its policies and procedures to promote future compliance with all program requirements. Views of Responsible Officials and Planned Corrective Actions: The Senior Programs have undergone significant improvements in the last 6 months following an audit by the federal funder which resulted in a corrective action plan (CAP) and a repayment of $54,228. Plans were implemented during the spring of 2024 in response to the CAP which resulted in an overhaul of the processes in place to properly develop the volunteer checklists and assure all records for staff and volunteers are now compliant. Our Quality and Compliance and Finance team worked closely with the new Program Manager to assure that we will be fully compliant and remain so.

Corporation for National and Community Service Foster Grandparent/Senior Companion Cluster – Assistance Listing #94.011, #94.016 #2023-003 – Material Weakness in Internal Controls over Compliance: Special Tests and Provisions Compliance Finding: Special Tests and Provisions This is a repeat of prior year finding #2022-005. Criteria: • Foster Grandparent and Senior Companion eligibility require background checks for Foster Grandparent and Senior Companion volunteers and Catholic Charities West Michigan staff involved in the program to be completed prior to the date they begin to work/serve. • All background checks are required to be adjudicated by Catholic Charities West Michigan to ensure the volunteer is eligible for service prior to the date they begin to work/serve. This adjudication should be documented within the AmeriCorps-approved software when used or Catholic Charities may manually document the eligibility decision and the date of this adjudication. Conditions/Context: • In the spring of 2023, the Corporation for National and Community Service (CNCS) completed an audit of the National Service Criminal History Checks (NSCHC) requirement compliance of a sample of volunteers who received a stipend during the period of 4/1/2022 through 12/31/2022 as well as all staff working in the programs. As a result of this audit, 86 noncompliance findings were noted. This audit was closed as of March 18, 2024, with the corrective action plan and findings resolved. • We tested a sample of 24 volunteers and 2 staff members who worked or received stipends during the fiscal year ending September 30, 2023, many of which were also subject to the CNCS audit previously performed. • For 13 of the 24 volunteers and both staff members we tested, at least one of the required background check components were not completed correctly prior to their start date. These missing background checks were completed before September 30, 2023 for 12 of the volunteers. The checks for the remaining volunteer and two staff members were completed subsequent to year-end, but prior to the audit beginning in April 2024. • For 23 of the 24 volunteers and both staff members we tested, adjudication of the check by Catholic Charities West Michigan staff was not completed or properly documented for at least one of the required background check components. All checks were adjudicated and properly documented subsequent to year-end, but prior to the audit beginning in April 2024. Cause: The Organization had not adequately trained the responsible staff of all program requirements for background checks. Additionally, policies and procedures in place did not adequately reflect all such requirements. Questioned Costs: The Organization repaid CNCS approximately $54,000 related to the CNCS audit findings for the period April 1, 2022 to December 31, 2022, referred to above. A portion of this obligation may be associated with the year ended September 30, 2023, although that amount is not able to be determined. Any additional questioned costs for the period January 1, 2023 through September 30, 2023 have not been determined. Identification of How Questioned Costs Were Computed: As a result of the CNCS audit findings noted above, cost-based disallowance was identified by the CNCS. The obligation for the period ended December 31, 2022 was based on the amount repaid to CNCS. Catholic Charities West Michigan recorded this obligation in the financial statements as of September 30, 2023 and repaid the amount subsequent to year end. Recommendations: • We recommend that the Organization undergo (and provide) further training to promote the awareness of requirements for all staff performing background checks. • We recommend that the Organization enhance its policies and procedures to promote future compliance with all program requirements. Views of Responsible Officials and Planned Corrective Actions: The Senior Programs have undergone significant improvements in the last 6 months following an audit by the federal funder which resulted in a corrective action plan (CAP) and a repayment of $54,228. Plans were implemented during the spring of 2024 in response to the CAP which resulted in an overhaul of the processes in place to properly develop the volunteer checklists and assure all records for staff and volunteers are now compliant. Our Quality and Compliance and Finance team worked closely with the new Program Manager to assure that we will be fully compliant and remain so.

Corporation for National and Community Service Foster Grandparent/Senior Companion Cluster – Assistance Listing #94.011, #94.016 #2023-004 – Significant Deficiency: Grant and Contract Management; Reporting This is a partial repeat of prior year finding #2022-003. Conditions and Criteria: Catholic Charities West Michigan has in place policies that require a separate review after the preparation of reports, however: • Two semi-annual reports for the Foster Grandparent/Senior Companion Cluster were prepared and submitted without documentation of a separate review. • Two quarterly Payment Management Services reports for Foster Grandparents/Senior Companion Cluster were prepared and submitted without documentation of a separate review. Cause/Context: The quarterly and semi-annual reports for the Foster Grandparent/Senior Companion program were prepared by the program director. An Administrative Assistant separately submits the reports but does not review them. The Director of Finance role is responsible for reviewing the reports prior to the submission, but there was no documentation to support this review being completed for four of the six reports tested. Recommendations: An individual independent of the preparation of financial and program reports should review and approve those reports, and documentation of this review should be retained. Views of Responsible Officials and Planned Corrective Actions: Timely reporting as well as documented approvals are very important to Catholic Charities West Michigan and we agree that we must demonstrate that proper reviews or reports have occurred. We have implemented a process including monthly meetings with the Program Manager and the Finance Accountant to review activity and close the month. All reporting is now filed timely with proper documented review.

Corporation for National and Community Service Foster Grandparent/Senior Companion Cluster – Assistance Listing #94.011, #94.016 #2023-004 – Significant Deficiency: Grant and Contract Management; Reporting This is a partial repeat of prior year finding #2022-003. Conditions and Criteria: Catholic Charities West Michigan has in place policies that require a separate review after the preparation of reports, however: • Two semi-annual reports for the Foster Grandparent/Senior Companion Cluster were prepared and submitted without documentation of a separate review. • Two quarterly Payment Management Services reports for Foster Grandparents/Senior Companion Cluster were prepared and submitted without documentation of a separate review. Cause/Context: The quarterly and semi-annual reports for the Foster Grandparent/Senior Companion program were prepared by the program director. An Administrative Assistant separately submits the reports but does not review them. The Director of Finance role is responsible for reviewing the reports prior to the submission, but there was no documentation to support this review being completed for four of the six reports tested. Recommendations: An individual independent of the preparation of financial and program reports should review and approve those reports, and documentation of this review should be retained. Views of Responsible Officials and Planned Corrective Actions: Timely reporting as well as documented approvals are very important to Catholic Charities West Michigan and we agree that we must demonstrate that proper reviews or reports have occurred. We have implemented a process including monthly meetings with the Program Manager and the Finance Accountant to review activity and close the month. All reporting is now filed timely with proper documented review.

Corporation for National and Community Service Foster Grandparent/Senior Companion Cluster – Assistance Listing #94.011, #94.016 #2023-004 – Significant Deficiency: Grant and Contract Management; Reporting This is a partial repeat of prior year finding #2022-003. Conditions and Criteria: Catholic Charities West Michigan has in place policies that require a separate review after the preparation of reports, however: • Two semi-annual reports for the Foster Grandparent/Senior Companion Cluster were prepared and submitted without documentation of a separate review. • Two quarterly Payment Management Services reports for Foster Grandparents/Senior Companion Cluster were prepared and submitted without documentation of a separate review. Cause/Context: The quarterly and semi-annual reports for the Foster Grandparent/Senior Companion program were prepared by the program director. An Administrative Assistant separately submits the reports but does not review them. The Director of Finance role is responsible for reviewing the reports prior to the submission, but there was no documentation to support this review being completed for four of the six reports tested. Recommendations: An individual independent of the preparation of financial and program reports should review and approve those reports, and documentation of this review should be retained. Views of Responsible Officials and Planned Corrective Actions: Timely reporting as well as documented approvals are very important to Catholic Charities West Michigan and we agree that we must demonstrate that proper reviews or reports have occurred. We have implemented a process including monthly meetings with the Program Manager and the Finance Accountant to review activity and close the month. All reporting is now filed timely with proper documented review.

Corporation for National and Community Service Foster Grandparent/Senior Companion Cluster – Assistance Listing #94.011, #94.016 #2023-002 – Significant Deficiency: Grant and Contract Management Compliance Finding: Adherence to Administrative Policies Requirements of Uniform Guidance This is a partial repeat of prior year finding #2022-002. Conditions and Criteria: • Policies associated with Financial Management and Cash Management as they pertain to the management of federal awards were in need of enhancement to meet the administrative requirements of Uniform Guidance at the start of the year under audit. Policies were put into place in February and September 2023. • Once these policies were established, they were not being followed, resulting in the delayed preparation of Schedule of Expenditures of Federal Awards. Certain balances were not reconciled to supporting documentation. Cause/Context: • Catholic Charities West Michigan had general policies and procedures that are applicable to federal awards. However, there are additional unique policy requirements related to Financial Management and Cash Management that are key to the Organization’s federal programs that were missing from the policies in place at the start of the year under audit. • Polices were adopted in February and September 2023. However, as of September 30, 2023, these policies were not being followed. Catholic Charities relies on information provided by passthrough agencies in the preparation of the SEFA. Necessary information was not received from one such agency until February 2024. Catholic Charities did not reconcile this information to documentation and the general ledger. Unreconciled differences were identified during the audit and required an adjustment to the federal expenditures reported on the SEFA. Recommendations: We recommend that financial management policies be followed to ensure that the SEFA is prepared timely and reconciled against the general ledger and other supporting documentation to ensure accuracy. Views of Responsible Officials and Planned Corrective Actions: Modifications of the Administrative Financial Management and Cash Management policies will be made to further address concerns identified in the Single Audit. In addition, the reconciliation process will be reviewed and improved to assure timely preparation of the SEFA. CCWM will reconcile federal programs to the passthrough agencies 9 months into the fiscal year at a minimum as part of the preparation of the SEFA report.

Corporation for National and Community Service Foster Grandparent/Senior Companion Cluster – Assistance Listing #94.011, #94.016 #2023-002 – Significant Deficiency: Grant and Contract Management Compliance Finding: Adherence to Administrative Policies Requirements of Uniform Guidance This is a partial repeat of prior year finding #2022-002. Conditions and Criteria: • Policies associated with Financial Management and Cash Management as they pertain to the management of federal awards were in need of enhancement to meet the administrative requirements of Uniform Guidance at the start of the year under audit. Policies were put into place in February and September 2023. • Once these policies were established, they were not being followed, resulting in the delayed preparation of Schedule of Expenditures of Federal Awards. Certain balances were not reconciled to supporting documentation. Cause/Context: • Catholic Charities West Michigan had general policies and procedures that are applicable to federal awards. However, there are additional unique policy requirements related to Financial Management and Cash Management that are key to the Organization’s federal programs that were missing from the policies in place at the start of the year under audit. • Polices were adopted in February and September 2023. However, as of September 30, 2023, these policies were not being followed. Catholic Charities relies on information provided by passthrough agencies in the preparation of the SEFA. Necessary information was not received from one such agency until February 2024. Catholic Charities did not reconcile this information to documentation and the general ledger. Unreconciled differences were identified during the audit and required an adjustment to the federal expenditures reported on the SEFA. Recommendations: We recommend that financial management policies be followed to ensure that the SEFA is prepared timely and reconciled against the general ledger and other supporting documentation to ensure accuracy. Views of Responsible Officials and Planned Corrective Actions: Modifications of the Administrative Financial Management and Cash Management policies will be made to further address concerns identified in the Single Audit. In addition, the reconciliation process will be reviewed and improved to assure timely preparation of the SEFA. CCWM will reconcile federal programs to the passthrough agencies 9 months into the fiscal year at a minimum as part of the preparation of the SEFA report.

Corporation for National and Community Service Foster Grandparent/Senior Companion Cluster – Assistance Listing #94.011, #94.016 #2023-002 – Significant Deficiency: Grant and Contract Management Compliance Finding: Adherence to Administrative Policies Requirements of Uniform Guidance This is a partial repeat of prior year finding #2022-002. Conditions and Criteria: • Policies associated with Financial Management and Cash Management as they pertain to the management of federal awards were in need of enhancement to meet the administrative requirements of Uniform Guidance at the start of the year under audit. Policies were put into place in February and September 2023. • Once these policies were established, they were not being followed, resulting in the delayed preparation of Schedule of Expenditures of Federal Awards. Certain balances were not reconciled to supporting documentation. Cause/Context: • Catholic Charities West Michigan had general policies and procedures that are applicable to federal awards. However, there are additional unique policy requirements related to Financial Management and Cash Management that are key to the Organization’s federal programs that were missing from the policies in place at the start of the year under audit. • Polices were adopted in February and September 2023. However, as of September 30, 2023, these policies were not being followed. Catholic Charities relies on information provided by passthrough agencies in the preparation of the SEFA. Necessary information was not received from one such agency until February 2024. Catholic Charities did not reconcile this information to documentation and the general ledger. Unreconciled differences were identified during the audit and required an adjustment to the federal expenditures reported on the SEFA. Recommendations: We recommend that financial management policies be followed to ensure that the SEFA is prepared timely and reconciled against the general ledger and other supporting documentation to ensure accuracy. Views of Responsible Officials and Planned Corrective Actions: Modifications of the Administrative Financial Management and Cash Management policies will be made to further address concerns identified in the Single Audit. In addition, the reconciliation process will be reviewed and improved to assure timely preparation of the SEFA. CCWM will reconcile federal programs to the passthrough agencies 9 months into the fiscal year at a minimum as part of the preparation of the SEFA report.

Corporation for National and Community Service Foster Grandparent/Senior Companion Cluster – Assistance Listing #94.011, #94.016 #2023-003 – Material Weakness in Internal Controls over Compliance: Special Tests and Provisions Compliance Finding: Special Tests and Provisions This is a repeat of prior year finding #2022-005. Criteria: • Foster Grandparent and Senior Companion eligibility require background checks for Foster Grandparent and Senior Companion volunteers and Catholic Charities West Michigan staff involved in the program to be completed prior to the date they begin to work/serve. • All background checks are required to be adjudicated by Catholic Charities West Michigan to ensure the volunteer is eligible for service prior to the date they begin to work/serve. This adjudication should be documented within the AmeriCorps-approved software when used or Catholic Charities may manually document the eligibility decision and the date of this adjudication. Conditions/Context: • In the spring of 2023, the Corporation for National and Community Service (CNCS) completed an audit of the National Service Criminal History Checks (NSCHC) requirement compliance of a sample of volunteers who received a stipend during the period of 4/1/2022 through 12/31/2022 as well as all staff working in the programs. As a result of this audit, 86 noncompliance findings were noted. This audit was closed as of March 18, 2024, with the corrective action plan and findings resolved. • We tested a sample of 24 volunteers and 2 staff members who worked or received stipends during the fiscal year ending September 30, 2023, many of which were also subject to the CNCS audit previously performed. • For 13 of the 24 volunteers and both staff members we tested, at least one of the required background check components were not completed correctly prior to their start date. These missing background checks were completed before September 30, 2023 for 12 of the volunteers. The checks for the remaining volunteer and two staff members were completed subsequent to year-end, but prior to the audit beginning in April 2024. • For 23 of the 24 volunteers and both staff members we tested, adjudication of the check by Catholic Charities West Michigan staff was not completed or properly documented for at least one of the required background check components. All checks were adjudicated and properly documented subsequent to year-end, but prior to the audit beginning in April 2024. Cause: The Organization had not adequately trained the responsible staff of all program requirements for background checks. Additionally, policies and procedures in place did not adequately reflect all such requirements. Questioned Costs: The Organization repaid CNCS approximately $54,000 related to the CNCS audit findings for the period April 1, 2022 to December 31, 2022, referred to above. A portion of this obligation may be associated with the year ended September 30, 2023, although that amount is not able to be determined. Any additional questioned costs for the period January 1, 2023 through September 30, 2023 have not been determined. Identification of How Questioned Costs Were Computed: As a result of the CNCS audit findings noted above, cost-based disallowance was identified by the CNCS. The obligation for the period ended December 31, 2022 was based on the amount repaid to CNCS. Catholic Charities West Michigan recorded this obligation in the financial statements as of September 30, 2023 and repaid the amount subsequent to year end. Recommendations: • We recommend that the Organization undergo (and provide) further training to promote the awareness of requirements for all staff performing background checks. • We recommend that the Organization enhance its policies and procedures to promote future compliance with all program requirements. Views of Responsible Officials and Planned Corrective Actions: The Senior Programs have undergone significant improvements in the last 6 months following an audit by the federal funder which resulted in a corrective action plan (CAP) and a repayment of $54,228. Plans were implemented during the spring of 2024 in response to the CAP which resulted in an overhaul of the processes in place to properly develop the volunteer checklists and assure all records for staff and volunteers are now compliant. Our Quality and Compliance and Finance team worked closely with the new Program Manager to assure that we will be fully compliant and remain so.

Corporation for National and Community Service Foster Grandparent/Senior Companion Cluster – Assistance Listing #94.011, #94.016 #2023-003 – Material Weakness in Internal Controls over Compliance: Special Tests and Provisions Compliance Finding: Special Tests and Provisions This is a repeat of prior year finding #2022-005. Criteria: • Foster Grandparent and Senior Companion eligibility require background checks for Foster Grandparent and Senior Companion volunteers and Catholic Charities West Michigan staff involved in the program to be completed prior to the date they begin to work/serve. • All background checks are required to be adjudicated by Catholic Charities West Michigan to ensure the volunteer is eligible for service prior to the date they begin to work/serve. This adjudication should be documented within the AmeriCorps-approved software when used or Catholic Charities may manually document the eligibility decision and the date of this adjudication. Conditions/Context: • In the spring of 2023, the Corporation for National and Community Service (CNCS) completed an audit of the National Service Criminal History Checks (NSCHC) requirement compliance of a sample of volunteers who received a stipend during the period of 4/1/2022 through 12/31/2022 as well as all staff working in the programs. As a result of this audit, 86 noncompliance findings were noted. This audit was closed as of March 18, 2024, with the corrective action plan and findings resolved. • We tested a sample of 24 volunteers and 2 staff members who worked or received stipends during the fiscal year ending September 30, 2023, many of which were also subject to the CNCS audit previously performed. • For 13 of the 24 volunteers and both staff members we tested, at least one of the required background check components were not completed correctly prior to their start date. These missing background checks were completed before September 30, 2023 for 12 of the volunteers. The checks for the remaining volunteer and two staff members were completed subsequent to year-end, but prior to the audit beginning in April 2024. • For 23 of the 24 volunteers and both staff members we tested, adjudication of the check by Catholic Charities West Michigan staff was not completed or properly documented for at least one of the required background check components. All checks were adjudicated and properly documented subsequent to year-end, but prior to the audit beginning in April 2024. Cause: The Organization had not adequately trained the responsible staff of all program requirements for background checks. Additionally, policies and procedures in place did not adequately reflect all such requirements. Questioned Costs: The Organization repaid CNCS approximately $54,000 related to the CNCS audit findings for the period April 1, 2022 to December 31, 2022, referred to above. A portion of this obligation may be associated with the year ended September 30, 2023, although that amount is not able to be determined. Any additional questioned costs for the period January 1, 2023 through September 30, 2023 have not been determined. Identification of How Questioned Costs Were Computed: As a result of the CNCS audit findings noted above, cost-based disallowance was identified by the CNCS. The obligation for the period ended December 31, 2022 was based on the amount repaid to CNCS. Catholic Charities West Michigan recorded this obligation in the financial statements as of September 30, 2023 and repaid the amount subsequent to year end. Recommendations: • We recommend that the Organization undergo (and provide) further training to promote the awareness of requirements for all staff performing background checks. • We recommend that the Organization enhance its policies and procedures to promote future compliance with all program requirements. Views of Responsible Officials and Planned Corrective Actions: The Senior Programs have undergone significant improvements in the last 6 months following an audit by the federal funder which resulted in a corrective action plan (CAP) and a repayment of $54,228. Plans were implemented during the spring of 2024 in response to the CAP which resulted in an overhaul of the processes in place to properly develop the volunteer checklists and assure all records for staff and volunteers are now compliant. Our Quality and Compliance and Finance team worked closely with the new Program Manager to assure that we will be fully compliant and remain so.

Corporation for National and Community Service Foster Grandparent/Senior Companion Cluster – Assistance Listing #94.011, #94.016 #2023-003 – Material Weakness in Internal Controls over Compliance: Special Tests and Provisions Compliance Finding: Special Tests and Provisions This is a repeat of prior year finding #2022-005. Criteria: • Foster Grandparent and Senior Companion eligibility require background checks for Foster Grandparent and Senior Companion volunteers and Catholic Charities West Michigan staff involved in the program to be completed prior to the date they begin to work/serve. • All background checks are required to be adjudicated by Catholic Charities West Michigan to ensure the volunteer is eligible for service prior to the date they begin to work/serve. This adjudication should be documented within the AmeriCorps-approved software when used or Catholic Charities may manually document the eligibility decision and the date of this adjudication. Conditions/Context: • In the spring of 2023, the Corporation for National and Community Service (CNCS) completed an audit of the National Service Criminal History Checks (NSCHC) requirement compliance of a sample of volunteers who received a stipend during the period of 4/1/2022 through 12/31/2022 as well as all staff working in the programs. As a result of this audit, 86 noncompliance findings were noted. This audit was closed as of March 18, 2024, with the corrective action plan and findings resolved. • We tested a sample of 24 volunteers and 2 staff members who worked or received stipends during the fiscal year ending September 30, 2023, many of which were also subject to the CNCS audit previously performed. • For 13 of the 24 volunteers and both staff members we tested, at least one of the required background check components were not completed correctly prior to their start date. These missing background checks were completed before September 30, 2023 for 12 of the volunteers. The checks for the remaining volunteer and two staff members were completed subsequent to year-end, but prior to the audit beginning in April 2024. • For 23 of the 24 volunteers and both staff members we tested, adjudication of the check by Catholic Charities West Michigan staff was not completed or properly documented for at least one of the required background check components. All checks were adjudicated and properly documented subsequent to year-end, but prior to the audit beginning in April 2024. Cause: The Organization had not adequately trained the responsible staff of all program requirements for background checks. Additionally, policies and procedures in place did not adequately reflect all such requirements. Questioned Costs: The Organization repaid CNCS approximately $54,000 related to the CNCS audit findings for the period April 1, 2022 to December 31, 2022, referred to above. A portion of this obligation may be associated with the year ended September 30, 2023, although that amount is not able to be determined. Any additional questioned costs for the period January 1, 2023 through September 30, 2023 have not been determined. Identification of How Questioned Costs Were Computed: As a result of the CNCS audit findings noted above, cost-based disallowance was identified by the CNCS. The obligation for the period ended December 31, 2022 was based on the amount repaid to CNCS. Catholic Charities West Michigan recorded this obligation in the financial statements as of September 30, 2023 and repaid the amount subsequent to year end. Recommendations: • We recommend that the Organization undergo (and provide) further training to promote the awareness of requirements for all staff performing background checks. • We recommend that the Organization enhance its policies and procedures to promote future compliance with all program requirements. Views of Responsible Officials and Planned Corrective Actions: The Senior Programs have undergone significant improvements in the last 6 months following an audit by the federal funder which resulted in a corrective action plan (CAP) and a repayment of $54,228. Plans were implemented during the spring of 2024 in response to the CAP which resulted in an overhaul of the processes in place to properly develop the volunteer checklists and assure all records for staff and volunteers are now compliant. Our Quality and Compliance and Finance team worked closely with the new Program Manager to assure that we will be fully compliant and remain so.

Corporation for National and Community Service Foster Grandparent/Senior Companion Cluster – Assistance Listing #94.011, #94.016 #2023-004 – Significant Deficiency: Grant and Contract Management; Reporting This is a partial repeat of prior year finding #2022-003. Conditions and Criteria: Catholic Charities West Michigan has in place policies that require a separate review after the preparation of reports, however: • Two semi-annual reports for the Foster Grandparent/Senior Companion Cluster were prepared and submitted without documentation of a separate review. • Two quarterly Payment Management Services reports for Foster Grandparents/Senior Companion Cluster were prepared and submitted without documentation of a separate review. Cause/Context: The quarterly and semi-annual reports for the Foster Grandparent/Senior Companion program were prepared by the program director. An Administrative Assistant separately submits the reports but does not review them. The Director of Finance role is responsible for reviewing the reports prior to the submission, but there was no documentation to support this review being completed for four of the six reports tested. Recommendations: An individual independent of the preparation of financial and program reports should review and approve those reports, and documentation of this review should be retained. Views of Responsible Officials and Planned Corrective Actions: Timely reporting as well as documented approvals are very important to Catholic Charities West Michigan and we agree that we must demonstrate that proper reviews or reports have occurred. We have implemented a process including monthly meetings with the Program Manager and the Finance Accountant to review activity and close the month. All reporting is now filed timely with proper documented review.

Corporation for National and Community Service Foster Grandparent/Senior Companion Cluster – Assistance Listing #94.011, #94.016 #2023-004 – Significant Deficiency: Grant and Contract Management; Reporting This is a partial repeat of prior year finding #2022-003. Conditions and Criteria: Catholic Charities West Michigan has in place policies that require a separate review after the preparation of reports, however: • Two semi-annual reports for the Foster Grandparent/Senior Companion Cluster were prepared and submitted without documentation of a separate review. • Two quarterly Payment Management Services reports for Foster Grandparents/Senior Companion Cluster were prepared and submitted without documentation of a separate review. Cause/Context: The quarterly and semi-annual reports for the Foster Grandparent/Senior Companion program were prepared by the program director. An Administrative Assistant separately submits the reports but does not review them. The Director of Finance role is responsible for reviewing the reports prior to the submission, but there was no documentation to support this review being completed for four of the six reports tested. Recommendations: An individual independent of the preparation of financial and program reports should review and approve those reports, and documentation of this review should be retained. Views of Responsible Officials and Planned Corrective Actions: Timely reporting as well as documented approvals are very important to Catholic Charities West Michigan and we agree that we must demonstrate that proper reviews or reports have occurred. We have implemented a process including monthly meetings with the Program Manager and the Finance Accountant to review activity and close the month. All reporting is now filed timely with proper documented review.

Corporation for National and Community Service Foster Grandparent/Senior Companion Cluster – Assistance Listing #94.011, #94.016 #2023-004 – Significant Deficiency: Grant and Contract Management; Reporting This is a partial repeat of prior year finding #2022-003. Conditions and Criteria: Catholic Charities West Michigan has in place policies that require a separate review after the preparation of reports, however: • Two semi-annual reports for the Foster Grandparent/Senior Companion Cluster were prepared and submitted without documentation of a separate review. • Two quarterly Payment Management Services reports for Foster Grandparents/Senior Companion Cluster were prepared and submitted without documentation of a separate review. Cause/Context: The quarterly and semi-annual reports for the Foster Grandparent/Senior Companion program were prepared by the program director. An Administrative Assistant separately submits the reports but does not review them. The Director of Finance role is responsible for reviewing the reports prior to the submission, but there was no documentation to support this review being completed for four of the six reports tested. Recommendations: An individual independent of the preparation of financial and program reports should review and approve those reports, and documentation of this review should be retained. Views of Responsible Officials and Planned Corrective Actions: Timely reporting as well as documented approvals are very important to Catholic Charities West Michigan and we agree that we must demonstrate that proper reviews or reports have occurred. We have implemented a process including monthly meetings with the Program Manager and the Finance Accountant to review activity and close the month. All reporting is now filed timely with proper documented review.