Audit 38754

Condition: For 5 out of 11 selections, no support was provided by management to document independent review and verification of income amounts reported by the selected participants. Criteria: In accordance with 2 CFR ?200.303: The Non-Federal entity must: (a) 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. As defined in CSBG Act, at 42 USC 9902(2), Eligible Entities/Other Subrecipients: The official poverty guidelines as revised annually by HHS shall be used to determine eligibility. The poverty guidelines are issued each year in the Federal Register and on the HHS website (http://aspe.hhs.gov/poverty/). The CSBG Act, at 42 USC 9902(2), grants the state the authority to adopt a revised poverty threshold but it may not exceed 125 percent of the HHS-determined poverty guidelines. Audit procedures should be designed to test whether recipients of CSBG services meet the federal poverty guidelines. Cause: UPO did not have proper controls in place to ensure the eligibility requirements of the grant were met. Effect: UPO may not be in compliance with the eligibility requirements of the grant. Questioned Costs: Unknown Recommendation: We recommend that UPO: (1)implement procedures and documents needed for documentation and retention of the review and approval of eligibility criteria; and (2) provide training about procedures related to the documentation of eligibility evaluations. Management?s Response and Corrective Action Plan: See schedule of corrective action plan.

Condition: For 5 out of 11 selections, no support was provided by management to document independent review and verification of income amounts reported by the selected participants. Criteria: In accordance with 2 CFR ?200.303: The Non-Federal entity must: (a) 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. As defined in CSBG Act, at 42 USC 9902(2), Eligible Entities/Other Subrecipients: The official poverty guidelines as revised annually by HHS shall be used to determine eligibility. The poverty guidelines are issued each year in the Federal Register and on the HHS website (http://aspe.hhs.gov/poverty/). The CSBG Act, at 42 USC 9902(2), grants the state the authority to adopt a revised poverty threshold but it may not exceed 125 percent of the HHS-determined poverty guidelines. Audit procedures should be designed to test whether recipients of CSBG services meet the federal poverty guidelines. Cause: UPO did not have proper controls in place to ensure the eligibility requirements of the grant were met. Effect: UPO may not be in compliance with the eligibility requirements of the grant. Questioned Costs: Unknown Recommendation: We recommend that UPO: (1)implement procedures and documents needed for documentation and retention of the review and approval of eligibility criteria; and (2) provide training about procedures related to the documentation of eligibility evaluations. Management?s Response and Corrective Action Plan: See schedule of corrective action plan.