Audit 403786

2025-002 – Significant Deficiency – Internal Control over Compliance Program: WIOA Cluster (ALN 17.258; ALN 17.259; ALN 17.278) Criteria: Per 2 CFR 200.303, recipients must establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control- Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: During our testing of compliance with requirements applicable to major federal programs, we noted that the entity did not have formal, consistently applied review and approval controls over key compliance areas. Specifically, evidence of supervisory review and approval was not consistently documented for compliance-related transactions. As a result, review procedures appear to be informal, inconsistent, or reliant on individual practices rather than standardized, documented controls. Cause: This condition appears to be the result of a lack of internal controls designed to ensure compliance with Uniform Guidance. Effect: The absence of formal and consistently documented review and approval procedures increases the risk that noncompliance with federal program requirements could occur and not be prevented or detected on a timely basis. Recommendation: We recommend that the Organization formalize policies and procedures by developing and documenting standardized procedures for review and approval of key compliance activities across all major federal programs, implement documented review controls, and enhance monitoring and oversight. View of Responsible Officials: Management agrees with the recommendation and has developed a much more stringent review and approval process.

2025-003 – Significant Deficiency – Eligibility Program: WIOA Cluster (ALN 17.258; ALN 17.259; ALN 17.278) Criteria: The Uniform Guidance requires a non-federal entity that has expended federal awards for Eligibility for Individuals to ensure participants between the ages of 18 and 26 are registered with the Military Selective Service. Condition: During our testing of participant eligibility for the WIOA Cluster, we identified an instance in which a male participant subject to Selective Service requirements was not registered with the Selective Service System, and no evidence of registration verification or documented exemption was maintained in the participant file. Cause: This deficiency appears to be the result of a data entry mistake within the Organization. Effect: The failure to verify and document Selective Service registration increases the risk that ineligible individuals may be enrolled and receive program benefits. Recommendation: We recommend that the Organization strengthen internal controls over eligibility determinations for WIOA programs by implementing formal eligibility procedures by developing and documenting standardized procedures requiring verification of Selective Service registration (or valid exemption) prior to enrollment, using eligibility checklists, and enhancing review and approval controls. View of Responsible Officials: Management agrees with the recommendation and has developed a guideline in which a participant is not to be co-enrolled in WIOA Youth while being enrolled in another youth program.