Finding 2022‐002: Eligibility‐(Material weakness in Compliance, Internal Control, and Service Provision within the APA (Assistance Program) Program) Effect: The Organization provided APA/R&P program funding to ineligible refugees and lawful permanent residents due to inadequate verification and inco...
Finding 2022‐002: Eligibility‐(Material weakness in Compliance, Internal Control, and Service Provision within the APA (Assistance Program) Program) Effect: The Organization provided APA/R&P program funding to ineligible refugees and lawful permanent residents due to inadequate verification and inconsistent documentation practices.
Auditor's Recommendation: The Organization should enhance its eligibility verification process to ensure that only enrolled refugees receive funding. Implementing regular training for staff and updating guidelines will help maintain accurate and complete documentation, ensuring compliance and maximizing the effectiveness of the APA/R&P program.
Management Response:
We agree with the recommendation and have also submitted the following response: Ensuring refugee eligibility as a sub-recipient of HIAS involves a comprehensive and diligent process. Staff are trained in verification and eligibility as required by the funder and follow an enhanced eligibility verification process. Screening is completed at the funder level to ensure refugee eligibility and program placement. Once approved, a referral is sent to the designated providers.
Eligibility: The referral number designates the refugee to a program; even though the Funder system lists “None,” the referral is eligible. For the 7 in the sample, each refugee had a designated approved number from HIAS
Verification: In the one exception where a refugee was a lawful permanent resident, JFSSV conducted its due diligence in the verification process and identified the client. This was immediately reported to the funder and rectified as required by the funder.
Documentation: During the fiscal year 21/22, amidst the wrap-up of COVID-19, intake was conducted via telehealth processes, and verbal approval was accepted. Additionally, not all services required forms to be signed, such as “providing information on accessing legal permanent resident status, family reunification procedures, assisting school-age children.” These services were verbally discussed during the intake process and updated in the refugees' case notes in the funder system.
JFSSV has provided Harshwal & Company LLP with detailed explanations on all samples and provided testing requirements with refugee backup during the audit. JFSSV ensures proper documentation and support as required by the grantor's requirements, and JFSSV adheres to all monitoring visits and grant program reviews
To address the specific concerns raised regarding internal controls over compliance and eligibility verification, JFSSV will:
Enhance the Eligibility Verification Process: JFSSV will continue to review and strengthen its eligibility verification process to ensure that only enrolled refugees receive funding.
Regular Staff Training: JFSSV will ensure continuous training to ensure they are well-versed in the updated guidelines and best practices for eligibility verification and documentation required from the Funder.
Improve Documentation Practices: JFSSV will continue best practices in validating eligibility
determinations and related documentation to be complete, accurate, and current. This includes maintaining thorough records in the case note log within the Funder’s system.