Finding 2024-200: The Commission did not comply with federal Matching, Level of Effort, and Earmarking grant requirements for the Rehabilitation Services-Vocational Rehabilitation Grants to States program. Related to Prior Finding: N/A Agency’s view: Agree Corrective Action Plan: The Cost Allocation...
Finding 2024-200: The Commission did not comply with federal Matching, Level of Effort, and Earmarking grant requirements for the Rehabilitation Services-Vocational Rehabilitation Grants to States program. Related to Prior Finding: N/A Agency’s view: Agree Corrective Action Plan: The Cost Allocation Plan (CAP) needs to be updated, resubmitted, and approved through RSA. We also agree that ICBVI needs to provide clear documentation to support the numbers in our CAP. ICBVI has reviewed its documentation and believes we met the federal Matching, Level of Effort, and Earmarking requirements for the Rehabilitation Services-Vocational Rehabilitation Grants to States program. Matching and Maintenance of Effort (MOE): ICBVI uses a monthly/semi-monthly CAP process to determine the level of federal draw for reimbursement. These draw amounts are based on the necessary monthly amounts (1/12) of the required 21.3% of the total grant award + match, OR the MOE amount from 2 years prior (whichever is greater). This CAP process keeps track of the Grant Total, Draws to Date, To be Drawn, State Portion, and Match/MOE amount YTD. It is through this systematic monthly process that we calculate what the allowable direct and indirect State expenditures are and will make draws that allow us to reach the Match/MOE targets. Based on our documentation, we have made our Match and MOE amounts for the years in question. Documentation supporting the reported amounts can be found in the CAPs from any FFY. Earmarking: Allowable expenditures for Pre-Employment Transition Services (Pre-ETS) are also tracked in the CAP. Documentation to support amounts reported can be found in the CAPs from any FFY. CAP Update and Approval: We have a meeting scheduled with the Director of the Indirect Cost Division at the US Dept of Education on 12/10/25. The CAP will be revised to reflect the current chart of accounts and reporting parameters of the Luma system. We will be submitting an updated CAP for review and approval. Documentation: All expenditure data and supporting documentation will be sourced directly from Luma and retained for verification. Internal Controls and Training: ICBVI will continue to improve its internal control procedures to include periodic training and cross-training on compliance requirements, ensuring reviews are substantive and error detection is robust. ICBVI will also seek further guidance from the federal grantor and will document all correspondence and remedial efforts. Anticipated Corrective Action Date: 1-15-26 Responsible for Corrective Action: Corey Bresina, Administrative Services Manager, 208-639-8369, cbresina@icbvi.idaho.gov