Grant No(s): 1505-0266 Criteria: Louisiana Revised Statute §24:523 requires public agencies to report any misappropriation, theft, or loss of public funds or assets to the Louisiana Legislative Auditor’s Office (LLA) immediately upon discovery. Additionally, 2 CFR §200.113 mandates that non-federal entities disclose in writing any violations of federal criminal law involving fraud, bribery, or gratuity violations potentially affecting the federal award. 2 CFR §200.331 and Treasury Emergency Rental Assistance (ERA) Program Guidance require that entities establish and maintain effective controls to ensure that assistance is provided only to eligible recipients. This includes verifying income, housing status, and risk of homelessness or housing instability. Condition: ERA personnel at Jefferson Parish identified instances of what appears to be externally caused fraudulent activity that occurred in 2022 that were found and reported to the Parish’s internal auditor, local law enforcement (Jefferson Parish Sheriff’s Office) and the Federal Bureau of Investigation (FBI). The misappropriation of public funds was not reported to the LLA and the Jefferson Parish District Attorney’s Office in a timely manner. In addition, the Parish was not insured over these types of misappropriations. See Attachment A for additional information required by the LLA regarding each instance of fraud. Universe/Population: The universe/population for Eligibility testing is 4,214 Participants receiving a total of $12,070,966 in assistance through rental and utility assistance in 2023. We selected 60 participants for testing of eligibility compliance requirements applicable to the program, noting no exceptions in our 2023 testing. Cause: In 2022, Jefferson Parish did not have adequate policies and procedures over the application and monitoring of eligibility requirements on all potential awardees of rental and utility assistance. The Parish’s internal controls did identify that the fraud occurred. Also, the Parish did not have adequate procedures in place to ensure that instances of fraud were reported to the LLA and the District Attorney’s Office timely. Effect: The failure to report the fraudulent activity and ensure proper eligibility review resulted in noncompliance with both state and federal requirements, delayed corrective actions, and increased the risk of continued misuse of federal funds. Questioned Costs: The questioned costs of $424,515 represent payments made in 2022 to ineligible recipients due to fraudulent activity. We did not have any exceptions in our eligibility testing for 2023. Identification of a repeat finding: This is not a repeat finding. Recommendation: Jefferson Parish should continue to monitor eligibility of award requirements and application of those requirements. View of Responsible Officials: With the support of a new leadership team, Jefferson Parish is committed to strengthening grants and financial management and enhancing the reliability of grants reporting. The Parish has engaged Deloitte & Touche LLP as a consultant to assist in establishing regular review practices, policies, procedures, and internal controls with the goal of improving audit readiness, refine documentation procedures, and strengthen internal controls to support accurate and complete financial data going forward. As part of this effort Jefferson Parish and Deloitte are working across Departments to re-define organizational structure, to establish governance and oversight between finance, accounting, and programmatic departments. Jefferson Parish and Deloitte are also working to implement data quality improvement measures, including the establishment of quarterly grants reconciliation and review processes. Jefferson Parish has also engaged Infor in the implementation of new financial and reporting technology to support improved financial processing and controls.
Finding Number: 2023-049 Prior Year Finding Number: N/A Compliance Requirement: Allowable Costs/Cost Principles – Payroll Activities Program: U.S. Department of Education Government Department/Agency: Department of Education (VIDE) Special Education Cluster ALN: 84.027A, 84.027X Award #: Various Award Period: Various Criteria – The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires the non-federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonable ensure compliance with Federal statutes, regulations, and other terms and conditions of the Federal Award. Management is responsible for establishing and maintaining a system of internal control that should include controls over its activities allowed or unallowed, allowable cost/cost principal process. CFR 200.403(g) states that for costs to be allowed under federal awards, they must be adequately documented. Additionally, salaries and wages charged to Federal awards are subject to the standards of documentation as described by 2 CFR Section 200.430(i) and must be based on records that accurately reflect the work performed. These records must: - Be incorporated into the organization’s official records. - Reasonably reflect the total activity for which the employee is compensated across all grant-related and non-grant related activities (100%); and - Support the distribution of employee salary across multiple activities or cost objectives. Furthermore, CFR 200.113 requires that an applicant, recipient, or subrecipient of a Federal award must promptly disclose, in writing, whenever it has credible evidence of the commission of a violation of Federal criminal law involving fraud, conflict of interest, bribery, or gratuity violations found in Title 18 of the United States Code, or a violation of the civil False Claims Act, in connection with the Federal award (including any activities or subawards thereunder). The disclosure must be made to the Federal agency, the agency’s Office of Inspector General, and the pass-through entity (if applicable). Condition – During our testing of allowable costs for payroll expenditures incurred throughout the year, we sampled and selected 40 of 2,573 payroll disbursements and noted 2 instances where the employee’s pay rate in the approved Notice of Personnel Action provided did not agree with the pay rate in the payroll register. Additionally, a fraud incident related to falsified payroll timesheet entries charged to this program was discovered and investigated during the year. It was discovered that bus driver timesheets were being approved with falsified time entries. An analysis conducted by VIDE determined the amount of theft to be $5,221. This incident was not disclosed or reported to the Federal awarding agency as required. As a result, it does not appear that the controls in place are operating at a level of precision to ensure compliance with the compliance requirement. Questioned Costs – $5,221. Context – This is a condition identified per review of VIDE’s compliance with the specified requirements using a statistically valid sample. The total payroll expenditures charged to the program in fiscal year 2023 was $5,744,863. The amount sampled is $102,945. Effect – An ineffective control system related to review of transactions to ensure that only allowable costs are allocated to federal programs can lead to noncompliance with federal statutes, regulations, and the provisions of grant agreements that could ultimately lead to disallowed costs for the major programs. Cause – VIDE does not appear to have adequate policies and procedures to ensure compliance with applicable cost principles and ensure that an appropriate level of review was completed prior to charging costs to a federal program. Recommendation – We recommend that VIDE reevaluate and improve internal controls to ensure adherence to federal regulations related to the fiscal administrative requirement for expending and accounting for payroll transactions. Additionally, fraud incident should be reported to the appropriate federal awarding agency in accordance with mandatory disclosure requirements. Views of Responsible Officials – The Government concurs with the auditor’s findings and recommendations. VIDE is taking immediate action to align payroll controls with our established fiscal improvement plan and to institutionalize a mandatory federal reporting protocol for fraud. The planned corrective actions are presented in the Government’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
2022-003 Financial Impropriety Information on Federal Program(s) U.S. Department of State Name of Program: Program to End Modern Slavery Assistance Listing Number: 19.019 Grant Award Number: S-SJTIP-17-CA-1018/S-SJTIP-18-CA-1014/ S-SJTIP-18-CA-3035 Grant Award Period: October 1, 2017 through June 30, 2022, October 1, 2018 through December 31, 2022, October 1, 2021 to September 30, 2024 Criteria - §200.516(a) Audit findings(6) requires known or suspected fraud be reported by the auditors. Condition - During the year ended December 31, 2022, the Fund received an e-mail from one of its subrecipients stating that they received a whistleblower complaint about an alleged financial impropriety that occurred within their country office. The subrecipient conducted an internal audit, which confirmed in December 2022 some of the allegations including receipt of per diem for trips not attended and use of an office vehicle and fuel for personal use. In February 2023, the subrecipient also contracted with a consultant to perform a forensic audit of the suspected inappropriate procurement and corruption activities at their Uganda Country office for the period from January 1, 2019 through December 31, 2022. The forensic report highlighted certain amounts that were misappropriated from the PEMS 2 grant for the year ended December 31, 2022. The Fund did not suffer any financial loss, since the Fund subtracted the misappropriated amount from the final disbursement to the subrecipient. In addition, in accordance with 2CFR 200.113, the Fund disclosed the financial impropriety incident to the Office of the Inspector General (OIG) for the Department of State and the cognizant Grants Officer was aware of substantiated misappropriation that impacted funding sub-awarded by the Fund to the subrecipient under the PEMS 2 grant. Cause - Individuals at the subrecipient organization committed inappropriate procurement and corruption activities. Effect - These conditions could result in unallowable expenses being charged to U.S. Government awards if the whistle blower complaint and subsequent investigation did not identify the financial impropriety. Questioned Costs - There are no questioned costs since the Fund subtracted the misappropriated amount from the final disbursement to the subrecipient. Context - This matter was identified through a whistleblower complaint at the subrecipient organization during the year ended December 31, 2022. Repeat Finding - This is not a repeat finding. Recommendation - The Fund should continue to monitor and assess the control environment in which its subrecipients operate. The Fund should also ensure a detailed risk assessment of all subrecipients is regularly performed and reviewed. It should also assess whether future funding be provided to the subrecipient. View of Responsible Officials - Management agrees with the Federal award finding identified in the audit. The Fund’s response to this finding is described in the accompanying management’s corrective action plan.
2022-003 Financial Impropriety Information on Federal Program(s) U.S. Department of State Name of Program: Program to End Modern Slavery Assistance Listing Number: 19.019 Grant Award Number: S-SJTIP-17-CA-1018/S-SJTIP-18-CA-1014/ S-SJTIP-18-CA-3035 Grant Award Period: October 1, 2017 through June 30, 2022, October 1, 2018 through December 31, 2022, October 1, 2021 to September 30, 2024 Criteria - §200.516(a) Audit findings(6) requires known or suspected fraud be reported by the auditors. Condition - During the year ended December 31, 2022, the Fund received an e-mail from one of its subrecipients stating that they received a whistleblower complaint about an alleged financial impropriety that occurred within their country office. The subrecipient conducted an internal audit, which confirmed in December 2022 some of the allegations including receipt of per diem for trips not attended and use of an office vehicle and fuel for personal use. In February 2023, the subrecipient also contracted with a consultant to perform a forensic audit of the suspected inappropriate procurement and corruption activities at their Uganda Country office for the period from January 1, 2019 through December 31, 2022. The forensic report highlighted certain amounts that were misappropriated from the PEMS 2 grant for the year ended December 31, 2022. The Fund did not suffer any financial loss, since the Fund subtracted the misappropriated amount from the final disbursement to the subrecipient. In addition, in accordance with 2CFR 200.113, the Fund disclosed the financial impropriety incident to the Office of the Inspector General (OIG) for the Department of State and the cognizant Grants Officer was aware of substantiated misappropriation that impacted funding sub-awarded by the Fund to the subrecipient under the PEMS 2 grant. Cause - Individuals at the subrecipient organization committed inappropriate procurement and corruption activities. Effect - These conditions could result in unallowable expenses being charged to U.S. Government awards if the whistle blower complaint and subsequent investigation did not identify the financial impropriety. Questioned Costs - There are no questioned costs since the Fund subtracted the misappropriated amount from the final disbursement to the subrecipient. Context - This matter was identified through a whistleblower complaint at the subrecipient organization during the year ended December 31, 2022. Repeat Finding - This is not a repeat finding. Recommendation - The Fund should continue to monitor and assess the control environment in which its subrecipients operate. The Fund should also ensure a detailed risk assessment of all subrecipients is regularly performed and reviewed. It should also assess whether future funding be provided to the subrecipient. View of Responsible Officials - Management agrees with the Federal award finding identified in the audit. The Fund’s response to this finding is described in the accompanying management’s corrective action plan.
2022-003 Financial Impropriety Information on Federal Program(s) U.S. Department of State Name of Program: Program to End Modern Slavery Assistance Listing Number: 19.019 Grant Award Number: S-SJTIP-17-CA-1018/S-SJTIP-18-CA-1014/ S-SJTIP-18-CA-3035 Grant Award Period: October 1, 2017 through June 30, 2022, October 1, 2018 through December 31, 2022, October 1, 2021 to September 30, 2024 Criteria - §200.516(a) Audit findings(6) requires known or suspected fraud be reported by the auditors. Condition - During the year ended December 31, 2022, the Fund received an e-mail from one of its subrecipients stating that they received a whistleblower complaint about an alleged financial impropriety that occurred within their country office. The subrecipient conducted an internal audit, which confirmed in December 2022 some of the allegations including receipt of per diem for trips not attended and use of an office vehicle and fuel for personal use. In February 2023, the subrecipient also contracted with a consultant to perform a forensic audit of the suspected inappropriate procurement and corruption activities at their Uganda Country office for the period from January 1, 2019 through December 31, 2022. The forensic report highlighted certain amounts that were misappropriated from the PEMS 2 grant for the year ended December 31, 2022. The Fund did not suffer any financial loss, since the Fund subtracted the misappropriated amount from the final disbursement to the subrecipient. In addition, in accordance with 2CFR 200.113, the Fund disclosed the financial impropriety incident to the Office of the Inspector General (OIG) for the Department of State and the cognizant Grants Officer was aware of substantiated misappropriation that impacted funding sub-awarded by the Fund to the subrecipient under the PEMS 2 grant. Cause - Individuals at the subrecipient organization committed inappropriate procurement and corruption activities. Effect - These conditions could result in unallowable expenses being charged to U.S. Government awards if the whistle blower complaint and subsequent investigation did not identify the financial impropriety. Questioned Costs - There are no questioned costs since the Fund subtracted the misappropriated amount from the final disbursement to the subrecipient. Context - This matter was identified through a whistleblower complaint at the subrecipient organization during the year ended December 31, 2022. Repeat Finding - This is not a repeat finding. Recommendation - The Fund should continue to monitor and assess the control environment in which its subrecipients operate. The Fund should also ensure a detailed risk assessment of all subrecipients is regularly performed and reviewed. It should also assess whether future funding be provided to the subrecipient. View of Responsible Officials - Management agrees with the Federal award finding identified in the audit. The Fund’s response to this finding is described in the accompanying management’s corrective action plan.
2022-003 Financial Impropriety Information on Federal Program(s) U.S. Department of State Name of Program: Program to End Modern Slavery Assistance Listing Number: 19.019 Grant Award Number: S-SJTIP-17-CA-1018/S-SJTIP-18-CA-1014/ S-SJTIP-18-CA-3035 Grant Award Period: October 1, 2017 through June 30, 2022, October 1, 2018 through December 31, 2022, October 1, 2021 to September 30, 2024 Criteria - §200.516(a) Audit findings(6) requires known or suspected fraud be reported by the auditors. Condition - During the year ended December 31, 2022, the Fund received an e-mail from one of its subrecipients stating that they received a whistleblower complaint about an alleged financial impropriety that occurred within their country office. The subrecipient conducted an internal audit, which confirmed in December 2022 some of the allegations including receipt of per diem for trips not attended and use of an office vehicle and fuel for personal use. In February 2023, the subrecipient also contracted with a consultant to perform a forensic audit of the suspected inappropriate procurement and corruption activities at their Uganda Country office for the period from January 1, 2019 through December 31, 2022. The forensic report highlighted certain amounts that were misappropriated from the PEMS 2 grant for the year ended December 31, 2022. The Fund did not suffer any financial loss, since the Fund subtracted the misappropriated amount from the final disbursement to the subrecipient. In addition, in accordance with 2CFR 200.113, the Fund disclosed the financial impropriety incident to the Office of the Inspector General (OIG) for the Department of State and the cognizant Grants Officer was aware of substantiated misappropriation that impacted funding sub-awarded by the Fund to the subrecipient under the PEMS 2 grant. Cause - Individuals at the subrecipient organization committed inappropriate procurement and corruption activities. Effect - These conditions could result in unallowable expenses being charged to U.S. Government awards if the whistle blower complaint and subsequent investigation did not identify the financial impropriety. Questioned Costs - There are no questioned costs since the Fund subtracted the misappropriated amount from the final disbursement to the subrecipient. Context - This matter was identified through a whistleblower complaint at the subrecipient organization during the year ended December 31, 2022. Repeat Finding - This is not a repeat finding. Recommendation - The Fund should continue to monitor and assess the control environment in which its subrecipients operate. The Fund should also ensure a detailed risk assessment of all subrecipients is regularly performed and reviewed. It should also assess whether future funding be provided to the subrecipient. View of Responsible Officials - Management agrees with the Federal award finding identified in the audit. The Fund’s response to this finding is described in the accompanying management’s corrective action plan.
2022-003 Financial Impropriety Information on Federal Program(s) U.S. Department of State Name of Program: Program to End Modern Slavery Assistance Listing Number: 19.019 Grant Award Number: S-SJTIP-17-CA-1018/S-SJTIP-18-CA-1014/ S-SJTIP-18-CA-3035 Grant Award Period: October 1, 2017 through June 30, 2022, October 1, 2018 through December 31, 2022, October 1, 2021 to September 30, 2024 Criteria - §200.516(a) Audit findings(6) requires known or suspected fraud be reported by the auditors. Condition - During the year ended December 31, 2022, the Fund received an e-mail from one of its subrecipients stating that they received a whistleblower complaint about an alleged financial impropriety that occurred within their country office. The subrecipient conducted an internal audit, which confirmed in December 2022 some of the allegations including receipt of per diem for trips not attended and use of an office vehicle and fuel for personal use. In February 2023, the subrecipient also contracted with a consultant to perform a forensic audit of the suspected inappropriate procurement and corruption activities at their Uganda Country office for the period from January 1, 2019 through December 31, 2022. The forensic report highlighted certain amounts that were misappropriated from the PEMS 2 grant for the year ended December 31, 2022. The Fund did not suffer any financial loss, since the Fund subtracted the misappropriated amount from the final disbursement to the subrecipient. In addition, in accordance with 2CFR 200.113, the Fund disclosed the financial impropriety incident to the Office of the Inspector General (OIG) for the Department of State and the cognizant Grants Officer was aware of substantiated misappropriation that impacted funding sub-awarded by the Fund to the subrecipient under the PEMS 2 grant. Cause - Individuals at the subrecipient organization committed inappropriate procurement and corruption activities. Effect - These conditions could result in unallowable expenses being charged to U.S. Government awards if the whistle blower complaint and subsequent investigation did not identify the financial impropriety. Questioned Costs - There are no questioned costs since the Fund subtracted the misappropriated amount from the final disbursement to the subrecipient. Context - This matter was identified through a whistleblower complaint at the subrecipient organization during the year ended December 31, 2022. Repeat Finding - This is not a repeat finding. Recommendation - The Fund should continue to monitor and assess the control environment in which its subrecipients operate. The Fund should also ensure a detailed risk assessment of all subrecipients is regularly performed and reviewed. It should also assess whether future funding be provided to the subrecipient. View of Responsible Officials - Management agrees with the Federal award finding identified in the audit. The Fund’s response to this finding is described in the accompanying management’s corrective action plan.
2022-003 Financial Impropriety Information on Federal Program(s) U.S. Department of State Name of Program: Program to End Modern Slavery Assistance Listing Number: 19.019 Grant Award Number: S-SJTIP-17-CA-1018/S-SJTIP-18-CA-1014/ S-SJTIP-18-CA-3035 Grant Award Period: October 1, 2017 through June 30, 2022, October 1, 2018 through December 31, 2022, October 1, 2021 to September 30, 2024 Criteria - §200.516(a) Audit findings(6) requires known or suspected fraud be reported by the auditors. Condition - During the year ended December 31, 2022, the Fund received an e-mail from one of its subrecipients stating that they received a whistleblower complaint about an alleged financial impropriety that occurred within their country office. The subrecipient conducted an internal audit, which confirmed in December 2022 some of the allegations including receipt of per diem for trips not attended and use of an office vehicle and fuel for personal use. In February 2023, the subrecipient also contracted with a consultant to perform a forensic audit of the suspected inappropriate procurement and corruption activities at their Uganda Country office for the period from January 1, 2019 through December 31, 2022. The forensic report highlighted certain amounts that were misappropriated from the PEMS 2 grant for the year ended December 31, 2022. The Fund did not suffer any financial loss, since the Fund subtracted the misappropriated amount from the final disbursement to the subrecipient. In addition, in accordance with 2CFR 200.113, the Fund disclosed the financial impropriety incident to the Office of the Inspector General (OIG) for the Department of State and the cognizant Grants Officer was aware of substantiated misappropriation that impacted funding sub-awarded by the Fund to the subrecipient under the PEMS 2 grant. Cause - Individuals at the subrecipient organization committed inappropriate procurement and corruption activities. Effect - These conditions could result in unallowable expenses being charged to U.S. Government awards if the whistle blower complaint and subsequent investigation did not identify the financial impropriety. Questioned Costs - There are no questioned costs since the Fund subtracted the misappropriated amount from the final disbursement to the subrecipient. Context - This matter was identified through a whistleblower complaint at the subrecipient organization during the year ended December 31, 2022. Repeat Finding - This is not a repeat finding. Recommendation - The Fund should continue to monitor and assess the control environment in which its subrecipients operate. The Fund should also ensure a detailed risk assessment of all subrecipients is regularly performed and reviewed. It should also assess whether future funding be provided to the subrecipient. View of Responsible Officials - Management agrees with the Federal award finding identified in the audit. The Fund’s response to this finding is described in the accompanying management’s corrective action plan.