Finding 10464 (2023-001)

Significant Deficiency
Requirement
B
Questioned Costs
$1
Year
2023
Accepted
2024-01-29

AI Summary

  • Core Issue: A significant theft of $29,797 occurred within the YWCA's Emergency Rental Assistance Program due to internal collusion among employees.
  • Impacted Requirements: The YWCA failed to comply with Uniform Guidance on allowable costs and lacked adequate internal controls over grant management.
  • Recommended Follow-Up: Conduct a thorough review of internal controls, implement stricter oversight measures, and ensure all employees disclose potential conflicts of interest.

Finding Text

Finding: 2023-001 Significant Deficiency Allowable Costs Criteria: YWCA of Western Massachusetts Inc. is required to be in compliance with the requirements of allowable services and costs under the Uniform Guidance, and to maintain an adequate system of internal control over compliance. Expenses being charged under the grant must meet the specific requirements of the grant and be properly approved by management. Condition: After one year and two grant cycles had been completed, a Program Specialist from the Department of Public Health, Division of Sexual and Domestic Violence Prevention & Services (hereinafter DPH), notified the YWCA of an anomaly in its spending of its Emergency Rental Assistance Program (hereinafter ERAP). As a result, the YWCA commenced a comprehensive review of every funding request related to this grant and found that $29,797.00 had been stolen. This theft occurred when a supervisory employee, who was in charge of the YWCA's ERAP grant, stole funds to benefit herself as well as family members. The intended recipients of ERAP funds were survivors of domestic violence, sexual abuse and human trafficking. The former supervisor promoted her half-sister to the position of ERAP Specialist. In this role, the half-sister should have helped process ERAP requests and acted as the internal check to ensure grant compliance. Both individuals had failed to disclose to anyone in a leadership position at the YWCA that they were half-sisters. A third employee and friend of both sisters, joined the conspiracy. All three stole ERAP funds to benefit themselves and their family members or friends. Due to DPH mandates, all personally identifiable information (such as name, address, social security number) was expunged on every ERAP request to avoid potentially revealing the address of survivors. The YWCA implemented this DPH anonymity mandate, which all three former YWCA employees exploited to commit their crimes.Questioned Costs: $29,797 Effect: Theft and misappropriation.

Corrective Action Plan

Recommendation: YWCA of Western Massachusetts Inc.’s internal control procedures should be revised to ensure an adequate review process is in place to ensure expenditures incurred are allowable under the terms of the grant. Views of Responsible Officials: Despite DPH's mandate to remove all personally identifiable information from these funding requests, the YWCA reconstructed every ERAP request using identifying vendor numbers. The YWCA ultimately identified how and where the three former employees illegally used ERAP funds to pay their bills as well as some of their family members or friends. They stole ERAP funds to illegally pay such bills as electricity, water and sewer bills, rent, car insurance payments, and credit card payments. As soon as the YWCA discovered these thefts, the YWCA immediately notified the appropriate authorities (such as the YWCA's Board of Directors, the police, and DPH) and kept them updated. Additionally, the employment ended for the three YWCA employees responsible for this fraud and theft. As of this audit issue date, all three former employees have been indicted for multiple felonies such as credit card fraud over $1300, larceny over $1200, and false entry in corporate books. Their criminal cases are pending in Hampden County Superior Court. The YWCA maintains an expectation that justice will be served. Finally, to prevent future theft and misuse of any grant funding, the YWCA has implemented some new policies and procedures. One, the YWCA will not hire close relatives. Two, a thorough review of all financial policies and procedures is in process to ensure that the appropriate checks and balances are in place. Three, any supervisor, who has access to YWCA funds, will be required to participate in a background check to ensure that do not have any personal or financial problems.

Categories

Questioned Costs Allowable Costs / Cost Principles Significant Deficiency Internal Control / Segregation of Duties

Other Findings in this Audit

  • 586906 2023-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
93.088 Advancing System Improvements for Key Issues in Women's Health $532,314
14.267 Continuum of Care Program $285,153
16.575 Crime Victim Assistance $238,335
16.320 Services for Trafficking Victims $213,968
21.023 Emergency Rental Assistance Program $183,058
14.231 Emergency Solutions Grant Program $71,406
16.736 Transitional Housing Assistance for Victims of Domestic Violence, Dating Violence, Stalking, Or Sexual Assault $37,212
93.671 Family Violence Prevention and Services/domestic Violence Shelter and Supportive Services $28,848
16.017 Sexual Assault Services Formula Program $18,750
93.497 Family Violence Prevention and Services/ Sexual Assault/rape Crisis Services and Supports $14,279
93.991 Preventive Health and Health Services Block Grant $6,250
16.525 Grants to Reduce Domestic Violence, Dating Violence, Sexual Assault, and Stalking on Campus $4,415
14.218 Community Development Block Grants/entitlement Grants $625