Finding Text
Reference Number: 2023-005 – Ineligible Participants
Federal Program Title: WIOA Cluster
Federal Assistance Listing Number: 17.258
Federal Agency: Department of Labor (DOL)
Pass-Through Entity: State of California Employment Development Program
Federal Award Number and Year: AA211079, 170305366
Category of Finding: Eligibility
Type of Finding: Significant Deficiency in Internal Control over Compliance, Instance of Noncompliance
Criteria
In accordance with Section 3 WIOA, 128 Stat. 1431 and grant agreements, participants must meet the WIOA definition of adult, dislocated worker, or dislocated homemaker and must not have previously participated in any WIOA program to be eligible to participate.
Condition
During our review of participant eligibility, we noted five (5) participants were ineligible for the as follows:
(1) One (1) participant was ineligible due to previously participating in a WIOA program with the Organization.
(2) Four (4) participants were ineligible due to being fully employed and did not meet the definition of either dislocated worker per Section 3(15), WIOA, 128 Stat. 1431 or dislocated homemaker per Section 3(16), WIOA, 128 Stat. 1432.
Cause
The Organization has experienced significant turnover in key personnel in the Organization’s finance department and management in past years. Absent robust accounting policies and procedures, when vacancies occur, information can be lost and as individuals are getting up to speed, some processes may not be fully executed if they are manual and not fully embedded into an automated system.
Effect
The Organization has no documented policies and procedures for determining eligibility and for reviewing eligibility.
Questioned Costs
We identified costs of $8,774 that could be considered questionable. We are unable to estimate total likely questioned costs.
Context
For the forty (40) participants selected for testing, five (5) were found to be ineligible.
The sample was not a statistically valid sample.
Recommendation
We recommend that the Organization develop and document processes for determining participant eligibility and for reviewing case manager determination of participant eligibility. We also recommend the Organization develop a recurring training program for staff involved with grant processes and procedures and compliance requirements.
Views of Responsible Officials and Planned Corrective Action
Person responsible: Leona Smith Di Faustino, Interim Executive Director
Corrective Action Plan: During the period being audited internal controls for program participants documents were not reviewed by the former Executive Director. The new Executive Director has implemented a check and balance procedure that requires the Case Manager, Program Manager, and Executive Director to review and sign off on participant application forms and to be documented on the participants application before the participant can move forward in the program.
Anticipated Implementation Date: June 30, 2024