Finding Text
Corporation for National and Community Service
Foster Grandparent/Senior Companion Cluster – Assistance Listing #94.011, #94.016
#2023-003 – Material Weakness in Internal Controls over Compliance: Special Tests and Provisions
Compliance Finding: Special Tests and Provisions
This is a repeat of prior year finding #2022-005.
Criteria:
• Foster Grandparent and Senior Companion eligibility require background checks for Foster Grandparent and Senior Companion volunteers and Catholic Charities West Michigan staff involved in the program to be completed prior to the date they begin to work/serve.
• All background checks are required to be adjudicated by Catholic Charities West Michigan to ensure the volunteer is eligible for service prior to the date they begin to work/serve. This adjudication should be documented within the AmeriCorps-approved software when used or Catholic Charities may manually document the eligibility decision and the date of this adjudication.
Conditions/Context:
• In the spring of 2023, the Corporation for National and Community Service (CNCS) completed an audit of the National Service Criminal History Checks (NSCHC) requirement compliance of a sample of volunteers who received a stipend during the period of 4/1/2022 through 12/31/2022 as well as all staff working in the programs. As a result of this audit, 86 noncompliance findings were noted. This audit was closed as of March 18, 2024, with the corrective action plan and findings resolved.
• We tested a sample of 24 volunteers and 2 staff members who worked or received stipends during the fiscal year ending September 30, 2023, many of which were also subject to the CNCS audit previously performed.
• For 13 of the 24 volunteers and both staff members we tested, at least one of the required background check components were not completed correctly prior to their start date. These missing background checks were completed before September 30, 2023 for 12 of the volunteers. The checks for the remaining volunteer and two staff members were completed subsequent to year-end, but prior to the audit beginning in April 2024.
• For 23 of the 24 volunteers and both staff members we tested, adjudication of the check by Catholic Charities West Michigan staff was not completed or properly documented for at least one of the required background check components. All checks were adjudicated and properly documented subsequent to year-end, but prior to the audit beginning in April 2024.
Cause: The Organization had not adequately trained the responsible staff of all program requirements for background checks. Additionally, policies and procedures in place did not adequately reflect all such requirements.
Questioned Costs: The Organization repaid CNCS approximately $54,000 related to the CNCS audit findings for the period April 1, 2022 to December 31, 2022, referred to above. A portion of this obligation may be associated with the year ended September 30, 2023, although that amount is not able to be determined. Any additional questioned costs for the period January 1, 2023 through September 30, 2023 have not been determined.
Identification of How Questioned Costs Were Computed: As a result of the CNCS audit findings noted above, cost-based disallowance was identified by the CNCS. The obligation for the period ended December 31, 2022 was based on the amount repaid to CNCS. Catholic Charities West Michigan recorded this obligation in the financial statements as of September 30, 2023 and repaid the amount subsequent to year end.
Recommendations:
• We recommend that the Organization undergo (and provide) further training to promote the awareness of requirements for all staff performing background checks.
• We recommend that the Organization enhance its policies and procedures to promote future compliance with all program requirements.
Views of Responsible Officials and Planned Corrective Actions:
The Senior Programs have undergone significant improvements in the last 6 months following an audit by the federal funder which resulted in a corrective action plan (CAP) and a repayment of $54,228. Plans were implemented during the spring of 2024 in response to the CAP which resulted in an overhaul of the processes in place to properly develop the volunteer checklists and assure all records for staff and volunteers are now compliant. Our Quality and Compliance and Finance team worked closely with the new Program Manager to assure that we will be fully compliant and remain so.