Finding Text
Type of Finding: Material Weakness in Internal Control over Compliance of Major Programs and Noncompliance
within the Major Programs
•Criteria: Caritas Family Solutions is responsible to implement an internal control system and process
for re-certifications be performed as part of the required annual process to ensure that participants
remain eligible for the grant.
•Condition: During the audit, it was observed that re-certification was not performed for two
participants as part of the required annual process to verify their ongoing eligibility.
•Cause: The failure to perform re-certification may be attributed to a lack of established procedures,
oversight, or a misunderstanding of the re-certification requirements. This could result in individuals
who are not eligible to receive funds under the major program.
•Effect: The absence of re-certification for eligible participants may lead to non-compliance with federal
eligibility regulations, raising concerns about the proper allocation of grant resources.
•Recommendation: The Organization should promptly establish and enforce clear procedures and
oversight for conducting re-certification as part of the required annual process to ensure ongoing
eligibility for all participants.
•Responsible Party: Gary Huelsmann, Chief Executive Officer
•Management Response and Corrective Action Plan: This deficiency was also discovered during our
internal investigation, and Caritas Family Solutions has implemented a new process to ensure that
internal controls are in place.
A SCSEP Employment Specialist will meet with participants to complete the recertification
application and gather the necessary documentation.
The recertification application and documentation will be forwarded to the PM for review and
approval.
The PM will review the form, sign, and date it after confirming that all information is accurate and
complete.
If there are inaccuracies and/or missing information, the form will be returned to the ES who will
follow up with the host site to obtain the missing information or correct the inaccuracy.
Steps 1 and 2 will be repeated.
The QI department will conduct quarterly file reviews to determine if processes are being followed.
Re-certification was modified during the pandemic out of an abundance of caution for the
participants in the program. Those who had access to the internet were asked to email their
documentation, and those who didn’t were asked to mail theirs. A drive through recertification
process was implemented when COVID restrictions eased, and participants were asked to
remain in their vehicles while SCSEP employment specialists obtained their recertification
documentation. Many participants do not have transportation and were not able to participate
in the drive through. The most recent, pre-pandemic certification information for participants
was used for those who were not able to attend the drive through or virtual recertification
processes. CWI did not end COVID protocols until Q4 of PY2022 (April 1, 2023). Alternative
recertification methods were used to comply with the protocols. With the end of the COVID
protocols and restrictions, we have reinstituted the in-person/face-to-face recertification
process required by the funder.
•Anticipated Completion Date: Implemented in September 2023, but the process will be ongoing while
the program is funded.