Finding Text
Reference Number: 2024-004 – 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 Department
Federal Award Number and Year: AA211079 Fiscal Year 2023-2024
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.
Condition
During our review of participant eligibility, we noted eleven (11) 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.
This is a repeat finding of 2023-005.
Cause
Due to significant turnover in key personnel in the Organization’s finance department and management in past years, the Organization has no documented policies and procedures for determining eligibility and for reviewing eligibility.
Effect
Failure to adequately document and maintain support for eligibility determinations may result in non-compliance with WIOA regulations and there is risk that federal funds may be used on ineligible participants.
Questioned Costs
We identified costs of $13,245 that could be considered questionable. We are unable to estimate total likely questioned costs.
Context
For the thirty-nine (39) participants selected for testing, eleven (11) 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: July 1, 2024