Finding Text
2023-004 (2022-004) – Classification of Consumer Goals – Significant Deficiency in Internal Controls over Compliance
ALN: 84.126
Federal Award Title: Rehabilitation Services Vocational Rehabilitation Grants to States
Federal Agency: United States Department of Education
Pass-Through Entity: Texas Health and Human Services Commission
Award Number(s): HHS000186000005, HHS000202900008
Federal Award Year: 2023
Condition: Eligibility dates were not matching between the ILS system and DRS system on 4 of 40 consumers tested.
Criteria: 2 CFR 200.303 requires a non-Federal entity to Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘‘Standards for Internal Control in the Federal Government’’ issued by the Comptroller General of the United States and the ‘‘Internal Control Integrated Framework’’, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Per ILS Program Standards 5.6.3.5 Revision 19-1, all entries to the Independent Living Services Data Reporting System made by the service provider will be considered a part of the consumer case file. Each consumer case file must minimally meet the requirements of 34 CFR, Subtitle B, Chapter III, Part 364, §364.53, and provide documentation concerning: the consumer’s goals for independence and anticipated methods and services to achieve the goals.
Effect: The Organization may unintentionally provide services to ineligible consumers.
Cause: Lack of internal controls at the Organization to ensure that eligibility dates are appropriate in both the ILS and DRS system.
Questioned Costs: No questioned costs identified.