Finding Text
Federal Agency: U.S. Department of Veterans Affairs
Federal Program Name: Supportive Services for Veteran Families
Assistance Listing Number: 64.033
Federal Award Identification Number and Year: 12-NC-050
Award Period: September 30, 2022 through September 30, 2024
- Type of Finding: Material Weakness in Internal Control over Compliance
Criteria or specific requirement: The Corporation is required to maintain adequate documentation to support the required eligibility determinations and redeterminations were performed for individuals receiving benefits. Properly completed intake forms and appropriately reviewed documentation are essential to ensure compliance requirements of the program.
Condition: The corporation failed to maintain adequate documentation to substantiate the eligibility determinations for individuals receiving benefits. Specifically, intake forms were not properly completed, documentation was not appropriately reviewed, and in certain instances, documentation was available for review.
Questioned costs: None
Context: During our testing of 16 samples related to eligibility determinations for individuals receiving benefits, we identified the following issues: 4 instances where the intake form was not properly completed, 10 instances where the documentation was not appropriately reviewed, and 1 instance where there was no documentation on the individual receiving benefits. Management has asserted that these may not be the only instances of such issues.
Cause: The corporation did not have sufficient controls in place to ensure that all eligibility determination documentation was properly completed, reviewed, and maintained.
Effect: Noncompliance with the federal requirements around the determination of an eligible individual.
Recommendation: We recommend that the Corporation establish and enforce a standardized process for completing and reviewing intake forms, provide training to staff on the importance of maintaining proper documentation and the procedures for completing and reviewing eligibility determinations, and implement periodic internal audits to ensure compliance with documentation requirements and to identify any areas needing improvement.
Views of responsible officials: Management agrees with the above finding. In fiscal year 2025, Passage Home implemented new programmatic policies and procedures ensuring that a Program Manager or the Program Director reviews and approves (by signature) all new client enrollments prior to case manager assignment. The Program Director will conduct related training for all program staff and will administer quarterly client record audits (peer or supervisor review) to verify ongoing compliance.