Finding 11569 (2023-004)

Significant Deficiency

Requirement

Questioned Costs

Year

2023

Accepted

2024-02-02

Audit: 15377

Organization: Volunteers of America Western Washington and Subsidiary (WA)

Auditor: Bdo USA PC

AI Summary

Core Issue: Missing documentation for the review of performance reports prior to submission for federal awards.
Impacted Requirements: Federal recipients must have verifiable controls over report preparation and submission.
Recommended Follow-Up: Implement controls to ensure proper documentation of review and approval processes for performance reports.

Finding Text

Award/Pass-Through Entity Identifying Numbers: HCS-21-37-2101-018(7), HCS-21-37-2103-018(7), HCS-21-17-2101-018(6), HCS-21-17-2104-018(4) 6, HCS-23-17-2301-018, and Network Agreement Criteria: Recipients of federal awards must establish verifiable controls over reports that are prepared and submitted. Condition: For all eight performance reports selected for testing in the Emergency Rental Assistance Program, appropriate documentation was not available to evidence review of the report prior to submission. For the one performance report tested in the Substance Abuse and Mental Health Services Projects of Regional and National Significance program, appropriate documentation was not available to evidence review of the report prior to submission. Cause: While the Organization has a policy in place that requires the contract compliance manager or controller to review monthly performance reports, proper documentation to support the policy was not available. Effect or Potential Effect: Reports could be submitted that are inaccurate or incomplete. The Organization does not have the documentation required regarding review/approval of the performance reports. Questioned Costs: N/A Context: There were 22 performance reports submitted for the Emergency Rental Assistance Program during the fiscal year; 8 performance reports were tested. There was one performance report submitted for the Substance Abuse and Mental Health Services Projects of Regional and National Significance program during the fiscal year. This is a condition identified per review of the Organization’s compliance with specified requirements not using a statistically valid sample. Recommendation: We recommend that the Organization implement controls to ensure proper documentation of review and approval of performance reports. Federal Agencies: Department of the Treasury and Department of Health and Human Services Federal Assistance Listing Numbers: 21.023 and 93.243 Programs: COVID-19 Emergency Rental Assistance Program and Substance Abuse and Mental Health Services Projects of Regional and National Significance Views of Responsible Officials: Management agrees with the finding and recommendations set forth within and has developed a corrective action plan to address the instances of noncompliance identified and lapses in prescribed internal controls.

Corrective Action Plan

Contract Reporting Documentation While the control exists, the documentation around required reporting review and submission was weak. Corrective Action: New Control A new control will be put in place to document the review, approval, and submission of required contract deliverables process in Accounting. This will also require the programs to standardize their documentation of their internal review, approval, and submission processes. New Controls Designed: CC-001 Contract Reporting Compliance New Control Implementation Timeline: effective immediately for those programs that had findings, retro documentation for FY24 FYTD also required. Effective 1/1 for the rest of the agency. Follow Up Action: VP of Finance/Controller to follow up with Contract Compliance Manager on progress of creating custom reporting checklists for each contract, starting with those that had findings. Once implemented, VP of Finance/Controller to follow up during Financial Review Meetings with Programs and Contract Compliance Manager. Name of Responsible Official: Claire Danielson, VP of Finance/Controller Anticipated Completion Date: July 2024

Other Findings in this Audit

11568 2023-003

Significant Deficiency
11570 2023-004

Significant Deficiency
11571 2023-004

Significant Deficiency
11572 2023-004

Significant Deficiency
11573 2023-004

Significant Deficiency
11574 2023-004

Significant Deficiency
588010 2023-003

Significant Deficiency
588011 2023-004

Significant Deficiency
588012 2023-004

Significant Deficiency
588013 2023-004

Significant Deficiency
588014 2023-004

Significant Deficiency
588015 2023-004

Significant Deficiency
588016 2023-004

Significant Deficiency

Programs in Audit

ALN	Program Name	Expenditures
21.023	Emergency Rental Assistance Program	$1.50M
21.019	Coronavirus Relief Fund	$1.46M
21.027	Coronavirus State and Local Fiscal Recovery Funds	$1.33M
93.243	Substance Abuse and Mental Health Services Projects of Regional and National Significance	$682,906
10.569	Emergency Food Assistance Program (food Commodities)	$681,247
14.231	Emergency Solutions Grant Program	$407,593
14.239	Home Investment Partnerships Program	$317,473
10.568	Emergency Food Assistance Program (administrative Costs)	$275,193
97.024	Emergency Food and Shelter National Board Program	$176,618
14.218	Community Development Block Grants/entitlement Grants	$157,494
93.566	Refugee and Entrant Assistance State Administered Programs	$76,000
93.959	Block Grants for Prevention and Treatment of Substance Abuse	$74,215
14.228	Community Development Block Grants/state's Program and Non-Entitlement Grants in Hawaii	$70,051
10.558	Child and Adult Care Food Program	$55,891
93.958	Block Grants for Community Mental Health Services	$50,000
93.575	Child Care and Development Block Grant	$40,500
10.525	Farm and Ranch Stress Assistance Network Competitive Grants Program (b)	$9,875
93.597	Grants to States for Access and Visitation Programs	$6,340
93.568	Low-Income Home Energy Assistance	$1,650
94.006	Americorps State and National	$219