Finding 1161287 (2024-003)

Material Weakness Repeat Finding
Requirement
E
Questioned Costs
-
Year
2024
Accepted
2025-10-23

AI Summary

  • Core Issue: AVCP is not consistently following internal control procedures for reviewing eligibility certifications for services provided to American Indians with disabilities.
  • Impacted Requirements: Compliance with the Rehabilitation Act's eligibility criteria is at risk, potentially allowing ineligible individuals to receive services.
  • Recommended Follow-Up: Update internal controls to include electronic reviews of eligibility documents to ensure proper maintenance and compliance.

Finding Text

Finding 2024-003 Significant Deficiency in Internal Control Over Compliance - Eligibility Application Review Identification of the federal program Agencies Award Numbers ALN 84.250 American Indian Vocational Rehabilitation Services Department of Education H250N210051- Year 2023 H250N210051- Year 2024 Criteria In accordance with the Rehabilitation Act of 1973, as amended, Title I, Part C, Section 121, AVCP must comply with the Section 7(9) of the Acts eligibility requirements. Recipients of grants must provide services to American Indians with disabilities residing on or near a Federal or State reservation who meet the definition of an individual with a disability in Section 7 (9) of the Rehabilitation Act. According to the Act the term "disability" means (A) a physical or mental impairment that constitutes or results in a substantial impediment to employment; or (B) a physical or mental impairment that substantially limits one or more major life activities. AVCP is required to check eligibility requirements prior to providing services. Condition The Association is not consistently following their own internal control procedures for keeping evidence of reviewing the eligibility certification form. Cause Due to the remoteness of the villages served by the Association, physical signatures are not always obtainable. Effect or possible effect Individuals who do not met the eligibility requirements may be provided services. Questioned Costs None Identified. Context We tested 16 individuals who were designated as eligible for the American Indian Vocational Rehabilitation Services program. Out of the 16 tested, we found 3 instances where the evidence of the review control was not maintained. Identification as a Repeat Finding None. Recommendation We recommend AVCP update their internal control to include electronic reviews of the eligibility certificate. Views of Responsible Official and Planned Corrective Action Management concurs with the finding. AVCP Vocational Rehabilitation department is adding internal control policies to ensure eligibility documentations are reviewed and maintained.

Corrective Action Plan

Finding 2024-003 Significant Deficiency in Internal Control Over Compliance – Eligibility Application Review Questioned Programs ALN 84.250 American Indian Vocational Rehabilitation Services Agencies: Department of Education Award Numbers H250N210051- Year 2023 H250N210051- Year 2024 Condition The Association is not consistently following their own internal control procedures for keeping evidence of reviewing the eligibility certification form. Status In Progress Management’s Corrective Action Plan Vocational Rehabilitation (VR) will update its required document checklist to include a check for required signatures. The intake staff will utilize the checklist for its first level of application intake to ensure all supporting documents are included and the application is complete, including required signatures. Another step VR will add in the process is a second level of review. Each application that has been approved for support will be reviewed by a second reviewer before final approval. Further, each application that exceeds an award of $10,000, will be reviewed by a third approver. Since applications for services are sometimes foreword to AVCP VR by the Yukon Kuskokwim Health Corporation Audiology Department, AVCP VR will conduct regular training to Audiology staff on the correct process for completing its application. Internally, AVCP VR will continue to conduct yearly training to Village based AVCP staff, who sometimes accept and forward applications to the VR staff, on the correct process for completing its application. Lastly, AVCP VR will update its internal policies and procedures to include these four key steps to ensure applications are complete and signed

Categories

Eligibility Significant Deficiency Internal Control / Segregation of Duties

Other Findings in this Audit

  • 1161284 2024-002
    Material Weakness Repeat
  • 1161285 2024-004
    Material Weakness Repeat
  • 1161286 2024-005
    Material Weakness Repeat
  • 1161288 2024-005
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
15.022 TRIBAL SELF-GOVERNANCE $31.43M
15.U03 477 Cluster $11.11M
93.600 HEAD START $3.24M
20.205 HIGHWAY PLANNING AND CONSTRUCTION $2.71M
15.U02 477 Cluster $888,602
84.250 AMERICAN INDIAN VOCATIONAL REHABILITATION SERVICES $522,870
93.047 SPECIAL PROGRAMS FOR THE AGING, TITLE VI, PART A, GRANTS TO INDIAN TRIBES, PART B, GRANTS TO NATIVE HAWAIIANS $259,925
93.556 MARYLEE ALLEN PROMOTING SAFE AND STABLE FAMILIES PROGRAM $147,989
10.558 CHILD AND ADULT CARE FOOD PROGRAM $143,371
16.710 PUBLIC SAFETY PARTNERSHIP AND COMMUNITY POLICING GRANTS $72,664
15.U01 Temporary Assistance for Needy Families $71,540
93.645 STEPHANIE TUBBS JONES CHILD WELFARE SERVICES PROGRAM $66,477
66.926 INDIAN ENVIRONMENTAL GENERAL ASSISTANCE PROGRAM (GAP) $35,475
93.053 NUTRITION SERVICES INCENTIVE PROGRAM $31,124
93.568 LOW-INCOME HOME ENERGY ASSISTANCE $28,392
15.643 ALASKA MIGRATORY BIRD CO-MANAGEMENT COUNCIL $25,900
66.817 STATE AND TRIBAL RESPONSE PROGRAM GRANTS $24,845