Finding 1175511 (2025-002)

Material Weakness Repeat Finding
Requirement
E
Questioned Costs
-
Year
2025
Accepted
2026-02-26

AI Summary

  • Core Issue: Incomplete eligibility documentation for WIOA youth participants, specifically missing case manager signatures on applications.
  • Impacted Requirements: Non-compliance with 2 CFR 200.303 and WIOA eligibility criteria, risking federal fund disbursement to ineligible participants.
  • Recommended Follow-up: Conduct a thorough review of all Youth Activities applications to ensure all eligibility documentation is complete and approved before federal funds are disbursed.

Finding Text

2025-002 – ELIGIBILITY (REPEAT OF PRIOR YEAR FINDING 2024-004) - Federal Program Information: Federal Agency and Program Name - U.S. Department of Labor WIOA Cluster. Federal Assistance Listing Number - 17.258/17.259/17.278 Criteria: 2 CFR 200.303 requires that a non-federal entity must “(a) 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 the provisions of the Workforce Innovation and Opportunity Act (WIOA), “A person is eligible to receive services under Youth Activities if they are an out-of school youth or an in-school youth (29 USC 3164(a)(1), 128 Stat. 1504)”, and meet the definition of such as defined in the Uniform Guidance. Condition: During our testing of WIOA participants, it was noted that for one of the six youth participants selected for testing the WIOA intake application was not signed by the case manager. Questioned Costs: Unknown. Context: Total federal expenditures for the WIOA Cluster were $1,115,599 for the year ended June 30, 2025. Cause: The Board’s policies and procedures are not sufficient to ensure that all participant applications are complete and approved for eligibility prior to disbursement of federal funds. Effect: Youth Activities participant(s) may be granted access to the Board’s program when they do not meet the prescribed eligibility requirements. Recommendation: We recommend that the Board thoroughly review all applications for Youth Activities to ensure that all required eligibility documentation is completed and properly approved. Views of Responsible Officials: We agree with the finding and will take the necessary corrective actions as noted in the corrective action plan attached.

Corrective Action Plan

2025-002 Eligibility- WIOA intake applications were not signed properly U.S. Department of Labor Assistance Listing Number 17.258/17.259/17.278 Condition: During our testing of WIOA participants, it was noted that for one of the six youth participants selected for testing the WIOA intake application was not signed by the case manager. Recommendation: We recommend that the Board thoroughly review all applications for Youth Activities to ensure that all required eligibility documentation is completed and properly approved. Region 3 Action:ln direct response to this finding, the Board developed and implemented a comprehensive Youth Eligibility Policy, effective February 25, 2025. This policy establishes clear and enforceable procedures to ensure that all youth participants are properly vetted prior to receiving WIDA-funded services.Specifically, the policy includes a dedicated "Eligibility Verification" and "Documents for Verifying WIOA Eligibility" section which requires that service providers confirm each individual meets all applicable WIOA eligibility requirements including age, selective service registration and citizenship status at the time of registration. The policy further requires that each participant file contain a completed application along with supporting documentation confirming general WIOA eligibility and all applicable Youth eligibility data elements. Additionally, all questions on the intake form must be fully answered and both the applicant and the intake staff member are required to sign the intake forms prior to the delivery of services. Primary Eligibility Review is the Local Board's program staff's responsibility to ensure all registration paperwork is complete and accurate before WIOA enrollment.The Board is confident that these policy requirements provide the necessary framework and controls to ensure consistent, documented eligibility verification across all service providers administering youth activities under WIOA. The Board will continue to monitor compliance with this policy through its oversight activities to ensure the controls remain effective on an ongoing basis.

Categories

Eligibility Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties Special Tests & Provisions

Other Findings in this Audit

  • 1175495 2025-001
    Material Weakness Repeat
  • 1175496 2025-002
    Material Weakness Repeat
  • 1175497 2025-003
    Material Weakness Repeat
  • 1175498 2025-001
    Material Weakness Repeat
  • 1175499 2025-002
    Material Weakness Repeat
  • 1175500 2025-003
    Material Weakness Repeat
  • 1175501 2025-001
    Material Weakness Repeat
  • 1175502 2025-002
    Material Weakness Repeat
  • 1175503 2025-003
    Material Weakness Repeat
  • 1175504 2025-001
    Material Weakness Repeat
  • 1175505 2025-002
    Material Weakness Repeat
  • 1175506 2025-003
    Material Weakness Repeat
  • 1175507 2025-001
    Material Weakness Repeat
  • 1175508 2025-002
    Material Weakness Repeat
  • 1175509 2025-003
    Material Weakness Repeat
  • 1175510 2025-001
    Material Weakness Repeat
  • 1175512 2025-003
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
17.278 WIOA DISLOCATED WORKER FORMULA GRANTS $676,635
17.259 WIOA YOUTH ACTIVITIES $132,760
10.561 STATE ADMINISTRATIVE MATCHING GRANTS FOR THE SUPPLEMENTAL NUTRITION ASSISTANCE PROGRAM $90,015
17.258 WIOA ADULT PROGRAM $50,421