Finding Text
Significant Deficiency Federal Agency: U.S. Department of Health and Human Services Pass-through Entity: Illinois Department on Aging Federal Program: Aging Cluster (Federal Assistance Listing No.’s 93.044, 93.045, 93.053) Requirement: Earmarking, Level of Effort and Matching Finding 2025-001 – Noncompliance with Earmarking Requirement Criteria: Per Older Americans Act 306 (a)(2) and 307(a)(2) as well as 45 CFR section 1321.27(h)(3), the Agency is required to allocate certain percentages of their funds to certain expenses as required by their state agency on aging. One of these required allocations is legal assistance expenses where the Agency is required to expend at least 3.02% of their total Title – IIIB funds in this area, per the Illinois Department on Aging’s 2025-2028 Area Plan. Condition: It was noted during our audit that the Agency underspent on legal assistance as they only spent 2.30% of their Title - IIIB funds received during fiscal year 2025 on legal assistance. The Agency had the minimum legal assistance expense factored into their budget for Title – IIIB funds based on the total amount awarded by the Illinois Department on Aging but did not meet this budgeted amount. Cause: As the Agency has a multitude of grants, all with their own specific grant requirements to follow, it is expectedly difficult to ensure that all requirements are being met by the Agency. Due to the number of grants and requirements, it is very important that the Agency has a process of ensuring compliance is maintained with all grant requirements. Effect: Without proper procedures to ensure grant funds are spent where planned, funds can be used for purposes other than intended by the granting agency, and therefore not for the intended purpose of the grant. This could result in inefficient use of funds as well as noncompliance with grant agreements which could lead to adverse conditions with the grantor of the funds. Questioned Costs: No questioned costs. Perspective Information: This appears to be an isolated event. Recommendation: We recommend the Agency implement a process to review earmarking requirements when budgeting so the Agency is aware of the minimums that must be met for the year, and set aside funds in advance so they are available for the intended purpose. Once these minimums are budgeted for, a monthly or quarterly review should be performed to ensure that actual expenses for these minimums are met as required. Response: West Central Illinois Area Agency on Aging will strengthen its budgeting and monitoring process to ensure required minimum spending levels are met. Beginning in FY2026, staff will verify earmarked requirements during budget preparation and review expenses quarterly to confirm compliance. Responsibility for monitoring has been assigned to fiscal leadership, with review and oversight by Director, Assistant Director, as well as Program Manager. The Agency believes this was an isolated incident and expects these steps to prevent recurrence in accordance with requirements from the Illinois Department on Aging.