Finding 1215588 (2025-001)

Material Weakness Repeat Finding
Requirement
E
Questioned Costs
-
Year
2025
Accepted
2026-05-27

AI Summary

  • Core Issue: 11 out of 91 LIHEAP participant files lacked effective internal controls, risking eligibility compliance.
  • Impacted Requirements: Missing management reviews, utility bills, and income verification violate 2 CFR 200.303 and Agency policies.
  • Recommended Follow-Up: Ensure all applicant files are complete and include documented management reviews to comply with established policies.

Finding Text

Condition: During testing of 91 Low-Income Home Energy Assistance Program (LIHEAP) participant files, we identified 11 files for which internal controls over compliance with major program requirements were not operating effectively, as follows: Nine (9) files did not include evidence of management review (i.e., a management signature or initials on the application). One (1) file was missing the utility bill from the hard-copy file maintained at the Agency; however, the Agency had submitted the eligibility documentation in FACSPro. One (1) file was missing income verification for the head of household and a social security card for one household member from the hard-copy file maintained at the Agency; however, the Agency had submitted the eligibility documentation in FACSPro. Criteria: In accordance with 2 CFR 200.303 and LIHEAP program requirements, recipients must establish and maintain effective internal controls to provide reasonable assurance that assistance is awarded only to eligible households. Eligibility determinations must be supported by complete and adequate documentation. The Agency’s policies require that each LIHEAP applicant folder include a hard copy of the documents used to determine eligibility that is maintained at the Agency. In addition, all applications must receive a secondary review by management. This review must be documented by the reviewer’s initials or signature on the application. Cause: The exceptions noted resulted from management not consistently adhering to the Agency’s established policies regarding documentation retention and documented management review of LIHEAP applications. Effect: Failure to consistently document and review LIHEAP applications increases the risk that assistance may be awarded to ineligible households. This could result in questioned costs and noncompliance with applicable federal requirements. Recommendation: We recommend that management consistently follow Agency policy by ensuring that (1) all LIHEAP applicant files maintained at the Agency are complete and include the documentation used to support eligibility and (2) all applications receive a management review that is clearly documented through reviewer initials or signatures. View of Responsible Officials: See auditee prepared Corrective Action Plan

Corrective Action Plan

CAPHMLC is implementing corrective actions to ensure full compliance and strengthen internal controls. 1. CAPHMLC will reinforce its requirement that all LIHEAP participant files include complete hard-copy documentation supporting eligibility determinations. 2. A standardized documentation checklist will be implemented and required in each file to verify completeness prior to approval. 3. A documented supervisory review will be required for all applications. Evidence of this review must include the reviewer's initials or signature and the date ofreview. 4. Applications will not be processed until the required review is completed and documented. CAPHMLC will provide mandatory trammg to all LIHEAP staff and supervisors on documentation requirements, record retention standards, and supervisory review procedures. Updated policies will be formally communicated, and staff will be required to acknowledge their unde-rstanding e fc-these-requirements. To ensure ongoing compliance, CAPHMLC will implement monthly quality assurance reviews of a sample of participant files to verify completeness of documentation and evidence of supervisory review. Results will be reported to management, and any identified deficiencies will be addressed promptly. Procedures will also be strengthened to ensure consistency between electronic records maintained in F ACSPro and hard-copy files. These corrective actions will be implemented within 90 days, with trammg and policy reinforcement completed within 30 days, and monitoring procedures initiated within 60 days. Supervisors will be responsible for enforcing compliance, and instances of noncompliance will be addressed in accordance with CAPHMLC personnel policies and procedures. Management will monitor the effectiveness of these corrective actions through ongoing quality assurance activities and periodic internal reviews to ensure sustained compliance with applicable requirements.

Categories

Eligibility

Other Findings in this Audit

  • 1215587 2025-001
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.569 COMMUNITY SERVICES BLOCK GRANT $400,255
81.042 WEATHERIZATION ASSISTANCE FOR LOW-INCOME PERSONS $278,161
93.568 LOW-INCOME HOME ENERGY ASSISTANCE $36,911
14.169 HOUSING COUNSELING ASSISTANCE PROGRAM $8,899