Finding Text
Finding 2024-003, Eligibility (Assistance Listings 93.583 and 93.576) Criteria: 2 CFR § 200.300 requires that the Federal Organization or pass-through entity must manage and administer the Federal award in a manner so as to ensure that Federal programs are implemented in full accordance with the U.S. Constitution, applicable Federal statutes and regulations. Condition and Context: The Organization’s maintains files for the documentation of program eligibility however those documents do not include evidence of review or approval by the Organization’s staff. 26 out of 60 samples didn’t include the signature of the interpreter which also served as case manager. There was no indication of who was handling the case unless the enrollment form was signed by the interpreter. Cause: Internal controls over the documentation of program eligibility were not operating effectively or designed properly. Effect: The review and approval performed on program eligibility was not documented. Identification as a repeat finding: Yes. Questioned costs: None. Recommendation: We recommend that the Organization institute a policy that provides for the documentation of the review of eligibility documents. View of responsible officials: Management has reviewed the finding regarding the documentation of program eligibility. We recognize the importance of maintaining clear, audit-ready files that explicitly demonstrate case ownership and supervisory approval. To ensure full alignment with 2 CFR § 200.300, we have drafted and instituted the following corrective actions: • Updated Internal Signature Policy: We have drafted a strict internal policy requiring the primary case manager-and any other staff actively working on a case-to sign and date all required enrollment documents. This explicitly includes signing intake forms and completing the interpreter sections, where applicable. This policy ensures there is never any ambiguity regarding who is handling the case. • Mandatory Supervisory Review: To enforce this new standard, our internal policy now requires Program Managers and Directors to systematically review each individual case file. Leadership must verify that all required staff signatures, interpreter sign-offs, and eligibility approvals are fully documented before a client's enrollment is considered complete. • Standardized Case Coversheet: To immediately resolve the issue of identifying case handlers, we are implementing a standardized enrollment coversheet for all new files. This document clearly assigns the primary case manager on day one and requires a final supervisory signature to formally authorize the eligibility review. • Targeted Training and Spot-Checks: We are conducting immediate refresher training for all program staff to clarify exactly which signatures are required on each document. Furthermore, leadership will conduct routine, random spot-checks of active case files each month to verify that staff are consistently adhering to this policy in real-time. By formalizing our signature requirements and mandating director-level reviews, we are confident this updated workflow establishes clear accountability and fully resolves the finding.