Finding 29191 (2022-001)

Significant Deficiency
Requirement
E
Questioned Costs
-
Year
2022
Accepted
2023-03-05
Audit: 25575
Organization: Independence Now, INC (MD)
Auditor: Aprio LLP

AI Summary

  • Core Issue: The Organization did not obtain signed eligibility verification forms before starting services for several beneficiaries, indicating a breakdown in internal controls.
  • Impacted Requirements: Compliance with eligibility criteria for the ACL Centers for Independent Living program was not met, posing a risk of serving ineligible individuals.
  • Recommended Follow-Up: Enforce control processes by limiting access to casefile setup and assigning a designated reviewer for eligibility verification forms.

Finding Text

Finding 2022-001: Reportable Finding Considered a Significant Deficiency ? Internal controls over eligibility for ACL Center of Independent Living Program Program Name: ACL Centers for Independent Living Assistance listing #: 93.432 Federal Awarding Agency: U.S. Department of Health & Human Services Compliance Requirement: Eligibility Criteria: Under the ACL Centers for Independent Living grants, recipients are required to check applicants for eligibility. As part of the Organization?s internal control process, each beneficiary is required to have a signed eligibility verification form prior to starting a new casefile. Condition: Under awards and periods listed below, the Organization failed to have signed verification forms prior to the start of services for several of the beneficiaries selected for testing during the audit. Award Number Period 2106MDILCL-00 10/1/21?9/30/22 2108MDILCL-00 10/1/21-9/30/22 2106MDILC5-00 4/1/21-9/30/22 2108MDILC5-00 4/1/21-9/30/22 Cause: Per discussion with Management, the missing verification forms resulted from staff starting a casefile before obtaining a signed eligibility verification form. Effect: The Organization?s internal control was not working effectively. While there were no issues of noncompliance identified during the audit, there is a risk that the Organization could serve an ineligible individual under the program by not following the established internal control processes. Repeat Finding: Not a repeat finding. Recommendation: We recommend that the Organization enforce the established control processes over the setup of new casefiles with limited access and assign an individual to review the eligibility verification form prior to opening a casefile. Views of Responsible Officials and Corrective Action Plan (unaudited): See corrective action plan.

Corrective Action Plan

All staff will be retrained in February 2023 on Consumer Information Records and the required documents and signatures, including the eligibility requirement. Staff are taking a pause from opening new cases for the month of February 2023 and confirming all documentation of current consumers is up to date and in the electronic file on CIL Suites. During this time staff will also close inactive cases. Going forward all electronic files will be reviewed by the Deputy Director before services can begin. This will allow the Deputy Director to verify all required documentation is in place before services begin. The Independent Living Staff also all agreed that our intake sessions for new consumers will occur in person only unless there are very extenuating circumstances. An in-person intake will ensure all documents are copied and signed by the consumer for uploading to the electronic files.

Categories

Eligibility Significant Deficiency

Other Findings in this Audit

  • 605633 2022-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
96.008 Social Security - Work Incentives Planning and Assistance Program $280,821
93.791 Money Follows the Person Rebalancing Demonstration $88,004
93.432 Acl Centers for Independent Living $50,753
93.369 Acl Independent Living State Grants $50,126
96.006 Supplemental Security Income $22,189
84.027 Special Education_grants to States $21,381
93.464 Acl Assistive Technology $6,874
93.630 Developmental Disabilities Basic Support and Advocacy Grants $5,000