Finding 35185 (2022-002)

Significant Deficiency
Requirement
ABN
Questioned Costs
-
Year
2022
Accepted
2023-03-26
Audit: 24786
Organization: Alvernia University (PA)

AI Summary

  • Core Issue: Missing documentation for stipend payments and criminal history checks due to staff turnover.
  • Impacted Requirements: Compliance with allowable costs and eligibility checks for participants under the AmeriCorps grant.
  • Recommended Follow-Up: Revise documentation systems for stipends and clearances, and improve processes for staff transitions to ensure ongoing compliance.

Finding Text

Federal Program Corporation of National and Community Service - AmeriCorps Seniors Foster Grandparent Program, ALN 94.011, Award No. 21SFBPA002, Period 7/1/21 - 6/30/24 Criteria Stipends paid to participants who meet income levels set by AmeriCorps are paid based on hours worked and mileage reimbursement. Grantees should maintain documentation to support all stipend expenses paid using grant funds. Through September 30, 2021, a stipend allowance was in place, allowing participants to be paid based on average hours worked prior to the COVID-19 emergency due to several locations still operating under restrictions as a result of the pandemic. Program staff and individuals working under the Foster Grandparent Grant are required to complete certain criminal history checks to determine eligibility prior to beginning work on service on the grant. These include: (1) National Sex Offender Public Website nationwide check; (2) Pennsylvania Criminal Record Check; (3) Pennsylvania Child Abuse Clearance; and (4) FBI fingerprint-based check. The grantee is required to maintain documentation that all required components were conducted on time through sources authorized by AmeriCorps and reviewed to consider eligibility. Condition/Cause Due to turnover in program staff, management was unable to locate certain requested documentation for audit testing. Effect The University was unable to support compliance with the allowable activities, allowable costs, and national service criminal history checks special tests requirements of the grant for certain items selected for audit testing. Questioned Costs Less than $25,000 Context We selected a sample of 40 stipend payments during the 2021-2022 year for testing. For 2 of the stipends selected, current program management was unable to provide documentation to support amount paid. These stipends fell during the allowance period and were based on average hours worked; however, documentation was not maintained which allowed for recalculation of stipend paid. For an additional 4 of the stipends selected, current program management was unable to locate timecards completed by the volunteer. However, hours paid agreed to a spreadsheet that had been maintained by a previous program director. We selected a sample of 7 individuals who worked as staff or volunteers within the program. Of the 7 selected, 2 of the 4 required clearances could not be located for 1 individual. The individual is no longer working as a staff member of the grant. Repeat Finding No. Recommendation We recommend that the University revisit and revise their documentation filing system for timecards, mileage reimbursement, and other documentation that would support amounts paid for stipends under the program. This would also include a complete inventory of all clearances/criminal background checks for current staff and volunteers working in the program and obtain updated background checks for any that are not on file. We also recommend the University revisit the process of replacing a director after their departure to ensure program compliance continues. Management Response See corrective action plan included in this report package.

Corrective Action Plan

Federal Program Corporation of National and Community Service - AmeriCorps Seniors Foster Grandparent Program, ALN 94.011, Award No. 21SFBPA002, Period 7/1/21 - 6/30/24 Condition/Cause Due to turnover in program staff, management was unable to locate certain requested documentation for audit testing. Recommendation We recommend that the University revisit and revise their documentation filing system for timecards, mileage reimbursement, and other documentation that would support amounts paid for stipends under the program. This would also include a complete inventory of all clearances/criminal background checks for current staff and volunteers working in the program and obtain updated background checks for any that are not on file. We also recommend the University revisit the process of replacing a director after their departure to ensure program compliance continues. Management Response We agree with the auditors' finding. The instance of non-compliance occurred during a period when the University had a vacancy in both the Grant Specialist and Program Director positions. These roles carry duties to includes design and oversight of the internal control environment regarding the compliance of the federal program. As of August 2022, both vacant positions have been appointed to provide oversight for program compliance. To mitigate deficiencies in controls regarding change management, personnel status change forms involving federally funded programs will be circulated to the Program Director, Grant Specialist, and Business Affairs office. The University will implement the auditors? recommendation to invest in a documentation and approval system for credentials and allowable costs. The Program Director will also perform routine maintenance over personnel files and required documentation.

Categories

Allowable Costs / Cost Principles Cash Management Eligibility Equipment & Real Property Management Special Tests & Provisions

Other Findings in this Audit

  • 35184 2022-001
    Significant Deficiency
  • 611626 2022-001
    Significant Deficiency
  • 611627 2022-002
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $22.57M
84.063 Federal Pell Grant Program $3.09M
84.033 Federal Work-Study Program $367,388
84.038 Federal Perkins Loans $339,209
84.031 Higher Education_institutional Aid $337,893
84.425 Education Stabilization Fund $257,600
94.011 Foster Grandparent Program $197,395
84.007 Federal Supplemental Educational Opportunity Grants $196,608