Finding 388141 (2023-007)

Material Weakness Repeat Finding
Requirement
M
Questioned Costs
-
Year
2023
Accepted
2024-03-28

AI Summary

  • Core Issue: EmployIndy reimbursed Eckerd Connects based on fixed percentages rather than actual time worked on WIOA grants.
  • Impacted Requirements: This violates federal compliance requirements for subrecipient monitoring as outlined in Title 2 Subtitle A Chapter II Part 200.
  • Recommended Follow-Up: EmployIndy should review subrecipient documents to ensure expenses are backed by proper invoices or time records.

Finding Text

FINDING 2023-007 Information on the federal program: Federal Agency: Department of Labor Pass-Through Entity: Indiana Department of Workforce Development Federal Program: WIOA Assistance Listing Number: 17.258, 17.259, 17.278 Compliance Requirement: Subrecipient Monitoring Audit Findings: Material Weakness, Qualified Opinion Criteria: Title 2 Subtitle A Chapter II Part 200 Subpart D, Section 200.331 and 200.332, establishes requirements that pass-through entities must adhere to in regard to their subrecipient grant agreements and the monitoring processes of those subrecipients. Condition: The EmployIndy subrecipient, Eckerd Connects, was reimbursed for personnel and fringe expenses that were allocated to the WIOA grants based off of a fixed allocation percentage for each Assistance Listing Number (ALN) instead of actual time worked on the grant. Cause: The condition was caused by a lack of internal controls over WIOA subrecipient/service provider claims for accrued expenditures. Effect: As a result of these matters, expenditures could be inaccurately charged to the federal grant. Questioned costs: There are no questioned costs. Context: During testing, Crowe identified monthly accrued expenditures of the Eckerd Connects subrecipient in which a fixed allocation for the separate WIOA grants was used each month to allocate personnel and fringe expenses. Identification as a repeat finding, if applicable: This is a repeat finding. Appeared as finding 2022-008 in the prior report. Recommendation: We recommend EmployIndy review subrecipient source documents to ensure accrued expenditures are appropriately supported by invoices or time-records showing time on task spent on specific grants. Views of responsible officials and planned corrective actions: Management acknowledges the finding. See management’s corrective action plan attached to this audit report.

Corrective Action Plan

Description of Corrective Action Plan: Prior to the completion of this audit, EmployIndy already made a number of changes to its financial operations. It parted ways with its Chief Financial Officer and procured the services of an outside Certified Public Accounting firm to begin the process of reviewing and updating its financial operations. In addition, it hired an Executive Vice President of Finance and Operations to lead the final development and implementation of updated financial processes. The Executive Vice President of Finance and Operations has worked with EmployIndy’s Board of Directors and Finance Committee to document a plan for improving EmployIndy’s financial operations across the board by the 2nd quarter of Calendar Year 2024. As part of the ongoing plan to improve its financial operations, EmployIndy Financial Operations, Grants & Contracts, and Program Management staff will work with WIOA subrecipients to update processes and provide any necessary training for documenting personnel costs that are charged to WIOA funding/cluster. WIOA subrecipients requesting reimbursements for personnel costs will be required to include staff timecards with documentation that shows the specific number of hours of work time charged to each program in the WIOA cluster. EmployIndy staff reviewing monthly invoices or accrued expenditure reports will be retrained on how to properly review subrecipient expenditures and supporting documentation prior to approval. Further, EmployIndy Financial and Program monitors will specifically review subrecipient time charging and invoicing activity to ensure that personnel costs are not allocated proportionately but based upon actual time worked within each program/cluster. Finally, Financial Operations, Grants & Contracts, and Program Leadership teams will receive further training on Uniform Administrative Requirements for Federal Awards to ensure there is greater understanding of documentation requirements necessary to support federal expenditures. Responsible Party and Timeline for Completion: Corrective Activity Responsible Party Timeline for Completion Develop training for subrecipient and contractor staff time charging and documentation requirements. Associate Director of Grants & Contracts, Controller 1st Quarter of Calendar Year 2024 Develop and provide updated training to EmployIndy Leadership on documentation requirements needed to approve subrecipient or contractor accrued expenditure reports or invoices that contain personnel costs Controller 1st Quarter of Calendar Year 2024 Deliver training to subrecipient and contractor staff time charging, submission, and documentation requirements Vice President of WorkOne, Vice President of Career Connected Learning, Vice President of Community Career Services 2nd Quarter of Calendar Year 2024 Update subrecipient monitoring process to review staff time charging and documentation requirements Associate Director of Grants & Contracts, Associate Director of Performance and Technical Assistance Completed in January 2024 Hold staff and subrecipients accountable for following processes Executive Vice President of Finance and Operations, EmployIndy Leadership Ongoing Complete training on Uniform Administrative Requirements for Federal Awards Financial Operations, Grants & Contracts, and Program Leadership Teams 1st Quarter of Calendar Year 2024

Categories

Subrecipient Monitoring Allowable Costs / Cost Principles Material Weakness

Other Findings in this Audit

  • 388133 2023-005
    Material Weakness Repeat
  • 388134 2023-005
    Material Weakness Repeat
  • 388135 2023-005
    Material Weakness Repeat
  • 388136 2023-005
    Material Weakness Repeat
  • 388137 2023-006
    Material Weakness Repeat
  • 388138 2023-006
    Material Weakness Repeat
  • 388139 2023-006
    Material Weakness Repeat
  • 388140 2023-006
    Material Weakness Repeat
  • 388142 2023-007
    Material Weakness Repeat
  • 388143 2023-007
    Material Weakness Repeat
  • 388144 2023-007
    Material Weakness Repeat
  • 388145 2023-008
    Material Weakness Repeat
  • 388146 2023-008
    Material Weakness Repeat
  • 388147 2023-008
    Material Weakness Repeat
  • 388148 2023-008
    Material Weakness Repeat
  • 388149 2023-009
    Material Weakness
  • 388150 2023-009
    Material Weakness
  • 388151 2023-009
    Material Weakness
  • 388152 2023-010
    Significant Deficiency
  • 388153 2023-010
    Significant Deficiency
  • 388154 2023-010
    Significant Deficiency
  • 964575 2023-005
    Material Weakness Repeat
  • 964576 2023-005
    Material Weakness Repeat
  • 964577 2023-005
    Material Weakness Repeat
  • 964578 2023-005
    Material Weakness Repeat
  • 964579 2023-006
    Material Weakness Repeat
  • 964580 2023-006
    Material Weakness Repeat
  • 964581 2023-006
    Material Weakness Repeat
  • 964582 2023-006
    Material Weakness Repeat
  • 964583 2023-007
    Material Weakness Repeat
  • 964584 2023-007
    Material Weakness Repeat
  • 964585 2023-007
    Material Weakness Repeat
  • 964586 2023-007
    Material Weakness Repeat
  • 964587 2023-008
    Material Weakness Repeat
  • 964588 2023-008
    Material Weakness Repeat
  • 964589 2023-008
    Material Weakness Repeat
  • 964590 2023-008
    Material Weakness Repeat
  • 964591 2023-009
    Material Weakness
  • 964592 2023-009
    Material Weakness
  • 964593 2023-009
    Material Weakness
  • 964594 2023-010
    Significant Deficiency
  • 964595 2023-010
    Significant Deficiency
  • 964596 2023-010
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
17.259 Wia Youth Activities $1.75M
17.258 Wia Adult Program $1.22M
21.027 Coronavirus State and Local Fiscal Recovery Funds $718,290
17.225 Unemployment Insurance $711,000
17.278 Wia Dislocated Worker Formula Grants $516,485
17.277 Covid-19 - Workforce Investment Act (wia) National Emergency Grants $253,114
17.285 Apprenticeship USA Grants $143,711
14.218 Community Development Block Grants/entitlement Grants $129,943
17.207 Employment Service/wagner-Peyser Funded Activities $120,000
84.425 Education Stabilization Fund $113,633
84.126 Rehabilitation Services_vocational Rehabilitation Grants to States $95,094