Finding 391936 (2023-001)

Federal Program: Assisting Listing No.16.575 Office for Victims of Crime (OVC) - Crime Victim Assistance Program Category: Internal Control/Compliance Compliance Requirement: Record retention Condition: The Organization could not make accessible part of the supporting documents for one (1) student file, from a sample of ten (10) items. The request for the student file was identified as identification number 8588. Criteria: §200.334 Retention requirements for records establish that “Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award, must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient.” §200.337 Access to records establish that “(a) Records of non-Federal entities. The Federal awarding agency, Inspectors General, the Comptroller General of the United States, and the pass-through entity, or any of their authorized representatives, must have the right of access to any documents, papers, or other records of the non-Federal entity which are pertinent to the Federal award, in order to make audits, examinations, excerpts, and transcripts. The right also includes timely and reasonable access to the non-Federal entity's personnel for the purpose of interview and discussion related to such documents.” Condition: The internal procedure manual of this program does not include a provision for record retention of participant records organization. Cause: One of ten student's record cannot be found, possibly misplaced, or misfiled, despite following the usual procedures for archiving upon graduation or withdrawal. These processes involve transferring records to either the graduate or inactive files within the premises of the organization. However, the sought-after record was not located in any of these designated areas. According to regulations, the record of the student who dropped out on May 30, 2023, should have been archived in the records of students who withdrew. Effects: Condition may result in noncompliance with the requirements of record retention. Questioned Costs: None Recommendation: ● Thorough file review - Conduct a comprehensive search in all relevant archives, including those of graduates, inactive students, and those who withdrew. Ensure to examine each file carefully to avoid overlooking the missing record. ● Procedures review and staff training - Evaluate current record management procedures and identify areas for improvement. Provide additional training to staff on the importance of maintaining proper record organization and specific steps to handle situations like this. Management’s response: ● It is important to emphasize that even when one section in one file was not located from a sample of ten items. The general information of that participant and the evidence of services provided were kept in records, in a file. The Executive President prepared a memorandum to discuss discipline actions with the Board of Directors, including all parties involved in the process. ● An external consultant will be selected to specifically evaluate current records management procedures and identify areas for improvement, including staff training. Training will begin on May 1, 2024. ● The Compliance Director prepared a corrective action plan that the Executive President will present to the Board of Directors on April 2024, that includes: ○ A “Records Management Policy” in accordance with the criteria §200.334 and §200.337, which covers all federal and state regulations in relation to the Programs administered by Nuestra Escuela. ○ A calendar of internal monitoring to review compliance with the Special Conditions of each contract. ○ A digital record of the files and a monthly control of the General Archive. ○ A Training Program for each of the departments of Nuestra Escuela that includes a protocol for identifying off-site documents.