Finding 396005 (2023-004)

Material Weakness
Requirement
E
Questioned Costs
$1
Year
2023
Accepted
2024-05-06

AI Summary

  • Core Issue: There is a material weakness in internal controls regarding participant eligibility documentation, leading to potential compliance violations.
  • Impacted Requirements: Failure to comply with OMB Circular A-122 and 2 CFR Part 200 regarding documentation retention and eligibility verification.
  • Recommended Follow-Up: Implement stronger controls for obtaining and retaining required documentation, ensuring independent verification before program acceptance.

Finding Text

2023-004 Material Weakness in Internal Control and Compliance over Eligibility Federal Agency: U.S. Department of Health and Human Services Federal Program: 93.558, Temporary Assistance for Needy Families Cluster Criteria or Specific Requirement - OMB Circular A-122, Costs Principles for Non-Profit Organizations requires specific compliance with the provisions of allowable costs and activities. The Organization is responsible for having internal controls designed to ensure compliance with this provision. Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, require that, among other things, participants in the program meet certain eligibility requirements. In compliance with 2 CFR Part 200, Subpart D, Performance and Financial Monitoring and Reporting § 200.329, 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. Condition - During our testing of participant eligibility, we noted that certain required documentation for participation in the program had not been obtained and retained in the participant’s file. Cause - There is a lack of sufficient adherence to internal controls over document retention, independent review and approval of required items, and the organization and accuracy of supporting documentation. Effect - Lack of supporting documentation could result in the Organization being required to return funds received for providing services to ineligible participants. Additionally, the funding agency could impose compliance actions against the Organization. Questioned Costs - $180,071 Context - As part of our audit procedures, we sampled a total of 25 participants to test internal controls over compliance and compliance with the eligibility of federal awards. During our testing of participant eligibility, we noted the following deviations: - Three selections in our statistically valid sample lacked appropriate documentation to substantiate the participants’ health records were obtained within 60 days of enrollment in the program and subsequently retained by the Organization. Repeat Finding - No Recommendation - The Organization should implement controls and procedures for obtaining and retaining supporting documentation for all participants as required by the specific provisions of each contract or grant agreement pertaining to the federal program. Procedures should include the implementation of controls over document retention that would prevent acceptance into the program until all supporting documentation has been verified by an individual independent of the admission process. Views of Responsible Officials and Planned Corrective Actions - Out of over 182 compliance records requested, the Organization was unable to provide 3 health assessments, all other requested documentation was provided. The missing health assessments were for high school students, who are not required to provide them to attend school and often do not have access to updated health assessments. We have been directed by the funding agency never to exclude these youth from participation for an inability to obtain a health assessment. BGCP has already taken steps to address these issues. The funding agency, PHMC, has begun sending monthly compliance reports. Over the last three months, we have collected 42% of missing health assessments organization-wide. Additionally, on our recent FY24 Admin review from PHMC, which included a full compliance report, all of our sites received overall scores of above 95%. We will continue to monitor compliance and follow-up with youth and families to complete needed items.

Categories

Questioned Costs Allowable Costs / Cost Principles Eligibility Subrecipient Monitoring Material Weakness Reporting Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 395990 2023-002
    Material Weakness Repeat
  • 395991 2023-002
    Material Weakness Repeat
  • 395992 2023-003
    Material Weakness Repeat
  • 395993 2023-003
    Material Weakness Repeat
  • 395994 2023-003
    Material Weakness Repeat
  • 395995 2023-003
    Material Weakness Repeat
  • 395996 2023-003
    Material Weakness Repeat
  • 395997 2023-003
    Material Weakness Repeat
  • 395998 2023-003
    Material Weakness Repeat
  • 395999 2023-003
    Material Weakness Repeat
  • 396000 2023-003
    Material Weakness Repeat
  • 396001 2023-003
    Material Weakness Repeat
  • 396002 2023-003
    Material Weakness Repeat
  • 396003 2023-003
    Material Weakness Repeat
  • 396004 2023-004
    Material Weakness
  • 396006 2023-005
    -
  • 396007 2023-005
    -
  • 396008 2023-005
    -
  • 396009 2023-005
    -
  • 396010 2023-005
    -
  • 396011 2023-005
    -
  • 396012 2023-005
    -
  • 396013 2023-005
    -
  • 396014 2023-005
    -
  • 396015 2023-005
    -
  • 396016 2023-005
    -
  • 396017 2023-005
    -
  • 972432 2023-002
    Material Weakness Repeat
  • 972433 2023-002
    Material Weakness Repeat
  • 972434 2023-003
    Material Weakness Repeat
  • 972435 2023-003
    Material Weakness Repeat
  • 972436 2023-003
    Material Weakness Repeat
  • 972437 2023-003
    Material Weakness Repeat
  • 972438 2023-003
    Material Weakness Repeat
  • 972439 2023-003
    Material Weakness Repeat
  • 972440 2023-003
    Material Weakness Repeat
  • 972441 2023-003
    Material Weakness Repeat
  • 972442 2023-003
    Material Weakness Repeat
  • 972443 2023-003
    Material Weakness Repeat
  • 972444 2023-003
    Material Weakness Repeat
  • 972445 2023-003
    Material Weakness Repeat
  • 972446 2023-004
    Material Weakness
  • 972447 2023-004
    Material Weakness
  • 972448 2023-005
    -
  • 972449 2023-005
    -
  • 972450 2023-005
    -
  • 972451 2023-005
    -
  • 972452 2023-005
    -
  • 972453 2023-005
    -
  • 972454 2023-005
    -
  • 972455 2023-005
    -
  • 972456 2023-005
    -
  • 972457 2023-005
    -
  • 972458 2023-005
    -
  • 972459 2023-005
    -

Programs in Audit

ALN Program Name Expenditures
84.287 Twenty-First Century Community Learning Centers $471,913
93.575 Child Care and Development Block Grant $401,441
10.558 Child and Adult Care Food Program $328,969
14.881 Moving to Work Demonstration Program $194,258
10.559 Summer Food Service Program for Children $108,549
93.558 Temporary Assistance for Needy Families $41,300
21.027 Coronavirus State and Local Fiscal Recovery Funds $27,954
84.425 Education Stabilization Fund $11,296
16.726 Juvenile Mentoring Program $4,993