Finding 47214 (2022-001)

Significant Deficiency Repeat Finding
Requirement
E
Questioned Costs
-
Year
2022
Accepted
2023-10-01
Audit: 52830
Organization: Wellspring Family Services (WA)
Auditor: Clark Nuber P S

AI Summary

  • Core Issue: There is a lack of clarity and agreement on who is responsible for determining eligibility for the Moving to Work Demonstration Program, leading to compliance testing limitations.
  • Impacted Requirements: The inability to confirm eligibility compliance means we cannot assess adherence to federal program requirements, affecting our audit opinion.
  • Recommended Follow-Up: Wellspring should establish clear internal controls to verify compliance responsibilities before accepting grant awards to avoid future issues.

Finding Text

Finding 2022-001 Auditor scope limitation over applicability and determination of eligibility requirements Federal Agency: Department of Housing and Urban Development Program Title: Moving to Work Demonstration Program Federal Assistance Number: 14.881 Award Number: SC-108463-1 Award Period: July 1, 2021 through June 30, 2022 Federal Agency: Department of Housing and Urban Development Program Title: Moving to Work Demonstration Program Federal Assistance Number: 14.881 Award Number: SC-107790 Award Period: June 1, 2020 through August 31, 2022 Criteria The auditor is required to test compliance requirements that are determined to be direct and material to the Federal major program. Condition/Context for Evaluation We were unable to determine if eligibility was direct and material to the federal major program being tested for the following reasons: ? The grantor and Wellspring are not in agreement as to the responsibilities over the determination of eligibility. ? The contracts lack clarity and are contradictory as to whether Wellspring or other parties are responsible for the determination of eligibility. ? Wellspring asserts and has received an outside legal opinion that Wellspring was not responsible for the determination of eligibility. ? In 2022, Pierce County issued a monitoring report asserting Wellspring was not in compliance with the determination of eligibility. Wellspring has vigorously disputed the findings in the report. Since we cannot obtain sufficient evidence to determine adherence to compliance requirements, we have qualified our opinion on compliance related to eligibility due to a scope limitation. Effect or Potential Effect An opinion on compliance over eligibility requirements was not able to be determined due to a scope limitation. Questioned Costs Not determinable. Cause Wellspring asserts that the contracts between Wellspring and Pierce County (the County) lack any formal guidance from the County. As such, Wellspring implemented internal controls based its interpretation of the compliance requirements. Repeat Finding Repeat of finding 2021-003. Recommendation We recommend that Wellspring implement internal controls to ensure that Wellspring?s responsibilities over compliance with specific grant terms are verified before entering into the award. Views of Responsible Officials of Auditee Management agrees with the finding and has provided the accompanying corrective action plan.

Corrective Action Plan

Finding Number 2022-001: Significant deficiency in internal controls over applicability and determination of eligibility requirements. Contact Person(s): Cobie Sparks-Howard, Director of Housing Services; Calli Clevinger, Housing Program Manager Corrective Action Plan: Wellspring has a long tradition of beginning work prior to having a signed contract in hand for ongoing programs. Wellspring recognizes the urgency of its clients? needs and wishes to help. However, beginning work prior to having a signed contract for a new program meant that systems and training were completed before Wellspring knew the terms of the contract. Beginning in 2023, Wellspring will no longer begin work prior to receiving a signed contract for a new program. Second, contracts often contain provisions that impact several areas within the agency, such as systems, finance, human resources, and programs. However, prior to 2023, contracts were generally reviewed by a limited number of individuals prior to being signed and were circulated among the broader team inconsistently. As a result, there was no centralized control over whether the terms of the contract were reviewed by the responsible party or implemented appropriately. Wellspring identified this as an issue in 2021 and instituted monthly contract meetings. However, it soon became evident that we needed a central tracking system and approval process in order to ensure compliance. Wellspring is currently in the process of building a contract management system that will manage both the approval process and the compliance aspects of our contracts. We expect this system to be fully implemented by September 30, 2023. Finally, in 2022, Wellspring hired a new and experienced housing director who has established new internal controls at the program level, including quarterly internal audit review procedures. Anticipated completion date: June 30, 2023.

Categories

Subrecipient Monitoring Eligibility Internal Control / Segregation of Duties

Other Findings in this Audit

  • 47215 2022-001
    Significant Deficiency Repeat
  • 623656 2022-001
    Significant Deficiency Repeat
  • 623657 2022-001
    Significant Deficiency Repeat

Programs in Audit

ALN Program Name Expenditures
14.881 Moving to Work Demonstration Program $580,896
93.434 Every Student Succeeds Act/preschool Development Grants $200,000
14.267 Continuum of Care Program $111,694
21.027 Coronavirus State and Local Fiscal Recovery Funds $85,460