Finding 479533 (2023-005)

Significant Deficiency
Requirement
E
Questioned Costs
$1
Year
2023
Accepted
2024-07-26

AI Summary

  • Core Issue: Five participants were found ineligible for WIOA programs due to prior participation or being fully employed, violating eligibility criteria.
  • Impacted Requirements: The organization lacks documented policies for determining and reviewing participant eligibility, leading to significant deficiencies in compliance controls.
  • Recommended Follow-Up: Develop and document eligibility processes, implement a recurring training program for staff, and ensure a review system is in place for participant applications by June 30, 2024.

Finding Text

Reference Number: 2023-005 – Ineligible Participants Federal Program Title: WIOA Cluster Federal Assistance Listing Number: 17.258 Federal Agency: Department of Labor (DOL) Pass-Through Entity: State of California Employment Development Program Federal Award Number and Year: AA211079, 170305366 Category of Finding: Eligibility Type of Finding: Significant Deficiency in Internal Control over Compliance, Instance of Noncompliance Criteria In accordance with Section 3 WIOA, 128 Stat. 1431 and grant agreements, participants must meet the WIOA definition of adult, dislocated worker, or dislocated homemaker and must not have previously participated in any WIOA program to be eligible to participate. Condition During our review of participant eligibility, we noted five (5) participants were ineligible for the as follows: (1) One (1) participant was ineligible due to previously participating in a WIOA program with the Organization. (2) Four (4) participants were ineligible due to being fully employed and did not meet the definition of either dislocated worker per Section 3(15), WIOA, 128 Stat. 1431 or dislocated homemaker per Section 3(16), WIOA, 128 Stat. 1432. Cause The Organization has experienced significant turnover in key personnel in the Organization’s finance department and management in past years. Absent robust accounting policies and procedures, when vacancies occur, information can be lost and as individuals are getting up to speed, some processes may not be fully executed if they are manual and not fully embedded into an automated system. Effect The Organization has no documented policies and procedures for determining eligibility and for reviewing eligibility. Questioned Costs We identified costs of $8,774 that could be considered questionable. We are unable to estimate total likely questioned costs. Context For the forty (40) participants selected for testing, five (5) were found to be ineligible. The sample was not a statistically valid sample. Recommendation We recommend that the Organization develop and document processes for determining participant eligibility and for reviewing case manager determination of participant eligibility. We also recommend the Organization develop a recurring training program for staff involved with grant processes and procedures and compliance requirements. Views of Responsible Officials and Planned Corrective Action Person responsible: Leona Smith Di Faustino, Interim Executive Director Corrective Action Plan: During the period being audited internal controls for program participants documents were not reviewed by the former Executive Director. The new Executive Director has implemented a check and balance procedure that requires the Case Manager, Program Manager, and Executive Director to review and sign off on participant application forms and to be documented on the participants application before the participant can move forward in the program. Anticipated Implementation Date: June 30, 2024

Corrective Action Plan

During the period being audited internal controls for program participants documents were not reviewed by the former Executive Director. The new Executive Director has implemented a check and balance procedure that requires the Case Manager, Program Manager, and Executive Director to review and sign off on participant application forms and to be documented on the participants application before the participant can move forward in the program.

Categories

Questioned Costs Eligibility Subrecipient Monitoring Significant Deficiency

Other Findings in this Audit

  • 479529 2023-001
    Significant Deficiency
  • 479530 2023-002
    Material Weakness
  • 479531 2023-003
    Significant Deficiency
  • 479532 2023-004
    Significant Deficiency
  • 479534 2023-006
    Significant Deficiency
  • 1055971 2023-001
    Significant Deficiency
  • 1055972 2023-002
    Material Weakness
  • 1055973 2023-003
    Significant Deficiency
  • 1055974 2023-004
    Significant Deficiency
  • 1055975 2023-005
    Significant Deficiency
  • 1055976 2023-006
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
17.258 Wia Adult Program $859,782
93.959 Block Grants for Prevention and Treatment of Substance Abuse $557,048