Finding 480062 (2021-005)

Material Weakness
Requirement
E
Questioned Costs
-
Year
2021
Accepted
2024-07-31

AI Summary

  • Core Issue: There is a material weakness in internal controls over compliance, specifically regarding eligibility documentation for the Emergency Solutions Grants (ESG) Program.
  • Impacted Requirements: The Organization failed to maintain necessary controls, resulting in 20 out of 46 individuals lacking documented eligibility forms.
  • Recommended Follow-up: Implement robust controls to ensure compliance with eligibility requirements, including proper retention of eligibility documentation.

Finding Text

Eligibility Material Weakness in Internal Control over Compliance and Material Noncompliance Emergency Solutions Grants (ESG) Program, Assistance Listing Number 14.231 Criteria: The Organization is required to maintain controls to ensure compliance with the terms of the grants which it negotiates with the federal government and is required to comply with the terms of the grant agreements to include eligibility. Condition: Twenty (20) of 46 individuals receiving services under the grant selected for testing did not have documented eligibility forms to reflect that the individuals were eligible to receive funds or services. During the period of the grant, we noted the Organization did not have documented controls in place to ensure that individuals were eligible to receive funds. Cause/Effect: Evidence of eligibility was not available over some individuals. Without appropriate documentation of eligibility, there is no degree of certainty that the individual was eligible to receive funds from Cornerstones, Inc.. Questioned costs: Unknown Context: Our sample was not intended to be statistically valid. Identification of prior audit finding: N/A Recommendation: The Organization should ensure that it has controls in place to monitor compliance with eligibility to include proper retention of eligibility forms. Views of responsible officials and planned corrective actions: Management’s response is reported in “Management’s Views and Corrective Action Plan” included at the end of this report.

Corrective Action Plan

Cornerstones acknowledges that our files were incomplete. It is our position that the COVID-19 pandemic created immense need to which Cornerstones responded by expanding rapidly and mobilizing funding and program requests that did not receive the benefit of comprehensive planning; the focus was on health prevention, isolation and quarantine activities and temporary shelter for homeless and other low-income, vulnerable seniors and disabled persons. We served those in need and our intake processes and record keeping did not keep pace. Additionally, given the time that has passed since the services in question, it is possible that records that did exist were misplaced. Staff turnover, resulting from the pandemic burden, made it challenging to go back to the work that had been done. In the time since these events Cornerstones has further emphasized the compliance and documentation needs of the case management process, and we have filled turned-over positions with experienced staff that also understand intake and documentation requirements. We have also hired a Senior Director, Finance with over 20 years of federal contracts experience that is an integral part of increased program compliance and operational oversight responsibilities within the Finance/Operations function.

Categories

Eligibility Material Weakness Internal Control / Segregation of Duties

Other Findings in this Audit

  • 480063 2021-005
    Material Weakness
  • 480064 2021-005
    Material Weakness
  • 1056504 2021-005
    Material Weakness
  • 1056505 2021-005
    Material Weakness
  • 1056506 2021-005
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
14.239 Home Investment Partnerships Program $3.70M
14.218 Community Development Block Grants/entitlement Grants $375,916
14.231 Emergency Solutions Grant Program $336,235
93.569 Community Services Block Grant $125,692
14.169 Housing Counseling Assistance Program $62,250
97.024 Emergency Food and Shelter National Board Program $37,733
10.558 Child and Adult Care Food Program $33,874