Finding 526316 (2024-002)

Significant Deficiency
Requirement
E
Questioned Costs
-
Year
2024
Accepted
2025-03-07
Audit: 345244
Organization: Commonwealth Cahtolic Charities (VA)

AI Summary

  • Core Issue: The Organization lacks a formal review process for verifying eligibility of "walk-in" participants in the Refugee and Entrant Assistance program.
  • Impacted Requirements: Internal controls over compliance with federal regulations are insufficient, risking benefits being granted to ineligible individuals.
  • Recommended Follow-Up: Implement a secondary review process for participant eligibility, requiring signature approval from a program manager or director.

Finding Text

Eligibility Significant Deficiency in Internal Control over Compliance Refugee and Entrant Assistance – State Administered Programs Criteria: The Organization is required to establish internal controls over compliance in order to evaluate and monitor compliance with federal statutes, regulations, and terms and conditions of their awards. Condition: The Organization did not have evidential review of eligibility by a program manager or director for participants in the program that were noted to be “walk-ins”. Cause: Documentation supporting eligibility for the program was maintained in case files for walk-in participants, however the Organization had no formal internal control review to ensure these participants were in fact eligible. Effect of potential effect: Benefit may be provided to an individual who is not eligible under the grant agreement. Questioned costs: None. Context: The deficiency was noted 12 times in a sample of 40. In all cases, there was no identified deficiency in compliance. The deficiency was deemed to be isolated to walk-in participants. Identification of prior period finding: Not a repeat finding. Recommendation: Recommendation is for the Organization to develop a secondary review of eligibility of participants with signature evidence of a program manager or director. 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

Action Plan: CCC’s managerial and quality assurance review processes include reviews of all client files to ensure appropriate documentation of eligibility, services rendered, and client progress. These reviews happen at intake and periodic intervals to ensure the accuracy and quality of the client record. We acknowledge that in some cases, management did not specifically document the management review of eligibility documentation, however the review process did ensure that all files did include appropriate documentation of client eligibility. Moving forward, we will ensure that all client files specifically evidence managerial confirmation of client eligibility with one or more of the following: 1. a signed checklist containing potential eligibility documents 2. a signature on the actual eligibility document or referral 3. an electronic case note to the file confirming review and presence of eligibility documentation. We have already begun working with relevant departments to implement these improvements and will monitor the implemented changes to ensure their effectiveness as we are committed to maintaining and enhancing our internal controls environment and the quality of services provided to the individuals and families we serve.

Categories

Eligibility Significant Deficiency Internal Control / Segregation of Duties

Other Findings in this Audit

  • 526317 2024-002
    Significant Deficiency
  • 526318 2024-002
    Significant Deficiency
  • 1102758 2024-002
    Significant Deficiency
  • 1102759 2024-002
    Significant Deficiency
  • 1102760 2024-002
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
93.676 Unaccompanied Children Program $2.92M
14.241 Housing Opportunities for Persons with Aids $1.33M
93.566 Refugee and Entrant Assistance State/replacement Designee Administered Programs $1.19M
19.510 U.s. Refugee Admissions Program $859,525
93.576 Refugee and Entrant Assistance Discretionary Grants $685,018
14.267 Continuum of Care Program $641,144
93.918 Grants to Provide Outpatient Early Intervention Services with Respect to Hiv Disease $378,525
93.567 Refugee and Entrant Assistance Voluntary Agency Programs $299,418
14.276 Youth Homelessness Demonstration Program $250,009
21.027 Coronavirus State and Local Fiscal Recovery Funds $89,923
93.556 Marylee Allen Promoting Safe and Stable Families Program $64,500
14.169 Housing Counseling Assistance Program $53,549
10.766 Community Facilities Loans and Grants $50,000
93.590 Community-Based Child Abuse Prevention Grants $44,520
93.598 Services to Victims of A Severe Form of Trafficking $17,284
14.218 Community Development Block Grants/entitlement Grants $13,744
16.574 Criminal Justice Discretionary Grant Program $8,082