Finding Text
Reference Number: 2024-005 – Missing Selective Service Registration
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 Department
Federal Award Number and Year: AA211079 Fiscal Year 2023-2024
Category of Finding: Eligibility
Type of Finding: Significant Deficiency in Internal Control over Compliance, Instance of Noncompliance
Criteria
In accordance with Section 188(h) WIOA, 128 Stat. 1599 and Title 50 United States Code “Military Selective Service Act,” Appendix 453, males who are who are subject to the registration requirements of the Military Selective Service Act must have complied with these requirements to be eligible for participation in WIOA-funded programs and services.
Condition
During our review of participant eligibility, we noted the Organization was unable to provide adequate supporting documentation for selective service registration for three (3) participants.
Cause
Due to significant turnover in key personnel in the Organization’s finance department and management in past years, the Organization has no documented policies and procedures for determining eligibility and for reviewing eligibility.
Effect
Failure to adequately document and maintain support for eligibility determinations may result in non-compliance with WIOA regulations and there is risk that federal funds may be used on ineligible participants.
Questioned Costs
Questioned costs were not determinable.
Context
For the thirty-nine (39) participants selected for testing, nineteen (19) were required to comply with the selective service registration requirements. From these nineteen (19), the Organization was unable to provide adequate supporting documentation for selective service registration for three (3) participants.
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: July 1, 2025