Finding 547043 (2024-005)

Material Weakness Repeat Finding
Requirement
ABE
Questioned Costs
-
Year
2024
Accepted
2025-03-31

AI Summary

  • Core Issue: Ineligible participants received payments due to weak internal controls and lack of oversight.
  • Impacted Requirements: TANF funding eligibility criteria and documentation standards were not met, leading to improper disbursements.
  • Recommended Follow-Up: Strengthen documentation and review processes for participant eligibility and payment approvals.

Finding Text

Finding 2024-005: Activities Allowed and Allowable Costs and Eligibility - see prior year finding 2023-005 Criteria TANF funds monthly cash assistance payments to low-income families with children. The Homeless Veterans Comprehensive Service Programs Act of 1992 (Public Law 102-590) established the VA Homeless Providers Grant and Per Diem Program to fund the costs of creating or improving transitional supportive housing facilities or services centers, and grants to support case managers to assist Veterans in attaining or retaining permanent housing. Condition/Context Based on a report by a forensic investigator and Catholic Charities it was determined supportive service expenditures were processed and paid for ineligible participants. However, based on the same report it was determined there could be additional costs that were processed and paid for ineligible participants. In addition, due to Wipfli LLP's audit procedures it was determined that the breakdown in internal controls over the review of participant eligibility and review of payments made for participants was significant and we cannot obtain sufficient audit evidence to support these payments or participant eligibility. Cause Due to lack of supervisory oversight and lack of review of required documentation to support invoices to be paid to participants, several employees falsified participant documents whereby ineligible individuals with personal relationships to these employees receive assistance payments. Effect Management became aware of the improprieties and hired an independent forensic investigator. The forensic investigator identified improper disbursements to ineligible participants along with other disbursements that required further research, inconclusive, insufficient, unverified, and LLC discrepancy disbursements. Recommendation Management should strengthen controls over documentation required for participants to receive assistance payments along with controls over review of documentation in participant files and processing of these payments. View of Responsible Officials Management agrees with the recommendation and have begun implementing additional procedures to ensure applicant files are complete and case files and support are being reviewed by supervisory personnel.

Corrective Action Plan

Corrective Action The improper activity was identified in October 2023 and the following actions were subsequently taken: • Two caseworks and a supervisor were terminated. • The agency's Executive Director retired. • The agency's Controller was temporarily elevated to Interim Administrator, overseeing day-to-day operations and reviewing all agency disbursements. • The central accounting department revised the check processing procedures to ensure that the following documentation accompanied housing related check requests: o W-9 signed by the vendor o A signed Promissory Agreement from the client, landlord and caseworker if the agency is paying Rent/Sec Dep. o Proof of Ownership for the property (Deed, Tax bill, NJ Parcels website) documentation. The Proof of Ownership documentation must match the W-9. Management has taken steps to ensure that the rental properties for which assistance will be rendered are in fact owned by the landlord stated on the lease. o Copy of an executed rental lease. o Rent Ledger, or a letter from the Landlord on their letterhead detailing client past and overdue charges/payments. Should include dates, amounts, etc. o Proof of Hardship - case management notes detailing hardship are sufficient for the Accounting Dept, although not necessarily sufficient for the requirement of the grant. • Policy changes with regard to check distribution have been modified. All checks are mailed directly to the vendor/payee from the central accounting department. • Two supervisors replaced the one terminated supervisor in order to ease the amount of supervision duties tasked to one person. • A new Executive Director for the Organization was hired in February 2024. • Created and filled the position of Grants Compliance Specialist. This position is responsible to: o Review, revise and create, where needed, policies/procedures to ensure that 0MB Uniform Administrative Requirements are being considered and followed in the administering of all grant funding. o Responsible for regularly reviewing client files on a judgmental basis in order to ensure adherence to the agency's policies and procedures. • Mandated the universal use of ETO Case Management Solution as the soul repository of client information, case notes with a link to electronic client documentation files on the agency network. This provides electronic access to client case files as well as an electronic audit trail. Projected Completion Date As mentioned, the actions note above have been implemented. Management and the Grant Compliance Specialist continue to review, modify and communicate policies/procedures with all case management staff. Contact Person Robert Waite, Controller 856-342-4186; robert.waite@camdendiocese.org If you have questions or concerns regarding this Plan, please reach out to Robert Waite, Controller using the phone number or email address above. Robert T Waite, Controller

Categories

Internal Control / Segregation of Duties Eligibility Allowable Costs / Cost Principles

Other Findings in this Audit

  • 547041 2024-003
    Material Weakness Repeat
  • 547042 2024-004
    Material Weakness Repeat
  • 547044 2024-005
    Material Weakness Repeat
  • 547045 2024-005
    Material Weakness Repeat
  • 547046 2024-005
    Material Weakness Repeat
  • 547047 2024-005
    Material Weakness Repeat
  • 547048 2024-006
    Material Weakness Repeat
  • 547049 2024-006
    Material Weakness Repeat
  • 547050 2024-006
    Material Weakness Repeat
  • 547051 2024-006
    Material Weakness Repeat
  • 1123483 2024-003
    Material Weakness Repeat
  • 1123484 2024-004
    Material Weakness Repeat
  • 1123485 2024-005
    Material Weakness Repeat
  • 1123486 2024-005
    Material Weakness Repeat
  • 1123487 2024-005
    Material Weakness Repeat
  • 1123488 2024-005
    Material Weakness Repeat
  • 1123489 2024-005
    Material Weakness Repeat
  • 1123490 2024-006
    Material Weakness Repeat
  • 1123491 2024-006
    Material Weakness Repeat
  • 1123492 2024-006
    Material Weakness Repeat
  • 1123493 2024-006
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
64.033 Va Supportive Services for Veteran Families Program $1.63M
93.558 Temporary Assistance for Needy Families $248,435
14.231 Emergency Solutions Grant Program $195,527
93.576 Refugee and Entrant Assistance_discretionary Grants $76,875
14.228 Community Development Block Grants/state's Program and Non-Entitlement Grants in Hawaii $72,542
19.510 U.s. Refugee Admissions Program $44,522
97.024 Emergency Food and Shelter National Board Program $12,015
93.566 Refugee and Entrant Assistance_state Administered Programs $2,136