Finding 564598 (2024-002)

Significant Deficiency

Requirement

Questioned Costs

Year

2024

Accepted

2025-06-12

Audit: 358729

Organization: National Indian Youth Council, Inc. (NM)

Auditor: Jaramillo Accounting Group LLC

AI Summary

Core Issue: One application out of 40 did not have the necessary documentation to prove eligibility under WIOA, specifically missing tribal affiliation, residency proof, and public assistance status.
Impacted Requirements: This finding violates federal compliance standards and internal policies requiring verifiable documentation for eligibility determinations.
Recommended Follow-up: Improve file management protocols to prevent loss of documentation and ensure all eligibility files are complete and secure.

Finding Text

2024-002 INSUFFICIENT WIOA ELIGIBILITY DOCUMENTATION Federal Agency: U.S. Department of Labor Federal Program and Assistance Listing Number: 17.265 Type of Finding: Significant Deficiency, Non-compliance Compliance Area: Eligibility Award Period: National Employment and Training (07/01/2022-06/30/2025) National Employment and Training (06/01/2023-06/30/2026) Questioned Costs: None Condition: 1 out of 40 sampled applications lacked sufficient documentation to support eligibility under WIOA Section 166. Specifically, the file was missing verification of tribal affiliation, proof of residency, and documentation of public assistance status. Criteria: Per 2 CFR §200.303 and §200.430, recipients of federal funds must establish and maintain effective internal controls to ensure compliance with federal statutes, regulations, and the terms and conditions of the award. The NIYC-WIOA Policy Manual requires that eligibility determinations be supported by verifiable documentation, including tribal enrollment records, residency verification, and evidence of low-income or public assistance status. Effect: Failure to maintain complete eligibility documentation may result in noncompliance with federal program requirements, potential disallowed costs, and increased risk of audit findings or funding claw backs. Cause: The missing documentation was attributed to a participant file being misplaced during a staff transition, indicating a lack of centralized and secure file management protocols.

Corrective Action Plan

Recommendation Implement a centralized, access-controlled digital system for participant file storage. Additionally, management should require the use of a standardized eligibility checklist and conduct periodic file audits to ensure documentation completeness and compliance with WIOA requirements. Management Response Corrective Action: In response to this incident, we have reinstated the Eligibility Determination and Intake (EDIR) Form. This form clearly states the participant identification information, the characteristics tracked by our program data management tool (GPMS), and states what has been provided by the participant to determine their eligibility for the program. Provided in a check list format, the form clearly demonstrates what makes the participant eligible for our program services. The form also lists the documentation included in the application that has been provided by the participant. This form added to the program application and maintained in the participant's official record will ensure that all WIOA eligibility documentation has been received, reviewed, and approved at the time of intake. Due Date of Completion: Completed as of May 31, 2025 Responsible Person(s):Director of Programs and Development is responsible for re-instating the use of the form and the Field Office Managers and Job Developers are responsible for filling out the form and including it in the participant's official record.

Other Findings in this Audit

564597 2024-001

Significant Deficiency Repeat
564599 2024-003

Significant Deficiency
1141039 2024-001

Significant Deficiency Repeat
1141040 2024-002

Significant Deficiency
1141041 2024-003

Significant Deficiency

Programs in Audit

ALN	Program Name	Expenditures
17.265	Native American Employment and Training	$1.97M