Finding 588326 (2023-001)

Section III - Federal Award Findings and Questioned Costs Significant deficiency in internal controls over eligibility requirements. Federal Agency: United States Department of Labor AL Number/Title: 17.235/Senior Community Services Employment Program Pass-Through Entity: Goodwill Industries International Award Numbers: AD-33650-19-60-A24; AD-35214-20-60-A-24; 23A60AD000034-01-00; YF-39532-23-60-A-24 Criteria Per the standards contained in Title 2 US Code of Federal Regulations (CFR) Uniform Administrative Requirements, Cost Principles and Audit Requirement for Federal Awards, Subpart D ‐ Post Federal Award Requirements, Section 200.303, non‐federal entities are required to establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non‐Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The Federal awards referenced require that eligible participants’ household earnings do not exceed specific income thresholds as outlined in Title 20 CFR, Section 641.500 and that participant eligibility is redetermined on an annual basis in accordance with Title 20 CFR Section 641.505. Condition/Context for Evaluation The Organization's internal compliance controls require that each participant’s household income is certified prior to admission to the program and then recertified annually thereafter in accordance with Title 20 CFR, Section 641.505. During testing for the year ended September 30, 2023, we noted that for two of the thirteen participants selected, while initial income certifications were performed, controls did not operate effectively to ensure the annual recertifications for the period under audit occurred. Eight of the thirteen selections required an annual recertification procedure. Questioned Costs Not applicable. Effect or Potential Effect Eligibility determinations were not completed in accordance with the requirements of the Federal awards. Cause The Organization’s internal controls over compliance did not operate effectively to recertify accurate eligibility determinations for participants. Repeat Finding Not applicable as no similar finding was noted in the prior year audit of the Organization.