Finding 7903 (2022-004)

Significant Deficiency
Requirement
L
Questioned Costs
-
Year
2022
Accepted
2024-01-08

AI Summary

  • Core Issue: LIFE failed to verify consumer goal classifications in the ILS and DRS systems for 1 out of 49 consumers tested.
  • Impacted Requirements: This violates 2 CFR 200.303 regarding internal controls and ILS Program Standards 5.6.3.5, which require accurate documentation of consumer goals.
  • Recommended Follow-Up: Implement stronger internal controls to ensure accurate reporting of consumer goals and conduct regular audits to verify compliance.

Finding Text

ALN: 84.126 Federal Award Title: Rehabilitation Services Vocational Rehabilitation Grants to States Federal Agency: United States Department of Education Pass-Through Entity: Texas Health and Human Services Commission Award Number(s): HHS000186000005, HHS000202900008 Federal Award Year: 2022 Condition: LIFE was not verifying the classification of consumer goals agreed in the ILS system and DRS system on 1 of 49 consumers tested. In addition, inaccurate listings of consumers were initially provided to the auditors. Criteria: 2 CFR 200.303 requires a non-Federal entity 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. These internal controls should be in compliance with guidance in ‘‘Standards for Internal Control in the Federal Government’’ issued by the Comptroller General of the United States and the ‘‘Internal Control Integrated Framework’’, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Per ILS Program Standards 5.6.3.5 Revision 19-1, all entries to the Independent Living Services Data Reporting System made by the service provider will be considered a part of the consumer case file. Each consumer case file must minimally meet the requirements of 34 CFR, Subtitle B, Chapter III, Part 364, §364.53, and provide documentation concerning: the consumer’s goals for independence and anticipated methods and services to achieve the goals. Effect: The classification of consumer goals reported and tracked in the DRS system may have been reported in the wrong category. Cause: Lack of internal controls at LIFE to ensure that consumer goals are reported correctly in both the ILS and DRS system and accurate reports are generated. Questioned Costs: No questioned costs identified.

Corrective Action Plan

2022-004 – Classification of Consumer Goals – Significant Deficiency in Internal Controls over Compliance Recommendation: The auditor recommends LIFE strengthen policies and procedures over the classification of consumer goals to ensure that the goals in the ILS and DRS systems match and are recorded in the correct categories as defined by ILS Program Standards 5.6.1 Revision 19-1. Action Taken: LIFE Management will: • Conduct a comprehensive review of existing policies/procedures related to the classification of Consumer goals. • Outline the steps for correctly classifying Consumer goals in line with Program Standards. • Conduct mandatory training sessions for all relevant staff on the classification of Consumer goals to ensure understanding and compliance. • Working with the Purchased Services staff, review the goal status of each Consumer at closure, including comparing goals on both data collection systems. • Conduct monthly quality assurance checks and internal audits to ensure the correct classification of Consumer goals. Due Date of Completion: November 30, 2023 Responsible Official: Director of Programs

Categories

Subrecipient Monitoring Reporting Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Other Findings in this Audit

  • 7901 2022-002
    Significant Deficiency
  • 7902 2022-003
    Significant Deficiency
  • 7904 2022-002
    Significant Deficiency
  • 7905 2022-003
    Significant Deficiency
  • 7906 2022-004
    Significant Deficiency
  • 584343 2022-002
    Significant Deficiency
  • 584344 2022-003
    Significant Deficiency
  • 584345 2022-004
    Significant Deficiency
  • 584346 2022-002
    Significant Deficiency
  • 584347 2022-003
    Significant Deficiency
  • 584348 2022-004
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
93.432 Acl Centers for Independent Living $218,803
93.432 Covid-19: Acl Centers for Independent Living $137,715
84.126 Rehabilitation Services_vocational Rehabilitation Grants to States $100,270
93.369 Acl Independent Living State Grants $96,337
93.268 Immunization Cooperative Agreements $5,913