Finding Text
2023-003: Lack of Documentation for Review of Participant Files
Federal Departments: Corporation for National and Community Service
Assistance Listing #: 94.006
Federal Departments: Department of Labor
Assistance Listing #: 17.274
Internal Controls Significant Deficiency
Category of Finding – Eligibility
Criteria – Uniform Guidance requires that nonprofit organizations 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.
Condition – Personnel at Change Inc. were unable to produce documentation supporting the review of participant files for participant eligibility.
Cause – Change Inc. has an informal process around participant file review and did not properly maintain documentation.
Effect – A participant’s eligibility could be incorrectly determined and not be caught as a file review was not completed, or the review is not properly completed and no one would know since there was no documentation of the review or lack of review.
Recommendation – We recommend that management create written participant file review policies and procedures which include a requirement that the review process be documented when reviews are completed.
Auditee’s comments and response – Management is in agreement with this finding. Change Inc. is working to formalize this process by creating a written participant file review policy and procedure.
Responsible party for corrective action: Jill Johnson, Associate Director
Repeat Finding: No