Veterans Northeast Outreach Center, Inc.

EIN: 042879409

UEI: M7EEN1KGY585

Data as of August 23, 2026

Veterans Northeast Outreach Center, Inc.10 audit years31 findings21 repeat
10
Audit Years
31
Total Findings
21
Repeat Findings

FY 2025-06-30

Management decision deadline — for entities that funded this organization

The FAC accepted this audit on April 10, 2026. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by October 10, 2026 (47 days from today).

What is a management decision? →
2025-003
Other
MATERIAL WEAKNESSREPEAT

Refer to Section II for findings 2025-001 and 2025-002. Information on the Federal Program: Federal Agency: United States Department of Veteran Affairs Program Name: VA Supportive Services for Veteran Families Program (SSVF) CFDA: 64.033 Federal Award Identification Number: 14-MA-209 Federal Award Year: 2025 Specific Requirement: In accordance with Title 2 U.S. Code of Federal Regulations Part 200, Subpart D, Section 200.303a, the Organization is 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. Condition Found: We noted there was limited or no segregation of duties for the majority of fiscal year ended June 30, 2025 in several areas during our audit. See Section II for findings 2025-001 and 2025-002. Context: We noted these conditions while obtaining an understanding of internal control for the respective transaction cycles listed in the findings. Questioned Costs: None noted Identification as a Repeat Finding, if Applicable: A repeat finding; See finding 2024-005, 2023-005, 2022-005, 2021-005, 2020-006, and 2019-007. Recommendation: We recommend the Organization implement a system of internal controls that would improve the segregation of duties related to payroll, cash receipts, and cash disbursements. This system of controls would include documented review of each significant transaction cycle. Specifically, we recommend the following: Payroll Processing • We recommend reviewing all files to verify they contain appropriate and current documents. • We recommend developing a termination process as part of the policy manual to ensure terminated employees have access rights terminated timely upon departure.   Cash Receipts and Tenant Accounts Receivable • We recommend that the Organization segregate the various aspects of the cash receipts process between the employees to mitigate conflicting responsibilities during the transaction cycle. We recommend that the individual that opens the mail create a log of checks received which is retained by this individual and reviewed against the actual deposit made to verify completeness. • We recommend that management perform monthly reconciliations and revenues over the accounts receivable balances. We also recommend management develop a procedure for following up on amounts past due, and refunds of security deposits. • We recommend the Organization implement a process of creating and obtaining tenant agreements with terms and conditions. Those tenant agreements should be signed by the Organization and the tenant, retained and updated at the term of any agreement. Cash Disbursements • We recommend the Organization develop a formal procedure surrounding the cash disbursement process which includes an appropriate level of review of all invoices, including purchases made with the credit cards and employee reimbursements that provide a clear description of the grant and business purpose of the expense. • We also recommend that the Organization adopt a formal policy surrounding employee reimbursements which includes requiring the use of a reimbursement request form which is reviewed and that itemized receipts for purchases be required. We recommend a formal documented review be performed on a monthly basis over journal entries and supporting documentation for each journal entry be retained. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan attached.

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Refer to Section II for findings 2025-001 and 2025-002. Information on the Federal Program: Federal Agency: United States Department of Veteran Affairs Program Name: VA Supportive Services for Veteran Families Program (SSVF) CFDA: 64.033 Federal Award Identification Number: 14-MA-209 Federal Award Year: 2025 Specific Requirement: In accordance with Title 2 U.S. Code of Federal Regulations Part 200, Subpart D, Section 200.303a, the Organization is 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. Condition Found: We noted there was limited or no segregation of duties for the majority of fiscal year ended June 30, 2025 in several areas during our audit. See Section II for findings 2025-001 and 2025-002. Context: We noted these conditions while obtaining an understanding of internal control for the respective transaction cycles listed in the findings. Questioned Costs: None noted Identification as a Repeat Finding, if Applicable: A repeat finding; See finding 2024-005, 2023-005, 2022-005, 2021-005, 2020-006, and 2019-007. Recommendation: We recommend the Organization implement a system of internal controls that would improve the segregation of duties related to payroll, cash receipts, and cash disbursements. This system of controls would include documented review of each significant transaction cycle. Specifically, we recommend the following: Payroll Processing • We recommend reviewing all files to verify they contain appropriate and current documents. • We recommend developing a termination process as part of the policy manual to ensure terminated employees have access rights terminated timely upon departure.   Cash Receipts and Tenant Accounts Receivable • We recommend that the Organization segregate the various aspects of the cash receipts process between the employees to mitigate conflicting responsibilities during the transaction cycle. We recommend that the individual that opens the mail create a log of checks received which is retained by this individual and reviewed against the actual deposit made to verify completeness. • We recommend that management perform monthly reconciliations and revenues over the accounts receivable balances. We also recommend management develop a procedure for following up on amounts past due, and refunds of security deposits. • We recommend the Organization implement a process of creating and obtaining tenant agreements with terms and conditions. Those tenant agreements should be signed by the Organization and the tenant, retained and updated at the term of any agreement. Cash Disbursements • We recommend the Organization develop a formal procedure surrounding the cash disbursement process which includes an appropriate level of review of all invoices, including purchases made with the credit cards and employee reimbursements that provide a clear description of the grant and business purpose of the expense. • We also recommend that the Organization adopt a formal policy surrounding employee reimbursements which includes requiring the use of a reimbursement request form which is reviewed and that itemized receipts for purchases be required. We recommend a formal documented review be performed on a monthly basis over journal entries and supporting documentation for each journal entry be retained. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan attached.

Corrective Action Plan

FINDING 2025-001 Corrective Action Plan During the fiscal year June 30, 2025, Veterans Northeast Outreach Center, Inc. (the Organization) began implementing procedures to strengthen its system of internal controls. The Organization continues efforts to strengthen its system of internal controls throughout fiscal year 2026 with a limited finance team. Internal controls improved include a rigorous review of tenant receivables and accounts payable. Responsible party: Jason Youngclaus; Chief Financial Officer; (978) 930-3830 Anticipated completion date: June 30, 2026 FINDING 2025-002 Corrective Action Plan Management will work to identify a process of reviewing journal entries on a regular basis. The challenge with implementing a journal review process is the limited staff to facilitate a multi-level review of journal entries. The Organization will be discussing internally and with the Board of Directors a manner in which this can be accomplished. Responsible party: Jason Youngclaus; Chief Financial Officer; (978) 930-3830 Anticipated completion date: June 30, 2026   FINDING 2025-003 Corrective Action Plan Refer to the corrective action plans for findings 2025-001 and 2025-002. Responsible party: Jason Youngclaus; Chief Financial Officer; (978) 930-3830 Anticipated completion date: June 30, 2026

Prior Finding References

2024-005, 2023-005, 2022-005, 2021-005, 2020-006, 2019-007

About Other →
2025-004
Procurement & Suspension/Debarment
MATERIAL WEAKNESSREPEAT

Information on the Federal Program: Federal Agency: United States Department of Veteran Affairs Program Name: SSVF CFDA: 64.033 Federal Award Identification Number: 14-MA-209 Federal Award Year: 2025 Specific Requirement: Required by 2 CFR, Part 200 for federally funded programs, when an institution enters into a covered transaction with an entity or individual, an institution must verify that the vendor is not suspended or debarred or otherwise excluded from participating in federal programs. Generally, a covered transaction is a transaction expected to equal or exceed $25,000 and be funded with federal dollars. This verification may be accomplished by checking the System for Award Management (SAM), formerly the Excluded Parties List System, maintained by the General Services Administration, collecting a certification from the vendor, or by adding a clause or condition to the covered transaction. Condition Found: The Organization did not have an internal control procedure designed to identify vendors and employees meeting the covered transaction threshold and crosschecking those vendors and employees against SAM. Context: We selected a nonstatistical sample of 40 vendors and 8 employees funded by SSVF. None of the vendors or employees tested were identified on SAM. Questioned Costs: None Cause and Effect: The Organization was aware of the requirement to verify vendors and employees against the SAM; however, a process was not implemented to verify vendors or employees. Without performing the required check of vendors and employees against SAM, the Organization could pay a vendor or an employee with federal funds inappropriately. Identification as a Repeat Finding, if Applicable: A repeat finding; See finding 2024-006, 2023-006, 2022-006, 2021-006, 2020-007, and 2019-008.   Recommendation: We recommend the Organization implement a process to compare all vendors and employees meeting the covered transaction threshold funded by a federal program to SAM on a regular basis and when a new vendor or employee is entered into the accounting system. The Organization should maintain documentation that the comparison has been performed. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan attached.

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Information on the Federal Program: Federal Agency: United States Department of Veteran Affairs Program Name: SSVF CFDA: 64.033 Federal Award Identification Number: 14-MA-209 Federal Award Year: 2025 Specific Requirement: Required by 2 CFR, Part 200 for federally funded programs, when an institution enters into a covered transaction with an entity or individual, an institution must verify that the vendor is not suspended or debarred or otherwise excluded from participating in federal programs. Generally, a covered transaction is a transaction expected to equal or exceed $25,000 and be funded with federal dollars. This verification may be accomplished by checking the System for Award Management (SAM), formerly the Excluded Parties List System, maintained by the General Services Administration, collecting a certification from the vendor, or by adding a clause or condition to the covered transaction. Condition Found: The Organization did not have an internal control procedure designed to identify vendors and employees meeting the covered transaction threshold and crosschecking those vendors and employees against SAM. Context: We selected a nonstatistical sample of 40 vendors and 8 employees funded by SSVF. None of the vendors or employees tested were identified on SAM. Questioned Costs: None Cause and Effect: The Organization was aware of the requirement to verify vendors and employees against the SAM; however, a process was not implemented to verify vendors or employees. Without performing the required check of vendors and employees against SAM, the Organization could pay a vendor or an employee with federal funds inappropriately. Identification as a Repeat Finding, if Applicable: A repeat finding; See finding 2024-006, 2023-006, 2022-006, 2021-006, 2020-007, and 2019-008.   Recommendation: We recommend the Organization implement a process to compare all vendors and employees meeting the covered transaction threshold funded by a federal program to SAM on a regular basis and when a new vendor or employee is entered into the accounting system. The Organization should maintain documentation that the comparison has been performed. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan attached.

Corrective Action Plan

FINDING 2025-004 Corrective Action Plan The Organization lost funding during 2025 and therefore there is no corrective action plan. Responsible party: Jason Youngclaus; Chief Financial Officer; (978) 930-3830 Anticipated completion date: Not Applicable

Prior Finding References

2024-006, 2023-006, 2022-006, 2021-006, 2020-007, 2019-008

About Procurement and Suspension and Debarment →
2025-005
Eligibility
MATERIAL WEAKNESSREPEAT

Information on the Federal Program: Federal Agency: United States Department of Veteran Affairs Program Name: SSVF CFDA: 64.033 Federal Award Identification Number: 14-MA-209 Federal Award Year: 2025 Specific Requirement: In accordance with the SSVF Program Guide dated December 2020, an organization must maintain adequate eligibility documentation. Grantees must implement policies and procedures that ensure appropriate documentation is obtained and is included in each participant’s file. Condition Found: During our testing of participant eligibility, we noted the following: 1. Documented approval by either the Program Coordinator or the Case Manager was missing for documentation related to 15 participant files out of the 25 selected for testing. 2. 90-day eligibility recertifications were not performed or not documented appropriately for 16 participants out of the 25 requiring recertification. Context: We sampled 25 participants out of 74 total participants, using a nonstatistical sample, who were provided support from the Organization’s SSVF program. Questioned Costs: N/A Cause and Effect: The Organization is aware of the eligibility requirements under the SSVF program and the importance of retaining all of the required documentation set forth in the SSVF Program Guide. Under the terms of the SSVF grant, grantees with insufficient case file documentation may be found out of compliance with SSVF Program regulations. The Organization also is at risk for providing services to ineligible participants. Identification as a Repeat Finding, if Applicable: A repeat finding; See finding 2024-007, 2023-007, 2022-007, 2021-008, 2020-010, and 2019-011. Recommendation: We recommend the Organization implement a system of controls that would properly document the eligibility requirements of participants under the SSVF program and compliance with the eligibility requirements set forth under the SSVF program. Participants’ documented eligibility should be properly reviewed, evidenced by appropriate supervisor signatures. All eligibility forms, recertification forms, and other required forms should be maintained in a file for each participant. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan attached.

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Information on the Federal Program: Federal Agency: United States Department of Veteran Affairs Program Name: SSVF CFDA: 64.033 Federal Award Identification Number: 14-MA-209 Federal Award Year: 2025 Specific Requirement: In accordance with the SSVF Program Guide dated December 2020, an organization must maintain adequate eligibility documentation. Grantees must implement policies and procedures that ensure appropriate documentation is obtained and is included in each participant’s file. Condition Found: During our testing of participant eligibility, we noted the following: 1. Documented approval by either the Program Coordinator or the Case Manager was missing for documentation related to 15 participant files out of the 25 selected for testing. 2. 90-day eligibility recertifications were not performed or not documented appropriately for 16 participants out of the 25 requiring recertification. Context: We sampled 25 participants out of 74 total participants, using a nonstatistical sample, who were provided support from the Organization’s SSVF program. Questioned Costs: N/A Cause and Effect: The Organization is aware of the eligibility requirements under the SSVF program and the importance of retaining all of the required documentation set forth in the SSVF Program Guide. Under the terms of the SSVF grant, grantees with insufficient case file documentation may be found out of compliance with SSVF Program regulations. The Organization also is at risk for providing services to ineligible participants. Identification as a Repeat Finding, if Applicable: A repeat finding; See finding 2024-007, 2023-007, 2022-007, 2021-008, 2020-010, and 2019-011. Recommendation: We recommend the Organization implement a system of controls that would properly document the eligibility requirements of participants under the SSVF program and compliance with the eligibility requirements set forth under the SSVF program. Participants’ documented eligibility should be properly reviewed, evidenced by appropriate supervisor signatures. All eligibility forms, recertification forms, and other required forms should be maintained in a file for each participant. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan attached.

Corrective Action Plan

FINDING 2025-005 Corrective Action Plan The Organization lost funding during 2025 and therefore there is no corrective action plan. Responsible party: Jason Youngclaus; Chief Financial Officer; (978) 930-3830 Anticipated completion date: Not Applicable

Prior Finding References

2024-007, 2023-007, 2022-007, 2021-008, 2020-010, 2019-011

About Eligibility →

FY 2024-06-30

FAC accepted this audit on November 13, 2024 — management decision was due May 13, 2025.

2024-005
Other
MATERIAL WEAKNESSREPEAT

Refer to Section II for findings 2024-001, 2024-002 and 2024-003 Information on the Federal Program: Federal Agency: United States Department of Veteran Affairs Program Name: VA Supportive Services for Veteran Families Program (SSVF) CFDA: 64.033 Federal Award Identification Number: 14-MA-209 Federal Award Year: 2024 Specific Requirement: In accordance with Title 2 U.S. Code of Federal Regulations Part 200, Subpart D, Section 200.303a, the Organization is 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. Condition Found: We noted there was limited or no segregation of duties for the majority of fiscal year June 30, 2024 in several areas during our audit. See Section II for findings 2024-001, 2024-002 and 2024-003. Context: We noted these conditions while obtaining an understanding of internal control for the respective transaction cycles listed in the findings. Questioned Costs: None noted Identification as a Repeat Finding, if Applicable: A repeat finding; See finding 2023-005, 2022-005, 2021-005, 2020-006 and 2019-007 Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan attached.

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Refer to Section II for findings 2024-001, 2024-002 and 2024-003 Information on the Federal Program: Federal Agency: United States Department of Veteran Affairs Program Name: VA Supportive Services for Veteran Families Program (SSVF) CFDA: 64.033 Federal Award Identification Number: 14-MA-209 Federal Award Year: 2024 Specific Requirement: In accordance with Title 2 U.S. Code of Federal Regulations Part 200, Subpart D, Section 200.303a, the Organization is 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. Condition Found: We noted there was limited or no segregation of duties for the majority of fiscal year June 30, 2024 in several areas during our audit. See Section II for findings 2024-001, 2024-002 and 2024-003. Context: We noted these conditions while obtaining an understanding of internal control for the respective transaction cycles listed in the findings. Questioned Costs: None noted Identification as a Repeat Finding, if Applicable: A repeat finding; See finding 2023-005, 2022-005, 2021-005, 2020-006 and 2019-007 Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan attached.

Corrective Action Plan

FINDING 2024-005 Corrective Action Plan Refer to the corrective action plans for findings 2024-001, 2024-002 and 2024-003. Finding 2024-001 Corrective Action Plan Before the end of fiscal year June 30, 2024, Veterans Northeast Outreach Center, Inc. (the Organization) began implementing procedures to strengthen its system of internal controls. Included as part of this implementation the Organization will begin procedures where: • the Executive Director reviews and approves each weekly payroll by email. In addition, any changes to the payroll being approved that differs from the previous weekly payroll will be noted in the email and part of the approval process. This includes new hire compensation and any adjustments to current staff. • the COO notifies the Executive Director and Chief Financial Officer of any terminated employee that has been removed from applicable benefits, software applications, and physical access rights within the Organization. • all checks will be procured at the front desk by intake staff and logged into a check and wire log before being brought to the Finance Office where the checks are then copied, deposited, and filed. • rent rolls are regularly updated by housing staff and any updates are made to the Organization’s accounts receivable subledger. Additionally, the Organization will be reviewing outstanding tenant receivables on a monthly and quarterly basis to ensure timely collection of rent. • all payments, including reimbursement and credit card purchases, be reviewed for appropriate backup and approved by the applicable program manager and/or supervisor; and all invoices and backup will be filed in the appropriate accounts payable file. Responsible party: Bill Kelly; Executive Director; (978) 853-7013 Anticipated completion date: June 30, 2025 FINDING 2024-002 Corrective Action Plan Management will work to identify a process of reviewing journal entries on a regular basis. The challenge with implementing a journal review process is the limited staff to facilitate a multi-level review of journal entries. The Organization will be discussing internally and with the Board of Directors a manner in which this can be accomplished. Responsible party: Bill Kelly; Executive Director; (978) 853-7013 Anticipated completion date: June 30, 2025 FINDING 2024-003 Corrective Action Plan Beginning in December 2024, the Finance Department implemented procedures where all bank account reconciliations are performed in a timely fashion the month following the closing of the previous month. Additionally, beginning in June 2024, the Finance Department implemented policies and procedures to have monthly financial reports prepared and provided to the Organization’s Board of Directors by the fourth Wednesday of the subsequent month for review. Responsible party: Bill Kelly; Executive Director; (978) 853-7013 Anticipated completion date: July 1, 2024 FINDING 2024-004 Corrective Action Plan The Organization’s senior leadership team has implemented procedures to track compliance deadlines and to monitor timely closing of financial periods. This monitoring will allow for the timely filing of the Massachusetts UFR by the required deadline of November 15, 2024. Responsible party: Bill Kelly; Executive Director; (978) 853-7013 Anticipated completion date: November 15, 2024

Prior Finding References

2023-005, 2022-005, 2021-005, 2020-006, 2019-007

About Other →
2024-006
Procurement & Suspension/Debarment
MATERIAL WEAKNESSREPEAT

Information on the Federal Program: Federal Agency: United States Department of Veteran Affairs Program Name: SSVF CFDA: 64.033 Federal Award Identification Number: 14-MA-209 Federal Award Year: 2024 Specific Requirement: Required by 2 CFR, Part 200 for federally funded programs, when an institution enters into a covered transaction with an entity or individual, an institution must verify that the vendor is not suspended or debarred or otherwise excluded from participating in federal programs. Generally, a covered transaction is a transaction expected to equal or exceed $25,000 and be funded with federal dollars. This verification may be accomplished by checking the System for Award Management (SAM), formerly the Excluded Parties List System, maintained by the General Services Administration, collecting a certification from the vendor, or by adding a clause or condition to the covered transaction. Condition Found: The Organization did not have an internal control procedure designed to identify vendors and employees meeting the covered transaction threshold and crosschecking those vendors and employees against SAM. Context: We selected a nonstatistical sample of 40 vendors and 7 employees funded by SSVF. None of the vendors or employees tested were identified on SAM. Questioned Costs: None Cause and Effect: The Organization was aware of the requirement to verify vendors and employees against the SAM; however, a process was not implemented to verify vendors or employees. Without performing the required check of vendors and employees against SAM, the Organization could pay a vendor or an employee with federal funds inappropriately. Identification as a Repeat Finding, if Applicable: A repeat finding; See finding 2023-006, 2022-006, 2021-006, 2020-007 and 2019-008   Recommendation: We recommend the Organization implement a process to compare all vendors and employees meeting the covered transaction threshold funded by a federal program to SAM on a regular basis and when a new vendor or employee is entered into the accounting system. The Organization should maintain documentation that the comparison has been performed. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan attached.

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Information on the Federal Program: Federal Agency: United States Department of Veteran Affairs Program Name: SSVF CFDA: 64.033 Federal Award Identification Number: 14-MA-209 Federal Award Year: 2024 Specific Requirement: Required by 2 CFR, Part 200 for federally funded programs, when an institution enters into a covered transaction with an entity or individual, an institution must verify that the vendor is not suspended or debarred or otherwise excluded from participating in federal programs. Generally, a covered transaction is a transaction expected to equal or exceed $25,000 and be funded with federal dollars. This verification may be accomplished by checking the System for Award Management (SAM), formerly the Excluded Parties List System, maintained by the General Services Administration, collecting a certification from the vendor, or by adding a clause or condition to the covered transaction. Condition Found: The Organization did not have an internal control procedure designed to identify vendors and employees meeting the covered transaction threshold and crosschecking those vendors and employees against SAM. Context: We selected a nonstatistical sample of 40 vendors and 7 employees funded by SSVF. None of the vendors or employees tested were identified on SAM. Questioned Costs: None Cause and Effect: The Organization was aware of the requirement to verify vendors and employees against the SAM; however, a process was not implemented to verify vendors or employees. Without performing the required check of vendors and employees against SAM, the Organization could pay a vendor or an employee with federal funds inappropriately. Identification as a Repeat Finding, if Applicable: A repeat finding; See finding 2023-006, 2022-006, 2021-006, 2020-007 and 2019-008   Recommendation: We recommend the Organization implement a process to compare all vendors and employees meeting the covered transaction threshold funded by a federal program to SAM on a regular basis and when a new vendor or employee is entered into the accounting system. The Organization should maintain documentation that the comparison has been performed. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan attached.

Corrective Action Plan

FINDING 2024-006 Corrective Action Plan For fiscal year ending June 30, 2025, the Organization will implement a procedure to verify if any vendor or employee being paid over $25,000 will be checked against SAM to confirm whether or not the vendor or employee is included on the excluded parties list. Responsible party: Bill Kelly; Executive Director; (978) 853-7013 Anticipated completion date: June 30, 2025

Prior Finding References

2023-006, 2022-006, 2021-006, 2020-007, 2019-008

About Procurement and Suspension and Debarment →
2024-007
Eligibility
MATERIAL WEAKNESSREPEAT

Information on the Federal Program: Federal Agency: United States Department of Veteran Affairs Program Name: SSVF CFDA: 64.033 Federal Award Identification Number: 14-MA-209 Federal Award Year: 2024 Specific Requirement: In accordance with the SSVF Program Guide dated December 2020, an organization must maintain adequate eligibility documentation. Grantees must implement policies and procedures that ensure appropriate documentation is obtained and is included in each participant’s file. Condition Found: During our testing of participant eligibility, we noted the following: 1. Documented approval by either the Program Coordinator or the Case Manager was missing for documentation related to 6 participant files out of the 37 selected for testing. 2. 90-day eligibility recertifications were not performed or not documented appropriately for 10 participants out of the 37 requiring recertification. Context: We sampled 37 participants out of 239 total participants, using a nonstatistical sample, who were provided support from the Organization’s SSVF program. Questioned Costs: N/A Cause and Effect: The Organization is aware of the eligibility requirements under the SSVF program and the importance of retaining all of the required documentation set forth in the SSVF Program Guide. Under the terms of the SSVF grant, grantees with insufficient case file documentation may be found out of compliance with SSVF Program regulations. The Organization also is at risk for providing services to ineligible participants. Identification as a Repeat Finding, if Applicable: A repeat finding; See finding 2023-007, 2022-007, 2021-008, 2020-010 and 2019-011 Recommendation: We recommend the Organization implement a system of controls that would properly document the eligibility requirements of participants under the SSVF program and compliance with the eligibility requirements set forth under the SSVF program. Participants’ documented eligibility should be properly reviewed, evidenced by appropriate supervisor signatures. All eligibility forms, recertification forms and other required forms should be maintained in a file for each participant. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan attached.

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Information on the Federal Program: Federal Agency: United States Department of Veteran Affairs Program Name: SSVF CFDA: 64.033 Federal Award Identification Number: 14-MA-209 Federal Award Year: 2024 Specific Requirement: In accordance with the SSVF Program Guide dated December 2020, an organization must maintain adequate eligibility documentation. Grantees must implement policies and procedures that ensure appropriate documentation is obtained and is included in each participant’s file. Condition Found: During our testing of participant eligibility, we noted the following: 1. Documented approval by either the Program Coordinator or the Case Manager was missing for documentation related to 6 participant files out of the 37 selected for testing. 2. 90-day eligibility recertifications were not performed or not documented appropriately for 10 participants out of the 37 requiring recertification. Context: We sampled 37 participants out of 239 total participants, using a nonstatistical sample, who were provided support from the Organization’s SSVF program. Questioned Costs: N/A Cause and Effect: The Organization is aware of the eligibility requirements under the SSVF program and the importance of retaining all of the required documentation set forth in the SSVF Program Guide. Under the terms of the SSVF grant, grantees with insufficient case file documentation may be found out of compliance with SSVF Program regulations. The Organization also is at risk for providing services to ineligible participants. Identification as a Repeat Finding, if Applicable: A repeat finding; See finding 2023-007, 2022-007, 2021-008, 2020-010 and 2019-011 Recommendation: We recommend the Organization implement a system of controls that would properly document the eligibility requirements of participants under the SSVF program and compliance with the eligibility requirements set forth under the SSVF program. Participants’ documented eligibility should be properly reviewed, evidenced by appropriate supervisor signatures. All eligibility forms, recertification forms and other required forms should be maintained in a file for each participant. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan attached.

Corrective Action Plan

FINDING 2024-007 Corrective Action Plan The Organization addressed the necessity of implementing a system of internal controls that would properly document the eligibility requirements set forth in the SSVF program during its most recent program audit (scope period January 1, 2022 – December 31, 2023) with the U.S. Department of Veterans Affairs. Subsequent to the program audit, the Organization instituted a corrective action plan to follow that process. In a letter dated August 21, 2024, the U.S. Department of Veterans Affairs stated and confirmed that “corrective actions were taken in response to recommendations issued by the Office of Business Oversight (OBO) in its SSVF Grant Programmatic Review.” Responsible party: Bill Kelly; Executive Director; (978) 853-7013 Anticipated completion date: August 21, 2024

Prior Finding References

2023-007, 2022-007, 2021-008, 2020-010, 2019-011

About Eligibility →
2024-008
Reporting
MATERIAL WEAKNESSREPEAT

Information on the Federal Program: Federal Agency: United States Department of Veteran Affairs Program Name: SSVF CFDA: 64.033 Federal Award Identification Number: 14-MA-209 Federal Award Year: 2023 Specific Requirement: In accordance with the Uniform Guidance §200.512, Report Submission, the audit must be completed, and the data collection form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor’s reports, or nine months after the end of the audit period. Condition Found: The Organization did not submit the 2023 data collection form prior to the 9 month deadline of March 31, 2024. Context: The late report submission is a condition identified per examination of the audit report date, in comparison to the required submission deadline date of the data collection form and reporting package. Questioned Costs: N/A Cause and Effect: Uniform Guidance audit was not completed by the reporting deadline due to issues with staffing. This presented delays in scheduling and other data gathering that likely could have been avoided or reduced had there been adequate staffing. Identification as a Repeat Finding, if Applicable: 2023-008 Recommendation: We recommend that staff organize an internal control structure that can facilitate timely preparation of the data collection form and the related reconciliations for the completion of the audit and submission of the data collection form before the submission deadline. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan attached.

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Information on the Federal Program: Federal Agency: United States Department of Veteran Affairs Program Name: SSVF CFDA: 64.033 Federal Award Identification Number: 14-MA-209 Federal Award Year: 2023 Specific Requirement: In accordance with the Uniform Guidance §200.512, Report Submission, the audit must be completed, and the data collection form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor’s reports, or nine months after the end of the audit period. Condition Found: The Organization did not submit the 2023 data collection form prior to the 9 month deadline of March 31, 2024. Context: The late report submission is a condition identified per examination of the audit report date, in comparison to the required submission deadline date of the data collection form and reporting package. Questioned Costs: N/A Cause and Effect: Uniform Guidance audit was not completed by the reporting deadline due to issues with staffing. This presented delays in scheduling and other data gathering that likely could have been avoided or reduced had there been adequate staffing. Identification as a Repeat Finding, if Applicable: 2023-008 Recommendation: We recommend that staff organize an internal control structure that can facilitate timely preparation of the data collection form and the related reconciliations for the completion of the audit and submission of the data collection form before the submission deadline. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan attached.

Corrective Action Plan

FINDING 2024-008 Corrective Action Plan The Organization’s senior leadership team has implemented procedures to track compliance deadlines and to monitor timely closing of financial periods. This monitoring will allow for the timely filing of the data collection form by the required deadline of the earlier of 30 days after the date of the independent auditor’s report or March 31, 2025. Responsible party: Bill Kelly; Executive Director; (978) 853-7013 Anticipated completion date: No later than March 31, 2025

Prior Finding References

2023-008

About Reporting →

FY 2023-06-30

FAC accepted this audit on August 1, 2024 — management decision was due February 1, 2025.

2023-005
Other
MATERIAL WEAKNESSREPEAT

Finding Number: 2023-005 Refer to Section II for findings 2023-001, 2023-002 and 2023-003 Information on the Federal Program: Federal Agency: United States Department of Veteran Affairs Program Name: VA Supportive Services for Veteran Families Program (SSVF) CFDA: 64.033 Federal Award Identification Number: 14-MA-209 Federal Award Year: 2023 Specific Requirement: In accordance with Title 2 U.S. Code of Federal Regulations Part 200, Subpart D, Section 200.303a, the Organization is 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. Condition Found: We noted there was limited or no segregation of duties in several areas during our audit. See Section II for findings 2023-001, 2023-002 and 2023-003. Context: We noted these conditions while obtaining an understanding of internal control for the respective transaction cycles listed in the findings. Questioned Costs: None noted Identification as a Repeat Finding, if Applicable: A repeat finding; See finding 2022-005, 2021-005, 2020-006 and 2019-007 Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan attached.

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Finding Number: 2023-005 Refer to Section II for findings 2023-001, 2023-002 and 2023-003 Information on the Federal Program: Federal Agency: United States Department of Veteran Affairs Program Name: VA Supportive Services for Veteran Families Program (SSVF) CFDA: 64.033 Federal Award Identification Number: 14-MA-209 Federal Award Year: 2023 Specific Requirement: In accordance with Title 2 U.S. Code of Federal Regulations Part 200, Subpart D, Section 200.303a, the Organization is 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. Condition Found: We noted there was limited or no segregation of duties in several areas during our audit. See Section II for findings 2023-001, 2023-002 and 2023-003. Context: We noted these conditions while obtaining an understanding of internal control for the respective transaction cycles listed in the findings. Questioned Costs: None noted Identification as a Repeat Finding, if Applicable: A repeat finding; See finding 2022-005, 2021-005, 2020-006 and 2019-007 Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan attached.

Corrective Action Plan

Findings 2023-001 through 2023-008 Since 2020, the Organization had gone through a significant amount of turnover at the management level and in the Finance department. These changes have resulted in the identification of a significant lack of internal controls as well as a lack of resources. The Organization has gone through a process of hiring new Finance positions and engaging outside consultants as needed. With a change in leadership and an increase in resources, the Organization is in the process of implementing a system of internal controls that will focus on segregation of duties related to all significant transaction cycles (including monthly close procedures), increasing communication and transparency of transactions within the Organization, and a heightened sense of documentation to support all transactions, including grant funded activity. The goal of implementing this system of controls is to mitigate the risk of any wrongdoing, intentional or unintentional, at the Organization and to allow for proper compliance with restrictions set forth by government agencies. Responsible party: Bill Kelly; Executive Director; (978) 853-7013 Anticipated completion date: December 31, 2024

Prior Finding References

2022-005, 2021-005, 2020-006, 2019-007

About Other →
2023-006
Procurement & Suspension/Debarment
MATERIAL WEAKNESSREPEAT

Finding Number: 2023-006 Information on the Federal Program: Federal Agency: United States Department of Veteran Affairs Program Name: SSVF CFDA: 64.033 Federal Award Identification Number: 14-MA-209 Federal Award Year: 2023 Specific Requirement: Required by 2 CFR, Part 200 for federally funded programs, when an institution enters into a covered transaction with an entity or individual, an institution must verify that the vendor is not suspended or debarred or otherwise excluded from participating in federal programs. Generally, a covered transaction is a transaction expected to equal or exceed $25,000 and be funded with federal dollars. This verification may be accomplished by checking the System for Award Management (SAM), formerly the Excluded Parties List System, maintained by the General Services Administration, collecting a certification from the vendor, or by adding a clause or condition to the covered transaction. Condition Found: The Organization did not have an internal control procedure designed to identify vendors and employees meeting the covered transaction threshold and crosschecking those vendors and employees against SAM. None of the vendors or employees tested were identified on SAM. Context: We selected a nonstatistical sample of 35 vendors and 15 employees funded by SSVF. Questioned Costs: None Cause and Effect: The Organization was aware of the requirement to verify vendors and employees against the SAM; however, a process was not implemented to verify vendors or employees. Without performing the required check of vendors and employees against SAM, the Organization could pay a vendor or an employee with federal funds inappropriately. Identification as a Repeat Finding, if Applicable: A repeat finding; See finding 2022-006, 2021-006, 2020-007 and 2019-008 Recommendation: We recommend the Organization implement a process to compare all vendors and employees meeting the covered transaction threshold funded by a federal program to SAM on a regular basis and when a new vendor or employee is entered into the accounting system. The Organization should maintain documentation that the comparison has been performed. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan attached.

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Finding Number: 2023-006 Information on the Federal Program: Federal Agency: United States Department of Veteran Affairs Program Name: SSVF CFDA: 64.033 Federal Award Identification Number: 14-MA-209 Federal Award Year: 2023 Specific Requirement: Required by 2 CFR, Part 200 for federally funded programs, when an institution enters into a covered transaction with an entity or individual, an institution must verify that the vendor is not suspended or debarred or otherwise excluded from participating in federal programs. Generally, a covered transaction is a transaction expected to equal or exceed $25,000 and be funded with federal dollars. This verification may be accomplished by checking the System for Award Management (SAM), formerly the Excluded Parties List System, maintained by the General Services Administration, collecting a certification from the vendor, or by adding a clause or condition to the covered transaction. Condition Found: The Organization did not have an internal control procedure designed to identify vendors and employees meeting the covered transaction threshold and crosschecking those vendors and employees against SAM. None of the vendors or employees tested were identified on SAM. Context: We selected a nonstatistical sample of 35 vendors and 15 employees funded by SSVF. Questioned Costs: None Cause and Effect: The Organization was aware of the requirement to verify vendors and employees against the SAM; however, a process was not implemented to verify vendors or employees. Without performing the required check of vendors and employees against SAM, the Organization could pay a vendor or an employee with federal funds inappropriately. Identification as a Repeat Finding, if Applicable: A repeat finding; See finding 2022-006, 2021-006, 2020-007 and 2019-008 Recommendation: We recommend the Organization implement a process to compare all vendors and employees meeting the covered transaction threshold funded by a federal program to SAM on a regular basis and when a new vendor or employee is entered into the accounting system. The Organization should maintain documentation that the comparison has been performed. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan attached.

Corrective Action Plan

Findings 2023-001 through 2023-008 Since 2020, the Organization had gone through a significant amount of turnover at the management level and in the Finance department. These changes have resulted in the identification of a significant lack of internal controls as well as a lack of resources. The Organization has gone through a process of hiring new Finance positions and engaging outside consultants as needed. With a change in leadership and an increase in resources, the Organization is in the process of implementing a system of internal controls that will focus on segregation of duties related to all significant transaction cycles (including monthly close procedures), increasing communication and transparency of transactions within the Organization, and a heightened sense of documentation to support all transactions, including grant funded activity. The goal of implementing this system of controls is to mitigate the risk of any wrongdoing, intentional or unintentional, at the Organization and to allow for proper compliance with restrictions set forth by government agencies. Responsible party: Bill Kelly; Executive Director; (978) 853-7013 Anticipated completion date: December 31, 2024

Prior Finding References

2022-006, 2021-006, 2020-007, 2019-008

About Procurement and Suspension and Debarment →
2023-007
Eligibility
MATERIAL WEAKNESSREPEAT

Finding Number: 2023-007 Information on the Federal Program: Federal Agency: United States Department of Veteran Affairs Program Name: SSVF CFDA: 64.033 Federal Award Identification Number: 14-MA-209 Federal Award Year: 2023 Specific Requirement: In accordance with the SSVF Program Guide dated December 2020, an organization must maintain adequate eligibility documentation. Grantees must implement policies and procedures that ensure appropriate documentation is obtained and is included in each participant’s file. Condition Found: During our testing of participant eligibility, we noted the following: 1. Documented approval by either the Program Coordinator or the Case Manager was missing for documentation related to 14 participant files out of the 37 selected for testing. 2. 90-day eligibility recertifications were not performed or not documented appropriately for 17 participants out of the 37 requiring recertification. Context: We sampled 37 participants out of 159 total participants, using a nonstatistical sample, who were provided support from the Organization’s SSVF program. Questioned Costs: N/A Cause and Effect: The Organization is aware of the eligibility requirements under the SSVF program, but was unaware of the importance of retaining all of the required documentation set forth in the SSVF Program Guide. Under the terms of the SSVF grant, grantees with insufficient case file documentation may be found out of compliance with SSVF Program regulations. The Organization also is at risk for providing services to ineligible participants. As a result of the Organization’s inability to provide certain documents, compliance over eligibility was unable to be tested. Identification as a Repeat Finding, if Applicable: A repeat finding; See finding 2022-007, 2021-008, 2020-010 and 2019-011 Recommendation: We recommend the Organization implement a system of controls that would properly document the eligibility requirements of participants under the SSVF program and compliance with the eligibility requirements set forth under the SSVF program. Participants’ documented eligibility should be properly reviewed, evidenced by appropriate supervisor signatures. All eligibility forms, recertification forms and other required forms should be maintained in a file for each participant. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan attached.

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Finding Number: 2023-007 Information on the Federal Program: Federal Agency: United States Department of Veteran Affairs Program Name: SSVF CFDA: 64.033 Federal Award Identification Number: 14-MA-209 Federal Award Year: 2023 Specific Requirement: In accordance with the SSVF Program Guide dated December 2020, an organization must maintain adequate eligibility documentation. Grantees must implement policies and procedures that ensure appropriate documentation is obtained and is included in each participant’s file. Condition Found: During our testing of participant eligibility, we noted the following: 1. Documented approval by either the Program Coordinator or the Case Manager was missing for documentation related to 14 participant files out of the 37 selected for testing. 2. 90-day eligibility recertifications were not performed or not documented appropriately for 17 participants out of the 37 requiring recertification. Context: We sampled 37 participants out of 159 total participants, using a nonstatistical sample, who were provided support from the Organization’s SSVF program. Questioned Costs: N/A Cause and Effect: The Organization is aware of the eligibility requirements under the SSVF program, but was unaware of the importance of retaining all of the required documentation set forth in the SSVF Program Guide. Under the terms of the SSVF grant, grantees with insufficient case file documentation may be found out of compliance with SSVF Program regulations. The Organization also is at risk for providing services to ineligible participants. As a result of the Organization’s inability to provide certain documents, compliance over eligibility was unable to be tested. Identification as a Repeat Finding, if Applicable: A repeat finding; See finding 2022-007, 2021-008, 2020-010 and 2019-011 Recommendation: We recommend the Organization implement a system of controls that would properly document the eligibility requirements of participants under the SSVF program and compliance with the eligibility requirements set forth under the SSVF program. Participants’ documented eligibility should be properly reviewed, evidenced by appropriate supervisor signatures. All eligibility forms, recertification forms and other required forms should be maintained in a file for each participant. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan attached.

Corrective Action Plan

Findings 2023-001 through 2023-008 Since 2020, the Organization had gone through a significant amount of turnover at the management level and in the Finance department. These changes have resulted in the identification of a significant lack of internal controls as well as a lack of resources. The Organization has gone through a process of hiring new Finance positions and engaging outside consultants as needed. With a change in leadership and an increase in resources, the Organization is in the process of implementing a system of internal controls that will focus on segregation of duties related to all significant transaction cycles (including monthly close procedures), increasing communication and transparency of transactions within the Organization, and a heightened sense of documentation to support all transactions, including grant funded activity. The goal of implementing this system of controls is to mitigate the risk of any wrongdoing, intentional or unintentional, at the Organization and to allow for proper compliance with restrictions set forth by government agencies. Responsible party: Bill Kelly; Executive Director; (978) 853-7013 Anticipated completion date: December 31, 2024

Prior Finding References

2022-007, 2021-008, 2020-010, 2019-011

About Eligibility →
2023-008
Reporting
MATERIAL WEAKNESS

Finding Number: 2023-008 Information on the Federal Program: Federal Agency: United States Department of Veteran Affairs Program Name: SSVF CFDA: 64.033 Federal Award Identification Number: 14-MA-209 Federal Award Year: 2023 Specific Requirement: In accordance with the Uniform Guidance §200.512, Report Submission, the audit must be completed, and the data collection form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor’s reports, or nine months after the end of the audit period. Condition Found: The Organization did not submit the data collection form prior to the 9 month extended deadline of March 31, 2024. Context: The late report submission is a condition identified per examination of the audit report date, in comparison to the required submission deadline date of the data collection form and reporting package. Questioned Costs: N/A Cause and Effect: Uniform Guidance audit was not completed by the reporting deadline due to issues with staffing. This presented delays in scheduling and other data gathering that likely could have been avoided or reduced had there been adequate staffing. Identification as a Repeat Finding, if Applicable: Not applicable Recommendation: We recommend that staff organize an internal control structure that can facilitate timely preparation of the data collection form and the related reconciliations for the completion of the audit and submission of the data collection form before the submission deadline. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan attached.

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Finding Number: 2023-008 Information on the Federal Program: Federal Agency: United States Department of Veteran Affairs Program Name: SSVF CFDA: 64.033 Federal Award Identification Number: 14-MA-209 Federal Award Year: 2023 Specific Requirement: In accordance with the Uniform Guidance §200.512, Report Submission, the audit must be completed, and the data collection form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor’s reports, or nine months after the end of the audit period. Condition Found: The Organization did not submit the data collection form prior to the 9 month extended deadline of March 31, 2024. Context: The late report submission is a condition identified per examination of the audit report date, in comparison to the required submission deadline date of the data collection form and reporting package. Questioned Costs: N/A Cause and Effect: Uniform Guidance audit was not completed by the reporting deadline due to issues with staffing. This presented delays in scheduling and other data gathering that likely could have been avoided or reduced had there been adequate staffing. Identification as a Repeat Finding, if Applicable: Not applicable Recommendation: We recommend that staff organize an internal control structure that can facilitate timely preparation of the data collection form and the related reconciliations for the completion of the audit and submission of the data collection form before the submission deadline. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan attached.

Corrective Action Plan

Findings 2023-001 through 2023-008 Since 2020, the Organization had gone through a significant amount of turnover at the management level and in the Finance department. These changes have resulted in the identification of a significant lack of internal controls as well as a lack of resources. The Organization has gone through a process of hiring new Finance positions and engaging outside consultants as needed. With a change in leadership and an increase in resources, the Organization is in the process of implementing a system of internal controls that will focus on segregation of duties related to all significant transaction cycles (including monthly close procedures), increasing communication and transparency of transactions within the Organization, and a heightened sense of documentation to support all transactions, including grant funded activity. The goal of implementing this system of controls is to mitigate the risk of any wrongdoing, intentional or unintentional, at the Organization and to allow for proper compliance with restrictions set forth by government agencies. Responsible party: Bill Kelly; Executive Director; (978) 853-7013 Anticipated completion date: December 31, 2024

About Reporting →

FY 2022-06-30

FAC accepted this audit on May 31, 2023 — management decision was due December 1, 2023.

2022-005
Other
MATERIAL WEAKNESSREPEAT

Finding Number: 2022-005 Refer to Section II for findings 2022-001, 2022-002 and 2022-003 Information on the Federal Program: Federal Agency: United States Department of Veteran Affairs Program Name: VA Supportive Services for Veteran Families Program (SSVF) CFDA: 64.033 Federal Award Identification Number: 14-MA-209 Federal Award Year: 2022 Specific Requirement: In accordance with Title 2 U.S. Code of Federal Regulations Part 200, Subpart D, Section 200.303a, the Organization is 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. Condition Found: We noted there was limited or no segregation of duties in several areas during our audit. See Section II for findings 2022-001, 2022-002 and 2022-003. Context: We noted these conditions while obtaining an understanding of internal control for the respective transaction cycles listed in the findings. Questioned Costs: None noted Identification as a Repeat Finding, if Applicable: A repeat finding; See finding 2021-005 Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan attached.

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Finding Number: 2022-005 Refer to Section II for findings 2022-001, 2022-002 and 2022-003 Information on the Federal Program: Federal Agency: United States Department of Veteran Affairs Program Name: VA Supportive Services for Veteran Families Program (SSVF) CFDA: 64.033 Federal Award Identification Number: 14-MA-209 Federal Award Year: 2022 Specific Requirement: In accordance with Title 2 U.S. Code of Federal Regulations Part 200, Subpart D, Section 200.303a, the Organization is 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. Condition Found: We noted there was limited or no segregation of duties in several areas during our audit. See Section II for findings 2022-001, 2022-002 and 2022-003. Context: We noted these conditions while obtaining an understanding of internal control for the respective transaction cycles listed in the findings. Questioned Costs: None noted Identification as a Repeat Finding, if Applicable: A repeat finding; See finding 2021-005 Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan attached.

Corrective Action Plan

Findings 2022-001 through 2022-007 During 2020 and 2021, the Organization had gone through a significant amount of turnover at the management level and in the Finance department. These changes have resulted in the identification of a significant lack of internal controls as well as a lack of resources. The Organization has gone through a process of hiring new Finance positions and engaging outside consultants as needed. With a change in leadership and an increase in resources, the Organization is in the process of implementing a system of internal controls that will focus on segregation of duties related to all significant transaction cycles (including monthly close procedures), increasing communication and transparency of transactions within the Organization, and a heightened sense of documentation to support all transactions, including grant funded activity. The goal of implementing this system of controls is to mitigate the risk of any wrongdoing, intentional or unintentional, at the Organization and to allow for proper compliance with restrictions set forth by government agencies. Responsible party: Scott Forbes; Executive Director; (978) 873-0916 Anticipated completion date: June 30, 2023

Prior Finding References

2021-005

About Other →
2022-006
Procurement & Suspension/Debarment
MATERIAL WEAKNESSREPEAT

Finding Number: 2022-006 Information on the Federal Program: Federal Agency: United States Department of Veteran Affairs Program Name: SSVF CFDA: 64.033 Federal Award Identification Number: 14-MA-209 Federal Award Year: 2022 Specific Requirement: Required by 2 CFR, Part 200 for federally funded programs, when an institution enters into a covered transaction with an entity or individual, an institution must verify that the vendor is not suspended or debarred or otherwise excluded from participating in federal programs. Generally, a covered transaction is a transaction expected to equal or exceed $25,000 and be funded with federal dollars. This verification may be accomplished by checking the System for Award Management (SAM), formerly the Excluded Parties List System, maintained by the General Services Administration, collecting a certification from the vendor, or by adding a clause or condition to the covered transaction. Condition Found: The Organization did not have an internal control procedure designed to identify vendors and employees meeting the covered transaction threshold and crosschecking those vendors and employees against SAM. None of the vendors or employees tested were identified on SAM. Context: We selected a nonstatistical sample of 20 vendors and 10 employees funded by SSVF. Questioned Costs: None Cause and Effect: The Organization was aware of the requirement to verify vendors and employees against the SAM; however, a process was not implemented to verify vendors or employees. Without performing the required check of vendors and employees against SAM, the Organization could pay a vendor or an employee with federal funds inappropriately. Identification as a Repeat Finding, if Applicable: A repeat finding; See finding 2021-006 Recommendation: We recommend the Organization implement a process to compare all vendors and employees meeting the covered transaction threshold funded by a federal program to SAM on a regular basis and when a new vendor or employee is entered into the accounting system. The Organization should maintain documentation that the comparison has been performed. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan attached.

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Finding Number: 2022-006 Information on the Federal Program: Federal Agency: United States Department of Veteran Affairs Program Name: SSVF CFDA: 64.033 Federal Award Identification Number: 14-MA-209 Federal Award Year: 2022 Specific Requirement: Required by 2 CFR, Part 200 for federally funded programs, when an institution enters into a covered transaction with an entity or individual, an institution must verify that the vendor is not suspended or debarred or otherwise excluded from participating in federal programs. Generally, a covered transaction is a transaction expected to equal or exceed $25,000 and be funded with federal dollars. This verification may be accomplished by checking the System for Award Management (SAM), formerly the Excluded Parties List System, maintained by the General Services Administration, collecting a certification from the vendor, or by adding a clause or condition to the covered transaction. Condition Found: The Organization did not have an internal control procedure designed to identify vendors and employees meeting the covered transaction threshold and crosschecking those vendors and employees against SAM. None of the vendors or employees tested were identified on SAM. Context: We selected a nonstatistical sample of 20 vendors and 10 employees funded by SSVF. Questioned Costs: None Cause and Effect: The Organization was aware of the requirement to verify vendors and employees against the SAM; however, a process was not implemented to verify vendors or employees. Without performing the required check of vendors and employees against SAM, the Organization could pay a vendor or an employee with federal funds inappropriately. Identification as a Repeat Finding, if Applicable: A repeat finding; See finding 2021-006 Recommendation: We recommend the Organization implement a process to compare all vendors and employees meeting the covered transaction threshold funded by a federal program to SAM on a regular basis and when a new vendor or employee is entered into the accounting system. The Organization should maintain documentation that the comparison has been performed. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan attached.

Corrective Action Plan

Findings 2022-001 through 2022-007 During 2020 and 2021, the Organization had gone through a significant amount of turnover at the management level and in the Finance department. These changes have resulted in the identification of a significant lack of internal controls as well as a lack of resources. The Organization has gone through a process of hiring new Finance positions and engaging outside consultants as needed. With a change in leadership and an increase in resources, the Organization is in the process of implementing a system of internal controls that will focus on segregation of duties related to all significant transaction cycles (including monthly close procedures), increasing communication and transparency of transactions within the Organization, and a heightened sense of documentation to support all transactions, including grant funded activity. The goal of implementing this system of controls is to mitigate the risk of any wrongdoing, intentional or unintentional, at the Organization and to allow for proper compliance with restrictions set forth by government agencies. Responsible party: Scott Forbes; Executive Director; (978) 873-0916 Anticipated completion date: June 30, 2023

Prior Finding References

2021-006

About Procurement and Suspension and Debarment →
2022-007
Eligibility
MATERIAL WEAKNESSREPEAT

Finding Number: 2022-007 Information on the Federal Program: Federal Agency: United States Department of Veteran Affairs Program Name: SSVF CFDA: 64.033 Federal Award Identification Number: 14-MA-209 Federal Award Year: 2022 Specific Requirement: In accordance with the SSVF Program Guide dated December 2020, an organization must maintain adequate eligibility documentation. Grantees must implement policies and procedures that ensure appropriate documentation is obtained and is included in each participant?s file. Condition Found: During our testing of participant eligibility, we noted the following: 1. Documented approval by either the Program Coordinator or the Case Manager was missing for documentation related to 25 participant files out of the 51 selected for testing. 2. 90-day eligibility recertifications were not performed or not documented appropriately for 20 participants out of the 35 requiring recertification. Context: We sampled 51 participants out of 187 total participants, using a nonstatistical sample, who were provided support from the Organization?s SSVF program. Questioned Costs: N/A Cause and Effect: The Organization is aware of the eligibility requirements under the SSVF program, but was unaware of the importance of retaining all of the required documentation set forth in the SSVF Program Guide. Under the terms of the SSVF grant, grantees with insufficient case file documentation may be found out of compliance with SSVF Program regulations. The Organization also is at risk for providing services to ineligible participants. As a result of the Organization?s inability to provide certain documents, compliance over eligibility was unable to be tested. Identification as a Repeat Finding, if Applicable: A repeat finding; See finding 2021-008 Recommendation: We recommend the Organization implement a system of controls that would properly document the eligibility requirements of participants under the SSVF program and compliance with the eligibility requirements set forth under the SSVF program. Participants? documented eligibility should be properly reviewed, evidenced by appropriate supervisor signatures. All eligibility forms, recertification forms and other required forms should be maintained in a file for each participant. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan attached.

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Finding Number: 2022-007 Information on the Federal Program: Federal Agency: United States Department of Veteran Affairs Program Name: SSVF CFDA: 64.033 Federal Award Identification Number: 14-MA-209 Federal Award Year: 2022 Specific Requirement: In accordance with the SSVF Program Guide dated December 2020, an organization must maintain adequate eligibility documentation. Grantees must implement policies and procedures that ensure appropriate documentation is obtained and is included in each participant?s file. Condition Found: During our testing of participant eligibility, we noted the following: 1. Documented approval by either the Program Coordinator or the Case Manager was missing for documentation related to 25 participant files out of the 51 selected for testing. 2. 90-day eligibility recertifications were not performed or not documented appropriately for 20 participants out of the 35 requiring recertification. Context: We sampled 51 participants out of 187 total participants, using a nonstatistical sample, who were provided support from the Organization?s SSVF program. Questioned Costs: N/A Cause and Effect: The Organization is aware of the eligibility requirements under the SSVF program, but was unaware of the importance of retaining all of the required documentation set forth in the SSVF Program Guide. Under the terms of the SSVF grant, grantees with insufficient case file documentation may be found out of compliance with SSVF Program regulations. The Organization also is at risk for providing services to ineligible participants. As a result of the Organization?s inability to provide certain documents, compliance over eligibility was unable to be tested. Identification as a Repeat Finding, if Applicable: A repeat finding; See finding 2021-008 Recommendation: We recommend the Organization implement a system of controls that would properly document the eligibility requirements of participants under the SSVF program and compliance with the eligibility requirements set forth under the SSVF program. Participants? documented eligibility should be properly reviewed, evidenced by appropriate supervisor signatures. All eligibility forms, recertification forms and other required forms should be maintained in a file for each participant. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan attached.

Corrective Action Plan

Findings 2022-001 through 2022-007 During 2020 and 2021, the Organization had gone through a significant amount of turnover at the management level and in the Finance department. These changes have resulted in the identification of a significant lack of internal controls as well as a lack of resources. The Organization has gone through a process of hiring new Finance positions and engaging outside consultants as needed. With a change in leadership and an increase in resources, the Organization is in the process of implementing a system of internal controls that will focus on segregation of duties related to all significant transaction cycles (including monthly close procedures), increasing communication and transparency of transactions within the Organization, and a heightened sense of documentation to support all transactions, including grant funded activity. The goal of implementing this system of controls is to mitigate the risk of any wrongdoing, intentional or unintentional, at the Organization and to allow for proper compliance with restrictions set forth by government agencies. Responsible party: Scott Forbes; Executive Director; (978) 873-0916 Anticipated completion date: June 30, 2023

Prior Finding References

2021-008

About Eligibility →

FY 2021-06-30

FAC accepted this audit on May 31, 2023 — management decision was due December 1, 2023.

2021-005
Other
MATERIAL WEAKNESSREPEAT

Finding Number: 2021-005 Refer to Section II for findings 2021-001, 2021-002 and 2021-003 Information on the Federal Program: Federal Agency: United States Department of Veteran Affairs Program Name: VA Supportive Services for Veteran Families Program (SSVF) CFDA: 64.033 Federal Award Identification Number: 14-MA-209 Federal Award Year: 2021 Specific Requirement: In accordance with Title 2 U.S. Code of Federal Regulations Part 200, Subpart D, Section 200.303a, the Organization is 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. Condition Found: We noted there was limited or no segregation of duties in several areas during our audit. See Section II for findings 2021-001, 2021-002 and 2021-003. Context: We noted these conditions while obtaining an understanding of internal control for the respective transaction cycles listed in the findings. Questioned Costs: None noted Identification as a Repeat Finding, if Applicable: A repeat finding; See finding 2020-006 Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan attached.

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Finding Number: 2021-005 Refer to Section II for findings 2021-001, 2021-002 and 2021-003 Information on the Federal Program: Federal Agency: United States Department of Veteran Affairs Program Name: VA Supportive Services for Veteran Families Program (SSVF) CFDA: 64.033 Federal Award Identification Number: 14-MA-209 Federal Award Year: 2021 Specific Requirement: In accordance with Title 2 U.S. Code of Federal Regulations Part 200, Subpart D, Section 200.303a, the Organization is 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. Condition Found: We noted there was limited or no segregation of duties in several areas during our audit. See Section II for findings 2021-001, 2021-002 and 2021-003. Context: We noted these conditions while obtaining an understanding of internal control for the respective transaction cycles listed in the findings. Questioned Costs: None noted Identification as a Repeat Finding, if Applicable: A repeat finding; See finding 2020-006 Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan attached.

Corrective Action Plan

During 2020 and 2021, the Organization had gone through a significant amount of turnover at the management level and in the Finance department. These changes have resulted in the identification of a significant lack of internal controls as well as a lack of resources. The Organization has gone through a process of hiring new Finance positions and engaging outside consultants as needed. With a change in leadership and an increase in resources, the Organization is in the process of implementing a system of internal controls that will focus on segregation of duties related to all significant transaction cycles (including monthly close procedures), increasing communication and transparency of transactions within the Organization, and a heightened sense of documentation to support all transactions, including grant funded activity. The goal of implementing this system of controls is to mitigate the risk of any wrongdoing, intentional or unintentional, at the Organization and to allow for proper compliance with restrictions set forth by government agencies. Responsible party: Scott Forbes; Executive Director; (978) 873-0916 Anticipated completion date: June 30, 2023

Prior Finding References

2020-006

About Other →
2021-006
Procurement & Suspension/Debarment
MATERIAL WEAKNESSREPEAT

Finding Number: 2021-006 Information on the Federal Program: Federal Agency: United States Department of Veteran Affairs Program Name: SSVF CFDA: 64.033 Federal Award Identification Number: 14-MA-209 Federal Award Year: 2021 Specific Requirement: Required by 2 CFR, Part 200 for federally funded programs, when an institution enters into a covered transaction with an entity or individual, an institution must verify that the vendor is not suspended or debarred or otherwise excluded from participating in federal programs. Generally, a covered transaction is a transaction expected to equal or exceed $25,000 and be funded with federal dollars. This verification may be accomplished by checking the System for Award Management (SAM), formerly the Excluded Parties List System, maintained by the General Services Administration, collecting a certification from the vendor, or by adding a clause or condition to the covered transaction. Condition Found: The Organization did not have an internal control procedure designed to identify vendors and employees meeting the covered transaction threshold and crosschecking those vendors and employees against SAM. None of the vendors or employees tested were identified on SAM. Context: We selected a nonstatistical sample of 37 vendors and 23 employees funded by SSVF. Questioned Costs: None Cause and Effect: The Organization was aware of the requirement to verify vendors and employees against the SAM, however, a process was not implemented to verify vendors or employees. Without performing the required check of vendors and employees against SAM, the Organization could pay a vendor or an employee with federal funds inappropriately. Identification as a Repeat Finding, if Applicable: A repeat finding; See finding 2020-007 Recommendation: We recommend the Organization implement a process to compare all vendors and employees meeting the covered transaction threshold funded by a federal program to SAM on a regular basis and when a new vendor or employee is entered into the accounting system. The Organization should maintain documentation that the comparison has been performed. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan attached.

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Finding Number: 2021-006 Information on the Federal Program: Federal Agency: United States Department of Veteran Affairs Program Name: SSVF CFDA: 64.033 Federal Award Identification Number: 14-MA-209 Federal Award Year: 2021 Specific Requirement: Required by 2 CFR, Part 200 for federally funded programs, when an institution enters into a covered transaction with an entity or individual, an institution must verify that the vendor is not suspended or debarred or otherwise excluded from participating in federal programs. Generally, a covered transaction is a transaction expected to equal or exceed $25,000 and be funded with federal dollars. This verification may be accomplished by checking the System for Award Management (SAM), formerly the Excluded Parties List System, maintained by the General Services Administration, collecting a certification from the vendor, or by adding a clause or condition to the covered transaction. Condition Found: The Organization did not have an internal control procedure designed to identify vendors and employees meeting the covered transaction threshold and crosschecking those vendors and employees against SAM. None of the vendors or employees tested were identified on SAM. Context: We selected a nonstatistical sample of 37 vendors and 23 employees funded by SSVF. Questioned Costs: None Cause and Effect: The Organization was aware of the requirement to verify vendors and employees against the SAM, however, a process was not implemented to verify vendors or employees. Without performing the required check of vendors and employees against SAM, the Organization could pay a vendor or an employee with federal funds inappropriately. Identification as a Repeat Finding, if Applicable: A repeat finding; See finding 2020-007 Recommendation: We recommend the Organization implement a process to compare all vendors and employees meeting the covered transaction threshold funded by a federal program to SAM on a regular basis and when a new vendor or employee is entered into the accounting system. The Organization should maintain documentation that the comparison has been performed. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan attached.

Corrective Action Plan

During 2020 and 2021, the Organization had gone through a significant amount of turnover at the management level and in the Finance department. These changes have resulted in the identification of a significant lack of internal controls as well as a lack of resources. The Organization has gone through a process of hiring new Finance positions and engaging outside consultants as needed. With a change in leadership and an increase in resources, the Organization is in the process of implementing a system of internal controls that will focus on segregation of duties related to all significant transaction cycles (including monthly close procedures), increasing communication and transparency of transactions within the Organization, and a heightened sense of documentation to support all transactions, including grant funded activity. The goal of implementing this system of controls is to mitigate the risk of any wrongdoing, intentional or unintentional, at the Organization and to allow for proper compliance with restrictions set forth by government agencies. Responsible party: Scott Forbes; Executive Director; (978) 873-0916 Anticipated completion date: June 30, 2023

Prior Finding References

2020-007

About Procurement and Suspension and Debarment →
2021-007
Cost Allowability
MATERIAL WEAKNESSREPEATQUESTIONED COSTS

Finding Number: 2021-007 Information on the Federal Program: Federal Agency: United States Department of Veteran Affairs Program Name: SSVF CFDA: 64.033 Federal Award Identification Number: 14-MA-209 Federal Award Year: 2021 Specific Requirement: In accordance with the SSVF Program Guide dated March 2021, travel is allowable as a direct program cost when such travel will provide direct benefit to the SSVF program and grant award. Travel costs, including the reason and scope, have a high audit profile and are routinely examined by auditors and other government stakeholders. Grantees must be prudent with costs and perception. Condition Found: The Organization did not have an internal control process to track and confirm that all travel reimbursements charged to SSVF were properly supported including documentation of the purpose of the travel costs in relation to SSVF. Context: We sampled payment for four travel and mileage transactions in the amount of approximately $570, using a nonstatistical sample, with no supporting documentation as to the business purpose behind the transactions and the relation to the SSVF grant. The SSVF grant was charged approximately $4,000 of total travel and mileage reimbursements and travel costs during 2021. Questioned Costs: $570 of known unsupported costs. Cause and Effect: The Organization was aware of the requirement to implement a process of tracking travel costs and the purpose of the travel as part of the SSVF program, however has not implemented a process to track or review travel costs. As a result, there is a risk of inappropriate travel costs to be charged the SSVF grant fund. Identification as a Repeat Finding, if Applicable: A repeat finding; See finding 2020-008 Recommendation: We recommend the Organization implement a process of obtaining proper support for all travel costs submitted for reimbursement and documented review of mileage reimbursements to confirm satisfaction of compliance restrictions set forth by the SSVF Program Guide. We also recommend that the Organization provide additional training to employees submitting and approving mileage reimbursements of what is considerable allowable under the grant and what constitutes proper supporting documentation. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan attached.

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Full finding narrative

Finding Number: 2021-007 Information on the Federal Program: Federal Agency: United States Department of Veteran Affairs Program Name: SSVF CFDA: 64.033 Federal Award Identification Number: 14-MA-209 Federal Award Year: 2021 Specific Requirement: In accordance with the SSVF Program Guide dated March 2021, travel is allowable as a direct program cost when such travel will provide direct benefit to the SSVF program and grant award. Travel costs, including the reason and scope, have a high audit profile and are routinely examined by auditors and other government stakeholders. Grantees must be prudent with costs and perception. Condition Found: The Organization did not have an internal control process to track and confirm that all travel reimbursements charged to SSVF were properly supported including documentation of the purpose of the travel costs in relation to SSVF. Context: We sampled payment for four travel and mileage transactions in the amount of approximately $570, using a nonstatistical sample, with no supporting documentation as to the business purpose behind the transactions and the relation to the SSVF grant. The SSVF grant was charged approximately $4,000 of total travel and mileage reimbursements and travel costs during 2021. Questioned Costs: $570 of known unsupported costs. Cause and Effect: The Organization was aware of the requirement to implement a process of tracking travel costs and the purpose of the travel as part of the SSVF program, however has not implemented a process to track or review travel costs. As a result, there is a risk of inappropriate travel costs to be charged the SSVF grant fund. Identification as a Repeat Finding, if Applicable: A repeat finding; See finding 2020-008 Recommendation: We recommend the Organization implement a process of obtaining proper support for all travel costs submitted for reimbursement and documented review of mileage reimbursements to confirm satisfaction of compliance restrictions set forth by the SSVF Program Guide. We also recommend that the Organization provide additional training to employees submitting and approving mileage reimbursements of what is considerable allowable under the grant and what constitutes proper supporting documentation. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan attached.

Corrective Action Plan

During 2020 and 2021, the Organization had gone through a significant amount of turnover at the management level and in the Finance department. These changes have resulted in the identification of a significant lack of internal controls as well as a lack of resources. The Organization has gone through a process of hiring new Finance positions and engaging outside consultants as needed. With a change in leadership and an increase in resources, the Organization is in the process of implementing a system of internal controls that will focus on segregation of duties related to all significant transaction cycles (including monthly close procedures), increasing communication and transparency of transactions within the Organization, and a heightened sense of documentation to support all transactions, including grant funded activity. The goal of implementing this system of controls is to mitigate the risk of any wrongdoing, intentional or unintentional, at the Organization and to allow for proper compliance with restrictions set forth by government agencies. Responsible party: Scott Forbes; Executive Director; (978) 873-0916 Anticipated completion date: June 30, 2023

Prior Finding References

2020-008

About Allowable Costs / Cost Principles →
2021-008
Eligibility
MATERIAL WEAKNESSREPEAT

Finding Number: 2021-008 Information on the Federal Program: Federal Agency: United States Department of Veteran Affairs Program Name: SSVF CFDA: 64.033 Federal Award Identification Number: 14-MA-209 Federal Award Year: 2021 Specific Requirement: In accordance with the SSVF Program Guide dated March 2021, an organization must maintain adequate eligibility documentation. Grantees must implement policies and procedures that ensure appropriate documentation is obtained and is included in each participant?s file. Condition Found: During our testing of participant eligibility, we noted the following: 1. Documented approval by either the Program Coordinator or the Case Manager was missing for documentation related to 19 participant files out of the 51 selected for testing. 2. 90-day eligibility recertifications were not performed or not documented appropriately for 11 participants out of the 40 requiring recertification. Context: We sampled 51 participants out of 231 total participants, using a nonstatistical sample, who were provided support from the Organization?s SSVF program. Questioned Costs: N/A Cause and Effect: The Organization is aware of the eligibility requirements under the SSVF program; but was unaware of the importance of retaining all of the required documentation set forth in the SSVF Program Guide. Under the terms of the SSVF grant, grantees with insufficient case file documentation may be found out of compliance with SSVF Program regulations. The Organization also is at risk for providing services to ineligible participants. As a result of the Organization?s inability to provide certain documents, compliance over eligibility was unable to be tested. Identification as a Repeat Finding, if Applicable: A repeat finding; See finding 2020-010 Recommendation: We recommend the Organization implement a system of controls that would properly document the eligibility requirements of participants under the SSVF program and compliance with the eligibility requirements set forth under the SSVF program. Participants? documented eligibility should be properly reviewed, evidenced by appropriate supervisor signatures. All eligibility forms, recertification forms and other required forms should be maintained in a file for each participant. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan attached.

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Full finding narrative

Finding Number: 2021-008 Information on the Federal Program: Federal Agency: United States Department of Veteran Affairs Program Name: SSVF CFDA: 64.033 Federal Award Identification Number: 14-MA-209 Federal Award Year: 2021 Specific Requirement: In accordance with the SSVF Program Guide dated March 2021, an organization must maintain adequate eligibility documentation. Grantees must implement policies and procedures that ensure appropriate documentation is obtained and is included in each participant?s file. Condition Found: During our testing of participant eligibility, we noted the following: 1. Documented approval by either the Program Coordinator or the Case Manager was missing for documentation related to 19 participant files out of the 51 selected for testing. 2. 90-day eligibility recertifications were not performed or not documented appropriately for 11 participants out of the 40 requiring recertification. Context: We sampled 51 participants out of 231 total participants, using a nonstatistical sample, who were provided support from the Organization?s SSVF program. Questioned Costs: N/A Cause and Effect: The Organization is aware of the eligibility requirements under the SSVF program; but was unaware of the importance of retaining all of the required documentation set forth in the SSVF Program Guide. Under the terms of the SSVF grant, grantees with insufficient case file documentation may be found out of compliance with SSVF Program regulations. The Organization also is at risk for providing services to ineligible participants. As a result of the Organization?s inability to provide certain documents, compliance over eligibility was unable to be tested. Identification as a Repeat Finding, if Applicable: A repeat finding; See finding 2020-010 Recommendation: We recommend the Organization implement a system of controls that would properly document the eligibility requirements of participants under the SSVF program and compliance with the eligibility requirements set forth under the SSVF program. Participants? documented eligibility should be properly reviewed, evidenced by appropriate supervisor signatures. All eligibility forms, recertification forms and other required forms should be maintained in a file for each participant. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan attached.

Corrective Action Plan

During 2020 and 2021, the Organization had gone through a significant amount of turnover at the management level and in the Finance department. These changes have resulted in the identification of a significant lack of internal controls as well as a lack of resources. The Organization has gone through a process of hiring new Finance positions and engaging outside consultants as needed. With a change in leadership and an increase in resources, the Organization is in the process of implementing a system of internal controls that will focus on segregation of duties related to all significant transaction cycles (including monthly close procedures), increasing communication and transparency of transactions within the Organization, and a heightened sense of documentation to support all transactions, including grant funded activity. The goal of implementing this system of controls is to mitigate the risk of any wrongdoing, intentional or unintentional, at the Organization and to allow for proper compliance with restrictions set forth by government agencies. Responsible party: Scott Forbes; Executive Director; (978) 873-0916 Anticipated completion date: June 30, 2023

Prior Finding References

2020-010

About Eligibility →
2021-009
Reporting
MATERIAL WEAKNESS

Finding Number: 2021-009 Information on the Federal Program: Federal Agency: United States Department of Veteran Affairs Program Name: SSVF CFDA: 64.033 Federal Award Identification Number: 14-MA-209 Federal Award Year: 2021 Specific Requirement: In accordance with the Uniform Guidance ?200.512, Report Submission, the audit must be completed and the data collection form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor?s reports, or nine months after the end of the audit period. Additionally, during 2021, the Organization had an automatic six-month extension granted due to COVID-19. Condition Found: The Organization did not submit the data collection form prior to the 15 month extended deadline of September 30, 2022. Context: The late report submission is a condition identified per examination of the audit report date, in comparison to the required submission deadline date of the data collection form and reporting package. Questioned Costs: N/A Cause and Effect: Uniform Guidance audit was not completed by the reporting deadline due to issues with staffing. This presented delays in scheduling and other data gathering that likely could have been avoided or reduced had there been adequate staffing. Identification as a Repeat Finding, if Applicable: Not applicable Recommendation: We recommend that staff organize an internal control structure that can facilitate timely preparation of the data collection form and the related reconciliations for the completion of the audit and submission of the data collection form before the submission deadline. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan attached

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Finding Number: 2021-009 Information on the Federal Program: Federal Agency: United States Department of Veteran Affairs Program Name: SSVF CFDA: 64.033 Federal Award Identification Number: 14-MA-209 Federal Award Year: 2021 Specific Requirement: In accordance with the Uniform Guidance ?200.512, Report Submission, the audit must be completed and the data collection form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor?s reports, or nine months after the end of the audit period. Additionally, during 2021, the Organization had an automatic six-month extension granted due to COVID-19. Condition Found: The Organization did not submit the data collection form prior to the 15 month extended deadline of September 30, 2022. Context: The late report submission is a condition identified per examination of the audit report date, in comparison to the required submission deadline date of the data collection form and reporting package. Questioned Costs: N/A Cause and Effect: Uniform Guidance audit was not completed by the reporting deadline due to issues with staffing. This presented delays in scheduling and other data gathering that likely could have been avoided or reduced had there been adequate staffing. Identification as a Repeat Finding, if Applicable: Not applicable Recommendation: We recommend that staff organize an internal control structure that can facilitate timely preparation of the data collection form and the related reconciliations for the completion of the audit and submission of the data collection form before the submission deadline. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan attached

Corrective Action Plan

During 2020 and 2021, the Organization had gone through a significant amount of turnover at the management level and in the Finance department. These changes have resulted in the identification of a significant lack of internal controls as well as a lack of resources. The Organization has gone through a process of hiring new Finance positions and engaging outside consultants as needed. With a change in leadership and an increase in resources, the Organization is in the process of implementing a system of internal controls that will focus on segregation of duties related to all significant transaction cycles (including monthly close procedures), increasing communication and transparency of transactions within the Organization, and a heightened sense of documentation to support all transactions, including grant funded activity. The goal of implementing this system of controls is to mitigate the risk of any wrongdoing, intentional or unintentional, at the Organization and to allow for proper compliance with restrictions set forth by government agencies. Responsible party: Scott Forbes; Executive Director; (978) 873-0916 Anticipated completion date: June 30, 2023

About Reporting →

FY 2020-06-30

FAC accepted this audit on January 8, 2022 — management decision was due July 8, 2022.

2020-006
Other
MATERIAL WEAKNESSREPEAT

Finding Number: 2020-006 Refer to Section II for findings 2020-001, 2020-002, 2020-004 and 2020-005. Information on the Federal Program: Federal Agency: United States Department of Veteran Affairs Program Name: VA Supportive Services for Veteran Families Program (SSVF) CFDA: 64.033 Federal Award Identification Number: 14-MA-209 Federal Award Year: 2020 Federal Agency: United States Department of Veteran Affairs Program Name: VA Homeless Providers Grant and Per Diem Program (GPD) CFDA: 64.024 Federal Award Identification Number: N/A Federal Award Year: 2020 Specific Requirement: In accordance with Title 2 U.S. Code of Federal Regulations Part 200, Subpart D, Section 200.303a, the Organization is 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. Condition Found: We noted there was limited or no segregation of duties in several areas during our audit. See Section II for findings 2020-001, 2020-002, 2020-004 and 2020-005. Context: We noted these conditions while obtaining an understanding of internal control for the respective transaction cycles listed in the findings. Questioned Costs: None noted Identification as a Repeat Finding, if Applicable: A repeat finding. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan attached.

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Finding Number: 2020-006 Refer to Section II for findings 2020-001, 2020-002, 2020-004 and 2020-005. Information on the Federal Program: Federal Agency: United States Department of Veteran Affairs Program Name: VA Supportive Services for Veteran Families Program (SSVF) CFDA: 64.033 Federal Award Identification Number: 14-MA-209 Federal Award Year: 2020 Federal Agency: United States Department of Veteran Affairs Program Name: VA Homeless Providers Grant and Per Diem Program (GPD) CFDA: 64.024 Federal Award Identification Number: N/A Federal Award Year: 2020 Specific Requirement: In accordance with Title 2 U.S. Code of Federal Regulations Part 200, Subpart D, Section 200.303a, the Organization is 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. Condition Found: We noted there was limited or no segregation of duties in several areas during our audit. See Section II for findings 2020-001, 2020-002, 2020-004 and 2020-005. Context: We noted these conditions while obtaining an understanding of internal control for the respective transaction cycles listed in the findings. Questioned Costs: None noted Identification as a Repeat Finding, if Applicable: A repeat finding. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan attached.

Corrective Action Plan

During 2020, the Organization had gone through a significant amount of turnover at the management level and in the finance department. These changes have resulted in the identification of a significant lack of internal controls as well as a lack of resources. The Organization has gone through a process of hiring new finance positions and engaging outside consultants as needed. With a change in leadership and an increase in resources, the Organization is in the process of implementing a system of internal controls that will focus on segregation of duties related to all significant transaction cycles (including monthly close procedures), increasing communication and transparency of transactions within the Organization, and a heightened sense of documentation to support all transactions, including grant funded activity. The goal of implementing this system of controls is to mitigate the risk of any wrongdoing, intentional or unintentional, at the Organization and to allow for proper compliance with restrictions set forth by government agencies. Responsible party: Rocco Vandermerwe; Deputy Director & CFO; (978) 372-3626 Anticipated completion date: June 30, 2021

Prior Finding References

2019-007

About Other →
2020-007
Procurement & Suspension/Debarment
MATERIAL WEAKNESSREPEAT

Finding Number: 2020-007 Information on the Federal Program: Federal Agency: United States Department of Veteran Affairs Program Name: SSVF CFDA: 64.033 Federal Award Identification Number: 14-MA-209 Federal Award Year: 2020 Federal Agency: United States Department of Veteran Affairs Program Name: GPD CFDA: 64.024 Federal Award Identification Number: N/A Federal Award Year: 2020 Specific Requirement: Required by 2 CFR, Part 200 for federally funded programs, when an institution enters into a covered transaction with an entity or individual, an institution must verify that the vendor is not suspended or debarred or otherwise excluded from participating in federal programs. Generally, a covered transaction is a transaction expected to equal or exceed $25,000 and be funded with federal dollars. This verification may be accomplished by checking the System for Award Management (SAM), formerly the Excluded Parties List System, maintained by the General Services Administration, collecting a certification from the vendor, or by adding a clause or condition to the covered transaction. Condition Found: The Organization did not have an internal control procedure designed to identify vendors and employees meeting the covered transaction threshold and crosschecking those vendors and employees against SAM. None of the vendors or employees tested were identified on SAM. Context: We selected a sample of 14 vendors and 9 employees funded by SSVF. We selected a sample of 8 vendors and 12 employees funded by GPD. Both samples were using a nonstatistical sample. Questioned Costs: None Cause and Effect: The Organization was aware of the requirement to verify vendors and employees against the SAM, however, a process was not implemented to verify vendors or employees. Without performing the required check of vendors and employees against SAM, the Organization could pay a vendor or an employee with federal funds inappropriately. Identification as a Repeat Finding, if Applicable: A repeat finding. Recommendation: We recommend the Organization implement a process to compare all vendors and employees meeting the covered transaction threshold funded by a federal program to SAM on a regular basis and when a new vendor or employee is entered into the accounting system. The Organization should maintain documentation that the comparison has been performed. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan attached.

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Full finding narrative

Finding Number: 2020-007 Information on the Federal Program: Federal Agency: United States Department of Veteran Affairs Program Name: SSVF CFDA: 64.033 Federal Award Identification Number: 14-MA-209 Federal Award Year: 2020 Federal Agency: United States Department of Veteran Affairs Program Name: GPD CFDA: 64.024 Federal Award Identification Number: N/A Federal Award Year: 2020 Specific Requirement: Required by 2 CFR, Part 200 for federally funded programs, when an institution enters into a covered transaction with an entity or individual, an institution must verify that the vendor is not suspended or debarred or otherwise excluded from participating in federal programs. Generally, a covered transaction is a transaction expected to equal or exceed $25,000 and be funded with federal dollars. This verification may be accomplished by checking the System for Award Management (SAM), formerly the Excluded Parties List System, maintained by the General Services Administration, collecting a certification from the vendor, or by adding a clause or condition to the covered transaction. Condition Found: The Organization did not have an internal control procedure designed to identify vendors and employees meeting the covered transaction threshold and crosschecking those vendors and employees against SAM. None of the vendors or employees tested were identified on SAM. Context: We selected a sample of 14 vendors and 9 employees funded by SSVF. We selected a sample of 8 vendors and 12 employees funded by GPD. Both samples were using a nonstatistical sample. Questioned Costs: None Cause and Effect: The Organization was aware of the requirement to verify vendors and employees against the SAM, however, a process was not implemented to verify vendors or employees. Without performing the required check of vendors and employees against SAM, the Organization could pay a vendor or an employee with federal funds inappropriately. Identification as a Repeat Finding, if Applicable: A repeat finding. Recommendation: We recommend the Organization implement a process to compare all vendors and employees meeting the covered transaction threshold funded by a federal program to SAM on a regular basis and when a new vendor or employee is entered into the accounting system. The Organization should maintain documentation that the comparison has been performed. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan attached.

Corrective Action Plan

During 2020, the Organization had gone through a significant amount of turnover at the management level and in the finance department. These changes have resulted in the identification of a significant lack of internal controls as well as a lack of resources. The Organization has gone through a process of hiring new finance positions and engaging outside consultants as needed. With a change in leadership and an increase in resources, the Organization is in the process of implementing a system of internal controls that will focus on segregation of duties related to all significant transaction cycles (including monthly close procedures), increasing communication and transparency of transactions within the Organization, and a heightened sense of documentation to support all transactions, including grant funded activity. The goal of implementing this system of controls is to mitigate the risk of any wrongdoing, intentional or unintentional, at the Organization and to allow for proper compliance with restrictions set forth by government agencies. Responsible party: Rocco Vandermerwe; Deputy Director & CFO; (978) 372-3626 Anticipated completion date: June 30, 2021

Prior Finding References

2019-008

About Procurement and Suspension and Debarment →
2020-008
Cost Allowability
MATERIAL WEAKNESSREPEATQUESTIONED COSTS

Finding Number: 2020-008 Information on the Federal Program: Federal Agency: United States Department of Veteran Affairs Program Name: SSVF CFDA: 64.033 Federal Award Identification Number: 14-MA-209 Federal Award Year: 2020 Specific Requirement: In accordance with the SSVF Program Guide, dated December 2019, travel is allowable as a direct program cost when such travel will provide direct benefit to the SSVF program and grant award. Travel costs, including the reason and scope, have a high audit profile and are routinely examined by auditors and other government stakeholders. Grantees must be prudent with costs and perception. Condition Found: The Organization did not have an internal control process to track and confirm that all travel reimbursements charged to SSVF were properly supported including documentation of the purpose of the travel costs in relation to SSVF. Context: We sampled payment for a taxi in the amount of approximately $100, using a nonstatistical sample, with no supporting documentation as to the business purpose behind the ride and the relation to the SSVF grant. The SSVF grant was charged approximately $13,000 of total mileage reimbursements and travel costs during 2020. Questioned Costs: $100 of known unsupported costs. Cause and Effect: The Organization was aware of the requirement to implement a process of tracking travel costs and the purpose of the travel as part of the SSVF program, however has not implemented a process to track or review travel costs. As a result, there is a risk of inappropriate travel costs to be charged the SSVF grant fund. Identification as a Repeat Finding, if Applicable: A repeat finding. Recommendation: We recommend the Organization implement a process of obtaining proper support for all travel costs submitted for reimbursement and documented review of mileage reimbursements to confirm satisfaction of compliance restrictions set forth by the SSVF Program Guide. We also recommend that the Organization provide additional training to employees submitting and approving mileage reimbursements of what is considerable allowable under the grant and what constitutes proper supporting documentation. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan attached.

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Full finding narrative

Finding Number: 2020-008 Information on the Federal Program: Federal Agency: United States Department of Veteran Affairs Program Name: SSVF CFDA: 64.033 Federal Award Identification Number: 14-MA-209 Federal Award Year: 2020 Specific Requirement: In accordance with the SSVF Program Guide, dated December 2019, travel is allowable as a direct program cost when such travel will provide direct benefit to the SSVF program and grant award. Travel costs, including the reason and scope, have a high audit profile and are routinely examined by auditors and other government stakeholders. Grantees must be prudent with costs and perception. Condition Found: The Organization did not have an internal control process to track and confirm that all travel reimbursements charged to SSVF were properly supported including documentation of the purpose of the travel costs in relation to SSVF. Context: We sampled payment for a taxi in the amount of approximately $100, using a nonstatistical sample, with no supporting documentation as to the business purpose behind the ride and the relation to the SSVF grant. The SSVF grant was charged approximately $13,000 of total mileage reimbursements and travel costs during 2020. Questioned Costs: $100 of known unsupported costs. Cause and Effect: The Organization was aware of the requirement to implement a process of tracking travel costs and the purpose of the travel as part of the SSVF program, however has not implemented a process to track or review travel costs. As a result, there is a risk of inappropriate travel costs to be charged the SSVF grant fund. Identification as a Repeat Finding, if Applicable: A repeat finding. Recommendation: We recommend the Organization implement a process of obtaining proper support for all travel costs submitted for reimbursement and documented review of mileage reimbursements to confirm satisfaction of compliance restrictions set forth by the SSVF Program Guide. We also recommend that the Organization provide additional training to employees submitting and approving mileage reimbursements of what is considerable allowable under the grant and what constitutes proper supporting documentation. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan attached.

Corrective Action Plan

During 2020, the Organization had gone through a significant amount of turnover at the management level and in the finance department. These changes have resulted in the identification of a significant lack of internal controls as well as a lack of resources. The Organization has gone through a process of hiring new finance positions and engaging outside consultants as needed. With a change in leadership and an increase in resources, the Organization is in the process of implementing a system of internal controls that will focus on segregation of duties related to all significant transaction cycles (including monthly close procedures), increasing communication and transparency of transactions within the Organization, and a heightened sense of documentation to support all transactions, including grant funded activity. The goal of implementing this system of controls is to mitigate the risk of any wrongdoing, intentional or unintentional, at the Organization and to allow for proper compliance with restrictions set forth by government agencies. Responsible party: Rocco Vandermerwe; Deputy Director & CFO; (978) 372-3626 Anticipated completion date: June 30, 2021

Prior Finding References

2019-009

About Allowable Costs / Cost Principles →
2020-009
Cost Allowability
MATERIAL WEAKNESSQUESTIONED COSTS

Finding Number: 2020-009 Information on the Federal Program: Federal Agency: United States Department of Veteran Affairs Program Name: SSVF CFDA: 64.033 Federal Award Identification Number: 14-MA-209 Federal Award Year: 2020 Specific Requirement: In accordance with the SSVF Program Guide, dated December 2019, temporary financial assistance payments are permissible on behalf of participants to help the participant remain in permanent housing or obtain permanent housing and meeting all other requirements set forth in 38 CFR 62.33 and 38 CFR 62.34. Condition Found: During our audit, we noted one instance of a security deposit paid to a landlord on behalf of an individual not identified as a SSVF participant. Context: We selected a sample of 14 vendor disbursements funded by the SSVF grant , using a nonstatistical sample. Of the 14 sample selection, 11 were for temporary financial assistance payments. Questioned Costs: $2,200 of known unsupported costs. Cause and Effect: The Organization was aware of the requirement to implement a process of specifically identifying veteran families benefiting the SSVF program, however, since a process has not implemented or performed, there is a risk of inappropriate costs to be charged to the SSVF grant funds. Recommendation: We recommend the Organization implement a process when making bulk purchase orders to document the specific veteran families benefiting from the purchase to confirm satisfaction of compliance restrictions set forth by the SSVF Program Guide. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan attached.

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Full finding narrative

Finding Number: 2020-009 Information on the Federal Program: Federal Agency: United States Department of Veteran Affairs Program Name: SSVF CFDA: 64.033 Federal Award Identification Number: 14-MA-209 Federal Award Year: 2020 Specific Requirement: In accordance with the SSVF Program Guide, dated December 2019, temporary financial assistance payments are permissible on behalf of participants to help the participant remain in permanent housing or obtain permanent housing and meeting all other requirements set forth in 38 CFR 62.33 and 38 CFR 62.34. Condition Found: During our audit, we noted one instance of a security deposit paid to a landlord on behalf of an individual not identified as a SSVF participant. Context: We selected a sample of 14 vendor disbursements funded by the SSVF grant , using a nonstatistical sample. Of the 14 sample selection, 11 were for temporary financial assistance payments. Questioned Costs: $2,200 of known unsupported costs. Cause and Effect: The Organization was aware of the requirement to implement a process of specifically identifying veteran families benefiting the SSVF program, however, since a process has not implemented or performed, there is a risk of inappropriate costs to be charged to the SSVF grant funds. Recommendation: We recommend the Organization implement a process when making bulk purchase orders to document the specific veteran families benefiting from the purchase to confirm satisfaction of compliance restrictions set forth by the SSVF Program Guide. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan attached.

Corrective Action Plan

During 2020, the Organization had gone through a significant amount of turnover at the management level and in the finance department. These changes have resulted in the identification of a significant lack of internal controls as well as a lack of resources. The Organization has gone through a process of hiring new finance positions and engaging outside consultants as needed. With a change in leadership and an increase in resources, the Organization is in the process of implementing a system of internal controls that will focus on segregation of duties related to all significant transaction cycles (including monthly close procedures), increasing communication and transparency of transactions within the Organization, and a heightened sense of documentation to support all transactions, including grant funded activity. The goal of implementing this system of controls is to mitigate the risk of any wrongdoing, intentional or unintentional, at the Organization and to allow for proper compliance with restrictions set forth by government agencies. Responsible party: Rocco Vandermerwe; Deputy Director & CFO; (978) 372-3626 Anticipated completion date: June 30, 2021

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2020-010
Eligibility
MATERIAL WEAKNESSREPEAT

Finding Number: 2020-010 Information on the Federal Program: Federal Agency: United States Department of Veteran Affairs Program Name: SSVF CFDA: 64.033 Federal Award Identification Number: 14-MA-209 Federal Award Year: 2020 Specific Requirement: In accordance with the SSVF Program Guide, dated December 2019, an organization must maintain adequate eligibility documentation. Grantees must implement policies and procedures that ensure appropriate documentation is obtained and is included in each participant?s file. Condition Found: During our testing of participant eligibility, we noted the following: 1. Eligibility and other required documentation required to be maintained in participant files could not be located for 4 participants out of the 40 selected for testing. 2. Key documentation was not maintained in 7 participants out of the 40 selected for testing. 3. Required documentation for participants eligible through the Veterans Affairs Supporting Housing (VASH) program was not maintained for 6 participants out of the 15 VASH eligible included in our sample. 4. Documented approval by either the Program Coordinator or the Case Manager was missing for documentation related to 5 participant files out of the 40 selected for testing. 5. 90-day eligibility recertifications were not performed or not documented appropriately for 21 participants out of the 32 requiring recertification. 6. Participants were not exited timely from the program or did not have a formal exit performed for 16 participants out of the 31 requiring recertification. Context: We sampled 40 participants out of 538 total participants, using a nonstatistical sample, who were provided support from the Organization?s SSVF program. Questioned Costs: N/A Cause and Effect: The Organization is aware of the eligibility requirements under the SSVF program; but was unaware of the importance of retaining all of the required documentation set forth in the SSVF Program Guide. Under the terms of the SSVF grant, grantees with insufficient case file documentation may be found out of compliance with SSVF Program regulations. The Organization also is at risk for providing services to ineligible participants. As a result of the Organization?s inability to provide certain documents, compliance over eligibility was unable to be tested. Identification as a Repeat Finding, if Applicable: A repeat finding. Recommendation: We recommend the Organization implement a system of controls that would properly document the eligibility requirements of participants under the SSVF program and compliance with the eligibility requirements set forth under the SSVF program. Participants? documented eligibility should be properly reviewed, evidenced by appropriate supervisor signatures. All eligibility forms, recertification forms and other required forms should be maintained in a file for each participant. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan attached.

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Full finding narrative

Finding Number: 2020-010 Information on the Federal Program: Federal Agency: United States Department of Veteran Affairs Program Name: SSVF CFDA: 64.033 Federal Award Identification Number: 14-MA-209 Federal Award Year: 2020 Specific Requirement: In accordance with the SSVF Program Guide, dated December 2019, an organization must maintain adequate eligibility documentation. Grantees must implement policies and procedures that ensure appropriate documentation is obtained and is included in each participant?s file. Condition Found: During our testing of participant eligibility, we noted the following: 1. Eligibility and other required documentation required to be maintained in participant files could not be located for 4 participants out of the 40 selected for testing. 2. Key documentation was not maintained in 7 participants out of the 40 selected for testing. 3. Required documentation for participants eligible through the Veterans Affairs Supporting Housing (VASH) program was not maintained for 6 participants out of the 15 VASH eligible included in our sample. 4. Documented approval by either the Program Coordinator or the Case Manager was missing for documentation related to 5 participant files out of the 40 selected for testing. 5. 90-day eligibility recertifications were not performed or not documented appropriately for 21 participants out of the 32 requiring recertification. 6. Participants were not exited timely from the program or did not have a formal exit performed for 16 participants out of the 31 requiring recertification. Context: We sampled 40 participants out of 538 total participants, using a nonstatistical sample, who were provided support from the Organization?s SSVF program. Questioned Costs: N/A Cause and Effect: The Organization is aware of the eligibility requirements under the SSVF program; but was unaware of the importance of retaining all of the required documentation set forth in the SSVF Program Guide. Under the terms of the SSVF grant, grantees with insufficient case file documentation may be found out of compliance with SSVF Program regulations. The Organization also is at risk for providing services to ineligible participants. As a result of the Organization?s inability to provide certain documents, compliance over eligibility was unable to be tested. Identification as a Repeat Finding, if Applicable: A repeat finding. Recommendation: We recommend the Organization implement a system of controls that would properly document the eligibility requirements of participants under the SSVF program and compliance with the eligibility requirements set forth under the SSVF program. Participants? documented eligibility should be properly reviewed, evidenced by appropriate supervisor signatures. All eligibility forms, recertification forms and other required forms should be maintained in a file for each participant. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan attached.

Corrective Action Plan

During 2020, the Organization had gone through a significant amount of turnover at the management level and in the finance department. These changes have resulted in the identification of a significant lack of internal controls as well as a lack of resources. The Organization has gone through a process of hiring new finance positions and engaging outside consultants as needed. With a change in leadership and an increase in resources, the Organization is in the process of implementing a system of internal controls that will focus on segregation of duties related to all significant transaction cycles (including monthly close procedures), increasing communication and transparency of transactions within the Organization, and a heightened sense of documentation to support all transactions, including grant funded activity. The goal of implementing this system of controls is to mitigate the risk of any wrongdoing, intentional or unintentional, at the Organization and to allow for proper compliance with restrictions set forth by government agencies. Responsible party: Rocco Vandermerwe; Deputy Director & CFO; (978) 372-3626 Anticipated completion date: June 30, 2021

Prior Finding References

2019-011

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2020-011
Cost Allowability
MATERIAL WEAKNESSQUESTIONED COSTS

Finding Number: 2020-011 Information on the Federal Program: Federal Agency: United States Department of Veteran Affairs Program Name: GPD CFDA: 64.024 Federal Award Identification Number: N/A Federal Award Year: 2020 Specific Requirement: In accordance with the VA GPD Program Grant Recipient Guide, per diem payment is for services and housing by day so you must?at a minimum?provide an invoice reflecting which Veterans receive which services on which days. Condition Found: During our audit, we noted instances of disbursements to vendors that did not provide support to specifically identify a veteran family associated with the GPD program. Context: We selected a sample of 21 vendor disbursements funded by the GPD grant, using a nonstatistical sample. Of the 21 sample selection, the support provided for 6 disbursements did not include documentation as to the specific veteran family benefiting from the disbursement. Questioned Costs: $3,856 of known unsupported costs. Cause and Effect: The Organization was unaware of the requirement to implement a process of specifically identifying veteran families benefiting from the purpose when supported by the GPD program. Since a process had not been implemented or performed, there is a risk of inappropriate costs to be charged to the GPD grant funds. Recommendation: We recommend the Organization implement a to verify that all purchases include documentation of the specific veteran families benefiting from the purchase to confirm satisfaction of compliance restrictions set forth by the VA GPD Program Grant Recipient Guide. We also recommend that the Organization provide additional training to employees submitting and approving requests for payment of what is considerable allowable under the grant and what constitutes proper supporting documentation. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan attached.

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Full finding narrative

Finding Number: 2020-011 Information on the Federal Program: Federal Agency: United States Department of Veteran Affairs Program Name: GPD CFDA: 64.024 Federal Award Identification Number: N/A Federal Award Year: 2020 Specific Requirement: In accordance with the VA GPD Program Grant Recipient Guide, per diem payment is for services and housing by day so you must?at a minimum?provide an invoice reflecting which Veterans receive which services on which days. Condition Found: During our audit, we noted instances of disbursements to vendors that did not provide support to specifically identify a veteran family associated with the GPD program. Context: We selected a sample of 21 vendor disbursements funded by the GPD grant, using a nonstatistical sample. Of the 21 sample selection, the support provided for 6 disbursements did not include documentation as to the specific veteran family benefiting from the disbursement. Questioned Costs: $3,856 of known unsupported costs. Cause and Effect: The Organization was unaware of the requirement to implement a process of specifically identifying veteran families benefiting from the purpose when supported by the GPD program. Since a process had not been implemented or performed, there is a risk of inappropriate costs to be charged to the GPD grant funds. Recommendation: We recommend the Organization implement a to verify that all purchases include documentation of the specific veteran families benefiting from the purchase to confirm satisfaction of compliance restrictions set forth by the VA GPD Program Grant Recipient Guide. We also recommend that the Organization provide additional training to employees submitting and approving requests for payment of what is considerable allowable under the grant and what constitutes proper supporting documentation. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan attached.

Corrective Action Plan

During 2020, the Organization had gone through a significant amount of turnover at the management level and in the finance department. These changes have resulted in the identification of a significant lack of internal controls as well as a lack of resources. The Organization has gone through a process of hiring new finance positions and engaging outside consultants as needed. With a change in leadership and an increase in resources, the Organization is in the process of implementing a system of internal controls that will focus on segregation of duties related to all significant transaction cycles (including monthly close procedures), increasing communication and transparency of transactions within the Organization, and a heightened sense of documentation to support all transactions, including grant funded activity. The goal of implementing this system of controls is to mitigate the risk of any wrongdoing, intentional or unintentional, at the Organization and to allow for proper compliance with restrictions set forth by government agencies. Responsible party: Rocco Vandermerwe; Deputy Director & CFO; (978) 372-3626 Anticipated completion date: June 30, 2021

About Allowable Costs / Cost Principles →
2020-012
Eligibility
MATERIAL WEAKNESS

Finding Number: 2020-012 Information on the Federal Program: Federal Agency: United States Department of Veteran Affairs Program Name: GPD CFDA: 64.024 Federal Award Identification Number: N/A Federal Award Year: 2020 Specific Requirement: In accordance with the VA GPD Program Grant Recipient Guide, "GPD grantee may receive per diem payments for homeless Veterans for whom VA authorized the provision of supportive housing or supportive services." Furthermore, for the Transition in Place program, "It is expected that Veterans will receive transition in place supportive services for approximately 6 to 12 months before assuming permanent occupancy of the unit. Any extension beyond 12 month requires prior written approval from the GPD liaison." Condition Found: During our testing of participant eligibility, we noted the following: 1. Certifications of eligibility for participants was not maintained in the participants file for 2 out of the 40 selected for testing. 2. Documented approval of eligibility for participants by the Program Director was missing for 3 participant files out of the 40 selected for testing. 3. No evidence maintained in the participant file that the VA approved the services to be provided related to 7 out of the 40 selected for testing. 4. Documentation to support the veteran status was not maintained in the participant file related to 4 out of 40 selected for testing. 5. The homelessness certification was not obtained or maintained in the participant file for 8 out of the 40 selected for testing. Context: We sampled 40 participants out of 86 total participants who were provided support from the Organization?s GPD program, using a nonstatistical sample. Questioned Costs: N/A Cause and Effect: The Organization is aware of the eligibility requirements under the GPD program; but was unaware of the importance of retaining all of the required documentation set forth in the VA GPD Program Grant Recipient Guide Under the terms of the GPD grant, grantees with insufficient case file documentation may be found out of compliance with GPD Program regulations. The Organization also is at risk for providing services to ineligible participants. As a result of the Organization?s inability to provide certain documents, compliance over eligibility was unable to be tested. Recommendation: We recommend the Organization implement a system of controls that would properly document the eligibility requirements of participants under the GPD program and compliance with the eligibility requirements set forth under the VA GPD Program Grant Recipient Guide. Participants? documented eligibility should be properly reviewed, evidenced by appropriate supervisor signatures. All eligibility forms, recertification forms and other required forms should be maintained in a file for each participant. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan attached.

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Full finding narrative

Finding Number: 2020-012 Information on the Federal Program: Federal Agency: United States Department of Veteran Affairs Program Name: GPD CFDA: 64.024 Federal Award Identification Number: N/A Federal Award Year: 2020 Specific Requirement: In accordance with the VA GPD Program Grant Recipient Guide, "GPD grantee may receive per diem payments for homeless Veterans for whom VA authorized the provision of supportive housing or supportive services." Furthermore, for the Transition in Place program, "It is expected that Veterans will receive transition in place supportive services for approximately 6 to 12 months before assuming permanent occupancy of the unit. Any extension beyond 12 month requires prior written approval from the GPD liaison." Condition Found: During our testing of participant eligibility, we noted the following: 1. Certifications of eligibility for participants was not maintained in the participants file for 2 out of the 40 selected for testing. 2. Documented approval of eligibility for participants by the Program Director was missing for 3 participant files out of the 40 selected for testing. 3. No evidence maintained in the participant file that the VA approved the services to be provided related to 7 out of the 40 selected for testing. 4. Documentation to support the veteran status was not maintained in the participant file related to 4 out of 40 selected for testing. 5. The homelessness certification was not obtained or maintained in the participant file for 8 out of the 40 selected for testing. Context: We sampled 40 participants out of 86 total participants who were provided support from the Organization?s GPD program, using a nonstatistical sample. Questioned Costs: N/A Cause and Effect: The Organization is aware of the eligibility requirements under the GPD program; but was unaware of the importance of retaining all of the required documentation set forth in the VA GPD Program Grant Recipient Guide Under the terms of the GPD grant, grantees with insufficient case file documentation may be found out of compliance with GPD Program regulations. The Organization also is at risk for providing services to ineligible participants. As a result of the Organization?s inability to provide certain documents, compliance over eligibility was unable to be tested. Recommendation: We recommend the Organization implement a system of controls that would properly document the eligibility requirements of participants under the GPD program and compliance with the eligibility requirements set forth under the VA GPD Program Grant Recipient Guide. Participants? documented eligibility should be properly reviewed, evidenced by appropriate supervisor signatures. All eligibility forms, recertification forms and other required forms should be maintained in a file for each participant. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan attached.

Corrective Action Plan

During 2020, the Organization had gone through a significant amount of turnover at the management level and in the finance department. These changes have resulted in the identification of a significant lack of internal controls as well as a lack of resources. The Organization has gone through a process of hiring new finance positions and engaging outside consultants as needed. With a change in leadership and an increase in resources, the Organization is in the process of implementing a system of internal controls that will focus on segregation of duties related to all significant transaction cycles (including monthly close procedures), increasing communication and transparency of transactions within the Organization, and a heightened sense of documentation to support all transactions, including grant funded activity. The goal of implementing this system of controls is to mitigate the risk of any wrongdoing, intentional or unintentional, at the Organization and to allow for proper compliance with restrictions set forth by government agencies. Responsible party: Rocco Vandermerwe; Deputy Director & CFO; (978) 372-3626 Anticipated completion date: June 30, 2021

About Eligibility →

FY 2019-06-30

FAC accepted this audit on April 2, 2020 — management decision was due October 2, 2020.

2019-007
Other
MATERIAL WEAKNESS

Finding Number: 2019-007 Information on the Federal Program: Federal Agency: United States Department of Veteran Affairs, Program Name: VA Supportive Services for Veteran Families Program (SSVF), CFDA: 64.033, Federal Award Identification Number: 14-MA-209, Federal Award Year: 2019 Specific Requirement: In accordance with Title 2 U.S. Code of Federal Regulations Part 200, Subpart D, Section 200.303a, the Organization is 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. Condition Found: We noted there was limited or no segregation of duties in several areas during our audit. See Section II for findings 2019-001, 2019-002, 2019-004, and 2019-005. Context: We noted these conditions while obtaining an understanding of internal control for the respective transaction cycles listed in the findings. Questioned Costs: None noted Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan attached.

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Full finding narrative

Finding Number: 2019-007 Information on the Federal Program: Federal Agency: United States Department of Veteran Affairs, Program Name: VA Supportive Services for Veteran Families Program (SSVF), CFDA: 64.033, Federal Award Identification Number: 14-MA-209, Federal Award Year: 2019 Specific Requirement: In accordance with Title 2 U.S. Code of Federal Regulations Part 200, Subpart D, Section 200.303a, the Organization is 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. Condition Found: We noted there was limited or no segregation of duties in several areas during our audit. See Section II for findings 2019-001, 2019-002, 2019-004, and 2019-005. Context: We noted these conditions while obtaining an understanding of internal control for the respective transaction cycles listed in the findings. Questioned Costs: None noted Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan attached.

Corrective Action Plan

During 2019, the Organization had gone through a significant amount of turnover at the management level and in the finance department. These changes have resulted in the identification of a significant lack of internal controls as well as a lack of resources. The Organization has gone through a process of hiring new finance positions and engaging outside consultants as needed. With a change in leadership and an increase in resources, the Organization is in the process of implementing a system of internal controls that will focus on segregation of duties related to all significant transaction cycles (including monthly close procedures), increasing communication and transparency of transactions within the Organization, and a heightened sense of documentation to support all transactions, including grant funded activity. The goal of implementing this system of controls is to mitigate the risk of any wrongdoing, intentional or unintentional, at the Organization and to allow for proper compliance with restrictions set forth by government agencies. Responsible party: Rocco Vandermerwe; Deupty Director & CFO; (978) 372-3626

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2019-008
Procurement & Suspension/Debarment
MATERIAL WEAKNESS

Finding Number: 2019-008 Information on the Federal Program: Federal Agency: United States Department of Veteran Affairs, Program Name: SSVF, CFDA: 64.033, Federal Award Identification Number: 14-MA-209, Federal Award Year: 2019 Specific Requirement: Required by 2 CFR, Part 200 for federally funded programs, when an institution enters into a covered transaction with an entity or individual, an institution must verify that the vendor is not suspended or debarred or otherwise excluded from participating in federal programs. Generally, a covered transaction is a transaction expected to equal or exceed $25,000 and be funded with federal dollars. This verification may be accomplished by checking the System for Award Management (SAM), formerly the Excluded Parties List System, maintained by the General Services Administration, collecting a certification from the vendor, or by adding a clause or condition to the covered transaction. Condition Found: The Organization did not have an internal control procedure designed to identify vendors and employees meeting the covered transaction threshold and crosschecking those vendors and employees against SAM. None of the vendors or employees in out sample were identified on SAM. Context: We selected a sample of 17 vendors and 23 employees funded by SSVF. Questioned Costs: None Cause and Effect: The Organization was unaware of the requirement to verify vendors and employees against the SAM and as a result had not implemented a process during the year ended June 30, 2019 to verify vendors or employees. Without performing the required check of vendors and employees against SAM, the Organization could pay a vendor or an employee with federal funds inappropriately. Recommendation: We recommend the Organization implement a process to compare all vendors and employees meeting the covered transaction threshold funded by a federal program to SAM on a regular basis and when a new vendor or employee is entered into the accounting system. The Organization should maintain documentation that the comparison has been performed. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan attached.

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Full finding narrative

Finding Number: 2019-008 Information on the Federal Program: Federal Agency: United States Department of Veteran Affairs, Program Name: SSVF, CFDA: 64.033, Federal Award Identification Number: 14-MA-209, Federal Award Year: 2019 Specific Requirement: Required by 2 CFR, Part 200 for federally funded programs, when an institution enters into a covered transaction with an entity or individual, an institution must verify that the vendor is not suspended or debarred or otherwise excluded from participating in federal programs. Generally, a covered transaction is a transaction expected to equal or exceed $25,000 and be funded with federal dollars. This verification may be accomplished by checking the System for Award Management (SAM), formerly the Excluded Parties List System, maintained by the General Services Administration, collecting a certification from the vendor, or by adding a clause or condition to the covered transaction. Condition Found: The Organization did not have an internal control procedure designed to identify vendors and employees meeting the covered transaction threshold and crosschecking those vendors and employees against SAM. None of the vendors or employees in out sample were identified on SAM. Context: We selected a sample of 17 vendors and 23 employees funded by SSVF. Questioned Costs: None Cause and Effect: The Organization was unaware of the requirement to verify vendors and employees against the SAM and as a result had not implemented a process during the year ended June 30, 2019 to verify vendors or employees. Without performing the required check of vendors and employees against SAM, the Organization could pay a vendor or an employee with federal funds inappropriately. Recommendation: We recommend the Organization implement a process to compare all vendors and employees meeting the covered transaction threshold funded by a federal program to SAM on a regular basis and when a new vendor or employee is entered into the accounting system. The Organization should maintain documentation that the comparison has been performed. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan attached.

Corrective Action Plan

During 2019, the Organization had gone through a significant amount of turnover at the management level and in the finance department. These changes have resulted in the identification of a significant lack of internal controls as well as a lack of resources. The Organization has gone through a process of hiring new finance positions and engaging outside consultants as needed. With a change in leadership and an increase in resources, the Organization is in the process of implementing a system of internal controls that will focus on segregation of duties related to all significant transaction cycles (including monthly close procedures), increasing communication and transparency of transactions within the Organization, and a heightened sense of documentation to support all transactions, including grant funded activity. The goal of implementing this system of controls is to mitigate the risk of any wrongdoing, intentional or unintentional, at the Organization and to allow for proper compliance with restrictions set forth by government agencies. Responsible party: Rocco Vandermerwe; Deupty Director & CFO; (978) 372-3626

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2019-009
Cost Allowability
MATERIAL WEAKNESSQUESTIONED COSTS

Finding Number: 2019-009 Information on the Federal Program: Federal Agency: United States Department of Veteran Affairs, Program Name: SSVF, CFDA: 64.033, Federal Award Identification Number: 14-MA-209, Federal Award Year: 2019 Specific Requirement: In accordance with the SSVF Program Guide, dated December 1, 2018, travel is allowable as a direct program cost when such travel will provide direct benefit to the SSVF program and grant award. Travel costs, including the reason and scope, have a high audit profile and are routinely examined by auditors and other government stakeholders. Grantees must be prudent with costs and perception. Condition Found: The Organization did not have an internal control process to track and confirm that all travel reimbursements charged to SSVF were properly supported including documentation of the purpose of the travel costs in relation to SSVF. Context: We sampled one mileage reimbursement in the amount of approximately $600 with no supporting documentation. The SSVF grant was charged approximately $20,000 of total mileage reimbursement during 2019. Questioned Costs: $600 of known unsupported costs. Cause and Effect: The Organization was unaware of the requirement to implement a process of tracking travel costs and the purpose of the travel as part of the SSVF program. Since a process has not been implemented or performed, there is a risk of inappropriate travel costs to be charged the SSVF grant funds. Recommendation: We recommend the Organization implement a process of obtaining proper support for all travel costs submitted for reimbursement and documented review of mileage reimbursements to confirm satisfaction of compliance restrictions set forth by the SSVF Program Guide. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan attached.

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Full finding narrative

Finding Number: 2019-009 Information on the Federal Program: Federal Agency: United States Department of Veteran Affairs, Program Name: SSVF, CFDA: 64.033, Federal Award Identification Number: 14-MA-209, Federal Award Year: 2019 Specific Requirement: In accordance with the SSVF Program Guide, dated December 1, 2018, travel is allowable as a direct program cost when such travel will provide direct benefit to the SSVF program and grant award. Travel costs, including the reason and scope, have a high audit profile and are routinely examined by auditors and other government stakeholders. Grantees must be prudent with costs and perception. Condition Found: The Organization did not have an internal control process to track and confirm that all travel reimbursements charged to SSVF were properly supported including documentation of the purpose of the travel costs in relation to SSVF. Context: We sampled one mileage reimbursement in the amount of approximately $600 with no supporting documentation. The SSVF grant was charged approximately $20,000 of total mileage reimbursement during 2019. Questioned Costs: $600 of known unsupported costs. Cause and Effect: The Organization was unaware of the requirement to implement a process of tracking travel costs and the purpose of the travel as part of the SSVF program. Since a process has not been implemented or performed, there is a risk of inappropriate travel costs to be charged the SSVF grant funds. Recommendation: We recommend the Organization implement a process of obtaining proper support for all travel costs submitted for reimbursement and documented review of mileage reimbursements to confirm satisfaction of compliance restrictions set forth by the SSVF Program Guide. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan attached.

Corrective Action Plan

During 2019, the Organization had gone through a significant amount of turnover at the management level and in the finance department. These changes have resulted in the identification of a significant lack of internal controls as well as a lack of resources. The Organization has gone through a process of hiring new finance positions and engaging outside consultants as needed. With a change in leadership and an increase in resources, the Organization is in the process of implementing a system of internal controls that will focus on segregation of duties related to all significant transaction cycles (including monthly close procedures), increasing communication and transparency of transactions within the Organization, and a heightened sense of documentation to support all transactions, including grant funded activity. The goal of implementing this system of controls is to mitigate the risk of any wrongdoing, intentional or unintentional, at the Organization and to allow for proper compliance with restrictions set forth by government agencies. Responsible party: Rocco Vandermerwe; Deupty Director & CFO; (978) 372-3626

About Allowable Costs / Cost Principles →
2019-010
Cost Allowability
MATERIAL WEAKNESSQUESTIONED COSTS

Finding Number: 2019-010 Information on the Federal Program: Federal Agency: United States Department of Veteran Affairs, Program Name: SSVF, CFDA: 64.033, Federal Award Identification Number: 14-MA-209, Federal Award Year: 2019 Specific Requirement: In accordance with the SSVF Program Guide, dated December 1, 2018, organizations are not allowed to bulk purchase items, unless each item is necessary for a specific identified veteran family. Condition Found: During our audit, we noted instances of disbursements to vendors on bulk purchases that did not provide support to specifically identify a veteran family associated with the SSVF program. Context: We selected a sample of 17 vendor disbursements funded by the SSVF grant. Of the 17 sample selection, three disbursements included bulk purchases and of those three disbursements, two did not have supporting documentation as to the specific veteran family benefiting from the disbursement. Questioned Costs: $997 of known unsupported costs. Cause and Effect: The Organization was unaware of the requirement to implement a process of specifically identifying veteran families benefiting from bulk purchases when supporting the SSVF program. Since a process had not been implemented or performed, there is a risk of inappropriate costs to be charged to the SSVF grant funds. Recommendation: We recommend the Organization implement a process when making bulk purchase orders to document the specific veteran families benefiting from the purchase to confirm satisfaction of compliance restrictions set forth by the SSVF Program Guide. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan attached.

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Full finding narrative

Finding Number: 2019-010 Information on the Federal Program: Federal Agency: United States Department of Veteran Affairs, Program Name: SSVF, CFDA: 64.033, Federal Award Identification Number: 14-MA-209, Federal Award Year: 2019 Specific Requirement: In accordance with the SSVF Program Guide, dated December 1, 2018, organizations are not allowed to bulk purchase items, unless each item is necessary for a specific identified veteran family. Condition Found: During our audit, we noted instances of disbursements to vendors on bulk purchases that did not provide support to specifically identify a veteran family associated with the SSVF program. Context: We selected a sample of 17 vendor disbursements funded by the SSVF grant. Of the 17 sample selection, three disbursements included bulk purchases and of those three disbursements, two did not have supporting documentation as to the specific veteran family benefiting from the disbursement. Questioned Costs: $997 of known unsupported costs. Cause and Effect: The Organization was unaware of the requirement to implement a process of specifically identifying veteran families benefiting from bulk purchases when supporting the SSVF program. Since a process had not been implemented or performed, there is a risk of inappropriate costs to be charged to the SSVF grant funds. Recommendation: We recommend the Organization implement a process when making bulk purchase orders to document the specific veteran families benefiting from the purchase to confirm satisfaction of compliance restrictions set forth by the SSVF Program Guide. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan attached.

Corrective Action Plan

During 2019, the Organization had gone through a significant amount of turnover at the management level and in the finance department. These changes have resulted in the identification of a significant lack of internal controls as well as a lack of resources. The Organization has gone through a process of hiring new finance positions and engaging outside consultants as needed. With a change in leadership and an increase in resources, the Organization is in the process of implementing a system of internal controls that will focus on segregation of duties related to all significant transaction cycles (including monthly close procedures), increasing communication and transparency of transactions within the Organization, and a heightened sense of documentation to support all transactions, including grant funded activity. The goal of implementing this system of controls is to mitigate the risk of any wrongdoing, intentional or unintentional, at the Organization and to allow for proper compliance with restrictions set forth by government agencies. Responsible party: Rocco Vandermerwe; Deupty Director & CFO; (978) 372-3626

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2019-011
Eligibility
MATERIAL WEAKNESS

Finding Number: 2019-011 Information on the Federal Program: Federal Agency: United States Department of Veteran Affairs. Program Name: SSVF, CFDA: 64.033, Federal Award Identification Number: 14-MA-209, Federal Award Year: 2019 Specific Requirement: In accordance with the SSVF Program Guide, dated December 1, 2018, an organization must maintain adequate eligibility documentation. Grantees must implement policies and procedures that ensure appropriate documentation is obtained and is included in each participant?s file. Condition Found: During our testing of participant eligibility, we noted the following: 1. Eligibility and other required documentation required to be maintained in participant files could not be located for 4 participants out of the 40 selected for testing. 2. Documented approval by either the Program Coordinator or the Case Manager was missing for documentation related to 20 participant files out of the 40 selected for testing. 3. 90-day eligibility recertifications were not performed or not documented appropriately for 7 participants out of the 19 requiring recertification. Context: We sampled 40 participants out of 550 total participants who were provided support from the Organization?s SSVF program. Questioned Costs: N/A Cause and Effect: The Organization is aware of the eligibility requirements under the SSVF program; but, was unaware of the importance of retaining all of the required documentation set forth in the SSVF Program Guide. Under the terms of the SSVF grant, grantees with insufficient case file documentation may be found out of compliance with SSVF Program regulations. The Organization also is at risk for providing services to ineligible participants. Recommendation: We recommend the Organization implement a system of controls that would properly document the eligibility requirements of participants under the SSVF program and compliance with the eligibility requirements set forth under the SSVF program. Participants? documented eligibility should be properly reviewed, evidenced by appropriate supervisor signatures. All eligibility forms, recertification forms and other required forms should be maintained in a file for each participant. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan attached.

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Full finding narrative

Finding Number: 2019-011 Information on the Federal Program: Federal Agency: United States Department of Veteran Affairs. Program Name: SSVF, CFDA: 64.033, Federal Award Identification Number: 14-MA-209, Federal Award Year: 2019 Specific Requirement: In accordance with the SSVF Program Guide, dated December 1, 2018, an organization must maintain adequate eligibility documentation. Grantees must implement policies and procedures that ensure appropriate documentation is obtained and is included in each participant?s file. Condition Found: During our testing of participant eligibility, we noted the following: 1. Eligibility and other required documentation required to be maintained in participant files could not be located for 4 participants out of the 40 selected for testing. 2. Documented approval by either the Program Coordinator or the Case Manager was missing for documentation related to 20 participant files out of the 40 selected for testing. 3. 90-day eligibility recertifications were not performed or not documented appropriately for 7 participants out of the 19 requiring recertification. Context: We sampled 40 participants out of 550 total participants who were provided support from the Organization?s SSVF program. Questioned Costs: N/A Cause and Effect: The Organization is aware of the eligibility requirements under the SSVF program; but, was unaware of the importance of retaining all of the required documentation set forth in the SSVF Program Guide. Under the terms of the SSVF grant, grantees with insufficient case file documentation may be found out of compliance with SSVF Program regulations. The Organization also is at risk for providing services to ineligible participants. Recommendation: We recommend the Organization implement a system of controls that would properly document the eligibility requirements of participants under the SSVF program and compliance with the eligibility requirements set forth under the SSVF program. Participants? documented eligibility should be properly reviewed, evidenced by appropriate supervisor signatures. All eligibility forms, recertification forms and other required forms should be maintained in a file for each participant. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan attached.

Corrective Action Plan

During 2019, the Organization had gone through a significant amount of turnover at the management level and in the finance department. These changes have resulted in the identification of a significant lack of internal controls as well as a lack of resources. The Organization has gone through a process of hiring new finance positions and engaging outside consultants as needed. With a change in leadership and an increase in resources, the Organization is in the process of implementing a system of internal controls that will focus on segregation of duties related to all significant transaction cycles (including monthly close procedures), increasing communication and transparency of transactions within the Organization, and a heightened sense of documentation to support all transactions, including grant funded activity. The goal of implementing this system of controls is to mitigate the risk of any wrongdoing, intentional or unintentional, at the Organization and to allow for proper compliance with restrictions set forth by government agencies. Responsible party: Rocco Vandermerwe; Deupty Director & CFO; (978) 372-3626

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