LAKE COUNTY CRISIS CENTER FOR THE PREVENTION OF DOMESTIC VIOLENCE, INC DBA A SAFE PLACE

Finding 2023-001 – Significant Deficiency: Reporting - Compliance Finding ALN 16.575 Crime Victim Assistance Program Federal Agency: U.S. Department of Justice Pass-Through Entity: Illinois Criminal Justice Information Authority and Illinois Coalition Against Domestic Violence Criteria or Specific Requirement: Program guidelines require that monthly, quarterly, and annual reports be submitted within 30 days of the end of the period. Condition: Of the eight reports selected for testwork, two reports were not submitted by the applicable deadline. Cause/Context: Management oversight. The individual responsible for performing and reviewing the financial close process in the Finance Department oversees various other cross-departmental responsibilities for A Safe Place and appears to be shorthanded for the financial close process work necessary to be completed accurately and timely. Effect: A Safe Place was in violation of the reporting requirements. Questioned Costs: None Identification As A Repeat Finding: This is a repeat of finding 2022-002 and 2021-005. Recommendation: We recommend that A Safe Place design and implement internal control procedures to ensure the timely submission of all required future reports. Views of Responsible Officials: The lingering effects of the pandemic have caused an unprecedented increase in activity in our domestic violence client base and their needs, and we have been blessed with several new funding sources to meet the demand. This, of course, meant a large increase in the workload required from those needed in the accounting and finance areas. Turnover at the CFO level during this time resulted in some administrative work, including preparation of reports, being put on hold as client services took precedence. The nature of the client services could result in lost lives if not addressed timely.

Finding 2022-001 – Material Weakness: Reporting – Control And Compliance Finding AL 16.034 Coronavirus Emergency Supplemental Funding Federal Agency: U.S. Department of Justice Pass-Through Entity: Illinois Criminal Justice Information Authority Criteria or Specific Requirement: The requirements of the Coronavirus Emergency Supplemental Funding program require that monthly and annual reports be submitted within 30 days of the end of the period. Condition: Of the seven reports selected for testwork, four reports were not submitted by the applicable deadline. Additionally, four reports did not contain evidence of a review by someone other than the preparer, which would have ensured the report was prepared accurately and submitted timely. Cause/Context: Management oversight. The individual responsible for performing and reviewing the financial close process in the Finance Department oversees various other cross-departmental responsibilities for A Safe Place and appears to be shorthanded for the financial close process work necessary to be completed accurately and timely. Effect: A Safe Place was in violation of the reporting requirements associated with the grant. Questioned Costs: None Identification As A Repeat Finding: This is a repeat of finding 2021-005. Recommendation: We recommend that A Safe Place design and implement internal control procedures to ensure the timely submission of all required future reports. Views of Responsible Officials: The lingering effects of the pandemic have caused an unprecedented increase in activity in our domestic violence client base and their needs, and we have been blessed with several new funding sources to meet the demand. This, of course, meant a large increase in the workload required from required from those needed in the accounting and finance areas. Turnover at the CFO level during this time resulted in some administrative work, including preparation of reports, being put on hold as client services took precedence. The nature of the client services could result in lost lives if not addressed timely.

Finding 2022-002 – Material Weakness: Reporting – Control and Compliance Finding AL 16.575 Crime Victim Assistance Program Federal Agency: U.S. Department of Justice Pass-Through Entity: Illinois Criminal Justice Information Authority Criteria or Specific Requirement: The requirements of the Coronavirus Emergency Supplemental Funding program require that monthly and annual reports be submitted within 30 days of the end of the period. Condition: Of the three reports selected for testwork, one report was not submitted by the applicable deadline. Cause/Context: Management oversight. The individual responsible for performing and reviewing the financial close process in the Finance Department oversees various other cross-departmental responsibilities for A Safe Place and appears to be shorthanded for the financial close process work necessary to be completed accurately and timely. Effect: A Safe Place was in violation of the reporting requirements associated with the grant. Questioned Costs: None Identification As A Repeat Finding: This is a repeat of finding 2021-005. Recommendation: We recommend that A Safe Place design and implement internal control procedures to ensure the timely submission of all required future reports. Views of Responsible Officials: The lingering effects of the pandemic have caused an unprecedented increase in activity in our domestic violence client base and their needs, and we have been blessed with several new funding sources to meet the demand. This, of course, meant a large increase in the workload required from required from those needed in the accounting and finance areas. Turnover at the CFO level during this time resulted in some administrative work, including preparation of reports, being put on hold as client services took precedence. The nature of the client services could result in lost lives if not addressed timely.

FINDING 2021-002 ? DOCUMENTATION OF AND INTERNAL CONTROLS OVER COMPLIANCE WITH ELIGIBILITY AND EARMARKING Criteria ? According to the grant agreement, for the grant period of performance, the Organization must maintain evidence of compliance with the eligibility compliance requirement for all participants of the major program awards, especially those earmarked for a specific, targeted population. Further, in accordance with 2.CFR 200.303, the non-Federal entity must 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 ? The Organization improperly tracked the number of program participants who were eligible for limited English proficiency (LEP) awards. Certain participant files, upon inspection, were noted by management to be LEP-eligible participants because they were provided such benefits, however such participants did not mark such notion in the ?Special Needs? section of the Client Intake Form (in English), and no supporting evidence was provided. Additionally, certain participant files, upon inspection, were not noted by management to be LEP-eligible participants because they were not provided such benefits, however such participants marked such notion in the ?Special Needs? section of the Client Intake Form (in English) or the form was in Spanish, indicating LEP eligibility. Questioned Costs ? None. Effect ? The Organization must be able to demonstrate how the major program eligibility requirement is satisfied to be able to support its assertion that all participants meet the minimum requirements to be eligible to benefit from the major program award. Not doing so could lead to adverse action by the grantor. Cause ? Inadequate internal controls over the existence, completeness and accuracy of the participant population and lack of understanding of how to meet the minimum eligibility documentation requirements outlined in the grant agreement. Recommendation ? We recommend that the Organization implement policies, procedures and internal controls to maintain supporting documentation and ensure the existence and completeness of the participant population. The Organization might consider adding a checkbox on the Client Intake/ Eligibility Form for the participant to indicate whether she/he is bilingual, and therefore eligible to benefit from the specific portion of the grant award earmarked for the Underserved. Views of Responsible Officials ? A Safe Place is proud of the services we provide to the Limited English Proficient (LEP) population with its 65% diverse staff who speak and are fluent in the language of the clients served by A Safe Place. Our programs are often highlighted as an organization that is extraordinary in providing services to the LEP population. Unfortunately, the Organization has been provided with a standard intake form which is required to be utilized by the grantor and then entered into the Illinois Infonet System. This system does not capture the necessary LEP information to properly identify the number of LEP participants served. The Organization will work with the grantor to modify the intake form to better capture the data necessary to comply with the terms of the grant agreement. This may be a lengthy process so in the short-term, The Organization will ensure the review process of the intake form properly identifies those receiving LEP benefits which will be independently tracked by program staff. To that end, A Safe Place developed a process whereby staff could include an eligibility statement with the intake file until approval was received to modify the intake document.

FINDING 2021-003 ? IMPROPER AMOUNT OF MATCHING FUNDS APPLIED Criteria ? Most of the various grant agreements under the DOJ specify a 25% matching funds requirement. The specific matching requirement in most of the grant agreements explicitly state ?Grantee certifies that it (a) meets the requirements of this agreement and (b) has at least 20 percent of its support (including in-kind contributions) from sources other than federal funds for the program described in the attached exhibits. Therefore, one dollar in cash or in-kind match is required for each four dollars of federal funding received.? Condition ? We noted that the Organization did not consistently apply the proper matching funds requirement outlined in the major program grant agreements. Questioned Costs ? None. Effect ? The Organization did not apply matching funds of 25%, thus the Organization was not in compliance with the matching funds requirements set forth in the specific grant agreements. Cause ? Inadequate internal controls over compliance with the matching funds requirement stated in the grant agreements. Recommendation ? We recommend that the Organization design and implement internal control procedures to ensure that the matching funds compliance requirements outlined in the grant agreements are met. Views of Responsible Officials ? See below. PRIOR TO COVID-19 Prior to COVID-19, A Safe Place?s key accounting personnel and CFO, was impacted by family illnesses and had to be out of work, and at the same time we experienced the loss of one of our accounting staff, which impacted the staff available to complete the necessary work. DURING COVID-19 The COVID-19 pandemic impacted A Safe Place with unforeseen and extenuating circumstances, never experienced in our history. Crisis calls went up by 635% and emergency shelter clients needing housing services went up by 525%, and to the date of this writing the numbers are still soaring and have not returned to pre-COVID-19 levels. Since the circumstances and effects of the COVID-19 crisis exploded in unprecedented activity in our domestic violence client base and needs, we have been blessed with several new funding sources/grants and have expanded our private fundraising to meet the demand. The increased activity has increased exponentially over the 17 months. This, of course, meant a huge increase in the work needed in the accounting and finance areas to keep our clients safe, housed, fed, counseled, etc. However, COVID-19 then affected us in a more direct way with members of our entire executive, accounting, operations, and administrative staff getting sick/testing positive for COVID-19 and/or affected by quarantine policies for significant stretches of October 2020 thru January 2021. We lost our full-time staff accountant for about 75% of the period October 2020 to January 2021. Our CEO was out for 8+ months with a severe case and there were multiple weeks with our entire executive team out. Whomever was available had to keep operations going and the audit preparations had to wait so we could focus on saving lives with a skeleton crew. With the need for on-going finance/accounting work to serve the needs of our clients, this was a significant loss and affected our ability to assist the auditors on timely basis.

FINDING 2021-004 ? NON-COMPLIANCE AND LIMITED CONTROLS OVER PROCUREMENT, SUSPENSION AND DEBARMENT Criteria ? The Organization?s Procurement Policy should be current with Uniform Guidance. Also, in accordance with 2 CFR 200.213 and 2 CFR part 180 non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred, or otherwise excluded. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. The requirement is for non-federal entities to check for suspended and debarred persons before entering covered transactions. In addition, 2 CFR 200.303 requires that ?The non-Federal entity must: (a)?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 ? The Organization?s Procurement Policy in effect during the year ended June 30, 2021 is not current with Uniform Guidance requirements and does not include provisions or procedures to timely perform or maintain evidence of the required suspension and debarment check on SAM.gov. Questioned Costs ? None. Effect ? The Organization?s Procurement Policy in effect during the year ended June 30, 2021 did not comply with Uniform Guidance and management did not perform or maintain evidence of performing proper suspension and debarment procedures regarding certain vendors of major program vendors prior to obtaining their services. This could have resulted in disallowed costs by the federal grantor. Cause ? The Organization does not have a Procurement Policy consistent with Uniform Guidance including written policies, procedures and controls to ensure compliance with the federal suspension and debarment requirements. Recommendation ? We recommend that the Organization strengthen procedures and internal controls to ensure that the Uniform Guidance requirements for procurement, suspension and debarment requirements are met and that support for the dates and results of suspension and debarment checks is retained. Views of Responsible Officials ? As noted in Finding 2021-001 Views of Responsible Officials, the COVID-19 pandemic impacted A Safe Place with unforeseen and extenuating circumstances, never experienced in our history. The circumstances and effects of the pandemic caused an unprecedented increase in activity in our domestic violence client base and their needs, and we have been blessed with several new funding sources to meet the demand. This, of course, meant a large increase in the workload required from those needed in the accounting and finance areas. Many of our executive, accounting, operations, and administrative staff either contracted COVID-19 or were affected by quarantine policies for significant stretches from October 2020 thru January 2021. Several key employees and members of management including our full-time staff accountant, CEO, and other executive team members were unable to work for long periods of time due to COVID-19 and others within the Organization, including the CFO, had to fill in and work on operational activities. This meant that some administrative work, including the updating of policies to be current with Uniform Guidance requirements was temporarily put on hold as client services took precedence. The nature of the client services could result in lost lives if not addressed timely.

FINDING 2021-005 ? LATE FINANCIAL REPORTING AND LIMITED CONTROLS OVER TIMELY REPORTING Criteria ? The various grant agreements under the DOJ specify certain reporting requirements for different types of reports to be submitted at different times. Condition ? The Organization failed to consistently complete and submit the monthly periodic financial reports by the specific due dates outlined in the grant agreement. Questioned Costs ? None Effect ? Delayed reporting affects the grantor?s ability to exercise effective grantee oversight and could result in grantor's withholding of payments and other adverse actions. Cause ? Management oversight. The individual responsible for performing and reviewing the financial close process in the Finance Department oversees various other cross-departmental responsibilities for the Organization and appears to be shorthanded for the financial close process work necessary to be completed accurately and timely. Recommendation ? We recommend that the Organization design and implement internal control procedures to ensure the timely submission of all required future reports. Views of Responsible Officials ? The COVID-19 pandemic impacted A Safe Place with unforeseen and extenuating circumstances, never experienced in our history. The circumstances and effects of the pandemic caused an unprecedented increase in activity in our domestic violence client base and their needs, and we have been blessed with several new funding sources to meet the demand. This, of course, meant a large increase in the workload required from those needed in the accounting and finance areas. Several key employees and members of management including our full-time staff accountant, CEO, and other executive team members were unable to work for long periods of time due to COVID-19 and others within the Organization, including the CFO, had to fill in and work on operational activities. This meant that some administrative work, including preparation of reports, was put on hold as client services took precedence. The nature of the client services could result in lost lives if not addressed timely.

FINDING 2020-002 ? DOCUMENTATION OF AND INTERNAL CONTROLS OVER COMPLIANCE WITH ELIGIBILITY AND EARMARKING FOR CFDA #16.575 Criteria ? According to the grant agreement, for the grant period of performance, the Organization must maintain evidence of compliance with the eligibility compliance requirement for all participants of the major program awards, especially those earmarked for a specific,targeted population. Further, in accordance with 2.CFR 200.303, the non-Federal entity must 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 ? The Organization improperly tracked the number of program participants who were eligible for limited English proficiency (LEP) awards. Certain participant files, upon inspection, were noted by management to be LEP-eligible participants because they were provided such benefits, however such participants did not mark such notion in the ?Special Needs? section of the Client Intake Form (in English), and no supporting evidence was provided. Additionally, certain participant files, upon inspection, were not noted by management to be LEP-eligible participants because they were not provided such benefits, however such participants marked such notion in the ?Special Needs? section of the Client Intake Form (in English) or the form was in Spanish, indicating LEP eligibility. Questioned Costs ? None. Effect ? The Organization must be able to demonstrate how the major program eligibility requirement is satisfied to be able to support its assertion that all participants meet the minimum requirements to be eligible to benefit from the major program award. Not doing so could lead to adverse action by the grantor. Cause ? Inadequate internal controls over the existence, completeness and accuracy of the participant population and lack of understanding of how to meet the minimum eligibility documentation requirements outlined in the grant agreement. Recommendation ? We recommend that the Organization implement policies, procedures and internal controls to maintain supporting documentation and ensure the existence and completeness of the participant population. The Organization might consider adding a checkbox on the Client Intake/ Eligibility Form for the participant to indicate whether she/he is bilingual, and therefore eligible to benefit from the specific portion of the grant award earmarked for the Underserved. Views of Responsible Officials - A Safe Place is proud of the services we provide to the Limited English Proficient (LEP) population with its 65% diverse staff who speak and are fluent in the language of the clients served by A Safe Place. Our programs are often highlighted as an organization that is extraordinary in providing services to the LEP population. Unfortunately, the Organization has been provided with a standard intake form which is required to be utilized by the grantor and then entered into the Illinois Infonet System. This system does not capture the necessary LEP information to properly identify the number of LEP participants served. The Organization will work with the grantor to modify the intake form to better capture the data necessary to comply with the terms of the grant agreement. This may be a lengthy process so in the short-term, the organization will ensure the review process of the intake form properly identifies those receiving LEP benefits which will be independently tracked by program staff.

FINDING 2020-003 ? LACK OF COMPETITIVE PROCUREMENT FOR CFDA #16.575 Criteria ? In accordance with 2 CFR 200.319 (a), ?All procurement transactions must be conducted in a manner providing full and open competition consistent with the standards of this section?? and in accordance with 2 CFR 200.320 (f), ?Procurement by noncompetitive proposals. Procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when one or more of the following circumstances apply: 1. The item is available only from a single source; 2. The public exigency or emergency for the requirement will not permit a delay resulting from competitive solicitation; 3. The Federal awarding agency or pass-through entity expressly authorizes noncompetitive proposals in response to a written request from the non-Federal entity; or 4. After solicitation of a number of sources, competition is determined inadequate.? Further, the specific procurement requirement in the grant agreement, says ?For procurements of $100,000 or less, Grantee must solicit quotes or bids from at least three sources. For procurements over $100,000, Grantee must formally advertise the proposed procurement through an Invitation for Bids (IFB), or a Request for Proposals (RFP) process.? Condition ? We noted that the Organization did not consistently follow the procurement requirement stated in the major program grant agreement. The Organization?s procurement of certain vendors without evidence of price comparisons or competitive bids did not satisfy the above exception in the Uniform Guidance (UG) to eliminate this requirement. In other circumstances the Organization did not adequately document their satisfaction of compliance with the procurement requirements set forth in the UG or in the specific grant agreement. Questioned Costs ? None. Effect ? Sole source procurement was not sought for costs from a certain vendor charged to the major program without competitive procurement, thus the Organization was not in compliance with the procurement requirements set forth in the Uniform Guidance or in the specific grant agreement. Cause ? Inadequate internal controls over compliance with minimum procurement documentation requirements outlined in the grant agreement, which appears to include every purchase under $100,000, and therefore the Organization was not in compliance. Recommendation ? We recommend that the Organization design and implement internal control procedures to ensure that the Uniform Guidance procurement compliance requirements are followed. In light of the Uniform Guidance update, we recommend that the Organization review its policies and procurement thresholds to be more consistent with those in the Uniform Guidance and the specific grant agreement. Views of Responsible Officials ? This grant agreement is very restrictive in mandating the grantee obtain three separate bids/quotes for ALL expenditures under $100,000. A majority of expenditures outside of wages and salaries are less than $10,000 and the administrative burden to obtain three quotes for all expenditures would be overwhelming to the Organization. A Safe Place will discuss the possibility of modifying the language in the grant agreement with the grantor to more closely align the procurement requirements in the grant with those of the OMB compliance supplement (2 CFR 200.320 (f), ?Procurement by noncompetitive proposals?).

FINDING 2020-004 ? LATE FINANCIAL REPORTING AND LIMITED CONTROLS OVER TIMELY REPORTING FOR CFDA #16.575 Criteria ? The various grant agreements under the DOJ specify certain reporting requirements for different types of reports to be submitted at different times. Condition ? We inspected a sample of reports for the various grants under the DOJ major program and noted 6 instances of late submissions, 2 of which were before COVID-19 and 4 of which were during COVID-19. Questioned Costs ? None Effect ? Delayed reporting affects the grantor?s ability to exercise effective grantee oversight and could result in grantor's withholding of payments and other adverse actions. Cause ? Management oversight. Recommendation ? We recommend that the Organization design and implement internal control procedures to ensure the timely submission of all future reports. Views of Responsible Officials ? As noted in Finding 2020-00 the COVID-19 pandemic impacted A Safe Place with unforeseen and extenuating circumstances, never experienced in our history. The circumstances and effects of the COVID-19 crisis caused an unprecedented increase in activity in our domestic violence client base and their needs, and we have been blessed with several new funding sources to meet the demand. This, of course, meant a large increase in the workload required from those needed in the accounting and finance areas. Many of our executive, accounting, operations, and administrative staff either contracted COVID-19 or were affected by quarantine policies for significant stretches from October 2020 thru January 2021. Several key employees and members of management including our full-time staff accountant, CEO, and other executive team members were unable to work for long periods of time due to COVID-19 and others within the Organization, including the CFO, had to fill in and work on operational activities. This meant that some administrative work, including some financial and performance reports due to grantors, was temporarily put on hold as client services took precedence. Reports were filed as soon as reasonably possible. The nature of the client services could result in lost lives if not addressed timely.