Veterans Bridge Home, Inc.

Criteria: The A-102 Common Rule requires that non-Federal entities receiving federal awards establish and maintain internal control designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Adequate segregation of duties provided between performance, review, and recordkeeping of a task is a control activity which will reasonably ensure compliance with federal laws, regulations, and program requirements. Condition: Documentation of preparer and reviewer could not be readily substantiated for two reimbursement requests selected for testing which is part of the Organization’s controls over allowable costs/activities and cash management. Questioned Costs – None. Context: Review of reimbursement requests are not performed in a consistent manner or consistently documented. Various methods, including emails, Teams chats, and informal verbal communications, are used by the Organization. Evidence was provided for other reimbursement requests being reviewed and approved through various methods. However, for the reimbursement requests selected for testing, documentation of review and approval could not be readily substantiated. Effect: By not maintaining adequate and consistent documentation of review, the Organization may not be able to readily prevent, detect, and correct potential errors in allowable costs/activities and cash management requirements. Therefore, the Organization may be incorrectly reimbursed for expenditures under the program requirements. Cause: Current processes do not include a consistent method of performing, documenting, and maintaining adequate documentation of the review of reimbursement requests.

This was corrected during 2024

2023-002

U.S. Department of Veterans Affairs Staff Sergeant Parker Gordon Fox Suicide Prevention Grant Program Assistance Listing # 64.055 Finding 2023-002 Significant Deficiency – Allowable Costs/Activities and Cash Management Criteria – The A-102 Common Rule requires that non-Federal entities receiving Federal awards establish and maintain internal control designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Adequate segregation of duties provided between performance, review, and recordkeeping of a task is a control activity which will reasonably ensure compliance with Federal laws, regulations, and program requirements. Condition – Documentation of preparer and reviewer could not be readily substantiated for two reimbursement requests selected for testing which is part of the Organization’s controls over allowable costs/activities and cash management. Questioned Costs – None. Context – Review of reimbursement requests are not performed in a consistent manner or consistently documented. Various methods, including emails, Teams chats, and informal verbal communications are used by the Organization. Evidence was provided for other reimbursement requests being reviewed and approved through various methods. However, for the reimbursement requests selected for testing, documentation of review and approval could not be readily substantiated. Effect – By not maintaining adequate and consistent documentation of review, the Organization may not be able to readily prevent, detect, and correct potential errors in allowable costs/activities and cash management requirements. Therefore, the Organization may be incorrectly reimbursed for expenditures under the program requirements. Cause – Current processes do not include a consistent method of performing, documenting, and maintaining adequate documentation of the review of reimbursement requests. Recommendation – The Organization should improve procedures to consistently perform and document review of reimbursement requests, including maintaining adequate documentation of its occurrence. Management’s Response – Management agrees with the finding.

Findings: 1. 2023‐002‐Allowable Costs/Activities and Cash Management: ‐ Documentation of the preparer and reviewer could not be substantiated for two reimbursement requests selected for testing. Corrective Actions: 1. Development of Standardized Review Process: ‐ Create a standardized procedure for reviewing reimbursement requests, ensuring consistency in documentation and approval. 2. Establish Documentation Protocol : ‐ Implement a documentation protocol that requires each reimbursement request to include a record of preparation and review, ensuring the use of consistent communication channels and record‐keeping. ‐ Utilize month‐end checklist to ensure all documentation is complete. 3. Training and Awareness: ‐Conduct training sessions for staff involved in preparing and reviewing reimbursement requests to ensure understanding and compliance with the new procedures. 4. Internal Audit and Monitoring: ‐ Implement a regular monitoring and internal audit process to ensure compliance with the standardized review process and documentation protocol. Management’s Response: Management agrees with the findings and after audit completion, have begun implementing the corrective actions listed above. Timeline: ‐ Immediate (0‐3 months): Create and implement month‐end checklist. ‐ Short‐term (3‐6 months): Conduct initial internal audits. ‐ Ongoing (6‐12 months): Regular reconciliation, review, and monitoring of grant activities and expenses. Responsible Parties: ‐ Chief Administration Officer: Co‐create month‐end checklist and oversee the implementation of corrective actions and ensure compliance. ‐ Compliance Director: Co‐create month‐end checklist and conduct training for staff involved. ‐ Internal Finance & Compliance Teams: Conduct audits and provide feedback on process improvements.