SOUTH BREVARD WOMEN'S CENTER, INC.Non-Profit

SD 2020-002: ELIGIBILITY CFDA 16.575 Crime Victim Assistance 2019 Funding U.S. Department of Justice Passed through the State of Florida, Department of Legal Affairs, Office of the Attorney General Criteria: Per 2 CFR 200.303, non-Federal entities must establish and maintain effective internal controls to provide reasonable assurance of compliance with the Uniform Guidance. Additionally, under 28 CFR 94.103, recipients of benefits under VOCA must be determined to be a victim of crime. Condition: Counseling service needs assessment forms to determine compliance with eligibility requirements were not consistently reviewed. However, the Center implemented a new control in April 2020 better documenting their review of eligibility requirements. No exceptions were noted after the implementation of this control. Perspective: The control was not consistently implemented for several participants evaluated prior to April 2020. None of the participants selected for testing were ineligible. Cause: Under the old process, documentation of the counselor?s review of eligibility requirements did not consistently match the same cause of victimization as the needs assessment form. Effect: Services could be provided under VOCA to ineligible participants. Questioned Costs: None. Recommendation: CRI recommends the Center continue with the new intake review process implemented in April 2020. Management Response: Eligibility determination prepared by the counselors will continue to be reviewed by the Director of Counseling to ensure compliance with grant requirements as implemented in April 2020.

CFDA 16.575 Crime Victim Assistance 2019 Funding U.S. Department of Justice Passed through the State of Florida, Department of Legal Affairs, Office of the Attorney General Criteria: Per 2 CFR 200.303, non-Federal entities must establish and maintain effective internal controls to provide reasonable assurance of compliance with the Uniform Guidance. Condition: Reimbursement requests submitted to the pass-through agency contained costs that were not reimbursed by the pass-through agency as the request contained unallowable costs. Perspective: Nine out of the twelve reimbursement requests contained costs that were not reimbursed by the pass-through agency. Cause: A more detailed review of the FICA calculations and comparing the reimbursement requests to the budget were not being completed.Effect: Unallowable costs, which included incorrect calculations of FICA and amount over the maximum allowed the category, were included in reimbursement requests and later corrected and resubmitted. Questioned Costs: None. Recommendation: Supporting documentation should be reviewed along with the grant draw down request to minimize the amount of disallowed costs from the pass through grantor. Management Response: Unallowable costs not reimbursed by pass through agency totaled $838, or 0.09% of the contract. Costs included FICA miscalculations due to differing decimal points used between organization and pass through agency. Exact decimal placement used by grantor will be used for all future calculations. All supporting documentation for each monthly submission will be reviewed by the Finance and Operations Assistant or designee and the Director of Grants Administration along with the grant draw down request to minimize the amount of disallowed costs from the pass through grantor

CFDA 16.575 Crime Victim Assistance 2018 Funding U.S. Department of Justice Passed through the State of Florida, Department of Legal Affairs, Office of the Attorney General Criteria: Per 2 CFR 200.303, non-Federal entities must establish and maintain effective internal controls to provide reasonable assurance of compliance with the Uniform Guidance. Additionally, under 28 CFR 94.103, recipients of benefits under VOCA must be determined to be a victim of crime. Condition: Counseling service needs assessment forms to determine compliance with eligibility requirements were not consistently reviewed. Perspective: The control was not consistently implemented. Cause: Documentation of the counselor?s review of eligibility requirements did not consistently match the same cause of victimization as the needs assessment form. Effect: Services could be provided under VOCA to ineligible participants. Questioned Costs: None. Recommendation: New victim demographics forms filled out by the counselors need to match the needs assessment forms filled out by participants if the new victim demographic forms are going to be used as evidence of review of eligibility documentation.Management Response: Eligibility determination prepared by the counselors will be reviewed by the Director of Counseling to ensure compliance with grant requirements.

CFDA 16.575 Crime Victim Assistance 2018 Funding U.S. Department of Justice Passed through the State of Florida, Department of Legal Affairs, Office of the Attorney General Criteria: Per 2 CFR 200.303, non-Federal entities must establish and maintain effective internal controls to provide reasonable assurance of compliance with the Uniform Guidance. The VOCA grant agreement between the State of Florida Office of the Attorney General and the Center requires a 20% in cash or in-kind contributions. Condition: Time sheets for in-kind services submitted for match were not logged in sufficient detail to determine if work was performed in direct service to victims of crime. Perspective: Seven out of the sixty time entries submitted for match as in-kind services, work performed was not described as being in direct service to victims of crime. There was sufficient detail for matching during the second half of the year to determine services were performed in direct service to victims of crime. Cause: Documentation to meet matching requirements is not consistently reviewed in a timely manner. Effect: The Center was not in compliance with the Uniform Guidance. Questioned Costs: $327 of known questioned costs. Recommendation: Timesheets and logs submitted for match should be reviewed by an independent person for compliance with grant requirements. Management Response: Total amount not allowed by pass through agency was $97.59, or 0.04% of match requirement. Approved Match submitted was in excess of contractual requirement. Volunteer Log sheets will be reviewed by Volunteer and Outreach Coordinator to ensure compliance with grant requirements prior to being given to Director of Grants Administration for submission to pass through agency.

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