CLC, INC.Non-Profit

2020-001 Criteria: The grant agreement allows for up to 25% of project participants to be enrolled under alternate eligibility requirements. Condition and context: Of a total of 85 enrollees in the project, 26 were enrolled under the alternate requirements, resulting in an over-enrollment under the alternate requirements of 5 students. Total incentives and stipends of $5,693 were paid to overenrolled students participating in the project. The remaining costs of providing services to these students were paid for using non-federal sources. Questioned Costs: $5,693 in total stipends and incentives were paid to overenrolled participants Cause: Oversight during review of total eligible participants in the program. Management carefully reviews each enrollee for eligibility, including under alternate provisions, but did not realize that the alternate enrollment criteria had exceeded 25% of the population during program operation. Effect: Over-enrollment resulted in individuals being served under the program which were not scoped into the program and payment of stipends which were potential unallowable. Recommendation: Recommend that management add a tracking mechanism to indicate this additional eligibility provision to its monitoring of eligible enrollees to ensure that the program is not over-enrolled based on alternate criteria. Recommend that this criteria be revisited with each additional potential enrollee to the project that is added. View of Responsible Officials: Management is in agreement. Management Reponses and corrective action planned: Management will work to develop a tracking mechanism to ensure that enrollees under the alternate eligibility requirements do not exceed 25% in the program going forward.