SELF ENHANCEMENT, INC

Requirement: Reports should be reviewed by appropriate management prior to submission. Condition/Context: The semi-annual progress report was not reviewed. Cause: There was no process in place for review of reports. Effect: Amounts and details reported could be inaccurate. Questioned Costs: None Recommendation: Procedures should be put in place to ensure reports are being reviewed prior to submission.

Finding # 2021-001 (repeat of 2020-001) Type: Federal Award ? Significant Deficiency CFDA Number: U.S. Department of Housing and Urban Development 14.267 Continuum of Care Requirement: Case files should be reviewed and eligibility to be approved by supervisory personnel. Condition/Context: Out of a sample of 12 selected for testing, 4 case files were missing supervisory review. Procedures for reviewing eligibility were not in place or carried out. Cause: Case files are maintained in paper copies. Due to the impact of COVID-19, there were challenges completing the case file review. Effect: Participants and costs could be ineligible for the program or case files could be missing required paperwork. Questioned Costs: Unknown Recommendation: Procedures should be put in place to ensure reviews are completed timely. This might include considering moving files to electronic format or further developing the process for monitoring to ensure all reviews are completed. Management?s Response: Improvements have been made in the year ended June 30, 2021, but full compliance was impacted by moving to a remote work environment due the impact of COVID-19. Management will review Self Enhancement, Inc.?s file review policy and update it for work performed in a remote environment.

Finding # 2020-001 (repeat of 2019-001)Type: Federal Award ? Material weaknessCFDA Number:U.S. Department of Housing and Urban Development14.267 Continuum of CareRequirement:Case files are required to be reviewed and eligibility to be approved by supervisory personnel.Condition/Context:Out of a sample of 14 selected for testing, 5 case files were missing supervisory review. Procedures for reviewing eligibility were not in place or carried out.Cause:Case files are maintained in paper copies. Due to the impact of COVID-19, there were challenges completing the case file review. The Organization should have additional follow up procedures in place to ensure that case files are reviewed.Effect:Participants and costs could be ineligible for the program or case files could be missing required paperwork.Questioned Costs:UnknownRecommendation:Procedures should be put in place to ensure reviews are completed timely. This might include considering moving files to electronic format or further developing the process for monitoring to ensure all reviews are completed.Management?s Response:Improvements has been made in the year ended June 30, 2020, but full compliance was impacted by moving to a remote work environment due the impact of COVID-19. Management will review Self Enhancement, Inc.?s file review policy and update it for work performed in a remote environment.

Finding # 2020-002 (repeat of 2019-002)Type: Federal Award ? Significant Deficiency, Immaterial NoncomplianceCFDA Number:U.S. Department of Housing and Urban Development14.267 Continuum of CareRequirement:The Organization is required to minimize the time elapsing between the transfer of funds from U.S. Treasury and the disbursement of funds for direct program or project costs and the proportionate share of allowable indirect costs.Condition/Context:The Organization held funds in excess of program disbursements related to prior periods.Cause:Draws were based on estimated expenditures; however, actual program costs were incurred at a slower rate than anticipated resulting in excess draw amounts on hand in the previous year.Effect:The Organization could overdraw on the contract funds.Questioned Costs:NoneRecommendation:The Organization should request a fund draw after programmatic disbursements are made to ensure accurate amounts are requested. The Organization has modified the process during the fiscal year and identified funds overdrawn from prior period.Management?s Response:Self Enhancement, Inc. has disbursed the funds held in excess of program disbursements related to prior periods, subsequent to June 30, 2020.

Finding # 2020-003 (repeat of 2019-003)Type: Federal Award ? Material weakness, NoncomplianceCFDA Number:U.S. Department of Housing and Urban Development14.267 Continuum of CareRequirement:The Organization is required to monitor activities of subrecipients in accordance with federal regulations.Condition/Context:The single audit of the subrecipient reported findings under the CFDA contract passed through from the Organization and the Organization did not take actions to resolve the findings with the subrecipients during the fiscal year.Cause:The Organization?s procedures and policies to audit and review the subrecipient?s activities were not adequate to detect and correct activities of noncompliance.Effect:Costs expended through subrecipient awards could be ineligible for the program.Questioned Costs:Approximately $57,000Recommendation:We recommend that supervisors amend subrecipient auditing procedures to ensure a proper system is in place to monitor, detect and take timely follow-up action on any issues identified in site visits and internal or external audits. The Organization might consider a control checklist/sheet and/or set of questionnaires to ensure that all compliance requirements have been considered and documented.Management?s Response:Self Enhancement, Inc. (SEI) has been closely working with the subrecipient to review and resolve findings identified on their last Single Audit and received a draft copy in June 2020 with the final version at the end of September 2020 and are in the process of finalizing the review and response.

Requirement: Case files are required to be reviewed and eligibility to be approved by supervisory personnel. Condition/Context: Out of a sample of 22 selected for testing, 21 case files were missing supervisory review. Procedures for reviewing eligibility were not in place or carried out. Additionally, 2 out of 22 did not have the supervisory approval on intake form denoting eligibility. Cause: The Organization should have additional follow up procedures in place to ensure that case files are reviewed. Effect: Participants and costs could be ineligible for the program or case files could be missing required paperwork. Questioned Costs: Unknown Recommendation: We recommend that staff and supervisors receive periodic education on the process of case file review. Procedures should be put in place to ensure reviews are completed timely. The Organization might consider a control checklist/sheet for the files to include final sign offs for efficient review to ensure that all compliance steps have been completed.

Requirement: The Organization is required to minimize the time elapsing between the transfer of funds from U.S. Treasury and the disbursement of funds for direct program or project costs and the proportionate share of allowable indirect costs. Condition/Context: The Organization drew down funds in excess of program disbursements. Cause: Draws were based on estimated expenditures; however, actual program costs were incurred at a slower rate than anticipated resulting in excess draw amounts on hand. Effect: The Organization could overdraw on the contract funds. Questioned Costs: None Recommendation: The Organization should request a fund draw after programmatic disbursements are made to ensure accurate amounts are requested. We recommend that supervisors generate a tracking report from system software and compare to the drawn down schedule to ensure the accuracy of amounts transferred.

Requirement: The Organization is required to monitor activities of subrecipients in accordance with federal regulations. Condition/Context: The single audit of the subrecipient reported findings under the CFDA contract passed through from the Organization and the Organization did not take actions to resolve the findings with the subrecipients. Cause: The Organization?s procedures and policies to audit and review the subrecipient?s activities were not adequate to detect and correct activities of noncompliance. Effect: Costs expended through subrecipient awards could be ineligible for the program. Questioned Costs: Unknown Recommendation: We recommend that supervisors amend subrecipient auditing procedures to ensure proper system is in place to monitor, detect and take follow-up action on any issues identified in site visits and internal or external audits. The Organization might consider a control checklist/sheet and/or set of questionnaire to ensure that all compliance requirements have been considered.

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