S. D EPARTMENT OF E DUCATION Finding Number FA 11-031

CFDA Number 84.126 and 84.390 (Includes Recovery Act Funding) Program Title Vocational Rehabilitation Cluster (VR)

Compliance Requirement Eligibility

State Agency Florida Department of Education (FDOE) Federal Grant/Contract

Number and Grant Year Various

Finding Type Opinion Qualification and Material Noncompliance

Finding FDOE did not always ensure that eligibility determinations were made within the time frame required by Program regulations.

Criteria 34 CFR 361.41(b)(1), Processing Referrals and Applications

Condition An eligibility determination must be made within 60 days after an individual submits an application for vocational rehabilitation services. However, if exceptional and unforeseen circumstances beyond the control of FDOE preclude making an eligibility determination within 60 days, then the individual and FDOE can agree to a specific extension of time.

Our examination of 40 case records disclosed 11 instances in which the determinations were made after the required 60 days or the agreed-to extension of time. The determinations were made from 1 to 75 days after the required date. Eight of the 11 instances resulted in determinations of eligibility and 3 resulted in determinations of ineligibility.

Cause The determinations were made by staff in several districts. FDOE management indicated that increased counselor caseloads may have also contributed to the delays.

Effect Untimely eligibility determinations delay the start of services for eligible individuals and may delay ineligible individuals in seeking other services.

Recommendation We recommend that FDOE management emphasize to its counselors the importance of timely completing eligibility determinations.

State Agency Response and Corrective Action Plan

FDOE/DVR continues to address adherence to prescribed procedures and federal program regulations in Supervisor’s Training and New Counselor Training, through communications with Area staff, and at the time of counselor reviews.

FDOE/DBS will continue utilizing its eligibility checklist to monitor and address eligibility timeliness among field staff. This tool was implemented July 2010, and is administered monthly by Field Management staff and reported to Headquarters with necessary action plans. FDOE/DBS is pleased with the impact that this tool has made since its implementation and is very confident that this tool will continue to further reduce non-compliance of eligibility timeliness.

Estimated Corrective Action Date

Ongoing

Agency Contact and Telephone Number

Martha K. Asbury, Assistant Deputy Commissioner, Finance and Operations (850) 245-0420

CFDA Number 84.394 and 84.397 (Includes Recovery Act Funding) Program Title State Fiscal Stabilization Fund (SFSF) Cluster

Government Services, Recovery Act

Compliance Requirement Activities Allowed or Unallowed and Allowable Costs/Cost Principles State Educational Entity Florida A&M University (FAMU)

Administering State Agency Florida Department of Education (FDOE) Federal Grant/Contract

Number and Grant Year 376-5921S-1CZ06, July 1, 2010 – June 30, 2011 Finding Type Noncompliance and Significant Deficiency

Questioned Costs – $867,203

Finding The institution provided $180,000 of funds to a not-for-profit organization for purposes that do not appear to be allowable grant charges. Also, institution records did not evidence that $20,000 of funds provided to the same not-for-profit organization, and $667,203 provided to another not-for-profit organization, were used for allowable grant purposes. Additionally, required reports submitted by one of the not-for-profit organizations were not sufficiently detailed as to the use of the funds.

Criteria United States Department of Education’s publication Guidance on the State Fiscal Stabilization Fund Program April 2009), Section III-E-3, provides that funds may be used for student financial aid, such as IHE-sponsored grants and scholarships and student services that promote a student’s emotional and physical well-being outside the context of the formal instructional program.

Condition During the 2010-11 fiscal year, the institution paid a total of $867,203 of grant funds to two not-for-profit organizations to provide scholarships and other mentoring and recruiting services for middle and high school students. We noted the following instances of unallowable or inadequately documented charges:

 $200,000 was used for students attending a minority golf association program, of which $180,000 was used to repair a city golf course. Funds were paid directly to the organization with the intent of assisting in the institution’s recruitment program. The organization awarded scholarships at its discretion without any review or input from institution personnel and institution records did not evidence review by institution personnel to determine that funds spent were used for allowable grant purposes. Further, the $180,000 of golf course repairs does not appear to be allowable costs under either the grant requirements or the contract with the golf association.

 $667,203 of grant funds were paid to another not-for-profit organization for a program intended to provide personal development to teenagers and minority groups. Funds were paid directly to the organization with the intent of assisting in the institution’s recruitment program. The organization awarded scholarships at its discretion without any review or input from institution personnel and institution records did not evidence review by institution personnel to determine that funds spent were used for allowable grant purposes. Additionally, three quarterly reports submitted by the not-for-profit organization to the institution regarding use of funds did not provide sufficient information as to what the funds were spent for or what results had been attained through the program for the students served, nor did institution records evidence that institution personnel reviewed and assessed the adequacy of the reports.

Cause The institution’s procedures were not adequate to ensure that funds provided to the not-for-profit organizations were used for allowable grant purposes.

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Effect When unallowable costs are charged to the program, the institution may be required to return disallowed costs.

Recommendation The institution should enhance its procedures to ensure that grant funds are used for allowable purposes. Such procedures should require documented oversight by institution personnel, including a review to assess the adequacy of required reports. In addition, the institution should document the allowability of amounts charged to the grants and consult with the grantor agency as to the resolution of the questioned costs.

FAMU Response and Corrective Action Plan

The University entered into an agreement with the Orlando Minority Youth Association (OMYGA), a non-profit organization. The basic objective of this association was to introduce the city at-risk youth to the sport of golf, which in turn, would assist in developing their social and life skills. The program also included an educational/study component to prepare students to grow in almost every aspect of life. It is the University’s understanding that the golf course is only used by this association.

$667,203 of grant funds (discretionary) was for a partial funding of an agreement with the Professional Opportunity Program for Students. In this agreement, it was stipulated that funds were to be used for scholarships.

Per the agreement with the Professional Opportunity Program for Students,

$667,203 of grant funds (discretionary) was stipulated for scholarships which was a part of the $700,000 scholarship budget. The University agrees to strengthen its procedures to ensure the proper monitoring of all contractor agreements.

Estimated Corrective Action Date

June 30, 2012

FAMU Contact and Telephone Number

Teresa Hardee, Chief Financial Officer and

Vice President for Administrative and Financial Services (850) 599-3211

CFDA Number Various (See Finding) (Includes Recovery Act Funding) Program Title Various (See Finding)

Compliance Requirement Activities Allowed or Unallowed; Allowable Costs/Cost Principles; Eligibility;

Matching, Level of Effort, Earmarking; Reporting; Procurement and Suspension and Debarment; and Special Tests and Provisions

State Agency Northwood Shared Resource Center (NSRC) Federal Grant/Contract

Number and Grant Year Various

Finding Type Significant Deficiency

Finding NSRC was established as a primary data center to serve as an information system utility for customer entities. In audit report No. 2011-082, dated January 2011, we disclosed in finding Nos. 1, 4, 6, and 7 deficiencies related to billing rates, lack of written policies and procedures for some functions, user identification codes, and password and logon controls, respectively, each of which we consider to be significant deficiencies. Details of the findings and recommendations, as well as NSRC management’s response are included in that report.

NSRC provides services for various systems, including the Florida On-line Recipient Integrated Data Access (FLORIDA), Grants and other Revenue Allocation and Tracking (GRANT) System, Information Delivery System (IDS), Personnel Management Data System (PMDS), and Florida Safe Families Network (FSFN), managed by the Florida Department of Children and Family Services, and the Health Grants System managed by the Florida Department of Health.

The above systems are used in administering aspects of the following major programs:

Programs that include Recovery Act Funding:

10.551 and 10.561 – Supplemental Nutrition Assistance Program Cluster

93.558, 93.714, and 93.716 – TANF (Temporary Assistance for Needy Families) Cluster 93.563 – Child Support Enforcement

93.720, 93.775, 93.776, 93.777, and 93.778 – Medicaid Cluster Programs that do not include Recovery Act Funding:

10.558 – Child and Adult Care Food Program

93.566 – Refugee and Entrant Assistance – State Administered Programs 93.667 – Social Services Block Grant

93.917 – HIV Care Formula Grants

93.959 – Block Grants for Prevention and Treatment of Substance Abuse

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