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Lutheran Community Services, Inc.

June 18, 2014 · Read the full official report (PDF) ↗

Published June 18, 2014 Audit covers July 1, 2011 – June 30, 2012 Under Suzanne M. Bump · 2011–2023

In plain English
Auditors found that Lutheran Community Services charged state-related programs for some costs it could not properly document, including payroll and travel, and that some reported program results were not backed up well enough.
source
“Summary of Findings”
Read the plain-English breakdown
What is this?

This is a Massachusetts State Auditor performance audit of Lutheran Community Services, Inc., a Worcester nonprofit that provided human and social services, including refugee and adoption services.

“LCS provides various human and social services, including refugee services and adoption services.”
Why was it audited?

The auditor reviewed whether selected costs charged to Massachusetts contracts were allowed and properly tied to those contracts, whether refugee-program goals were met, and whether related-party transactions were proper.

“The objectives of our audit were to (1) determine whether certain LCS expenses charged to Massachusetts contracts were reasonable, allowable, and allocable to these contracts in accordance with regulations promulgated by the state’s Operational Services Division (OSD); (2) determine whether LCS achieved all of the performance-goal standards stipulated in its contract with the Massachusetts Office for Refugees and Immigrants (MORI); and (3) analyze selected transactions conducted between LCS and a related party, LSS, to determine whether they were reasonable, allowable, and allocable to LCS’s state contracts.”
Why it matters

Public money may have paid for costs that lacked required proof or were not allowed, and state agencies may have received unreliable information about program performance.

“As a result, LCS cannot support the reported performance results, and state oversight agencies may be relying on incorrect information.”
What's in it for me?

For an ordinary taxpayer, the issue is whether state contract money was spent only on documented, allowable services and whether agencies had accurate information to oversee those services.

“Therefore, LCS overcharged its state contracts by as much as $5,279 for these expenses, and OSD should recover all state funds that were used to pay for these unallowable charges.”
The bottom line

The audit found unsupported payroll costs, unallowable travel costs, and weak documentation for refugee-program performance reporting.

“We assessed these relevant controls and identified deficiencies related to the first three items as discussed in the Detailed Audit Results and Findings section of this report.”
What happens next

The report says the state should recover unsupported or unallowable costs, and LCS should improve documentation, approval, travel, and case-file procedures.

“OSD should recover the $5,701 we identified as unsupported costs against its MORI contracts.”
Why it's significant

The dollar amounts in the findings were relatively small compared with total program revenue, but the audit points to oversight weaknesses that affect accountability for state-funded services.

“Below is a summary of LCS’s revenue for the fiscal year ended June 30, 2012.”
Jargon, unpacked

“Nonreimbursable” means the state should not pay back or cover a cost if the organization cannot properly prove it or if it is not related to the program.

“According to OSD regulation 808 Code of Massachusetts Regulations (CMR) 1.05(26), undocumented costs are nonreimbursable program costs, as follows:”
Identified in this audit - source-verified
$10,980

1 figure(s) pending source verification - not shown

What the Auditor checked

What the Auditor found

LCS lacked payroll documentation and overcharged MORI contracts by $5,701.
payroll/timerecordkeeping/documentationinternal controls

Why it matters: Unsupported payroll costs were nonreimbursable and represented overcharges to state contracts that should be recovered.

Standard: 808 Code of Massachusetts Regulations 1.05(26), undocumented expenses are nonreimbursable program costs. ( 808 Code of Massachusetts Regulations 1.05(26) )

2 recommendations
  • OSD should recover the $5,701 identified as unsupported costs against MORI contracts.
  • LCS should ensure pay increases are properly authorized and documented in each employee’s file.agency: already implemented
Agency response & Auditor reply
Agency: "All pay rate adjustments require the approval of both a member of the Human Resource team as well as an Operational Vice President (or member of Executive Management) before it is entered into the Human Resource System."
LCS allocated undocumented and non-program-related CEO travel expenses to its programs.
recordkeeping/documentationinternal controls

Why it matters: State contracts may have been overcharged for unallowable travel expenses.

Standard: 808 CMR 1.05(26) and 808 CMR 1.05(12), which make undocumented and non-program-related costs nonreimbursable. ( 808 CMR 1.05(26); 808 CMR 1.05(12) )

2 recommendations
  • OSD should determine how much of the $5,279 of unallowable travel costs billed against state contracts should be recovered and recoup those funds.
  • LCS should strengthen internal controls to ensure travel expenses charged to state contracts are appropriately documented.agency: already implemented
Agency response & Auditor reply
Agency: "Immediately upon review of this policy by the new CEO, new procedures regarding travel were instituted by the Organization requiring all travel be pre-approved based upon purpose and estimated expense by an immediate supervisor."
LCS did not adequately document required MORI program performance reporting.
recordkeeping/documentationinternal controlsreporting timeliness

Why it matters: LCS could not support reported performance results, and state oversight agencies may rely on incorrect information.

Standard: MORI contract performance goals and LCS policies requiring reported information to be supported by case file information. ( MORI contract performance goals )

2 recommendations
  • LCS should continue its planned procurement of a more modern case file management system.agency: agreed
  • LCS should document information required by MORI contracts and conduct additional case-worker training if necessary.agency: agreed
Agency response & Auditor reply
Agency: "Management agrees with the State’s recommendation that it should consider the procurement of a more modernized case management system."

Verified dollar findings

Improper payments identified $10,980

Money paid out that the audit found should not have been - overpayments, unallowable and nonreimbursable charges, improper claims.

$5,701 - unsupported payroll overcharges
$5,279 - unallowable travel costs