North Shore Community Action Programs, Inc.
August 5, 2011 · Read the full official report (PDF) ↗
source
“Our audit identified that NSCAP has not established adequate internal controls over a number of its administrative activities and the agency’s Board of Directors is not constituted in the manner required by NSCAP’s by-laws, nor is the Board meeting all of its oversight responsibilities.”
Read the plain-English breakdown
This is a Massachusetts State Auditor performance audit of North Shore Community Action Programs, Inc., a nonprofit human services agency on the North Shore, covering July 1, 2007 through December 31, 2009.
“The scope of our audit was to examine the various administrative and operational activities of NSCAP during the period of July 1, 2007 through December 31, 2009.”
Auditors reviewed whether NSCAP had good management controls and whether it followed laws, regulations, contract rules, and fiscal requirements tied to state funding.
“The objectives of our audit were to (1) determine whether NSCAP had implemented effective management controls and (2) assess NSCAP’s business practices and its compliance with applicable laws, rules, and regulations and the various fiscal and programmatic requirements of its state contracts.”
NSCAP received most of its money from state contracts, so weak controls could affect whether public funds were spent properly and documented correctly.
“NSCAP receives the majority of its funding from contracts with state agencies, as indicated in the table below:”
If you are a taxpayer or a person who relies on community services, this audit is about whether money meant for housing, homelessness, education, energy, and other support programs was managed carefully.
“During our audit period, NSCAP operated a variety of programs offering services in housing/homelessness, energy, income maintenance, education and training, and homecare under contracts with the Department of Transitional Assistance (DTA), the Department of Elementary and Secondary Education (DESE), the Massachusetts Rehabilitation Commission (MRC), and the Executive Office of Housing and Economic Development (EOHED).”
The report says NSCAP needed stronger written policies, better documentation, proper cost allocation, better board governance, and controls to prevent unallowable or unsupported charges to state contracts.
“During our audit, we found that NSCAP had not developed and implemented an adequate system of internal control over certain aspects of its operations.”
The auditor recommended that NSCAP fix its policies and controls, document costs properly, use approved cost allocation methods, reimburse certain unallowable costs, and bring its board practices into compliance.
“NSCAP should take measures to ensure that it establishes effective internal controls over all aspects of its operations, including the maintenance of its records; the proper documentation, classification, and recording of its expenses; and performing CORI checks on all staff.”
The findings were significant because the auditor questioned at least hundreds of thousands of dollars in cost allocation, tens of thousands in purchasing and payroll documentation, and whether oversight systems were strong enough to protect public funds.
“During fiscal years 2007 and 2008, we determined that NSCAP used a MAB method to allocate $627,092 of indirect costs to its programs.”
“Indirect costs” means shared expenses that support more than one program, such as general administration, and must be fairly divided across programs instead of charged casually to one place.
“Other expenses are related to more than one program or supporting activity, or to a combination of programs and supporting services.”
10 figure(s) pending source verification - not shown
What the Auditor checked
- Did not comply Did NSCAP implement effective management controls?
- Did not comply Did NSCAP comply with applicable laws, rules, regulations, and fiscal and programmatic requirements of its state contracts?
What the Auditor found
Why it matters: NSCAP and the Commonwealth could not be assured that purchases were fair, equitable, or obtained at the lowest possible cost.
Standard: Section 7 of the General Contract Conditions and 808 CMR 1.03(8). ( Section 7 of the General Contract Conditions, Record-keeping and Retention, Inspection of Records; 808 Code of Massachusetts Regulations 1.03(8) )
1 recommendation
- Develop and implement formal written contract administration and procurement policies approved by the Board and consistent with OSD requirements, and monitor compliance.
Agency response & Auditor reply
Agency: "NSCAP updated its procurement policies… prior to accepting ARRA funds in 2009."
Auditor: "Based on its response, NSCAP is taking measures to address our concerns relative to the implementation of formal written contract administration and procurement policies and procedures to ensure compliance with OSD regulations and the terms and conditions of its state contracts."
Why it matters: Unsupported expenses were unallowable and could have been charged to the wrong program.
Standard: Commonwealth Terms and Conditions for Human and Social Services, 808 CMR 1.04(1), and 808 CMR 1.05(26). ( 808 CMR 1.04(1); 808 CMR 1.05(26) )
1 recommendation
- Ensure staff time and expenses are properly recorded and charged to the correct cost center, and monitor controls over documentation and classification.
Agency response & Auditor reply
Agency: "The fact that the actual time sheet did not support the services that these employees were providing to the Scattered Sites contract does not negate the fact that they were providing those services."
Auditor: "Without such documentation, the expenses in question are clearly unallowable under SSFES’s state contracts in accordance with 808 CMR 1.05 (26)."
Why it matters: There was inadequate assurance that program activity results reported to the Commonwealth were accurate.
Standard: OSD cost allocation guidelines, 808 CMR 1.02, and the UFR Audit & Preparation Manual. ( 808 CMR 1.02; UFR Audit & Preparation Manual )
1 recommendation
- Resubmit fiscal years 2007 and 2008 UFRs using an acceptable cost allocation method and develop a formal indirect cost allocation plan.
Agency response & Auditor reply
Agency: "Management realizes that because of the manner in which we reported our services on the UFR, that we created a fractured view of our major functional areas."
Auditor: "In its response, NSCAP acknowledges the fact that it did not correctly report the indirect costs in question and as a result provided the Commonwealth with a “fractured view” of its major functional areas."
Why it matters: State contracts were charged for unallowable fringe benefits, and taxable compensation was not reported to taxing agencies.
Standard: 808 CMR 1.05(9), IRS requirements, and Massachusetts Department of Revenue regulations. ( 808 CMR 1.05(9); Section 713 of the U.S. Master Tax Guide )
2 recommendations
- Reimburse the Commonwealth for the non-reimbursable fringe benefits and ensure such benefits are not charged to state contracts.agency: agreed
- Account for and safeguard the tools purchased with NSCAP funds.agency: already implemented
Agency response & Auditor reply
Agency: "In response to this issue, NSCAP agreed to reimburse the Commonwealth for the $5,200 in non-reimbursable fringe benefits in question we identified during our audit."
Auditor: "We believe that the actions taken by NSCAP regarding the tools in question and its decision to discontinue paying a stipend to the agency’s Maintenance Coordinator for the use of his personal truck for work were necessary and appropriate."
Why it matters: NSCAP could not ensure adequate representation of its target groups or that agency objectives were met economically and efficiently.
Standard: Chapter 180, Section 6A of the Massachusetts General Laws; Condition 11 of the Contract Conditions; NSCAP corporate by-laws Article IV. ( Section 6A of Chapter 180 of the Massachusetts General Laws; Condition 11 of the Contract Conditions; NSCAP corporate by-laws, Article IV, Board of Directors )
1 recommendation
- Ensure board composition and activities comply with by-laws, contract conditions, state regulations, and Attorney General guidelines.
Agency response & Auditor reply
Agency: "It is an ongoing challenge to fulfill the difficult requirements of tri-partite board membership."
Auditor: "While we acknowledge that assembling and sustaining a tri-partite Board membership of 18 members is challenging, by not maintaining its Board membership in accordance with its own corporate by-laws and state regulations, NSCAP cannot ensure that the interests of all of its designated target populations are receiving the necessary representation."
Why it matters: NSCAP improperly charged unallowable bad debt and did not ensure required background checks were completed for some staff.
Standard: GAAP, 808 CMR 1.05(6), and 106 CMR 150.170. ( 808 CMR 1.05(6); 106 CMR 150.170 )
1 recommendation
- Establish effective internal controls over records, expense documentation and classification, and CORI checks for all staff.agency: partially agreed
Agency response & Auditor reply
Agency: "NSCAP management agrees that bad debt is not an allowable expense."
Auditor: "We do not agree with NSCAP that the fact that it charged bad debt expenses incurred by its related party against its state contracts is not an internal control issue."
Verified dollar findings
Money paid out that the audit found should not have been - overpayments, unallowable and nonreimbursable charges, improper claims.
Identified dollar findings that do not fall in a named band.
More audits of this entity
Other Office of the State Auditor reports on North Shore Community Action Programs, Inc. .
- North Shore Community Action Programs, Inc.Nonprofit / Vendor · October 9, 2015