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The Institute for Developmental Disabilities, Inc.

NOVEMBER 19, 2012 · Institute for Developmental Disabilities, Inc. · Read the full official report (PDF) ↗

Published NOVEMBER 19, 2012 Audit covers July 1, 2009 – June 30, 2011 Under Suzanne M. Bump · 2011–2023

In plain English
Auditors found that IDDI, now called Crystal Springs Inc., misused or improperly charged state-funded contracts in several ways, including related-party purchases, LUSA funding, fringe benefits, rental income, employee compensation, and fundraising costs.
source
“IDDI charged unallowable fundraising costs totaling $9,335 against its state contracts.”
Read the plain-English breakdown
What is this?

This is a Massachusetts State Auditor report reviewing IDDI, a nonprofit that served children and adults with severe disabilities, for the period July 1, 2009 through June 30, 2011.

“The scope of our audit was to examine various administrative and operational activities of the Institute for Developmental Disabilities, Inc. (IDDI) during the audit period July 1, 2009 through June 30, 2011; however, in some instances it was necessary for us to extend the period covered by our audit in order to adequately examine certain transactions that were selected for testing during our review.”
Why was it audited?

The audit checked whether IDDI followed laws, regulations, contract rules, and good controls for areas such as payroll, benefits, contracts, vehicles, related-party dealings, and fundraising.

“An assessment of IDDI’s business practices and its compliance with applicable laws, rules, and regulations, as well as the various fiscal and programmatic requirements of its state contracts.”
Why it matters

The report matters because IDDI received substantial public funding and the audit found state money was charged for costs the auditors considered unallowable, unnecessary, or improperly handled.

“Consequently, because the $90,922 in LUSA funding was not used for its intended purpose, these payments to IDDI were unnecessary, unallowable, and inappropriate.”
What's in it for me?

For an ordinary taxpayer, the issue is whether public money meant to support services for people with developmental disabilities was spent and tracked properly.

“According to DDS’s policies, the funding provided under these contracts is to be used by contracted service providers such as IDDI to purchase unanticipated, intermittent, and as-needed services for developmentally disabled individuals.”
The bottom line

The auditor said IDDI should repay several amounts to the Commonwealth and tighten how it buys services, records income, handles benefits, and reports fundraising costs.

“IDDI should remit the $9,335 in unallowable fundraising expenses it charged to its state contracts and ensure that any future fundraising expenses are properly identified and reported.”
What happens next

The report recommends that IDDI work with state agencies, repay identified improper charges, and change its procedures so future spending follows state rules.

“IDDI should consult with OSD and DDS to resolve the unallowable capital purchases paid for with LUSA funds.”
Why it's significant

The audit found multiple control problems, including weak competitive bidding, missing written agreements, unallowable charges, and poor cost allocation, all involving state-funded contracts for services to vulnerable residents.

“Rather, our audit provides findings and conclusions on the extent of IDDI’s compliance with applicable laws, regulations, and contractual agreements, and identifies operational and administrative processes, methods, and internal controls that could be made more efficient and effective.”
Jargon, unpacked

A LUSA is a limited-use agreement meant for unexpected, short-term, as-needed services, not for routine capital purchases like vans, air conditioning, or flooring.

“The purpose of LUSAs is to allow providers the opportunity to place on file with DDS a contract that can be accessed at any time during its life when an unexpected or limited time service is agreed upon by both the provider and DDS.”
Identified in this audit - source-verified
$100,257

6 figure(s) pending source verification - not shown

What the Auditor checked

What the Auditor found

IDDI bought $359,573 in equipment and services from a related-party organization without full competitive procurement or written agreements.
procurement/contractsinternal controlsvendor oversight

Why it matters: IDDI could not ensure that it obtained the highest-quality services for the lowest price and lacked protection against contractor performance or legal issues.

Standard: 808 CMR 1.03(8) and OSD related-party requirements ( 808 CMR 1.02; 808 CMR 1.03(8) )

1 recommendation
  • IDDI should comply with OSD regulations relative to the competitive procurement of goods and services and ensure that it enters into formal written contracts with all of its contractors.
Agency response & Auditor reply
Agency: "The Organization did bid certain major projects with Thermo Mechanical Systems Corporation (Thermo Mechanical)."
Auditor: "However, this hardly constitutes a competitive bid process, and we do not agree that it provides sufficient evidence that Thermo Mechanical’s prices are competitive."
IDDI used $90,922 in LUSA funds for capital purchases instead of limited-use services.
grants managementinternal controls

Why it matters: The LUSA payments were unnecessary, unallowable, and inappropriate because they were not used for their intended purpose.

Standard: DDS Purchase of Service Manual and DDS Authorization for Services requirements for LUSA funding ( DDS Purchase of Service Manual )

2 recommendations
  • IDDI should consult with OSD and DDS to resolve the unallowable capital purchases paid for with LUSA funds.agency: disagreed
  • IDDI should ensure that any LUSA funding received in the future is expended in accordance with LUSA contract regulations.agency: disagreed
Agency response & Auditor reply
Agency: "The Organization acted in good faith in executing the contract."
Auditor: "Although IDDI did not initiate this transaction, IDDI is responsible for being aware of and adhering to all state regulations, including those relating to the purchasing of capital items and the use of LUSA funding."
IDDI provided $23,839 in unallowable fringe benefits through vehicle expenses and employee loans.
payroll/timeinternal controls

Why it matters: The benefits were nonreimbursable because they were not available to all employees under an established agency policy.

Standard: 808 CMR 1.05(9) ( 808 CMR 1.05(9) )

2 recommendations
  • IDDI should ensure that it does not use state funds to provide loans to staff members.agency: already implemented
  • IDDI should remit to the Commonwealth the $11,739 in unallowable vehicle expenses and ensure it does not charge unallowable vehicle expenses against state contracts.
Agency response & Auditor reply
Agency: "These amounts [loans] were never charged to an expense, as they were reported as an asset in the Organization’s financial statements and thus were not funded with state funds."
Auditor: "However, these loans were funded by IDDI’s general operating account, which did contain state funds."
IDDI did not use $13,200 in rental income to offset state costs for its Adult Residential Program.
recordkeeping/documentationinternal controls

Why it matters: IDDI received $13,200 in excess funding from the Commonwealth.

Standard: 808 CMR 1.02 offsetting revenue requirements ( 808 CMR 1.02 )

2 recommendations
  • IDDI should remit to the Commonwealth the $13,200 that it overbilled by failing to report the rental income received from its former Executive Director as revenue to its Adult Residential Program.agency: disagreed
  • IDDI should ensure that all program income is accurately recorded and properly reported in accordance with state regulations.agency: disagreed
Agency response & Auditor reply
Agency: "The Organization had historically classified the revenue associated with the rental as administrative revenue because such revenue is non-program related."
Auditor: "Contrary to state regulations, IDDI reported the rental income from its former Executive Director as “other revenue” rather than program revenue that was available to offset the state’s cost of operating IDDI’s Adult Residential Program."
IDDI charged $38,792 in unnecessary compensation for positions that appeared unnecessary.
payroll/timeinternal controls

Why it matters: The Commonwealth paid for compensation that was unnecessary and therefore nonreimbursable under state contracts.

Standard: 808 CMR 1.05, 808 CMR 1.02, and OMB Circular A-122 reasonable cost standards ( 808 CMR 1.05; 808 CMR 1.02; OMB Circular A-122 )

2 recommendations
  • IDDI should remit to the Commonwealth the $38,792 in unnecessary compensation it provided to the individual in question.agency: no response
  • IDDI should ensure it does not charge unnecessary expenses against state contracts in the future.agency: no response
Agency response & Auditor reply
Agency: "IDDI chose not to respond to this issue."
IDDI charged $9,335 in fundraising expenses to state contracts.
internal controlsrecordkeeping/documentation

Why it matters: The Commonwealth reimbursed expenses that state regulations prohibit from being charged to state contracts.

Standard: 808 CMR 1.05(10) ( 808 CMR 1.05(10) )

2 recommendations
  • IDDI should remit $9,335 to the Commonwealth for the inappropriate fundraising expenses charged to its state-funded contracts during fiscal year 2010.agency: agreed
  • IDDI should implement policies and procedures to ensure that all future fundraising expenses are properly and accurately identified and reported in accordance with state contracts.agency: agreed
Agency response & Auditor reply
Agency: "Based upon review of support provided by the state auditor, the amount indicated appears reasonable."

Verified dollar findings

Improper payments identified $100,257

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

$90,922 - unallowable contract billings
$9,335 - unallowable fundraising expenses